Chinese cosmetic labels: the display face, the visible face, and the “family use” trap

Chinese cosmetic labelling has a structural feature that catches designers rather than regulatory teams: the regulations distinguish between two parts of a package, and place different items on each.

• The display face (展示面) is the face presented to the customer on the shelf — the front, or the front and side.
• The visible face (可视面) is any face a customer can see without opening the package, including the base.

Product name and net content go on the display face, moving to a visible face only where the shape or volume genuinely prevents it. The ingredient list, the local agent’s details, the batch and date information, the filing or approval number and any safety warnings go on a visible face. A layout that puts the ingredient list somewhere elegant and internal fails; so does one that hides the net content on the base of a package that had room for it on the front.

Everything below sits on top of one requirement: every smallest sales unit must carry a Chinese label, either printed directly or applied. Where it is applied, its content must match the original label — a Chinese label saying more, less or differently from the source label is a defect in itself.

Regulatory basis

• 《化妆品监督管理条例》 — Regulations on the Supervision and Administration of Cosmetics, State Council Order No. 727
• 《消费品使用说明 化妆品通用标签》 GB 5296.3-2008 — Instructions for Use of Consumer Products: General Labelling for Cosmetics, the general labelling standard for the category
• 《儿童化妆品监督管理规定》 — Provisions on the Supervision and Administration of Children’s Cosmetics
• 《化妆品安全技术规范（2015版）》 — Safety and Technical Standards for Cosmetics
• 海关总署 2021 年第 108 号公告 — which, from 1 January 2022, abolished the domestic consignee filing for imported cosmetics

That last one is worth stating plainly because it removes a step people still plan for: the domestic consignee now needs only the ordinary customs consignor and consignee filing, not a separate cosmetics-specific one.

What the label must carry

Product name. Chinese cosmetic names are built from three parts — a trademark name, a generic name and an attribute name — and must reflect what the product actually is. Series numbers and shade numbers may sit on a visible face.

Country or region of origin, introduced by a lead-in word. Hong Kong, Macau and Taiwan are named as regions.

The Chinese responsible party — the name and address of the agent, importer or distributor legally registered in China, on a visible face, with or without a lead-in word. The manufacturer’s own name and address may be omitted.

Net content, on the display face where the package allows.

Full ingredient list, on a visible face, introduced by 成分. Every ingredient deliberately added and performing a function in the finished product is named. The order is prescribed: ingredients above 1% of the formula in descending order of quantity, ingredients at or below 1% in any order after them. Where two or more ingredients share a line they are separated by a Chinese enumeration comma.

A point that catches formulators: an ingredient that reacts with another after addition is still declared. The list describes what was put in, not what survived.

Shelf life, by one of two methods — production date plus shelf life, or batch number plus a use-by date. Dates run year, month, day, with a four-digit year. Shelf life is written as a number of years or months.

Filing or approval number. Ordinary imported cosmetics carry the filing number; special cosmetics carry the approval number. It must match the certificate issued by the drug regulator exactly.

Safety warnings, where law or the nature of the product requires them, introduced by 注意 or 警告 — do not knock, keep away from fire, avoid direct sunlight, keep out of reach of children.

Two further items are recommended rather than mandatory, and both are worth including: usage guidance, in words or diagrams, and the storage conditions needed to make the shelf life real.

What the label may not say

Four prohibitions run across all cosmetics:

• Content stating or implying a medical effect
• False or misleading content
• Content contrary to public order and morals
• Anything else prohibited by law or administrative regulation

The first is the one that translates badly. Claims that read as ordinary cosmetic marketing in other markets — repairs, heals, treats, clinically proven to cure — are medical claims here, and the Chinese label is where they become a regulatory defect rather than a marketing decision.

Children’s cosmetics: a wider definition than most brands assume

A children’s cosmetic is a product for children aged 12 and under, for cleansing, moisturising, refreshing or sun protection. That is the expected part.

The unexpected part is what else falls in. A product labelled as suitable for the whole family, or a colour cosmetic marketed for “family use”, or any product that states it can be used by children, is managed as a children’s cosmetic. The category follows the claim, not the intended customer. A brand extending a general-market product with inclusive family-oriented copy can move it into the children’s regime without changing the formula.

The consequences are concrete:

• Children’s sun protection products are special cosmetics and require a registration certificate issued by the NMPA. Other children’s cosmetics are filed rather than registered.
• The sales package display face must carry the little gold shield (小金盾) children’s cosmetics mark.
• A warning introduced by 注意 or 警告 must appear on a visible face, stating that the product is to be used under adult supervision.
• Food-related presentation is prohibited: no “food grade”, no “edible”, no food imagery. This is aimed squarely at products styled to look appetising to a child.

Validity differs too: filings for ordinary imported cosmetics do not expire, while a special cosmetic registration runs for five years, with renewal applied for at least thirty working days before it lapses. Both can be checked on the NMPA site at nmpa.gov.cn.

How this is checked at the border

At declaration, the product name is entered against the customs product catalogue, the licence type and code are selected, and the registration or filing number issued by the NMPA goes in the licence number field, where the system verifies it automatically against the regulator’s records.

On examination, customs checks the packaging, the label and the instructions, and the test report, with testing covering heavy metals and microbiological limits against the cosmetic safety and technical standards. Goods passing are released with an Inspection and Quarantine Certificate for Inbound Goods; goods failing may not be sold or used and are ordered destroyed or re-exported within a set period, with customs disposing of them if that period passes.

The practical sequence

Settle the regulatory category first — ordinary or special, and adult or children’s, remembering that a family-use claim decides the last of those. Then obtain the registration or filing, because its number has to appear on the label. Then design the label to the display-face and visible-face rules. Then print.

Reversing the last two steps is the common and expensive error, because a label laid out before the number exists has nowhere to put it.