Cosmetics - New changes New challenge by cosmetic packaging design companies

On December 8, the cosmetic filing system issued a notice stating that the general cosmetic filing information system has added a new "raw material safety information self-renewal" function, which allows for filing change applications when there is a change in the raw material supplier or a change in trace stabilizers and other ingredients. 

This also means that companies do not need to re-filing. Upon the release of the above notice, many industry insiders have said, "Great, no need to worry about the product to re-filing" "can change the supplier in the future" "the future product filing more flexible ". However, what needs to be taken seriously is that from January next year, new products will need to provide full ingredient safety information on raw materials, and old products will also need to make up raw material information information within the stipulated time limit, so a new round of tests are waiting for everyone. 

Change of raw materials, trace preservatives, etc., no need to re-record It is reported that the new "raw material safety information update" function contains 2 main aspects: First, the product has been recorded using raw materials manufacturers, raw material quality specifications increase or change, the raw materials used in the formulation of the content and the specific ingredients in the type of raw materials, the proportion of The proportion has not changed, can be updated through the "raw material safety information self-update" function to update maintenance. 

Secondly, the content of raw materials in the formula and the content of the main functional ingredients in the ingredients and solvents have not changed, in order to ensure the quality of raw materials and add trace stabilizers, antioxidants, preservatives and other components of the type or content changes need to initiate filing change applications, in the change application to modify. For the above two update functions, a number of regulatory engineers said to Green Eye, "This means that if a company changes the supplier of raw materials in a product or if a trace ingredient such as a preservative or stabiliser in a product changes, the product does not need to be filed again, but only needs to be changed. 

This solves the problem that many companies are currently facing." However, the above-mentioned industry sources also said that the 2 policies of "relaxation" are prerequisites. For example, in the first, although companies can change the supplier of raw materials, but the premise is that the specific types of ingredients and ratios in this raw material are not changed. 

For the second update, the core premise is that the content of the main functional ingredients and solvents in the raw material has not changed, "that is, the only thing that can change is the preservatives in the raw material, stabilizers and other auxiliary role of trace ingredients. It is worth noting that in the second update, when trace amounts of stabilisers, antioxidants, preservatives and other ingredients in the raw materials have changed in type or content, it is also necessary to apply for changes in the record. 

For this case, according to the "Cosmetics Registration and Filing Information Management Regulations" Article 42, companies should submit an application form for special cosmetic changes or information sheets for general cosmetic changes; product formulations; a description of the circumstances under which the change occurred, including the reasons for the change, the purpose of use of the changed ingredients in the raw materials, etc.; 

product safety assessment of the product to be changed and other information. In addition, if there is a change in the standard of implementation of the product, the standard of implementation of the product to be changed should be submitted; if the matter to be changed involves a change in the labeling of the full composition of the sample product, such as changes in safety warning terms, the sample product labeling of the product to be changed should be submitted. 

Some industry professionals raised the concern that "if the preservatives in the raw materials change, it will cause differences between the actual formula sheet on file and the ingredient list on the product label". In this regard, a senior industry regulatory engineer said that in July this year, the State Drug Administration issued a "cosmetic supervision and management FAQ (V)" has made it clear that "in order to ensure the quality of cosmetic raw materials in the raw materials added to the extremely small amounts of antioxidants, preservatives, stabilizers and other ingredients can be marked, or not marked. "  

When the raw material submission code application platform went live on December 30 last year, many industry players believed that the raw material submission code would further deepen the bond between cosmetic registrants/recorders and raw material suppliers. Companies encounter raw materials out of supply or change raw material suppliers, the registrant / filer will have to change the raw material information. There are even factory managers who say, "Suppose the original supplier doesn't have enough raw materials to make a pot of ingredients, it's just sitting there waiting." 

Now, it seems that with the new function of "self-updating raw material safety information", the above problems will be solved. According to Zhang Taijun, director of research and development at the TWS Biotechnology Research Institute, this is actually more conducive to full competition in the market and does not allow administrative means to interfere with market competition. "For example, if a company starts out using raw materials from company A, if there are other companies with equivalent raw materials at a lower price, the company can always replace them, instead of being afraid to do so for fear of violating the rules."

 A similar view was expressed by an industry source who did not want to be named, saying that to a certain extent, this could also be used when raw materials are not available, to solve the urgent needs of enterprises. Not only this, the previous cosmetic filers in accordance with the provisions of the new platform to claim the old products, and old product information to make up the record, there are also factories generally reflect "part of the raw material suppliers to provide information inconsistent, so that product information to make up the dilemma" of the situation. 

The main reason for this is that many raw material suppliers in the new rules before the provision of raw material information only active ingredients, but in the new rules, raw material suppliers are required to fill in the full composition of raw materials, so more than a few auxiliary ingredients. "According to the new raw material information for the record, it will be inconsistent with the old product label; according to the old raw material information to fill in, it does not meet the product record information and the actual production of raw material information consistent with the provisions. It really puts us in a dilemma." The person in charge of a factory in Guangzhou introduced, "

At that time, we had to re-filed some simple efficacy of the wash and care products in order to solve this dilemma, and some skin care products in the wait and see. Now the raw material safety information of the products can be changed, so we don't have to struggle to re-filing, after all, the cost of re-filing is not small." According to Li Bin, deputy general manager of Zhongshan Lichang Quality Management Service Co Ltd, "Overall, the new function is definitely good for enterprises, at least it clarifies the scope of changes that can be made." 

However, he also said that because some of the raw materials have changed, there are still some cases where the main ingredients of the raw materials have changed, and when this happens, the company will have to file again. A regulatory engineer who has been in the industry for nearly 20 years believes that the new "raw material safety information self-renewal" function will make cosmetics filing more flexible. 

In his opinion, "the core purpose of the State Drug Administration to set up raw material reporting codes is still safety and traceability, so the system should be set up in a more convenient direction for details that do not affect the safety of raw materials." Another new regulation implementation into the countdown State Drug Administration at this time to add "raw material safety information updated by itself" function, and the upcoming implementation of the new regulation node requirements are closely related.