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A Collection of Obligatory Safety Warnings on the Chinese Labels of Cosmetics

In recent years, the surge in applications for cosmetic registration and notification in China has been accompanied by a noteworthy proportion of rejections. Among these cases, label non-compliance stands out prominently. This encompasses various aspects, such as incomplete label content, false or exaggerated efficacy claims, inconsistencies between ingredients in product names and formulas, improper labeling of shelf life, omission of mandatory warnings and instructions, and more. This article comprehensively compiles the regulations concerning the obligatory safety warnings on cosmetics' labels in the Chinese market.

General Requirements

As per the Administrative Measures on Cosmetics Labeling, the safety warning is an integral part of Chinese cosmetics label, referring to the content that must be present on the label as mandated by laws, administrative regulations, departmental rules, mandatory national standards, technical specifications, etc. 

The Chinese label of cosmetics shall include at least the following contents:

  1. Product’s Chinese name and special cosmetic’s registration certificate number;

  2. Name and address of the registrant or notifier. If the registrant or notifier is an overseas enterprise, the name and address of the domestic responsible person shall also be labeled;

  3. Name and address of the production enterprise. For domestically produced cosmetics, the production enterprise’s production license number shall also be labeled;

  4. Product’s executive standard number;

  5. All ingredients;

  6. Net content;

  7. Durability;

  8. Application method;

  9. Necessary safety warnings;

  10. Other contents that shall be labeled as prescribed by laws, administrative regulations and mandatory national standards. 

This information should follow the guide words "Caution:" or "Warning:" and be placed on the visible panel of the sales packaging. 

20230829103631.jpgSource: Nail enamel (JD.com)Currently, safety warnings are necessary for: (1) 49 restricted and permitted ingredients outlined in the Safety and Technical Standards for Cosmetics (STSC); (2) 15 cosmetics categories specified by national and industry standards; (3) certain special cases, such as cosmetics designed for children.

Ingredients Requiring Safety Warnings Labeling in STSC

  • Restricted Ingredients

No.

INCI/English Name

Use instructions and warnings that must be indicated on labels

1

Benzalkonium chloride, bromide and saccharinate

Avoid contacting eyes.


Notes: If the use purpose is not preservative, the ingredient and its function must also be indicated on the product label.

2

Salicylic acid

Contains salicylic acid.

Not for use by children under three years of age (It should be labeled only if the products are possibly used by children under three and will have contact with the skin for a long period.)


Notes: If the use purpose is not preservative, the ingredient and its function must also be indicated on the product label.

3

Strontium peroxide

Avoid contacting eyes. Rinse immediately if the product goes into eyes.

Only for professional use.

Wear proper gloves.

4

Resorcinol

Contains resorcinol

5

Selenium disulfide

Contains selenium disulfide.

Avoid contacting eyes or wounded skin.

6

Strontium chloride

Contains strontium.

Not suitable for frequent use by children.

7

Dimethylol ethylene thiourea

Contains dimethylol ethylene thiourea.

8

Hydrogen peroxide, and other compounds or mixtures that release hydrogen peroxide, including carbamide peroxide and zinc peroxide

a) Hair Products: Wear proper gloves.

Contains hydrogen peroxide.

Avoid contacting eyes. Rinse immediately if the product goes into eyes.


b) Skin Products:

Contains hydrogen peroxide.

Avoid contacting eyes. Rinse immediately if the product goes into eyes.


c) Nails hardening Products:

Contains hydrogen peroxide.

Avoid contacting eyes. Rinse immediately if the product goes into eyes.

9

Oxalic acid, its esters and alkaline salts

Only for professional use.

10

Calcium hydroxide

a) Hair straight-perming products containing calcium hydroxide and guanidine salts:

Contains strong base.

Avoid contacting eyes. May lead to blindness.

Prevent children’s access.


b)  pH modifier for depilating products:

Contains weak base.

Avoid contacting eyes.

Prevent children’s access.

11

Inorganic sulfites and hydrogen sulfites

If the use purpose is not preservative, the ingredient and its function must also be indicated on the product label.

12

Lithium hydroxide

(a) Hair straight-perming products:

1. General use:

Contains strong base.

Avoid contacting eyes. May lead to blindness.

Prevent children’s access.

2. Professional use:

Only for professional use.

Avoid contacting eyes. May lead to blindness.

 

(b) pH modifier for depilating products:

Contains strong base.

Avoid contacting eyes.

Prevent children’s access.

13

(1) Thioglycollic acid and its salts

(a) Hair perming products:

Contains thioglycollates.

Follow the use instructions.

Prevent children’s access.

Only for professional use.

