Q&As on Ordinary Cosmetics Filing in Guangzhou (Vol. 68)

We have collected the latest FAQs on ordinary cosmetics filing from the Guangzhou Administration for Market Regulation and translated them into English for your reference.

1. What should be considered when setting pH control indicators in cosmetic product standards?

The "Safety and Technical Standards for Cosmetics" is the basic requirements to ensure the quality and safety of cosmetics. Registrants should strictly establish relevant product quality control indicators based on these specifications. When setting pH control indicators in product standards, attention should be paid to:

1. When a formula contains multiple ingredients with pH limit requirements according to the "Safety and Technical Standards for Cosmetics", the relevant ingredients should be considered comprehensively. For example, if a formula contains both citric acid and sodium hydroxide, the product's pH control indicators should meet both the requirement of pH ≥ 3.5 for alpha-hydroxy acids and pH ≤ 11 for sodium hydroxide as specified in the "Safety and Technical Standards for Cosmetics".

2. For children's cosmetics, the requirements of the "Technical Guidelines for Children's Cosmetics" should be met: Leave-on cosmetics should have a pH range of 4.5 to 7.5 (inclusive of 4.5 and 7.5); Rinse-off cosmetics should have a pH range of 4.5 to 8.5 (inclusive of 4.5 and 8.5). If specific physiological characteristics of the application area (e.g., infant diaper area), product attributes, or ingredient stability factors are considered, and the pH range is set in any of the following situations, a scientific and reasonable explanation should be provided, along with a comprehensive safety assessment:

• The lower limit of the pH range is set ≥3.5 but <4.5;
• The upper limit of the pH range for leave-on cosmetics is set >7.5 but ≤10.5;
• The upper limit of the pH range for rinse-off cosmetics is set >8.5 but ≤10.5.

3. Set an appropriate pH control range based on the product's formulation and process. For finalized products with specific fixed formulations, the pH indicator should fluctuate within a reasonable range. If the product's pH indicator is set between 4 and 10, the range is too broad and cannot effectively stabilize product quality.

2. What issues should be considered regarding the control indicators for functionality ingredients in the standards implemented for cosmetic products?

In cosmetic quality control, both the safety and stability of the product should be considered, with appropriate control indicators set for key ingredients. For example, when zinc pyrithione is used as an anti-dandruff agent, it is the primary component responsible for the product's dandruff-removing efficacy. Including zinc pyrithione in quality control measures is crucial for maintaining product stability. The quality control indicators for zinc pyrithione should not only meet the maximum allowable concentration of ≤1.5% as specified in the "Safety and Technical Standards for Cosmetics" but also be based on the scientifically determined amount during product development, taking into account production and testing variations to establish an acceptable range that ensures product stability. In the hypothetical scenario, if the scientifically determined formulation of a rinse-off anti-dandruff hair product contains 1.0% zinc pyrithione, and multiple production batches have verified that the variation in this concentration remains within 20%, the control range for zinc pyrithione can be set at 0.8% to 1.2%.

3. How to handle the situation when the "Legal Entity Verification Unsuccessful" message appears during the registration of a corporate account on the National Medical Products Administration's government service portal?

Please visit the National Enterprise Credit Information Publicity System to verify that the public information of the enterprise is completely consistent with the information provided during registration. Common discrepancies include:

• The company name confuses the Chinese and English formats of punctuation marks, such as using full-width and half-width parentheses inconsistently: "XXXX Company（Guangzhou）" vs. "XXX Company(Guangzhou)".
• The Unified Social Credit Code confuses the number "0" with the letter "o".
• The company name or the legal representative's name contains spaces or lacks spaces.

If the enterprise information is not found in the National Enterprise Credit Information Publicity System, it may be due to recent registration with the local market regulation department. Please contact the local market regulation department to confirm that the enterprise registration information has been submitted to the National Enterprise Credit Information Publicity System.

If the registration is still unsuccessful, please use the "Contact Us" option in the homepage menu or the "Consultation" sidebar on the National Medical Products Administration's government service portal. Select "Portal Usage Inquiry" and provide the required information to help system maintenance personnel verify and resolve the issue.

4. How to handle the situation when the "Legal Representative Real-Name Verification Unsuccessful" message appears during the registration of a corporate account, or "Real-Name Verification Unsuccessful" during personal account registration on the National Medical Products Administration's government service portal?

(1) Please download the "CTID" (Cyber Trusted Identity) app from mobile app store. Use the "Identify ID Card" method to activate the cyber trusted identity, then try registering again.

(2) If the real-name verification is still unsuccessful after activating the above identity, it may be due to issues such as ID card replacement or loss reporting. It is recommended to contact the local police station to verify the ID card information before proceeding with user registration.

If the registration is still unsuccessful, please use the "Contact Us" option in the main menu or the "Consultation" sidebar on the homepage of the National Medical Products Administration's government service portal. Select "Portal Usage Consultation" and provide the required information to assist system maintenance personnel in verifying and resolving the issue.

5. How to handle the situation when receiving a prompt saying "You have not changed your password for over 90 days" when logging into the National Medical Products Administration's government service portal?

To protect the security of accounts on the government service portal, not changing your password or not logging in for over 90 days may cause the system to flag your account as a security risk. Please follow the prompts to change your password, or click "Forgot Password?" on the corporate or individual login page to reset your password using the identity information provided during registration.

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