[Updated] China Non-compliant Cosmetic Cases in 2024

Editor's Note: This article tracks and collects typical non-compliant cosmetic cases in 2024, as per the latest developments. Previous contents can be seen at the bottom of the article.

ChemLinked collected and analyzed typical non-compliant cosmetics cases from routine and random inspections in 2024 conducted by China's regulatory authorities, including National Medical Products Administration (NMPA), local medical products administration (MPA) and administration for market regulation (AMR). By sharing these examples, ChemLinked aims to help cosmetics manufacturers and operators identify potential pitfalls and navigate the regulatory landscape more effectively.

December 2024

Penalty / Release Date	Penalty Authority	Penalty Reason	Penalty Measures
December 1, 2024	Guangzhou Baiyun District Administration for Market Regulation (AMR) Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 836	The involved company entrusted cosmetics production to a business that did not hold the required production license.	Guangzhou Baiyun District AMR imposed fines on the company.
December 1, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1005	The involved company entrusted cosmetics production to a business that did not hold the required production license. Besides, the company manufactured cosmetics with false labels.	Guangzhou Baiyun District AMR issued warnings to the company, imposed fines, and confiscated its illegal gains.
December 1, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1027	The involved company entrusted cosmetics production to a business that did not hold the required production license, with the cosmetics primarily aimed at children.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains.
December 1, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1415	The involved company failed to implement both a sample retention management system and a sample retention record system for finished cosmetic products.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
December 3, 2024	Hangzhou Xiaoshan District AMR Relevant announcement: Hang-Xiao-Shi-Jian Penalty Notice [2024] No. 1956	The involved company manufactured cosmetics that failed to meet the microorganism standards specified in Safety and Technical Standards for Cosmetics 2015 (STSC 2015).	Hangzhou Xiaoshan District AMR imposed fines on the company, and confiscated its illegal gains.
December 4, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Detection of Banned Ingredients in 15 Batches of Cosmetics (No. 53 of 2024)	The following 11 prohibited ingredients specified in STSC 2015 were detected in 15 batches of non-compliant cosmetics: 1) Triclosan: 1 batch 2) Mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate: 1 batch 3) Isopropylparaben: 1 batch 4) Acrylamide: 1 batch 5) Progesterone: 2 batches 6) Dichloromethane: 1 batch 7) Bimatoprost: 4 batches 8) 3- and 4-(4-Hydroxy-4-methylpentyl)cyclohex-3-ene-1-carbaldehyde: 1 batch 9) Desonide: 1 batch 10) Benzene: 1 batch 11) 2-Chloro-p-phenylenediamine sulfate: 1 batch Notes: a. The ingredient referenced in “1)” is a permitted preservative as per STSC 2015. However, its application scope does not extend to the shampoo category detected in this instance. b. The ingredient referenced in “2)” is a permitted preservative as per STSC 2015. However, it is only allowed in rinse-off cosmetics, while the non-compliant product containing it is a leave-on formulation.	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
December 9, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 2428	The involved company manufactured cosmetics that failed to meet the microorganism standards specified in STSC 2015.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains.
December 11, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Unannounced Inspection Results of Two Companies (No. 54 of 2024)	The Inner Mongolian company involved was found to have the following deficiencies during the inspection: 1) Quality assurance and control: failure to implement the required record-keeping system; 2) Factory facilities and equipment management: unauthorized changes to the division of functional areas of the production workshop; 3) Production process management: failure to adhere to the technical requirements stated in cosmetics registration dossiers, and failure to implement the required product release management system; 4) Production sales management: failure to implement the required product sales record system.	NMPA ordered the Inner Mongolia Autonomous Region MPA to file a case against the involved company, evaluate the safety risks of its products, enforce a product recall, and implement emergency control measures if necessary. Inner Mongolia Autonomous Region MPA has instructed the company to halt production and operations, and take corrective actions in response to the issues identified during the inspection.
December 11, 2024		The Guangxi company involved was found to have the following deficiencies during the inspection: 1) Quality assurance and control: failure to implement the required record-keeping and sample retention systems; 2) Production process management: failure to implement the required product release management system; 3) Material and product management: failure to store materials and products in accordance with regulations.	NMPA ordered the Guangxi Zhuang Autonomous Region MPA to file a case against the involved company, evaluate the safety risks of its products, enforce a product recall, and implement emergency control measures if necessary. Guangxi Zhuang Autonomous Region MPA has instructed the company to halt production and operations, and take corrective actions in response to the issues identified during the inspection.
December 12, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 2458	The involved company manufactured cosmetics that failed to meet the lead content standards specified in STSC 2015.	Guangzhou Baiyun District AMR imposed fines on the company, confiscated its illegal gains, and instructed it to rectify the illegal practices.
December 16, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Detection of Banned Ingredients in 10 Batches of Cosmetics (No. 56 of 2024)	The following 8 prohibited ingredients specified in STSC 2015 were detected in 10 batches of non-compliant cosmetics: 1) Acrylamide: 1 batch 2) Mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate: 4 batches 3) Betamethasone: 1 batch 4) Betamethasone acetate: 1 batch 5) Benzene: 1 batch 6) Dichloromethane: 1 batch 7) 3- and 4-(4-Hydroxy-4-methylpentyl)cyclohex-3-ene-1-carbaldehyde: 1 batch 8) Terbinafine: 1 batch Notes: a. The ingredient referenced in “2)” is a permitted preservative as per STSC 2015. However, it is only allowed in rinse-off cosmetics, while the non-compliant products containing it are leave-on formulations.	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
December 16, 2024	Dongyang AMR Relevant announcement: Dong-Shi-Jian Penalty Notice [2024] No. 1328	The involved company failed to implement a purchase inspection record system, sold counterfeit cosmetics, and marketed cosmetics that had not been notified.	Dongyang AMR issued warnings to the company, imposed fines, and confiscated its illegal gains.
December 17, 2024	Guangdong MPA Relevant announcement: Guangdong MPA’s Notice on Cosmetic Sampling Testing (Issue 5 of 2024)	The 18 batches of non-compliant cosmetics were found to have 4 primary reasons for non-compliance: 1) Permitted ingredients failing to meet use conditions: 5 batches 2) Microorganisms exceeding the standard: 5 batches 3) Detected ingredients being inconsistent with product labels and registration dossiers: 1 batch 4) Detection of prohibited ingredient: 7 batches	Guangdong MPA directed the involved companies to implement risk control measures, including sales suspension and product recall, and to investigate the causes of non-compliance and take corrective actions. Besides, Guangdong MPA instructed local MPAs to file cases against these companies, thoroughly investigate and penalize violations such as providing false information or concealing facts to deny production, and publicly disclose the investigation results as required.
December 18, 2024	Dongyang AMR Relevant announcement: Dong-Shi-Jian Penalty Notice [2024] No. 1337	The involved company failed to implement a purchase inspection record system.	Dongyang AMR issued warnings to the company, and imposed fines.
December 19, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 2506	The involved company published false advertisements that exaggerated the product's functions.	Guangzhou Baiyun District AMR imposed fines on the company, and ordered it to cease the publication of illegal advertisements and eliminate the impact within the relevant scope.
December 23, 2024	Yiwu AMR Relevant announcement: Yi-Shi-Jian Penalty Notice [2024] No. 3134	The actual net content of the cosmetics produced by the involved company does not match the labeled value. Additionally, the height of the labeled characters does not comply with Measures for the Supervision and Management of Quantitative Packaging Commodities.	Yiwu AMR imposed fines on the company.
December 27, 2024	NMPA Relevant announcement: NMPA’s Announcement on 29 Batches of Non-Compliant Cosmetics (No. 63 of 2024)	The 29 batches of non-compliant cosmetics were found to have 3 primary reasons for non-compliance: 1) Permitted ingredients failing to meet use conditions: 9 batches 2) Detected ingredients being inconsistent with product labels and registration dossiers: 19 batches 3) Microorganisms exceeding the standard: 1 batch	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
December 27, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Unannounced Inspection Results of a Company (No. 62 of 2024)	The involved company was found to have the following deficiencies during the inspection: 1) Institutions and personnel: the person in charge of quality and safety of the company failed to perform his duties effectively as required; 2) Quality assurance and control: failure to implement the testing management system as required; 3) Production process management: failure to conduct production in accordance with the technical requirements stated in cosmetics notification dossiers.	NMPA ordered the Hunan MPA to file a case against the involved company, evaluate the safety risks of its products, enforce a product recall, and implement emergency control measures if necessary. Hunan MPA has instructed the company to halt production and operations, and take corrective actions in response to the issues identified during the inspection.

