Here comes ~ analysis of quality and safety information submission of cosmetic raw materials

Release time:

2021-01-29 17:47

Article 27 of the Code for Registration and Filing Materials of Cosmetics (draft for comments, 2020/11/4) (II) stipulates that "(raw material safety related information) the registrant, the filing person or the domestic responsible person shall fill in the manufacturer information of the raw materials used in the products and upload the raw material quality and safety information documents issued by the raw material manufacturer. If the raw material manufacturer has submitted information on the quality and safety of raw materials in accordance with the Guidelines for Submitting Information on the Quality and Safety of Cosmetic Raw Materials (Annex 12 and Annex 13), the registrant, the filing person or the domestic responsible person may fill in the information document on the quality and safety of raw materials submitted by the raw material submission code (Annex 14)". Since then, the management of cosmetic raw materials has entered a new era.

Combined with the requirements of the "Cosmetics Regulatory Regulations" that came into effect on January 1, 2021, the management mode of cosmetic raw materials under the new regulations is summarized as shown in Figures 1 and 2.

Figure 1 Judgment of existing raw materials and new raw materials for cosmetics

Figure 2 Quality and safety information management of raw materials in cosmetics registration

This management model strengthens the management of cosmetic raw materials, and at the same time puts forward new requirements for cosmetic raw material enterprises and cosmetic enterprises. New Anrun Consulting hereby proposes the following countermeasures for raw material enterprises and cosmetic enterprises:

(1) Cosmetic raw material enterprises

May 1 before the completion of raw material quality and safety information submitted, for the downstream cosmetics enterprise product registration to provide convenience. According to the information obtained by Xiao An, cosmetics management (cosmetics and cosmetics new raw materials registration) will be launched before May 1, and raw material quality and safety information/submission codes under the new system shall be provided simultaneously during cosmetics filing/registration.

(2) cosmetics enterprises

Organize the existing raw material inventory. If there are the same raw materials produced by different raw material manufacturers, the internal raw material system or raw material code shall be sorted out as required to meet the requirements of subsequent new regulations. Under the new regulations, cosmetics should be directly associated with raw material manufacturers when filing and registering. If raw material manufacturers need to be changed after filing, raw material information should be maintained through the filing and registration platform, and safety assessment should be carried out if necessary.

The announcement on the detailed rules for the transitional treatment of five types of special-purpose cosmetics such as hair development is here!

If the illegal act of cosmetics occurs before January 1, 2021, the "Regulations on Cosmetics Hygiene Supervision" shall apply, but if it is considered that it is not illegal or should be given a lighter punishment according to the "Regulations", the "Regulations" shall apply. If the violation occurs after January 1, 2021, the Regulations shall apply.

The announcement on the detailed rules for the transitional treatment of five types of special-purpose cosmetics such as hair development is here!