1. Answer to "The system prompts that the raw material submission code is inconsistent with the raw material safety information platform data"
From January 1, 2024, the raw material safety information of all raw materials used in the product formula shall be filled in when filing ordinary cosmetics. Raw material safety information can choose to fill in the raw material submission code or upload the raw material safety information file. When the raw material submission code is inconsistent with the raw material safety information platform data, the system will automatically prompt a blue asterisk. It is recommended that the registrant verify the Chinese and English names of the raw materials in the raw material submission code to keep them consistent with the raw material names in the formula.
2. Answer to "The purpose of use of raw materials is not standardized, such as antibacterial moisturizers, anti-allergic agents or capryloyl hydroxamic acid and p-hydroxyacetophenone are filled in as preservatives"
The purpose of use of raw materials in the formula should comply with the requirements of the "Safety Technical Specifications for Cosmetics" and the scope of general cosmetic efficacy claims. If the raw materials are expected to be used as antibacterial agents or anti-allergic agents in cosmetics, they are suspected of having medical effects and exceed the scope of efficacy claims of ordinary cosmetics. Octanoyl hydroxamic acid and p-hydroxyacetophenone are not raw materials in the table of permitted preservatives in the "Technical Specifications for Safety of Cosmetics" and shall not be used as preservatives.
3. Answer to "Plant raw materials do not specify the use part in the formula remarks column:PRUNUS AMYGDALUS DULCIS OIL, COMMIPHORA ERYTHRAEA OIL, BOSWELLIA CARTERII OIL, PORTULACA OLERACEA FLOWER/LEAF/STEM EXTRACT"
According to Article 29 of the "Regulations on the Administration of Cosmetic Registration and Filing Materials": For products directly derived from plants, the specific parts of the original plants to be used shall be stated. "Directly derived from plants" includes raw materials named as XXXplant extract, XXX plant oil, XXX plant water, XXX plant juice, etc. For example, PORTULACA OLERACEA flower/leaf/stem extract indicates that the above-ground parts of the plant and its extracts are all used raw materials, and their specific parts shall be indicated when used. It should be noted that the parts to be used are clearly stated in the raw material name, such as LEVISTICUM OFFICINALE root extract, indicating that the part to be used of the plant is the root, and no further explanation is required in the formula remarks column.
4. Answers to "The product claims to be anti-acne/anti-wrinkle, but the ingredients in the formula have no relevant purpose of use"
According to Article 7 of the Technical Guidelines for Filling in Cosmetic Formulas: Requirements for filling in the purpose of formula raw materials: Cosmetics that claim to have the effects of hair dyeing, perming, removing spots and whitening, sun protection, anti-hair loss, acne removal, anti-wrinkle, anti-dandruff, deodorization, and cosmetics that claim new effects (except for special groups of people) should mark the corresponding functional ingredients in the purpose column of the formula table. If the functional ingredients that need to be marked are not a single component, their specific functional ingredients should be clearly stated in the purpose column. Therefore, if the product claims to remove acne/anti-wrinkle, the purpose of the formula raw materials should be acne remover/anti-wrinkle agent.
5. Answer to "The product names are 'XXX Hydrating Collagen Mask' and 'XXX Ammonium Lactate Moisturizing and Soothing Special Care Lotion'. Collagen and ammonium lactate are used as skin conditioners in the formula, which is inconsistent with the product efficacy claims of moisturizing and soothing"
According to Article 8 (2) of the "Cosmetic Label Administration Measures": If the generic name uses the name of a specific raw material or a word indicating the category of the raw material, it should be consistent with the product formula ingredients, and the efficacy of the raw material in the product should be consistent with the product efficacy claim. The skin conditioner is unclear, and the purpose of using collagen and ammonium lactate should be related to moisturizing and soothing.
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