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Deciphering Toothpastes Market Status and Regulatory Requirements in China

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Toothpastes Market Overview and Industry Structure

1. Market Overview: Rising Demand for Toothpastes with the Increasing Oral Health Awareness in China

Compared to the previous year, the market size of Chinese toothpastes increased by 6.2% to 29.1 billion yuan in 2019, expecting to exceed 30 billion yuan in 2020 [1].

china-toothpastes-market-size-in-2016-2020e.png

Source: 2019-2025 China's Toothpastes Industry Special Survey and Development Trend Analysis Report

2. Industry Structure

In terms of the toothpastes industry's overall structure, in 2018, local Chinese brands accounted for the highest proportion of the output, foreign brand products accounted for the second.

china-toothpastes-industry-overall-structure-in-2018.png

Source: Huaon

Multinational enterprises such as Procter & Gamble, Colgate, and Lion are optimistic about Chinese market and have established R&D centers, production bases, and sales platforms in China. Under the pressure of competition from foreign brands, local enterprises such as Yunnan Baiyao have invested a lot of capital in development. In 2019 industry statistics, Yunnan Baiyao ranked first among brands in the toothpastes industry in China.

Top 10 Brands in China’s Toothpastes Industry in 2019

No.

Brand

Enterprise

1

Yunnan Baiyao

yunnan-baiyao.jpg

Yunnan Baiyao Group Co., Ltd.

2

Darlie

darlie-1.png

Hawley & Hazel Chemical (Zhongshan) Co., Ltd.

3

Colgate

colgate.png

Colgate Palmolive (China) Co., Ltd.

4

Crest

crest.png

Procter & Gamble (China) Co., Ltd.

5

Zhong Hua

zhonghua.jpg

Unilever (China) Investment Co., Ltd.

6

Sensodyne

sensodyne.png

GlaxoSmithKline (China) Investment Co., Ltd.

7

Lion

lion.jpg

Lion Daily Chemical (Qingdao) Co., Ltd

8

Oral-B

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Procter & Gamble (China) Co., Ltd.

9

Saky

saky.png

Guangzhou Weimeizi Industrial Co., Ltd.

10

Ora2

ora2.jpg

Sunstar International Trade (Shanghai) Co., Ltd.

Source: AskCI

Timeline of Major Regulatory Events for Toothpastes

  • Before 2006: Production license is not required for toothpastes.

  • In August 2006: The former General Administration of Quality Supervision promulgated the “Implementation Rules for Toothpastes Product Production License." According to this document, toothpastes shall be produced after obtaining a production license and shall label the QS (Quality Safety) mark. Only toothpastes producers with an annual output of more than 2,000 tons are eligible for the production license.

  • In 2010: China Oral Care Industry Association (COCIA) was established, and a complete standardization system was established from the procurement of the ingredients to the marketed product labeling.

  • In June 2011: The toothpastes production was included in the list of the restricted industries, and no production license would be issued.

  • In 2015: The draft for approval of CSAR classified toothpastes and other oral care products as cosmetics, but the specific management methods are not clear.

  • In January 2016: The former CFDA implemented the Practice for Cosmetics Production Licensing, regulating toothpastes as an independent unit of cosmetics to implement production license management. Toothpastes shall refer to the cosmetic management requirements and obtain a production license issued by the provincial FDA (now provincial MPA).

  • In October 2019: toothpastes was removed from the restricted industries' list, and the restriction on the production license was canceled.

  • In June 2020: The final CSAR stipulated that toothpastes does not belong to cosmetics, but shall be managed with reference to the general cosmetics provisions.

  • In July 2020: COCIA released an announcement to collect all the ingredients used in toothpastes that has been on the market in China before July 31, 2020. A list of Existing Toothpastes Ingredients in China will be formulated later.

  • In the second half of 2020: Administrative Measures for Toothpastes will be issued, which will clarify pre-market requirements for toothpastes, requirements for toothpastes ingredients, toothpastes efficacy claims, etc.

Current Regulatory Requirements

1. Definition

According to GB/T 8372-2017 Toothpastes, toothpastes refer to the paste materials formed by mixing main ingredients including abrasives, humectants, thickeners, foaming agents, fragrance compound, water, and other additives (containing functional ingredients used for improving oral health).

