The classification of products is very important in navigating the regulatory landscape. Cosmetic products are often borderline with other classifications of products on the market. Furthermore, cosmetics are not an exclusive class of products – meaning they can be both cosmetics and another type of product. In this article we will go into the varying product types which border cosmetics and discuss their classification.
Classification of Cosmetic Products Series
To learn more about the differences in classification across regional regulations, explore our classification of cosmetic products series:
Classification of General Cosmetic Products
Regulation
All cosmetic products are regulated by the Cosmetic Supervision and Administration Regulation (CSAR), authorised by the National Medical Products Administration (NMPA). CSAR came into force in 2021. It replaced the Regulations on Hygiene Supervision of Cosmetics.
The CSAR regulation is divided into primary, secondary and tertiary regulations. The primary regulation for all cosmetic products is the CSAR regulation, the secondary and tertiary regulations can be in the regulatory reference zone.
Definition
The definition of a cosmetic product is outlined in Article 3 of the CSAR regulation:
“daily chemical industrial products applied to the skin, hair, nails, lips and other human body surfaces by scrubbing, spraying or other similar methods for the purpose of cleansing, protecting, beautifying or modifying.”
Examples of General Cosmetic Classification
Skincare Products
Traditional skincare products such as moisturisers, toners and cleansers are all classified as general cosmetic products as long as they do not claim to make any efficacy claims (e.g. reduces signs of ageing).
Makeup
Makeup products are placed on the human body to beautify. They are referred to as colour cosmetics as they provide colour to the complexion or lashes. They are applied to the face, lashes, eyelids and occasionally body and are unlikely to contain any efficacy claims.
Classification of Special Cosmetic Products
Regulation
Special cosmetics are also regulated by the Cosmetic Supervision and Administration Regulation (CSAR).
The difference between general and special cosmetics is that general cosmetic products perform general cosmetic functions (cleansing, protecting, beautifying) and special cosmetic products have a special function of modifying. Special cosmetics have efficacy claims which require efficacy testing.
Definition
The definition of a cosmetic product is outlined in Article 3 of the CSAR regulation:
“daily chemical industrial products applied to the skin, hair, nails, lips and other human body surfaces by scrubbing, spraying or other similar methods for the purpose of cleansing, protecting, beautifying or modifying.”
It is the same definition as for general cosmetics, but special cosmetics focus on the modifying function of cosmetic products, whereas general cosmetics focus on cleansing, protecting and beautifying.
Examples of Special Cosmetic Classification
Hair Dye/Hair Perm Products
Hair dye and perming products physically alter the structure of the hair shaft (and in some cases the cortex). They are higher risk products due to the potential to cause allergic dermatitis (contact dermatitis), therefore, additional efficacy testing data is required before placing these products on the market.
Anti-acne Products
Acne is a skin disorder caused by the blockage of pilosebaceous units. These products make efficacy claims such as “reduces the appearance of acne”, or “reduces spots”. These claims require efficacy testing as they modify the skin’s function (either through reducing sebum production or exfoliating pores).
Skin Whitening Products
Skin whitening products are highly controversial in many places, however, in China they are seen as essential daily cosmetics. The lightening of the skin can be achieved through the downregulation of melanocyte melanin production or skin bleaching. Skin whitening claims are efficacy claims, and therefore, need to be substantiated with efficacy testing.
Sun Protection Products
Sunscreens are regarded as cosmetics in China. The claim ‘sun protection’ is an efficacy claim and UVB and UVA levels must be measured through SPF/PF testing.
In China the indication of UVB protection is given as an SPF value. There is a separate system to denote UVA protection, usually labeled as PA+ , PA++ , PA+++, or PA++++ based on the Protection Factor of UVA (PFA) value.
Classification of Soap Products
Regulation
Traditional soap products are not regulated under the Cosmetic Supervision and Administration Regulation (CSAR) regulation. Soaps are regulated under Product Quality Law enforced by China’s Nation Standards (GB Standards) issued by the Standardization Administration of China (SAC).
GB/T 26396-2011: This standard classifies detergents and soaps into three types based on their intended use and the associated health and safety risks.
