Q1: When applying for cosmetic registration, how should I submit raw material safety information for raw materials that have not yet obtained the NMPA Codes of ingredients?
Registrants, filers or domestic responsible persons shall provide the information in either of the following two methods according to the specific situations.
1. The raw material specification document or the related raw materials safety information stamped with the official seal of the raw material manufacturer (Annex 14 of the Provisions on the Management of Cosmetic Registration and Filing Data). (Note: The registrants or domestic responsible persons shall also affix the official seal page by page at the same time)
2. Where the registrants, the filers or the domestic responsible persons authorized by the raw material manufacturers need to fill in the safety information of the raw materials (Annex 14), the registrants, filers or the domestic responsible persons shall provide the safety information of the related raw materials (Annex 14) stamped with the official seal of the registrants, the filers or the domestic responsible persons. In the “Other issues that need to be addressed” column, the following information shall be given: registrants, filers or the domestic responsible persons (specific enterprise name) are authorized by the raw material manufacturer (specific enterprise name) to fill in the relevant content in Annex 14. All the information provided is true, complete and accurate.
Q2: What should we pay attention to when submitting the Chinese translation of labels printed on the sales package for imported products?
According to Paragraph 2 of Article 31 of the Provisions on the Management of Cosmetic Registration and Filing Data, the registrant, the filers or the domestic responsible persons of imported cosmetics shall submit the Chinese translation of the sales packages (including the instructions) and the labels of the imported products.
The Chinese translation submitted shall be consistent with that of the original label. Information of the labels shall not be concealed, nor shall be modified via covering or altering. If sales package have the same contents as the labels have (including the instructions), it can be translated only once.
Q3: What should we pay attention to when there are registered trademarks in foreign languages in the sales package labels?
According to Article 6 of the Measures for Administration of Cosmetics Labeling, cosmetics shall have Chinese labels. The Chinese label shall use standard Chinese characters. If other characters or symbols are used, the corresponding explanation in standard Chinese characters shall be printed on the visible side of the product sales package (except that the website, name and address of overseas enterprises, and the conventional technical terms must use other languages).
If same registered trademark in foreign language is printed on multiple visible surfaces of the product label, the corresponding explanation in standard Chinese characters can be printed on one of the visible surfaces.
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