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Guide

Additional requirements for children’s cosmetics in China

Children’s cosmetics must meet the ordinary-filing or special-registration path that the product itself requires, and they must also meet the Provisions on Supervision of Children’s Cosmetics. The sales pack should show the required children’s cosmetics mark (often called the “little golden shield”) and warnings such as use under adult supervision. The formula should follow safety first, efficacy only as needed, and a simplified composition. Safety assessment should consider children’s physiology and is generally submitted as a full report.

How to judge whether the product is a children’s cosmetic

Look at the labelled users, the claims and the pack design. An adult product should not be dressed up as a children’s product through cartoons or wording. Products that claim food-grade quality, edibility or food-like pictures are not allowed, because they increase the risk of accidental ingestion. A children’s sunscreen remains a special cosmetic and is registered; it does not move to ordinary filing because it is intended for children, and it does not use the 10–20 day ordinary-filing cycle.

What extra requirements apply

Prefer ingredients with a long history of safe use. Do not use new ingredients that are still in their safety-monitoring period. In principle, ingredients made with gene technology or nanotechnology should not be used unless the rules provide otherwise. The need for fragrances, colorants, preservatives and surfactants should be specifically justified. Toxicology reports for children’s products are generally not eligible for the waiver that may apply to some adult ordinary cosmetics.

Cautions

Design the formula and the pack for children from the start. Do not file an adult product and later “turn it into a kids’ version.” The labelled age group must be consistent across the label, the product standard and the safety assessment.

Questions we are often asked

Can children’s ordinary cosmetics use a basic safety-assessment conclusion only?

Generally no. Children’s cosmetics are treated as products that should submit a safety-assessment report, not as ordinary adult products that may keep a full report only on file.

Is the golden shield optional if the word “children” is already on the pack?

The required children’s cosmetics mark and warning statements should appear as provided in the rules. A word in the name is not a substitute for the mark.

Next step

Discuss your China market path

Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.

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