On May 19, 2017, China Food and Drug Administration (CFDA) issued Notification No.72 of 2017, defining that if an imported non-special use cosmetic, which has finished the permit inspection but has not submitted administrative approval documents, is to conduct import filings in Pudong New Area, its survey report can be submitted as a filing material of imported non-special use cosmetics. As for manufacturer that commissions cross-border production (including packaging) of cosmetics, if the last procedure which contacts with the contents is completed abroad, the product should have import declaration.

According to the requirements of “The State Council’s Decision on The Temporary Adjustment of the Administrative Regulation Related and the State Council Documents Stipulated Administrative Approval in Pudong New Area” No.24 of 2016 as well as “Announcement About the Pilot Implementation in Pudong New Area to Manage Imported Non-Special Use Cosmetics By Filings And Relevant Matters Concerned” No.7 of 2017, the further clarification of filing management as presented as follows:

| Survey Report of Imported Non-Special Use Cosmetics

When the cosmetics administrative licensing inspection institution issues the survey report of imported non-special use cosmetics in accordance with the requests of “Requirements for Cosmetic Administrative Licensing Testing”, the relevant information of the domestic responsible individual should be filled in the blank of “declaring of domestic responsible organization” and the words “domestic responsible individual” should be marked behind the name of the organization.

If imported non-special use cosmetics, which have completed the permit inspection but haven’t submitted administrative approval documents, are to conduct import filings in Pudong New Area, their survey reports can be submitted as a filing material of imported non-special use cosmetics. If the current domestic responsible organization or the domestic responsible person of the filing is different from the initial one, the applicant should submit the relevant explanation of the situation to make clear that the product for filing and the initial inspected product are the same product. Besides, a consent form issued by the initial domestic responsible organization that permits the use of this survey report should be presented simultaneously.

| Overseas Production Commission of Domestic Production Enterprises

According to “Requirements for Application and Acceptance of Administrative Licensing for Cosmetics” (2009) No.856, as long as the last procedure which contacts with the contents is completed abroad, the manufacturer who commissions cross-border production (including packaging) of cosmetics should provide import declaration for their products. For imported non-special use cosmetics, which are commissioned for overseas production by domestic cosmetic companies that registered in Pudong New Area, Shanghai, their filings and other relevant matters could be handled in Pudong New Area and these companies shall legally take the responsibility of related quality and safety issues of their products.

The eligible domestic cosmetic company that commissions cross-border production of imported non-special use cosmetics should registers through the filing system of imported non-special use cosmetics without the mandatory requirement of submitting the authorization of domestic responsible individual or other related documents. And domestic cosmetic company should submit relevant filing materials about producing commission according to “Requirements for Application and Acceptance of Administrative Licensing for Cosmetics” when submitting filing information of the product.

| Further Information: CFDA issues notification on the filing of imported cosmetics for non-special purposes-C&K Testing reported on Jan. 18, 2017

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