New Labelling Requirements for Cosmetic Products in China
The new Cosmetics Supervision and Administration Regulation (CSAR) was enacted in China. The National Medical Products Administration (NMPA) has released standards for the testing of cosmetic products' safety profile and efficacy claims. The NMPA has also published the Administrative Measures on Cosmetics Labelling, an updated set of requirements for the label of cosmetic products made available in the Chinese market.
Marta Pinto

Marta Pinto

Regulatory Affairs Associate

CHINESE COSMETICS REGULATION

The implementation of a new Cosmetics Supervision and Administration Regulation (CSAR) has come into force on 1st of January (2021). On the 4th of March (2021) the National Medical Products Administration (NMPA) released the final versions of the two regulations: Provisions for Management of Cosmetic Registration and Notifications Dossiers (previously called as Instructions for Cosmetic Registration and Notification Dossiers) and Provisions for Management of New Cosmetic Ingredient Registration and Notifications Dossiers. The key goal of these regulations is to standardize and guide the registration and filing of new cosmetic materials and products, specifying The documentation requirements for application, modification, renewal and cancellation of a cosmetic registration and notification.

On the 3rd of June, NMPA published the Administrative Measures on Cosmetics Labelling (also called the “Measures”), unifying the contents of regulations, standards and normative documents on cosmetic labelling management. It sharpened up the requirements in accordance with the new CSAR, implementing certain conditions for the labelling and prohibiting specific cosmetic claims.

ADMINISTRATIVE MEASURES ON COSMETICS LABELLING

Labelling plays a main role in cosmetics. It needs to be clear, true and give all the essential information to the consumer. It is a powerful and essential tool of marketing. The NMPA had already issued standards for testing the cosmetic products’ safety profile and efficacy of claims: “Cosmetics Efficacy Claim Evaluation Standards” and “The Technical Guidelines for Cosmetic Safety Assessment (2021 Edition)”, explained in our previous post.

The Chinese new labelling regulation (Administrative Measures on Cosmetics Labelling) introduced five main changes regarding the ingredient list, Chinese labelling (sticker), requirements for claiming specific ingredients and efficacy of ingredients, executive standard number, and extension of words not allowed. The Measures apply to words, symbols, numbers, patterns and other markings on the packaging and containers of cosmetic products.

The label will now need to contain the full ingredients list. The ingredients shall be listed in descending order of concentration if they are present at a concentration above 0.1% (w/w). Ingredients with content under 0.1% (w/w) should be labelled separately, under the term “other trace ingredients”.

According to the new Measures, cosmetic products that enter in China shall bear Chinese labels, using standard Chinese characters. Exceptions are made for trade names, websites, names and addresses of foreign companies and conventional technical terms (e.g., Colour Index number, SPF value, etc.). A visible panel on the sales packaging with standard Chinese characters shall be used in order to explain other symbols or characters that might be used.

Chinese stickers can be used in imported cosmetics but product’s safety information and efficacy claims on these stickers need to be consistent with the contents present in the original labels. This means that the Chinese sticker cannot contain any claim that was not originally placed on the product’s label, nor it can add any new information related to product’s safety or efficacy. Moreover, the font size of the Chinese characters on the labels needs to be at least as large as the font size of other characters (exception of registered trademarks). Claims need to be in compliance with Chinese cosmetic regulation requirements.

Claiming particular ingredients or the efficacy of certain ingredients has become stricter. For example, if a product claims to have a determined ingredient or indicates the category of the ingredient, it needs to be consistent with the product’s formula. Brand names cannot imply effects or raw materials/ingredients that the product does not contain.

Cosmetic products available in the Chinese market need to indicate the product’s executive standard number in its label. This number is automatically generated in the notification of ‘general cosmetics’ (preparatory notification number received by the applicant).

Requirements were also set for the expansion of words that are not allowed to use on cosmetic labels or in claims. Medical terms/effects (explicit or implicit), guarantee of safety or efficacy, false/exaggerated/misleading information are some of the features that cannot be used in the labelling of cosmetic products in China.

In sum, the Chinese label must contain the following information:

  • Chinese name of the product and registration certificate number of special cosmetics
  • Name and address of the registrant/filling person or of the person responsible in China (for foreign company)
  • Name and address of the manufacturer (if manufactured in China, it also needs the manufacturer’s production license number)
  • Product implementation number
  • Full ingredient list
  • Net content
  • Use period/expiry date
  • Instructions of use and safety warnings
  • Other content as required by relevant laws, administrative regulations and national standards.

The Chinese product name and the expiration date need to be indicated in the outer package (e.g. box).

Although the Measures are scheduled to be implemented on 2022 (May 1st), companies should start to comply with the requirements as soon as possible.

The Chinese legal framework on cosmetics can be tricky and hard to understand, but Critical Catalyst has a team of experts that can help you. Please feel free to contact us using our email info@criticalcatalyst.com.

References:

  1. Technical Guidelines for Cosmetic Safety Assessment. 2021. (Chinese).
  2. Interview Vol. 4. Interpretation of China’s New Cosmetic Labeling Regulation. Chemlinked. Jul 09, 2021. Available from: https://cosmetic.chemlinked.com/news/interview/interview-vol-4-interpretation-of-chinas-new-cosmetics-labeling-regulation?utm_source=edm
  3. CSAR Subsidiary Regulations: China Finalizes Requirements for Cosmetic Labeling. Chemlinked. Jun 04, 2021. Available from: https://cosmetic.chemlinked.com/news/cosmetic-news/csar-subsidiary-regulations-china-finalizes-requirements-for-cosmetic-labeling

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