(4)Common questions during cosmetic review in China

Q1: Is it able to apply for the change of registrant if the registrant is merged or has established a subsidiary?

A1: According to Article 49 of Provisions for Registration and Notification of Cosmetics(hereinafter referred to as the Provisions), the registration certificate of cosmetics shall not be transferred. When the principle qualification of the original registrant is canceled due to the legal causes such as merger and division of enterprises, and the registrant is changed to a newly-established enterprise or other organizations, The change of registration shall be applied for according to the requirements of the Provisions.

Q2: What are the requirements for the Certification documents of the Corporate Entity required by the registering on the registering platform of ingredient safety information by overseas users?

A2: The Certification documents of the Corporate Entity shall be notarized by Chinese notary organizations or confirmed by Chinese Embassy(Consulate). If the text is in foreign language, it shall all be entirely and normatively translated into Chinese and the original text shall be attached behind the corresponding translated text.

Q3: Can a couple of Chinese responsible persons be authorized for new cosmetic ingredients?

A3: According to Article 11 of the Rules for Registration and Notification Dossiers of New Cosmetic Ingredients, The same one new cosmetic ingredient can’t be authorized to a couple of Chinese responsible persons.

Q4: How to log in to the registering platform of cosmetic ingredient safety information? Is it necessary to register an account?

A4: Chinese users don’t need to register an account and they can log in by the module “registering platform of cosmetic ingredient safety information” of NMPA online service hall(https://zwfw.nmpa.gov.cn). Overseas users need to register on ”registering platform of cosmetic ingredient safety information”(http://ciip.nifdc.org.cn), upload the Certification documents of the Corporate Entity notarized by Chinese notary organizations or confirmed by Chinese Embassy(Consulate), and log in after it passes the review.

Q5: What if the authorization letter of Chinese RP of New Cosmetic Ingredient expires?

A5: According to Article 11 of the Rules for Registration and Notification Dossiers of New Cosmetic Ingredients, after the authorization period specified on the authorization letter of Chinese RP expires, the authorization letter for extending the authorization period shall be re-submitted within 30 days before the expiration of the authorization period or the changing of Chinese RP shall be handled according to the requirements.

Q6: When applying for the NCI(New Cosmetic Ingredient) username, which contents shall be stated in the authorization letter of Chinese RP?

A6: According to Article 11 of the Rules for Registration and Notification Dossiers of New Cosmetic Ingredients, The following contents and information shall at least be specified in the authorization letter of Chinese RP: the names of new cosmetic ingredient registrant, notifier and Chinese RP, the authorizing and the authorized relationship, the authorizing scope, the authorizing period.


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ZMUni Chinese Cosmetic Regulation Compliance Centre 中贸合规中心

Contact us: info@zmuni.com

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