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Are Microcrystal or Microneedle Products Considered Cosmetics in China?
Publication date:2023-12-15

On December 13, 2023, Guangdong Province of China released the 51st edition of the FAQ on the filing of cosmetics, which includes the following:

Q: Is there a time limit for using the pre-filing number?

A: Pre-filing numbers that have been issued or temporarily stored between January 1 and December 31 of each year should be submitted for filing before December 31 of the same year. Otherwise, they will be cleared and invalidated. Enterprises are advised to arrange the submission of filing materials reasonably and pay attention to relevant notifications from the system.

Q: Can food-related patterns be labeled on children's cosmetics?

A: According to Article 13 of the Regulations on the Supervision and Administration of Children's Cosmetics, the registrant, the filer and the entrusted manufacturing enterprise should take measures to avoid confusion between the properties, smells, appearance, etc., of children's cosmetics and those of food, drugs, and other products, in order to prevent ingestion or misuse. Children's cosmetics labels should not include words such as "food-grade" or "edible," or any food-related patterns.

Q: Are microcrystal or microneedle products considered cosmetics?

A: Products that claim to be microcrystal or microneedle products, using small needle-shaped materials such as hydrolyzed sponges or corresponding production techniques, and have effects by penetrating the skin or promoting product penetration, are beyond the scope of cosmetics as they are not applied to the surface of the skin.

Q: What should be particularly noted in the quality control of seaweed masks?

A: In the cosmetic sampling results reported by relevant departments this year, there were instances of excessive microorganisms in multiple batches of seaweed masks. The production process and storage conditions of seaweed masks should strictly control the microbial indicators. In addition, according to Announcement No. 74 of the National Medical Products Administration on the updated list of prohibited ingredients in cosmetics (2021), Semen Hyoscyami is a prohibited plant (animal) ingredient in cosmetics. It is strictly prohibited to mistake "Semen Hyoscyami" as "seaweed" for cosmetic production or filing/registration.

Q: How should the applicable skin types be described in the instructions for use?

A: It is not recommended to use vague expressions such as "suitable for multiple skin types," "suitable for various skin types," or "suitable for all skin types" in the instructions for use. The specific skin type that the product is suitable for should be clearly stated, such as dry, oily, or combination skin. If it is suitable for sensitive skin, the corresponding efficacy claims should be evaluated, and a summary of the efficacy evaluation basis should be provided.

Official source: https://scjgj.gz.gov.cn/zwdt/tzgg/content/post_9381628.html