The publication of the new overarching Cosmetic Supervision and Administration Regulation (CSAR), which entered into force on 1 January 2021, has opened an opportunity to work with the Chinese Government to end the requirements to test general cosmetic products on animals in China. Although CSAR does not specifically mention the animal testing exemption, further details are provided in the implementing Regulation “Provisions for Management of Cosmetic Registration and Notification Dossiers”, which came into effect on 1 May 2021.
According to the Provisions, general cosmetics do not need to be tested on animals as long as a Good Manufacturing Practices (GMP) certificate issued by the Government in the country where the products are made, together with a full safety assessment report can be provided. Therefore, the UK cosmetics industry, represented by CTPA and several individual companies, worked collaboratively with the UK Government to ensure UK Brands can benefit from this exemption.
Starting 1 May 2021, Brands and companies manufacturing in the UK are now able obtain a GMP certificate from the UK Government for export to China. Applications for the certificate will be handled by the Import Licensing Branch (ILB) of the Department for International Trade (DIT), mandated and supported by the Office for Product Safety and Standards (OPSS) - the national regulator for all consumer products, except for vehicles, medicines and food - as part of the Department for Business, Energy and Industrial Strategy (BEIS).
To obtain the GMP certificate, companies would need to create an account or log into the DIT ILB Import Case Management System (ICMS), and must be able to show their cosmetic products are manufactured according to GMP guidelines and standards. That is, a third-party certificate from a recognised source should be presented, according to at least one of the two below options:
- adherence to ISO 22716:2007, Cosmetics – GMP – Guidelines on Good Manufacturing Practices. The company issuing the GMP certifications should be accredited to standards ISO 17021 or ISO 17065 by an accreditation body member of the International Accreditation Forum (IAF), such as the United Kingdom Accreditation Service (UKAS); or
- a Brand Reputation Compliance Global Standards (BRCGS) certification for Consumer Products covering the manufacturing of cosmetic products.
For more information with regards to the obtention of the GMP certification from the UK Government, please visit the UK Government website.
Please note that the National Medical Products Administration (NMPA), the Chinese regulator, has not issued a formal acceptance of the UK approach and will not be pre-approving the UK GMP certification; instead, they have indicated a list of criteria required for the certification to be accepted. The UK GMP certification process meets these requirements in full, and it is anticipated that any such submissions to the Chinese regulators will therefore be accepted.
The development of this process has been the result of years of collaborative work. On behalf of the UK cosmetics industry, CTPA would like to express its gratitude to the UK Government, other key stakeholders and member companies for their active engagement and input into the discussions.