China Animal Testing Free in Conditions since May 1st, 2021

On Mar 4, 2021, China NMPA finally released the formal version of “Management Standards of Cosmetics Registration and Filing Documents”. It specifically listed that imported general cosmetics will be exempt from animal testing from May 1st, 2021 under certain conditions.

Article 33:

(2) If the manufacturer of general cosmetics has obtained the relevant qualification certification of the production quality management system(GMP/ISO)issued by the government department of the country (region), and the product safety risk assessment result can fully confirm the safety of the product, it is exempted from animal testing, except for the following situations:

1. The product claims to be used by infants and children;

2. The product uses new cosmetic raw materials under safety monitoring period;

3. According to the quantitative grading and scoring results, the filing person, the domestic responsible person, and the production enterprise are listed as key supervision objects. (not full fill yet)


Condition 1: GMP Certificates

Please be great aware of the line in the article: “…has obtained…(GMP/ISO)issued by the government department of the country…”

It is indicated only the government released GMP certificate can be qualified for cruelty-free application.  

You may still remember a few months ago ANSM (National Agency for the Safety of Medicines and Health Products) from France announced the China animal testing free solutions for local companies. That is the case, ANSM from a government background would issue the GMP certificates for local cosmetic manufacturers and brands, so they will capable to enter China market freely.

However, in most circumstances, the government authority won’t issue a GMP certificate. The GMP certificates usually issued by cosmetic associations or international testing agency which will not be recognized by NMPA.

Good News is more countries are considered creating the GMP system: “The U.K. government is working closely with industry to create a certification system that will satisfy new Chinese regulations on cosmetics, following the removal of the requirement for animal testing on imported cosmetics,” said a U.K. Department of International Trade spokesperson.

Cosmetics Bridge note: Check your current GMP status to see it is qualified or not. If you are not sure, contact us for analysis.

Condition 2: Safety Assessment Report

Instead of Animal testing, a safety assessment report will be required for the cosmetics notification and registration.

However, there is no formal standard for the safety assessment report composing. Actually, NMPA issued a draft Technical Guidelines for Cosmetic Safety Assessment on July 29, 2020. But the draft Guidelines are not been delivered yet since the the requirement is too hard to fulfil for China cosmetics brands and manufacture.

Reasonable believe that the standard will be issued as well before May 1st, 2021.

Cosmetics Bridge Insights:

Since the draft guidelines of the safety assessment report are too hard for China cosmetics industry, an easy, medium level of guidelines will be published first as a transition. Please follow the cosmetics bridge for further information.

Further Reading:China NMPA issued the “Management Standards for Cosmetics Registration and Filing Documents”


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