Summary of Hot Spots of Cosmetic Raw Materials Compliance Symposium
On April 27th, 2021, NAR Consulting successfully held a special webinar on the compliance of cosmetic raw materials and new raw materials in order to further publicize the latest policies on the submission of safety and quality information of cosmetic raw materials and the registration of new cosmetic raw materials.
The teacher gave a detailed introduction to the compliance of cosmetic raw materials and new raw materials from the aspects of supervision situation of cosmetic raw materials in China, management mode of cosmetic raw materials under regulations, and detailed explanation of registration and filing of new cosmetic raw materials.
We listed some of the answers to the questions in the seminar:
Q1: Can foreign manufacturers submit the quality and safety information of cosmetic raw materials? If domestic products are sold to foreign customers, do you still need to submit relevant information of foreign customers? Do you only need to submit the next-level customer information, or do you need to submit the whole sales chain customer information?
A: Foreign manufacturers cannot submit raw material quality and safety information by themselves, but must entrust a domestic submitter to do so.
The quality and safety information of raw materials is submitted to serve domestic cosmetics, so only the finished cosmetics using this raw material should be registered and filed in China. If this raw material is sold abroad to be used as cosmetic raw material, and the cosmetics produced are not required to be registered in China, they are not required to be submitted.
The raw material quality and safety information submitted is the raw material quality and safety information of this company, and does not involve the requirements of relevant information of raw material supply chain.
Q2: If the quality and safety information of cosmetic raw materials is not submitted within the stipulated time, what are the penalties?
A: The submission of quality and safety information of cosmetic raw materials can be provided by the raw material manufacturer or the cosmetics enterprise using this raw material during product registration and filing. If the previous manufacturer fails to submit it, there will be no submission code. If the finished product registration cannot be associated with relevant information through the submission code, the finished product registration and filing must be filled in.
If it is not filled in, the registration of the whole finished product cannot be carried out.
Q3: What are the specific requirements for notarization of power of attorney? The system has not been opened yet. What regulations are implemented at present?
A: According to the information communicated at the training meeting of the Institute of Advanced Studies of the Food and Drug Administration on April 22-23, the authorization letter for submitting the quality and safety information of cosmetic raw materials does not need to be notarized.
The system is not open. At present, the quality and safety information of raw materials can only be filled in when cosmetics products are registered.
Q4: If the ingredient list of cosmetic raw materials contains residues that are not functional ingredients, such as 1% glucose and 2% solvent residues, if all ingredients are marked, the label will be very long if impurities are included. Can you not mark them on the cosmetic label?
A: According to the standard requirements of the cosmetic label ingredient list, these need to be marked; However, it can be compared with "List of All Ingredients-Labeling Exemptions".
The total composition table-marked exemptions are divided into the following five points:
1. Appropriate amount of preservatives, antioxidants and other ingredients added to protect raw materials. Because the amount of raw materials added is limited or relatively small, the content of preservatives, antioxidants and other ingredients brought in by raw materials in the final cosmetics is far less than the limit requirements of cosmetics hygiene standards, so it can be exempted from labeling;
2. Trace impurities mixed in raw materials. Under the current technical conditions, these trace impurities inevitably exist in raw materials, and the existence of these trace impurities does not affect the safety evaluation and use of the raw materials:
3. Trace unreacted materials or reaction by-products existing in the reaction products:
4. Processing AIDS intentionally added in the production process but not present in the final product:
5. Non-woven fabrics as carriers of facial masks and other products are not counted as cosmetic ingredients.
Q5: Regarding banned plants, if I am not sure whether a certain plant can be used, is there any organization that can inquire?
A: The substances in the list of banned plants must not be used; Plant raw materials in the catalogue of used cosmetic raw materials can be used. If you are not sure whether they belong to them, you can find a consulting agency or an industry expert to judge, but there should be no special agency to issue a report format conclusion at present; If the used cosmetic raw materials are not included in the final confirmation, it is necessary to register new raw materials.
Q6: Cosmetic raw materials do not have a production license, so the distributor may fill in according to the manufacturer. If the raw material information reporting system is enabled, how to distinguish the manufacturer from the distributor?
A: The submission of cosmetic raw materials should be carried out by the manufacturer or the submitter authorized by the manufacturer, and the submission code can only be obtained after the raw materials are submitted.
Q7: There is no need to notarize the delivery of raw materials and the registration and filing of new raw materials. Is this true?
A: The power of attorney for submitting raw material quality and safety information does not need to be notarized.
If the new raw materials are registered and filed outside the country, the domestic responsible person shall be authorized to do so, and the power of attorney shall be notarized.
If you are interested in the training content, please contact us for information or video content. The contact information is shown below. Thank you.
Contact person: Miss An
Mobile phone number: 15801695345 (WeChat with the same number)