Analysis on Cosmetics not Allowed to Enter Mainland China Market

There are 52 batches of imported cosmetics are found unqualified for hygiene standards from January to August, according to the statistics from the China Customs. These cosmetics are not allowed to enter Mainland China market and have been returned or destroyed at the port.

These cosmetics are mainly imported from Taiwan, Germany, France and South Korea. Details are as follows:

CIRS have analyzed the reasons for not allowing to entry Mainland China market. They are:

• Disqualified label;
• Total number of colonies, molds and yeast exceeding the standard;
• Failure to provide certificates of conformity and other related certificates as required;
• High levels of arsenic and lead;
• Boric acid detected; and
• Exceeding shelf life.

The regulatory requirements are as follows:

• Disqualified label

According to the Notice on the implementation of Measures for the Administration of Cosmetic Labels released on 3 Jun. 2021, cosmetics applying for registration or filing must comply with the requirements of the Measures for the Administration of Cosmetic Labels since 1 May 2022. If the cosmetics are registered/ filed before 1 May 2022 and the labels are not marked based on the Measures, then registrants or filers must update their labels before 1 May 2023.

• Total number of colonies, molds and yeast exceeding the standard

Based on the requirements of Safety and Technical Standards for Cosmetics (2015 Edition), the total number of colonies for cosmetics in Mainland China shall be:

1. Eye make-up preparations, lip make-ups and children’s cosmetics: ≤500 CFU/g or CFU/ml;

2. Other cosmetics: ≤1000 CFU/g or CFU/ml;

Total number of molds and yeast shall be: ≤100 CFU/g or CFU/ml;

• High levels of arsenic and lead

Based on the requirements of Safety and Technical Standards for Cosmetics (2015 Edition), levels of arsenic and lead shall be 2 mg/kg and 10 mg/kg respectively

• Boric acid detected

On 28 May 2021, China National Medical Products Administration announced that boric acid, borate and tetraborate have been added into the Inventory of Prohibited Ingredients for Cosmetics.

• Exceeding shelf life

In accordance with the requirements of Article 39 of Regulation on the Supervision and Administration of Cosmetics, cosmetic manufacturers shall regularly inspect and dispose of cosmetics exceeding the shelf life. Those in violation of the above regulations will be dealt with according to Article 60 of the Regulation on the Supervision and Administration of Cosmetics or Article 33 of the Administrative Penalties Law.

• Failure to provide certificates of conformity and other related certificates as required

38% of the products not allowed to enter Mainland China for failing to provide certificates of conformity and other related certificates as required. There are three circumstances, they are:

1. The products are not filed;

2. The products are suspended for sale when entering Mainland China market;

3. Failing to provide relevant materials as required;

Information of Cosmetics not Allowed to Enter Mainland China Market from Jan.-Aug. 2021

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