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(1)Common Questions During Cosmetic Review in China
Publication date:2022-04-25
Q1: Should the typeface and color of children’s cosmetic mark be consistent with those recommended in the notice?

A1: According to Childrens Cosmetic Supervision and Administration Regulation, children’s cosmetic mark should be labeled on the display panel of sales packaging of children’s cosmetic. To facilitate the consumers to identify, children’s cosmetic mark should be labeled in equal proportion on the top left of the main display panel of sales packaging so that it’s clear and easily identified. The whole children’s cosmetic mark is in gold. There is no mandatory requirement for the coloring matching information in the notice and children’s cosmetic enterprises can slightly adjust the typeface and color according to the actual packaging, but they should be clear and long-lasting, easily identified and read.

 

Q2: If there are flaws on the cosmetic label as stipulated in Article 20 of Measures for Administration of Cosmetic Label(hereinafter referred to as Measures), what measures can enterprises take to make corrections?

A2: If there are flaws on cosmetic labels that don’t affect the quality safety and mislead the consumers, enterprises should promptly make corrections. They can print and make the labels again or correct the flaws by means of sticking and covering. However the labels corrected should be clear and long-lasting, easily identified and read. There shall be no falling off of printing words, loose pasting, etc.

 

Q3: Should antioxidant, preservative and stabilizer added in the ingredient, protecting the ingredient be marked on product label?

A3: Measures stipulates, the ingredient standard Chinese name of all the cosmetic components on cosmetic label should be marked on the visual panel of sales packaging. Cosmetic components refer to those which are added into the product formula with a purpose during manufacturing process and take effects in the final product. For tiny amount of antioxidant, preservative, stabilizer added in the ingredient to ensure the cosmetic ingredient quality, even if they’re filled in in the product formula submission as the compound form of the ingredient when the registration or notification is applied for, they’re not categorized as cosmetic components and may not be marked on the product label. Of course, when the enterprise wants to protect consumers' right to know, they can also be marked on the product label.

 

Q4:Are there any requirements If the specific ingredient name or words indicating the ingredient category are used in the common name of cosmetic name?

A4: Measures stipulates if the specific ingredient name or words indicating the ingredient category are used, they should comply with the components in the product formula and the efficacy of product brought by the ingredient should comply with the product efficacy claims. For example, if the product name is “XX amino acid facial mask ” and it claims the efficacy of anti-wrinkle, then amino acid should be included in the formula and the purpose of use of amino acid should be anti-wrinkle-related. If the names of animal, plant or mineral are used to describe the flavor, color, or shape of a product, the ingredient may not be included in the formula. The product can be named in the form of names of animal, plant or mineral plus flavor, color, or shape in the common name, or the suffix note can be added behind the attribute name, eg. cucumber flavor cleanser or cleanser(cucumber flavor).

 

Q5: If there are components whose amount is not more than 0.1%(w/w) in cosmetic formula, how to mark them?

A5: As Measures stipulates, minor components refer to those whose amount is not more than 0.1%(w/w) in cosmetic formula. When there are minor components included in the product formula, “other minor components” should be marked as leading words to lead to another mark, which may not be listed in descending order according to the amount of the components. Minor components just need to be marked once, which will not be marked again behind the leading words “components”.

 

If you have any questions, please contact us: info@zmuni.com

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 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
  • Disinfectionproducts 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

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ZMUni Chinese Cosmetic Regulation Compliance Centre 中贸合规中心

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