Summary of Hot Spots of Cosmetic Raw Material Compliance Seminar

Release time:

2021-04-28 17:56

In order to further promote the latest policies on the reporting of safety and quality information of cosmetic raw materials and the filing and registration of new cosmetic raw materials, we successfully held a webinar on compliance of cosmetic raw materials and new raw materials on April 27, 2021.

The teacher gave a detailed introduction to the compliance of cosmetic raw materials and new raw materials from the aspects of the supervision situation of cosmetic raw materials in China, the management mode of cosmetic raw materials under the regulations, and the detailed explanation of the registration and filing of new cosmetic raw materials.

We have listed some of the questions answered during 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 the relevant information of foreign customers? When submitting, do you only need to submit the next-level customer information, or do you need to submit the customer information of the entire sales chain?

Answer: The quality and safety information of raw materials is submitted. Foreign manufacturers cannot submit it on their own. They must entrust a domestic reporting person to carry out it.

The quality and safety information of raw materials is submitted to serve domestic cosmetics, so only the finished cosmetics using this raw material need to be registered and filed in China. If this raw material is sold abroad for use as a cosmetic raw material, and the cosmetics produced are not required to be registered in China, they are not required to be submitted.

The quality and safety information of raw materials is the quality and safety information of this raw material, 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?

Answer: The submission of quality and safety information of cosmetic raw materials can be provided by the raw material manufacturer or the cosmetic enterprise that uses this raw material during the product registration and filing. If the manufacturer does not submit the information in the early stage, there is no submission code. If the finished product registration and filing cannot be related to relevant information through the submission code, then 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 the notarization of the power of attorney? The system is not yet open, what are the current regulations?

A: According to the information communicated at the training meeting of the High Research Institute of the Food and Drug Administration on April 22-23, the authorization letter submitted for 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 the finished products of cosmetics are registered.

Q4: If the ingredient list of cosmetic raw materials contains residues that do not belong to functional ingredients, such as 1% glucose and 2% solvent residues, if all ingredients are marked with impurities, the label will be very long. Can it not be marked on the cosmetic label?

Answer: According to the standard requirements for labeling the ingredient list on cosmetic labels, these need to be labeled. However, it can be compared with the "full ingredient list-labeling exemption".

Full Ingredient Table-Note Exemptions are divided into the following five points:

1, to protect the raw materials and add the right amount of preservatives, antioxidants and other ingredients. 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 cosmetic hygiene standards, so labeling can be exempted;

2. Trace impurities mixed in raw materials. Under the current technical conditions, these trace impurities inevitably exist in the raw materials. The existence of these trace impurities does not affect the safety evaluation and use of the raw materials:

3. Trace unreacted substances or reaction by-products present in the reaction product:

4. Processing aids intentionally added in the production process but not present in the final product:

5, as a mask and other products of the carrier of non-woven fabric is not considered cosmetic ingredients.

Q5: Regarding prohibited plants, if I do not confirm whether a plant can be used, is there any organization that can inquire?

Answer: The substances in the list of prohibited plants must not be used. The plant raw materials in the list of used cosmetic raw materials can be used. If you are not sure whether they belong to the list, you can find a consulting organization or industry experts to judge, but there should be no special organization to issue a conclusion on the report format at present. If it is finally confirmed that it is not included in the used cosmetic raw materials, new raw materials registration is required.

Q6: There is no production license for cosmetic raw materials. It is possible that dealers will fill in the raw material information according to the manufacturer. If the raw material information reporting system is opened, how can manufacturers and distributors be distinguished?

Answer: The submission of cosmetic raw materials should be carried out by the manufacturer or the person authorized by the manufacturer. The submission code can only be obtained after the raw materials are submitted.

Q7: The delivery of raw materials does not need notarization, and the registration and filing of new raw materials needs notarization. Is this right?

Answer: The power of attorney submitted for raw material quality and safety information does not need to be notarized.

For the registration and filing of new raw materials, if the registered filing person is abroad, it is necessary to authorize the domestic responsible person to carry out the registration and filing, and the authorization letter needs to be notarized.

Key Analysis of "Cosmetics Label Management Measures"

Notice on Issuing the Technical Guide for Submission of Registration and Filing Materials for Cosmetics (for Trial Implementation) (No. 26 of 2021)

Key Analysis of "Cosmetics Label Management Measures"

Notice on Issuing the Technical Guide for Submission of Registration and Filing Materials for Cosmetics (for Trial Implementation) (No. 26 of 2021)

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