China to Increase Stringency of Child Cosmetic Standard

Child cosmetics in China have been the subject of strict regulatory enforcement over the course of the last several months according to a CFDA publication entitled “Guidance on Child Cosmetic Notification and Review”. Technical guidance for general cosmetic hygiene and safety standards have been available since 2007, however there has never been any individualized standards to regulate child cosmetics as a discrete category of cosmetics. The only discernable category specific standards have been developed at an industry level and are not compulsory national standards. Given the unique physiological differences between adults and children, lack of specialized standards must be seen as a major shortcoming in China’s cosmetic regulatory framework.

The release of the guidance comes at a critical juncture in China’s cosmetic market, when awareness over skin irritation caused by child cosmetics is on the rise among consumers. Given the unique physiological requirements of children’s skin a major focus of the guidance is a maximal reduction in the use of fragrances, preservatives and flavors. According to the guidance document it is necessary to “reduce or not use fragrances, flavor and surfactant, while monitoring any ill effect should such ingredient be adopted in production”. The guidance also stipulates “it is inappropriate to use such ingredients that contribute to whitening, freckle-removing, acne-removing, depilation, perspiration, deodorization, hair-growth, hair-dyeing, hair-perming, breast augmentation, ingredients of GMO origin and nanotechnology”.

The aim of simplifying the permitted ingredient list for child cosmetic as outlined in the guidance has been endorsed by the medical community and championed by dermatological expert Li Xiaofen. According to Li, acne and freckles are not uncommon among children and worryingly the use of cosmetics to target acne and freckles poses a risk of serious adverse effects. Chou Meng a renowned dermatologist in China has also publically stated his beliefs that child cosmetics should only use ingredients associated moisturizer functions and not use fragrance, flavors or preservatives.

While the guidance has finally addressed the issue of individualized regulatory treatment of child cosmetics, it’s somewhat vague provisions have fallen short of providing a cohesive regulatory foundation to facilitate transparent regulation for both industry and regulators. Until a separate child cosmetics inventory is compiled and supporting regulations promulgated, industry will still be required to undertake a certain amount of guess work when formulating child cosmetics.