The following instructions are required: Avoid contacting eyes. Rinse immediately with large amount of water if the product goes into eyes, and seek doctor’s advice.

 

(b) Depilating products:

Contains thioglycollates.

Follow the use instructions.

Prevent children’s access.

The following instructions are required: Avoid contacting eyes. Rinse immediately with large amount of water if the product goes into eyes, and seek doctor’s advice.

 

(c) Other rinse-off hair products:

Contains thioglycollates.

Follow the use instructions.

Prevent children’s access.

The following instructions are required: Avoid contacting eyes. Rinse immediately with large amount of water if the product goes into eyes, and seek doctor’s advice.

(2) Thioglycollic acid esters

Contains thioglycollates.

Follow the use instructions.

Prevent children’s access.

Only for professional use.

The following instructions are required: Avoid contacting eyes. Rinse immediately with large amount of water if the product goes into eyes, and seek doctor’s advice.

14

Silver nitrate

Contains silver nitrate.

Wash immediately if the product goes into eyes.

15

(1) Alkali sulfides

Prevent children’s access.

Avoid contacting eyes.

(2) Alkaline earth sulfides

Prevent children’s access.

Avoid contacting eyes.

16

Strontium hydroxide

Prevent children’s access.

Avoid contacting eyes.

17

Aluminium zirconium chloride hydroxide complexes; AlxZr(OH)yClz and the aluminium zirconium chloride hydroxide glycine complexes

Not for use on wounded or irritated skins.

18

Zinc phenolsulfonate

Avoid contacting eyes.

19

Potassium hydroxide, sodium hydroxide

a) Solvent of the protective films for nails:

Contains strong base.

Avoid contacting eyes. May lead to blindness.

Prevent children’s access.

 

b) Hair straight-perming products

1. General use:

Contains strong base.

Avoid contacting eyes. May lead to blindness.

Prevent children’s access.

2. Professional use:

Only for professional use.

Avoid contacting eyes. May lead to blindness.

 

c) pH modifier for depilating products:

Avoid contacting eyes.

Prevent children’s access.

20

Talc: hydrated magnesium silicate

Powder products for children under the age of three:

Keep the powder away from children’s nose and mouth.

21

a-Hydroxy acids and their salts, esters

If it is used in non-sunscreen skin care cosmetics and contains ≥3% α-Hydroxy acids, or claims α-Hydroxy acids on the label, it should indicate "use the product together with sunscreens".

22

Ammonia

The product shall indicate “contains ammonia” when it contains more than 2% ammonia.

23

Dichlorophen

Contains dichlorophen.

24

Alkyl(C12-C22) trimonium chloride

If the use purpose e is not preservative, the ingredient and its function must be indicated on the product label.

25

Benzoic acid

Sodium benzoate

If the use purpose e is not preservative, the ingredient and its function must be indicated on the product label.

26

Phenoxyisopropanol

If the use purpose e is not preservative, the ingredient and its function must be indicated on the product label.

27

Zinc pyrithione

If the use purpose e is not preservative, the ingredient and its function must be indicated on the product label.

28

Inorganic sulfites and hydrogen sulfites

If the use purpose e is not preservative, the ingredient and its function must be indicated on the product label.

29

Benzyl alcohol

If the use purpose e is not preservative, the ingredient and its function must be indicated on the product label.

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  • Permitted Preservatives

No.

INCI/English Name

Use instructions and warnings that must be indicated on labels

1

Benzalkonium chloride, bromide and saccharinate

Avoid contacting eyes.

2

Chlorobutanol

Contains acetone chloroform

3

Glutaral

Contains glutaraldehyde (It should be labeled only if the concentration of glutaraldehyde in product exceeds 0.05%).

4

Iodopropynyl butylcarbamate

Not for use by children under three years of age (It should be labeled only if the products are possibly used by children under three, except for the bath products and shampoos).

5

Salicylic acid and its salts

Contains salicylic acid.

Not for use by children under three years of age (It should be labeled only if the products are possibly used by children under 3 and will have contact with the skin for a long period).

6

Phenylmercuric salts (including borate)

Contains benzenemercury compound

7

Thimerosal

Contains merthiolate

Notes: For cosmetics containing substances that can release formaldehyde, if the formaldehyde concentration in the finished product exceeds 0.05% (calculated in free formaldehyde), they must be marked "contains formaldehyde" on the product label, and are prohibited for use in spray products.

  • Permitted Sunscreens

No.

INCI Name

Use instructions and warnings that must be indicated on labels

1

Benzophenone-3

Contains benzophenone-3

  • Permitted Hair Dyes

No.

