Do you know the principle of "consistency" in notification efficacy claims of common cosmetic?

“Classification Rules and Classification Catalogue of Cosmetics” has unified specifications for classification of cosmetics based on dimensions such as efficacy, site of action, users, product dosage form and method of use. However, common cosmetic notifiers still feel confused about how to check the efficacy and whether all labels need to be labeled when preparing notification materials. In this issue, we combine common problems in filling out notification materials and start with the three "consistency" principles to help notifiers further improve the level of notification compliance.

Consistency between the efficacy claims in the classification code under the "notification application form" and the claims under the "product label"

All the efficacy of the product must be checked under the "notification application form" in order to be claimed in the future. If the product is stated or implied in the label to have repairing and soothing effects, the corresponding effects must be selected under the "notification application form". However, due to packaging design or requirements of business strategy, products with repair and soothing effects may not necessarily be claimed by the enterprise in the label. After selecting the above effects in the notification application form, they can be claimed in advertisements in the future.

Consistency between the efficacy claims in the notification materials and the summary of the efficacy basis for public disclosure

The pre market notification and summary disclosure of product efficacy are both provisions of “Cosmetics Supervision and Administration Regulations” (CSAR), and enterprises should ensure the authenticity of relevant data. Although the summary of the efficacy basis does not belong to the scope of notification materials or the inspection of notification materials, it is within the scope of the main responsibility of the enterprise. The efficacy claims in the notification materials should be based on the efficacy confirmed by research and development, so the two should be consistent.

Consistency between product formula ingredients and efficacy claims

Formula ingredients are the material basis for efficacy of cosmetics. If cosmetics claim to have repairing and soothing effects, there should be corresponding ingredients in the formula. These ingredients can have a single effect or a combination of multiple components, but they should be confirmed through research. So the ingredients and efficacy claims of the product formula should be consistent.