November 2024

Penalty / Release Date	Penalty Authority	Penalty Reason	Penalty Measures
November 4, 2024	Shanghai Municipal Jinshan District AMR Relevant announcement: Hu-Shi-Jian-Jin Penalty Notice [2024] No. 282024003636	The involved company manufactured and marketed cosmetics that had not been notified.	Shanghai Municipal Jinshan District AMR imposed fines on the company.
November 7, 2024	NMPA Relevant announcement: NMPA's Announcement on the Unannounced Inspection Results of a Company (No. 48 of 2024)	The involved company was found to have the following deficiencies during the inspection: 1) Quality assurance and control: failure to implement the required sample retention and record-keeping systems; 2) Factory facilities and equipment management: inadequate facilities and equipment for manufacturing the respective cosmetic products; 3) Material and product management: failure to store materials and products in accordance with regulations, inadequate management of unqualified materials, and the use of expired ingredients in production; 4) Production process management: failure to adhere to the technical requirements stated in cosmetics notification dossiers, and to maintain truthful, complete, and accurate production records.	NMPA ordered Sichuan MPA to file a case against the involved company, evaluate the safety risks of its products, enforce a product recall, and implement emergency control measures if necessary. Sichuan MPA has instructed the company to halt production and operations, and take corrective actions in response to the issues identified during the inspection.
November 7, 2024	Shanghai Municipal Pudong New Area AMR Relevant announcement: Hu-Shi-Jian-Pu Penalty Notice [2024] No. 152024004214	The involved company manufactured special cosmetics that had not been registered. It also produced and marketed cosmetics with non-compliant labeling.	Shanghai Municipal Pudong New Area AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
November 8, 2024	Guangdong MPA Relevant announcement: Guangdong MPA’s Notice on Cosmetic Sampling Testing (Issue 4 of 2024)	The 13 batches of non-compliant cosmetics were found to have four primary reasons for non-compliance: 1) Permitted ingredients failing to meet use conditions: 5 batches 2) Microorganisms exceeding the standard: 4 batches 3) Detected ingredients, product labels, and registration dossiers being inconsistent: 3 batches 4) Detection of prohibited ingredient: 1 batch	Guangdong MPA directed the involved companies to implement risk control measures, including sales suspension and product recall, and to investigate the causes of non-compliance and take corrective actions. Besides, Guangdong MPA instructed local MPAs to file cases against these companies, thoroughly investigate and penalize violations such as providing false information or concealing facts to deny production, and publicly disclose the investigation results as required.
November 12, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 2180	The involved company manufactured cosmetics that failed to meet the microorganism standards specified in STSC 2015.	Guangzhou Baiyun District AMR imposed fines on the company, confiscated its illegal gains, and instructed it to rectify the illegal practices.
November 12, 2024	Guangzhou Huadu District AMR Relevant announcement: Sui-Hua-Shi-Jian Penalty Notice [2024] No. 1051	The involved company failed to use the ingredient "mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate" in compliance with STSC 2015 during cosmetics production.	Guangzhou Huadu District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
November 17, 2024	Shanghai Municipal Chongming District AMR Relevant announcement: Hu-Shi-Jian-Chong Penalty Notice [2024] No. 302024003665	The involved company published advertisements containing false information.	Shanghai Municipal Chongming District AMR imposed fines on the company, and directed it to cease illegal advertising activities immediately.
November 19, 2024	Guangzhou AMR Relevant announcement: Guangzhou AMR Issues Consumer Advisory for Products Including S-touch Eyelash Serum	The following 14 prohibited ingredients specified in STSC 2015 were detected in 33 batches of non-compliant cosmetics: 1) Acrylamide: 5 batches 2) 3- and 4-(4-Hydroxy-4-methylpentyl)cyclohex-3-ene-1-carbaldehyde: 5 batches 3) Betamethasone acetate: 4 batches 4) Clobetasol propionate: 4 batches 5) Mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate: 4 batches 6) Bimatoprost: 2 batches 7) Desonide: 2 batches 8) Clobetasol acetate: 2 batches 9) Dexamethasone: 2 batches 10) Triclosan: 2 batches 11) Flumethasone: 1 batch 12) Betamethasone: 1 batch 13) Progesterone: 1 batch 14) Chloramphenicol: 1 batch *Notes:* a. The ingredient referenced in "5)" is a permitted preservative as per STSC 2015. However, it is only allowed in rinse-off cosmetics, while the non-compliant product containing it is a leave-on formulation; b. The ingredient referenced in "10)" is a permitted preservative as per STSC 2015. However, its application scope does not extend to the shampoo category detected in this instance.	Local AMRs have filed cases against the involved companies, and mandated them to take immediate risk control measures, and to conduct self-inspection and rectification.
November 21, 2024	NMPA Relevant announcement: NMPA's Announcement on 50 Batches of Non-Compliant Cosmetics (No. 50 of 2024)	The 50 batches of non-compliant cosmetics were found to have four primary reasons for non-compliance: 1) Permitted ingredients failing to meet use conditions: 26 batches 2) Detected ingredients, product labels, and registration dossiers being inconsistent: 15 batches 3) Detection of prohibited ingredients: 5 batches 4) Microorganisms exceeding the standard: 4 batches	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
November 21, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 2282	The involved company failed to organize production in accordance with the good manufacturing practices.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
November 22, 2024	Hangzhou Qiantang District AMR Relevant announcement: Hang-Qian-Tang-Shi-Jian Penalty Notice [2024] No. 442	The involved company marketed cosmetics with non-compliant labeling, and failed to implement a purchase inspection record system.	Hangzhou Qiantang District AMR issued warnings to the company, imposed fines, and confiscated its illegal gains.
November 25, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 2328	The involved company manufactured cosmetics that failed to meet the microorganism standards specified in STSC 2015, and refused to cease production and operation even after being ordered by the relevant MPA.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal property.
November 28, 2024	NMPA Relevant announcement: NMPA's Announcement on 40 Batches of Non-Compliant Cosmetics (No. 52 of 2024)	The 40 batches of non-compliant cosmetics were found to have four primary reasons for non-compliance: 1) Detected ingredients, product labels, and registration dossiers being inconsistent: 24 batches 2) Permitted ingredients failing to meet use conditions: 11 batches 3) Microorganisms exceeding the standard: 5 batches 4) Detection of prohibited ingredient: 1 batch	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
November 28, 2024	Anhui MPA Relevant announcement: Notice of Anhui MPA Seventh Branch on the Supervision and Inspection of Cosmetics Production (Issue 5 of 2024)	Four involved companies were found to have defects in their production quality management systems.	Anhui MPA directed the companies to make corrections within a specified timeframe.

