Article 27 (2) of the Standard for Registration and Filing of Cosmetics (Draft for Comment, 2020/11/4) “ The registrant, recordholder or domestic responsible person shall fill in the manufacturer information of the raw materials used in the product and upload the raw material quality and safety information file issued by the raw material manufacturer. If the raw material manufacturer has submitted the raw material quality and safety related information in accordance with the Guidelines for the Submission of Quality and Safety Information of Cosmetic Raw Materials (Annex 12 and Annex 13), the registrant, filing person or domestic responsible person can fill in the raw material submission code (Annex 14) associated raw material quality and safety information document” .

Cosmetic raw material submission code requirements, each raw material produced by each production enterprise only corresponds to a submission code, which is equivalent to the ID card of raw materials. If a cosmetic product company chooses a company that has not obtained a submission code, it may not be able to obtain the safety information documents of its raw materials, which will directly affect the registration and filing of cosmetic products.

How should overseas cosmetics raw material enterprises report?

According to the requirements of regulations, overseas raw material manufacturers can submit the safety information of cosmetic raw materials by themselves, and they can also authorize overseas or domestic legal entities to submit and maintain the safety information of raw materials. Of course, if there is authorization, when the authorized enterprise opens the user rights, it should also submit the authorization letter issued by the cosmetic raw material manufacturer. The authorization letter should clarify the authorization relationship and the scope of authorization, and the raw material safety related information of the same quality specification can only be authorized by one enterprise.

Cosmetic raw materials submission code writing principles

After submitting the safety-related information of cosmetic raw materials through the information platform, the cosmetic raw materials submission code will be automatically generated. The cosmetic raw material submission code consists of a five-digit manufacturer digital code, a six-digit raw material digital code and a three-digit raw material quality specification digital code.

NMPA has developed the relevant transitional measures and determined the information requirements required for the material submission code. Cosmetics companies should make corresponding preparations in advance according to the transition policy.

From May 1, 2021, when applying for registration or filing, the registrant/filer shall fill in the source and trade name information of the raw materials of the product formula, which involves the raw materials with quality specifications required in the Technical Specifications for Cosmetic Safety, and shall also submit the quality specification certificate or safety-related information of the raw materials.

From January 1, 2022, when the registrant/filer applies for registration or for filing, it shall, in accordance with the requirements of the Provisions, provide safety-related information about raw materials with anti-corrosion, sun protection, coloring, hair coloring, freckle-removing and whitening functions.

From January 1, 2023, the registrant/recordholder shall, when applying for registration or filing, provide all safety-related information of raw materials in accordance with the requirements of the Regulations. For cosmetics that have been registered or completed the record, the registrant and the record holder shall supplement and provide safety-related information about all raw materials in the product formula before May 1, 2023.