Regulatory FAQs: Ordinary Cosmetics Filing in China (Vol.6)

Following FAQs are all related to ordinary cosmetics filing, CIRS Group has compiled the information and translated them into English for your reference.

Frequently Asked Questions on Personalized Cosmetic Services

Question 1: What are personalized cosmetic services? Are there any restrictions on the cosmetics used in such services?

Answer: According to Article 2 of the Requirements for the Pilot Program of Personalized Cosmetic Services, "personalized cosmetic services" refer to services provided by cosmetic registrants or domestic responsible persons authorized by overseas registrants (hereinafter referred to as "pilot enterprises") at their designated retail outlets, such as exclusive stores or directly operated stores (hereinafter referred to as "pilot stores"). These services involve small-scale, on-site, simple blending and repackaging of two or more registered general cosmetics based on individual consumer needs.

The cosmetics used in personalized services must be general cosmetics that have been registered by the pilot enterprise. Such services shall not involve children's cosmetics, eye care cosmetics, or cosmetics formulated with new cosmetic ingredients.

Question 2: What are the requirements for pilot enterprises intending to engage in personalized cosmetic services?

Answer: Pilot enterprises intending to engage in personalized cosmetic services must be cosmetic registrants or domestic responsible persons authorized by overseas registrants, possessing a valid cosmetics manufacturing license, maintaining a sound credit record and a well-established quality management system. In addition, they must not have been subject to any administrative penalties due to cosmetic quality or safety issues within the past three years. Enterprises that have participated in previous pilot programs may continue to carry out personalized cosmetic service pilot activities.

Question 3: What are the labeling and instruction requirements for personalized cosmetic products provided by pilot enterprises?

Answer: Pilot enterprises shall assess the safety of personalized cosmetic products provided to consumers and ensure product quality and safety. The contents indicated on the accompanying labels or instructions for use of personalized cosmetic products must comply with relevant laws, regulations, mandatory national standards, and technical specifications. The labels or instructions must clearly state the name and address of the enterprise and the business premises providing the personalized service, the date of service, and the product's period of use. Pilot stores must also inform consumers of any necessary usage precautions for the simply blended products.

Question 4: What are the management requirements for pilot enterprises regarding their pilot stores?

Answer: Pilot enterprises are responsible for the quality and safety of personalized cosmetic products provided to consumers and must incorporate pilot stores into the quality management system of the cosmetic registrant. They are required to establish and effectively implement a quality management system that is appropriate to the scale of personalized services and the types of cosmetics involved. Pilot enterprises must oversee the facilities, equipment, operational environment, service activities, and personnel of the pilot stores, establish quality management systems and standard operating procedures for the pilot stores, and ensure product traceability through batch numbers or other unique identifiers.

Question 5: What are the requirements for the operational areas and facilities of pilot stores?

Answer: Pilot stores must be equipped with operational areas and facilities appropriate for conducting personalized services, with a rational layout. The operational area must be physically separated from other areas with protective measures to prevent unauthorized access. It should be easy to clean and maintain, and environmental control parameters must meet the operational needs of personalized cosmetic services.

Frequently Asked Questions on Cosmetic Electronic Labeling

Question 1: What is an electronic label for cosmetics? What are the requirements for an electronic label?

Answer: An electronic label for cosmetics refers to the Chinese labeling information of a cosmetic product that is stored through a certain electronic storage mechanism, along with a corresponding QR code generated via an information system.

The electronic label should support convenient scanning and reading functions, allowing consumers to access the Chinese labeling information of the product directly by scanning the QR code using commonly used communication or payment applications installed on smartphones.

The electronic label constitutes an integral part of the cosmetic product label.

Question 2: What are the eligibility requirements for enterprises participating in the electronic label pilot program?

Answer: Enterprises participating in the electronic label pilot program must meet the following conditions:

• Be a cosmetic registrant, filing person, or a domestic responsible person authorized by the registrant or filing person;
• Possess the technical capabilities compatible with the requirements of the electronic label pilot program and be equipped with appropriate management personnel;
• Have a sound quality management system in place;
• Be capable of carrying out the electronic label pilot work.

Question 3: What are the requirements for the QR code and display content of the electronic label?

Answer: Firstly, the QR code of the electronic label must be accompanied by a prominently displayed description below it, stating either “Cosmetic Electronic Label” or “Toothpaste Electronic Label” in Chinese characters.

Secondly, the QR code must be affixed in a prominent position on the visible surface of the sales packaging. If a Chinese label is additionally affixed, the QR code must be placed in a prominent position on the Chinese label.

Thirdly, the QR code must be clearly printed, firmly affixed, and easily identifiable. In principle, its size should not be smaller than 9mm×9mm. The placement of the QR code should facilitate easy scanning and take into full account potential impacts from storage and transportation processes, such as displacement, wrinkling, deformation, or ink fading, which may affect scan readability.

Also, the QR code and display content of the electronic label must comply with the Regulations on the Supervision and Administration of Cosmetics, the Measures for the Administration of Cosmetic Labels, as well as the relevant requirements of the Cosmetic Electronic Label Data Set and the Technical Specifications for QR Codes of Cosmetic Electronic Labels.

Finally, the content of the electronic label must be displayed directly on the landing page after scanning the QR code. No additional conditions for access shall be imposed, and no pop-ups or other interfering elements that hinder normal reading are allowed. Pilot enterprises must fully display the mandatory labeling items specified in Article 7 of the Measures for the Administration of Cosmetic Labels within the electronic label. Any additional content displayed must not exceed what is included in the approved product label sample.

Question 4: For cosmetics labeled with a Chinese label via an electronic label, what information must still be displayed in standard Chinese characters on the visible surface of the product’s sales packaging, in addition to the electronic label QR code?

Answer: The following information must be labeled in standard Chinese characters on the visible surface of the product’s sales packaging:

• The Chinese name of the product and the registration certificate number for special cosmetics;
• The name of the registrant or filing entity;
• The net content;
• The period of use (expiry date or production date plus shelf life);
• Safety warning statements required by laws, regulations, mandatory national standards, and technical specifications;
• For children's cosmetics, the designated logo for children's cosmetics must be displayed.
• For small-sized products with a net content of no more than 15g or 15ml, item (5) above (safety warning statements) may be exempted from being displayed on the physical label.

Question 5: Before cosmetics using electronic labels are marketed and sold, what electronic label information must pilot enterprises upload to the Cosmetics Registration and Notification Information Service Platform? What are the specific requirements?

Answer: Pilot enterprises must upload the following information to the Cosmetics Registration and Notification Information Service Platform:

• The data structure code of the electronic label URL;
• The display content of the electronic label;
• Images of the product’s sales packaging showing the placement of the electronic label.

The data structure code of the electronic label URL must be generated in accordance with the requirements of the Technical Specifications for QR Codes of Cosmetic Electronic Labels. The uploaded URL data structure code must be specific to the product identification unit.

If any changes occur to the electronic label information, the pilot enterprise must upload the updated electronic label information to the platform before the cosmetics with the updated label are marketed and sold.

Question 6: For cosmetics using electronic labels that are no longer being manufactured or imported, how long must the electronic label display content remain accessible?

Answer: For products that are no longer being manufactured or imported, pilot enterprises must ensure that the display content of the electronic label remains accessible for at least one year after the expiration of the use period of the last batch of manufactured or imported products.

For products with a use period of less than one year, the electronic label display content must remain accessible for no less than two years.

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