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Analysis of Cosmetic Labeling Compliance (7)

This article mainly analyzes cosmetic efficacy marked on the cosmetic label.

The labeling of cosmetic efficacy is similar to the site of application, and both of which are not stipulated by relevant regulations. The only difference is that the site of application may not be marked, but the cosmetic efficacy must be marked.

Under the current regulations issued by China NMPA (National Medical Products Administration), cosmetics under application for registration or filing must fill out and submit the product classification code. Without labeling the efficacy, it is impossible to determine the product efficacy classification, whether the product belongs to special cosmetics or general cosmetics, and whether the product meets the definition of cosmetics. Therefore, product efficacy must be marked on the cosmetic label. If the efficacy claim involves innovative terms, it needs to be annotated in the adjacent position.

Labeling methods of cosmetic efficacy

The labeling methods of cosmetic efficacy are not specifically stipulated by the relevant regulations. It can be marked with guide words such as "产品功效(product efficacy)", "产品特点(product features)", "产品作用(product functions)", or marked directly in the cosmetic name, claims and the scope of application, or marked with icons, graphics, etc. It is recommended that the cosmetic efficacy should be marked on the visible surface of the sales package, or in the product specifications attached to the product.

Attention points of cosmetic efficacy

Cosmetic efficacy claims are the basis for judging the definition and classification of products, and directly determine efficacy categories and the cost of efficacy evaluation. Therefore, the words used in efficacy claims shall be more rigorous.

1. Product efficacy claims shall conform to the cosmetic definition. For example, products that claim efficacy with losing weight are not cosmetics in China. In addition, products that claim the following efficacy as: promoting cell regeneration, DNA repair, helping to lighten dark circles, relieving eye fatigue, improving eye puffiness, anti-allergy and desensitization, etc., which are suspected of containing medical, false, exaggerated, and misleading claims, are also not cosmetics in China.

2. The efficacy claims on the Chinese label shall be consistent with the relevant information on the foreign cosmetic label. For example, foreign cosmetic labels claim the efficacy with anti-acne, while words like "补水控油" (moisturizing and oil control) are marked on the Chinese label. Obviously, it’s a non-compliance case.

3. Product efficacy claims shall not contain prohibited words.

4. The efficacy claims marked on the cosmetic label shall be consistent with the actual situation. For example, the exfoliating efficacy of the product is mainly due to the fact that the cosmetic formula contains 5% glycolic acid. Therefore, the "草本去角质" (exfoliating efficacy with herbal essence) marked on the cosmetic label does not match with the actual situation, which is misleading to consumers and should be revised and modified.

5. The efficacy claims marked on the cosmetic label shall be consistent with the efficacy classification codes filled out and submitted on the registration and notification system, and shall not exceed the efficacy types covered by the efficacy classification codes.

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