China’s Provincial Medical Products Administration Clarifies Key Points for Cosmetic Labeling

1.

Chinese Product Name

Must have introductory words.

1. It shall be labeled in a prominent position on the visible panel of the sales packaging;

2. It shall be listed after an introductory word, which indicates this is a Chinese product name, at least at one place on the package;

3. If letters, Chinese pinyin, digits, symbols, etc., are used as trade names,

• the trademark registration certificate must be obtained;

• their meanings shall be explained and described on the visible panel of the product’s sales packaging;

4. It shall be labeled on the packaging container in direct contact with the contents (primary packaging);

5. It shall not claim any medical efficacies or efficacies that the product does not have;

6. If it uses an ingredient name or an ingredient category name, the related ingredient shall be contained in the formula and its actual efficacy shall be consistent with the efficacy claim. If it uses the name of animals, plants, or minerals to describe the aroma, color, or shape of the product, the related ingredient can be exempted from being used in the formula.

2.

Registrant, Notifier, and Chinese Domestic Responsible Person

The introductory words are modified.

Production methods

Previous requirements for introductory words

Current requirements for introductory words

Entrusted production

Entrusting enterprise:

Entrusted production enterprise:

Notifier:

Production enterprise:

Self-production

Production enterprise:

Notifier / Production enterprise:

Notes: The above is the requirements for introductory words of general cosmetic products.

3.

Production Enterprise

The labeling requirements are refined.

1. The name and address of the production enterprise that completes the last process that contacts the contents shall be labeled;

2. For Chinese domestic production enterprises, the cosmetic production license number shall also be labeled after the enterprise name and address;

3. If the registered address of the production enterprise is inconsistent with the actual production address, the actual production address stated on the production license shall be labeled.

4.

Executive Standard

Newly added mandatory labeling item.

1. It shall be introduced by the introductory words;

2. The executive standard number can be labeled as the product notification number. The previous national standard number, industry standard number, and company standard number can no longer be labeled.

5.

Full Ingredients

The requirements for labeling form and descending order are modified.

1. It shall be labeled on the visible panel of sales packaging;

2. The standard Chinese name of the ingredients shall be labeled;

3. The concentration refers to the total concentration of the individual ingredient in the formula:

• Previous requirements:

Ingredients: the ingredients with a concentration of more than 1% shall be listed in descending order, followed by ingredients with a concentration of less than 1% in random order;

• Current requirements:

Ingredients: the ingredients with a concentration of more than 0.1% shall be listed in descending order,

Other trace ingredients: the ingredients with a concentration of less than 0.1% shall be listed afterwards in random order;

4. Cosmetic ingredients are those that are purposefully added to the product formula during the production process and play a role in the final product. Those components, such as antioxidants, preservatives, and stabilizers, added in very small amounts in the ingredients to ensure the ingredient quality can be exempted from being labeled.

6.

Net Content

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1. It shall be labeled in Chinese national legal units of measurement (other measurement units should be converted into Chinese legal measurement units);

2. It shall be labeled on the display panel of the sales packaging.

7.

Durability

The labeling requirements are refined.

1. Two labeling forms: production date and shelf life; production batch number and expiration date;

2. If there are multiple individually-packaged products in the sales packaging, each individual packaging shall be labeled with its durability. The durability on the sales packaging can be listed in two ways: the durability of the earliest expiring individually packaged product, or the durability of all the individually-packaged products;

3. The durability shall be labeled on the packaging container in direct contact with the contents (primary packaging), which can be labeled with the production batch number and the period after opening.

8.

Use Method

The labeling contents are clarified.

1. It can ensure that consumers use the product correctly;

2. When necessary to label the use method, it shall be labeled on the visible panel of the sales package or in the leaflet attached to the product.

9.

Necessary Safety Warnings

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1. The term “Precaution” or “Warning” shall be used as the introductory word;

2. Under the following three circumstances, the safety warnings shall be labeled:

• Where there are labeling requirements for warnings and safety precautions on restricted and permitted cosmetic ingredients;

• Where there are labeling requirements for the precautions on cosmetics applicable to children or other special populations;

• Other situations where warnings and safety precautions should be labeled.

10.

Other Contents

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Other contents that shall be labeled as prescribed by laws, administrative regulations, or mandatory national standards.