500 Questions and Answers on Issues Related to the Filing of Domestic General Cosmetic Products in China

Preface

1 General Section

1-1. What are the commonly used websites for the filing of general cosmetics?

1-2. How to use the Cosmetics Registration and Filing Information Service Platform?

1-3. What points should be noted during the application process for an enterprise account?

1-4. Recently, many issues have emerged with the new filing system. How can I contact the staff in charge of the filing system?

1.5. In the new system, the legal representative has already granted authorization to the handling agent, yet the system shows that the handling agent has no enterprise information authorization and thus cannot apply for a pre-filing number. How can this issue be resolved?

1-6. How long does the review process take after the "Enterprise Information" of the new system is submitted?

1-7. For the filing of ordinary cosmetics via the new system, should it be done before or after obtaining the pre-filing number?

1-8. How to cancel products of the legacy system?

1-9. What are the key points of the new regulations to be noted in the supplementary recording of cosmetics registration and filing products starting from May 1,2022?

1-10. What are the key points of the new regulations to be noted for the labeling of cosmetics registered and filed as of May 1,2022?

1-12. What are the key points of the new regulations to be noted regarding the summary of basis for efficacy claims of products containing prohibited ingredients in cosmetic registration and filing as of May 1,2022?

1-13. For product supplementary entry, what are the differences between imported products and domestic products?

1-14. How long does it take to complete the filing of general cosmetics?

1-15. How should cosmetics manufactured in China upon entrustment by overseas parties be filed for registration, and what are the filing requirements for those exclusively for export?

1-16. Is it allowed to use copies of the original filing documents when re-filing for imported general cosmetics after their cancellation?

1-17. What contents should be included in the resume of the person in charge of quality and safety?

1-18. Can the person in charge of quality safety hold concurrent posts in different cosmetic registrants, filing entities and entrusted manufacturing enterprises?

1-19. If the registrant/filing entity has no production capacity and entrusts another cosmetic manufacturer, can it borrow the person in charge of quality and safety from the entrusted manufacturer?

1-20. May the person in charge of quality and safety authorize another person to perform his or her duties on his or her behalf?

1-21. Do cosmetics registrants and filers engaged in cosmetics production activities need to additionally activate account permissions in the name of a "manufacturing enterprise"?　

1-22. Is it necessary to affix the official seal page by page on the materials related to cosmetics user information?

1-23. What might be the cause of the unresponsive page during the record-filing operation of the new system?

1-24. If the filing entity both manufactures products on its own and acts as a contracted manufacturer for other parties, does it need to activate the role of a manufacturing enterprise?

1-25. What should be done if the enterprise information in the product filing still shows the pre-change information after the enterprise information is updated?

1-26. How to obtain a test system account for a newly registered account on the new registration and filing platform?

1-27. How to handle the situation where the submitter of the inspection report is inconsistent with the registrant/filing holder of the product due to historical reasons?

1-28. Why does the system prompt "Filing information form not uploaded" when I click Submit?

1-29. When submitting the filing materials, why does the system display "Error reason: Please contact the administrator, the system cannot find the approver for the current user!"?

1-30. Can changes be made after the product filing materials are submitted but before they are publicly announced?

1-31. After the entrusting party of the old system completes the post-filing inspection, if the post-filing inspection of the entrusted party is ordered to make rectification, can the entrusting party continue to make changes and modifications in the old system?

1-32. When submitting the product after it has been ordered to make corrections, a prompt appears: "Error reason: Filing application submission failed! The submitter is not the same person as the first filer. " How to handle this?

1-33. If rectification is ordered, since the packaging part does not involve formula-related issues, how should the rectification be carried out? Should the change be initiated in the old system, or can it only be restarted from the new system?

1-34. I would like to ask whether the filing of general cosmetics has a validity period? If yes, how long is the validity period?

1-35. During the filing process of general cosmetics, the product was initially manufactured through a consignment arrangement between the entrusting party and the entrusted party, with the filing completed in the name of both parties. Later, due to adjustments in client requirements, the ownership of the previously developed product was transferred to the entrusted party, and the filing was converted to the form of self-production. As the stock of packaging materials is marked in the consignment format, the initial consignment-based filing has not been cancelled. In this case, is it compliant and permissible for the product to be sold normally when two filing forms coexist for a single product?

1-36. Both the filing authority for general cosmetics and the entrusted party have completed the online filing procedures for general cosmetics. When the general cosmetics are submitted for on-site verification, the entrusted party has passed the verification, but the entrusting party fails to conduct the on-site verification in a timely manner or submits incomplete materials, and the drug regulatory system issues a rectification order for reasons unrelated to product quality. In this case, can the products already on the market continue to be sold normally?

1-37. How to register imported cosmetics claimed to be for use by pregnant women?

1-38. If a compound raw material is purchased and directly filled for sale, how should the product filing be handled?

1-39. A new system account has been created, but the enterprise has now been deregistered. Should the enterprise account be deregistered via the "Enterprise Information and Data Management" section of the Cosmetics Registration and Filing Platform, or via the Service Hall? If the account is deregistered, will all product information that was originally filed under this account be deregistered along with it?

1-40. How should cosmetics registrants and filing entities retain product samples? How to determine the quantity of retained samples?

1-41. Where shall the registrants and filing parties of imported cosmetics keep samples of the cosmetics they import into China?

1-42. If the filing of a general cosmetic has been completed and cancelled, can the products with production date before the cancellation be normally sold until the end of their shelf life?

1-43. Is there a validity period for the pre-filing number that has been applied for?

1-44. Should cosmetics operators establish and implement a product sales record system?

1-45. Can beauty salons, barbershops, hotels and other similar establishments formulate and fill cosmetics?

1-46. If consumers buy cosmetics from a company whose cosmetics production license has been revoked via online shopping, does the online store involved violate relevant regulations?

1-47. How to determine whether a cosmetic product contains harmful additives?

1-48. Can a single cosmetic that has completed the filing of general cosmetics and a disinfection product (antibacterial hand sanitizer) that has completed filing be combined into a set for sale together?

1-49. According to Item (3) of Article 10 (Requirements for Labeling of Enterprise Information) of the *Measures for the Administration of Cosmetic Labeling (Draft for Comment)*(Drug Administration Cosmetic Letter [2020] No. 105), "the name and address of the manufacturer shall be those of the manufacturer that completes the final process in contact with the contents", the phrase "the final process in contact with the contents" can be interpreted as the filling process.The conditions of our company's production activities comply with the requirements of Article 26 of the Regulations on the Supervision and Administration of Cosmetics (State Council Decree No. 727) and the Work Specifications for Cosmetics Production Licensing (No. 265 of 2015). However, in terms of production equipment, we do not have a production emulsification workshop, only relevant production facilities and equipment for filling. Does this meet the requirements for applying for a cosmetics production license?

