Cosmetic ingredients comply with the "instruction manual" | Beauty and Health law
Cosmetics are a chemical mixture of natural, synthetic or extracted basic raw materials, auxiliary raw materials and functional raw materials with different functions, processed by heating, stirring and emulsifying production processes and production processes. The quality of cosmetics is affected by many factors such as raw materials, formula, production process, production process and environment. Among the above factors that affect the quality of cosmetics, the raw materials of cosmetics have the greatest impact on the quality of cosmetics. Product compliance is a core component of cosmetic business compliance. Ingredient compliance is the most important part of cosmetic product compliance. Non-compliance of cosmetic ingredients will not only cause significant damage to brand goodwill, but also lead to economic losses such as product removal, packaging material scrap, waste of entry fees, product recall, etc. In serious cases, it will lead to product safety and quality accidents, and in serious cases, it will be suspected of criminal crimes. This paper will discuss the five key issues of cosmetic ingredient compliance from a full perspective for the reference of cosmetic operators.
New ingredients in cosmetics can only be used by permission. Cosmetic ingredients in China can be divided into two types: used ingredients and new ingredients. New ingredients in cosmetics refer to natural or artificial raw materials first used in cosmetics in China. China's "Cosmetic hygiene Supervision Regulations" stipulate that "the use of new raw materials for the production of cosmetics must be approved by the health administration department of The State Council", which establishes a licensing system for the use of new raw materials for cosmetics in China. The new ingredients of cosmetics in China can only be used after administrative permission, and cosmetics operators shall not unilaterally pursue product effects and use unauthorized new raw materials. The "Catalog of Used Cosmetics Raw Materials" (currently implemented as the 2015 edition) clearly specifies the 8,783 cosmetic raw materials that have been used in the field of cosmetics production in China, and cosmetics manufacturers can use the above raw materials in the process of cosmetics production, but if they use new raw materials beyond the list, they should go through the relevant licensing and approval procedures. It can only be used after obtaining the health administrative license, otherwise it is not in compliance. Cosmetics operators should carefully study the "Catalogue of Used Cosmetics Raw Materials" and master the latest used cosmetics ingredients. If new raw materials need to be used, they must go through administrative licensing procedures before use, and can only be used after obtaining permission. Although the "Regulations on the Supervision and Administration of Cosmetics" has been reviewed and adopted, the new raw material licensing system has been changed to a record system, but the direction of supervision of the use of new raw materials has not changed. It should be emphasized that some raw materials that can be used in foreign cosmetics are not of course used raw materials in China, and cosmetics operators need to pay attention when importing the above products.
Prohibited and restricted ingredients of cosmetics shall not be used in violation of regulations. China divides cosmetic ingredients into three categories: usable ingredients, prohibited ingredients and restricted ingredients. The prohibited ingredients of cosmetics refer to the ingredients that are not allowed to be used in the production of cosmetics as clearly stipulated by China's cosmetic laws and regulations. Cosmetics restricted ingredients refer to the use of cosmetics in the production process, but the use of limited concentration, limited scope of use, restricted conditions of use or the label must be marked with conditions of use and precautions. For example, the use of boric acid, calcium hydroxide and other ingredients should be marked with "prevent children from grasping or children under 3 years old do not use" precautions. The "Cosmetic Safety Technical Code" defines mercury, mercury compounds, lead, lead compounds and other prohibited substances; The restricted substances such as benzaldehyde and selenium sulfide have been stipulated, and the system of prohibiting the use of specific raw materials of cosmetics in China has been established. Cosmetics manufacturers should strengthen the use of raw materials management, strictly import raw materials, strictly prohibit the purchase and use of unknown sources, fake and shoddy raw materials, should not use cosmetics prohibited substances for the specific effect of the product, and shall not exceed the scope of the use of restricted substances. While pursuing product effects, cosmetic manufacturers should attach great importance to the control of raw materials from the perspective of cosmetic safety, grasp the scope of prohibited substances, resolutely eliminate the use of prohibited raw materials in strict accordance with the requirements of the "Technical Specifications for Cosmetic Safety", strictly control the use of restricted raw materials, and use restricted raw materials in accordance with the limited concentration, scope of use and conditions of use. Ensure that the products produced meet the national health standards. At present, the non-standardized use of cosmetic ingredients is a prominent problem in the compliance of cosmetic ingredients.
