Moisturizing Claims in China: What You Need to Know to Ensure Compliance and Success

 

Having regard to the Regulation on the Supervision and Administration of Cosmetics, it requires to choose efficacy claims in the process of registration and notification of cosmetic products. Meanwhile, substantiation shall be submitted to evaluate and support these efficacy claims.

As an important basis for the administration of cosmetics, the Classification Rules and Catalog of Cosmetics has carried out a detailed classification of cosmetics efficacy,i.e. 26+x efficacy claim categories (Table 1).

Table 1: 26+X Efficacy Claims

A New efficacy	01 Hair dye	02 Hair perm	03 Whitening and spot removing
04 Sunscreen	05 Anti-hair loss	06 Anti-acne	07 Nourishing
08 Repairing	09 Cleaning	10 Makeup Remover	11 Moisturizing
12 Beautifying	13 Perfume	14 Deodorization	15 Anti-wrinkle
16 Firming	17 Soothing	18 Oil-control	19 Exfoliating
20 Body refreshing	21 Hair care	22 Anti-hair break	23 Anti-dandruff
24 Hair color care	25 Depilation	26 Pre-shave

Among these 26+X efficacy claims, moisturizing is one of the most common efficacy claimed by registrants/notifiers. This article provides guidance on what expressions can be used to claim moisturizing and what scientific evidence is required to substantiate moisturizing claims.

As is defined in the Classification Rules and Catalog of Cosmetics, moisturizing refers to the function of supplementing or enhancing the water, oil, and other component contents of the applied area; it helps to maintain the water content of the applied area or reduce water loss. Therefore, as long as the claim is made around this definition, it is within the scope of compliance. For instance, expressions such as "moisture", "hydration", "relieve dryness" and related ones are allowed to be used for moisturizing claims.

Pursuant to the Classification Rules and Catalog of Cosmetics, four types of substantiation can be utilized to evaluate efficacy claims, namely, human trial, consumer use test, laboratory test, literature review or data analysis (Table 2). Claims related to moisturizing can be supported by any of the four types of substantiation.

However, if you want to highlight the moisturizing property of products to attract consumers and use quantitative numbers, such as all-day moisturizing, 12-hour long-lasting moisturizing, etc, validation of the claims requires the selection of one of the three listed types of substantiation: human trial, consumer use test, laboratory test.

Table 2: Types of Substantiation Required for Efficacy Claims

Cosmetics Category	Efficacy Claims	Required Substantiation
Special Cosmetics	Hair-dye, hair-perm	Exemption
	Whitening and freckle removal, anti-hair loss, sun protection	Human trial
	Other new efficacy	It depends on efficacy claims.
General Cosmetics	Anti-acne, nourishing, repairing	Human trial
	Exfoliating, oil-control, soothing, tightening, anti-wrinkle, anti-dandruff, hair-breakage prevention, claims of gentleness (no stimulation), claims of  quantitative indication	Human trial/consumer use test/laboratory test (at least choose one of the three); A literature review or data analysis can be provided to substantiate the claims.
	Hair care, moisturizing, specific claims (the efficacy of ingredients)	Human trial/consumer use test/laboratory test/literature review or data analysis (at least choose one of the four)
	Specific claims (suitable for sensitive skin, tear-free formula)	Human trial/consumer use test (at least choose one of the two)

Note: Not all products are required to submit substantiation for efficacy claims.

With regard to the Standard for the Evaluation of Efficacy Claims of Cosmetics, the following efficacy claims, with clear clarification for the use of physical methods to achieve the efficacy on the label,  can be exempted from submitting substantiation:

A. Efficacy claims can be directly recognized by senses, such as vision and smell, e.g. cleansing, make-up removing, beautifying, perfume, body refreshing, hair perm, hair dye, hair-care, deodorant, assisted shaving.

B. Efficacy claims are achieved through simple and physical covering, attachment, friction, etc., for example, physical covering of freckles, physical exfoliation, physical removal of blackheads, etc.

As one of the leading compliance companies in China, ZMUni provides professional review for efficacy claims, which assists you to navigate compliantly in the Chinese market.