1-50. If a manufacturing enterprise expands its production facilities based on the existing workshop, and accordingly changes the addresses on its business license and production license simultaneously (the scope of the address after change is larger than that of the original address), can the old-version packaging materials (with the address being the one before the change) be normally used in the transitional production process?

1-51. The product is manufactured by two contracted manufacturers A and B as entrusted by the filing sponsor, and the filing has been completed normally (with the entrusting party associated with A and B). After the production license of Manufacturer A is cancelled, can the packaging materials (marked with contracted manufacturers A and B) still be used up in the production process at Factory B?

1-52. Who are the personnel directly engaged in cosmetic production activities? What are the diseases that may jeopardize the quality and safety of cosmetics as stipulated by the competent health department of the State Council?

2. Filing Application Form

2-1. Which products do not fall under the definition scope of cosmetics?

2-2. How to file for products that claim to be for intimate area cleansing (without claiming bacteriostatic effect)?

2-3. Foot bath solutions are products made from raw materials such as vinegar, milk or plant extracts. They are poured into warm water for foot soaking to achieve the effects of warming the feet and delivering a pleasant fragrance. Are such products classified as cosmetics?

2-4. Products that are directly applied to the human scalp and hair, have one or more of the functions of hair care, cleansing, oil control, hair growth promotion, itch relief and dandruff removal, and also have a bacteriostatic effect — do such products belong to disinfection products, cosmetics, or pharmaceuticals?

2-5. Is tattoo and permanent makeup pigment classified as a special cosmetic? If an enterprise intends to produce and sell tattoo and permanent makeup pigment, what categories must be included in the licensed items on the production license?

2-6. Which products shall be declared as special cosmetics?

2-7. The product is labeled to deodorize and eliminate underarm odor, and it works by spraying to achieve deodorization and underarm odor removal. Is this product a cosmetic or a disinfectant?

2-8. Could you please advise whether shampoos with the "hair breakage prevention" function can currently be filed as "ordinary cosmetics", or whether such products must be regulated as "special cosmetics"?

2-9. A customer intends to produce a mask product consisting of a serum and a powder for combined use, which is packaged in the same aluminum pouch; when in use, the serum in the upper part needs to be squeezed into the of the aluminum pouch where the powder is contained. The serum will be manufactured by our company, while the powder will be produced by another manufacturer. Could you please advise on how to file for the registration of such a product?

2-10. Are free gift samples (non-saleable items) required to be filed for record?

2-11. Is it mandatory to upload the supporting documents for record filing?

2-12. What are the different types of suit forms?

2-13. How to register the first type of kit? (The product contains two or more (including two) individually packaged components)

2-14. How to register the second type of kit? (Non-detachable combined packaging)

2-15. How to file for the third type of kit? (Products that are used in combination of two or more)

2-16. For a skin care lotion, the semi-finished product is purchased by domestic Company A from overseas and then filled and packaged by domestic Company B in China. Is this skin care lotion considered an imported commodity? Is Company A, which conducts the packaging, regarded as the actual manufacturer, and does its enterprise information need to be displayed on the product?

2-17. Multiple imported products are listed on the same production and sales certificate. Is it necessary to submit the original sales certificate for each product? If a copy is submitted, is notarization still required?

2-18. What is the classification code for cosmetics?

2-19. What are the classification codes for cosmetic efficacy claims?

2-20. What are the classification codes for the application sites of cosmetics?

2-21. What are the categories in the coding system for the applicable population of cosmetics?

2-23. What are the application methods used in the classification code of cosmetics?

3 Basis for Product Naming

3-1. What are the requirements if the common name in a cosmetic name uses a specific raw material name or a term indicating the category of raw materials?

3-2. How to standardize the filling of the naming basis for cosmetic filing product names?

3-3. Requirements for the use of registered trademarks in the filing of general cosmetics

3-4. What requirements shall be met for the use of trademarks on cosmetic labels?

3-5. If a product has multiple registered trademarks, how to submit via the newly registered filing platform?

3-6. The product has two trademarks: one is an English trademark (which has been registered and obtained the registration certificate), and the other is a Chinese trademark which is the transliteration of the English trademark. Now we plan to launch new products, and both trademarks will be marked on the outer packaging (the English trademark actually mainly serves to decorate the color box). Do we need to mark the TM symbol and R symbol respectively when labeling? If a product has multiple registered trademarks, please upload them together in one document.

3-7. May I ask whether the following two Chinese trademarks can be used on the same product at the same time?

3-8. The name of a cosmetic product shall generally consist of a trademark name, a generic name and an attribute name. Could you please clarify whether "essence" can be used as an attribute name? (It has been found that such names exist in the inquiry of domestic special-use cosmetics.)

3-9. The product is urgently needed to be launched on the market, but currently there is only a TM trademark and no R mark. Is it possible to use this trademark for record-filing?

3-10. After a product has been filed for record, its trademark is changed. For example, the trademark was still under registration acceptance when the product was filed for record, but later the trademark failed to pass the registration process and needs to be changed. What procedures should be followed?

3-11. Is it acceptable for the English text on the trademark certificate to differ in capitalization from the English text on the product label?

3-12. If a product name contains foreign letters, and the trademark has been registered abroad but not in China, is it acceptable to provide the foreign registered trademark for record-filing purposes?

3-13. If a registered trademark contains filed prohibited words, can such a prompt appear during the trademark registration process: According to relevant cosmetics regulations, this trademark contains prohibited words?

3-14. For each individual product included in the set filing, is it required to add the name of the set as well?

3-15. The issue of using "stock solution" as the attribute name.

3-16. If the product formula consists solely of plant extracts, can the product be named as "hydrosol"?

3-17. Do the terms "all-effect" in "all-effect laundry detergent" and "highly-effective" in "highly-effective laundry detergent" comply with the national naming requirements?

3-18. Can spaces be used in the naming of cosmetics?

3-19. Can "ancient prescription", "Han prescription" and "Miao prescription" be used in cosmetic trademark names?

3-20. Can "Xinglin" be used in a cosmetic trademark name?

3-21. Can "Yingningkang" be used as a cosmetic trademark name?

3-22. What are the points for attention in filling in the product name?

3-23. How to file for the record when using non-Chinese registered trademarks in product names?

3-24. Common Prohibited Expressions – Absolute Terms

3-25. Common Prohibited Expressions – False Semantic Meanings

3-26. Common Prohibited Expressions: Exaggerated Meanings

3-27. Common Prohibited Expressions — Medical-related Terms

3-28. Common Prohibited Expressions: Words or phrases that are unrelated to product features and difficult for consumers to understand.

3-29. Common Prohibited Expressions — Vulgar Connotations

3-30. Common Prohibited Expressions – Meaning of Terms Related to Feudal Superstitions.

4 Product Formulation

4-1. How to make supplementary entry if the standard Chinese name or INCI name of raw materials in the formula of historical cosmetic products is inconsistent with the *Catalog of Used Cosmetic Raw Materials (2021 Edition)*?

4-2. How to correctly fill in the safety information of cosmetic raw materials during the cosmetic registration and filing process?

4-3. How to log in to the Cosmetic Raw Material Safety Information Registration Platform, and is it necessary to register an account?

4-4. After the launch of the Cosmetic Raw Material Safety Information Registration Platform, can raw material information only be associated via the raw material submission code?

4-5. How to fill in the safety-related information of cosmetic ingredients?

4-6. What content does the safety-related information of raw materials include?

4-7. How to define a raw material manufacturer?

4-8. Can raw material distributors submit safety-related information of cosmetic raw materials via the Cosmetic Raw Material Safety Information Registration Platform?

4-9. Is a raw material producer only allowed to authorize one other enterprise to submit safety information?

4-10. How to generate the raw material submission code?

4-11. Usage of Raw Material Submission Code

4-12. Are there any differences between the raw material safety information sheet, raw material submission code, and raw material quality specification?

4-13. How to provide the raw material safety information sheet, raw material submission code, and raw material quality specification?

4-14. Which raw materials are subject to the quality specification requirements specified in the *Safety and Technical Standards for Cosmetics*?

4-15. How to submit information related to raw material quality and safety for production water?

4-16. What are the points for attention when filling in and submitting the raw material submission code?

4-17. Can multiple raw material submission codes be submitted?

4-18. The new system requires the full ingredient list to be submitted in the product formula. If the addition content of individual raw materials in the formula needs to be adjusted due to various factors in production, is it allowed to fill in the content as a value range?

4-19. What are the hydrocarbons derived from petroleum coal tar?

4-20. Compared with the Catalogue of Used Cosmetic Ingredients (2015 Edition), which ingredients in the Catalogue of Used Cosmetic Ingredients (2021 Edition) have had their Chinese names updated?

4-21. Which ingredients in the Catalogue of Names of Used Cosmetic Ingredients (2021 Edition) have been newly included in the management of prohibited substances?

4-22. If a formulation contains nanomaterials, how should it be labeled in the formulation list?

4-23. If a product formula contains a propellant that comes into direct contact with the product content, how should the propellant be reported?

4-24. If the product formula contains denatured alcohol, how should it be filled in and reported?

4-25. Is a component with a content of 0.1% classified as a trace component?

4-26. How should ingredients with a content not exceeding 0.1%(w/w) in cosmetic formulations be labeled?

4-27. Should raw materials with a content of less than 0.1% be arranged in descending order when filling in the formula in the filing system?

4-28. How to sort in descending order when the formula is reported in the form of compounded or mixed raw materials?

4-29. How to fill in the colorant information in the cosmetics filing management system?

4-30. By what time node should the safety-related information of raw materials be submitted?

4-31. By what time should the supplementary entry of products from the old system be completed?

4-32. What does the supplementary record content include?

4-33. If a product formula contains flavor raw materials, how should it be filled in when submitting the product formula and what materials need to be provided?

4-34. What are the requirements for filling in the purpose of using raw materials?

4-35. What should be noted when applying for products using patch or film-type carrier materials?

4-36. What is the function of the remarks column in the raw material formula sheet?

4-37. When filling in the product formula, how should the content be filled in?

4-38. Is it reasonable to fill in the solvent-free form of Kathon compounding in the system?

4-39. When filling in the product formulation for vegetable oils such as "sweet almond oil", is it necessary to specify the specific extraction part?

4-40. Can the same raw material be separately declared in the product formulation table of the regular cosmetics filing management system?

4-41. What are the precautions for adding chemical sunscreens to ordinary cosmetics?

4-42. For the same raw material manufacturer, should only one entity be reported or is it allowed to report multiple entities?

4-43. For a product of an old system, one of the raw materials in its formulation is a compound raw material, but a single component was filled in the historical filing. Can the enterprise fill in the actual components when supplementing the product record?

4-44. The ingredient oat (AVENA SATIVA) beta-glucan itself does not have an INCI name, but the system prompts that the field cannot be empty when uploading the formulation table. How should this be handled?

4-45. Why is the component content in the raw materials displayed as blank?

4-46. Why does garbled text appear in the formula after importing the product formula?

4-47. Regarding thimerosal and phenylmercury compounds as permitted preservatives: the 2021 edition of the Catalogue of Standard Chinese Names of Cosmetics in Use does not include the INCI names of phenylmercury compounds and thimerosal. When applying for the filing of eye cosmetics, if such raw materials are to be used, how should the filing be conducted? Or are these raw materials already prohibited cosmetic ingredients?

4-48. 100% pure single essential oil, which is directly extracted from plants and cannot be directly applied to the skin, belongs to which category: cosmetics, or fragrances and flavorings?

4-49. What are the common non-standard issues in product formula labeling?

4-50. Are there documents such as the catalogue of traditional Chinese medicine (TCM) available for shampoo and body wash, as well as the list of commonly added TCM ingredients?

4-51. Issues related to formula submission and reporting.

4-52. What does it mean that there is an error in the formula submission method?

4-53. For the categorized raw materials in the formula, no specific raw material names are indicated.

4-54. The purpose of using the raw materials in the formula does not match the actual situation.

5-55. The compound raw materials are not declared in the form of a compound formulation, or there are errors in the declaration.

4-56. The colorants in the formulation are not labeled with the Color Index Number (CI number).

4-57. Using preservatives or colorants other than the permitted preservatives or permitted colorants.

4-58. Common cases of excessive use of restricted substances.

4-59. Common Cases of Off-Scope Use of Restricted Substances

4-60. Common restricted substances are shown in the table below.

4-61. The category raw materials in the formula are not labeled with specific raw material names.

4-62. Several scenarios where the intended use of raw materials in a formulation does not match the actual use.

4-63. After a product has been filed, if the net content of the product information changes, for example, the net content in the original filing information is 25ml and it is to be changed to 30ml or 30g, what procedures should be followed?

4-64. After a product has been filed, if the percentage of raw materials in subsequently produced products changes (excluding raw materials for restricted substances such as preservatives), is it necessary to conduct re-filing inspection?

4-65. If the common name in a cosmetic name uses a specific raw material name or a term indicating the category of raw materials, what are the relevant requirements?

4-66. In the formula list, compound raw materials need to be listed one by one. What should be done if the composition of each raw material is unknown?

4-67. If a formulation only contains amino acid surfactants such as sodium cocoyl glycinate, disodium lauroyl glutamate, sodium lauroyl sarcosinate, etc. , can it be labeled as "amino acid"?

4-68. Should the ingredients added to cosmetic raw materials for protecting the raw materials, such as antioxidants, preservatives, and stabilizers, be labeled on the product label?

