Cosmetic product declaration

Frequently asked questions about cosmetics declaration.
Which are the cosmetic categories defined by the product's Chinese regulations?

Whether a product belongs to the category of cosmetics defined by my country’s laws and regulations is mainly considered from the following three aspects:

  1. The use method of the product should be rubbing, spraying, or other similar methods, such as rubbing, wiping, applying, etc., and products that achieve beauty purposes by oral, injection, etc. do not belong to the category of cosmetics.
  2. The part where the product is applied to the human body should be any part of the human body surface, such as skin, hair, nails, lips, etc., but teeth, oral mucosa, etc. are not in this category. At present, cosmetics defined by regulations do not include toothpaste and other products that come into contact with the oral mucosa.
  3. The function and purpose of use of the product should be for cleaning, eliminating bad odors, skincare, beauty, and modification. It does not have the function of preventing and curing diseases. This is also the essential difference between cosmetics and medicines. If the hand sanitizer has antibacterial and antibacterial publicity, it is a disinfection product.
What are special purpose cosmetics?

Special-purpose cosmetics refer to cosmetics with hair growth, hair dyeing, perming, hair removal, beauty milk, bodybuilding, deodorization, freckle whitening, and sun protection.

What tests need to be carried out for the product?

The cosmetics permit inspection report includes the sanitary safety inspection (microbiology, hygienic chemistry, toxicology) report and the human safety inspection report.

Can overseas reports be used?

Only the SPF report of special cosmetics can use the overseas report. The rest must be tested at the inspection agency designated by the administrative license (commonly include CDC, drug testing institutes, dermatological hospitals, etc.).

What are the components of the product declaration fee? How is the cycle?

The application fee consists of import formula label review, test supervision, and agency fees. The general declaration period for imported non-special cosmetics is 4-6 months, and the declaration period for imported special cosmetics is 6-8 months.

When can non-special use cosmetics not accept toxicology test?

If the risk assessment can confirm the safety of the product, the relevant toxicology test of the product can be exempted.

What is the overall analysis report of the formula of children's products?

The overall analysis report of the formula is to analyze the formula design and the safety of the product in combination with the raw materials used in the formula. The raw materials involved in the “Hygiene Standards for Cosmetics” that have restricted requirements should be described in conjunction with the restricted requirements.

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Cosmetic raw material declaration

What is the basis for judging new raw materials in China?

According to the “Name List of Used Cosmetic Ingredients” (2014.6.30 version)

The cycle and cost of new raw material declaration?

The cost of new raw material declaration consists of test supervision and file production, and the test cost depends on the specific substance. The reporting period is generally 1 to 2 years.

Can overseas test reports be used?

The overseas test report can be used for new raw material declaration, but the laboratory qualification certificate and its notarized copy are required, and the original test report shall be provided at the same time.

Is the in vitro toxicology test report available?

At present, CFDA only publicly solicits opinions on the 3T3 neutral red ingestion phototoxicity test. As the test method is still in the stage of soliciting opinions, the in vitro toxicology test report still cannot be used for new raw material declaration.