After the promulgation of the "Measures for the Administration of Cosmetic Labeling" (hereinafter referred to as the "Measures"), there have been constant disputes in the industry, and many practitioners have expressed some "confusion". On the one hand, it is difficult to implement the regulations such as "raw materials with a content not exceeding 0. 1% are trace components" and "all components in cosmetic samples". On the other hand, products that excessively pursue "ingredient labels" may also decrease with the promulgation of the Measures.
The labeling of "trace components" caused industry controversy.
Faced with the problem of replacing the outer packaging of products, cosmetics companies are generally "at a loss". The method issued by the State Administration of Pharmaceutical Products clearly stipulates that if the content of ingredients in cosmetic formula does not exceed 0. 1% (w/w), all ingredients that do not exceed 0. 1%(w/w) shall be labeled as "other trace ingredients" and shall not be arranged in descending order of ingredient content.
"The labeling of' trace components' has caused great controversy in the industry, because there are too many raw materials with content less than 0. 1%, such as astaxanthin, polypeptide, fibronectin and so on." Chen Laicheng, chief engineer of Guangzhou Zunyi Cosmetics Co., Ltd. told China Business Daily that this regulation seems to be "amateur" and it is difficult for enterprises to implement it.
The original intention of this regulation is to prevent false marketing of cosmetics. The relevant staff of Shandong Drug Administration told Huashang Daily that some cosmetics will claim to contain some functional raw materials in marketing, but the content of this raw material is not indicated. Many consumers buy products for this raw material. If the actual content of this raw material in cosmetics is very low, it constitutes false marketing and harms the interests of consumers.
At present, "whether labeling' trace ingredients' will affect consumers' choices" is the most concerned issue for cosmetics enterprises. There are indeed many consumers who pay more attention to some ingredients in cosmetics, such as hyaluronic acid. "A beauty blogger with more than 65,438+million fans told Huashang Daily that when he sells goods in the live broadcast room, he will also use ingredients as a promotional selling point for cosmetics. If the outer package is marked with "trace ingredients", consumers may question the efficacy of the product. Zhang Ran (pseudonym), a staff member of R&D department from a cosmetics processing factory, told China Business Daily that if these measures are implemented, almost all cosmetics on the market will be replaced.
What difficulties will enterprises encounter in implementing the requirements of the Measures? Tan Qin, a senior beauty brand management expert and CEO of Qin Tian brand consulting company, told reporters that compared with before, the operation process of enterprises has become more complicated. At the initial stage of product development, the ingredients should be arranged well, and there should be a guide for "trace ingredients" on the label, and everything below 0. 1% should be listed. Product managers and business personnel should also be particularly professional. At the initial stage of development, enterprises must communicate clearly the requirements of product proofing, otherwise, if all components are provided later, it will waste time, resulting in repeated adjustments and rising costs.
Samples and imported cosmetics should be marked with ingredient content.
"In fact, the label management law is to implement the previously promulgated packaging regulations," Chen Lai Cheng said. "But there are too many details, and it will be more troublesome to implement small packaging products."
The Measures stipulate that small packaged products with a net content of no more than 15g or 15mL shall be marked with Chinese name, composition, net content and service life; For products with packaging boxes, the Chinese name and service life of the products should also be marked on the packaging container that directly contacts the contents.
"A sample product may not be as big as a finger, so it is difficult for enterprises to label all ingredients and service life." Zhang Ran told the China Business Daily that it is even more difficult to indicate the above information for products such as two-investment products and experience products.
There are also imported cosmetics companies that find it difficult. The relevant person in charge of Shanghai Baoshi Supply Chain Management Co., Ltd. told the reporter that the outer packaging of imported cosmetics is in English, and manufacturers generally only mark Chinese names. It takes a lot of work to translate and label all the ingredients. In addition, some formulas of imported cosmetics are also confidential, and it is almost impossible to indicate all the ingredients.
In addition, the "Measures" stipulate that cosmetics that are tried, given or redeemed for free should also be clearly marked. The reporter searched for the keyword "cosmetics gifts and samples" on Taobao platform and found that there are thousands of shops selling gifts and samples, most of which are imported cosmetics with no obvious use period. How to label these products? After the promulgation of the "Measures", can it be sold normally as before? The customer service staff of one of the stores told the reporter that the products are still in normal sales and have not received the information that new packaging needs to be replaced.