On April 15, 2026, China’s National Institutes for Food and Drug Control (NIFDC) published six technical guidelines regarding hair dye, perm and sunscreen cosmetics. We have collected the latest FAQs and translated them into English for your reference.
Q&A on the Technical Guidelines for Hair Dye Cosmetics
Q1: Is it necessary to submit information on the hair dyeing mechanism when applying for registration of hair dye cosmetics?
A: Conventional oxidative (two-part) and non-oxidative hair dye cosmetics are not required to submit information on the mechanism of action. For novel hair dye cosmetics (e.g., single-part oxidative hair dye products), explanatory materials elucidating the hair dyeing mechanism along with corresponding scientific basis shall be submitted in conjunction with the formula.
Q2: What materials must be submitted when a hair dye cosmetic formula contains organic colorants listed in Table 6, Chapter III of the Safety and Technical Standards for Cosmetics that are not prohibited for use in hair dye cosmetics?
A: Objective evidence demonstrating that the organic colorants do not participate in the hair dyeing process must be submitted. For oxidative hair dye products, safety assessment data for the organic colorants under the conditions of use of oxidative hair dye products must also be submitted.
Q3: What are the requirements for the suffix of the Chinese product name of a hair dye cosmetic?
A: The Chinese product name generally consists of three parts: trademark name, generic name, and attribute name. When different products share the same trademark name, generic name, and attribute name, other required information shall be appended after the attribute name, including color or shade number, fragrance, applicable hair type, or target population. The suffix of the Chinese product name shall not use terms outside the above circumstances, such as "plant protein conditioning type" or "amino acid care type." When describing colors, terms that explicitly denote color should be used, such as "coffee-colored" or "chocolate-colored," avoiding terms such as "coffee" or "chocolate" alone.
Q4: How should hair dye-related items be specified in the product standards for hair dye cosmetics?
A: Appropriate hair dye specifications and quality control measures shall be established based on the hair dyes contained in the product formula (including hair dyes for which no test methods are yet available in the Safety and Technical Standards for Cosmetics), ensuring comprehensive and accurate reflection of the hair dye quality control status of the product.
Q5: Which hair dyes must be tested during registration testing of hair dye cosmetics?
A: In accordance with the Cosmetics Registration and Filing Testing Standards, all hair dyes contained in the formula for which corresponding test methods exist in the Safety and Technical Standards for Cosmetics (including the "Chapter IV, Section 6: Test Methods for Colorants") shall be tested during registration testing as required by the said Standards.
Q&A on the Technical Guidelines for Perm Cosmetics
Q1: What are the requirements for the suffix of the Chinese product name of a perm cosmetic?
A: The Chinese product name of a cosmetic generally consists of three parts: trademark name, generic name, and attribute name. When different products share the same trademark name, generic name, and attribute name, other required information may be appended after the attribute name, such as fragrance or applicable hair type. Terms that do not comply with the relevant requirements of the Measures for the Administration of Cosmetics Labeling shall be avoided, such as "French perm," "quick perm," "plant nourishing type," or "protein softening type."
Q2: How should quality management measures be established for perm cosmetics containing thioglycolic acid, its salts, and thioglycolate esters?
A: For perm cosmetics containing thioglycolic acid, its salts, and thioglycolate esters, quality management measures shall not rely solely on "raw material specification control." Alternative measures such as "production process control" or a combination of non-testing and testing-based quality management approaches may be adopted to ensure that the content and product quality meet the standards.
Q3: When a testing-based approach is adopted as the quality management measure for thioglycolic acid specifications in perm cosmetic product standards, how should an appropriate test method be selected?
