China New Sunscreen Labeling Requirements: Compliance Q&A

Takehome

New sunscreens labeling requirements were released by CFDA on June 1 but many requirements weren’t specified clearly. After consulting with CFDA, ChemLinked compiled the answers to some important questions.                            

Q: The new regulation stipulates that if the measured SPF = 2~50, the actual measured value shall be marked. If the value is 43, should cosmetics be labeled with SPF 43?

A: CFDA hasn’t yet figured out a reasonable labeling approach for SPF value but they will release a related notice ASAP. It is said that the labeled value may combine 95% confidence intervals and a multiple of 5. Due to the uncertainty companies can also label the SPF value based on the previous regulation, which can be accepted by CFDA. In November of this year CFDA will notify companies to supplement documents and change the SPF value based on finalized requirements.

Q: Can companies submit a new testing report for claim modification?

A: Absolutely no. Companies must submit the original testing reports. For special circumstances, companies can make an explanation but it could still be refused.

Q: If the sunscreens name on the original packaging indicates SPF 45 but the measured value is 30. What should companies do?

A: Companies are recommended to change the original product name. Otherwise, application will not be granted. If the SPF 45 is just marked on other parts other than product name, there is no need to make changes.

Q: PA++++ can’t be tested out by using the testing methods in the STSC 2015. What should companies do?

A: Companies can refer to the related testing methods released by ISO or submit overseas reports.

Q: Can products name indicate pre-water SPF value?

A: No, product names can only use post-water SPF or both post-water SPF and pre-water SPF. Only indication of pre-water SPF is not permitted.