FAQs Vol. 14 | Guangzhou AMR Answers Questions About Cosmetic Notification and Labeling Requirements

When filing the notification application, the notifier needs to apply for a preliminary notification number, which will be the official one after the application is submitted. For the canceled cosmetic, it will receive another preliminary notification number in the new application, thus the number will be different from its previous one.

In terms of the product name, at present, it cannot be reused in a new notification application.

According to NMPA, for cosmetics that have been registered and notified before May 1, 2021, cosmetic registrants and notifiers should upload the abstract of the efficacy claim's basis in accordance with the transitional policies. After registrants and notifiers evaluate product’s efficacy claim as required by Standards for Cosmetic Efficacy Claim Evaluation, if the evaluation result cannot support the efficacy claim involved in the product name and/or label, a change application can be filed before the transitional period expires. In the application, the registrants and notifiers shall adjust the classification code of the product based on its actual properties, and amend the relevant content in product name and/or label, to make it comply with the regulatory requirements. 

For cosmetics satisfying the above conditions, the notifiers can apply for changing the product name after completing the document supplement.

It is possible if the application has not been submitted yet. The notifier can modify the product name under the "Obtain the Preliminary Notification Number" section.

However, if the notified product is ordered to make corrections to the notification information, the product name cannot be modified when the amendment is temporarily saved.

The product's notification shall be cancelled by the regulatory authority if the notifier:

• Fails to submit the annual report as required: starting from January 1, 2022, notifiers shall submit the annual report of general cosmetics notified over one year ago through the new platform from January 1 to March of each year. For notifiers failing to meet this requirement, they will be ordered to make corrections within the prescribed time limit. Otherwise, the notification will be canceled;

• Fails to confirm the product on the new platform as required: for products notified on the previous platform, the notifiers should claim and confirm them on the new platform. For cosmetics remain unconfirmed by March 31, 2022, their notifications have been canceled.

• Involves in circumstances outlined in Article 59 of Administrative Measures on Cosmetics Registration and Notification: a. the notifier submits false documents in the notification application; b. the documents of notified products do not meet the requirements, and the notifier does not make the corrections within the prescribed time limit, or the notifier does not suspend the sales and use of cosmetics or new cosmetic ingredients as required; c. the notified new cosmetic ingredients or cosmetics fall beyond the notification scope.

If a product's notification is canceled, the notifier can conduct a self-examination by reference to these circumstances. If none of them applies, the notifier can consult the regulatory authority.

Cosmetic ingredients refer to those that are purposefully added to the product formula in the production process, and play a role in the final product. In accordance with Administrative Measures on Cosmetics Labeling (Measures), all ingredients shall be labeled by their standard Chinese names on the visible panel of cosmetic's sales packaging, and listed in descending order as per the content in the product formula.

For ingredients whose content is no more than 0.1% (w/w), they shall be labeled separately with "other trace ingredients" as the guide language. In addition, they do not have to be listed in descending order as per the content in formula. Those who fulfil any of the following conditions can be exempted from being labeled:

1. antioxidants, preservatives, stabilizers, etc. with extremely trace amount that are added in the ingredients to ensure the ingredient quality;

2. the processing aids added in the production process, who do not chemically react with other ingredients and do not exist in the final product.

As per the Measures, the required labeling information and its corresponding requirements are as follows: