Cosmetics Alliance continues to pursue the establishment of a new Government issued GMP compliance certificate to facilitate the export of Canadian manufactured cosmetic products to China. CA is currently in discussions with HC on the details of a draft proposal for a voluntary Health Canada GMP Certificate Program. CA will formally submit the proposal once the details have been agreed to by government officials.
As previously reported, this compliance certificate was created under China’s new cosmetic regulations to exempt imported cosmetic products from its animal testing requirements and as such provides a significant opportunity for the Canadian cosmetic manufacturing industry. However, it MUST be issued by the government of the exporting jurisdiction which is not something that is part of the regulatory frameworks for cosmetics anywhere across the globe. GMP compliance certificates issued by third parties – including CA – have not been accepted as they are not issued by government.
Although the Chinese provision was officially implemented on May 1, 2021, neither CA, its member companies, or allied trade associations internationally are aware of any certificate that has yet been accepted by Chinese authorities. In fact, it may actually be the intention of Chinese authorities to make it essentially impossible to meet the exemption in order to bolster domestic Chinese products or force international companies to manufacture in China. Having the Canadian Government, as well as other governments, put this to the test by developing a reasonable and responsible pilot certification program – and to test if it would meet the Chinese requirements and if not, why – would assist in determining if this is a non-tariff barrier to trade for which some trade action could be considered.
Your CA Team will keep you updated on this important issue.
