Product Compliance
filing/registration/consulting/training
Beijing Drug AdministrationOne question, one answer 33rd issue
answer Personnel engaged in cosmetic safety assessment shall meet the requirements of Guidelines for Identification and Assessment of Hazardous Substances in Cosmetics The requirements stipulated in the regulations.
Should be based on the source of raw materials Physical and chemical properties The preparation process affects the input of raw materials,Analysis of the situation where hazardous substances are generated or introduced during the production process of the product,Combining existing toxicology test data clinical research Population epidemiological investigation and other data,Identify potential risk substances in cosmetics,according to Guidelines for Identification and Assessment of Hazardous Substances in Cosmetics The evaluation principles, procedures, and other related requirements in the safety assessment of risk substances.
answer according to Technical specifications for cosmetic safety regulations Identify and evaluate potential risk substances in cosmetics using methods such as referencing risk assessment conclusions from authoritative domestic and foreign institutions,Including but not limited to the following situations
one When the following harmful substances may be present in the product,Special cosmetics should provide inspection reports issued by cosmetic registration and filing inspection agencies Ordinary cosmetics can provide inspection reports issued by cosmetic registration and filing inspection agencies,Or the registrant may follow Announcement on Optimizing the Management Measures for Filing and Inspection of Ordinary Cosmetics 2023year The13number Required inspection report.
1.mercury lead arsenic cadmium All registered or filed products must provide mercury lead arsenic Cadmium inspection report,The mercury limit in the product is1mg/kg The lead limit is10 mg/kg The arsenic limit is2 mg/kg The cadmium limit is5 mg/kg.
2.Dioxane Ingredients containing ethoxy structures in the formula, such as ethoxydiglycol polyethylene glycol PEG Class and its derivatives Fatty alcohol polyethers and their derivatives Polysorbate esters and their derivatives When using raw materials such as poloxamer, it is necessary to detect the presence of dioxane in the product,The limit value of dioxane in the product is30 mg/kg.
3.asbestos When the formula contains talc powder raw materials, asbestos in the product needs to be detected,Evaluate based on the test results,Under the existing detection methods,Asbestos must not be detected in the product.
4.free formaldehyde Ingredients containing formaldehyde slow-release agents such as imidazolidinylurea in the formula DMDMHydantoin double methylol Imidazolidinylurea sodium hydroxymethylglycinate 2-bromine-2-Nitropropane-1,3glycol 5-bromine-5-Nitro group-1,3-Dioxane Formaldehyde benzyl alcohol hemiacetal 7-Ethylbis (oxazolidine) When using raw materials such as dimethyl oxazolidine, it is necessary to detect free formaldehyde,Evaluate based on the test results.
5.methanol When ethanol is included in the formula Sum of isopropanol content≥10% w/w ,A test report for methanol in the product issued by a cosmetic registration and filing inspection agency should be provided,The methanol limit in the product is2000mg/kg.
two Technical specifications for cosmetic safety Raw materials with restricted requirements for hazardous substances present in the raw materials,Risk substances can be assessed through raw material quality specifications or raw material safety information documents It can also be evaluated by combining the inspection report of the risk substance content in the raw materials with corresponding quality management measures,To ensure that the relevant control indicators of the raw materials comply with Technical specifications for cosmetic safety requirement,Including but not limited to the following situations
1.Nitrosamine The formula contains hair dye such as2,6-Dihydroxyethylaminotoluene 2-amino-4-Hydroxyethylaminoanisole 2-methyl-5-Hydroxyethylaminophenol HCyellow2number N,N-double 2-Hydroxyethyl When dealing with raw materials such as phenylenediamine sulfate,Need to identify and evaluate the risk substance nitrosamines,This raw material is not used with nitrosylation system Maximum content of nitrosamines in raw materials 50g/kg Store in a container free of nitrite.
2.Secondary alkylamine Nitrosamine The formula contains trialkylamine Trialkanolamines and their salts such as triethanolamine,Or containing single chain alkylamine Single chain alkylamines and their salts such as tromethamine Aminomethylpropanol Pyrrolidone ethanolamine salt When using raw materials such as ethanolamine,Need to identify and evaluate the risk substance secondary alkylamine Nitrosamine,This raw material does not belong to the nitrosylation system (Nitrosating system) Use together Avoid the formation of nitrosamines The minimum purity is99% Maximum content of secondary alkylamine in raw materials 0.5% Maximum content of nitrosamines in the product 50g/kg Store in a container free of nitrite.
