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Cosmetics: certificate of free sale in the EU as a requirement to export cosmetics to China

In order to export cosmetics to China, relevant manufacturers must go through a filing or registration process of their products with China’s National Medical Product Administration. During the registration process, manufacturers might be asked to provide a proof that the cosmetic had already been selling in the country of origin and/or in the European Union. However, there was uncertainty in terms of what could constitute such proof.

Such proof is a document, in general (there can be differences depending on individual Member States) issued by central, or regional, government agencies for medical and health products. In some countries can also be issued by chambers of commerce. One example of such proof is the ‘certificate of free sale’ below: