Q&As on Ordinary Cosmetics Filing in Guangzhou (Vol. 62)

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.

How do you Conduct a Safety Assessment for Nanomaterials?

The "Guidelines for Submission of Cosmetic Safety Assessment Data" stipulate that if a product formulation contains nanomaterials, it must clearly include information on the ingredient quality specifications such as purity, crystalline form, initial particle size distribution, and surface coating substances. Based on these quality specifications of the ingredients, a safety assessment should be conducted for the nanomaterials at the levels used in the formulation. It is also necessary to explain whether the toxicological test methods used for the assessment are suitable for testing nanomaterials.

Due to the small particle size of nanomaterials, there is a higher risk of inhalation exposure. Therefore, the use of nanomaterials in products where there is a potential risk of inhalation exposure is discouraged.

How do you Assess the Flavors and Fragrances in a Product?

The "Guidelines for Submission of Cosmetic Safety Assessment Data" specify different requirements for the assessment of flavors and fragrances based on how they are listed in the product formulation. If the "Standard Chinese Name" column of the product formulation table only lists "fragrance" as an ingredient, the fragrance must be assessed according to the principles and requirements of the guidelines. It should be clearly stated that the fragrance used in the product complies with the International Fragrance Association (IFRA) Code of Practice or meets the relevant national standards for fragrances in China. If the "Standard Chinese Name" column lists both "fragrance" and specific fragrance components, each fragrance component must undergo a safety assessment.

For children's cosmetics containing fragrances, essential oils, or flavoring components, it is necessary to identify and assess any allergenic components present.

If the Ingredient is Not Listed in the Formulation, Does it Need to Be Assessed for Safety?

The "Technical Guidance Principles for Cosmetic Formulation Reporting" specify that cosmetic registrants, filers, or domestic responsible persons must ensure the quality of the materials they choose to use. Ingredients or ingredient components that are not part of the formulation do not need to be reported in the product formulation.

However, when assessing materials, it is also necessary to individually describe and conduct a thorough safety assessment of extremely trace components (for example, those added to ensure the quality of cosmetic materials) that are not reported as part of the formulation. This is to ensure that such components do not compromise the quality and safety of the materials.

How do you Scientifically Understand the "Anti-Itch" Claims of Cosmetics?

Cosmetics should be strictly distinguished from medicines and should not exaggerate claims of "anti-itch" effects. If the itchiness is due to factors such as mosquito bites, fungal infections, eczema, or allergic dermatitis, it exceeds the definition of cosmetics. Cosmetic registrants should adhere to the National Medical Products Administration's "Cosmetic Classification Rules and Classification Catalogue" Appendix 1, which includes a classification of 21 types of general cosmetic effects along with their definitions and claim guidelines. Claims should be scientifically, reasonably, and legally marked based on evidence that is scientific, reasonable, and sufficient.

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