ZMUni Compliance Centre

During our Jan. 18 webinar【New Rules on Children’s Cosmetics in China】, our audiences raised some really INFORMATIVE and PRACTICAL questions that may help you with your products registration or notification in China. Let’s check out:

Q1: Is efficacy claims the only claims we can make?

A1: No, besides the efficacy claims, you also can claim the character of the products, for example  tear free, for sensitive skin, etc.

Q2:With anti-counterfeiting technology: Do you mean like a numbered hologram sticker for instance?

A2: Yes,it is.

Q3: Do the fragrances used in the products need to be ALLERGEN FREE?

A3: According to our experience, for the children cosmetic, we suggest to use the allergen free ingredient, or, the concentrations of the allergens are under the limit of the EU label claim requirements.

Q4: How to define an ingredient is still in the monitoring period please?

A4: First,It means the cosmetic ingredients used for children/infant have to be found in the "IECIC 2021"(Inventory of Existing Cosmetic Ingredients in China). Second, If the ingredient can NOT be found in the "IECIC 2021", it will count as New Ingredient, which need to be registered or notified to the Chinese NMPA first before you can register or notify your cosmetic product. And the NMPA monitoring period for new cosmetic ingredient is usually about 3 years.

Q5:Does the notifier or registrant be located in China? is it OK to be the manufacturers/brand owner from overseas?

A5: Of course, the notifier and registrant can be the overseas companies.

Q6: I noticed, at the beginning of your presentation, that only 17 sunscreen brands are currently labeled as 'suitable for children? Is that correct?

A6: Because the children cosmetic for sunscreen is the special cosmetic, the registration is NOT easy. we collected the data as of October 20th, 2021. WHICH ONLY INCLUDED THE registration certificate that’s within the expiration date.

Q7: What is meant by the ' Product executive standard number' as required on the product label?

A7: For the general cosmetics, the Product executive standard number is equal to the product notification number.

Q8: The requirement is: "Product shall not be irritating etc". We could perform an HRIPT-test or animal testing, but it does not eliminate the chance of irritation completely. How to handle an occasional complaint? Does that easily affect our eligibility to sell the product as a children’s product?

A8: First, the product shall pass the animal test for notification, for the occasional complaint, you shall establish the quality management system in which a Product Quality Traceability System shall be included. This question is complicated, you can contact us by email.

Q9: Is the responsible person required to be in located in China?

A9: Yes, if you are going to sell your cosmetics in China, you shall authorize a Chinese responsible person, this RP shall be located in China mainland.

Q10: What is beautifying in Chinese please？

A10: "Beautifying" means make someone or something more attractive or beautiful in Chinese. For example, I could use lipsticks to put on my lips to make myself look good, which is what the "beautifying" means in this stage.

If you have other questions, you can send them to our email address: : info@zmuni.com  We’ll be happy to help you at any time.

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ZMUni Chinese Cosmetic Regulation Compliance Centre 中贸合规中心

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