Andrew Atkinson
7 July 2020 0 Comments

Since early January when the draft to update China’s CSAR (Cosmetic Supervision and Administration Regulation) was passed to the next stage – beauty brands world over have been waiting for the official version to be released alongside the guidelines to implement it. On June 29th, we got part of this but still don’t know all the answers. It was a somewhat hollow announcement, as we know many brands are wanting to know if and how they can enter general trade in China without the archaic requirement to test on animals.

The main takeaways on animal testing you need to know are this:

– There will be an avenue to general trade in China by Jan 2021 that does not involve testing on animals

– This ‘exemption’ will be granted to brands whose products have a ‘GMP Cert’ and a ‘Safety Assessment’

– Calls with the NMPA (National Medical Products Association who govern safety filing) have gone round in circles about what is actually needed for this standard of ‘GMP Cert’, and the ‘Safety Assessment’ is still vague in its detail. We have been told that the definition behind these two items will be delivered within the next 2-3 months.

– Brands can feel more comfortable preparing for a China launch (in general trade) in 2021, but there is still the unknown of the exact timeline/cost/extent of what the safety certs will be.

The animal testing component is just a section of a much larger update to the regulation, which covers new filing methods for ingredients and efficacy claims amongst other updates. With guidelines and implementation documents to come over the coming months we will be publishing any major updates as and when they are delivered.