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The U.S. International Trade Administration (ITA) estimates that the sale of cosmetic products in China reached $50 billion (USD) in 2015. This represents approximately 18 percent of the global market for cosmetics, and places China with the U.S. and Japan among the top three leading countries for cosmetic products. However, the ITA estimates that only about 10 percent of China’s population uses cosmetic products on a regular basis, spending an average of just $24 (USD) per person in 2014, compared with $223 per year in South Korea and $174 per year in Japan. These market characteristics portend above average annual growth increases of 7-10 percent in China’s cosmetic market over the next several years, outpacing market growth in other, more developed economies.
Originally implemented in 1990, China’s Regulation concerning the hygiene supervision over cosmetics organises cosmetic products into one of two categories. “Non-special purpose cosmetics” include products with no medicinal effect, such as skin care products, makeup and lipstick, nail care products, perfumes and colognes, and hair care products like shampoos and conditioners. The term “special purpose cosmetics” covers products that promote specific beauty or health benefits, such as products for hair growth or hair removal, hair colours and dyes, deodourants, products for body shaping or fitness, and anti-spot or UV-blocking creams and lotions.
Under Chinese law, all imported cosmetic products, regardless of their classification, are subject to pre-market review and approval under regulations promulgated by the China Food and Drug Administration (CFDA, formerly the State Food and Drug Administration, SFDA). The CFDA is responsible for the administration and oversight of the pre-market review programme, and for the authorisation of designated testing bodies that conduct pre-market product testing. The CFDA is also responsible for post-market surveillance regarding the quality and safety of cosmetic products already on the market.
In brief, the regulatory approval process for imported cosmetic products involves the following steps:
The entire application, testing, dossier preparation and CFDA review process can take as long as nine months to a year, depending on the type and ingredient complexity of the cosmetic product.
Imports of CFDA-approved cosmetic products are also subject to inspection and testing at ports of entry by agents of China’s Inspection and Quarantine Bureau (CIQ). As part of the inspection, CIQ agents will review the CFDA licensed issued in connection with the product being imported, as well as other product-related documentation. Product labelling will be evaluate for conformity with the applicable Chinese regulations and standards, and agents will also conduct physiochemical and microbiological testing on random product samples. Products that pass this inspection will be issued a certificate of inspection, and allowed to complete the review by Customs officials.
It is important to note that non-special purpose cosmetic products produced in China are subject to far less rigorous review. In some cases, manufacturers can reduce time to market by partnering with a China-based company that can assemble finished cosmetic products from ingredients shipped to them by the manufacturer. Of course, another alternative is to utilise e-commerce platforms to ship cosmetic products directly to consumers, bypassing the regulatory process altogether.
TÜV SÜD state-of-the-art testing facility in Shanghai, China is fully equipped to conduct all testing consistent with the requirements of Safety and Technical Standards for Cosmetics 2015, including physio-chemical, microbiological and toxicology testing. For more information about TÜV SÜD testing services for cosmetic and personal care products for China, speak to us today.
 “China Personal Care and Cosmetic Products,” U.S. International Trade Administration, June 6, 2016. Available here (as of 22 August 2017).
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