Chemlinked Cosmetic Portal, which provides insight into regulatory and compliance issues in APAC, has emphasised the upcoming deadline and the impact that the failure to obtain the license before the New Year will have on domestic manufacturers.
The new Cosmetic Production License, which will now be accessed via local Food and Drug Administration's (FDA), consolidates and replaces the old system.
Previously, cosmetics manufacturers would have to obtain a Cosmetics Production License, known as a National Industrial Production Permit, from Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) and a Hygiene License, called a Sanitary Certificate of Cosmetics Manufacturer.
The China Food and Drug Administration (CFDA) announced the update on 15th December 2015, giving companies a year to complete the application process and receive the Cosmetic Production License. From 1st January 2016, new manufacturers have been able to apply for the license and existing manufacturers have been able to exchange their old licenses.
Companies that fail to make appropriate provisions and complete their application by 31st December 2016 will be prevented from carrying out any manufacturing activities.
Packaging need-to-knows
Once the consolidation process is complete, the CFDA will eradicate the requirement to display a QS Label on cosmetic packaging. The Cosmetics Production License does not contain any requirements relating to the use of QS Labels. The Label, which since 2005 has been compulsory on all cosmetics products, will therefore no longer feature on cosmetic product packaging.
The CFDA states that from 1st July 2017, domestic manufacturers in China must only use new packaging that satisfies the rules stated in the Cosmetics Production License.
However, packaged products that adhere to the preceding regulations can be available for purchase until they reach their expiration date. After that date, they must be replaced with packaging that complies with the new regulations.
Application process and considerations
Manufacturers applying for the new production license must submit the initial application and materials. Once received, a format check will be conducted and it is at this point that an application is either refused or accepted.
If it is accepted, then the FDA will carry out an on-site inspection to ensure compliance. If satisfied, the manufacturer will receive a certificate confirming that it has successfully obtained the cosmetics production license.
Chemical Inspection and Regulation Service (CIRS), a product safety and chemical management consulting firm, highlights the FDA’s aim to simplify the existing process through consolidating cosmetics licenses.
To provide additional guidance, China also released information on “The Key Inspection Points of Production License of Cosmetic”, outlining good manufacturing practices relating to cosmetics production.
In a bid to encourage the adoption of ISO 22716:200, which provides guidelines for the production, control, storage and shipment of cosmetic products, companies that fail to comply with these may find it challenging to achieve certification.
Monitoring the entire manufacturing system is also high on the agenda for the Chinese cosmetics industry as the regulation emphasises the need for quality management. Manufacturers must abide by a number of software requirements that monitor the complete process from raw material purchases, production, inspection, storage and sales. It also outlines the need to implement a traceability system into its manufacturing operations.