The formula contains fatty acid double chain alkyl amides and fatty acid double chain alkyl alcohol amides such as cocoamide DEA Palm kernel oil amideDEA Whale wax base-PG-When using raw materials such as hydroxyethyl palmitamide,Need to identify and evaluate the risk substance secondary alkylamine Nitrosamine,This raw material does not belong to the nitrosylation system (Nitrosating system) Use together Avoid the formation of nitrosamines Maximum content of secondary alkylamine in the product0.5%,Maximum content of nitrosamines50g/kg Maximum content of secondary alkylamine in raw materials5% Store in a container free of nitrite.
three Technical specifications for cosmetic safety Raw materials with restricted requirements for hazardous substances present in the product,Risk substances can be assessed through raw material quality specifications or raw material safety information documents It can also be evaluated through inspection reports on the content of risk substances in raw materials or products, in conjunction with corresponding quality management measures,To ensure that the product complies with Technical specifications for cosmetic safety requirement,Including but not limited to the following situations
Acrylamide The formula contains polymers synthesized from acrylamide as the starting material, such as acrylamide/Sodium acrylate copolymer polyacrylamide Polyacrylic acid ester-13 Polyquaternary ammonium salt-7When waiting for raw materials,Need to identify and evaluate the risk substance acrylamide,Maximum residual amount of acrylamide monomer in resident type products0.1mg/kg,Maximum residual amount of acrylamide monomer in other products0.5mg/kg.
four Hazard identification,When there may be the following risk substances in the product, an inspection report on the content of risk substances in the raw materials or products can be provided,Or include raw material quality specifications or raw material safety information documents that include control requirements for the risk substance,And based on this, conduct a risk assessment on it,To ensure its safe use.
1.Diethylene glycol The formula contains the following ingredients such as glycerol Propylene glycol glycol,Ethoxydiglycol polyethylene glycol PEG Class and its derivatives Polysorbate esters and their derivatives Fatty alcohol polyether and its derivatives, etc,Need to identify and evaluate diethylene glycol,The limit value can refer to the evaluation conclusion of authoritative institutions.
2.phenol Regarding the raw materials that may introduce phenol,When phenoxyethanol is prepared by the addition reaction of phenol and ethylene oxide,Need to identify and evaluate the risk substance phenol,The limit value can refer to the evaluation conclusion of authoritative institutions.
3.methanol The formula contains ethanol Denatured ethanol When using raw materials such as isopropanol ethanol Sum of isopropanol content<10% w/w ,Need to identify and evaluate the risk substance methanol.
4.pesticide residue Understanding the preparation process of plant-based raw materials is essential,Plant raw materials such as vegetable oil that are directly used after mechanical processing only Plant leaf juice, etc,Need to identify and evaluate pesticide residues,The limit value can refer to relevant requirements in China and internationally.
5.hydroquinone For raw materials that may introduce hydroquinone, such asα-Arbutin β-Arbutin, etc,Need to identify and evaluate the risk substance hydroquinone,The limit value can refer to the evaluation conclusion of authoritative institutions.
6.benzene For raw materials that may introduce benzene, such as carbomer, etc,Need to identify and evaluate the risk substance benzene,The residual amount in the product should be≤2 mg/kg.
five Proof or safety information from the raw material manufacturer is required,Confirm that it does not belong to Technical specifications for cosmetic safety Prohibit raw materials from the raw material catalog,Including but not limited to the following situations
1.When the formula contains mineral grease,It is necessary to confirm the entire refining process and be able to prove that the obtained substance is not a carcinogen.
2.Containing propellant propane butane Isobutane,Need to confirm the butadiene content≤0.1%(w/w).
3.Originating from petroleum Mixed alkanes of coal tar, such asC15-19Alkane C18-21Alkane,Need to provide itCASnumber,And according to Technical specifications for cosmetic safety Provide relevant quality specifications or proof materials in accordance with relevant requirements.asCASbe entitled as64741-76-0of,Need to confirm the content of dimethyl sulfoxide extract≤3% CASbe entitled as64742-46-7of,It is necessary to confirm the entire refining process and be able to prove that the obtained substance is not a carcinogen.
six Assessment of Risk Substances to Consider in Children's Cosmetics
Based on the physiological characteristics of children,Children's cosmetics should complete the above tasks one to four In addition to the identification and assessment of prescribed risk substances,Further identification and assessment of the following risk substances are required
1.When the formula contains ingredients such as Curacao aloe vera,Need to identify and evaluate the risk substance anthraquinone,Its evaluation can refer to the evaluation conclusions of authoritative institutions.
2.When the formula contains cocoamidopropyl betaine,It is necessary to identify and evaluate the presence of cocoamidopropyl dimethylamine 3,3-Dimethylaminopropylamine and monochloroacetic acid,The limit value can refer to the evaluation conclusions of authoritative institutions or relevant standards in China.
3.The formula contains essence When it comes to plant essential oils or spice ingredients,It is necessary to identify and evaluate the allergenic components involved,If it contains alternating leaves and white millets MELALEUCA ALTERNIFOLIA Leaf oil time,Need to identify and evaluate the risk substance methyl eugenol,The limit value can refer to the evaluation conclusion of authoritative institutions.
