On June 9, 2022, the Cosmetics Evaluation and Inspection Center of Beijing Municipal Medical Products Administration (MPA) released several FAQs pertaining to the cosmetics classification code in the Notification Application Form to help companies distinguish some confusing concepts and thereby avoid notification failures.

🆀: How to fill in the classification code in the Notification Application Form?

According to Paragraph 2 of Article 27 of the Provisions for Management of Cosmetic Registration and Notification Dossiers, the registrant and notifier shall determine the product category and the corresponding product classification code per the provisions of Cosmetic Supervision and Administration Regulation (CSAR) and Cosmetic Classification Rules and Catalogs (the Catalog). Where the special cosmetic efficacy claim is involved, it shall be registered as special cosmetics.

In addition, according to Article 10 of the Catalog, cosmetics containing two or more independent formulas that must be used together or whose packaging container cannot be separated shall be classified and coded as one product.

🆀: What application areas might be confusing in the classification code?

-“Head” and “Hair.” According to Annex Table, 2 Classification Catalog of Application Areas of the Catalog, hair dyeing and hair perming products can only apply to “Hair” as the application area; sun-screening products are not allowed to apply to “Hair”. In addition, the application area “Head” does not include the face.

Therefore, if a shampoo claims to “nourish the scalp and hair” on its label, then “04 Head” should be determined as the application area in the classification code of the Notification Application Form.

– “Face,” “Torso,” and “Total Skin.” According to Annex Table 2 Classification Catalog of Application Areas of the Catalog, the application area “Face” does not include lips and eyes; the application area “Torso” does not include head, face, hands, and feet; and the application area “Total Skin” does not include lips and eyes.

Therefore, if the use method in the product label is “smearing on the face and neck,” then the application area should be “03 Torso/05 Face” instead of “09 Total Skin”.

🆀: What is the difference between “Infants and Toddlers” and “Children” in the target groups in the classification code?

According to Annex Table 3 Classification Catalog of Use Populations of the Catalog, “Infants and Toddlers” are people aged three years and under; product efficacy claims involving such group are limited to cleaning, moisturizing, hair care, sun-screening, soothing, and body refreshing. “Children” are those between 3 and 12 years of age (including 12 years old), and product efficacy claims involving such group are limited to cleaning, makeup removing, moisturizing, beautifying and embellishing, perfuming, hair care, sun-screening, repairing, soothing, and body refreshing. Therefore, if a children cosmetic claims to have a “repairing” efficacy, its target users can only be “02 Children”.

🆀: Which product dosage forms are easily confused in the classification code?

-“Gel” and “Patch and Mask, Including Base Materials.” According to Annex Table 4 Classification Catalog of Product Dosages of the Catalog, “Gel” refers to gels, glues, etc. “Patch and Mask, Including Base Materials” refers to patches, masks, and base materials used in conjunction with cosmetics.

Therefore, if a sleeping mask is in a gel state and there is no film-forming step in the production process, the product dosage form should be “03 Gel” instead of “10 Patch and Mask, Including Base Materials”.

-“Spray” and “Aerosol.” According to Annex Table 4 Classification Catalog of Product Dosages of the Catalog, “Spray” does not contain propellants, while “Aerosol” contains propellants.

Therefore, if a spray’s product formula contains propellants such as propane, butane, etc., then the product dosage form should be “09 Aerosol”.

Reprinted from: ChemLinked

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