What is a cosmetic label?
According to Article 3 of the Cosmetics Supervision and Administration Regulations, 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. In other words, the label includes both the "software" information and the "hardware" information carrier.
What is the minimum sales unit? What are the labeling requirements for the minimum sales unit under the Measures for the Administration of Cosmetics Labels?
The definition of 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.
According to Article 5 of the Measures for the Administration of Cosmetics Labels, minimum sales units of cosmetics shall have labels. Cosmetic labels shall comply with relevant laws, administrative regulations, departmental regulations, mandatory national standards, and technical specifications. Label content shall be legal, true, complete, accurate, and consistent with the relevant content of the product registration or filing.
Cosmetic labels shall be clear, durable, easy to identify and read. Any phenomenon such as falling off printing characters, loose pasting, etc. shall not appear on the cosmetic labels.
What are special provisions for different packaging labeling under the Measures for the Administration of Cosmetics Labels?
(1) Products with packaging boxes
According to Article 7 of the Measures for the Administration of Cosmetics Labels, for products with packaging boxes, the Chinese name and shelf life of the product shall also be labeled in the packaging container that directly contacts with the contents.
According to Article 14 of the Measures for the Administration of Cosmetics Labels, for the labeling of packaging container that directly contacts with the contents, in addition to the form of the production date and shelf life or production batch number and expiration date, you can also use the production batch number and shelf life after opening.
(2) Small packaging products
According to Article 17 of the Measures for the Administration of Cosmetics Labels, for small packaging products with cosmetic net content not more than 15g or 15mL, only the Chinese name of the product, registration certificate number of the special cosmetics, name of the registration or notification person, net content, shelf life, etc. shall be marked on the visible surface of the sales package, other information that shall be marked can be marked in the product specification attached to the product.
Which contents of Children's cosmetics labels shall be specially marked?
According to Article 6 of the Provisions for the Supervision and Administration of Children's Cosmetics, children's cosmetics shall mark the exclusive logo (Small Gold Shield) stipulated by China National Medical Products Administration NMPA on the display surface of the sales package; Children's cosmetics shall use "attention" or "warning" as guide words, and mark warning words such as "should be used under adult supervision" on the visible surface of the sales package. In addition, cosmetics registrants and filers are encouraged to use anti-counterfeiting technology on labels to facilitate consumer identification and selection of legitimate products.
What are the common problems in the product labeling module in the filing system?
1. net content
For products with multiple specifications, the "net content" column should be filled in all the specifications, not just fill in a specification.
2. Other special claims are not checked accordingly
(1) specific claims (claiming to be suitable for sensitive skin)
Product labels claim that "suitable for all skin types", "suitable for sensitive skin" or similar expressions, the claim should be checked.
(2) claims of quantitative indicators (time, statistics, etc.)
Product labeling efficacy claims retention time, relevant statistics, specific pH values, etc., the claim should be checked.
3. The label pictures uploaded in the attached information do not meet the requirements
Label pictures shall include all the packaging visible surface plans and a three-dimensional display chart that can reflect the appearance of the product. In addition, the picture shall be complete and clear. Plan should be easy to identify all the labeling content, and the local enlargement or product packaging design drawings should be submitted in case all the labeling content cannot clearly show. The complete plan includes pictures of the top and bottom of the product packaging. For uploaded plans and three-dimensional display charts, color, size, and other information should not be marked.
4. Sales packaging plan
(1) The address of the filer, the address of the manufacturer, the product implementation standard number, and other information on product labels are inconsistent with the corresponding information in the application form for filing.
(2) Chinese labels of imported products fail to reflect the content related to product safety, and efficacy claims in the original packaging label.
(3) Chinese labels marked vulgarity, feudal superstition, or other content that violates social order and morality.
(4) Products that use words such as "适用于所有人群 (applicable to all people)", "全家使用(available for all family members)" or use trademarks, patterns, homophonic expressions, letters, Chinese Pinyin, numbers, symbols, packaging forms, etc. to imply that the use group includes children, but not in accordance with children's cosmetics for the filing.
(5) The packaging of domestic products uses non-Chinese characters or symbols without corresponding explanation in Chinese characters on the visible surface of the product sales packaging.
(6) The use of innovative terms that have not yet been widely used in the cosmetic industry, has not been explained in an adjacent location. Innovative terms that are difficult for consumers to understand are not prohibited content on cosmetics labels.
(7) The label content and instructions for uploading pictures beyond the content of the sample product label.
Note: For cosmetics that have completed filing before May 1, 2022, cosmetics filers shall complete product label updates to make it consistent with provisions and requirements of the Measures for the Administration of Cosmetics Labels before May 1, 2023.
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