Clean Beauty Compliance - Regulatory Environment in China

 

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 What is Clean Beauty?

While the clean beauty concept originated in Western markets, it has gained significant traction in China as well. This is driven by several factors - rising awareness of ingredients' safety and environmental impact, demand for natural and organic components, and concerns over issues like pollution and animal testing. Brands that can meet this demand gain an edge.

Nonetheless, the concept of "clean beauty" does not have an official definition in China, nor is there a universally accepted standard internationally. However, with the rising popularity of clean beauty products, standards or guidelines formulated by associates are beginning to emerge, such as ISO 16128  issued by the International Organization for Standardization in the EU and the Cosmetics - Clean Beauty General Principles published by Guangdong Cosmetics Association in China.

ISO 16128 does not specifically define clean beauty, but it establishes criteria for the calculation and labeling of natural and organic content in cosmetics.

In the Cosmetics - Clean Beauty General Principles, clean beauty products refer to cosmetics where the entire product lifecycle complies with transparency, traceability, responsibility for human health and safety, environmental friendliness, cruelty-free policies, and undertaking humanitarian and social responsibilities. Furthermore, clean beauty requires risk control across the entire cosmetics process, from design and production to final disposal, including stages such as design, manufacturing, packaging, storage, transportation, usage, and more. 

As it is defined in a beauty journal, Amelies, clean beauty is a term used to describe products made with ingredients that are safe for humans and the environment. It also stands for transparency about sourcing and manufacturing practices. Clean beauty products avoid using harmful chemicals, such as parabens, phthalates, and sulfates and tend to use natural and organic ingredients wherever possible. More often than not, their packaging often takes sustainability into consideration.

The official definition of clean beauty may vary depending on different organizations or brands, but it generally involves avoiding harmful chemicals, artificial fragrances, parabens, sulfates, and other potentially harmful substances. Clean beauty products are often cruelty-free, sustainable, and promote overall well-being.

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What Ingredients Are Allowed to be Used in Clean Beauty Products in China?

Clean beauty products may incorporate ingredients from approved positive lists and avoid substances on negative lists. In China, the key references are:

Positive Lists

- Inventory of Existing Cosmetic Ingredients in China (IECIC) 2021 lists 8,965 permitted ingredients.

 

Negative Lists

- Safety and Technical Standards for Cosmetics lists prohibited and restricted Ingredients in China.

- EU Cosmetic Regulations

- Health Canada's Cosmetic Ingredient Hotlist

- IFRA Banned Fragrance Materials

- Known carcinogens

- Environmental contaminants like microplastics

- CITES Appendices for endangered species

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When selecting clean beauty ingredients, manufacturers should cross-check substances against these latest negative lists to avoid prohibited components. Formulating with non-toxic, biodegradable, natural ingredients from approved sources supports clean beauty claims. Traceability, ethical sourcing and exclusion of allergens or irritants are also advised. While clean beauty lacks a legal definition in China, compliance with national and global prohibited substances lists is an important starting point. Brands can further eliminate controversial synthetics and emphasize plant, mineral, or other natural ingredients to align with consumer perceptions of clean beauty.

 

Accepted Certification * EWG – The Non-Toxic Certification * Made Safe- Non-toxic Certification * Clean ICADA - Approved ingredients certification * The Credo - Safe ingredient certification * Natrue - Natural and organic cosmetic products Certification

 

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What are the Criteria for Clean Beauty?

While there is currently no official definition or national standard for clean beauty products in China, several common concepts are associated with the category:

- Product safety, mildness, and non-irritating

- Natural, naturally-derived or organic ingredients

- Cruelty-free (no animal testing)

- Green, sustainable practices

 

Brands making clean beauty claims in China should be aware of relevant regulations and how to substantiate certain attributes.

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How to Ensure Product Safety and Make Claims on Mildness and Non-irritation?

Brands should implement robust quality management systems, adhere to safety regulations, perform clinical and consumer testing, and analyze results to reliably demonstrate cosmetic products are safe, mild and non-irritating. Making claims without proper substantiation risks regulatory and consumer backlash.  

