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Analysis of Cosmetic Labeling Compliance (1)

China NMPA Regulations Notice

According to the Regulations for the Supervision and Administration of Cosmetics, China NMPA drafted and issued the Measures for the Administration of Cosmetics Labels (hereinafter referred to as the Measures) on June 3, 2021.

It defines the label of cosmetics and clarifies the main responsibilities of cosmetic registrants and filing applicants, as well as the requirements for the content and form of cosmetic labels. In addition, it stipulates what shall be labeled and marked on cosmetic labels, and what shall be prohibited from being labeled and marked. It also specifies the specific circumstances of label defects and their relevant laws and regulations.

The label content shall be legal, true, complete, accurate, and consistent with the relevant content of product registration or notification. Cosmetic registrants and notification persons shall be responsible for the legality, authenticity, integrity, accuracy, and consistency of cosmetics labels.

EnterCo has sorted out key points of the new Measures of cosmetic labels within ten articles.

1. Implementation Date

As of June 3, 2021, cosmetics registrants and filing applicants are encouraged to label and mark cosmetics according to the Measures.

As of May 5, 2022, cosmetics under application for registration or filing must comply with the Measures.

For cosmetics that have completed the registration and filing before May 1, 2022, and have not been labeled and marked in accordance with the Measures, the cosmetics registrants and filing applicants must complete the update of product labels prior to May 1, 2023, so as to make them comply with the Measures.

2. Scope of application

The label management of cosmetics produced and operated within the Chinese Mainland is applicable to the Measures. Export only, cross-border e-commerce, inside the national border but outside the customs territory (such as airport duty-free shops) and other sales channels are not applicable.

3. Definition of cosmetics labels

Cosmetics labels refer to the words, symbols, numbers, patterns, and other marks used to identify and explain the basic information, attributes, and safety precautions of products on the sales packages, as well as the packaging containers, packaging boxes, and instructions with marking information.

According to the definition, cosmetics labels can be understood from three aspects:

Contents: basic product information, attributes, and safety precautions

Content forms: words, symbols, numbers, patterns, and other marks

Content carriers: packaging containers, packaging boxes, and instructions with marking information

4. Basic terms of cosmetics labels

Some basic terms related to cosmetics labels should be understood in advance:

  • Minimum sales unit: The minimum packaging form for the purpose of product sales when the product contents are delivered to consumers with product packaging containers, packaging boxers, and product instructions.

  • Sales package: The packaging of minimum sales unit, which includes packaging containers that directly contact contents, packaging boxes in which the packaging containers are placed, and instructions attached to the products.

  • Contents: The product is contained in a packaging container. Display surface: Any surface that can be seen by consumers except the bottom surface when cosmetics are displayed. (1-5 in the schematic diagram are display surfaces)

  • Visible surface: Any surface of cosmetics that can be seen by consumers without damaging the sales package. (1-6 in the schematic diagram are visible surfaces)

  • Guide words: words used to elicit/lead out the marked content, such as "product name", "net content", etc.

Cosmetic Product Packaging


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