4-69. Is it permitted to change the cosmetic formula?

4-70. How to register and file cosmetics that must be used with instruments or tools?

4-71. How should the product names of essential oil products be written? Are "lavender essential oil" and "kidney care essential oil" acceptable?

4-72. Is phenylethyl resorcinol allowed for use in ordinary cosmetics?

4-73. Can the formula confirmed by the inspection body be changed?

4-74. Our company has declared "plankton extract" in the product formula and submitted it to the inspection agency for testing. Later, we were informed that "plankton extract" is a category of raw materials, and the specific raw materials contained therein should be specified. Now our company intends to make modifications through a change application. Is this permissible?

4-75. What are the precautions for using oligopeptide-1, an oligopeptide raw material?

4-76. The Catalogue of Used Cosmetic Ingredients (2021 Edition) has been implemented. Is it necessary to prepare the supplementary filing formula in accordance with the 2021 Edition for supplementary filing now? If the supplementary filing formula is prepared according to the 2021 Edition catalogue, it will lead to inconsistency between the expression of the filed ingredients and the actual packaging. Is there any problem with this?

4-77. What are the possible adverse reactions caused by the use of AHA (alpha-hydroxy acid)?

4-78. What is the difference between oligopeptide-1 and epidermal growth factor (EGF)? Can EGF be used as a raw material for cosmetics?

4-79. Can Angelica dahurica be added to cosmetics as a formulation ingredient?

4-80. How are plant components in cosmetics defined?

4-81. How should plant extracts be named?

4-82. What documents need to be provided when using extracts from animal organ tissues and blood products as raw materials?

4-83. Hydrogenated vegetable oil*, brown algae extract* — what does the asterisk (*) marked here mean?

4-84. Can a single ingredient from a compound ingredient blend be used alone?

4-85. How to declare deionized water used in products?

4-86. How to declare the use of small molecule water in products?

4-87. Can personal care and cleaning products such as body wash be formulated without adding surfactants?

4-88. Nowadays consumers all prefer pure natural products. Why is it mandatory to add preservatives to most products?

4-89. If "carbomer" as a thickening agent is flagged as problematic, how should the issue be rectified?

4-90. Should a CAS number be reported for hydrocarbons whose origin from petroleum or coal tar is uncertain?

4-91. Where to query the CAS number?

4-92. Where should the type and part of plant extracts be filled in for filing?

4-93. How should colorants be filled in when being declared?

4-94. For products that integrate multiple formulas into one, such as eyeshadow palettes, how should the product formula be declared? Is it necessary to file for each formula separately?

4-95. What should be done if the INCI name of ingredients marked on the original packaging of imported products is inconsistent with the ingredient name in the formula?

4-96. What are the key points in product formula design?

5 New Raw Materials for Product Formulations

5-1. Before applying for the registration and filing of new cosmetic ingredients, user information registration is required. What information is mainly registered?

5-2. When the domestic responsible person registers or records a new cosmetic ingredient, how should the units in foreign language materials such as gallons and pints be declared?

5-3. Matters concerning the change of information of the registrant, filing holder or domestic responsible person of new cosmetic raw materials.

5-4. What are the requirements for the enterprise entity certification documents required for overseas users to register on the Cosmetic Ingredient Safety Information Registration Platform?

5-5. What contents should be specified in the authorization letter of the domestic responsible party when applying for a new raw material user name?

5-6. Can a new cosmetic raw material be authorized to multiple domestic responsible persons?

5-7. What should I do if the authorization letter of the domestic responsible person for new raw materials expires?

5-8. What materials shall be submitted by the registrant or filing applicant of a new cosmetic raw material when applying for the registration of a new cosmetic raw material or handling the filing of a new cosmetic raw material?

5-9. What contents should be included in the development report for new cosmetic ingredients?

5-10. What are the requirements for compiling a brief description of the preparation process for new cosmetic ingredients?

5-11. What contents should the quality control standard for new cosmetic ingredients include?

5-12. How should the safety assessment data for new cosmetic ingredients be compiled?

5-13. Shall the registrant, filing party of new cosmetic ingredients or their domestic responsible person preserve the samples of new cosmetic ingredients?

5-14. What contents shall be included in the label of the sample of a new cosmetic ingredient?

5-15. Can the registration and filing materials of the domestic responsible person for new cosmetic raw materials use foreign language documents?

5-16. What obligations shall the registrant, filing holder or domestic responsible party of a new cosmetic raw material fulfill during the safety monitoring period of the said new cosmetic raw material?

5-17. Is phenylethyl resorcinol allowed to be used in ordinary cosmetics?

5-18. What raw materials are regulated as new cosmetic raw materials?

5-19. Which circumstances mean that a raw material does not fall into the category of new cosmetic raw materials?

5-20. How to correctly understand the filing of new cosmetic raw materials?

5-21. After a new cosmetic ingredient completes registration or filing, what obligations shall the registrant or filing sponsor of the new cosmetic ingredient still perform?

5-22. How to determine whether a new cosmetic ingredient should be subject to registration application or filing based on its attributes?

5-23. The system prompts "There are new raw materials for which no authorization application information has been sent", how to deal with this?

5-24. Why does the formula show new ingredients even though no new ingredients were used?

5-25. What should be noted when filing using new materials that are in the registration period or filing period?

5-26. If a new raw material is ordered to be suspended from use, how should the relevant cosmetics be disposed of?

5-27. How to register and file cosmetics containing new raw materials that are in the monitoring period?

5-28. Can the fermentation product of a raw material listed in the *Catalog of Used Cosmetic Ingredients* be regarded as equivalent to the raw material itself?

5-29. Is bimatoprost used to promote eyelash growth?

5-30. How are new raw materials for toothpaste managed?

5-31. What should be noted when declaring nano raw materials?

5-32. What are the requirements for the declaration of raw materials derived from biotechnology?

5-33. Functions such as hair loss prevention, acne removal, anti-wrinkle, dandruff removal, and antiperspirant are relatively common, especially in some hair care and hair washing products. Why are the requirements for the declaration of such new raw materials consistent with those for new raw materials with functions like whitening and sun protection?

5-34. What documents need to be provided when using extracts from animal organ tissues and blood products as new raw materials?

6 Product Implementation Standards

6-1. What contents are included in the standards implemented by the product?

6-2. What are the points for attention in the description of production process?

6-3. Is it permissible to omit the canning step in the brief description of the production process?

6-4. How should the raw material phase separation information in the production process of the system be filled in?

6-5. Which process parameters need to be specified in the description of the production process?

6-6. In the "Product Implementation Standard" module of the General Cosmetic Filing Management System, if the same raw material is used in different stages of the production process, how should it be distinguished?

6-7. For products involving segmented production, how should they be indicated?

6-8. How to set the sensory indicators?

