CFDA Clarifies Cosmetic Registration Dossier Requirements for Dual Listed Ingredients

Takehome: Products using dual Listed Ingredients must be labeled with the specific functionality of the ingredient.

Since the release of STSC 2015 many companies have consulted with CFDA on the cosmetic registration application dossier requirements in instances where an ingredient is listed in both the “List of Restricted Ingredients” and the “List of Permitted Preservatives” in the new standard.

Recently CFDA gave the explanation that if this dual listed ingredient is not used as a preservative, the actual function of the ingredient must be marked on the product label irrespective of whether or not it exceeds the limit set for preservatives. Therefore, companies need to make the corresponding adjustments on packaging and labels and include the information in the application documents related to labeling and packaging.