Regulatory Compliance under the Latest CSAR Framework
Successfully entering the Chinese cosmetics market requires full compliance with the Cosmetic Supervision and Administration Regulation (CSAR), which came into effect in 2021. The regulation strictly governs product classification, ingredient management, and authorization procedures.
Domestic Responsible Person
Foreign manufacturers exporting cosmetics to China must designate a legally registered entity within China as the Domestic Responsible Person. This entity assumes legal responsibility for quality and safety assurance, as well as registration and notification procedures.
Cosmetic Ingredient Management System
China strictly classifies cosmetic ingredients as either Existing Cosmetic Ingredients (ECI) or New Cosmetic Ingredients (NCI). Even IECIC-listed ingredients must obtain a Safety Information Code (ECI Code).
- New Cosmetic Ingredient (NCI): Ingredients not listed in the IECIC. Management requirements vary based on risk classification.
- Existing Cosmetic Ingredient (ECI): Safety information must be submitted to the NMPA-designated platform and an ECI Code must be obtained.
Authorization & Registration Procedure Overview
Preparation
Domestic Responsible Person (RP) selection and NMPA platform account creation
Testing & Evaluation
Product testing at China-designated institutions and safety/efficacy assessment
Submission & Review
Upload of formulation, labeling, and process documentation. Format and technical review by product category (general vs. special-use)
Post-Market Management
Adverse event monitoring and periodic safety report submission
Our Services
Our Services
Product Registration & RP Services
- Registration and Filing for general and special-use cosmetics
- Domestic Responsible Person (RP) designation support
Ingredient Regulatory Compliance
- New Cosmetic Ingredient (NCI) registration support
- IECIC compliance review and ECI Code acquisition
- Ingredient safety and regulatory compliance assessment
Testing & Evaluation Support
- Efficacy and stability testing coordination
- Toxicology data gap analysis
- International literature survey and summary
Labeling & Documentation Review
- Labeling compliance review and guidance
- Formulation review and documentation support
Additional Support Services
- Annual reporting and post-market management
- Adverse event monitoring
- Customized training and seminar programs
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