The new rules are of particular importance to companies who are bringing cosmetic samples to China for testing, exhibition or R&D purposes whereby the samples imported do not require registration with the State Food and Drug Administration (SFDA).
However, the China Exit-Entry Inspection and Quarantine Bureau (CIQ) stresses that cosmetic companies will still be required to provide certain documents when applying for custom clearance for imports at the port of entry.
Divided into four categories with each containing its own requirements, cosmetic companies can apply for an inspection directly from Shanghai CIQ by providing the following documents illustrated in the table below.
Category of Cosmetic Samples
Procedure & Requirements
Sample to be tested in labs designated by government
Sample used for internal research & development or quality assurance testing
The company who conducts R&D activities or quality assurance shall register itself with Shanghai CIQ first by providing the following documents, pass CIQ’s on-site inspection and then obtain a record-keeping certificate from CIQ prior to importing any cosmetic samples.
After obtaining a keeping certificate for CIQ, the company can import cosmetic samples and apply for an inspection by providing the following documents:
Sample used for trial on targeted human group
Similar to the process for sample used for R&D except that:
Sample used for exhibition, internal display or training and other samples
The new rules have been made in accordance with the AQSIQ Order No. 143 of 2011 - The Administrative Measures on the Inspection, Quarantine and Supervision of Import and Export of Cosmetics that came into force on 1 Feb 2012, outling requirements on the inspection of imported cosmetics.
However, the Order did not explain in detail how cosmetic samples were to be inspected at the port of entry, the rules published by Shanghai CIQ is said to have solved this issue.
In March, the CIQ declared it “will no longer issue labels for imported cosmetics that have passed CIQ's inspections."
The older version of the Order required imported cosmetics to pass the inspection of the AQSIQ while also being affixed with a China Inspection and Quarantine label as without it the product was not allowed onto the Chinese market.
“All cosmetics imported to China for the first time still have to pass [the] CIQ's inspection, it is still mandatory.”
Then, April Guo, CIRS spokesperson told CosmeticsDesign.com USA "It is easy to buy fake CIQ labels and put them on imported cosmetics, the goal of using CIQ labels to protect consumers can easily be undermined."