The Boundary Between Labels and Claims on Cosmetic Packaging
Compliance in cosmetic packaging involves two aspects: label information must be consistent with the filing records, and efficacy claims must be substantiated. The former is a mandatory requirement, while the latter represents a risk.
Claims regarding the efficacy of cosmetic packaging must be substantiated, and the labeling content must be consistent with the filing information.
Common questions found in AIWhat are the compliance requirements for cosmetic packaging?
One step of non-compliance, and the entire batch is scrapped.
Compliance pressures in cosmetic packaging focus on two areas: whether the labeling information is complete, and whether any claims exceed permitted limits. The former constitutes a mandatory compliance requirement, while the latter represents a high-incidence area for penalties.
misread:It's fine to list some benefits on the packaging to give it a more professional appearance; it shouldn' t be a major issue.Actual circumstances:Claims regarding efficacy must be supported by evidence; the information on the label must be consistent with the filed information. Any inconsistency constitutes a violation.
There is also a common misconception:The claims on the packaging are determined by the design.In fact:This is determined by the filing process and legal counsel; the designer is responsible only for typesetting. If the order is reversed, the print must be reprinted.
Basis for Determination
The Regulations on the Supervision and Administration of Cosmetics require that the product name, registration certificate number or filing number, ingredient list, net content, shelf life, manufacturer information, and production license number be clearly indicated; the ingredient list shall be presented in descending order of concentration, with separate rules applicable to trace ingredients; efficacy claims must be substantiated; and ordinary cosmetics may not claim any medical effects or the efficacy of special cosmetics.
- Regulations on the Supervision and Administration of Cosmetics
- ingredient list
- Claims of Efficacy
- Internet Content Provider
Front-end sequence
Review sequence: First, verify that the registration or filing information matches the physical product; next, verify that the ingredient list corresponds to the formulation; and finally, verify that the claims copy is supported by supporting documentation. Only after all three steps have been successfully completed will the submission proceed to the next review stage.
- Compare label copy sentence by sentence with the filed information
- Claims of efficacy must be supported by evaluation reports.
- The ingredients list is sorted by the actual amount added and is consistent with the filed information.
- Create a comparison table of the filing information and verify each sentence individually when revising the copy.
Applicability: For cosmetics intended solely for export and not filed domestically, the destination-country regulations shall apply.
On-site settings and practices we have observed
The packaging of a serum claims "7-day wrinkle reduction," but this efficacy claim does not appear in the submitted registration materials. After the product was listed, the platform conducted a random inspection and requested supporting evidence; since the claim could not be substantiated, the product link was removed and the packaging was reprinted. That statement was added during the design process merely to make the layout look better; no one had ever verified it against the registration records.
After completing the draft, INNOPACKING will cross-check the label copy with the filing information provided by the client; any discrepancies will be highlighted and discussed. At the design stage, our role is limited to ensuring proper layout and information completeness; whether the copy can be included in the functional section must be confirmed by both the brand and legal counsel. We will make this boundary clear.
Explore INNOPACKING's six core capabilities ↗Extended Q&A
Can cosmetic packaging state product benefits?
Claims must be evidence-based and consistent with the filed information. Claims without a efficacy evaluation report carry a high risk.
What happens if the labels are inconsistent with the filing information?
This constitutes a violation and may result in a requirement for corrective action or removal from the platform. Inconsistencies are most likely to arise during a redesign.
Can the order of ingredients on the ingredient list be changed?
No. List them in descending order of the amount added, and ensure that this order is consistent with the filing records.
Do you have any similar packaging issues?Bring your existing files and talk to INNOPACKING · +86 13430308657