FAQs Vol. 18 | Prohibition on Cosmetics Repackaging? What to Include in Label Sample Manuscript?

A1: According to Cosmetics Supervision and Administration Regulations (CSAR), the smallest sales unit of cosmetics must be properly labeled. Additionally, Supervision and Administration Measures on Cosmetics Manufacture and Operation stipulates that cosmetics production license is required for any preparation, packing, and filling of cosmetic contents.

Therefore, if cosmetics operators, including beauty salons, hotels, and other businesses that use cosmetics or provide cosmetics to consumers, get into contact with cosmetic contents while "repackaging" large-package cosmetics into smaller packages, this is considered a cosmetics production activity. In such cases, the operator must obtain a valid cosmetics production license. Failure to obtain the required license would render the "repackaging" and subsequent sale of the cosmetics as suspected illegal behavior that should be prohibited.

A2: According to CSAR, the product label of cosmetics must include the following information:

• Product name

• Special cosmetics registration certificate number

• Name and address of the registrant, notifier, and/or the entrusted production enterprise

• Executive standard number

• Full ingredient list

• Net content

• Shelf life

• Application method

• Necessary safety warnings

The label sample manuscript submitted during the cosmetics registration or notification process is the basis for making the actual product label. Cosmetics registrants and notifiers are responsible for the content of the label sample manuscript and bear the primary responsibility for the product's quality and safety.

The label sample manuscript should include the text, symbols, numbers, and graphical descriptions used to identify and explain the basic information of, characteristics of, and safety warnings for the cosmetic product. In addition to legally required label content, the manuscript can also include information related to product safety and efficacy claims that the company chooses to display on the label.

However, the label sample manuscript should not include additional contents that are not marked on the product label, such as brand concepts, corporate culture, founder stories, or other promotional materials.

A3: According to Supervision and Administration Measures on Online Operation of Cosmetics, cosmetics operators on e-commerce platforms must fulfill the obligation of comprehensive, truthful, accurate, clear, and timely disclosure of cosmetics label information that is consistent with the product's registration or notification dossiers.

The disclosed label information must include all the contents on the actual labels of cosmetics being sold on the platform. Regarding "shelf life", as cosmetics operators may sell multiple product batches, they can state prominently on the product display page that customers can refer to the shelf life on the physical product packaging.

In addition to disclosing the label information, cosmetics operators must also disclose any other relevant information related to the product's safety and efficacy claims. This information should be consistent with the content in the product's registration or notification dossiers. The consistency requirement refers to consistency in meaning, rather than an exact textual match. Cosmetics operators are permitted to include advertising promotions on the product display pages, provided that such promotions do not exceed the scope and the actual meaning of the safety and efficacy claims documented in the registration or notification dossiers.