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CourseMeetings & TrainingRegulationsZMUni16/09/2021(1)How to import in the new system cosmetics that have been registered and filed/ notified?

We conducted an online training on September 9,2021 . The Topic was: How to import in the new system cosmetics that have been registered and filed/ notified? And the speaker was our specialist–senior cosmetic technical regulation manager of ZMUni.

At the end of the training, a series of questions were raised, and the followings are the 1st batch of our Q&As:


Q1.Supplementary toxicological test report is required for additional recording of children’s products. Which law stipulates that?

A: Because some domestic children’s cosmetics did not submit toxicological test reports before notification, after the new regulations, children’s cosmetics do not belong to toxicological free products, so they may need to be submitted.


Q2.How to prepare the annual report?

A: The annual report of general cosmetics needs to report the production, shutdown, sales, adverse cosmetic reactions, self-examination, etc.


Q3.Is it necessary to change the publicity of additional recording products? If so, what is the content of the change?

A: At present, in our actual operation, after the product is added, the product change will be publicized in the publicity system. The change may be packaging, domestic responsible person and other matters.


Q4.Does the raw material name and INCI name in the supplementary formula need to be subject to the used raw material catalogue in version 2021?

A: The 2015 version of the raw material catalogue is used for the notification of historical products. At this stage, NMPA(National Medical Products Administration) has issued the catalogue of used cosmetic raw materials (2021 version) on April 30 this year. We suggest that the Chinese name and INCI name of the raw materials contained in the 2021 version of the catalogue should be directly used for the supplementary recording, and the inconsistency of the raw material names will be explained at the formula description.


Q5.Can the unfinished additional recording products be produced?

A: First of all, as long as the products are notified, they can be produced. During the supplementary recording period, they can also be produced if they comply with laws and regulations.


Q6.If you need to supplement 20 products , can you supplement 2 first and then complete the supplementary recording?

A: it’s OK to supplement two products first. It’s recommended to complete the supplementary recording at one time.


Q7.For the products registered on the new website, will the products be publicized during the change period?

A: Yes.


Q8.If the products are not additionally recorded to the new system, can the products be sold normally?

A: The regulations have told us explicitly that the notification person should submit the annual report from January 1 to March 31 every year, submit the product implementation standards and product label samples, fill in the product formula of domestic general cosmetics, and upload the label pictures of sales packages of special cosmetics before May 1, 2022. If it is not done in accordance with the requirements of National Announcement No. 35, The product can be considered not to comply with the current laws and regulations. In principle, it is not allowed to be sold.



ZMUni regulatory compliance services in China include: 
  • Registration Service of Special Cosmetic Products
  • Filing/Notification Service of General Cosmetic Products
  • Infant/Children General Cosmetic Products Filing/Notification Service
  • Infant/Children Sunscreen Cosmetic Products Registration Service
  • New Cosmetic Ingredients (NCI) Filing/Notification and Registration Service
  • Chinese responsible agency service
  • Apply for CITIS permit or certificate of endangered species service
  • Toothpaste Filing/Notification Service
  • Mouthwash etc. Dental Care Products regulatory compliance Service
  • Custom clearance service
  • Disinfection products Filing/Notification Service
  • Anti-bacterial products Filing/Notification Service
  • QMS (Quality Management System) service
  • ACR (Adverse Cosmetic Reaction) Service
  • Labelling Reviews
  • Regulatory Dossiers
  • Compliance Solutions
  • Regulatory Support



ZMUni Chinese Cosmetic Regulation Compliance Centre 中贸合规中

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