中文
English
Answers to 5 Frequently Asked Questions about Cosmetic Filing Labels
Question 1: What is a cosmetic label?
Answer: According to Article 3 of the "Measures for the Administration of Cosmetic Labels", cosmetic labels refer to the text, symbols, numbers, patterns, and other markings used to identify and explain the basic information, attribute characteristics, and safety warnings of the product on the sales packaging, as well as the packaging containers, packaging boxes, and instructions with identification information. That is to say, labels include both "software" information and "hardware" information carriers.
Question 2: What is the minimum sales unit? What are the requirements for the minimum sales unit label in the "Cosmetics Label Management Measures"?
Answer: The definition of minimum sales unit: The minimum packaging form of a product that is delivered to consumers along with product packaging containers, boxes, and product manuals for the purpose of product sales.
According to Article 5 of the "Measures for the Administration of Cosmetic Labels", the minimum sales unit of cosmetics should have labels. The label should comply with relevant laws, administrative regulations, departmental rules, mandatory national standards, and technical specifications. The content of the label should be legal, authentic, complete, accurate, and consistent with the relevant content of product registration or filing.
Cosmetic labels should be clear, durable, easy to recognize and read, and there should be no signs of words falling off or sticking loosely.
Question 3: What are the special provisions for labeling different packaging in the "Cosmetics Label Management Measures"?
Answer: (1) Products with packaging boxes
According to Article 7 of the "Measures for the Administration of Cosmetic Labeling", products with packaging boxes should also be labeled with the Chinese name and expiration date of the product on the packaging containers that come into direct contact with the contents.
According to Article 14 of the "Measures for the Administration of Cosmetic Labeling", when labeling the expiration date on packaging containers that come into direct contact with the contents, in addition to selecting the production date and shelf life or the production batch number and expiration date for labeling, the production batch number and expiration date after opening can also be labeled.
(2) Small size packaging products
Answer: According to Article 6 of the "Regulations on the Supervision and Administration of Children's Cosmetics", firstly, children's cosmetics should be labeled with the children's cosmetics logo specified by the National Drug Administration on the sales packaging display surface, namely "Little Golden Shield"; Secondly, children's cosmetics should be guided by "caution" or "warning", and warning phrases such as "should be used under adult supervision" should be marked on the visible surface of the sales packaging. In addition, cosmetic registrants and registrants are encouraged to use anti-counterfeiting technology and other means on their labels to facilitate consumers' identification and selection of legitimate products.
Question 5: What are the common problems with filling in the product label module in the filing system?
Answer: 1. Incomplete filling of net content
For products with multiple specifications, all specifications should be filled in the "Net Content" column, and not just one specification.
2. Other special claims not checked accordingly
(1) Specific claims (claims applicable to sensitive skin)
When declaring "suitable for all skin", "suitable for sensitive skin" or similar expressions in the product label, the claim should be checked.
(2) Declare quantitative indicators (time, statistical data, etc.)
The claim of efficacy should be checked for retention time, relevant statistical data, and specific pH values in the product label.
3. The uploaded label image in the attachment does not meet the requirements
The label images include a floor plan of all visible packaging surfaces and a three-dimensional display that reflects the appearance of the product. The images should be complete and clear. The floor plan should be easily distinguishable from all marked content; If it is not possible to clearly display all the marked content, a partial enlarged drawing or product packaging design drawing should also be submitted. The complete floor plan includes pictures of the top and bottom of the product packaging. When uploading design drawings for floor plans and stereoscopic displays, information such as color and size should not be labeled.
4. Sales Packaging Plan
(1) The information in the product label, such as the address of the registrant, the address of the production enterprise, and the standard number of the product execution, is inconsistent with the corresponding information in the filing application form.
(2) The Chinese labels of imported products do not reflect the content related to product safety and efficacy claims in the original packaging labels. If there is a claim about the efficacy of the raw material in the original packaging, the Chinese label does not indicate it accordingly.
(3) Mark vulgar, feudal superstition, or other content that violates social order and good customs in Chinese labels.
(4) The use of words such as "applicable to the entire population" and "for whole family use" or the use of trademarks, patterns, homophonics, letters, Chinese Pinyin, numbers, symbols, packaging forms, etc. to imply that the product is intended for use by children, but has not been registered as a children's cosmetics. If the packaging is printed with children's patterns, the user group should be reported as "ordinary people" in the filing system.
(5) If other words or symbols are used in the packaging of domestic products, the corresponding explanations in standard Chinese characters are not used on the visible surface of the product sales packaging.
(6) The use of innovative terms in cosmetics labels that have not yet been widely used in the industry makes it difficult for consumers to understand, but are not prohibited from labeling content, and their meanings have not been explained in adjacent positions.
(7) The label content and manual content of the uploaded image exceed the content stated in the product label sample. If the storage conditions of the product are indicated in the Chinese label, the corresponding content is not specified in the label sample.
Special reminder: According to the Announcement No. 77 of 2021 issued by the State Food and Drug Administration on the Implementation of the "Measures for the Administration of Cosmetic Labels", cosmetics that have been filed before May 1, 2022 and have not been labeled in accordance with the "Measures for the Administration of Cosmetic Labels" must have their product labels updated by May 1, 2023, in order to comply with the provisions and requirements of the "Measures for the Administration of Cosmetic Labels".
