Guangzhou Administration for Market Regulation Issued FAQs on General Cosmetic Filing

1. Are products such as bitter nail polish that stop children from sucking their fingers considered general cosmetics?

Bitter nail water is generally made by adding bitter substances such as denatonium benzoate or bitter melon extract into the product. It can make children feel bitter when sucking their fingers, inhibit the stimulation of sucking fingers, and thus help children quit the habit of sucking fingers. The purpose of this product is beyond the definition of cosmetics and does not belong to general cosmetics.

2.Are products that use dihydroxyacetone to adjust skin color and cover up white spots considered general cosmetics?

Dihydroxyacetone (DHA) is an active ingredient used in sunless skin tanning products. The ketone functional group in dihydroxyacetone can react with the amino group of skin keratin to form a brown polymer, which can darken the skin. Products that adjust skin color and cover white spots by forming a brown substance through the contact of dihydroxyacetone with the skin are not general cosmetics.

3.Can silver nitrate be used in hair products?

According to the "Cosmetic Safety Technical Specifications", silver nitrate is limited to "products for dyeing eyelashes and eyebrows", so it is prohibited to use silver nitrate in hair products.

Some hair products on the market add silver nitrate to dye hair black using the photosensitive properties of silver ions. The use of silver nitrate does not meet the requirements of the "Cosmetic Safety Technical Specifications" and also exceeds the scope of the use of hair dyes outside the table of cosmetic hair dyes.

4.What should be noted when using products with atomizers, sprayers and other instruments?

(1) It is necessary to clarify whether the method of use meets the definition of cosmetics, and whether the product is applied to the skin, hair, nails, lips and other human surfaces after the product is atomized by the instrument. If the product acts on the human body through inhalation or other methods after atomization, it does not belong to the method of use of cosmetics.

(2) You need to pay attention to whether "products used with instruments" are checked on the filing management system.

(3) Whether the safety under the conditions of use with instruments or tools is evaluated in the safety assessment; whether the explanation materials are provided on whether the instrument or tool has cosmetic functions during the use of the product, whether it participates in the reproduction process of cosmetics, and whether it changes the mechanism of action between the product and the skin.

(4) Whether the product has the possibility of inhalation exposure. If there is a risk of inhalation exposure, a safety assessment of its inhalation toxicity should be conducted.

5.What should be noted when the cosmetic label claims that the user group is involved？

Products marked with words such as "suitable for all people", "for the whole family", "for teenagers", "suitable for students", etc., or using trademarks, patterns, homophones, letters, Chinese pinyin, numbers, symbols, packaging forms, etc. to imply that the product user group includes children shall be managed as children's cosmetics.

General cosmetics marked with "pregnant and breastfeeding women use with caution" does not exclude the possibility of use by pregnant and breastfeeding women. Such safety warning terms should be expressed more clearly, such as "pregnant and breastfeeding women are prohibited to use".

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