5 Key Points of China’s “Administrative Measures for Cosmetics Registration and Filing (Notification)”

On January 12, 2021, the National Medical Products Administration(NMPA) issued the General Administration Order No. 35, stating that the“Administrative Measures for Cosmetics Registration and Filing” (hereinafter referred to as the “Measures”)was approved by the State Administration of Market Regulation, it will be implemented on May 1, 2021.

We analyze the first-hand information and articles and concluded five key points that may affect Foreign Brands business and registration as follows:


  1.  3 months grace period

Since the implementation of the “Measures”is on May 1, 2021, which means cosmetics brands have a three months grace period to catch the window and to complete the filing last time with the old notification system.  But please be aware of that, the future restriction of the new regulation might still affect the previously notified products and are required to make supplements accordingly. So please pay close attention to the recent regulation changes if you already begin the registration and filing process.


  1. Important of Responsible Person

According to Article 8 of the “Measures”,  it indicates that Responsible Persons of the brands in China will take more responsibilities than ever before. For example, the responsible person should take responsibility for the products’ quality and safety and also support the registrant and filing person to implement the Adverse reaction monitoring.

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