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Official Filing Q&A - Preliminary Case Number Clearing and Risk Statement for Microcrystalline/Micro Needle Products

The Guangzhou Municipal Administration for Market Regulation recently released the 51st issue of Q&A on the filing of ordinary cosmetics, with detailed content as follows:

Question 01: Is there a time limit for the use of preliminary case numbers?

Answer: According to the regular cosmetics filing management system, the preparation number that has been received or temporarily stored between January 1st and December 31st each year should be submitted for filing before December 31st of that year, otherwise it will be cleared and invalidated. Please arrange the submission time of filing materials reasonably for each enterprise and pay attention to the relevant notices in the system.

Question 02: Can children's cosmetics labels label food related patterns?

Answer: According to Article 13 of the Regulations on the Supervision and Administration of Children's Cosmetics, cosmetics registrants, filers, and entrusted production enterprises should take measures to avoid confusion between the appearance, odor, and appearance of children's cosmetics with food, drugs, and other products, and to prevent accidental ingestion and misuse. Children's cosmetics labels shall not indicate words such as "food grade" or "edible" or food related patterns.

Question 03: Are microcrystalline or microneedle products cosmetics?

Answer: It is claimed that microcrystalline or microneedle products, such as those using small needle like raw materials such as hydrolyzed sponges or corresponding production processes, are effective by penetrating the skin or penetrating the product, and are not applied to the skin surface. Such products go beyond the definition of cosmetics.

Question 04: What should be paid special attention to in the quality control of seaweed facial mask?

Answer: According to the results of cosmetics spot check reported by relevant departments this year, many batches of seaweed facial mask have exceeded the standard of microorganisms. The production process and storage conditions of seaweed facial mask should strictly control the microbial indicators. In addition, according to the Announcement of the National Medical Products Administration on Updating the Catalogue of Prohibited Raw Materials for Cosmetics (No. 74 of 2021), Tianxianzi (Hyoscyama scoparia) is a prohibited plant (animal) raw material for cosmetics, and it is strictly prohibited to mix "Tianxianzi" with "seaweed" for cosmetic production or registration.

Question 05: How to describe the suitable skin type in the usage method?

Answer: It is not recommended to use vague expressions such as "suitable for multiple skin types", "suitable for multiple types of skin", and "suitable for all skin types" in the instructions. It is necessary to clarify the specific skin type applicable, such as whether it is suitable for dry, oily, or mixed skin. If it is suitable for sensitive skin, corresponding efficacy claims and evaluations need to be conducted, and a summary of the efficacy evaluation criteria should be uploaded.