October 2024

Penalty / Release Date	Penalty Authority	Penalty Reason	Penalty Measures
October 8, 2024	Ningbo Yinzhou District Administration for Market Regulation (AMR) Relevant announcement: Yong-Yin-Shi-Jian Penalty Notice [2024] No. 1240	1) The content of the cosmetics advertisements released by the company during the livestream was inconsistent with the efficacy claims in the product notification information, constituting an illegal act of publishing false advertisements; 2) In promoting cosmetics during the livestream, the company used phrases like "rash does not go away" and "redness and inflammation," which constituted illegal advertising related to disease treatment, utilizing medical terminology that could confuse the promoted products with drugs and medical devices; 3) The company cited data such as "15 minutes of hydration +104.2%," "30 minutes to reduce redness and swelling -18.06%," and "4 weeks of repair +42.86%" in its promotions but did not indicate the source, which is an illegal act of using data and statistics in advertisements without indicating the source.	Ningbo Yinzhou District AMR ordered the company to cease publishing illegal advertisements, mitigate the impact within the relevant scope, and imposed a fine.
October 9, 2024	Shanghai Municipal MPA Relevant announcement: Shanghai Municipal MPA's Announcement on Cosmetic Supervision and Sampling Quality (Issue 2 of 2024)	The six batches of non-compliant cosmetics were found to have three main reasons for non-compliance (some batches had multiple issues): 1) Excessive prohibited or restricted ingredients: Three batches contained levels of dioxane, methanol, or a mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate that exceeded the allowed limits; 2) Ingredient discrepancies: Three batches had ingredients that did not match the labels or the technical requirements outlined in the product registration dossiers; 3) Label inconsistencies: Two batches had product labels that were inconsistent with the technical requirements specified in the registration dossiers.	Shanghai Municipal MPA required the local market regulation departments where the sampled units are located to order the relevant cosmetics operators to immediately cease the sale of the involved products and to investigate and penalize any illegal activities found in accordance with the law.
October 10, 2024	Shanghai Municipal MPA Relevant announcement: Hu-Yao-Jian-Ji Penalty Notice [2024] No. 762024000014	The involved company failed to establish and implement a purchase inspection record system and a product sales record system.	Shanghai Municipal MPA issued a warning and imposed fines on the company.
October 14, 2024	NMPA Relevant announcement: NMPA’s Announcement on 20 Batches of Cosmetics Containing Prohibited Ingredients (No. 39 of 2024)	The following five prohibited ingredients specified in STSC 2015 were detected in these 20 batches of cosmetics: 1) Benzene: 13 batches 2) Clobetasol acetate: 2 batches 3) Acrylamide: 2 batches 4) 3- and 4-(4-Hydroxy-4-methylpentyl)cyclohex-3-ene-1-carbaldehyde: 2 batches 5) Mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate: 1 batch *Notes:* a. The ingredient referenced in “5)” is a permitted preservative as per STSC 2015. However, it is only allowed in rinse-off cosmetics, while the non-compliant product containing it is a leave-on formulation. b. Among the involved products, one batch of benzene-contained cosmetics was also found to have an excessive amount of the permitted hair dye phenyl methyl pyrazolone.	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
October 18, 2024	Guangdong Provincial MPA Relevant announcement: Guangdong Provincial MPA's Announcement on Cosmetics Supervision and Inspection (Issue 3 of 2024)	45 involved companies were found to have serious defects in their production quality management systems.	Guangdong Provincial MPA required local MPA departments to implement emergency control measures, including ordering non-compliant companies to suspend production and operations, to effectively manage product risks in a timely manner.
October 21, 2024	NMPA Relevant announcement: NMPA’s Announcement on Four Typical Non-complaint Cases	In four typical cases, the involved companies were found to have committed the following violations: 1) manufacturing and selling counterfeit cosmetics 2) manufacturing cosmetics without a production license 3) manufacturing and operating cosmetics that do not meet the requirements in STSC 2015 4) failing to establish and implement a purchase inspection record system	The local court, MPAs, and AMRs imposed criminal and administrative penalties on involved companies.
October 22, 2024	NMPA Relevant announcement: NMPA’s Announcement on 49 Batches of Non-compliant Cosmetics (No. 40 of 2024)	The 49 batches of non-compliant cosmetics were found to have four primary reasons for non-compliance: 1) Detected ingredients, product labels, and registration dossiers being inconsistent: 39 batches 2) Restricted and permitted ingredients failing to meet use conditions: 6 batches 3) Microorganisms exceeding the standard: 3 batches 4) pH value failing to meet limits: 1 batch	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
October 22, 2024	Guangdong Provincial MPA Relevant announcement: Typical Cases from Guangdong Province's Special Initiative to Enhance Drug Safety (The Seventh Batch)	The involved company used the prohibited ingredient tacrolimus to produce children's cosmetics.	Guangzhou Baiyun District AMR imposed penalties on the company, including the confiscation of illegal gains and a fine. Meanwhile, Guangdong Provincial MPA issued a six-month suspension of the company’s cosmetics business, revoked its cosmetics production license, and will not accept its cosmetics notification or administrative licensing applications for the next 10 years. Additionally, the company's legal representative and quality manager were fined and permanently banned from engaging in cosmetics production and operations.
October 22, 2024		The involved company failed to establish and implement a purchase inspection record system and produced cosmetics without a license.	Wujiang District AMR of Shaoguan City imposed a fine on the company and confiscated the illegally produced and sold cosmetics.
October 25, 2024	Guangzhou Municipal AMR Relevant announcement: Guangzhou Municipal AMR's Announcement on the Results of the 2024 Net Content Measurement Inspection for Quantitative Packaged Goods	Out of 80 batches of sampled products—including food, daily necessities, cosmetics, and wires and cables—12 batches of cosmetics failed the net content or net content labeling inspection. This included products such as shampoo and shower gel.	For the non-compliant products and their associated companies, the relevant district AMR conducted follow-up actions in accordance with the law.
October 25, 2024	Guangzhou Municipal AMR Relevant announcement: Guangzhou Municipal AMR’s Announcement on Typical Cases from Special Initiative to Enhance Drug Safety (The Second Batch)	The involved company produced and sold unlabeled cosmetics.	Baiyun District AMR directed the company to immediately rectify their illegal actions and imposed administrative penalties, including fines and confiscation of illegal gains.
		The involved company commissioned others to produce cosmetics without a license.	Conghua District AMR required the company to correct their illegal activities, confiscated unqualified products, and imposed fines.
		The involved company sold cosmetics with non-compliant labels.	Panyu District AMR required the company to address their illegal actions and imposed administrative penalties, including the confiscation of illegal gains and fines.

