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Infant and Children Cosmetics Face Stricter Supervision in China

Many regions in China are conducting special inspections of children cosmetics. The special inspection will last for 7 months and cover the production, notification and operation of children cosmetics. Special requirements for children cosmetics are proposed under the CSAR regulatory framework.

Since Jan. 2021, the regulatory authorities in more than 20 regions in China, such as Beijing and Zhejiang, have issued the Special Inspection Work Plan for Children Cosmetics. Most of the work plans are similar, carrying out special rectification work on children cosmetics from Mar. 1 to Sep 30. 1

Key Points of the Special Inspection Work Plan

1. Key Inspection Products

  • Cosmetics illegally added hormones and anti-infective drugs;

  • Counterfeit and substandard cosmetics;

  • Cosmetics without certificates;

  • Cosmetics claiming "medicated cosmetics," "medical skincare products,";

  • Homemade cosmetics without production licenses.

2. Major Inspection Items

Inspection Targets

Inspection Items

Manufacture

Manufacturers of infant and children cosmetics, the registrants and notifiers of entrusted products

  • Ingredient source;

  • Labels and claims;

  • Whether the product is manufactured in accordance with the registered or notified formula.

Notification

Post-notification inspection of notified infant and children cosmetics

  • Labels. Whether the production date and shelf life (or batch number and expiration date), domestic manufacturer's name, address and production license No. (for domestic cosmetics), country of origin, domestic responsible person's name and address (for imported cosmetics) are labeled;

  • Claims. Whether there are illegal claims of "medicated cosmetics," "medical skincare products," claims expressing or indicating attending functions, indications, therapeutic functions or medicinal effects, etc.;

  • Formula. Whether the product formula meets the safety requirements.

Operation

Infant and children cosmetics operators such as supermarkets, maternal and infant products specialty stores, children barber shops, infant bath centers, and cosmetics centralized trading markets

  • Whether the product qualification is compliant;

  • Whether the purchase and sale channels are legal;

  • Whether the purchase inspection and record and sales record are true and complete;

  • Whether there are illegal claims such as “treat diseases”;

  • Whether the transportation and storage conditions meet the requirements on the labels and instructions;

  • Whether there are self-made cosmetics (without production licenses).

Sampling and Testing

Leave-on infant and children cosmetics

Microorganisms, hormones, anti-infective drugs, and fluconazole.

Investigation and Punishment

  • For infant and children cosmetics illegally added substances that may be harmful to human health, or the labels indicating or implying medical effects, heavier penalties shall be imposed;

  • For cosmetic registrants, notifiers, entrusted production enterprises who illegally add substances that may harm human health, heavy penalties shall be imposed if the circumstances are serious, and the legal representative or the main responsible person, the person who is directly in charge and other directly responsible persons shall be investigated for legal responsibility;

  • For suspected crimes, promptly transfer to the public security organs. The products involved should be inspected and verified.

The special inspections on children cosmetics will last for 7 months, cover a wide range of inspection targets and impose heavy penalties for non-compliance. Children cosmetics are now ushering more stringent surveillance in China. While strengthening post-market surveillance of children cosmetics, China also put forward special requirements for children cosmetics’ registration, notification and production.

Special Requirements for Children Cosmetics under the New Regulations

Compared with adult cosmetics, Safety and Technical Standards for Cosmetics 2015 and Guidance on Application and Review of Children Cosmetics have already imposed stricter requirements on children cosmetics’ ingredients, formulas, production processes, labels, use methods, and quality control. Three CSAR subsidiary regulations, Provisions for Management of Cosmetic Registration and Notification Dossiers, Cosmetic Classification Rules and Catalog (Draft) and Good Manufacturing Practices for Cosmetics (Draft), will further tighten the registration, notification and production requirements for children cosmetics.

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