INCI/English Name

Use instructions and warnings that must be indicated on labels

1

1-Naphthol (CI 76605)

Contains 1-napthol

2

2-Methylresorcinol

Contain Methylresorcinol

3

N,N-bis(2-hydroxyethyl)-pphenylenediamine sulfate

Contains phenylenediamines

4

N-phenyl-p-phenylenediamine

Contains phenylenediamines

5

N-phenyl-p-phenylenediamine HCl

Contains phenylenediamines

6

N-phenyl-p-phenylenediamine sulfate

Contains phenylenediamines

7

p-Phenylenediamine

Contains phenylenediamines

8

p-Phenylenediamine HCl

Contains phenylenediamines

9

p-Phenylenediamine sulfate

Contains phenylenediamines

10

Toluene-2,5-diamine

Contains phenylenediamines

11

Toluene-2,5-diamine sulfate

Contains phenylenediamines

12

Resorcinol

Contains phenylenediamines

Notes: In addition to the instruction and warnings specified in the above table, the following warnings must be marked on the labels of hair coloring products:

  • Hair dyes may cause severe allergic reaction.

  • Read the instruction before use and do as required.

  • This product is not suitable for consumers under the age of 16.

  • Not for use at eyebrows or eyelashes.

  • If the product goes into eyes s, rinse immediately.

  • Wear proper gloves when the product is applied in professional use.

  • Please do not dye hairs in case of rash on the face, inflammation, allergy, or wound of the scalp happen, or if the user has history of adverse effects caused by hair dyes.

Cosmetic National or Industry Standards Requiring Safety Warnings Labeling

No.

Standard Name

Use instructions and warnings that must be indicated on labels

1

GB/T 27574-2011 Mascara

  1. Do not use the product into eyes;

  2. Upon usage, please tighten the lid immediately to avoid the product drying too fast;

  3. For contact lens wearers, please take out the contact lenses before removing the mascara;

  4. Keep in a cool place and away from direct sunlight;

  5. Do not use in cases of eye discomfort, such as inflammation, infection, or injury.

2

QB/T 1858.1-2006 Florida Water

Precautions for safe use such as “use and keep away from fire sources” shall be marked.

3

GB/T 35955-2018 Anti-perspiration (Fragrant) Liquid (Lotion, Spray, Paste)

  1. Products added with aluminium zirconium chloride hydroxide complexes [A1xZr(OH)yClz] and/or aluminium zirconium chloride hydroxide glycine complexes antiperspirant should be marked with warnings such as "This product shall not be used on irritated or damaged skin and shall be kept out of reach of children."

  2. Products added with zinc phenolsulfonate antiperspirant should be marked with warnings such as "This product should avoid contact with eyes and keep out of reach of children."

  3. For aerosol can products, the requirements in BB/T 0005-2010 shall be followed at the same time.

4

GB/T 26516-2011 Massage Essential Oil

  1. Do not use internally;

  2. Do not apply directly to the skin;

  3. Not suitable for pregnant women, infants, as well as individuals with hypertension, kidney disease, epilepsy, or damaged skin. Sensitive skin users shall perform a patch test prior to use.

5

QB/T 4079-2010 Massage Base Oil, Massage Oil

1) The massage base oil must specify the specific type of vegetable oil added to the product.

2) The massage oil should be marked with the following content:

  1. Types and contents of massage essential oils;

  2. The type of vegetable oil added to the massage base oil;

  3. Avoid contact with the area around the eyes;

  4. Do not use internally;

  5. Not suitable for pregnant women, infants, as well as individuals with hypertension, kidney disease, epilepsy, or damaged skin. Sensitive skin users shall perform a patch test prior to use;

  6. Store away from light, sealed and at low temperature.

6

QB/T 2287-2011 Nail Enamel

  1. The sales packaging of organic solvent-based nail enamel should be marked with "Warning/Cautions: Flammable. Keep away from high temperature and fire sources." or other similar warnings.

  2. If the concentration of formaldehyde in the formula exceeds 0.05%, the label should indicate: "Contains formaldehyde. Please protect the skin with oil."

  3. The labels on the sales packaging can be marked with: "Avoid contact with chemical fiber fabrics while nail enamel is still wet", "Use with caution for children" (excluding nail enamel for children) or other similar precautions.

7

QB/T 4364-2012 Nail Enamel Remover

The visible panel of the nail enamel remover sales packaging should be marked with warnings such as "Warning/Cautions: Flammable. Keep away from high temperature and fire sources. Keep out of reach of children. Children should only use this product under adult supervision."

