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CSAR Subsidiary Regulations: China Finalizes Requirements for Cosmetic Labeling

On June 3, 2021, China NMPA released the finalized Administrative Measures on Cosmetics Labeling, spelling out the requirements for the labeling and prohibited claims of cosmetics under China’s new cosmetic regulations. The most significant change relates to the full ingredient listing. Ingredients with content more than 0.1% (w/w) shall be listed in descending order while ingredients less than 0.1% (w/w) shall be labeled separately under “other trace ingredients”. Chinese stickers can be affixed for imported cosmetics. The contents related to product safety and efficacy on Chinese stickers are required to be consistent with the contents on the original labels.

On June 3, 2021, China National Medical Products Administration (NMPA) released the finalized Administrative Measures on Cosmetics Labeling (hereinafter referred to as the Measures). The Measures spells out the requirements for the labeling and prohibited claims of cosmetics (including cosmetics provided to consumers in the form of trial, gift, exchange, etc.) under China's new cosmetic regulations.

The Measures is scheduled to be implemented on May 1, 2022. Starting from the implementation date all cosmetics to be registered or notified shall comply with the Measures.  However, companies are encouraged to label cosmetics in accordance with the Measures from now on. For cosmetics that have been registered or notified before June 3, 2021, but not complied with the Measures, the registrants or notifiers shall update the labels by May 1, 2023.

Basic Requirements for Cosmetic Labeling

Cosmetics are required to bear Chinese labels with all contents using standard Chinese characters except for trade names, websites, names and addresses of overseas companies, and conventional technical terms (e.g. CI number, SPF value and series No.). If other characters or symbols are used, standard Chinese characters should be used on a visible panel on the sales packaging to explain the corresponding meaning.

For imported cosmetics, Chinese stickers can be affixed. The contents related to product safety and efficacy on Chinese stickers are required to be consistent with the contents on the original labels.

As per the Measures, the following information shall be marked on cosmetic labels:

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