September 2024

Penalty / Release Date	Penalty Authority	Penalty Reason	Penalty Measures
September 4, 2024	Guangzhou AMR Relevant announcement: Guangzhou AMR’s Report on the 2023 Special Random Inspection of Cosmetics in Guangzhou	The 96 batches of non-compliant cosmetics were found to have five primary reasons for non-compliance: 1) Restricted ingredients failing to meet use conditions: 45 batches 2) Microorganisms exceeding the standard: 30 batches 3) Detected ingredients being inconsistent with product labels and registration dossiers: 20 batches 4) Detection of prohibited ingredients: 2 batches 5) pH value failing to meet limits: 1 batch	Guangzhou AMR has organized relevant district AMRs to investigate and take legal action against the manufacturers and operators of discovered non-compliant cosmetics. They ordered these companies to recall the products, identify their sources, quantities, and distribution, and communicate this information to the market supervision departments in the areas where the products were distributed. For non-compliant products from companies outside Guangzhou, Guangzhou AMR has notified the appropriate market supervision departments to conduct investigations and address the issue.
September 6, 2024	Shanghai Municipal MPA Relevant announcement: Hu-Yao-Jian-Ji Penalty Notice [2024] No. 762024000022	The involved company failed to use the colorant "CI 51319" in compliance with the “Safety and Technical Standards for Cosmetics 2015 (STSC 2015)” during cosmetics production.	Shanghai Municipal MPA imposed fines on the company, and confiscated its illegal gains and illegal property.
September 6, 2024	Shanghai Municipal MPA Relevant announcement: Hu-Yao-Jian-Ji Penalty Notice [2024] No. 762024000023	The involved company failed to implement a purchase inspection record system for packaging materials that come into direct contact with cosmetic contents.	Shanghai Municipal MPA imposed fines on the company, and confiscated its illegal gains and illegal property.
September 6, 2024	Anhui MPA Relevant announcement: Notice of Anhui MPA Sixth Branch on the Supervision and Inspection of Cosmetics Production (Issue 3 of 2024)	Three involved companies were found to have defects in their production quality management systems.	Anhui MPA directed the companies to make corrections within a specified timeframe.
September 11, 2024	NMPA Relevant announcement: NMPA’s Announcement on 36 Batches of Non-Compliant Cosmetics (No. 33 of 2024)	The 36 batches of non-compliant cosmetics were found to have four primary reasons for non-compliance: 1) Detected ingredients being inconsistent with product labels and registration dossiers: 21 batches 2) Microorganisms exceeding the standard: 10 batches 3) Detected ingredients being inconsistent with notification dossiers: 4 batches 4) Hazardous substance lead exceeding the limit: 1 batch	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
September 11, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Detection of Banned Ingredients in 3 Batches of Cosmetics (No. 34 of 2024)	The following two prohibited ingredients, specified in the STSC 2015 were detected in these three batches of cosmetics: 1) Clobetasol propionate: 2 batches 2) Betamethasone acetate: 1 batch	NMPA ordered Guangdong MPA to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
September 14, 2024	Guangzhou Huadu District AMR Relevant announcement: Sui-Hua-Shi-Jian Penalty Notice [2024] No. 795	The involved company failed to organize production in accordance with the good manufacturing practices.	Guangzhou Huadu District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
September 18, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Suspension of the Operation of Cosmetics Labeled "Blue Cap Spray" (No. 36 of 2024)	The foreign company involved used the prohibited ingredient diflorasone propionate to produce cosmetics labeled as "Blue Cap Spray" and "Blue Cap Foam."	NMPA has ordered the company to suspend the operation of these two cosmetics.
September 18, 2024	Guangdong MPA Relevant announcement: Yue-Yao-Jian-Zhuang Penalty Notice [2024] No. 4001	The involved company failed to organize production in accordance with the good manufacturing practices. Besides, it manufactured cosmetics that did not meet the technical requirements stated in notification dossiers.	Guangdong MPA imposed fines on the company, and confiscated its illegal gains.
September 18, 2024	Guangdong MPA Relevant announcement: Yue-Yao-Jian-Zhuang Penalty Notice [2024] No. 2009	The involved company manufactured cosmetics that failed to meet the microorganism standards specified in STSC 2015, and had been reported multiple times by NMPA. Additionally, the company was previously found to have serious defects in its production quality management systems during an unannounced inspection.	Guangdong MPA ordered the company to suspend production and operations, revoked its production license, imposed fines on the company’s legal representative and the person in charge of quality and safety, and banned him from engaging in cosmetics production and operations for the next 10 years.
September 20, 2024	Hangzhou Xiaoshan District AMR Relevant announcement: Hang-Xiao-Shi-Jian Penalty Notice [2024] No. 1381	The involved company marketed cosmetics that had not been notified, and failed to organize production in accordance with the good manufacturing practices.	Hangzhou Xiaoshan District AMR imposed fines on the company, and confiscated its illegal gains.
September 26, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1864	The involved company failed to organize production in accordance with the good manufacturing practices.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.

