No Food-Grade Labels on Children Cosmetics for Promotion on Tmall

Tmall added Specification for Publishing Children Cosmetics: ban the use of words like food-grade, edible or any other devices related to food when promoting the children cosmetics.

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At present, Tmall added a public notice named Specification for Publishing Children Cosmetics(hereinafter, the Specification). This rule was publicized on July 5th, 2022 in China Standard Time(the Time is applied in the whole text), and will go into effect on July 12th, 2022. The Specification regulates the ban on the use of words like food-grade, edible, or devices related to food, and the publication of medical terms in children's cosmetics promotion.

For the past few years, the e-commerce platform acts as an important channel for the cosmetics business. According to the data issued by China’s cross-border e-commerce platform Koala Global, the total consumption of children cosmetics increased by 300% in 2020 compared with 2019. Due to the increasing demand for children's cosmetics, more and more merchants engage in the cosmetics industry for children. When CHAILEEDO inputted Children Cosmetics on Tmall, various children's make-up boxes came into view. CHAILEEDO learned that most of these cosmetics boxes were children's toys to make-up dolls instead of kids, therefore, they were not under the cosmetics regulations.

What’s more, in order to attract consumers and dispel their misgivings, CHAILEEDO found some cosmetics products were blatantly labeled as edible on the promotion posters to hint to parents that these kinds of cosmetics were safer. In fact, cosmetics differ from food in product categories, so there are no so-called food-grade cosmetics.

In October 2021, the National Medical Products Administration also point out in popular science articles that children's cosmetics can never be labeled with words like food-grade and devices related to food. On January 1st this year, the implementation of China’s first regulation on children's cosmetics, the Children Cosmetics Supervision and Administration Regulation, marked China initiated strict supervision ofchildren's children cosmetics.

The quality safety of children's cosmetics remains as an important livelihood issue as well as the considerable content of China’s cosmetics supervision. However, relying on the work of regulators is quite inadequate. The e-commerce platform, as the children's cosmetic business operator, shall take effective administration and oversight. For instance, firstly, the platform should define the regulatory significance of the whole e-commerce link like Tmall’s release of the Specification. Then, the platform is supposed to further train the related business runners to learn more about laws, regulations and other specialized knowledge of the cosmetics field, for improving the professional quality of the staff.

As the Specification regulates, the make-up products with efficacy like cleansing, moisturizing, tonging and sun blocking on Tmall are classified as children's cosmetics once utilizing trademarks, devices, words, partial tone, alphabet, Chinese pinyin, numbers, symbols and packaged forms on the captions, main photos, attribution and detail pages of products to express or imply its accessibility to children.

The Specification also points out that the main photos and detail pages of children's cosmetics must clearly and completely show the label devices with Children Cosmetics on the packaging; When publishing children's cosmetics registered or filed after May 1st, 2022, it is necessary to display the product packaging pictures marked with the children cosmetics logo Xiaojindun(a little golden shield). Those registered before May 1st need to be supplemented with the logo before May 1st, 2023.

As the Specification requires, the efficacy of children's cosmetics used by infants (0 ~ 3 years old, including 3 years old) is limited to cleaning, moisturizing, hair care, sunscreen, soothing and refreshing; that for children (3-12 years old, including 12 years old) is limited to cleaning, makeup removal, moisturizing, beauty modification, fragrance, hair care, sunscreen, repairing, soothing and refreshing.

Ensuring the quality and safety of children's cosmetics is a long-term and uninterrupted project. To achieve the healthy development of children's cosmetics in China entails the joint efforts of regulatory departments, production and operation enterprises and e-commerce platforms.