Cosmetic Sets Labeling and Naming Requirements in China

In the cosmetics business and its marketing approach, the phrase “cosmetic sets” is frequently used. It is also referred to as a beauty package, a cosmetic box, etc. Selling cosmetics in a single container or in a package with several different cosmetic goods is the fundamental concept.

However, in the regulatory realm, the definition of a “Cosmetic Set” varies somewhat based on the scenario and the product combination.

According to the NMPA in China, cosmetic sets are any of the following circumstances, with varying requirements for labeling.

• 1. Several Products must be used together in the set.

For example:

1. hair dye products are generally composed of two parts: hair dye and oxidant, which are called“I agent” and “II agent“.
2. the essential oils of many essential oil products can only be used after being diluted and blended with base oils, and the essential oils and base oils are combined into one product.
3. some frozen-dried powder products need a certain solvent to dissolve the powder before use, and the freeze-dried powder and solvent are combined into one product.

In principle, the above types of products are necessary to be registered as one product, but the formulas shall be filled in separately.

If one or more products in the set are special cosmetics, they should be registered as special cosmetics;

If one or more products of a set are produced overseas, they shall apply for registration or notification as imported cosmetics.

In this case, the Cosmetic Set should be labeled with a set’s product name. 

• 2. Each product in the Cosmetic set can be used separately. 

Products that could be used separately, but brands claim they should be used together as good performance care and put products into a set for registration and notification, such as putting facial cleanser, face cream, and eye cream in one box for sale. China NMPA allowed to register as a Cosmetic Set. But if you want to sell the inside product separately as well, you need to register each product again. 

In this case, just like in case 1, the cosmetic set should have a set product name.

• 3. Each product inside the cosmetic set that has been registered separately but the cosmetic set is not registered in NMPA.

For example, combining a registered hair conditioner and a registered hair coloring product into a set product, there are two situations:

(1) Transparent packaging

At this point, consumers can directly see the label information of the product inside through the outer packaging of the box, so there is no need to mark the label information on the box.

(2) Non-transparent packaging

At this time, consumers cannot see the label information of the product inside the box, so the label information inside the product must be copied to the outer packaging of the box. The content related to product safety and efficacy marked on the outer packaging of the box should be consistent with the label information on the internal product. For example, the name, service life, and implemented standard number of each internal product should be marked on the outer packaging of the box. . At this time, an additional box product name can be marked on the outer packaging of the box,or it can not be marked. If the product name of the box is marked, it should comply with the cosmetic naming rules. The pictures of the outer packaging of the box may not be uploaded to the registration and filing system.

According to the law:

“Regulations on the Administration of Cosmetics Registration and Filing Data” Article 32 When filing for ordinary cosmetics and before the listing of special cosmetics, the registrant, filing person or domestic responsible person shall upload the label picture of the product sales package, and the picture shall meet the following requirements: Requirements:

…

(4) If there are multiple sales packages, the label pictures of all sales packages shall be submitted. If one or more of the following situations are met, the label picture of one of the sales packages shall be submitted, and the label pictures of other sales packages may not be uploaded repeatedly:

1. Only the net content specification is different;
2. Only the additional label on the uploaded sales package Information on sales channels, promotions, special funds for festivals, gifts, etc.;
3. There are differences in only the color of the sales package;
4. The registered or filed products are sold in sets, gift boxes, etc., and the combination process does not touch the product contents, except for adding Except for the product name of the combined package, the content of other labels does not exceed the content of each product label;
5. The text description can clearly reflects the difference from the uploaded sales package and has been noted.

Article 35 For cosmetics that contain two or more independent formulas that must be used together or whose packaging containers cannot be disassembled, the formulas shall be filled out separately, and registration or filing shall be handled as one product.

If one (agent) or more (agents) of the products are special cosmetics, they should apply for registration as special cosmetics; if one (agent) or more (agents) of products are produced overseas, they should apply for registration or go through filing as imported cosmetics.