Q&As on Ordinary Cosmetics Filing in Guangzhou (Vol. 71)

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. How should the pH value of children's cosmetics be set?

The Provisions on the Supervision and Administration of Children's Cosmetics encourage the formulation of product implementation standards that are stricter than mandatory national standards and technical specifications for children's cosmetics. Children's cosmetics should comply with the requirements of the Technical Guidelines for Children's Cosmetics, setting scientifically reasonable pH parameters, index ranges, and quality management measures based on product formulation, production process, usage method, and related research data. A brief explanation should also be provided. According to the Inspection Work Standards for the Registration and Filing of Cosmetics, products that do not require pH testing—such as purely oil-based (including wax-based) products—are exempt from this requirement.

2. How should the control range of ingredients that require content regulation be properly reported in the product implementation standards?

In the product implementation standards, certain ingredients require a control range based on the declared formulation amount. For example, if Octocrylene is added at 5% in the product formula and the intended control range is set with an upper limit of 6% and a lower limit of 4%, the control range can be expressed as 4%–6%, (4–6) %, or (0.8–1.2) × the formulation amount. It is recommended to avoid using non-standard or ambiguous expressions, such as 5±20% or 5%±20%, to ensure clarity and compliance.

3. How to Fill in the Brief Description of the Manufacturing Process in the Product Implementation Standards?

(1) The main steps of the actual manufacturing process should be briefly described, including ingredient addition, mixing, and filling. If certain steps, such as premixing or filling, are carried out in collaboration with different manufacturing enterprises, this should be indicated in the remarks section.

(2) The description should include the key manufacturing process parameters, such as temperature, ensuring consistency with the basic properties of the raw materials and the product formulation type.

(3) The description should include all ingredients in the formulation, with ingredient names or sequence numbers consistent with those in the formulation table. If the same ingredient is used at different stages of the process, it should be distinguished accordingly. Additionally, any auxiliary materials such as water or volatile solvents that are used during manufacturing but removed in later stages should be clearly indicated.

4. How should the specific plant part be indicated when using ingredients directly derived from plants in the formulation?

According to the Provisions on the Management of Cosmetic Registration and Filing Data, when using ingredients directly derived from plants in the formulation, the specific plant part used should be indicated. For example, if the ingredient reported in the formulation is "Prunus Persica (Peach) Juice", its source should be specified in the remarks column of the formulation table, such as "fruit pulp."

5.  How should the standard Chinese name be reported for plant-derived ingredients obtained through steam distillation in the formulation?

If plant-derived ingredients obtained through steam distillation are used in the formulation, their standard Chinese names should be reported based on the actual product obtained from the preparation process, following the naming conventions in the Inventory of Existing Cosmetic Ingredients in China (IECIC 2021). For example, if an oily liquid is obtained from the steam distillation of Rosa rugosa (Rose) flowers, it should be reported as "Rosa rugosa (Rose) Flower Oil". If an aqueous solution is obtained, it should be reported as "Rosa rugosa (Rose) Flower Water".

If the Inventory of Existing Cosmetic Ingredients in China (IECIC 2021) does not include a corresponding name for a plant-derived ingredient obtained through steam distillation, but the name of the relevant plant extract is listed, it can be reported under the plant extract name. Additionally, a clarification should be provided in the remarks column of the formulation table.

For example, if an oily liquid is obtained from the steam distillation of Polianthes tuberosa (Tuberose) flowers, it can be reported as "Polianthes tuberosa Extract". In the remarks column of the formulation table, it should be noted: "The used part is the flower, and the actual ingredient is Polianthes tuberosa Flower Oil".

About CIRS

The CIRS cosmetic team is dedicated to ensuring that cosmetic products meet the stringent regulatory standards around the globe. It can provide one-stop services covering the whole life-cycle of a personal care product, which includes cosmetic ingredient development, physical/chemical tests, toxicological tests (in vivo & in vitro), efficacy studies (in vivo & in vitro), ingredient registration, and product registration.

Cosmetic services in China:

• China Cosmetic Registration and Filing;
• China New Cosmetic Ingredient Registration and Filing;
• China Cosmetic Ingredient Quality and Safety Information Code Application (NMPA Code);
• China Cosmetics Safety and Efficacy Test;
• China Cosmetic Safety Assessment Report;
• China Toothpaste Filing;
• China Disinfectant Notification; and
• China Cosmetic Formula/Label/Claim Review

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

Further Information

https://scjgj.gz.gov.cn/zmhd/cjwt/pthzpba/content/post_10027706.html