3 Reasons China’s Cosmetic Standards Need Reform

Growth in China’s cosmetics industry means that the health hazards posed by cosmetic ingredients are more significant than ever before. China needs to address the strengths and weakness of its current patchwork of standards and reformulate, amend and consolidate to align its industry with international best practices.

Background

Beginning in the early 1990s, China’s legislative effort in cosmetic safety management has been prolific, putting in place hundreds of regulations, standards and measures to administrate the diversified range of products on China’s market, with some specifically focusing on ingredient safety and risk assessment.

“Cosmetic Safety Technical Standard” (formerly known as “Cosmetic Hygiene Standard”) is to date the most significant progress made in China’s endeavor to regulate restricted and prohibited ingredients. In this China lays down testing methods and maximum volume limits of restricted and prohibited substances. “Risk Assessment Guidance for Potential Safety Risk Substance in Cosmetics” is another key legislative output. Both however lag behind international studies in relevant field.

The latest release of “Guidance for Cosmetic Safety Risk Assessment” is a promising sign. But a good number of technical standards, most of which were formulated in late 1990s and barely changed since, remain a big concern for an exploding cosmetic market.

A Dearth of Safety Supervision Standards

Despite having hundreds of standards, there remains a dearth of those concerned with cosmetic safety supervision. There is presently a severe shortage of technical standards and testing methods which can be seen in the newly revised “Cosmetic Safety Technical Standard”, which covers 1386 prohibited substances and 354 restricted substances with over 70% of them devoid of corresponding testing methods. Another barren area of China’s cosmetic standards system is the lack of identification and testing methods for colorants and associated impurities. There are some green shoots in the offing with the recent proposal or drafting of several new standards however these will only offer testing methods for a mere 20 or so colorants.

Manufacturers of liquid shampoo made of Chinese herbal medicine can also easily dodge supervision, given that the current industrial standard—QB/T1974—2004 liquid shampoo/cream offers no specific testing methods to target this niche business which is often marketed as green and environmentally friendly. Meanwhile, a growing awareness of cosmetic safety has led more consumers to inquire into the subtle connection between safety and function. In this regard, China only has the cosmetic function assessment standards for sunscreen and moisturizing cosmetics, leaving the greater majority unaccounted for.

Because standards are regarded as the principal baseline in China’s regulatory framework to measure product quality, the fact that a significant portion of products lack such standards leaves a lot to be desired and leaves the industry open to exploitation by counterfeiters and other criminals.

Overlap and Redundancy

Technical inability aside, China has long standing problems associated with its careful observance of tradition and the excessively bureaucratic hierarchies of its regulatory authorities and governmental ministries that greatly mire supervision work. The hundreds of published standards are not harmonized and have not been developed by a centralized organization but are issued by a number of government departments, many of which overlap each other.

For instance, the “GB/T 24800.2－2009 Determination of 41 Glucocorticoids in Cosmetics by LC-MS-MS and TLC Method” and “SN/T2533－2010 Determination of Corticosteroids and Progesterones in Cosmetic for Import and Export” overlap in the types of hormones tested for and the testing methods used.

Government bodies have attempted to address these inefficiencies by engaging in a nationwide campaign to reduce administrative redundancy exemplified in its treatment of oral care products which have been formally recognized as cosmetics in “Regulation of Cosmetic Hygiene Supervision” for the first in this August thus aligning with both “Rules of Cosmetic Labeling Management” and “Cosmetic Safety Technical Standard” where these products have long been considered as cosmetics.

Obsolete Content

Most of China’s standards are over 10 years old and have undergone minimal amendment since their publication. The “Regulation of Cosmetic Hygiene Supervision” was only recently revised. The “Cosmetic Hygiene Standard” has been renamed “Cosmetic Safety Technical Standard”, although the content revision is far from substantive. By contrast, revision occurs frequently in the EU.  

With technology developing fast, these outdated standards are no longer fit for purpose to deal with problems posed by problematic cosmetics. The cosmetic products made by genetic and nano-technology remain loosely under control while many newly introduced cosmetics bearing special-use function also free from separate treatment. For a country with a steadily growing middle class, the government needs to safeguard its cosmetic industry with enhanced safety assessment and quality control mechanism. Fixing the standards governing these areas is a great place to start.