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New Cosmetic Raw Materials "Negative List System" Proposal

During the two sessions, Zhu Tongyu, a member of the National Committee of the Chinese People's Political Consultative Conference and director of the Shanghai Public Health Clinical Center, proposed that China should implement a "negative list system" for the filing of new cosmetic ingredients as soon as possible.


That is, for cosmetic ingredients that have been used in Europe, the United States, and other developed countries for more than three years without side effects and negative reports, and are safe and controllable, they can be included in the list of used cosmetic product ingredients for direct use in China; For new cosmetic ingredients that have not been used in developed countries such as European countries and the United States, they shall be in compliance with the Rules for Registration and Notification Dossiers of New Cosmetic Ingredients for the registration and notification; And for the cosmetic product ingredients (Chinese herbal medicine) with superior resources in China, it is recommended to give priority to approval after clarifying the source and safety-related information of cosmetic product ingredients.


Zhu proposed this proposal from consideration of three aspects:

First, the used cosmetic product ingredients are relatively few in China. The Catalogue of Used Cosmetic Raw Materials (Edition 2021) includes 8972 kinds of cosmetic product ingredients, and 189 new cosmetic ingredients compared with the 2015 edition, while there are 30072 kinds of used cosmetic product ingredients in the EU and 27500 in the United States.


Second, the new cosmetic ingredients safety certification period is relatively long and costly. It is revealed that enterprises spent no less than one million yuan to complete the filing of a new cosmetic ingredient.


Third, waste of government administrative resources. Zhu believes that Europe and the United States and other developed countries have done cell experiments, animal replacement experiments for used cosmetic product ingredients, there is no need to repeat the filing approval. And the cosmetic safety differences caused by the skin differences between human races are not significant, overseas Chinese have been using these products.


In Zhu's view, the current number of used cosmetic product ingredients blocks the technical development of the domestic cosmetics industry, reducing the international competitiveness of domestic brands, therefore, the implementation of the "negative list system" cannot wait.


However, in the opinion of many cosmetic industry insiders, the proposal is unlikely to be adopted.


"You cannot simply use the number of cosmetic product ingredients in the catalog of Europe and the United States to compare with the number of cosmetic product ingredients in the catalog that have been used in China." In fact, as early as 2021, an officer of the Cosmetics Regulation Department of National Medical Products Administration (NMPA) has made an answer to this issue.


He pointed out that the use purpose and management of cosmetic product ingredients catalog are different between China and EU and the United States. The Catalogue of Used Cosmetic Raw Materials is formed on the basis of sorting out and adjusting the cosmetic product ingredients that have been listed in China, and carries out dynamic management. Its main purpose is to provide a reference basis for determining new cosmetic ingredients.


EnterCo will continue to pay attention to cosmetics-related proposals during the two sessions.

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