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Beauty Products and Samples Face Increased Scrutiny and Compliance on Tmall

From March 8, beauty samples sold on Tmall shall indicate the product information such as variety, specification, quantity, price, etc., and the attribute keywords such as "trial," "sample," "tester," "trial packaging" in the title of the product. From March 15, CBEC imported makeup and skincare products sold on Tmall Global shall provide relevant qualification certificates or third-party authoritative testing reports.

To further improve product quality and safety, and standardize the market, Tmall and its sub-platform Tmall Global adopted two new management rules for the products on their platforms in March.

1. Tmall Sample Products Posting Specification 1

On March 1, Tmall released a new standard, i.e., Sample Products Posting Specification, which stipulates the definition, classification, and posting specifications of the sample products sold on the platform and applies to multiple categories, including cosmetics, food, health care products, household appliances. The standard has taken effect on March 8, 2021.

As per the standard, merchants are required to meet the following requirements:

  • The variety, specification, quantity, price, and other information of the sample are clearly indicated in the product information webpage.

  • The price of the sample is higher than that of the same proportion of the full-size product.

  • The quality of the sample and the full-size product is consistent.

  • The sample volume does not exceed 30% of the full-size product.

  • Attribute keywords such as "trial," "sample," "tester," "trial packaging," "experience packaging," are clearly indicated in the title of the released sample.

  • Legal business qualification certificates of sample products, and corresponding category authorization from Tmall are obtained.

  • True and valid purchase vouchers are provided to prove the credible source of the samples.

Notably, this move of Tmall follows the implementation of the Cosmetic Supervision and Administration Regulations on January 1, 2021, which propose that "the minimum sales unit of cosmetics shall be labeled, which shall comply with relevant laws, administrative regulations and mandatory national standards, and the content therein shall be true, complete and correct," bringing cosmetic sample products into the regulatory net for the first time. So far, merchants of cosmetic sample products, both offline and online, are subject to stringent supervision. China is on track to achieve full coverage of cosmetics sample management.

2. Qualification Requirements for Cosmetics on Tmall Global 2

On March 8, Tmall Global issued a notice clarifying that merchants shall ensure conformance to the corresponding product posting guidelines of Tmall Global when releasing beauty, food, and pet products, and provide qualification certificates or third-party authoritative testing reports that meet the specified qualification requirements.

In the beauty sector, the CBEC imported cosmetics need to submit qualification certificates of the following items:

Commodity Type

Test Item

Test Method/Standard

Makeup and skincare products (made in China and other countries)

Total bacterial count (CFU/g or CFU/ml)

Safety and Technical Standards for Cosmetics 2015

Mercury

Lead

Makeup and skincare products (made in the United States)

Total bacterial count (CFU/g or CFU/ml)

The United States Pharmacopeia (USP) 61 or 62

Mercury

Code of Federal Regulations Title 21 (21 CFR 700.13)

Lead

California Proposition 65 (CA 65)

Makeup and skincare products (made in Europe)

Total bacterial count (CFU/g or CFU/ml)

European Pharmacopoeia (EP) 9.0-2.6.12 Microbial enumeration tests

Mercury

The "Technically Avoidable Heavy Metal Limits in Cosmetics" issued by the German Federal Office of Consumer Protection and Food Safety (BVL) in December 2016

Lead

In case of any violations of the quality specifications given in the above standards, Tmall Global will pull the illegal products off shelves. Also, the platform will conduct random inspections of cross-border e-commerce products on sale per the General Rules of Conduct for Tmall Global Product Spot Check. Unqualified products found during the inspections will subject to punishment by the platform and financial loss.

The notice has come into force on March 15, 2021.

*ChemLinked also provides services to help brands enter Tmall Global. If you have any further questions, please feel free to contact us at [email protected].

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