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CourseMeetings & TrainingRegulationsZMUni17/09/2021(2)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. Yesterday we presented you the 1st batch of our Q&As,

and the followings are the 2nd batch of Q&As:


Q9.What do innovative terms mean?

A: Article 18 of The Measures for the Administration of Cosmetics Labels reads: if the use of innovative terms in cosmetics labels has not been widely used by the industry, which is difficult for consumers to understand, but does not belong to the content prohibited from labeling, its meaning shall be explained in the adjacent position.


Q10.Will the registered products of the new website be publicized during the change period?

A: The current publicity system can publicize normally.


Q11.What changes can be submitted?

A: For example, product packaging change, manufacturer address change, raw material manufacturer change, executive standard change, label change, etc.


Q12.How to transfer the filed/notified products from the old system to the new system?

A: Taking imported general cosmetics as an example, the enterprise needs to apply for new system permission, and then the product enters the 2.0 system according to the enterprise’s unified credit code, the formula raw material information is confirmed, and finally the product is supplemented.


Q13.The packaging material has changed from opaque to transparent. Does it need to be changed?

A: In principle, the packaging is inconsistent with the notification and needs to be changed.


Q14.After and during the supplementation, what we really shall submit is the previous one we call label or packaging. Can we change it after the supplementation is completed? –For example, we claimed anti wrinkle or other nourishing and repairing efficacy at that time. I may not be able to achieve it according to the actual situation of the product, or this is not my market selling point. Can I change the packaging?

A: First of all, we now know that the document claim on the package can be changed. Secondly, whether the product name can be changed depends on the situation. If it is an imported product, the foreign name should correspond to the Chinese name. If the Chinese name removes the nourishment of the effect, but there is in the foreign name, it will not comply with the laws and regulations, because the foreign name is not allowed to be changed, and the Chinese name of imported products cannot be changed in this case. Under what circumstances can it be changed? There is no such word in the foreign name of the product, but it is added in the Chinese translation, so we think it can be changed in this case. Now we need a reasonable reason to change the product name.


Q15.We didn’t get the user name of the new system. Can’t the old system open after September 15?

A: At this stage, it is suggested that enterprises can apply for new system permissions and give sufficient time for product supplementary recording. According to the announcement “NMPA comprehensive cosmetic notice [2021] No. 264” issued by the state, the notification person shall complete the rectification as required no later than September 15, 2021. If it fails to correct within the time limit or still fails to meet the requirements after rectification, the notification management department shall cancel the notification.



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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