Can’t we notify/register products without permitted preservatives in them?

Along with people’s growing demand for becoming beautiful, the demand for skincare products is gradually diversified. For sensitive skin consumers, low-irritation skincare products have definitely become their first choice. Due to this situation, lots of cosmetic enterprises begin launching products with non-chemical preservative.

Since we posted"“Turn pale at the mention of preservatives”? Don’t be that way! (", many cosmetic enterprises from home and abroad came to consult us with various questions. In response to Frequently Asked Questions from those enterprises, the answers are organized by ZMUni as follows:


Q: Is it necessary to add in the products the permitted preservatives prescribed in Safety and Technical Standards for Cosmetics(STSC)?

A: There is no mandatory requirement in STSC for cosmetics that they must use the permitted preservatives in STSC. Cosmetic enterprise can keep products from deteriorating through other preservative technology, they may not add permitted preservatives.


Q: If the products don’t add the permitted preservatives prescribed in STSC but add plant preservative ingredients, can we notify/register the products?

A: According to Article 6 of CSAR, cosmetic registrants, notifiers claim responsibility for quality safety and efficacy claims of cosmetics. Combine the answers to Question 1, as long as cosmetic enterprises could ensure the quality safety of the product and provide scientific, reasonable preservative challenging test report and stability test report as well, the product can be notified/registered. It is worth noting that purpose of use of the plant preservative ingredient can’t be preservative.


Q: Are there any requirements for preservative challenging test and stability test? Must these tests be done in designated labs in China?

A: In regard to preservative challenging test and stability test, currently there is no regulation basis or guidelines guiding the enterprises to do the tests. Enterprises may conduct the tests in accordance with industry standards or test method from other countries. It’s Okay when the test process and test result are true, scientific and reasonable.

There is no requirement for preservative challenging test and stability test to be performed in designated laboratories in China, and enterprises can choose their own test institutions according to their own circumstances. (Note: When test report from abroad is submitted for notification/registration, the report shall be translated into standard simplified Chinese.)


ZMUni Chinese Cosmetic Regulation Compliance Centre 中贸合规中心

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