As our relevant article posted before, “Children’s Cosmetics Supervision and Administration Regulation” in China(hereinafter referred to as “CCSAR”)was released by NMPA on 8 Oct. 2021, here ZMUni is going to guide you quickly through key points you must know about “CCSAR”
?How does “Children’s Cosmetics Supervision and Administration Regulation” define children’s cosmetics?
According to “Children’s Cosmetics Supervision and Administration Regulation”, children’s cosmetics refer to cosmetics that are suitable for children under 12 years old (including 12) and have efficacy of cleansing, moisturizing, refreshing and sunscreen, etc.
NOTES: Claims such as “ can be used by anyone” or “can be used by the whole family”, trademarks, patterns, homophones, letters, Chinese pinyin, numbers, symbols, packaging, etc. which imply that the product users include children shall be managed as children’s cosmetic.
?What should we pay special attention to regarding children’s cosmetics mark?
- Children’s cosmetics shall be marked with the children’s cosmetics logo stipulated by National Medical Products Administration(NMPA) on the display surface of the sales package.
- Non-children’s cosmetics shall not be marked with children’s cosmetics logo.
- “Attention” or “warning” shall be used as the guiding words for children’s cosmetics, and warning words such as “should be used under adult supervision” shall be marked on the visual surface of the sales package.
- Person responsible for cosmetics registration and notification are encouraged to apply methods such as anti-counterfeiting techniques on the labels of children’s cosmetics for consumers to identify and select legal products.
?When it comes to quality safety, what obligations should cosmetic registrants, notifiers, manufacturers and operators perform?
- Cosmetic registrants and notifiers are responsible for the quality safety and efficacy claims of children’s cosmetics.
- Cosmetics manufacturers and operators shall engage in production and operation activities in accordance with laws, regulations, mandatory national standards, and technical specifications, strengthen the quality management of children’s cosmetics, honest and self disciplined, and ensure product quality safety.
- Cosmetic registrants and notifiers shall based on the child’s physiological characteristics and possible application scenarios research and develop children’s cosmetics, following the principles of scientificity and necessity.
?Do you know formula design principles of children’s cosmetics and product safety evaluation?
General principle of formulation design of children’s cosmetics : safety first, essential efficacy only, extremely simple formula
- Cosmetics raw materials with long-term safe use history shall be selected, and new cosmetic ingredients still in the monitoring period shall not be used. Raw materials prepared by new technologies such as gene technology (GMO) and nanotechnology are not allowed.
- The scientificity and necessity of children’s cosmetics raw materials should be evaluated based on the safety, stability, function and compatibility of them, combined with the physiological characteristics of children.
Children’s cosmetics shall conduct product safety evaluation through safety assessment and necessary toxicological tests.
When cosmetics registrants and notifiers conduct safety assessments of children’s cosmetics, the physiological characteristics of children should be considered in aspects such as identification of harm and calculation of exposure.
?Can “food grade” children’s cosmetics be eaten?
Children’s cosmetics shall be produced in accordance with the requirements of the cosmetics production quality management specifications, and the environmental requirements of the production workshops of children’s skincare cosmetics shall comply with relevant regulations.
Cosmetic registrants, notifiers, and entrusted manufacturing enterprises shall take measures to avoid confusion between children’s cosmetics and food, medicines & other products because of the similarities in characteristics, smell, appearance and shape, and to prevent wrong ingestion and misuse.
Labels of children’s cosmetics shall not be marked with words such as “food grade”, “edible”, or food-related patterns.
The regulatory team of ZMUni Regulatory Compliance Centre has rich experience in registration and notification of children’s cosmetics. Based on our experience, the key point of children’s cosmetics notification and registration is that the product formula must meet all the requirements of Chinese children’s cosmetics related regulations.
ZMUni regulatory compliance services in China include:
- Registration Service of Special Cosmetic Products
- Filing/Notification Service of General Cosmetic Products
- Infant/Children General Cosmetic Products Filing/Notification Service
- Infant/Children Sunscreen Cosmetic Products Registration Service
- New Cosmetic Ingredients (NCI) Filing/Notification and Registration Service
- Chinese responsible agency service
- Apply for CITES permit or certificate of endangered species service
- Toothpaste Filing/Notification Service
- Mouthwash etc. Dental Care Products regulatory compliance Service
- Custom clearance service
- Disinfection products Filing/Notification Service
- Anti-bacterial products Filing/Notification Service
- QMS (Quality Management System) service
- ACR (Adverse Cosmetic Reaction) Service
- Labelling Reviews
- Regulatory Dossiers
- Compliance Solutions
- Regulatory Support
ZMUni Chinese Cosmetic Regulation Compliance Centre 中贸合规中心