August 2024

Penalty / Release Date	Penalty Authority	Penalty Reason	Penalty Measures
August 1, 2024	Shanghai Municipal AMR Relevant announcement: Hu-Shi-Jian-Pu Penalty Notice [2024] No. 152024005138	The involved company manufactured and operated imported cosmetics that did not include Chinese names on labels.	Shanghai Municipal AMR imposed fines on the company.
August 5, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1455	The involved company manufactured cosmetics that did not meet the technical requirements stated in notification dossiers.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
August 9, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1497	The involved company published advertisements containing false and misleading information.	Guangzhou Baiyun District AMR imposed fines on the company, and directed it to cease illegal advertising activities immediately and mitigate any negative impacts within the corresponding scope.
August 12, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1507	The involved company manufactured cosmetics outside its licensed scope.	Guangzhou Baiyun District AMR imposed fines on the company, and confiscated its illegal gains and illegal property.
August 13, 2024	NMPA Relevant announcement: NMPA’s Announcement on the Unannounced Inspection Results of a South Korean Company (No. 30 of 2024)	The involved company failed to implement the required product release management system, and did not establish a supervision system for the production activities of the entrusted manufacturers.	NMPA has directed Zhejiang MPA to ensure that the company rectifies the detected deficiencies. If any suspected illegal activities are discovered, Zhejiang MPA is required to file a case for investigation in accordance with the law.
August 13, 2024	NMPA Relevant announcement: NMPA’s Announcement on 37 Batches of Non-compliant Cosmetics (No. 31 of 2024)	The 37 batches of non-compliant cosmetics were found to have two primary reasons for non-compliance: 1) Microorganisms exceeding the standard: 30 batches 2) Detected ingredients / product labels being inconsistent with registration and notification dossiers: 7 batches	NMPA ordered local MPAs to file cases against the involved companies, and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs should also instruct relevant operators to stop selling the illegal products, investigate their purchase inspection records and other situations, trace the source of the illegal products, investigate and punish the illegal acts, and transfer those suspected of crimes to the public security organs.
August 21, 2024	Guangzhou Baiyun District AMR Relevant announcement: Sui-Yun-Shi-Jian Penalty Notice [2024] No. 1584	The involved company manufactured cosmetics with labels containing false information.	Guangzhou Baiyun District AMR imposed fines on the company, and ordered it to rectify its practice of manufacturing cosmetics with false information on labels.
August 22, 2024	Shanghai Municipal MPA Relevant announcement: Hu-Yao-Jian-Ji Penalty Notice [2024] No. 762024000021	The involved company engaged in cosmetics production without the production license.	Shanghai Municipal MPA imposed fines on the company, and confiscated its illegal property.
August 23, 2024	Anhui MPA Relevant announcement: Anhui MPA’s Notice on Suspension of Production and Sales (Wan-Yao-Jian-Hua Suspension Notice No. 1-3)	The involved company did not establish the production quality management system, and failed to organize production in accordance with the good manufacturing practices.	Anhui MPA ordered the company to immediately halt the production and sales of the affected products, and recall those already on the market.
August 26, 2024	Guangdong MPA Relevant announcement: Yue-Yao-Jian-Zhuang Penalty Notice [2024] No. 6003, Yue-Yao-Jian-Zhuang Penalty Notice [2024] No. 6004	The involved company failed to organize production in accordance with the good manufacturing practices.	Guangdong MPA imposed fines on the company, and confiscated its illegal gains and illegal property.