6-9. How to set sensory indicators for mask-type cosmetics?

6-10. How should the sensory indicators of set products be set?

6-11. What should I do if the same product comes in multiple colors?

6-12. What should I do if the product color is hard to describe?

6-13. Could you please advise whether the internal control indicators and documents formulated by an enterprise need to be publicly declared online, or they also require online filing?

6-14. If the quality control measures for microbial indicators and physicochemical indicators in the product execution standard include the description of "control of raw material-related indicators", shall the filing party provide a specific explanation for the "control of raw material-related indicators" in the brief description?

6-15. If the quality control measures for microbial indicators and physical and chemical indicators in the product implementation standards include the description of "production process flow control", briefly explain the reason why no specific interpretation has been provided for "production process flow control".

6-16. If the quality control measures for microbial indicators and physical and chemical indicators in the product execution standards contain descriptions of "full inspection" and "entrusted inspection", is it necessary to provide an explanation on the inspection frequency?

6-17. Can the test method be inconsistent with the methods specified in the Technical Specification for Cosmetic Safety?

6-18. How to fill in quality management measures in compliance with regulations?

6-19. Is there any requirement for the inspection frequency of type test?

6-20. The ingredient preparation date and the emulsification date are not the same day. There is a semi-finished product production date in the batch record. Which date should be taken as the standard? Is it the ingredient preparation date or the emulsification date?

6-21. What are the key points for systematic form-filling that should be noted when inspection methods are adopted as quality control measures in the standards implemented for products?

6-22. What are the key points for systematic form-filling that should be noted when non-inspection methods are adopted as quality control measures in the standards implemented by products?

6-23. What are the signs of microbially contaminated products?

6-24. If the recommended national standards or industry standards set a relatively wide range for the pH value indicators of products in relevant categories such as facial cleansers, skin care lotions, and hair perm agents, can enterprises directly refer to the corresponding pH value indicators in the recommended national standards or industry standards when setting the pH value control range for specific products?

6-25. Ingredients with specified pH restrictions and requirements in the *Safety and Technical Standards for Cosmetics*, such as potassium hydroxide, sodium hydroxide, and α-hydroxy acids (and their salts and esters), are added to the product formula, yet the pH control is not specified in the standard implemented for the product.

6-26. Regarding the requirements of Clause 6.4 in the implementation standard GB-T 34857-2017, where the type test items are the test items specified in 4.2 and 4.3, such as mercury, lead, arsenic and the like, is it mandatory to obtain a third-party test report? Can the company conduct the test by itself?

6-27. Which items in the microbiological and physicochemical indicators are mandatory to be tested?

6-28. Is it mandatory to conduct microbiological testing on a batch-by-batch basis for products?

6-29. If a facial mask has not been tested for methanol, is it ineligible for product filing?

6-30. Do perfume products not need to undergo microbial testing items?

6-31. How to test multi-shade series sunscreen cosmetics?

6-32. How to inspect multi-shade series of ordinary cosmetics?

6-33. Among the microbiological indicators, there are multiple requirements for the total bacterial count. How to determine which one is applicable?

6-34. Our company manufactures a facial mask, and our internal control standard for the total bacterial count is ≤500 (CFU/g or CFU/mL), while the "Safety and Technical Standards for Cosmetics" stipulates that for cosmetics not intended for eye area, lip area or children, the required total bacterial count shall be ≤1000 (CFU/g or CFU/mL). May I ask if such a filing can be approved?

6-35. When is it necessary to add a methanol project?

6-36. When is it necessary to add the dioxane item?

6-37. When is it necessary to add asbestos-related items?

6-38. When is it necessary to add the free formaldehyde item?

6-39. When is it necessary to add chemical sunscreens?

6-40. When is it necessary to add the pH value item?

6-41. When is it necessary to add the anti-dandruff agent item?

6-42. What should be done if product sampling and testing cannot be conducted due to packaging issues?

6-43. Can the expression "avoid environments with extremely high or low temperatures" be used for product storage conditions?

6-44. How to clearly define the service life of a product?

6-45. For some products, the implementation standard previously adopted was the industry standard, but now a new national standard has been released. How should the product be labeled in this case?

6-46. Control measures for microbial contamination of cosmetics.

6-47. Notes for filling in the product usage method in the product execution standard.

6-48. Requirements for filling in safety warning terms.

6-49. How should the product service life be set?

6-50. What needs to be done when making changes to the product implementation standards where the brief description of production process, microbiological and physical-chemical indicators and quality control measures, directions for use, safety warning statements, storage conditions, shelf life, etc. are altered?

7 Product Labels

7-1. Requirements for content labeling of cosmetics labels and instructions.

7-2. What contents are required for Chinese labels of cosmetics?

7-3. Notes on Labeling of Cosmetic Label Names

7-4. Notes on labeling the name, address and other relevant information of the registrant, filing entity, domestic responsible party and manufacturer on cosmetic labels.

7-5. For cosmetic manufacturers (including registrants, filing entities that conduct self-production, and entrusted manufacturers), if the registered address is inconsistent with the actual production address, how should the address of the manufacturer be labeled?

7-6. Notes on the full ingredient labeling of cosmetics.

7-7. Why is the full ingredient labeling regulation implemented?

7-8. Detailed Explanation of the Regulations on Full Ingredient Labeling

7-9. Which cosmetics are subject to the full ingredient labeling requirement?

7-10. Should the ingredients added to cosmetic raw materials for protecting the raw materials, such as antioxidants, preservatives and stabilizers, be labeled on the product label?

7-11. For products submitted to the new system prior to the implementation of the Administrative Measures for Cosmetic Labeling, shall their label markings be implemented in accordance with the current labeling requirements?

7-12. After the implementation of the Administrative Measures for Cosmetic Labeling, is it necessary to modify the labels of products that have been filed in the new system?

7-13. What does the symbol "Little Golden Shield" for children's cosmetics mean?

7-14. When should the "Little Golden Shield" mark be added to already filed products?

7-15. Can the "Little Golden Shield" logo indicate that a product has passed the quality certification of the relevant authorities?

7-16. What are the requirements for the font and color of the mark for children's cosmetics?

7-17. How to control the size of the child cosmetic label when the same product has different specifications?

7-18. What corrective measures can enterprises take if there are defects in cosmetic labels as stipulated in Article 20 of the Measures?

7-19. How should ingredients with a content not exceeding 0.1%(w/w) in cosmetic formulations be labeled?

7-20. What are the labeling requirements for packaging containers (inner packaging) that come into direct contact with the contents as specified in the Administrative Measures for Cosmetic Labeling?

7-21. How to claim a patent on a label?

7-22. What are the tag guidelines?

7-23. Can cosmetic labels make claims about medical research institutions and time-honored pharmaceutical brands?

