1. Is it necessary to check the specific claim (raw material efficacy), if cosmetic generic names use specific raw material names or the word that indicates the category of raw materials?
Yes, it is. Except for those that use animal, plant, or mineral names to describe the fragrance, color, or shape of the product. According to Article 8 of the Measures for the Administration of Cosmetics Labels, if a generic name uses a specific raw material name or a word indicating the category of raw material, it should be consistent with the ingredients of the product formula, and the efficacy of the raw material in the product should be consistent with the efficacy claim of the product; According to Article 11 of the Standard for the Evaluation of Efficacy Claims of Cosmetics, if a product efficacy claim is made by claiming the efficacy of a raw material, literature research, research data analysis, or efficacy claim evaluation experiments should be conducted to confirm that the raw material has the claimed efficacy, and the efficacy claim of the raw material should have sufficient correlation with the efficacy claim of the product.
If there are words such as the name of the raw material or indicating the category of the raw material in the generic name of the product name, and if the label claims the specific efficacy of the raw material, the specific claim (raw material efficacy) should be checked in the sample product label.
2. If a specific raw material name or word indicating the category of raw material is used in the generic name of the product name, how to fill in the purpose of use of this raw material?
According to Article 8 of the Measures for the Administration of Cosmetics Labels, if a generic name uses a specific raw material name or a word indicating the category of raw material, it should be consistent with the ingredients of the product formula, and the efficacy of the raw material in the product should be consistent with the efficacy claim of the product. Therefore, the purpose of use of this raw material in the formula should be consistent with the claimed efficacy of the product. Except for those that use animal, plant, or mineral names to describe the fragrance, color, or shape of the product.
3. What information is required for filing when animal organ tissue and blood extracts are used as raw materials in the product formula?
According to Article 29 (6) of the Provisions for the Registration or Filing Dossier of Cosmetics, if animal organ tissue and blood extracts are used as raw materials in product formulas, their source, composition, and preparation process should be provided, and relevant documents allowed to be used by the raw material production country should be provided.
4. How should cosmetic labels correctly claim the amount of added raw materials?
The claimed content of cosmetic labels should be legal, true, complete, and accurate, and should not contain false or misleading descriptions. When claiming the amount of added raw materials, the name of the raw material should be clearly stated, and the amount of "raw material (component)" added should not be confused with the amount of "raw material solution" added, nor should the "amount of raw material added" be confused with the "purity (concentration) of the raw material".
5. For cosmetics that claim to contain the raw material "芋螺肽Mu-conotoxin CnIIIC" on the label, what points should be noted?
"芋螺肽Mu-conotoxin CnIIIC" is a new cosmetic raw material that has completed filing in 2023, whose filing number is "国妆原备字20230010", and it is currently in the monitoring period. According to Article 20 of the Provisions for Registration and Filing of Cosmetics, during the safety monitoring period, if cosmetic registrants or filers use new cosmetic raw materials to produce cosmetics, the registration or filing of relevant cosmetics should be associated by the registrant or filer of the new cosmetic raw material through the Information Service Platform for Registration and Filing of Cosmetics.
In addition, "芋螺肽Mu-conotoxin CnIIIC" has a clear chemical name, CAS number, and chemical structure formula, therefore other irrelevant raw materials cannot be claimed as "芋螺肽Mu-conotoxin CnIIIC" to avoid misleading consumers.
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