China cosmetics label requirements have been clarified further following a recent announcement by the NIFDC (National Institute for Food and Drug Control). The NIFDC has clarified whether antioxidants, preservatives, stabilizers, and other protective ingredients that are added to cosmetic raw materials should be marked on the product label.
Extremely small amounts of antioxidants, preservatives, stabilizers and other protective ingredients are added to raw materials in order to preserve their quality. These cosmetic ingredients are then used in product formulations during production and thereby play a role in the final product.
ACCORDING TO CHINA COSMETICS LABEL REQUIREMENTS, SHOULD INGREDIENTS BE MARKED ON THE PRODUCT LABEL?
Antioxidants, preservatives, stabilizers, and other protective ingredients are not strictly considered “cosmetic ingredients”. However, they have to appear on the list of ingredients in the product formulas which is required when registering or filing a new cosmetic product for sale in mainland China.
The NIFDC has announced that these “protective ingredients” do not have to appear on the product label. Companies may choose to list them on the product label to protect consumers’ right to know.
As a reminder, “The Measures” requires all ingredients to be listed in descending order of their content unless the ingredient is less than 0.1 percent (W/W) in the product formula. All ingredients that do not exceed 0.1% (w/w) of the product formula must be listed under “other microconstituents” on the Chinese label.
And this requirement to list ingredients applies equally to free samples, giveaways, gifts, and cosmetics products that are “not for sale”.
This clarification on listing antioxidants, preservatives, stabilizers and other protective ingredients on cosmetics labels in China applies to new product registrations and filings as of May 1, 2022. However, as of May 1, 2023, it will apply to ALL cosmetics that are currently on the market i.e. those cosmetic products that have already received a filing or registration approval.
For further information on “The Measures” (China cosmetics label requirements), read our article here: https://www.cisema.com/en/nmpa-issued-administrative-measures-on-cosmetics-labeling/
As China Regulatory and Registrations specialists, Cisema can assist you with ensuring your cosmetics are fully compliant with the changing regulatory landscape.
Cisema covers all your needs from domestic responsible agent to registration, from post-market compliance to in-China localization.
Send us your enquiry to see how we can help you.