July 2024

Penalty Date	Penalty Authority	Penalty Reason	Penalty Measures
July 2024	NMPA Relevant announcement: NMPA Announces 113 Batches of Non-Compliant Cosmetics	Inconsistency between product formula/labeled ingredients and registration/notification dossiers: 60% Microorganisms exceeding the standard: 21.7% Restricted ingredients exceeding the standard: 17.4% Heavy metals exceeding the standard: 0.9%	NMPA ordered local medical products administrations (MPAs) to file cases against the relevant companies and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs also instructed the relevant operators to stop selling the illegal products, investigated their purchase inspection records and other situations, traced the source of the illegal products, investigated and punished the illegal acts, and transferred those suspected of crimes to the public security organs. It is worth noting that three companies have applied for objections to the authenticity of the samples, and the authorities have verified that the samples are their own products. These companies will be severely punished in accordance with the law for providing false information and concealing the truth.
July 1, 2024	NMPA Relevant announcement: NMPA Announces 17 Batches of Cosmetics Containing Prohibited Ingredients	These illegal products contain prohibited ingredients: metronidazole, clindamycin, lincomycin, fusidic acid, ciprofloxacin, enrofloxacin, cimetidine, terbinafine, m-phenylenediamine, o-aminophenol, clobetasol propionate, dexamethasone, flumethasone, etc.	NMPA ordered Guangdong Provincial MPA to file cases against the relevant companies and instructed the companies to immediately take risk control measures and carry out rectification. The local MPAs also instructed the relevant operators to stop selling the illegal products, investigated their purchase inspection records and other situations, traced the source of the illegal products, investigated and punished the illegal acts, and transferred those suspected of crimes to the public security organs.
July 3, 2024	NMPA Relevant announcement: NMPA Announces 3 Typical Non-complaint Cases	Changing the expiration date of cosmetics; Producing perfumes without production license; Using recycled cosmetics to produce cosmetics.	The companies involved have been administratively punished by the local MPAs.
July 17, 2024	Guangzhou AMR Relevant announcement: Guangzhou Municipal Administration for Market Regulation (AMR) Unveils the First Batch of Representative Drug Safety Enhancement Actions in 2024	Production or operation of cosmetics that did not meet technical specifications; Provision of false evidence materials; Excessive total colony count; Failure to fulfill the obligation of purchase inspection; Detection of unlabeled ingredients.	Guangzhou Municipal AMR has imposed administrative penalties on the relevant companies, including orders to correct the issues, confiscation of the involved products and illegal gains, as well as fines.
July 24, 2024	Guangdong MPA Relevant announcement: Guangdong Provincial MPA Unveils the Sixth Batch of Representative Drug Safety Enhancement Actions	Serious defects in the production quality management system; Detection of hair dye ingredients not indicated on the product label and registration dossiers; Production of unregistered special cosmetics; Providing false evidence materials to deny the production of substandard cosmetics.	Guangdong Provincial MPA has taken severe administrative penalty measures against the relevant companies, including ordering rectification, confiscation of illegal gains, and fines. For companies that deliberately provided false information and concealed the truth, they were punished more severely in accordance with the law—the MPA ordered them to stop cosmetics business for 6 months, revoked their cosmetics production licenses, and banned them from applying for cosmetics notification or registration certificates within 10 years. Additionally, the corporate legal persons involved were fined and banned from cosmetic business for life.
July 30, 2024	Guangdong MPA Relevant announcement: Guangdong Provincial MPA Releases the Second Issue of Cosmetic Supervision and Sampling Testing Report for 2024	Serious production quality management defects	Guangdong Provincial MPA has required relevant departments to take emergency control measures in accordance with the law. This includes the suspension of production and operation for these problematic companies, as well as timely control of possible product risks.
July 2024	Guangdong Provincial MPA	The company had produced unregistered special cosmetics; Hair dye ingredients that were not marked on the product label and registration dossiers were detected; The labeled hair dye ingredients were not actually present; The manufacturer had not complied with the requirements of Good Manufacturing Practices (GMP), with issues such as lack of material purchase inspection records, incomplete batch production records, failure to inspect finished products, and lack of retained samples and sample retention records.	In response to these violations, the manufacturer was ordered to forfeit its illegal gains and fined. Notably, the brand that had commissioned the above manufacturer to produce the products was also punished for failing to effectively supervise the production activities of the entrusted manufacturer, which resulted in the commissioned products being put on the market without proper inspection. The brand was also ordered to forfeit its illegal gains and fined.
	Guangzhou Baiyun District AMR	A company's children's cosmetics were marked with a false notification number. Actually, these products had not been notified when they were put on the market. Besides, the manufacturer's name and address were not labeled on the packaging.	Guangzhou Baiyun District AMR imposed fines on the companies involved, confiscated their illegal gains, and confiscated their illegal property.
		A company's hair dye cream did not meet the requirements of Safety and Technical Standards for Cosmetics 2015 (STSC 2015) in terms of the benzene inspection indicator. Furthermore, the inspection revealed that the ingredients, packaging materials, tools, and equipment used by the company to produce the batch of hair dye cream were also used for the production of other cosmetics.
		Total colony count that did not meet regulatory requirements

H1 2024

1. National Medical Products Administration (NMPA) Announcements

During H1 2024, NMPA issued 5 announcements on cosmetics sampling results, identifying a total of 116 batches of non-compliant cosmetics. In terms of product categories, 22 batches (19%) were sunscreen products, followed by 20 batches (17.2%) of facial mask products.

Figure 1: Categories of Non-compliant Cosmetics

For these non-compliant cosmetics, NMPA has ordered the respective local MPAs to investigate the relevant registrants, notifiers, and contract manufacturers. The involved enterprises have been mandated to immediately implement risk control measures, conduct self-inspection, and rectify any issues in accordance with the law. Relevant cosmetics operators have been ordered to cease the sale of these non-compliant products, review their purchase inspection records, and trace the source of the illegal items. Any verified illegal activities will be severely penalized under the law. Suspected criminal cases will be transferred to public security authorities for further prosecution.

Non-compliance Reasons Analysis

The 116 non-compliant cosmetic batches involved four types of issues, among which some products had multiple violations:

1) Ingredient Discrepancies: ingredients in 44 batches were detected inconsistent or labeled inconsistently with the formulation stated in the registration dossiers. For example:

Ingredients like 3-o-ethyl ascorbic acid and 4-butylresorcinol were not indicated on the labels of whitening products;
Sunscreen agents such as ethylhexyl methoxycinnamate and 4-methylbenzylidene camphor were not indicated on the labels of sunscreen products;
Ingredients like 4-amino-2-hydroxytoluene and toluene-2,5-diamine sulfate were not indicated on the labels of hair dyeing products.