The cosmetic ingredients list should label all cosmetic ingredients. In order to protect consumers' right to know, facilitate consumers to choose products and avoid allergic raw materials, countries around the world have formulated strict regulations to manage the ingredients of cosmetics. Cosmetics ingredient list is an important part of cosmetics label. In principle, cosmetics produced or imported after June 17, 2010 in China must be marked with the full composition of cosmetics, except for free use by consumers and marked with the corresponding logo (such as gifts, non-sale products, etc.) cosmetics. The so-called cosmetic ingredients refer to the ingredients that are purposefully added to the product formula by the cosmetic manufacturer according to the product formula and play a certain role in the final product, such as water, glycerin, preservatives, sunscreen, moisturizers, colorants, etc. The cosmetic ingredient list shall be marked on the visual surface of the cosmetic sales package and be led out with the guidance of "ingredient:". The labeling of the cosmetic ingredients list must be true, and all ingredients added to the formula must be truthfully labeled, and no ingredients added for purpose shall be concealed, nor shall any ingredients actually not added be labeled. In addition to the ingredients that cosmetic operators purposefully add, cosmetic raw materials may also bring other substances, there are two main categories: one is the stabilizer, antioxidant, preservative, etc. added to the raw material manufacturer when producing raw materials to ensure the quality of raw materials; The other is the inevitable trace impurities in the technical process carried by the raw material itself or the residue, and the above-mentioned substances are not purposefully added into the cosmetics, so they do not need to be marked. At the same time, although it is added in the production process, it does not react chemically with other ingredients added, and raw materials such as processing AIDS that do not exist in the final product do not have to be labeled. For example, the ethanol added in the process of wet manufacturing solid foundation will evaporate after the product is formed, and the ingredient does not need to be labeled. In practice, it is necessary to pay special attention to the labeling of the following three special ingredients: (1) The combination ingredients, the cosmetic ingredients list for the mixture in the cosmetic raw materials to mark each component before mixing; The extraction solution should be labeled with the extract, the extraction solvent left in the extraction solution and the dilution solvent. (2) Essence, the fragrance, auxiliary ingredient, carrier can be labeled as an ingredient with the word "essence", and the auxiliary ingredient and carrier in the essence need not be listed as a separate ingredient. (3) Colorant: the name of the colorant adopts the English abbreviation of the colorant index number (dye index number) "CI" plus the colorant index number, such as "CI 12012", "CI 15633" and so on. If the colorant does not have an index number, the Chinese name of the colorant contained in the "Cosmetic Safety Technical Specification" can be used, such as: apple red, orange yellow, etc. For colorants that have other effects in the product at the same time, they can be marked separately according to the purpose of use, or they can be combined. For example: titanium dioxide can be used as a sunscreen, can also be used as a colorant, can be specifically marked according to the purpose of the formula design, the difference is that as a colorant other than the purpose of the need to use the Chinese name marked, as a colorant to use CI number marked. In short, it is a principle to truly label all ingredients on the visual surface of the cosmetic sales package, and it is an exception to not label the ingredient list or label the ingredient list on the manual and other materials.
Cosmetic ingredient lists must use standard translations. According to the regulations, the cosmetic ingredient list needs to be named in accordance with the International Nomenclature of Cosmetic Ingredients (INCI) Chinese Translation. For the raw materials that are not included in the International Nomenclature of Cosmetic Ingredients (INCI), the company can name them according to the pharmacopoeia name, chemical name or botanical name in turn. In the catalog, in addition to the standard Chinese translation of some ingredients, there are other names in the brackets behind, and cosmetics operators can mark according to the above complete form when labeling cosmetics ingredients, or they can choose a name label. For example, the Chinese translation of the ingredient "tocopherol" is "tocopherol (vitamin E)", and cosmetics operators can mark "tocopherol (vitamin E)", and can also mark "tocopherol" or "vitamin E". In addition, when labeling the standard name of the ingredient in the cosmetic ingredient list, the operator can also mark an alias or common name that is easy for consumers to understand after the official name of the ingredient. For example, the common name of "honeysuckle" is "Honeysuckle", and the operator can be marked as "Honeysuckle (honeysuckle) extract" in the ingredient list, but the ingredient name "honeysuckle" shall not be marked separately in the product ingredient list. It should be emphasized here that although the cosmetic ingredient list cannot be separately labeled with the common name of the cosmetic ingredient, the common name of the ingredient can be used alone in the name or claim of the cosmetic product, such as honeysuckle acne lotion. It should be noted that, according to the requirements of the "Regulations on the Naming of Cosmetics", the use of specific raw material names or raw material category words in the product name should be consistent with the product formula ingredients. Where the name of a specific raw material is used in the product name, the ingredients of the product formula shall contain the raw material; Where the term raw material category is used in the product name, the ingredients of the product formula shall contain specific raw materials that can be included in the category. Where the name of the raw material used in the product name is a popular name, the popular name shall have a consistent correspondence with the standard Chinese name of the raw material in the product formula.
The order of cosmetic ingredients list should be standardized. According to the regulations, cosmetic ingredients should in principle be ranked from high to low according to the size of the content. Among them, for the addition of more than 1% of the ingredients, in the product ingredient list in accordance with the decline of the amount of ingredients added in the product formula; If the amount of ingredients added is less than or equal to 1%, it can be arbitrarily arranged after the amount of ingredients added is greater than 1%. If two or more ingredient names are listed in the same row, separate each ingredient name with a comma (,). Special attention needs to be paid to the sequencing of the following three cosmetic ingredients: (1) Compound ingredients should be sorted according to their substance content before mixing. For example, if the amount of A raw material is 10%, and the raw material is A mixture composed of two components, 10%A and 90%B, "A" and "B" should be marked when the whole ingredient is labeled; When ordering the amount of ingredients added, it is necessary to multiply the amount of the raw material added to the product formula with the ratio of each ingredient in the raw material before ordering. Specifically: the content of A 10%*10%=1%; B content is 10%*90%=9%. Finally, it is sorted with the other ingredients in the recipe. (2) Extraction liquid, the extraction liquid should be sorted according to the extract, the extraction solvent remaining in the extraction liquid and the dilution solvent content. For example, the manufacturing method of "rose extract" with the addition amount of 2% in the formula is: 100g fresh rose → 0.1kg rose extract → 19.9kg dilution with 100% ethanol → 20kg rose extract. Therefore, rose extract accounts for 0.5% in this rose extract. Ethanol is 99.5%. When ordering the amount of ingredients added, it is necessary to calculate the amount of the raw material added to the product formula and the multiplying proportion of the ingredients in the raw material, and then the ordering. Specifically, the content of rose extract is 2%*0.5%=0.01%; Ethanol content 2%*99.5%=1.99%. Finally, it is sorted with the other ingredients in the recipe. (3) Colorants, regardless of whether the amount of colorants added to the product is greater than or equal to 1%, can be arranged in any order after the amount of more than 1%. In addition, when labeling colorants for multi-color cosmetics, insert "colorants that may be contained" at the end of the ingredients list; As a guide, colorants of all color ranges can then be arranged in any order.