Cosmetic labelling requirements in China

As is the case in many other countries, labelling is a very important part of ensuring compliance with the relevant cosmetics legislation in China. The applicable national standard for cosmetic products labelling is GB 5296.3-2008. Cosmetic labels, including claims, are checked during the process of pre-market product registration and they are also checked by the CIQ when the products arrive in Chinese ports. Failing to place compliant labels on the products when exporting cosmetics to China may result in product rejection or in the products being destroyed at the port.

Product labels have to be written in Chinese. Companies can either design special labels with the aim of being compliant with the rules of the Chinese cosmetics legislation or they can use their original packaging with China compliant over-labels.

The following information has to appear on the labels:

  • Product name
  • Name and address of the manufacturer
  • Net content
  • List of ingredients, which have to be written according to their Chinese INCI names, in descending order of concentration, at least for ingredients with a concentration above 1%
  • Shelf life and production date
  • Manufacturer’s license, product standard or administrative approval code that is received when the product is successfully registered
  • Safety marks, any possible precautions for use
  • Country of origin of imported products
  • Name and address of the distributor in China for imported cosmetics
  • Instructions for use and storage conditions if inadequate storage conditions will impact product safety.

Claims made on the cosmetic product labels have to be true and have to be in line with the Chinese definition of cosmetic products. Exaggerated claims regarding the performance or efficiency of the products, their composition, etc., are not allowed, as is also the case for any therapeutic claims, medical claims or comparisons that denigrate competitor products. Further, claims such as hypoallergenic, dermatologically tested or 100% natural will be challenged by the CFDA/SAMR expert panel.