FAQs Vol. 22 | China NIFDC Answers Questions About Cosmetic Labels, Children’s Cosmetics and Microneedle Products

Efficacy claims on the product labels should align with claims specified under the classification code, as outlined in the Cosmetic Registration and Notification Application Form. The claims on the product label shall not exceed the scope covered by the classification code. For example, if the classification code only includes the claim “moisturizing,” the product label can state moisturizing-related claims such as “moisturizing,” “reducing moisture loss,” or “relieving dry skin.” However, claims outside the moisturizing scope, such as “firming” or “soothing” are not allowed.

The Supervision and Administration Provisions on Children’s Cosmetics encourages the development of product executive standards for children’s cosmetics that are stricter than mandatory national standards and technical specifications. Currently, children’s cosmetics should comply with the Technical Guidelines for Children Cosmetics and scientifically reasonable pH value parameters, indicator ranges, quality management measures, and brief descriptions, based on relevant research materials such as product formulas, production processes, and usage methods. Additionally, the Working Rules for Cosmetic Registration and Filing Testing specifies that products that are not subject to pH testing, such as pure oily (wax-based) products, are exempt from this requirement.

If a product with the claim of “microcrystal” or “microneedle” is not intended for application to the skin surface, in consideration of factors such as its formulation, manufacturing process, method of use, and product form, it may fall outside the definition of cosmetics as outlined in the Cosmetic Supervision and Administration Regulation (CSAR).