In August, Shanghai Institute of Technology released the "Frequently Asked Questions on Cosmetic Labeling (II)", which includes the following content:
According to the Announcement on the Implementation of the Measures for the Administration of Cosmetic Labeling issued by the National Drug Administration (No. 77 of 2021), starting from May 1, 2022, cosmetics applying for registration or filing must comply with the provisions and requirements of the Measures for the Administration of Cosmetic Labeling; If cosmetics that have previously applied for registration or registration have not been labeled in accordance with the provisions of the "Cosmetics Label Management Measures", the cosmetics registrant and registrant must complete the update of the product label before May 1, 2023, to make it comply with the provisions and requirements of the "Cosmetics Label Management Measures".
In the "Frequently Asked Questions on Cosmetic Product Labeling (1)" released on April 28th, Shanghai Institute of Technology and Technology interpreted common issues such as multi-layer adhesive labels and sales packaging of packaged products. At present, the transition period for cosmetic labeling has ended. Shanghai Institute of Technology and Technology will provide an explanation and clarification for the completeness and consistency of product labeling information found in the recent filing materials of registrants and domestic responsible persons.
1、What are the basic requirements for filling in product labels when cosmetic registrants are conducting product registration?
Firstly, attention should be paid to the completeness of the information provided. According to regulatory requirements, all contents should be filled out completely to avoid regulatory authorities being unable to determine the compliance, safety, etc. of the product due to incomplete filling.
Secondly, attention should be paid to the consistency of information provided. The usage methods, safety warning terms, storage conditions, and usage period involved in the label sample should comply with the standards implemented by the product; The information of the registrant and domestic responsible person should be consistent with the corresponding information in the application form.
2. What are the common issues with the registration materials of cosmetic registrants and domestic responsible persons?
The filing materials of the registrant and domestic responsible person are prone to frequent and frequent issues, mainly including the following situations:
1) Other copy content or sales packaging claims the efficacy and time of the raw materials, without checking the corresponding items in the "Other Special Claims" section. For example, the enterprise claims that "concealer ingredients (CI 77891 * triisostearic acid isopropoxide titanium salt, etc.) that are applied to skin like magnets can help concealer effectively", and does not check "specific claims (raw material efficacy)".
2) The content of the product sales packaging exceeds the content specified in the label sample. If the company identifies storage conditions in the sales packaging, but the label sample is not filled in.
3) The product sales packaging claims to be inconsistent with the original packaging of the product. This situation is common in the filing of imported ordinary cosmetics with Chinese labels. According to the requirements of the "Measures for the Administration of Cosmetics Labels", "For those with Chinese labels, the content related to product safety and efficacy claims on the Chinese label should be consistent with the relevant content of the original label." Enterprises should pay attention to maintaining consistency when conducting filing.
4) The claimed raw material content in the original packaging of the product is inconsistent with the declared formula, and no supporting materials are found. For example, the enterprise claims on the original packaging that the alcohol content is 80% (volume ratio), and the declared formula is the mass ratio. The two are inconsistent, and the enterprise has not provided conversion proof materials.
