Impacts of China’s New Sunscreen Labeling Requirements

Takehome

The new sunscreens labeling requirements released by CFDA on June 1 permits the marking of SPF > 50 and PA ++++ on labels.

1 International Companies

The new requirements are expected to be favorable for international companies by allowing greater labeling flexibility.

As stipulated, starting June 1 2016 manufactures/importers that want to adjust the claims of their existing sunscreens are permitted to apply for modification by submitting corresponding testing reports. Different from other cosmetics, sunscreens enjoy a preferential policy which CFDA can accept UV test reports of SPF value, water resistance and PFA value from overseas labs. As overseas countries/regions such as EU, America and Japan have accepted SPF 50+ and PA++++ for a long time importers have existing qualified testing reports which are acceptable by CFDA. In such case, they can submit their applications immediately and change the labeling more quickly. This regulatory amendment will offer a significant market advantage to international companies over domestic companies particularly in light of consumer preference for high SPF/PFA products.

2 Domestic Companies

Under the previous regulation only SPF 30+ and PA+++ were permitted to be labelled. This obviously left domestic companies with little incentive to engage in research and development of high SPF/PFA sunscreens. The change in regulation will mean domestic enterprises are at a disadvantage in terms of their product efficacy. New R&D is time-consuming and to obtain a license for sunscreens requires around 12-18 months, thus domestic companies will suffer short-term losses.

3 Sunscreen agent suppliers

Ingredient suppliers are the direct beneficiaries of the new regulation. This regulation will encourage cosmetic company to develop new high SPF/PFA value sunscreens and will drive purchase of associated sunscreen raw materials.

The new policy aligns with the international standards and will help meet consumer demand for more efficacious products. But the requirements still require improvements in the aspects of testing reports and original packaging. Due to the difference between domestic and international testing methods, different interpretations of product profile may arise. To eliminate the gap CFDA should uniformly adopt domestic testing reports or introduce international testing methods. In addition, some sunscreens with original packaging indicating SPF 120 or 70 are still circulating in the market. Some measures should be taken to resolve the problem.