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Guangzhou AMR Issued Some FAQs Related to Soaps

Guangzhou Faqs

1. What is the production process of soap?

Currently, the soap on the market is mainly made from fatty acid sodium generated by saponification (fatty acid and alkali neutralization) of animal and plant fats, with or without other surfactants, functional additives, etc., and produced through grinding, cooling and molding processes.

Fatty acid sodium salts that can be used to manufacture soaps include sodium laurate, sodium stearate, sodium myristate, sodium oleate, etc.

2. Does soap meet the definition of cosmetics? Does soap implement registration and filing management refer to cosmetics?

From the perspective of the use method (wiping), application site (human body surface), and main purpose (cleaning) of soap, soap meets the definition of cosmetics.

According to Article 77 (2) of the Cosmetics Supervision and Administration Regulations, soap is not subject to the Regulations, but soaps that claim to have special cosmetic efficacy is subject to the Regulations. Soaps that only have cleaning and other ordinary functions are managed according to general daily chemical products; Soaps that claim to have special efficacy such as "whitening and sun protection" shall be registered and managed as special cosmetics.

3. Do "liquid soap" and "soap liquid" are cosmetics?

Currently, the "liquid soap" and "soap liquid" products used for the human body on the market, although the name contains "soap", do not meet the definition of soap in QB/T 2485-2008, and are actually similar to products such as shower gel and hand sanitizer. Therefore, based on the product's process formula, usage method, purpose of use, and site of use, they may still belong to cosmetics.

4. Do you need to obtain a production license to produce soap?

Soaps that claim to have special cosmetic efficacy are applicable to the Cosmetics Supervision and Administration Regulations and are included in the production license management of cosmetics.

5. How to conduct filing for cosmetics that must be used in conjunction with the instrument?

Except for brushes, air cushions, perm tools that only assist in applying and wiping, cosmetics that must be used in conjunction with instruments or tools should be evaluated for their safety under the conditions of use during the product safety assessment process.

In principle, instruments or tools used together should not have cosmetic functions, should not participate in the reproduction process of cosmetics, and should not change the way and mechanism of action between cosmetics and the skin.

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