After implementing the new “Cosmetics Supervision and Administration Regulation (CSAR)” in China, will it be more difficult for imported cosmetics to import customs clearance?
The CosmeticsBridge brings you a summary and analysis of the reasons why cosmetics were not allowed to enter the country from January to April 2021.
According to the official website of the General Administration of Customs, a total of 31 batches of imported cosmetics were not allowed to enter the country this year due to unqualified labels and other reasons.
These products are produced in France, Thailand, South Korea, Israel, Japan, etc. The reasons for entry are shown in the figure below:
| Non-entry Reasons | Cases | Compliance analysis and Recommendations |
| Unqualified labels | 9 | Imported cosmetics should be labeled in Chinese or use Chinese packaging designed for the Chinese market, and should comply with cosmetics Regulatory requirements. When products registration or filing, it is necessary to submit the Chinese label or packaging to NMPA review. So The suggestion is when importing, the Chinese labels of products should consistent with the labels submitted to NMPA during filing or registration. |
| Beyond the shelf life | 8 | Cosmetics imported and sold should be within the shelf life. Reminder: The labeling requirements of cosmetics regulations accept shelf life marking as “Production date+Shelf life” or “Production batch number+Expiration date”. |
| The total number of colonies exceeds the limit | 1 | The “Cosmetics Safety Technical Standard 2015” clearly requires that the total number of bacterial colonies should be ≤1000 (CFU/g or CFU/ml). For eye cosmetics, lip cosmetics, and children’s cosmetics, the index should be ≤500 (CFU/g or CFU/g). CFU/ml). Reminder: The quality management measures of imported cosmetics should be able to ensure that the cosmetics production complies with the requirements of Chinese cosmetics regulations, and during the process of packaging, storage, and transportation, they should not cause pollution to the products. |
| Excessive Heavy Metal (LEAD & Arsenic) | 3 | Arsenic will cause changes in the human body’s nervous system. Symptoms such as hand numbness, foot numbness, limb weakness, and pain will occur. The normal color changes to blue-gray or gray-brown. In severe cases, skin cancer can also be induced. Reminder: The “Cosmetics Safety Technical Standard 2015” clearly requires that the arsenic index should be ≤2mg/kg. Excessive LEAD long-term use of lead-exceeded cosmetics will damage the skin and then cause allergies such as redness and itching and have certain effects on the human nervous system, intellectual development, kidneys, and reproduction. Reminder: The “Cosmetics Safety Technical Standard 2015” clearly requires that the lead index should be ≤10mg/kg. Imported cosmetics quality management measures should be able to ensure that the cosmetics products comply with the requirements of Chinese cosmetics regulations, and at the same time, during packaging, storage, and transportation, etc., the products should not be contaminated. |
| The cargo certificate does not match goods | 6 | The cargo certificate of imported cosmetics must match the goods and also meet the mandatory requirements of China’s relevant laws and regulations and national technical specifications. Cosmetics that do not provide certificates or qualified materials as required are not allowed to enter. |
| Failure to submit a certificate of cosmetics | 4 | Reminder: special cosmetics under Article 17 “Cosmetics Supervision and Administration Regulation (CSAR)”, Special cosmetics can only be produced and imported after they have been registered by the National Medical Products Administration (NMPA). Imported General cosmetics shall be filed with NMPA before import. |
