On June 3, 2021, the NMPA released the Administrative Measures on Cosmetics Labeling (hereinafter referred to as “Measures”), that will be implemented in different phases:
| Applicant | Voluntary Period | Mandatory Start |
| New applicant | June 3, 2021 – April 30, 2022 | May 1, 2022 |
| Applicants with registrations / filings successfully approved before May 1, 2022 | June 3, 2021 – April 30, 2023 | May 1, 2023 |
For cosmetics registration and filing, GB5296.3 has always been the guiding principle for labeling requirements. The implementation of the “Measures” is a tailored and exclusive guidance to further standardize the labeling of cosmetics whilst making some changes to the GB5296.3 as indicated in the comparison table below.
| Conditions | Before | After |
| Labeling for DRAs (Domestic Responsible Agents) and factories | Name and address of the applicants are required for registration and filing | In addition to the applicant’s, the name and address of the DRAs and factories will also be required |
| Labeling for cosmetics with outer packaging and containers that have direct contact with the contents | / | According to the labeling requirements, the Chinese name of the product and product expiration dates* must be indicated |
| More than one factory designated by the registrant / filer to be part of the final production process (excluding the packaging process) | / | The names and addresses of all the factories can be displayed together on the Chinese Label |
| Labeling of raw materials | List the ingredients by names | In addition to the list of ingredient names, all cosmetic ingredients that do not exceed 0.1% (w/w) of the product formula should be listed under “other microconstituents” |
| Labeling of Product Name Indicator | The Chinese name of the product without the indicator in front would suffice. | The product name indicator “中文产品名称:/Chinese Product Name:” must be shown before the actual Chinese name of the product. |
| Labeling for instructions for use | Instructions for use was only recommended but not mandatory | Instructions for use must be displayed on the Chinese Label |
By James Xu. Contact Cisema if you would like to learn more.
