1. Can the product label mark the China National Intellectual Property Administration logo?
Unapproved use of the China National Intellectual Property Administration logo and name on the product label is suspected of using the name or image of state agencies to promote and endorse the technology or quality of its products, and its labeling may mislead the public, constituting misconduct in the use of the patent mark.
2. What are the transitional management requirements for goods with a net content of less than 1g under the Measures for the Supervision and Management of Quantitative Packaging Commodities (Order No. 70 of the State Administration for Market Regulation)?
According to SAMR Announcement on Matters Related to the Implementation of the Measures for the Supervision and Management of Quantitative Packaging Commodities (No.25 of 2023), for products with a net content of less than 1g, a transition period of 12 months will be granted based on the original implementation date (June 1, 2023). Goods produced or imported before the end of the transition period can be sold until the end of the shelf life.
3. If products only claim to have efficacy that can be directly identified by sight, smell, and other senses or achieve effects through the physical covering, adhesion, friction, and other simple ways (such as cleaning, makeup removal, exfoliation through the physical method, etc.), and “Yes” for “Whether it can be exempted” has been cheeked in the “Efficacy Claims” module, is it still possible to fill in and submit the summary of efficacy claims for specific claims (e.g. claim suitable for sensitive skin, claim tear-free formula, claim ingredient efficacy, etc.)?
Currently, if “Yes” for “Whether it can be exempted” has been cheeked in the “Efficacy Claims” module on the Information Service Platform for Registration and Filing of Cosmetics, it is still possible to fill in and submit the summary of efficacy claims for specific claims (e.g. claim suitable for sensitive skin, claim tear-free formula, claim ingredient efficacy, etc.).
4. From the perspective of filing inspection, what should be noted when rinse-off products claim to have efficacy such as anti-acne, anti-wrinkle, and anti-spot?
According to the Work Specifications for Cosmetics Registration and Record-filing Inspection, rinse-off products that claim to have anti-acne, anti-wrinkle, and anti-spot efficacy should conduct human trial safety evaluation.
5. Do cosmetics offered to consumers in the form of free trial, gift, exchange, etc. need to meet the requirements of the Measures for the Administration of Cosmetics Labels?
According to Article 21 of the Measures for the Administration of Cosmetics Labels, cosmetics offered to consumers in the form of free trial, gift, exchange, etc. also need to mark Chinese labels on their packages, whose contents shall comply with the Measures.
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