8

GB/T 29678-2013 Permanent Wave

Curling agent (straightening agent) and hydrogen peroxide type styling agent should be marked as follows:

 

1) Curling agent (straightening agent):

  1. Avoid contact with eyes;

  2. If the product accidentally gets into eyes, rinse with plenty of water immediately and seek medical treatment;

  3. Wear suitable gloves;

  4. Contains thioglycolate;

  5. Use according to the instructions;

  6. Keep out of reach of children;

  7. For professional use only (general-use products have no need to be marked with this item);

  8. Individuals with a history of perm product allergies should refrain from using. Do not use this product if the scalp is damaged.


2) Hydrogen peroxide type styling agent:

  1. Wear suitable gloves;

  2. Contain hydrogen peroxide;

  3. Avoid contact with eyes;

  4. If the product accidentally gets into eyes, rinse immediately;

  5. Use according to the instructions;

  6. Keep out of reach of children;

  7. For professional use only (general-use products have no need to be marked with this item);

  8. Individuals with a history of perm product allergies should refrain from using. Do not use this product if the scalp is damaged.

9

QB/T 4126-2010 Hair Bleaching Preparation

  1. Please read the following important information before use, and operate in strict accordance with the instructions;

  2. Keep this product out of children's reach and refrain from applying it to children's hair;

  3. Properly wear suitable gloves;

  4. Do not use on eyebrows or eyelashes;

  5. Remove contact lenses before use. Prevent any contact of the prepared mixture with the eyes. In case of accidental eye exposure, rinse immediately with water. In case of any discomfort, immediately seek medical attention.

  6. This product may trigger allergic reactions. If any discomfort arises (including redness, burning, pain, and itching), cease further application and consult a doctor;

  7. Refrain from using this product on uncomfortable, red, or damaged scalp;

  8. Do not use on fragile or damaged hair. It's recommended to use the product up to only once within 24 hours;

  9. Employ solely plastic or glass tools, clips, or combs. Strictly avoid the use of metal tools;

  10. Bleaching agents must be labeled: "Avoid inhalation."

10

QB/T 5108-2017 Hair Removal Cream (Lotion)

  1. Contains thioglycolate;

  2. Use according to the instructions;

  3. Keep out of reach of children;

  4. Avoid contact with eyes. If the product accidentally gets into eyes, rinse with plenty of water immediately and seek medical treatment;

  5. This product might cause allergic reactions in a small number of individuals. If you experience discomfort, discontinue the use immediately. Prior to each application, perform the allergy test on a small patch of skin. Proceed with the usage only if no adverse skin reactions occur within 24 hours;

  6. Refrain from using this product on inflamed or damaged skin;

  7. A 48-hour interval should be ensured between successive applications on the same skin area;

  8. For external use only.

11

QB/T 1643-1998 Hair Mousse

Follow the requirements of BB/T 0005-2010.

12

QB/T 1644-1998 Hair Styling Gel

Follow the requirements of BB/T 0005-2010.

13

QB/T 1862-2011 Hair Oil

Aerosol can products shall comply with the requirements of BB/ 0005-2010.

14

QB/T 4076-2010 Hair Wax

Aerosol can products shall comply with the requirements of BB/ 0005-2010.

15

BB/T 0005-2010 Label, Classification and Terms of Aerosol Products

  1. Pressurized Packaging: avoid impact and use away from fire sources.

  2. Store in a dry and ventilated environment below 50°C, avoid direct sunlight, and keep away from fire and heat sources.

  3. Keep out of reach of children.

  4. Do not puncture the product or empty cans, and do not dispose of them in open flames.

  5. The labeling of flammable aerosol products must adhere to the requirements of GB 20578.

  6. Products with potential toxicity to humans and animals should display relevant instructions.

Certain Cases with Special Safety Warning Labeling Requirements

In addition, children's cosmetics shall, as stipulated by the Supervision and Administration Provisions on Children Cosmetics, include warnings like “It should be used under adult’s supervision”. This information should be marked after guide words like "Caution" or "Warning," and be prominently displayed on the visible panel of the sales packaging.

For flammable and explosive cosmetics, such as nail enamel, nail hardener, perfume, and aerosols, adherence to chemical management standard GB 30000.4-2013 Rules for Classification and Labeling of Chemicals Part 4: Aerosols is also required. Products shall also label hazard pictograms, signal words, hazard descriptions, prevention descriptions, product identifiers, and supplier identifiers. 

The selection of the hazard pictogram depends on the product's hazard category, generally featuring a black symbol with a white background and a red frame. Signal words serve to denote the relative severity of the hazard and alert readers to potential risks. For example, highly volatile aerosols are marked with the signal word "dangerous", and flammable aerosols is marked with the signal word "warning". 

20230829101813.jpgSource: sunscreen spray (JD.com)

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