Following FAQs are all related to ordinary cosmetics filing, CIRS Group has compiled the information and translated them into English for your reference.
Question 1: When filing for ordinary cosmetics, is it necessary to upload information related to the safety of cosmetic ingredients?
Answer: According to the "Opinions on Deepening Cosmetic Regulatory Reform and Promoting High-Quality Development of the Industry" (National Medical Products Administration [2025] No. 18), the responsibility for the quality and safety of cosmetic registrants and filers is emphasized. The safety information of cosmetic ingredients is to be archived by the enterprise for future reference. When submitting filing materials, filers are not required to upload ingredient safety information, including ingredient submission codes and safety-related information (Annex 14). However, for ingredients with quality specifications required by the "Cosmetic Safety Technical Specifications" and "Cosmetic Registration and Filing Data Management Regulations," relevant safety information meeting these quality requirements must be provided.
Question 2: How should inspection be conducted for serums and lyophilized powders that must be used together but are packaged separately?
Answer: According to the "Inspection Work Standards for the Registration and Filing of Cosmetics", serums and lyophilized powders that are independently packaged and can be sampled separately should undergo separate microbiological and physicochemical testing. Toxicological tests, human safety, and efficacy evaluations should be conducted according to the usage methods described in the instructions. If there is a possibility of using each part separately, they should be tested individually.
Question 3: How should inspection reports be submitted for cosmetics containing anti-dandruff agents in their formulation?
Answer: According to the "Inspection Work Standards for the Registration and Filing of Cosmetics", products with formulations containing ingredients used as anti-dandruff agents must be tested for these agents. If the "Cosmetic Safety Technical Specifications" (2015 edition) or supplementary testing methods have been published, testing must be conducted and an inspection report provided. For anti-dandruff agents without existing testing methods, testing is temporarily not required.
Question 4: What are the requirements for uploading flat and three-dimensional images of product sales packaging when filing for ordinary cosmetics?
Answer: Images should include flat views of all visible packaging surfaces and three-dimensional representations that reflect the product's appearance. The images must be complete and clear. The flat view should allow easy identification of all labeled content. If not all content is clearly visible, close-up images or packaging design drawings should be submitted. For cylindrical bottles, soft tubes, or similar shapes where the top or bottom does not contain text and does not affect the determination of product quality, safety, or efficacy claims, uploading images of the top and bottom is not necessary. However, the packaging must indicate that these areas do not contain text; otherwise, images of the top and bottom must be uploaded.
Question 5: Can ordinary cosmetics include syringe or IV drip-related images on their labels?
Answer: According to Article 38 of the "Measures for the Supervision and Administration of Cosmetics Production and Operation", cosmetic registrants, filers, and entrusted production enterprises must take measures to avoid confusion between the product's characteristics or appearance and those of food or drugs, preventing accidental ingestion or misuse. Article 19 of the "Cosmetic Labeling Management Measures" prohibits the use of trademarks, images, font sizes, color differences, homophones, or suggestive text, letters, pinyin, numbers, symbols, etc., to imply medical effects or make false claims. Therefore, cosmetic filers should not use images like syringes or IV drips that suggest medical effects, to avoid confusion with drugs and prevent misuse.
Question 6: What is a cosmetic electronic label?
Answer: A cosmetic electronic label refers to the content of the Chinese label stored through a certain electronic storage mechanism, along with a corresponding QR code generated by an information system. The electronic label is part of the cosmetic label and should be easily readable, allowing consumers to directly scan it using common communication or payment software installed on smartphones to obtain the product's Chinese label information.
Question 7: Can cosmetic companies in Guangzhou that meet the pilot enterprise conditions still apply to become a cosmetic electronic label pilot enterprise?
Answer: According to the principle of "steadily advancing pilot work" by the National Medical Products Administration, cosmetic companies that meet the pilot enterprise conditions and wish to participate in the electronic label pilot in Guangzhou can submit the necessary written application materials and PDF electronic documents to the Guangzhou Market Supervision Administration during the pilot application periods in June and December each year. December 2027 will be the last pilot application period. Applications are not accepted outside the pilot application periods. Companies must submit the "Guangdong Province Cosmetic Electronic Label Pilot Enterprise Application Form" and corresponding proof materials (written and PDF documents) by the last working day of each pilot application period.
Question 8: How should the QR code for the cosmetic electronic label be marked on the sales packaging?
Answer: The QR code for the cosmetic electronic label should be prominently marked on the visible surface of the sales packaging. If a Chinese label is affixed, the QR code should be prominently marked on the Chinese label.
The QR code should be printed clearly, adhered firmly, and easily recognizable, generally not smaller than 9mm×9mm. The position of the QR code should facilitate scanning and consider the effects of displacement, creasing, deformation, or ink fading during storage and transportation. For products with packaging boxes, pilot enterprises are encouraged to also use electronic labels on the packaging container directly in contact with the product contents.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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