INTERNATIONAL TRADE NEWS

CHINA FINALLY EXEMPTS IMPORTED COSMETICS FROM ANIMAL TESTING

In March 2021, Chinese regulators made headlines when they announced a change to animal testing requirements that the country had previously maintained for imported cosmetics.

The change, which came into effect on May 1st of this year, exempts mandatory premarket animal testing for general imported cosmetics, and stands to have significant implications for Irish cosmetics brands.

The mandatory animal testing requirements imposed by Beijing on imported cosmetics have posed a major dilemma for many cruelty-free brands. Until now, only companies that manufacture locally in mainland China were able to bypass mandatory animal testing.

While China has not banned animal testing for all cosmetics, the new regulations provide a pathway for Irish, and any other cosmetic and beauty brands, to enter the China market and remain cruelty-free, including shampoo, skincare, body wash, lipstick, and makeup.

While these ‘general’ cosmetics will be excluded from mandatory animal-testing and require a simple declaration, ‘special use’ products (including hair dyes, hair perming products, freckle-removing and whitening products & more) will require registration with the National Medical Products Administration and are likely to require animal testing.

Nonetheless, this is a hugely significant change, given that China is now the secondlargest cosmetics market after the U.S. The Chinese cosmetics and beauty market is expected to record a value of US$87.64 billion in 2025, increasing at a CAGR of 6%, for the duration spanning 2021-2025.

Factors, other than the loosening of restrictions on testing, which are predicted to drive growth in the Chinese market, are: a growing female population, an upsurge in demand for natural and organic cosmetics, an escalating number of social media users, rapid urbanization and strong brand awareness among young consumers.

The primary regulatory hurdle that brands need to be aware of is the appointing of a Domestic Responsible Agent. Legally, the main requirement is that the Domestic Responsible Agent must be based in China.

Companies who already export to Russia or the U.S. will be familiar with the requirement to appoint a local contact to look after importation and official documentations.

Domestic Responsible Agents for Irish brands are likely to be one of the following…

A Chinese Importer or Distributor (A buyer) Or A Regulatory Expert, Consultant or Agent

For more information on the new regulations, domestic responsible agents, or new opportunities in China in general, please feel free to reach to Tadhg Morris at tmorris@WTCDublin.ie.