China has long been associated with strict animal testing requirements for cosmetics, aimed at ensuring the quality and security of cosmetic products produced in and exported to China. The situation changed substantially in May 2021, when the National Medical Products Administration released the Provisions for Management of Cosmetic Registration and Notification Dossiers. The Provisions allow all general use cosmetics to be exempted from mandatory animal testing requirements during the notification process with NMPA, taking into account that:
- The product does not claim to be used by infants and children;
- The product does not contain new cosmetic ingredients;
- The product’s notifier/intermediary/manufacturer is not listed as a key supervision target according to the results of the quantitative rating system established by NMPA.
However, the animal testing exemption is not an automatic process. It is granted only when the manufacturer submits, as part of the notification process with NMPA: (i) a good manufacturing practice (GMP) certificate issued by an official government agency where the manufacturer is located; (ii) a safety assessment report fully confirming the safety of the product. Finally, it must also be noted that the above applies only to general use cosmetics, and not to special cosmetics.
More details on the classification, the content of the safety assessment report, as well as a list of EU Member States agencies issuing GMP certificate for this purpose, are provided in an ad hoc report completed by the EU SME Centre in early 2022 (see below).