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On July 20, 2022, China NMPA issued an announcement, answering four FAQs about cosmetic labeling. 1
Cosmetics sold in China shall have Chinese labeling, in which standardized Chinese characters shall be used. If other texts or symbols are used in the Chinese labeling, the corresponding explanation and description shall be given in standardized Chinese characters on the same visible panel of the products’ sales packaging, except for websites, names and addresses of overseas enterprises, and conventional technical terms that must be in other languages.
If letters, Chinese pinyin, digits, symbols, etc. are used in the registered trademark in the Chinese name of a product, their meanings shall be explained and described on the same visible panel of the product’s sales packaging.
Except for registered trademarks, the size of other fonts on the same visible panel of the Chinese labeling shall be less than or equal to the standardized Chinese character font.
If a Chinese sticker is affixed to the original foreign packaging, the Chinese sticker shall meet the above requirements as well.
Cosmetics are health-related products. In order to protect the legitimate rights and interests of consumers and facilitate them to identify the main subject of product liability, cosmetic product shall be labeled with the name and address of the product registrant, notifier, and domestic responsible person. In addition, considering that the same registrant or notifier may entrust different manufacturers, and the products produced by different entrusted manufacturers may vary in quality and safety, so the entrusted manufacturer's information shall also be indicated on the label.
The following information is prohibited from being labeled on the product:
Other concepts, terms and expressions related to manufacturer but without clear definition in regulations and uniform understanding among the public, such as “supervised by…”, “presented by…”, “brand authorized by…”;
Other trademarks not included in the product trade name.
These two kinds of information may make consumers misunderstand the manufacturer and the subject of liability, thus belong to "false or misleading content" stipulated by CSAR.
The cosmetic labeling shall indicate the standard Chinese names of all cosmetic ingredients on the visible panel of the sales packaging with "ingredients" as the cue word. All ingredients shall be listed in descending order of concentration in the product formula.
Cosmetic ingredients refer to those that are purposefully added to the product formula during the production process and play a role in the final product. Extremely trace antioxidants, preservatives, stabilizers, etc. are not considered as ingredients of the final product if they are added to the ingredient to ensure the ingredient quality.
During the product registration or notification process,
When filling in the product formula, the extremely trace components shall be clarified in the ingredient composition;
The extremely trace components can be exempted from being indicated on the product label. Enterprises can choose whether to label them or not.
When applying for product registration or notification, the cosmetic registrant or notifier shall compile and submit relevant information about "product executive standard." In order to facilitate the labeling of the product executive standard number, the number generated by the NMPA registration and notification system is the same as the registration license or notification certificate number. The registration license number for special cosmetics is obtained after the registration is approved, while the notification certificate number for general cosmetics can be preset through the notification system.
The cosmetics registrant and notifier shall indicate the correct executive standard number on the product label. If it is necessary to additionally indicate the national standard, industry standard, or other relevant standard number on the label, it shall comply with relevant laws and regulations, and the content shall be true, complete, and accurate.
Industry Interpretation
This FAQ clarifies that non-standardized Chinese characters on the Chinese labels and registered trademarks (including graphic trademarks) shall be explained with standardized Chinese characters on the same visible panel of the product. Enterprises should ensure that any visible panels labeled with such trademarks have corresponding explanations.
If the product is without an outer box, the primary packaging is directly used as the sales packaging. In this case, if the trademark is labeled on the primary packaging, there should be explanations on the primary packaging;
If the product has an outer box, the primary packaging is not visible, so the corresponding explanations are allowed not to be labeled on the primary packaging.
If the product has a round packaging, and the trademark is labeled on the front and back, then corresponding explanations are required on both the front and back. 2
Chinese sticker affixed to imported products shall also comply with the above requirements; that is, the non-standardized Chinese characters on the Chinese sticker shall be explained on the same visible panel. Other non-standardized Chinese characters on the original foreign packaging are not within the scope that needs to be explained.
*Visible panel: any panel of a cosmetic that consumers can see without destroying the sales packaging.
In addition, the FAQ mentions that extremely trace components added to ingredients can be exempted from labeling. However, the specific concentration that can be defined as “extremely trace” is yet to be clarified by NMPA.
ChemLinked expects assist companies in preparing compliant cosmetic labels and registering/notifying cosmetics in China. If you have any further cosmetic compliance consultation needs, please contact us at [email protected].
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