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General Labeling for Cosmetics and Technical Safety Requirements for Toothpaste: Two National Standards Open for Comments!

Mar 31, 2026
China
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On March 30, 2026, China's National Medical Products Administration (NMPA) publicly solicited opinions on two mandatory national standards, including “Instructions for use of consumer interest- Part 3: General labelling for cosmetics” and “General requirements of safety and technical for toothpastes”.

Interpretation of Instructions for use of consumer interest- Part 3: General labelling for cosmetics

Application Scope

This part of GB 5296 specifies the form, basic principles, labeling content, and labeling requirements for the general labels of cosmetic sales packaging. This standard applies to cosmetics sold within the territory of the People's Republic of China, including cosmetics provided to consumers in forms such as free trials, gifts, and exchanges. The products involved include special cosmetics and general cosmetics.

Compilation Principles

The current mandatory national standard "Instructions for Use of Consumer Products - General Labeling for Cosmetics" was promulgated in 2008 and has not been revised since. To date, the highest-level regulations for cosmetics supervision have been revised, and the cosmetics regulatory system has undergone profound changes, leading to significant adjustments in the actual regulatory requirements for cosmetic labels. Therefore, this standard revision is based on the newly promulgated "Regulations" and related labeling regulations, combined with the actual needs of the industry and years of practical experience, to revise the content of the current mandatory national standard.

Basis for Major Technical Requirements

This revision has made necessary adjustments to the overall content of the standard, detailing the contents and requirements of various label markings. The structure of the standard separately lists the special requirements for labeling imported cosmetics, small-sized cosmetics, and children's cosmetics, and adds relevant requirements for the use of electronic labels.

The main revision contents are introduced based on the sequence of standard documents:

  • Standard Name Norms and Addition of Foreword Content

According to GB/T 1.1—2020 "Directives for Standardization - Part 1: Structure and Drafting of Standardization Documents," the standard name and foreword content have been standardized to meet the relevant requirements of series standards.

  • Adjustment of the Scope of the Standard

Cosmetics provided to consumers in forms such as free trials, gifts, and exchanges are no longer considered special cases.

  • Adjustment of Terms and Definitions

Several necessary terms and definitions have been modified and added for better understanding and delineation. For example, terms such as "small-sized cosmetics," "children's cosmetics," "Chinese label for imported cosmetics," "electronic label," "period after opening," "guiding words," and "manufacturing enterprise" have been added. The term "contents" has replaced "inner contents," and the terms and definitions for "net content" and "shelf life" have been modified. Necessary annotations for "sales packaging" and "visible surface" have also been added.

  • Addition of Label Forms

Based on the needs of industry development and regulatory science, the form of electronic labels has been added.

  • Standardization of Basic Principles

The provisions related to "basic principles" and "basic requirements" in the current standard have been integrated and improved, mainly detailing the requirements for the use of text on labels and other content that should not be marked on labels.

  • Optimization and Adjustment of Labeling Content and Requirements

For example, the labeling items and specific requirements for "name and address of the cosmetic registrant, filer, and manufacturing enterprise" and "product use period" have been adjusted. Specific requirements for labeling "Chinese name of cosmetics" and "ingredients list of cosmetics" have been detailed. The current standard requirements for "net content," "product standard number," "special cosmetics registration certificate number," "safety warning language," "usage guide or applicable guide illustration," and "storage requirements" have been retained with necessary textual modifications.

  • Addition of Electronic Label Content

Based on the future development needs of the industry, relevant content for electronic labels has been added, specifying the form, content requirements of electronic labels, and the minimum content that must be marked on the physical label of products using electronic labels.

  • Addition of Appendix A: Period After Opening Icon

The "Period After Opening Icon" involved in the standard content has been normatively required in the form of Appendix A.

Comparative Analysis with International Standards, Laws, and Regulations of Other Countries or Regions

Comparative Analysis with International Standards

Regarding cosmetic labeling, the International Organization for Standardization (ISO) has issued ISO 22715:2006 "Cosmetics — Packaging and Labeling." Upon comparison, the draft revision of the standard includes corresponding requirements for general labeling content such as the name of the responsible person for product market sales, address of the responsible person for product market sales, ingredient list, storage conditions, content, traceability information, precautions and warnings, and usage instructions that are stipulated in the international standard. For the general labeling content requirement of product functionality, it can be queried through the cosmetic registration and filing information system as specified in the draft revision of the standard.