A: Section 3.9, Chapter IV of the Safety and Technical Standards for Cosmetics provides three methods for the determination of thioglycolic acid content: "Method 1: High-Performance Liquid Chromatography (HPLC)," "Method 2: Ion Chromatography (IC)," and "Method 3: Chemical Titration." Enterprises shall clearly specify the test method selected in their quality management measures. It should be particularly noted that when chemical titration is used, certain substances such as thiopropionic acid and cysteine may interfere with the determination, potentially leading to inaccurate results. Therefore, when the product formula contains such ingredients, Method 1 (HPLC) or Method 2 (IC) shall be selected as the determination method for thioglycolic acid content to ensure the reliability and accuracy of test results.
Q&A on the Technical Guidelines for Sunscreen Cosmetics
Q1: How should imported sunscreen cosmetics label their sun protection efficacy claims?
A: Imported sunscreen cosmetics are subject to the same requirements as domestically manufactured sunscreen cosmetics. They shall conduct testing in accordance with the sun protection efficacy test methods specified in the Safety and Technical Standards for Cosmetics, as required by the CSAR, the Measures for the Administration of Cosmetics Labeling, and the Cosmetics Registration and Filing Testing Standards. The SPF value, PA rating, and water resistance claims shall be labeled on the product label artwork and Chinese label in accordance with China's labeling management requirements for sunscreen cosmetics. If the SPF value, PA rating, and water resistance claims indicated on the original sales packaging label of an imported sunscreen cosmetic are inconsistent with the SPF value, UVA protection test results, and water resistance test results determined using the test methods specified in the Safety and Technical Standards for Cosmetics, a sales packaging shall be specifically designed for the Chinese market.
Q2: What should be noted when UV filters exist in the form of acids, salts, or other forms in formula declaration and product standard specification setting?
A: For UV filters existing in the form of acids, salts, or other forms, such as terephthalylidene dicamphor sulfonic acid and its salts, benzylidene camphor sulfonic acid and its salts, phenylbenzimidazole sulfonic acid and its sodium and potassium salts, etc., the specific name of the ingredient in its existing form (e.g., acid, sodium salt, or potassium salt) shall be indicated in the formula declaration or the remarks column. The specific name of the ingredient in its existing form shall also be clearly stated in the product standards, and the corresponding control range for the UV filter specification shall be correctly converted.
For example, if a sunscreen cosmetic uses disodium terephthalylidene dicamphor sulfonate, the formula shall declare "disodium terephthalylidene dicamphor sulfonate," or declare "terephthalylidene dicamphor sulfonate salts" with "disodium terephthalylidene dicamphor sulfonate" noted in the remarks column. If the declared formulation amount is 5%, the control range may be stated as "4.0%–6.0%, calculated as disodium terephthalylidene dicamphor sulfonate" or "3.7%–5.6%, calculated as terephthalylidene dicamphor sulfonic acid."
Q3: How should a safety assessment be conducted for aerosol-type sunscreen cosmetics?
A: When conducting a safety assessment for aerosol-type sunscreen cosmetics, the propellant shall be assessed separately from other ingredients. The assessment concentration for other ingredients shall be the concentration of each component in the formula after deducting the propellant (calculated as 100%); the propellant may be assessed separately or assessed according to its concentration in the formula.
For aerosol-type sunscreen cosmetics with potential inhalation exposure risk during use, a safety assessment for the inhalation toxicity of the propellant shall also be conducted.
Q4: What should be noted regarding usage instructions and safety warning statements for aerosol-type sunscreen cosmetics?
A: For aerosol-type sunscreen cosmetics using flammable gas as propellant, relevant labeling shall be provided in accordance with applicable laws, administrative regulations, departmental rules, mandatory national standards, and technical specifications, such as "Caution: Flammable. Keep away from fire and sources of ignition," or in the form of pictograms.
For aerosol-type sunscreen cosmetics with potential inhalation exposure risk, it is recommended to clearly state in the usage instructions: "Spray onto palms first, then apply to face." Safety warning statements such as "Do not spray directly on face," "Avoid inhalation," and "Avoid use in small, enclosed, or poorly ventilated spaces" or similar cautionary language shall be included.
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