CSAR Subsidiary Regulations: China Consults on Supervision and Administration Provisions on Children Cosmetics: the Strictest Supervision Ever

The new Supervision and Administration Provisions contains stricter requirements for children cosmetics, including the use of ingredient, safety assessment, packaging design, production and operation, registration and notification, and post-market surveillance; Children cosmetics are not allowed to use functional ingredients for freckle-removing, whitening, anti-acne, depilating, deodorant, anti-dandruff, anti-hair loss, hair dyeing, and hair perming agents; Children cosmetics should be labeled with NMPA designated children cosmetics’ logo in a prominent position on the display surface, and the executive standard number directly below the logo.

On June 18, China NMPA released the draft Supervision and Administration Provisions on Children Cosmetics for public consultation. ¹ Any suggestions can be mailed to huazhuangpinchu@163.com before July 31, 2021.

Supervision and Administration Provisions on Children Cosmetics (hereafter referred to as the new Provisions) covers all aspects of children cosmetics supervision, including its definition, formula design principles, safety assessment, labeling, production and operation, registration and notification, as well as sampling inspection. Compared with the current guidance for children cosmetics, the new Provisions is stricter and more systematic.

Definition

In China, children cosmetics refer to cosmetics for children aged 12 and under. In addition to age restrictions, the following two products are also regulated as children cosmetics:

Product labeling "applicable to the whole population," "for the whole family," etc.; or
Product using trademarks, patterns, homophones, letters, Pinyin, numbers, symbols, packaging, etc. to imply that the target users include children.

Formula Design Principles

The formula design principles in the new Provisions is similar with the current guidance. But the requirement in the current guidance "not recommended to use certain functional ingredients" has been changed to "not allowed to use certain functional ingredients” in the new Provisions.

Formula Design Principles

(1) Children cosmetics should reduce the number of ingredients used in formulas and assess the scientificity and necessity of ingredients (especially fragrances, colorants, preservatives, and surfactants) from the aspects of safety, stability, function, and compatibility;