ANIMAL TESTING REGULATIONS FOR COSMETICS IN CHINA – LATEST DEVELOPMENTS
CIBE is China’s biggest cosmetics expo – they have events in Shanghai, Beijing and Guangzhou. It is a really huge event with over 3800 exhibitors and 200,000 professional attendees – retailers, distributors, bloggers, KOLs and brands.
This time they invited me to join the event as they were running a Cruelty free conference within their Guangzhou event. It is the first time they had addressed this topic. Most of the exhibitors are Chinese companies but it attracts a lot of distributors who look after foreign brands as well.
In terms of the Cruelty free conference I am going to focus on two of the experts who were very informative about the latest processes and developments as I think this is the most useful for foreign brands wanting to enter the Chinese market.
LATEST DEVELOPMENTS WITHIN COSMETICS TESTING METHODS IN CHINA?
Dr Shujun Cheung from Jiaotong University in Shanghai, his expertise lay in the type of tests that are carried out in China and elsewhere. He was talking about the different non animal testing methods that are used to test cosmetics globally and how China was reviewing them. There was a general consensus that for China to increase its competitiveness globally they need to adopt International standards and norms. Interestingly 80% of the world by land mass still use some form of animal testing methods but the 20% that don’t are the core producers and consumers of cosmetics.
There is rapid development in the non-animal testing methods. For example, to check for cancer cells non animal testing methods are much quicker in establishing concrete outcomes. In these very definitive cases Chinese authorities are already referring to global norms.
However overall the message was that the Chinese authorities are studying many different methods and need to decide which ones to adopt. They are looking at Green chemistry, Invitro CNAS, GIVIMP etc. GIVIMP will have a Chinese language version out soon which he believes will speed up the innovation in China.
WHAT ARE THE CURRENT PROCESSES?
The next very insightful speaker was Monica Chau from QTCC. QTCC is a regulatory service provider who help companies navigate the Chinese regulatory process both imported and local brands. They have worked on Erno Laszio, Jurlique, Blistex, Watsons and many more.
She broke down cosmetics products into special use and non-special use. Special use there are 9 categories including sunscreen/SPF, anti-wrinkle, anti-spots, deodorant, slimming, hair dye…. all special use cosmetics are treated differently and need a longer more in-depth process.
The focus of her presentation was on Non special use cosmetics – so all the rest.
If you are imported brand currently you still need to go through animal testing to sell in physical retail stores in China.
The process is as follows:
- Electronic Credence which includes sample test report. This is where animal testing is currently mandatory for all imported cosmetics.
- Customs Clearance proof
- Commodity Inspection Report
- Chinese label
Currently under consideration by the NMPA (Chinese equivalent of the FDA) is that non special use cosmetics may not need animal testing as part of their sample test report if the products are manufactured under certified GMP conditions and if the safety assessment data sufficiently proves product safety – the exact details of this are not clear yet. There are exceptions to this:
- If products are specifically for Children or infants
- Or if the products contain any ingredients that has not been listed in the IECIC which is the list of approved ingredients. New ingredients would need to go through animal testing.
For Local cosmetics the process is different. Local cosmetics could be brands produced in China, but it could also be brands who send semi-finished goods into China and then put product into final packaging and do labelling in China and therefore can be classified as local for this purpose. In order to qualify to be a local cosmetics product you need to:
- Be packaged in China
- The packaging needs to have more Chinese than English on it
- Product must have a Chinese name
- On the Electronic Credence the manufacturer needs to be the local Chinese filling factory NOT the brand. This may change soon but that is the current situation. So, your brand will not be on the official paperwork as the manufacturer of the products.
- Electronic Credence and sample test report
This test report does not require animal testing. It will require microbiological test and heavy metal test.
You also need to prepare – Product name, shelf life, net weight, packaging art work, product manufacturing process, Formula but only key ingredient percentage not the whole formula, business licence of the Chinese filling factory along with a production certificate.
- Customs clearance proof
- Certification documents of Chinese filling factory
In terms of timing it will take around 2 months before you can start selling – 1 month for the preparation, 3 weeks for inspection, 1 more week to get electronic credence after which you can start selling and then another 3 months to get local FDA verification.
In early 2019 the NMPA abolished the post market animal testing. Meaning that now if you have a non-special use cosmetics product that is produced in China or at least packaged there you do not risk any animal testing.
If you are a non-Chinese brand who wants to enter the Chinese market but wishes to maintain your cruelty free status, then you currently have the following options:
- Use Cross Border e-commerce an online only route where product is kept outside of mainland China usually Hong Kong and only sent it once the consumer orders it online. More information on this here.
- Send your products into China as semi-finished goods and have them put into the final packaging by a local Chinese filling factory.
- Wait…. from this conference the experts agreed that regulations will change but the timing is likely to be 2 years from now best case and 5 years if things move slowly.
If you would like to know more about Cross border e-commerce, please see my Online course which goes into this route in much more detail. Or if you want to discuss your options then please get in touch to book a free 15 min consultation with me on firstname.lastname@example.org