CIRS clears up 'poor understanding' of baby toiletry guidelines

By Michelle Yeomans

- Last updated on GMT

CIRS clears up 'poor understanding' of baby toiletry guidelines

Related tags Cosmetics

Since the implementation of the Guideline in 2013, less than 100 non-special use baby care toiletry imports were permitted into China by the CFDA. CIRS reckons this is down to the industry's 'poor understanding' of the notification and breaks down the difficulties here.

According to the China Inspection and Regulation Service, imported baby care toiletries like shampoos, body washes and lotions require more complicated documents than similar products intended for adults.

China has specific requirements on several aspects of baby care products, including application documents, ingredients, microorganism and toxicology standards, and labels.

However, it is the varying specifications and requirements in the rest of the region that is causing the confusion for international companies.

CIRS advises that overseas companies need to pre-evaluate product safety and analyze the ingredients selection, product formula and production process.

Interpreting the difficulties of the notification

Apart from ensuring that their ingredients, formula, manufacturing process and quality control are compliant with current Chinese cosmetic regulations, international brands must also have Chinese labels or use special packages designed for the market.

The words “suitable for kids​” needs to be declared on the Chinese product name or package of baby care cosmetics as well as a warning like “use under the supervision of adult​”.

Overall, the China FDA will conduct strict technical examinations for the completeness, rationality and scientificity of the application dossiers of baby toiletries.

Product formula​:​ Formula design principle is required. An example is shown in the Guideline for reference. Safety assessment should be conducted for the content of each ingredient used in cosmetics. 

Production process​:​ Combining manufacturing characteristics, enterprises should clarify how to control the quality during the manufacturing process from the perspective of ensuring the safety of baby care cosmetics. 


  1. Using less ingredients based on the effect of products is achieved.
  2. The content of fragrance, colorant, preservative and surfactant should be less
  3. The cosmetic ingredients except sun block agents having the effects of whitening, spots removal, anti-acne, hair removal, hidroschesis, deodorizing, hair growth, hair dye, hair perm, fitness and breast shaping are unsuitable for baby care cosmetics. 
  4. The genetic or nano materials are not encouraged to use.
  5. Not using ingredients banned for baby care cosmetics in terms of Hygienic Standard for Cosmetics (2007).

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