Currently, there are more and more set cosmetics composed of moisturizing cream, serum, face cream, and other products on the market. EnterCo has collected some Q&A related to the precautions for the filing, inspection, sales, and other aspects of the set cosmetics from the Center for Drug and Cosmetic Evaluation of Shanghai MPA.
1. What are the forms of set cosmetics?
Set cosmetics have two forms: 1) a variety of individual packaging combination of cosmetics; 2) cosmetics with multiple formulas that must be used in conjunction with or whose packaging containers cannot be separated.
2. How to apply for the registration or filing of set cosmetics?
1). For set cosmetics in combination of several cosmetics with individual packaging, each single cosmetic shall apply for registration or filing;
2). For cosmetics with multiple formulas that must be used in conjunction with or whose packaging containers cannot be separated, according to Article 35 of the Provisions for the Registration or Filing Dossier of Cosmetics, the cosmetic formula shall be filled in separately, and apply for registration or filing as one product. If one or more contained cosmetics are special cosmetics, it shall apply for registration as special cosmetics; If one or more contained cosmetics are produced outside the country, it shall apply for registration or filing as imported cosmetics.
3. How to label the expiration date of set cosmetics?
According to Article 14 of the Measures for the Administration of Cosmetics Labels, when the sales package contains multiple products with their own individual packages, each individual package shall be marked with the expiration date, and the expiration date on the visible surface of the sales package shall be marked in accordance with the expiration date of individual products that expire earliest.
4. After multiple imported general cosmetics have completed filing separately and are sold in the form of a set box, do I need to submit the label picture of the sales package of a set box?
According to Article 32 of the Provisions for the Registration or Filing Dossier of Cosmetics, when cosmetics that have completed registration or filing are sold within a set box, a gift box, etc., it is not necessary to upload the label picture repeatedly when filing combined packaging products under the following conditions: the combination process does not contact the product contents; the label contents of combined packaging products do not exceed the content of each single product label except for adding the name of combined packaging products; the label contents of combined packaging products cover the label contents of every single product inside.
5. How to test the sample with only one product name, while has different packaging types, and different formulas for each part?
According to the Annex 1 of the Work Specifications for Cosmetics Registration and Record-filing Inspection:
1). Microbiological items, if a sample whose package contains several individual packaging, it should be tested separately; if a sample whose package contains several non-individual packaging, a mixed sampling test should be conducted. If the product is a combination of different categories of make-up cosmetics, it should be tested separately.
2). Physical and chemical items should be tested separately according to each part: If it is not possible to sample separately and does not involve testing items related to the content of formula ingredients, it can be tested according to the instructions; If test items involve the content of formula ingredients, enterprise can provide semi-finished products before packaging for testing, sampling method should be explained in the test report.
3). Toxicology tests and human safety and efficacy evaluation tests can be conducted in accordance with the instructions for testing. When there is the possibility of separate use of each part, it should be tested separately.
Can set cosmetics be sold separately?
1). For set cosmetics in combination of several cosmetics with individual packaging, each single product should apply for registration or filing. Enterprises are free to choose the form of sales, which can be sold as a single product, or be sold in the form of sets.
2). For cosmetics with multiple formulas that must be used in conjunction with or whose packaging containers cannot be separated, they should apply for registration or filing as one product and must be sold together.
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