7-24. How to correctly understand the regulation that "the production process of labeling shall be completed within the cosmetics manufacturer that has finished the final production process involving contact with cosmetic contents"?

7-25. Can the term "acid peeling" be labeled on cosmetics?

7-26. Can the names of enterprise filing entities and manufacturing enterprises that contain medical-related terms such as "Li Shizhen Chinese Medicine" and "**Pharmaceutical" be marked on the label?

7-27. What are the requirements for the floor plans and three-dimensional drawings uploaded for the filing of general cosmetics?

7-28. If a formulation only contains amino acid surfactants, such as sodium cocoyl glycinate, disodium lauroyl glutamate, sodium lauroyl sarcosinate, etc. , can it be labeled as "amino acid"?

7-29. Can the content of the packaging of supplementary registered products be modified in accordance with the requirements of the new label management measures?

7-30. Are the precautions for cosmetics mandatory to be printed on the packaging box? Is it not allowed if they are not written?

7-31. A gift set contains multiple individual products. Is it necessary to label the shelf life for each individual product?

7-32. In cosmetic labeling, if a foreign entity entrusts a domestic entity to conduct filing, both the entrusting party and the entrusted party are required to be indicated. Is it allowed to additionally list a brand owner?

7-33. If the packaging of a cosmetic product is changed while its ingredients remain unchanged, is it necessary to re-conduct the quality inspection report and re-file for the record?

7-34. When filing for product registration, all ingredients were labeled in accordance with regulatory requirements, yet a random inspection by market regulators determined the product label to be non-compliant, on the grounds that the product listed preservatives that were not detected. The regulators have required that all undetectable preservatives be omitted from labeling. Should we revise the label as required by the market regulators, remove all undetectable preservatives, and re-submit for product registration?

7-35. Is it mandatory to list all ingredients on the packaging of cosmetic products? Since our own formula contains certain raw materials that are not convenient to disclose, can we only list the basic ingredients instead?

7-36. The company name has been changed, and all relevant certificates have been processed. I would like to ask whether the packaging materials produced before the company name change can still be used? Is there a transition period? If they cannot be used, is there any legal or regulatory basis for this requirement?

7-37. Can traditional Chinese characters be used on the labels of domestically produced ordinary cosmetics?

7-38. Is it allowed to use foreign languages on the outer packaging of domestically produced ordinary cosmetics with additional Chinese labels attached?

7-39. What are the requirements for the uploaded product packaging images?

7-40. The label information is inconsistent with the information filled in the filing system.

7-41. The address information of the manufacturer marked on the label is incomplete.

7-42. The labeling of product shelf life is non-standard.

7-43. Why can't the label "28ml × 10pcs" be approved for filing?

7-44. Is it permissible to use the wording "upgraded formula" in product claims?

7-45. Is it acceptable for labels to claim "no chemical fragrances"?

7-46. What circumstances are suspected of involving false and exaggerated publicity?

7-47. How to label safety warning statements for children's cosmetics?

7-48. How should products containing chemical sunscreens be labeled with safety warning statements?

7-49. How should safety warning statements be labeled for products containing preservatives?

7-50. How should safety warning statements be labeled for products containing raw materials that are both restricted substances and permitted preservatives?

7-51. How should safety warning statements be labeled for products that claim to contain alpha-hydroxy acids and their salts and esters (or products that do not make such a claim but have an alpha-hydroxy acid content of ≥3%(w/w))?

7-52. How should flammable cosmetics such as nail polish, nail polish remover, nail hardener, and pressure-packaged gel be labeled with safety warning statements?

7-53. Issues concerning foreign languages in trademarks.

7-54. Is it permissible to use foreign patents for promotional purposes?

7-55. Several scenarios of non-standard label annotation guidance.

7-56. How to use the guiding texts on labels for production date and expiration date?

7-57. When labeling ingredients, should the names of various ingredients be separated by spaces?

7-58. When multiple color shades share a unified ingredient list, how should the colorants be labeled?

7-59. Does the packaging claim that food-grade raw materials are used?

7-60. Our company's products use nano-scale raw materials, and we hope to promote this feature. How can we conduct such promotion in compliance with relevant regulations?

7-61. The rectification order states that "the manufacturer's address information indicated on the label is incomplete", but the address of our company is exactly the one we have filed. What's going on here?

7-62. Our company produces a type of nose patch which is black in color and advertised as using bamboo charcoal to remove blackheads. Is it mandatory to contain actual bamboo charcoal ingredients?

7-63. Can a product claim to repair sunburn?

7-64. Prohibited medical terms.

7-65. Among our branded products, there is one containing "medicinal Fomes officinalis extract" as an ingredient, and we promote this ingredient on the label, naming the product set "Medicinal Fomes officinalis Nourishing Set", with the main promotion focusing on the product's moisturizing and nourishing effects. We would like to ask: Can "medicinal Fomes officinalis" be directly used in the naming of a product set? Can this ingredient be promoted on the outer packaging? Can it be used for the filing of domestic ordinary cosmetics?

7-66. If the business license of the entrusting party of a cosmetics enterprise has been changed, but the packaging of the involved special cosmetics and non-special cosmetics has not been changed online, can the packaging materials with the old address in stock be normally used up during the transition period?

7-67. Put words such as "developed by XX Company", "technical support by XX Company" or "supervised by XX Company" on the outer packaging of the product.

7-68. Can two trademarks appear on the outer packaging of a product?

7-69. Regarding the production of Chinese labels for products entrusted by domestic entities to overseas parties, can the "entrusting party" and "entrusted party" on the Chinese label be changed to "exporter (domestic responsible party)" and "actual manufacturing enterprise"?

7-70. Can product packaging claim to be preservative-free?

7-71. For the Chinese-English markings on the outer packaging of a product box, is it required that the Chinese and English texts correspond one-to-one vertically, or is it acceptable as long as the content on different surfaces matches each other?

7-72. For the English part of the Chinese-English bilingual markings on the outer packaging of a product box, is it allowed to be distributed in different positions on the same plane?

7-73. For products manufactured under entrustment, is it mandatory to label both the actual manufacturing enterprise and the repackaging enterprise on the product packaging simultaneously?

7-74. If a product is labeled as "suitable for all skin types", will it be considered to include sensitive skin? Is it necessary to add a warning statement for use by people with sensitive skin?

7-75. If a product comes in two variants (e. g., a moisturizing type and a refreshing type with different formulas), can they use the same packaging and only affix an additional label to distinguish which one is the moisturizing type?

7-76. For the documents required to be uploaded in the online filing of domestic general cosmetics, in addition to the formula, product three-dimensional view and product plan view, is it necessary to upload the following materials in the additional materials, such as:(1) The proof of the origin claimed in the product;(2) If there is a foreign trademark in the product name, whether it is necessary to upload the trademark registration certificate;(3) Whether the organic product claim requires the upload of organic certification;(4) If it is claimed that the product is developed by a certain laboratory, whether supporting certification materials are required.

