Guangzhou MPA Released a Q&A to Guide How to Use Ingredient Usage Information of Marketed Products

1. What content has been updated in the "Ingredient Usage Information of Marketed Products" released in February 2025?

The "Ingredient Usage Information of Marketed Products" released in February 2025, based on the 2234 raw materials and 4415 usage information released on April 30, 2024, sorted out and analyzed the raw material information in the effective cosmetics registered and filed in China, and updated it to 3608 raw materials and 7672 usage information, and added the action parts such as body hair and nails, and also optimized the reference use principles.

2. How to understand the "Ingredient Usage Information of Marketed Products"?

According to the "Cosmetic Supervision and Management Regulations", "Cosmetic Safety Assessment Technical Guidelines (2021 Edition)" and other laws, regulations and technical documents, cosmetics registrants and recorders are responsible for the quality and safety of cosmetics, and should conduct safety assessments by themselves or entrust professional institutions to form safety assessment reports, and be responsible for their authenticity and scientificity. This "Ingredient Usage Information of Marketed Products" is an objective collection of information on the use of raw materials used in registered and valid cosmetics in my country. It does not organize a systematic evaluation of the safety of the listed raw materials. When using relevant raw material information, cosmetics registrants and recorders shall comply with relevant national laws and regulations, mandatory national standards and technical specifications, conduct cosmetics safety assessments and assume quality and safety responsibilities.

3. What are the reference usage principles of "Ingredient Usage Information of Marketed Products"?

The reference usage principles of "Ingredient Usage Information of Marketed Products" are as follows:

1. For the same raw material with the same action site, if only the raw material usage of the leave-in product is used, the rinse-in product can refer to the use of the leave-in product.

2. For the same raw material with the same usage method, the order of whole body, trunk, face (including neck), hands and feet, head, hair, lips, eyes, and nails can be used. The latter action sites can refer to the raw material usage of the former action sites. However, when the product action site is the eye and the usage of other parts is referenced, the eye irritation needs to be evaluated separately. Among them, the lips and eyes cannot refer to the raw material usage of hands, feet, head, and hair; body hair can only refer to the raw material usage of the whole body or trunk; if the action sites are both the head and hair, the raw material usage of the head can be referred to; if the action sites are the face (including the neck), eyes and/or lips at the same time, the raw material usage of the face (including the neck) can be referred to. When the action site includes the eyes, the eye irritation needs to be evaluated separately; for the raw material usage of other products used in multiple action sites at the same time, the usage of the upper-level action site using the same usage method shall be selected.

4. How to correctly apply the Ingredient Usage Information of Marketed Products?

The registrants and recorders of cosmetics should use the raw material usage correctly in combination with the product usage method and the site of action. In order to facilitate the industry to better apply the "Ingredient Usage Information of Marketed Products", the following representative examples are given:

(1) How should the "Ingredient Usage Information of Marketed Products" be used for rinse-off products with the sites of action being "face (including neck)" and "hands and feet"?

The raw material usage of rinse-off products for "trunk" or "whole body" in the "Ingredient Usage Information of Marketed Products" can be used. If not available, the raw material usage of leave-on products for "trunk" or "whole body" can be selected.

(2) How should the "Ingredient Usage Information of Marketed Products" be used for rinse-off products with the sites of action being "head" and "hair"?

The amount of raw materials used for rinse-off products for "head" in the "Information on the Use of Raw Materials of Marketed Products" can be used; if there is no such amount, the amount of raw materials used for leave-on products for "head" can be selected; if there is no such amount, the amount of raw materials used for leave-on or rinse-off products for "hands and feet" or "face (including neck)" or "trunk" or "whole body" can be selected.

(3) How to use the "Information on the Use of Raw Materials of Marketed Products" for leave-on products with the action sites of "face (including neck)", "eyes" and "lips" at the same time?

The amount of raw materials used for leave-on products for "face (including neck)" in the "Information on the Use of Raw Materials of Marketed Products" can be used; if there is no such amount, the amount of raw materials used for leave-on products for "trunk" or "whole body" can be selected. It should be noted that if the "Information on the Use of Raw Materials of Marketed Products" does not contain the amount of raw materials used for leave-on products for eyes, eye irritation needs to be evaluated separately.

5. If the usage exceeds the amount in the "Information on the Use of Raw Materials of Marketed Products", how should the safety assessment of raw materials be carried out?

When the cosmetics registrants and recorders produce products, if the usage of raw materials exceeds the amount in the "Information on the Use of Raw Materials of Marketed Products", they should carry out safety assessments in accordance with the "Cosmetics Safety Assessment Technical Guidelines (2021 Edition)" or use other raw material data types in accordance with the "Cosmetic Raw Material Data Usage Guidelines".

If you have any questions related to cosmetic safety assessment, please contact us via info@enter-co.com.

Also, you can follow us on LinkedIn for the latest cosmetic and toothpaste compliance information.