2) Exceeded Microbial Limits: 35 Batches

In 35 cosmetic batches, microorganism levels exceeded regulatory standards. The violations involved:

Total bacterial count
Total yeast and mold count
Presence of Pseudomonas aeruginosa

Table 1: Microbial Limits in Cosmetics in China

Microbiological Indicator	Limit	Remark
Total bacterial count (CFU/g or CFU/ml)	≤ 500	Eye-applicable cosmetics, lip care and lip make-up and children's cosmetics
Total bacterial count (CFU/g or CFU/ml)	≤ 1,000	Other cosmetics
Molds and yeast count (CFU/g or CFU/ml)	≤ 100	/
Fecal Coliforms/g (or ml)	Not be tested out	/
Staphylococcus Aureus/g (or ml)	Not be tested out	/
Pseudomonas Aeruginosa/g (or ml)	Not be tested out	/

3) Exceeded Ingredient Concentration: 35 Batches

In 35 batches, the concentration of some ingredients exceeded the regulatory limits, including:

Table 2: Ingredient Use Requirements in China

Ingredient	Regulatory Limit
Mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate	≤ 0.0015% Limited to be used in rinse-off products; not to be used together with Methylisothiazolinone
Salicylic acid	Used as a restricted ingredient: (a) Leave-on products and skin rinse-off products: ≤ 2.0% (b) Hair rinse-off products: ≤ 3.0% Used as a preservative: ≤ 0.5% total concentration of salicylic acid and its salts in one product (as acid) Not to be used in products for children under the age of 3 except shampoo.
Phenyl methyl pyrazolone	Used as a hair dyeing agent in hair dyeing product: ≤ 0.25%
Ethylhexyl methoxycinnamate	Used as a sunscreen agent: ≤ 10%
Acrylamide	Prohibited ingredient The maximum residual amount of monomers in leave-on products is 0.1mg/kg. For other products, the maximum residual amount of monomers is 0.5mg/kg.
Ethylhexyl salicylate	Used as a sunscreen agent: ≤ 5%
4-methylbenzylidene camphor	Used as a sunscreen agent: ≤ 4%
Butyl methoxydibenzoylmethane	Used as a sunscreen agent: ≤ 5%
Benzophenone-3	Used as a sunscreen agent: ≤ 10%
Lead	≤ 10mg/kg
Arsenic	≤ 2mg/kg

4) Prohibited Ingredient Presence: 9 Batches

9 batches of cosmetics were found to contain prohibited ingredients, with terbinafine as the most common one, present in 3 of the 9 batches. Other prohibited ingredients detected were:

Naphazoline
Metronidazole
Clindamycin
Flumethasone
1,2-Dichloroethane
2-chloro-p-phenylenediamine sulfate
Halobetasol propionate
Clobetasol propionate
Cyproheptadine

2. Provincial Medical Products Administration (MPA) Announcements

1) Shanghai Municipal MPA Releases Cosmetics Supervision and Sampling Inspection Results

On April 17, 2024, Shanghai Municipal MPA released an announcement revealing the results of cosmetics supervision and sampling inspections. During the inspections, a total of 15 batches of cosmetics were found to be non-compliant for various reasons, including excessive amounts of acrylamide, methanol, a mixture of methylchloroisothiazolinone and methylisothiazolinone with magnesium chloride and magnesium nitrate, the presence of the prohibited ingredient bimatoprost, and the aerobic plate count found beyond limit.

The corresponding market regulation department where the sampled units were located have ordered the relevant cosmetics operators to immediately cease the sale of the non-compliant products. Furthermore, they were directed to conduct investigations and initiate appropriate legal actions against any identified illegal activities.

2) Guangdong Provincial MPA Releases Cosmetics Supervision and Sampling Inspection Results

On April 19, 2024, Guangdong Provincial MPA released an announcement, disclosing the results of cosmetics supervision and sampling inspections. The MPA conducted on-site inspections of 65 cosmetics manufacturers and identified 17 companies with significant deficiencies in their production quality management systems. As a consequence, Guangdong Provincial MPA ordered these companies to suspend production and operations. It is important to highlight that a majority of these 17 companies have faced penalties in the past two years due to non-compliance with Safety and Technical Standards for Cosmetics 2015 (STSC 2015) or the production of unregistered special cosmetics.

Enterprises, particularly those with non-compliance records, must strictly adhere to regulations to ensure that their product quality and production environments meet the required standards.

3) Jiangxi Provincial MPA Releases the First Issue of Cosmetic Supervision and Sampling Inspection Report for 2024

On May 9, 2024, Jiangxi MPA announced the first issue of cosmetic supervision and sampling testing report for 2024. The announcement disclosed nine batches of non-compliant cosmetics, with the main reasons including the following factors:

Excessive mold and yeast counts, and excessive bacterial counts;
Detection of prohibited ingredients, including Terbinafine, Chloramphenicol, Erythromycin, and heavy metals (Lead and Arsenic);
Unqualified pH value;
Failure to meet use conditions specified in STSC 2015 for Toluene-2,5-diamine Sulfate, Butyl Methoxydibenzoylmethane, Diethylhexyl Butamido Triazone, Ethylhexyl Methoxycinnamate, Homosalate, Methylene Bis-benzotriazolyl Tetramethylbutylphenol, and Octocrylene.

3. General Administration of Customs of the People's Republic of China (GACC) Notices

From January to May 2024, a total of 20 batches of imported cosmetics from 7 countries/regions were rejected by GACC. The majority of non-compliant imported cosmetics originated from France (35%), Germany (20%) and Thailand (20%). The main categories of rejected cosmetics were perfume (25%), shampoo (20%), essence (15%) and hand wash products (10%).

The reasons for import rejections were as follows:

Lack of required certificates or qualifications (70%)
Unqualified labeling/packaging (25%)
Expired products (5%)

All non-compliant cosmetics have been either returned or destroyed at the port of entry.

Compliance Suggestions

1) Lack of required certificates or qualifications

To avoid import rejections of cosmetics lacking of required certificates or qualifications, enterprises must establish a strict management and review process for goods and certification materials. This ensures consistency between the goods and certification materials, preventing discrepancies due to errors or omissions.

Customs clearance materials for importing cosmetics include:

Contracts, invoices, packing lists, bills of lading, certificates of origin, customs declaration letters, cosmetics approval documents, production/batch certificates, certificate of free sales, MSDS (for dangerous cosmetics), safety commitments, product formulas, original labels, Chinese label translations, and other documents required by GACC.

2) Unqualified labeling/packaging

During customs inspections, the labels of cosmetics are reviewed for compliance. Importers of finished cosmetics with sales packaging are required to submit the Chinese label sample, the original label, and its Chinese translation to the customs.

Packaging labels must be in line with the requirements specified in the Administrative Measures on Cosmetics Labeling. The following information shall be indicated on labels of the imported cosmetics:

Product name and special cosmetic registration license number
The name and address of registrant or notifier
The name and address of the production enterprise
The product executive standard number
Full ingredients listing
Net content
Durability
Application method
Safety warnings
Other content prescribed by laws, administrative regulations, and mandatory national standards

3) Expired products

Enterprises should strengthen inventory management and implement the first-in-first-out (FIFO) principle, to ensure the earliest produced products are shipped first. They must also closely monitor product shelf life, checking all items before export to confirm they meet import requirements.