7-77. Is it mandatory to place the Chinese product name on the front side?

7-78. Is it mandatory to print warning statements on product packaging?

7-79. Is it allowed to include wording such as "target population" on labels?

7-80. What should be done if some of the ingredients indicated on the packaging are somewhat different from those actually submitted to the filing platform?

7-81. For some products, the previously implemented standard was an industry standard, but now a new national standard has been released. How should the product labeling be handled in this case?

7-82. Should ingredients added to cosmetic raw materials for the purpose of protecting the raw materials, such as antioxidants, preservatives and stabilizers, be labeled on the product label?

7-83. For products that have completed historical record filing and information supplementation, if the packaging is changed for the first time, is it only necessary to upload the new packaging images?

7-84. If an enterprise's quality management system has obtained ISO and GMPC certifications, can the relevant marks be labeled on the product?

7-85. Can the phrases "fade wrinkles" and "remove wrinkles" be used in product descriptions?

7-86. Is it permissible to promote "**stock solution" on labels?

7-87. Are all terms containing the character for "white" prohibited for use? For example, whitening, brightening, radiance-boosting, antioxidant? Is a product description like "leaves skin smooth, supple and bright after application" acceptable?

7-88. Can the product name or label contain the words "instant" and "repair"?

7-89. Is it permissible to claim "gene-based brightening with no trace left" on labels?

7-90. How should colorants be labeled on product labels?

7-91. How should the "Other Information" and "Labeled Label Content" fields in the product labels of the new filing platform be filled in?

7-92. A certain facial mask product claims on its original packaging: "Apply it to align with facial acupoints, press gently, it can improve circulation and reduce edema". Does this go beyond the specified usage method of cosmetics?

7-93. What is the "minimum sales unit" of cosmetics? Do free gifts count as such?

7-94. What does "contents" refer to?

7-95. What are the display surface and visible surface of cosmetics?

7-96. What is the guiding text on cosmetic labels?

8 Product Inspection Report

8-1. How to determine the test items for general cosmetics?

8-2. How to determine the testing items for special cosmetics?

8-3. What do the nine routine items for cosmetic testing refer to?

8-4. How to determine the test items for cosmetics using new raw materials?

8-5. How to inspect set samples of different packaging types?

8-6. For the filing of general cosmetics, under what circumstances is the submission of the product's toxicological test report exempted?

8-7. What are the requirements for toxicological tests when gaseous propellants are declared as new cosmetic ingredients?

8-8. What matters should be noted when applying for the filing of multi-color series of ordinary cosmetics that have undergone sampling toxicological tests?

8-9. For ordinary cosmetics that need to be used in combination, how to conduct toxicological tests during the filing process?

8-10. What sunscreen agent tests are required for sunscreen products?

8-11. What are the requirements for cosmetic inspection reports?

8-12. Is there a standard format for cosmetic inspection reports?

8-13. What specific contents are included in the inspection report?

8-14. How to handle the situation where the product name, applicant for inspection, and product registration/filing information in the inspection report are inconsistent?

8-15. For ordinary cosmetics registration, how should samples with different packaging types, different formulas for each part, and only one product name be tested?

8-16. For ordinary cosmetics added with chemical sunscreens, what tests shall be conducted?

8-17. If multiple manufacturers produce the same ordinary cosmetic, how should the test report be submitted during the product filing?

8-18. Does the filed inspection report have an "expiry date"?

8-19. What are the requirements for test reports when a cosmetics manufacturer applies for the filing of domestic ordinary cosmetics? Is it sufficient that the testing institution issuing the test report has CMA qualification?

8-20. If the product formula is qualified but the product name does not comply with relevant regulations, can the test report issued under the non-compliant name still be used?

8-21. If the product has already been sent for inspection first, and a formula discrepancy is found when submitting the filing materials, can this inspection report still be used?

8-22. If a product is to be re-filed under a new name after its cancellation, can the original inspection report be used?

8-23. What materials should be submitted for the product inspection report items of the new filing platform?

8-24. Is it possible to respectively commission two inspection and testing institutions to conduct microbiological testing and physical-chemical testing?

8-25. Can the formula confirmed by the inspection body be changed?

8-26. What are the requirements for inspection of imported products against registered products?

8-27. How to apply to become a cosmetics inspection and testing institution?

8-28. What qualifications are required for cosmetics inspection and testing institutions?

8-29. Do inspection and testing institutions need to retain sample reserves? If yes, what is the retention period?

8-30. How should cosmetics registrants and filing holders retain samples?

8-31. What should a testing and inspection institution do when changes occur due to commercial activities?

8-32. Examine the relevant provisions on the preservation of archival materials.

8-33. What inspection files and materials shall the inspection and testing institution retain?

8-34. What matters should be noted when supplementary testing of the dioxane indicator is required for imported ordinary cosmetics?

8-35. Our company is the domestic responsible person for cosmetics, and some of our products are sold at Hainan outlying island duty-free shops. Since the products at duty-free shops are directly shipped by the overseas filing entity, our company is unaware of the batch numbers of the imported products and cannot implement the sample retention system. Is it feasible for the duty-free shop to retain the samples instead?

8-36. What are the requirements for cosmetic samples submitted for inspection?

8-37. When applying for cosmetic registration or filing, can trial-produced samples be used as the samples submitted for inspection?

8-38. What should be done if product sampling and testing cannot be conducted due to packaging issues?

8-39. What are the toxicological test items for ordinary cosmetics?

8-40. What are the toxicological test items for special cosmetics?

8-41. How to determine the toxicological test items for products that are used in combination of two or more doses?

8-42. What are the items for human safety test? How to determine them?

9 Safety Assessment Documentation

9-1. What are the requirements for product safety assessment materials at the current stage?

9-2. What contents are included in the safety assessment report of cosmetic products?

9-3. What contents are included in the safety assessment report of cosmetic ingredients?

9-4. The new system requires the submission of product safety assessment materials for the filing of general cosmetics. For general cosmetics that have not submitted toxicological test reports, a product safety assessment report shall be submitted. What are the respective qualification requirements for internal company personnel or entrusted external testing institutions to issue the safety assessment report?

9-5. How to conduct a safety assessment for flavorings?

9-6. When evaluating nanomaterials used in a formulation, what relevant information shall be provided?

9-7. For cosmetics that must be used with instruments or tools, how to conduct product safety assessment?

9-8. What issues should be noted in the safety assessment data of children's cosmetics?

9-9. Among the acceptable evidence for the simplified cosmetic product safety assessment report, if the concentration of the raw material in the products that have been marketed by the same enterprise with the same application method for at least 3 years (i. e. the historical use concentration of the enterprise) is taken as the evidence for assessment, how should such evidence be submitted?