— end—
Source: Beijing Municipal Drug Administration
Answer: According to Article 3 of the "Measures for the Administration of Cosmetic Labels", cosmetic labels refer to the text, symbols, numbers, patterns, and other markings used to identify and explain the basic information, attribute characteristics, and safety warnings of the product on the sales packaging, as well as the packaging containers, packaging boxes, and instructions with identification information. That is to say, labels include both "software" information and "hardware" information carriers.
Question 2: What is the minimum sales unit? What are the requirements for the minimum sales unit label in the "Cosmetics Label Management Measures"?
Answer: The definition of minimum sales unit: The minimum packaging form of a product that is delivered to consumers along with product packaging containers, boxes, and product manuals for the purpose of product sales.
According to Article 5 of the "Measures for the Administration of Cosmetic Labels", the minimum sales unit of cosmetics should have labels. The label should comply with relevant laws, administrative regulations, departmental rules, mandatory national standards, and technical specifications. The content of the label should be legal, authentic, complete, accurate, and consistent with the relevant content of product registration or filing.
Cosmetic labels should be clear, durable, easy to recognize and read, and there should be no signs of words falling off or sticking loosely.
Question 3: What are the special provisions for labeling different packaging in the "Cosmetics Label Management Measures"?
Answer: (1) Products with packaging boxes
According to Article 7 of the "Measures for the Administration of Cosmetic Labeling", products with packaging boxes should also be labeled with the Chinese name and expiration date of the product on the packaging containers that come into direct contact with the contents.
According to Article 14 of the "Measures for the Administration of Cosmetic Labeling", when labeling the expiration date on packaging containers that come into direct contact with the contents, in addition to selecting the production date and shelf life or the production batch number and expiration date for labeling, the production batch number and expiration date after opening can also be labeled.
(2) Small size packaging products
According to Article 17 of the "Measures for the Administration of Cosmetic Labeling", small size packaged products with a net content of no more than 15g or 15mL of cosmetics only need to be labeled on the visible surface of the sales packaging with the Chinese name of the product, the registration certificate number of the special cosmetics, the name of the registrant or registrant, net content, and service life. Other information that should be labeled can be labeled in the accompanying product manual.
Answer: According to Article 6 of the "Regulations on the Supervision and Administration of Children's Cosmetics", firstly, children's cosmetics should be labeled with the children's cosmetics logo specified by the National Drug Administration on the sales packaging display surface, namely "Little Golden Shield"; Secondly, children's cosmetics should be guided by "caution" or "warning", and warning phrases such as "should be used under adult supervision" should be marked on the visible surface of the sales packaging. In addition, cosmetic registrants and registrants are encouraged to use anti-counterfeiting technology and other means on their labels to facilitate consumers' identification and selection of legitimate products.
Question 5: What are the common problems with filling in the product label module in the filing system?
Answer: 1. Incomplete filling of net content
For products with multiple specifications, all specifications should be filled in the "Net Content" column, and not just one specification.
2. Other special claims not checked accordingly
(1) Specific claims (claims applicable to sensitive skin)
When declaring "suitable for all skin", "suitable for sensitive skin" or similar expressions in the product label, the claim should be checked.
(2) Declare quantitative indicators (time, statistical data, etc.)
The claim of efficacy should be checked for retention time, relevant statistical data, and specific pH values in the product label.
3. The uploaded label image in the attachment does not meet the requirements
The label images include a floor plan of all visible packaging surfaces and a three-dimensional display that reflects the appearance of the product. The images should be complete and clear. The floor plan should be easily distinguishable from all marked content; If it is not possible to clearly display all the marked content, a partial enlarged drawing or product packaging design drawing should also be submitted. The complete floor plan includes pictures of the top and bottom of the product packaging. When uploading design drawings for floor plans and stereoscopic displays, information such as color and size should not be labeled.
4. Sales Packaging Plan
(1) The information in the product label, such as the address of the registrant, the address of the production enterprise, and the standard number of the product execution, is inconsistent with the corresponding information in the filing application form.
(2) The Chinese labels of imported products do not reflect the content related to product safety and efficacy claims in the original packaging labels. If there is a claim about the efficacy of the raw material in the original packaging, the Chinese label does not indicate it accordingly.
(3) Mark vulgar, feudal superstition, or other content that violates social order and good customs in Chinese labels.
(4) The use of words such as "applicable to the entire population" and "for whole family use" or the use of trademarks, patterns, homophonics, letters, Chinese Pinyin, numbers, symbols, packaging forms, etc. to imply that the product is intended for use by children, but has not been registered as a children's cosmetics. If the packaging is printed with children's patterns, the user group should be reported as "ordinary people" in the filing system.
(5) If other words or symbols are used in the packaging of domestic products, the corresponding explanations in standard Chinese characters are not used on the visible surface of the product sales packaging.
(6) The use of innovative terms in cosmetics labels that have not yet been widely used in the industry makes it difficult for consumers to understand, but are not prohibited from labeling content, and their meanings have not been explained in adjacent positions.
(7) The label content and manual content of the uploaded image exceed the content stated in the product label sample. If the storage conditions of the product are indicated in the Chinese label, the corresponding content is not specified in the label sample.
Special reminder: According to the Announcement No. 77 of 2021 issued by the State Food and Drug Administration on the Implementation of the "Measures for the Administration of Cosmetic Labels", cosmetics that have been filed before May 1, 2022 and have not been labeled in accordance with the "Measures for the Administration of Cosmetic Labels" must have their product labels updated by May 1, 2023, in order to comply with the provisions and requirements of the "Measures for the Administration of Cosmetic Labels".
— end—
Source: Beijing Municipal Drug Administration