4. When glycerol is included in the formula,Its purity should be≥ 95.0%,Identification and evaluation of diethylene glycol content should≤0.1%.
answer Guidelines for Identification and Assessment of Hazardous Substances in Cosmetics Only corresponding assessment requirements have been proposed for common risk substances in cosmetics based on the current level of technology and knowledge.Encourage enterprises to source raw materials based on their origin form Production process Comprehensive identification of risk substances in products in terms of packaging materials and other aspects,If not found Guidelines for Identification and Assessment of Hazardous Substances in Cosmetics The risk substances listed in,according to Technical Guidelines for Safety Assessment of Cosmetics Request for evaluation,Only materials with safe evaluation conclusions can be used.
Quick Tips Guidelines for Identification and Assessment of Hazardous Substances in Cosmetics It was formulated under the current regulations and standards, as well as the current level of scientific understanding,With the updating and improvement of regulations and standards,And the development of science and technology,Adjustments will be made in a timely manner.
Beijing Drug Administration: A Question and Answer 34th issue
Quality Management Standards for Cosmetics Production Article 10: Provisions,Enterprises should develop and implement employee onboarding training and annual training plans,Ensure that employees are familiar with their job responsibilities,Having legal knowledge to fulfill job responsibilities Professional knowledge and operational skills,Only those who pass the assessment can take up their posts.
Implementing the Regulations on Supervision and Management of the Main Responsibility for Cosmetics Quality and Safety in Enterprises Article 22: Provisions,Enterprises should provide necessary conditions for the learning and training of quality and safety managers,Ensure that the quality and safety manager continuously updates their professional and legal knowledge in quality and safety management,Improve the ability to perform duties.The person in charge of quality and safety shall receive no less than annual relevant learning and training40Class hours.
Quality Management Standards for Cosmetics Production Article 10: Provisions,Enterprises should establish employee training records,Training records generally consist of two parts: training situation records and training certification materials.Including training personnel time content Methods and assessment results, etc.
basis Regulations on the Supervision and Administration of Cosmetics regulations,The scope of diseases that may affect the quality and safety of cosmetics shall be determined by the health regulatory department of the State Council,Before the relevant regulations are issued by the health regulatory department of the State Council,Currently implementing the original regulations Regulations on the Supervision of Cosmetics Hygiene The scope of diseases that may affect the quality and safety of cosmetics as stipulated,include:dysentery Typhoid fever Viral hepatitis Active pulmonary tuberculosis Hand skin disease(Hand ringworm Nail ringworm Hand eczema Psoriasis or scales occurring in the hands)Diseases such as exudative skin diseases.Individuals suffering from these diseases,Cannot directly engage in cosmetics production activities.
The content of personnel health records includes employee names Health check-up dates and results health certificate Medical examination report and other related content.And Quality Management Standards for Cosmetics Production Article 11: Provisions,Enterprises should establish health records for their employees,At least save3year.
Quality Management Standards for Cosmetics Production Article 11: Provisions,Enterprises should establish and implement a management system for external personnel,Including the approval registration system for external personnel entering production or storage areas.Before entering these areas,External personnel must be cleaned by enterprise personnel disinfect Changing clothes Guidance on safety and other aspects,After entering, relevant personnel of the enterprise should also accompany and supervise their behavior,Avoid behaviors that may affect product quality and safety.
Q&A on the Filing of Ordinary Cosmetics by Guangzhou Municipal Supervision Bureau Sixty fifth issue
When choosing packaging materials for cosmetics,Cosmetic registrant The registrant can determine the composition of the cosmetics based on their ingredients Assess the compatibility between cosmetics and packaging materials based on actual risk levels and other factors,Including but not limited to selecting appropriate simulated solutions for the study of leachate from packaging materials,Historical safety data or reports of cosmetic products,According to the food Compatibility research report on packaging materials of cosmetics using drugs or self built methods,Based on data, statements, or quality control reports provided by suppliers,Comprehensive evaluation of cosmetic stability test results and cosmetic safety report, etc.Cosmetic registrant The registrant may use one or more of these methods,Evaluate the compatibility between cosmetics and packaging materials.
If the cosmetics registrant The registrant is unable to provide the above-mentioned safety assessment materials or discovers that cosmetics interact with their packaging materials and affect the quality of cosmetics When safety is affected,Should refer to Compatibility Technical Guidelines Conduct relevant research.
Approximate formula system for cosmetics When the packaging material of the container or carrier in direct contact with the content is the same and the source is consistent,Cosmetic registrant The registrant may conduct compatibility evaluation based on existing information and experimental data,But the reasons need to be explained,describe the circumstances.
Cosmetic registrant The registrant may submit a registration and filing application after the acceleration test is completed,Long term test report enterprise archive.
The purpose of evaluating the stability of cosmetics is to examine them at a certain temperature The law of time variation under humidity and other conditions,Influence factor test Accelerated testing The long-term testing time is determined by the cosmetics registrant The registrant shall record based on the characteristics of cosmetics Determination of packaging materials and other factors.Multiple experimental time points need to be set up to study the quality changes of cosmetics,The setting of time points should be based on the characteristics of product form and stability trend evaluation requirements.
Approximate formula system Cosmetics with the same packaging material,Stability evaluation can be carried out based on existing data and experimental data,But the reasons need to be explained,describe the circumstances.