ZMUni Compliance Centre

On December 16, 2025, China's National Institutes for Food and Drug Control (NIFDC) released two cosmetic technical guidance documents, including the Technical Guidelines for Anti-Hair Loss Products (Trial) and Technical Guidelines for Research on Efficacy-Related Ingredients in Anti-Hair Loss Cosmetics (Trial), together with the corresponding Q&A. The draft versions of these documents were previously released for public consultation in September 2025.

Key Highlights from the Q&A:

Q1: What ingredients are considered efficacy-related ingredients for anti-hair loss cosmetics?

A: Efficacy-related ingredients for anti-hair loss cosmetics are divided into two categories:

• Anti-hair loss agents, which are single ingredients or components within ingredients composed of multiple components that have been demonstrated through research to have anti-hair loss effects and are declared in the formulation as anti-hair loss agents.

• Anti-hair loss auxiliaries, which support or enhance the anti-hair loss effect and are declared in the formulation as anti-hair loss auxiliaries.

In general, for ingredients composed of multiple components, it is not required to identify individual components acting as anti-hair loss auxiliaries. Anti-hair loss auxiliaries may be used alone or in combination with anti-hair loss agents in cosmetic products.

Q2: How should interference from other ingredients be excluded when evaluating the efficacy of declared anti-hair loss agents?

A: As a general principle, test substances may be prepared by simply dissolving or dispersing the declared anti-hair loss agent based on its use in the reference product. The composition of the test substance should be clearly described, and the potential influence of other ingredients on the evaluation results should be assessed, such as effects on hair smoothness or hair growth stimulation.

If ingredients other than solvents or dispersants are necessary (for example, preservatives), their necessity should be justified, and objective evidence should be provided to demonstrate that they do not affect the anti-hair loss efficacy evaluation.

Q3: Can efficacy-related ingredients for anti-hair loss be used in product claims?

A: Anti-hair loss agents may be claimed for anti-hair loss efficacy on product labels; Anti-hair loss auxiliaries must not be used to support anti-hair loss efficacy claims on product labels.