4. Other Typical Non-compliant Cosmetic Cases

Case 1: Children's Cosmetics Contained Prohibited Ingredient Progesterone

Shantou Jinping AMR discovered that a company's children's cosmetics products contained the prohibited ingredient progesterone. The company also failed to produce "egg yolk oil" in accordance with the technical requirements stated in notification dossiers, and published false advertisements on their Tmall stores. As a result, Shantou Jinping AMR confiscated 1,779 bottles of illegal ingredients from the company; confiscated illegal income of 115,700 yuan; and imposed a fine of 2.49 million yuan. The total fines and confiscations amounted to 2.61 million yuan.

Case 2: Guangzhou Baiyun District AMR Penalty Notice [2024] No. 831 – Demonstrating serious defects in the production quality management system

Guangzhou Baiyun District AMR found that a company possessed serious defects in its production quality management system, i.e., failing to organize production in according with the good manufacturing practices. Citing a breach of Cosmetic Supervision and Administration Regulation(CSAR), Guangzhou Baiyun District AMR ordered the company to stop the illegal production and imposed penalties including fines, confiscation of illegal gains, and confiscation of illegal property.

Case 3: Guangzhou Haizhu District AMR Penalty Notice [2024] No. 351 – Counterfeiting well-known brands and selling unnotified cosmetics

Guangzhou Haizhu District AMR uncovered a company was selling eyeshadow palettes highly similar in name, packaging, etc. to well-known cosmetic brands in its online store. This behavior violated relevant provisions of Supervision and Administration Measures on Online Transactions as well as Anti-Unfair Competition Law of the People's Republic of China.

Additionally, in the course of its cosmetics operations, the company failed to establish a purchase inspection record system, and even sold unnotified, counterfeit and substandard cosmetic products. These actions violated CSAR and Guangdong Province Regulations on Investigating and Punishing Illegal Activities of Producing and Selling Counterfeit and Substandard Goods.

In response to these illegal acts, Guangzhou Haizhu District AMR ordered the company to make immediate corrections, and imposed punishment measures such as warnings, fines, and the confiscation of the illegal products.

Case 4: Guangzhou Baiyun District AMR Penalty Notice [2024] No. 1027 – Entrusting unlicensed individuals to produce children's cosmetics

Guangzhou Baiyun District AMR found that a company had commissioned an individual without a cosmetics production license to manufacture children's cosmetics. This action violated the relevant provisions of CSAR and Guangdong Provincial Cosmetics Safety Regulation.

In response to this illegal behavior, Guangzhou Baiyun District AMR confiscated the illegal gains of the parties involved and imposed a fine.

Case 5: Guangzhou Baiyun District AMR Penalty Notice [2024] No. 1061 – Failing to retain batch production records and sample products, and providing false materials

Guangzhou Baiyun District AMR found that a company's produced cosmetics had excessive bacterial counts, non-compliant to the requirements in STSC 2015. Due to inadequate management, the company did not retain batch production records and sample products of these cosmetics. Furthermore, the company denied producing non-compliant cosmetics and provided false information to Guangzhou Baiyun District AMR, attempting to conceal the truth. These actions are in violation of the relevant provisions of the CSAR and the Guangdong Provincial Cosmetics Safety Regulation. Guangzhou Baiyun District AMR ordered the company to rectify the issues and imposed penalties, including warnings, confiscation of illegal gains, and fines. Additionally, the company's legal representative was also fined.

Case 6: Pudong New Area AMR Penalty Notice [2024] No. 762024000010 – Producing cosmetics that do not comply with STSC 2015

Shanghai Municipal MPA found that a company's notified hand cream contained CI 61585 beyond its permitted scope. The ingredient CI 61585, classified as a permitted colorant as specified in STSC 2015, is only allowed in cosmetics with temporary skin contact. However, the usage instructions for the hand cream implied that it was not limited to temporary skin contact, which exceeded the approved use scope of CI 61585. This action violated the CSAR and constituted an illegal act of failing to use ingredients in accordance with mandatory national standards or technical standards. Shanghai Municipal MPA decided to confiscate the company's illegal gains and impose a fine.

Case 7: Pudong New Area AMR Penalty Notice [2024] No. 152024003189 – Advertising general cosmetics as "suitable during pregnancy"

Pudong New Area AMR found that a company published advertisements on its Tmall flagship store promoting general cosmetic products with claims such as "soothing stretch marks during pregnancy", "preventing stretch marks", "suitable for pregnant skin", "suitable during pregnancy/breastfeeding", and "soothing stretch marks and caring for sensitive skin during and after pregnancy", accompanied by images of pregnant women.

However, the products did not actually have new efficacies suitable for pregnant women, and there was no evidence that they could be applied to all skin types to prevent or improve the appearance of stretch marks. Additionally, the use of the medical term "stretch marks" in the advertising of cosmetics was prohibited.

This advertising behavior violated relevant provisions of Advertising Law of the People's Republic of China and constituted the illegal publication of false promotional content. In response, Pudong New Area AMR ordered the company to cease publishing the illegal advertisements and imposed a fine of 100,000 yuan.

Case 8: Guangzhou Huadu District AMR Penalty Notice [2024] No. 427 – Improperly labeling the quantitative packaged product’s net content

Guangzhou Huadu District AMR found that the shower gels produced and sold by a company was improperly labeled. To be specific, the deviation between the product’s actual content and the labeled content exceeded the prescribed range. Citing a breach of Measures for the Supervision and Management of Quantitative Packaging Commodities, Guangzhou Huadu District AMR ordered the company to correct the illegal mislabeling of the product’s net content, and imposed a fine.

Case 9: Guangzhou Baiyun District AMR Penalty Notice [2024] No. 33 – Selling cosmetics with non-compliant labels

Guangzhou Baiyun District AMR found that there were 5 batches of products sold on an e-commerce platform that had false or misleading content on their labels. As a result, Guangzhou Baiyun District AMR confiscated 15,302 yuan illegal gains and imposed a 120,000 yuan fine, totaling 135,302 yuan.

[Updated] China Non-compliant Cosmetic Cases in 2024

Further Reading