Animal testing on cosmetics is the top concern for stakeholders all over the world. In China, animal testing can be exempt for the filing of domestic non-special use cosmetics since 2014 but still required for the registration/filing of imported cosmetics so far. There are only two ways to avoid animal testing on cosmetics. One is to be sold by cross-border e-commerce. The other is to produce as domestic non-special use cosmetics. Kindly note when exporting the bulk to mainland China for filling and packing, this kind of cosmetic is regarded as domestic cosmetic.
On May 27, 2019, the comprehensive division of NMPA released the draft Management Measures on the Filing of Non-Special Use Cosmetics for public opinion. It mentions that toxicological test on animals can be waived for imported non-special use cosmetics as long as the manufacturer has obtained the official qualification certification of production quality management system and the safety risk assessment results are sufficient to prove the product safety. Nevertheless animal testing will be mandatory for the following situations:
- Products claiming for baby or Children care;
- Products containing new approval or recorded cosmetic ingredient. The new cosmetic ingredient has not been included in IECIC list;
- According to the quantitative grading results, the applicant, domestic responsible person or actual manufacturer is listed as a key regulatory object;
- The applicant, domestic responsible person or actual manufacturer has been investigated or punished due to the quality and safety issue of cosmetics in the past three years.
This Management Measures should come into force after the enforcement of Cosmetics Supervision and Administration Regulation which is estimated to be effective in the end of this year. We know that the government in some countries like EU and US is not in charge of issuing official GMP/ISO certificate. Which will bring challenges to foreign manufacturers to prepare qualified GMP/ISO certificate to avoid animal testing. Another challenge we will face is preparing qualified safety risk assessment of which the detailed requirements have not been issued yet.