2. Standardization Situation

There are 19 national standards, 52 industrial standards, and 3 group standards for oral care and cleansing products. According to Sun Dongfang, the deputy director of COCIA, the standard for herbal toothpastes is under formulation.

Type

Number

Details

Example

National Standard

19

For product: 2

Relate to method: 14

  • GB/T 21842-2008 Determination of diethylene glycol in toothpastes

  • GB/T 32115-2015 Determination of ethylene glycol and diethylene glycol in oral care products

  • GB/T 32112-2015 Determination of peroxide in oral care products-High performance liquid chromatography method

  • GB/T 32118-2015 Determination of formaldehyde in toothpaste—High performance liquid chromatography

For basic management: 3

Industry Standard

52

For product: 25

Relate to method: 27

  • QB/T 2969-2008 Experimental method for determination of triclosan in toothpastes

  • QB/T 5096-2017 Oral care and cleansing products-Determination of dipotassium glycyrrhizinate in toothpastes-High performance liquid chromatography

  • QB/T 5222-2018 Oral cavity nursing materials-Phytic acid sodium (inositol sodium phosphat) for toothpaste

Group Standard

3

For the product: 2

  • T/COCIA 2-2018 Oral cleaning and care products --- Dipotassium glycyrrhizinate for toothpastes

  • T/COCIA 1-2018 Oral cleaning and care products --- Glycyrrhetinic acid for toothpastes

Relate to method: 1

  • T/COCIA 3-2018 Detection of soluble fluoride in oral care products using olaflur as a fluorine source

3. Compliance Requirements

1) Production License

In January 2016, the former CFDA promulgated the Practice for Cosmetics Production Licensing, regulating toothpastes as an independent unit of cosmetics to implement production license management. Toothpastes shall refer to the cosmetic management requirements and obtain a production license issued by the provincial FDA (now provincial MPA).

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Toothpastes Production License (source: internet)

2) Safety Management

Ingredients used in toothpastes shall meet the requirements in GB 22115-2008 General Requirements on Raw Materials of Toothpastes.

Prohibited Ingredients

1466

Including benzene, benzidine sulphate, carbon monoxide, chlorine, etc.

Restricted Ingredients

39

Including aluminum fluoride, ammonia, calcium fluoride, sodium nitrite, stannous fluoride, etc.

Permitted Preservatives

48

Including chlorobutanol, 2-chloroacetamide, formaldehyde and paraformaldehyde, sodium iodate, etc.

Permitted Colorants

102

Including CI 11920, CI 12490, CI 13015, CI 14270, CI 14700, etc.

Each ingredient used should be conducted a safety assessment. To assess toothpastes ingredients' safety, stakeholders should first consider its hygiene, sensory and physicochemical indicators, and then follow the four steps of hazard identification, dose-response assessment, exposure assessment, and risk characterization.

Hygiene Indicators

Hygiene Indicators

Requirements

Total numbers of the colony / (CFU/g)

≤ 500

Molds and yeasts / (CFU/g)

≤ 100

Thermotolerant coliform bacteria / g

No detection

Pseudomonas aeruginosa / g

No detection

Staphylococcus aureus / g

No detection

Lead (Pb) content / (mg/kg)

≤ 10

Arsenic (As) content / (mg/kg)

≤ 2


Sensory and Physicochemical Indicators

Items

Requirements

Sensory   Indicator

Paste

Uniform, without foreign matter

Physicochemical   Indicators

pH

5.5a-10.5

Stability

The paste does not overflow out of the nozzle, does not separate the liquid, and the flavor and color are normal

Superhard particles

No scratches on the slide

Soluble fluorine or free fluorine contentb (the lower limit only applies to anticarious fluoride toothpastes) / %

0.05-0.15 (applying to fluoride toothpastes)

0.05-0.11 (applying to children fluoride toothpastes)

Total fluorine content (the lower limit only applies to anticarious fluoride toothpastes) / %

0.05-0.15 (applying to fluoride toothpastes)

0.05-0.11 (applying to children fluoride toothpastes)

Note:

a For toothpastes with a pH lower than 5.5, the responsible party of the product shall provide two testing reports issued by qualified third-party organizations on the safety assessment of dental hard tissues (including tooth enamel and dentine)   according to standard methods. The testing conclusions of the reports shall both meet the safety requirements of the standard methods. At least one of the reports shall be issued by the dental research institutes (school of stomatology, the provincial dental research institute) or the dental medical institutes (the tertiary dental specialty hospital, the dental department of a general hospital).

b For the fluoride toothpastes which contains sodium monofluorophosphate or combination of sodium monofluorophosphate and sodium fluoride (stannous fluoride, ammonium fluoride), the detection method of soluble fluorine applies; for the fluoride toothpastes made with sodium fluoride or (stannous fluoride, ammonium fluoride) as the ingredient, the detection method of free fluorine applies; if the fluoride used is not sodium monofluorophosphate, sodium fluoride, stannous fluoride, or ammonium fluoride, the applicability of the detection method shall be discussed.

