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Q&As on Ordinary Cosmetics Filing in Guangzhou (Vol. 61)

from CIRS by

We have collected the latest FAQs on ordinary cosmetics filing from the Guangzhou Administration for Market Regulation and translated them into English for your reference.


What Are the Legal Responsibilities for a Quality and Safety Responsible Person?

The Quality and Safety Responsible Person appointed by the registrant/filer of cosmetics produced under contract should assist the legal representative of the company in undertaking the following product quality and safety management and product release responsibilities:

1. Establish and implement the company's quality management system, ensure the implementation of quality and safety management responsibilities, and regularly report the operation of the quality management system to the legal representative.

2. Make decisions on product quality and safety issues and sign related documents.

3. Review cosmetics registration and filling materials.

4. If the client procures or provides materials, manage the audit of material suppliers and the release of materials.

5. Release products to the market.

6. Supervise and manage the selection of contract manufacturers and their production activities.

7. Manage the monitoring of adverse reactions to cosmetics.

What are the Competencies Required for a Quality and Safety Responsible Person?

1. Professional Knowledge Application: Possess professional knowledge related to cosmetics quality and safety that meets the requirements of their job responsibilities, and be able to apply this knowledge in quality and safety management tasks.

2. Legal Knowledge Application: Be familiar with the laws and regulations related to cosmetics, ensuring that the company's quality and safety management activities comply with legal requirements.

3. Organizational and Coordination Skills: Have the leadership skills necessary to implement the company's cosmetics quality and safety accountability system, and be able to effectively organize and coordinate activities involving quality and safety within the company.

4. Risk Assessment Skills: Be knowledgeable about risk management in cosmetics quality and safety, able to accurately identify and assess potential product quality risks in the company's production and business activities, and propose solutions.

5. Other Necessary Cosmetics Quality and Safety Management Skills: Possess additional capabilities required for managing cosmetics quality and safety.

What Qualifications are Required to be a Quality and Safety Responsible Person?

1. Professional Knowledge Requirements: Must possess professional knowledge relevant to cosmetics quality and safety in fields such as cosmetics, chemistry, chemical engineering, biology, medicine, pharmacy, food, public health, or law. This knowledge can be demonstrated through academic education, non-academic education, technical qualifications, or effective training.

2. Work Experience Requirements: Familiar with relevant laws and regulations, mandatory national standards, and technical specifications, and must have over five years of experience in cosmetics production or quality management. In regulatory practice, if a Quality and Safety Responsible Person has professional knowledge related to cosmetics quality and safety, their experience in the production or quality management of pharmaceuticals, medical devices, or special foods may be considered equivalent to experience in cosmetics production or quality safety management.

Can a Quality and Safety Responsible Person Hold Other Positions?

1. Cross-Company Part-Time Requirements: To ensure effective performance of duties, Quality and Safety Responsible Persons are generally not permitted to hold positions across different companies. However, when the cosmetics registrant/filer and the contracted manufacturing company belong to the same corporate group and operate under the same quality management system, and the contracted manufacturer produces on behalf of the registrant/filer, the same individual may be employed as the Quality and Safety Responsible Person for both the registrant/filer and the contracted manufacturer.

2. Internal Part-Time Requirements within the Company: The Quality and Safety Responsible Person should be able to perform their duties independently, without interference from other company personnel. They must not hold any other position that could compromise their independence, such as being the head of the production department. In smaller companies, the Quality and Safety Responsible Person may also serve as the head of the quality management department.

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