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KnowledgeLatest NewsNews & InformationRegulations19/08/2022Can’t we notify/register products without permitted preservatives in them?

Along with people’s growing demand for becoming beautiful, the demand for skincare products is gradually diversified. For sensitive skin consumers, low-irritation skincare products have definitely become their first choice. Due to this situation, lots of cosmetic enterprises begin launching products with non-chemical preservative.

Since we posted “Turn pale at the mention of preservatives”? Don’t be that way! – ZMUni Chinese Cosmetic Regulation Compliance Center, many cosmetic enterprises from home and abroad came to consult us with various questions. In response to Frequently Asked Questions from those enterprises, the answers are organized by ZMUni as follows:


Q: Is it necessary to add in the products the permitted preservatives prescribed in Safety and Technical Standards for Cosmetics(STSC)?

A: There is no mandatory requirement in STSC for cosmetics that they must use the permitted preservatives in STSC. Cosmetic enterprise can keep products from deteriorating through other preservative technology, they may not add permitted preservatives.


Q: If the products don’t add the permitted preservatives prescribed in STSC but add plant preservative ingredients, can we notify/register the products?

A: According to Article 6 of CSAR, cosmetic registrants, notifiers claim responsibility for quality safety and efficacy claims of cosmetics. Combine the answers to Question 1, as long as cosmetic enterprises could ensure the quality safety of the product and provide scientific, reasonable preservative challenging test report and stability test report as well, the product can be notified/registered. It is worth noting that purpose of use of the plant preservative ingredient can’t be preservative.


Q: Are there any requirements for preservative challenging test and stability test? Must these tests be done in designated labs in China?

A: In regard to preservative challenging test and stability test, currently there is no regulation basis or guidelines guiding the enterprises to do the tests. Enterprises may conduct the tests in accordance with industry standards or test method from other countries. It’s Okay when the test process and test result are true, scientific and reasonable.

There is no requirement for preservative challenging test and stability test to be performed in designated laboratories in China, and enterprises can choose their own test institutions according to their own circumstances. (Note: When test report from abroad is submitted for notification/registration, the report shall be translated into standard simplified Chinese.)


ZMUni tips

Cosmetics, whether in the production process, or the process of use will face the risk of microbial contamination, so only the scientific and reasonable anti-corrosion system is capable of guarding the quality and safety of the product. Whether it is the addition of permitted preservatives in STSC, or through other preservative technology to achieve the effect of anti-corrosion, the purpose is the same. Only enterprises achieve compliance, the enterprise can go long term.


If you have any questions, please contact us:

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
  • Cosmetic Ingredients Code Application Service
  • Cosmetic Efficacy Claim Evaluation Service
  • Chinese responsible person 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

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