The overall safety assessment of the toothpastes should also combine with the partial safety data of the finished product [2], including but not limited to past formulation experience, adverse reaction statistics of marketed products, epidemiological survey data, clinical data of the product, tests on the safety of oral soft tissues, tests on the safety of teeth/hard tissues, such as the relative dental abrasivity, RDA/Profilometry. Specific requirements can refer to Administrative Measures for Safety Assessment of Oral Care and Cleansing Products and Guideline for Safety Assessment of Oral Care and Cleansing Products.

3) Pre-market requirements

Toothpastes are classified into two categories, general toothpastes, and functional toothpastes. At present, the Chinese government does not implement registration or filing management for toothpastes. Products can enter the market as long as they comply with relevant national and industry standards.

Category

Scope

Current Pre-market requirements

General toothpastes

Toothpastes only has the basic functions: cleaning the oral cavity, reducing teeth stains, reducing soft dirt, whitening teeth, reducing dental plaque, bringing fresh breath, refreshing taste, maintaining the health of teeth and periodontal tissue (including gingiva), and maintaining oral health.

  • Shall have a production license.

  • No need to register or file the product. Products can enter the market as long as they comply with relevant national and industry standards.

Functional Toothpastes

  • Toothpastes with functional ingredients, which has additional efficacy of auxiliary precaution or alleviation to certain oral problems, contributes to oral health except for the basic functions of toothpastes.

  • Efficacy: anti-caries, control of dental plaque, anti-dentin sensitivity, control of dental gingivitis, stain removal and whitening, anti-dental calculus, ozostomia alleviation and other functions completing the verification of the efficacy of improving oral problems.

  • Shall have a production license.

  • No need to register or file the product.

  • Efficacy shall be supported by the efficacy evaluation report (clinical test or laboratory evaluation report) issued by the dental medical institution, stomatological hospital, etc. The relevant efficacy can be marked on the label if supported by evaluation reports.

  • Functional ingredients shall be detected qualitatively or quantitatively.

 

*For toothpastes in which fluoride acts as the functional ingredient preventing caries, the clinical evaluation of caries prevention is not indispensable.

* Toothpastes claiming the same efficacy, using the same functional ingredients, and the concentration is no less than the verified products, no further efficacy evaluation is required.

 The CSAR promulgated on June 29 stipulates that toothpastes will be managed with reference to the general cosmetics provisions. After toothpastes notification applicants conduct the efficacy evaluation in accordance with national standards and industry standards, they can claim that the toothpastes has efficacy such as anti-caries, plaque inhibition, anti-dentine hypersensitivity, and relieve gingiva problems, etc. The specific notification requirements remain to be seen until the release of Administrative Measures on Toothpastes.

4) Labeling Requirements

Information Necessary for Oral Care and Cleansing Products Labeling [3]

Product name

Manufacturer name and address (For imported products, country or region of origin and agent, importer or distributor’s name and address)

Net content

Ingredient list

Manufacturing date and shelf life or batch number and expiry date

Standard number

Warnings

Storage condition (if necessary)

Product user manual (if necessary)

Note:

  • The product packaging whose maximum surface area is less than 10 cm2, or the net content is less than 15g/ml, may only label product name, manufacturer name and address, net content, manufacturing date, and shelf life or batch number and expiry date. Other information could be marked in descriptive information.

  • Net content, full ingredient list, and the standard number could be exempt for free trial products with corresponding marks (gifts, not for sale)

Oral care and cleansing products are prohibited from labeling or claiming the following content:

  • Medical terms

  • False, exaggerated, misleading or confusing claims

  • Feudal superstition and violation of public order and good customs

  • Absolute terms

  • Claims prohibited by other laws, regulations, and national standards.

Toothpastes that has not been verified by efficacy evaluation shall not be marked with efficacy on the product label.

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