Q&As on Ordinary Cosmetics Filing in Guangzhou (Vol. 57)

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.

1. What are "cosmetic samples"?

"Cosmetic samples" are colloquially known in the industry and have gradually become a new retail format. Generally, they refer to cosmetics packaged in smaller containers compared to the full-sized products sold on the market. They are often used as trial products or gifts accompanying the sale of full-sized products, and can also be sold as stand-alone items. They are characterized by their small size and portability.

2. What are the labeling requirements for "cosmetic samples"?

"Cosmetic samples" must present the product's relevant information to consumers truthfully, completely, and accurately on the label. "Cosmetic samples" without a Chinese name, without the name of the registrant or filer, and without an expiration date—known as the "three no's" products—are illegal and should be prohibited.

According to Articles 17 and 21 of the "Measures for Administration of Cosmetics Labeling," the labels of cosmetics provided to consumers for free trial, as gifts, or for exchange, etc., are subject to these measures. For cosmetic products in small packaging with a net content not exceeding 15g or 15mL, only the product's Chinese name, special cosmetic registration certificate number, name of the registrant or filer, net content, and expiration date need to be marked on the visible surface of the sales packaging. Other information that should be labeled can be included in the instructions that accompany the product.

3. What are the production requirements for "cosmetic samples"?

According to the "Measures for the Supervision and Administration of Cosmetics Production and Operation", the production of cosmetics (including samples) must be carried out by enterprises that have obtained the "Cosmetic Production License." Cosmetic operators are not allowed to formulate cosmetics (including samples) for sale by themselves. The formulation, filling, and packaging of cosmetic contents must be conducted by entities with a cosmetic production license. The production of "cosmetic samples" with fake ingredients in "genuine" packaging or the illegal addition of substances is strictly prohibited.

4. What are the registration and filing requirements for "cosmetic samples"?

China implements registration management for special cosmetics and filing management for general cosmetics. Special cosmetic samples must be registered with the National Medical Products Administration before they can be produced or imported. General cosmetic samples must be filed with the local drug regulatory authority before they are marketed or imported.

When general cosmetics are filed, and before special cosmetics are marketed, the registrant, filer, or domestic responsible person must upload images of the product's sales packaging labels. If there are multiple types of sales packaging, images of the labels for all types of packaging should be submitted. If the sample is only different in net content specifications, it may be exempted from uploading. General cosmetics can report all specifications in the "Net Content" section of the "Product Label" module in the filing management system, while special cosmetics can note the specification information when uploading images of the sales packaging.

5. What are the requirements for the operation of "cosmetic samples"?

Cosmetic samples are not exempt from legal regulations. According to the "Measures for the Supervision and Administration of Cosmetics Production and Operation", when cosmetic operators provide cosmetics to consumers for free trials, gifts, exchanges, etc., they must fulfill the obligations of cosmetic operators as stipulated by the Cosmetic Supervision and Administration Regulations. This includes implementing a supplier review system, keeping records of goods inspections, and other relevant systems.

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