The requirements for labeling position and special packaging forms specified in the international standard are also addressed in the draft revision of the standard, with corresponding provisions made based on China's cosmetic labeling management requirements and years of practical experience. Furthermore, the international standard explicitly states that "the regulations of certain countries may be stricter in certain aspects than this international standard," thus the draft revision of the standard does not violate the overall requirements of the international standard.

Comparative Analysis with Regulations of Other Countries and Regions

The drafting group compared the relevant labeling requirements of the United States, the European Union, Japan, South Korea, ASEAN, Australia, New Zealand, Brazil, and other countries and regions. Through comparison, the requirements for labeling items such as product name, responsible person information, net content, shelf life, and ingredient list are similar. Other labeling content and requirements are closely related to the cosmetic regulatory systems, product classifications, and consumer usage habits of each country and region, resulting in significant differences. Therefore, the draft revision of the standard primarily considers China's labeling requirements, cosmetic regulatory needs, and consumer usage habits.

Recommendation and Reasons for External Notification

External notification is recommended. Cosmetics are internationally circulated products, and each country has different labeling requirements. Moreover, the "Regulations" stipulate that imported cosmetics can have Chinese labels affixed to the original packaging, but the safety and efficacy content must remain consistent. Therefore, it is necessary for the registrants and filers of imported cosmetics to be promptly informed of changes in labeling management regulations and to make compliant improvements in a timely manner.

Interpretation of General requirements of safety and technical for toothpastes

Application Scope

This document stipulates the general requirements and product requirements for toothpaste. It applies to toothpaste produced and marketed within the People's Republic of China, as well as toothpaste intended exclusively for sale outside the People's Republic of China.

Background of Compilation

Toothpaste is both a daily consumer product and one closely related to the oral health of the public. With the continuous development of the market, China has become the world's largest producer and consumer of toothpaste. On January 1, 2021, the "Cosmetics Supervision and Administration Regulation" officially came into effect, stipulating that toothpaste is to be managed with reference to general cosmetics. In 2023, China released and implemented specific regulations and normative documents for toothpaste for the first time, such as the "Toothpaste Supervision and Administration Regulations" and the "Toothpaste Filing Data Management Regulations."

These regulations impose mandatory requirements on the use of ingredients, physicochemical and microbiological testing, toxicological testing, and other aspects of toothpaste products. On March 18, 2024, the National Medical Products Administration included 15 testing methods, including the pH value testing method for toothpaste, which will be fully implemented from December 1, 2024, for toothpaste filing and sampling inspection. Additionally, since a general safety technical requirement mandatory national standard for toothpaste products has not yet been established, it is urgent and necessary to formulate the "General Safety Technical Requirements for Toothpaste" to ensure the quality and safety of toothpaste products and protect consumer health.

Comparative Analysis with International Standards, Laws, and Regulations of Other Countries or Regions

This document does not adopt international standards. During its formulation, parts of ISO 11609:2017 related to safety, such as the requirement for total fluoride content in unit containers, were referenced. The document was developed with full consideration of foreign regulations, directives, international standards, and advanced foreign standards, and was compiled in conjunction with the actual situation in China. This approach helps China to align with international standards in a timely manner. In terms of technical requirements, it fully considers the actual conditions of the domestic industry while striving to maintain consistency with international requirements.

Recommendation and Reasons for External Notification

It is recommended to notify externally. Currently, the international standard ISO 11609:2017 has been published, and the requirements for heavy metals, microbiology, abrasiveness, etc., in the document are not consistent with Chinese regulatory requirements. Therefore, the international standard was not adopted during the revision of this document. Given the significant export volume of Chinese toothpaste products, the release of the standard may have a substantial impact on trade with other members of the World Trade Organization (WTO). According to the relevant provisions of the "Administrative Measures for Mandatory National Standards," it is recommended to notify externally in accordance with the requirements of the World Trade Organization (WTO).

These two mandatory national standards are now open for public consultation. The consultation period is from March 30, 2026, to May 29, 2026. Relevant organizations and individuals can submit their feedback to hzpbwh@nifdc.org.cn, and please indicate "General Labeling for Cosmetics - Feedback" or "General requirements of safety and technical for toothpastes - Feedback" in the email subject line.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Our Services

  • China Cosmetics Registration and Filing
  • China New Cosmetic Ingredients Registration and Filing
  • China Toothpaste Filing
  • China Cosmetics Safety and Efficacy Test
  • Being Domestic Responsible Person
  • Safety Evaluation Report
  • Cosmetic Ingredient Quality and Safety Info Code Application
  • Formula/Label/Ingredient Review
  • Regulatory Consulting/Reporting/Training
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Further Information:
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