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Overview: China’s New CSAR Regulation

Issue Background 

New York – On January 3, 2022 the China State Council passed the Cosmetic Supervision and Administration (CSAR) regulation. Modernizing and replacing outdated laws, this directly affects the Chinese $53 Billion USD  market for beauty and personal care products.  Many of these regulations are standard across developed markets like the EU and the US but the change is being felt by the world’s top cosmetic brands. The regulation’s goals are “to regulate the production and business activities of cosmetics, strengthen the supervision and management of cosmetics, ensure the quality and safety of cosmetics” (State Decree No. 727).Changes mainly affect the introduction of new products into the market, with stricter safety protocols and after-market monitoring. For established products these new regulations will make the production and sales more streamline and digitalized.  

Key Points 

  • Key Point 1: Companies will be expected to show the burden of proof and submit scientific literature to back efficacy claims for products claiming new effects. 
  • Key Point 2: Products used for hair dyeing, perming, freckle whitening, sun protection, and anti-hair loss will fall under “special-use cosmetics” a new category and will have to go through special scrutiny and register with the Drug regulatory department of the State Council. 
  • Key Point 3: New ingredients introduced to the market will be monitored for risks for three years before they are included in the catalog of proven ingredients. 

Recommendations 

It is recommended that companies do their due diligence on the ingredients used in their cosmetic products. It is also recommended that for new products and  special use cosmetics (SUC) a system of post market surveillance be made for the three-year reports on new ingredients. 

FAO Global’s China experience & global reach can educate & facilitate compliance with CSAR for multinational operators in China. 

  1. China State Department: http://www.gov.cn/zhengce/content/2020-06/29/content_5522593.htm 
  1. NYT: https://www.nytimes.com/2012/09/25/business/estee-lauder-develops-a-brand-just-for-china.html 
  1. WSJ: https://www.wsj.com/articles/a-young-beauty-in-china-could-turn-investors-heads-11604315833