9-10. In the safety assessment report, what are the sources of the toxicological safety data of raw materials?

9-11. Two Questions Concerning Safety Assessment

9-12. What should be noted when uploading the safety assessment report?

9-13. What is the relationship between cosmetic ingredients and their safety?

9-14. After the resume of the product safety assessor and the safety assessment report are affixed with the official seal of the assessment entity, is it still necessary to affix the official seal of the filing entity?

9-15. When our company conducts a safety assessment for a new product, we intend to use the maximum usage level of a certain raw material from our already marketed products as supporting documentation to prove the safe application of this raw material in the new product. What materials need to be submitted in this case?

9-16. What are the current requirements for product safety assessment materials at this stage?

9-17. For rinse-off products claiming acne removal or anti-wrinkle effects, can the safety evaluation of human patch test be exempted after submitting a simplified safety assessment report?

9-18. For general cosmetics for children and pregnant women, if toxicological testing has already been conducted during the cosmetics filing process, is it still necessary to conduct a safety risk assessment, and is testing for risk substances still required?

9-19. How to conduct toxicological tests for multi-color series of ordinary cosmetics?

9-20. For imported ordinary cosmetics of a multi-shade series that undergo toxicology tests by sampling in accordance with the Specifications for Cosmetic Registration and Filing Inspection, is it permissible to use copies of the toxicology test reports?

9-21. How to provide supporting materials for the assessment of hazardous substances?

9-22. Requirements for reference materials cited in safety assessment.

9-23. If certain raw materials have chemical, biological or other interactions with each other, how should such interactions be evaluated?

9-24. What are the requirements for retaining cosmetic safety assessment materials?

9-25. Is it necessary to update the safety assessment data of cosmetics?

9-26. What contents are included in the resume of an assessor?

9-27. The specific time for transitioning from the simplified version to the full version of the cosmetic safety assessment report.

9-28. Requirements for the full version of the cosmetic safety assessment report?

9-29. What are the requirements for the simplified version of the cosmetic safety assessment report?

9-30. What are the four procedures that should be followed in cosmetic risk assessment?

9-31. The relationship between toxicological research and cosmetic safety assessment.

9-32. Under what circumstances is it necessary to re-conduct a safety assessment of cosmetics?

9-33. What evidence can be used in the simplified version of the cosmetic product safety assessment report?

10 Efficacy Claims

10-1. How to correctly understand the evaluation of cosmetic efficacy claims?

10-2. What is the significance of efficacy claims?

10-3. What is the efficacy claim evaluation of cosmetics?

10-4. What should be done if the efficacy claims of a registered product fail to meet the requirements of the new regulations?

10-5. Is efficacy claim evaluation necessarily required to be conducted by a third party? What conditions should an efficacy claim evaluation institution meet?

10-6. How to fill in the product efficacy claims for products claiming physical exfoliation and physical blackhead removal?

10-7. What contents need to be filled in the summary of the basis for cosmetic efficacy claims?

10-8. What preliminary preparations are required if a product is to undergo human safety and efficacy evaluation testing?

10-9. What are the efficacy evaluation tests?

10-10. For cosmetics whose effects can be directly recognized through senses or only produced by physical means, how to apply for exemption from publishing the summary of the basis for product efficacy claims on the filing system?

10-11. How to conduct efficacy promotion evaluation for cosmetics with specific claims?

10-12. Cosmetics that make efficacy claims based on the efficacy of their raw materials.

10-13. How should cosmetics claiming new efficacy undergo efficacy claim evaluation?

10-14. Can a wrongly submitted summary of efficacy claims be withdrawn and modified?

10-15. Which cosmetics are exempted from the requirement of publishing the summary of the basis for product efficacy claims?

10-16. Which cosmetics can undergo efficacy claim evaluation through methods such as literature research, research Data Analysis, or cosmetic efficacy claim evaluation tests?

10-17. Which cosmetics shall undergo efficacy claim evaluation by means of cosmetic efficacy claim evaluation tests, in combination with the results of literature review or research Data Analysis?

10-18. Which cosmetics shall undergo efficacy claim evaluation via human efficacy evaluation tests?

10-19. For cosmetics belonging to the same series that only differ in shade numbers due to different added colorants, is it necessary to conduct multiple efficacy claim evaluations?

10-20. Requirements for equivalent evaluation of cosmetic efficacy claims.

10-21. For products applying for initial filing as of January 1,2022, is it required to timely fill in the summary of the basis for product efficacy claims?

10-22. By what deadline should the summary of the basis for cosmetic efficacy claims be uploaded?

10-23. For product efficacy, are enterprises allowed to comply with industry standards, group standards or enterprise standards as the basis?

10-24. Common Circumstances of Non-Standard Claims

10-25. The product is suspected of having issues involving false or non-compliant claims.

10-26. Several key time points in efficacy test reports for skin whitening, spot fading and hair anti-loss products.

10-27. For products that have been filed in the current historical record and are undergoing their first efficacy claim change after completing information supplementation, is it only necessary to upload images of the new packaging?

10-28. The product has already obtained the special cosmetic certificate for sun protection or the special cosmetic certificate for spot fading, but words related to whitening are also used in the product name and label claims. Can such a product still be sold normally? Is it compliant?

10-29. What is your view on the inconsistent classification standards for efficacy claims and the phenomenon of "double standards" existing in different regions and cities?

10-30. Our company intends to import a batch of wax products and declare them as depilatory cosmetics. Is it permissible to claim "get rid of the troubles caused by fine facial hairs" and "facial hair removal" on the labels?

10-31. Does mascara have the effect of "promoting eyelash growth"?

10-32. What efficacy claims can be made for toothpaste?

10-33. Cosmetics for hair loss prevention, acne removal, anti-wrinkle, dandruff removal and antiperspiration shall be subject to strict administration.

10-34. Requirements for the summary of the basis for cosmetic efficacy claims.

10-35. What contents does the efficacy claim report include?

10-36. What kind of literature materials can support the efficacy claims of cosmetics?

10-38. What kind of research data can support the efficacy claims of cosmetics?

10-39. What is a human efficacy evaluation test that can support the efficacy claims of cosmetics?

10-40. What is a consumer use test that can support efficacy claims for cosmetics?

10-41. What are laboratory tests that can support efficacy claims for cosmetics?

10-42. What are the points for attention when filling in the summary of the basis for cosmetic efficacy claims?

10-43. There are only 19 efficacy claim terms specified in the current regulations, which is far too few. What if we accidentally end up making a new efficacy claim?

10-44. If efficacy-related terms are used, one must either select 19 qualifying terms or classify the claim under "new efficacy" — does this mean efficacy claims are being "forcefully categorized"?

10-45. Can a product be modified if one or more efficacy claims are added or removed based on its original efficacy?