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Interview Vol. 4 | Interpretation of China’s New Cosmetic Labeling Regulation

Cosmetic labeling has always been the focus of the regulatory authorities because it is the most direct way for consumers to obtain basic product information and safe use instruction. On June 3, 2021, China NMPA released the Administrative Measures on Cosmetics Labeling, which unified the contents of regulations, standards, and normative documents pertaining to cosmetic labeling management, and refined the requirements for cosmetics labeling in line with the current cosmetics supervision status. To help companies better cope with the new regulation, ChemLinked invited Alice Zhang, the cosmetic regulatory technical engineer from REACH24H, to introduce the key changes brought by the new regulation and give insightful advices in terms of regulatory compliance.
1. What are the significant changes brought by the Administrative Measures on Cosmetics Labeling

In general, there are five main changes in this new regulation:

  1. The first is the labeling of ingredients. The Measures requires that cosmetic labels should indicate the full ingredients of cosmetics, and ingredients in the formula with content less than 0.1% (w/w) should be labeled separately under the term "other trace ingredients".

  2. The second is the affixed Chinese label. Generally, the original packaging of imported products is mostly in foreign languages, and Chinese labels will be affixed when entering China. The previous regulations primarily concentrated on the compliance review of the contents claimed in Chinese, but now a new item is subject to review. That is, if a Chinese label is affixed, the contents related to product safety and efficacy claims thereon shall be consistent with the relevant contents on the original label.

    In this way, on the one hand, the Chinese label affixed cannot claim the efficacy that is not on the original packaging and cannot delete or add any content related to product safety on the original packaging. On the other hand, the relevant content on the original packaging itself must comply with Chinese laws and regulations.

  3. The third is the requirements for claiming certain ingredients or the efficacy of ingredients on the label. In recent years, it has become a trend in the industry to name cosmetics with ingredients, such as "Retinol Eye Cream" and "Carnosine Base Primer." The Measures puts forward strict requirements in response to this phenomenon, stipulating that where the generic name of a product uses the name of a specific ingredient or indicates the category of the ingredient, the ingredient shall be consistent with that in the product formula, and the efficacy of such ingredient in the product shall be in line with the product’s efficacy claim. At the same time, it is not allowed to claim the function of the ingredient used to imply the product having the efficacy that it does not actually possess or that is forbidden in claims. For example, a cosmetic is only a moisturizing product but claims on the packaging that it "contains XX ingredients with whitening effect." This is clearly a violation of the Measures.

  4. The fourth is the product’s executive standard number. The Measures requires the Chinese label to indicate the product’s executive standard number. The notion may seem quite foreign to overseas companies. For general cosmetics, this number is actually the preparatory notification number received by the applicant at the time of notification. It is automatically generated by the system and will replace the "notification number" that must be marked on the label before.

  5. The fifth is the expansion of words that are not allowed to use on cosmetic labels or in claims.

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