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Registering and Accrediting Spa Products


Obtaining registration and accreditation from the relevant Chinese departments is the first and most important thing for overseas manufacturers in terms of launching their spa products in the Chinese market


tion. All Spa products in the cosmetics category require an application for registration to the State Food and Drug Administration for the Registration Credence of Imported Cosmet- ics for Non-Special Purpose or the Document for Hygiene Permit of Imported Cosmetics for Special Purpose. Spa products which are not related to cosmetics (for example, aro- matic essential oils that evaporate into the air when heated) need no registration. Applicants should be clear on the category of their prod- ucts before submitting an application. Also, relevant safety tests, including microbiological tests, hygienic chemical tests and toxicologi- cal tests, and possibly human tests should be completed before submitting the application, according to the State Food and Drug Admin- istration’s requirements. The registration and application process for


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spa products and ordinary daily use chemical skin care products is more or less the same and is usually divided into six steps: Primary Prepa- ration, Recording Authorization Letter on Reg- istration Responsible Party in China, Product Inspection, Application Document Preparation and Submitting, Application Document Veri- fication and finally Obtaining the Certificate. For spa products, it is important to distinguish whether the product is classified as a Cosmetic for Special Purpose or a Cosmetic for Non- special Purpose according to its functions and uses. They differ slightly in registration time and cost. The Cosmetics for Special Purpose refer to what we often call “functional products”, such as body shaping products and breast beautifying products. Cosmetics not belonging to the cate- gory of Cosmetics for Special Purpose are called as Cosmetics for Non-special Purpose. The second step is Customs clearance and commodity inspection (including Chinese


here are two steps to bring a foreign spa product into the Chinese market. The first step is product registra-


Labeling Record) for imported products. When importing products at a Chinese port, you should declare to the Customs office at the port and apply for commodity inspection (includ- ing Chinese label record) to the local Entry- Exit Inspection and Quarantine Bureau. The local Entry-Exit Inspection and Quarantine Bureaus will carry out basic tests and conform- ance tests according to the ingredients (such as preservatives, vitamins, etc.) and net content stated on the packaging, examine the applica- tion documents for Chinese Labeling Record and then issue The Imported Goods Inspection and Quarantine Certificate and Chinese Labe- ling Record Number. To complete the above-mentioned two


steps, applicants need to provide documents such as product formula, manufacturing proc- ess, product quality and safety control require- ment, Authorization Letter on Registration Responsible Party in China, Free Sales Cer- tificate issued by relevant organizations in the manufacturing country, safety assessment doc- uments for substances with potential safety risk existing in the product, as well as product samples for testing and verification. Apart from preparing sufficient documents


and materials, applicants should estimate the cost and time needed. With the help of a professional agent, it usually takes about 6-8 months from the start of the registration proc- ess to obtaining registration documentation, and costs about RMB11,000 for the registration of imported cosmetics for non-special pur- poses. As to imported cosmetics for special purposes, it usually takes 9-11 months, and the cost will differ greatly for different categories. For example, registering a hair-growing prod- uct will cost around RMB47,000. Applicants should arrange a registration schedule based on the launch plan in China. At the same time, it is necessary to set aside more time in case of delays caused by special cases.


Not all products pass the registration proc-


ess. During the fourth quarter of 2012, 83% of the cosmetics products for which applications were made passed the verification of the State Food and Drug Administration. The reasons for rejection mainly include product safety problems (for example, the documentation submitted was not sufficient to prove there was no safety issue with the product, or the prod- uct contains substances prohibited in China), inconsistent information (for example, the name of the product is not the same in differ- ent documents), providing false information, improper product name and documentation in wrong formats, etc. When submitting registration documents,


it is important to note the following tips: exag- gerated, false or determinate claims should not be used on packages. Claims of the efficacy as pharmaceutical products such as anti-allergy, treatment of arthritis or dermatitis cannot be used. The product name must be standardized rather than using arbitrarily abbreviated names or product codes as a substitute. Banned sub- stances including some medicinal ingredients or raw materials (such as exotic special plant components) should not be included in the product formula. False documentation like unauthentic product formula is not permitted. We remind you that if the State Food and


Drug Administration finds that the application documents are not authentic, the application will be rejected. In this case, the product can- not be submitted for registration again for a year. The State Food and Drug Administra- tion will issue a warning to the applicant and a public notice of criticism of the enterprise that provided false documentation. Once the products are successfully regis-


tered, overseas suppliers can ship these prod- ucts to China. After Customs clearance and commodity inspection, the products can be legally sold in the China market.


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