Type B detergents: These detergents are used for personal hygiene, such as toilet soap, hand wash, and shower gel.
GB 38850-2020: This standard lists restricted substances in disinfectants, including active and non-active chemicals used in product formulations.
Category | Application scope | Relevant China National Standards |
A | tooth | GB 22115-2008 General requirements on raw materials of toothpastes |
B | Body | QB 1994-2013 Bath agents and shower agents QB 2485-2008 Toilet soap |
B | Hand | QBT 2654-2013 Hand cleaner |
B | Soap | GBT 26396-2011 Technical specification for safety of soap |
Definition
The definition of a Category B detergent is defined in GBT 26396-2011 – Technical specification for safety of soap and detergent:
“Detergent/cleanser used for personal hygiene, such as toilet soaps, shower gels and hand washes etc.”
Examples of Soap Classification
Bar of Soap
Bars of soap and other traditional cleansing products which do not make efficacy claims (e.g. kills acne-causing bacteria) fall under the classification of category B detergents in accordance with the Chinese National Standards. If they make efficacy claims, they would be classified as special cosmetics and regulated under CSAR.
Classification of Children's Products
Regulation
All children’s products are regulated under the Cosmetic Supervision and Administration Regulation (CSAR), the secondary regulation is the Supervision and Administration Provisions on Children Cosmetics, and the tertiary regulations are the Technical Guidelines for Children’s Cosmetics and the Announcement on NMPA’s Children Cosmetics Logo.
National Medical Products Administration (NMPA) created a children’s cosmetics label called “Little Gold Shield” on December 1, 2021. The legislation relating to this logo can be found in the tertiary regulation Announcement on NMPA’s Children Cosmetic Logo.
Definition
The Technical Guidelines for Children’s Cosmetics defines children’s cosmetics as:
“cosmetics for children aged 12 or under”
Products with labels such as “applicable to the whole population” and “used by the whole family” or using trademarks, patterns, homonyms, letters, Chinese pinyin, numbers, symbols, packaging forms, etc, to indicate that the users of products include children are subject to the management of children’s cosmetics.
Examples of Children's Products Classification
Cosmetic Toys
Toy decorative products produced exclusively for the makeup and decoration of toys by toy manufacturers shall not be managed as cosmetics. There is a certain risk when children misuse this kind of toy as cosmetics. “Lipstick toys”, “blush toys” and other products produced according to general Toy Safety Standards (GB6675-2014) may contain substances that are not suitable for use as cosmetic materials, including colorants with relatively high safety risks, which may irritate children’s skin if used.
Children's Toothpaste
Although there are separate secondary and tertiary regulations for toothpastes, children’s toothpastes are regulated as children’s cosmetics as general products. This includes its labelling and safety obligations.
Classification of Antiperspirant/Deodorant Products
Regulation
The definition of cosmetic products under CSAR has been revised, and this change has been reflected in the way cosmetic products are classified in China. With regards to the cosmetics definition specifically, the term ‘correcting body odours’ has been removed, meaning that products with this function, such as deodorants, may not be classified as special cosmetic products under CSAR. However, fragrances and perfumes are still included in the scope of general cosmetics. There is a 5 year transition period (from January 2021) for these products, therefore, from January 2026, deodorants will no longer be classified as cosmetics in China.
Classification of Toothpaste
Regulation
Although toothpaste products are not classified as cosmetic products, they are regulated under the same process as general cosmetics and follow their own administrative measures.
The primary regulation for toothpastes remains the Cosmetic Supervision and Administration Regulation (CSAR), the secondary regulation is Administration Measures on Toothpaste, and the tertiary regulation is the Provisions for Toothpaste Regulation.
Definition
The Provisions for Toothpaste Regulation defines a toothpaste as:
“a paste product applied to the surface of human teeth by means of friction, with the main purpose of cleaning.”
Examples of Toothpaste Classification
Adult Toothpaste
All toothpastes fit the definition of a toothpaste according to the Provisions for Toothpaste Regulations as the main function will always be to cleanse the teeth. There are, however, additional benefits that toothpastes may have, such as refreshing the breath, preventing cavities or removing harmful oral bacteria. All these toothpastes are regulated under the same regulation.