Purpose	Measure
Ensure Product Safety	Establish a quality management system and
	Adhere to requirements in Safety and Technical Standards for Cosmetics
Make Claims on Mildness and Non-irritation	Human patch testing: 30 test subjects showing grade 0 reactions (no skin response) confirms the product is non-irritating.
	Consumer usage testing: After ** weeks of use, **% of respondents agreed this product is mild/non-irritating."

 

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How to Make Claims of Natural/Naturally Derived/Organic Compliantly in China?

Per ISO 16128, natural ingredients are obtained from plants, animals, microorganisms or minerals, using processes like physical methods, natural fermentation, traditional solvent extraction, etc.

Brands making natural cosmetic claims should source certified ingredients whenever possible. Adding some natural components without full certification does not justify “all-natural” product claims - this risks being deemed false advertising.

Globally, COSMOS and USDA Organic certifications apply to cosmetics. In China, the organic certification framework does not currently include cosmetics.

Accepted Certification * USDA Organic – The Organic Certification for Ingredients * Cosmos – Organic and Natural Cosmetics Certification * Non-GMO Project – Label for Non-GMO Ingredients

 

 

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How to Enter the Chinese Market Cruelty-Free?

Previously, China required all cosmetic products to conduct animal testing. However, after the Measures on the Administration of Registration and Notification Dossier of Cosmetics came into force as of May 2021, animal testing can be exempted under certain conditions.

Conditions for Animal Exemption in China
A	It is general cosmetics.
B	Manufacturers have obtained a certificate issued by the government to prove their qualification to produce qualified products, such as Good Manufacturing Practices.
C	The safety assessment results can substantiate the safety of products.
D	It does not involve New Cosmetic Ingredients.
E	It is not intended for kids or infants.
F	Domestic responsible persons, notifiers, and manufacturers of products have no bad records in China.

As for cosmetic products that can not be exempted from animal testing, some alternative testing methods can be adopted to substantiate the safety of cosmetics. Table 2 lists officially permitted alternatives to animal testing in China.

Alternatives to Animal Testing Permitted in China
Testing	Application Field	Testing Purpose	Does it involve animals?
In vitro 3T3 NRU phototoxicity test	Cosmetic ingredients	To assess the phototoxicity of cosmetic ingredients	No
Short Time Exposure In Vitro Test Method (STE)	Cosmetic ingredients	To assess the eye irritation of cosmetic ingredients	No
In Chemico Skin Sensitisation: Direct Peptide Reactivity Assay (DPRA)	Cosmetic ingredients	To assess the skin sensitization of cosmetic ingredients	No
Bacterial Reverse Mutation Assay	Cosmetic ingredients or products	To assess the gene mutation of Cosmetic ingredients or products	No
In Vitro Mammalian Cells Chromosome Aberration Test	Cosmetic ingredients or products	To assess the mutagenicity o Cosmetic ingredients or products	No
In Vitro Mammalian Cell Gene Mutation Test	Cosmetic ingredients or products	To assess the mutagenicity o Cosmetic ingredients or products	No
In Vitro Mammalian Cells Micronucleus Test	Cosmetic ingredients or products	To assess the mutagenicity o Cosmetic ingredients or products	No

 

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How to Make Claims on Green/Sustainable?

Here are some ways cosmetic brands can substantiate "green" and "sustainable" claims in China:

1. Avoid excessive packaging

China's upcoming regulations on Restricting Excessive Packaging for Food and Cosmetics, effective September 2023, evaluate this based on void volume, number of layers, and cost. The formula is: Packaging Cost / Product Sales Price ≤ 20%

 

2. Use biodegradable materials

Opt for 100% biodegradable paper boxes, formulas with >90% naturally biodegradable ingredients.

 

3. Incorporate recyclable packaging

Use recycling symbols, FSC - Sustainability Beauty Certification

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4. Conduct life cycle assessments

Quantify environmental impacts across the product lifecycle including sourcing, manufacturing, logistics, consumer use and disposal.

 

From renewable energy to ethical sourcing policies, brands should embed sustainability in their business. Communicating green attributes through trusted labels, implementing recognized best practices, and minimizing environmental footprints allows cosmetic brands to credibly make sustainable claims in China's eco-conscious market.

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While there is currently no official definition or set standards for clean beauty in China or internationally, cosmetics that are responsible for human health and safety, environmentally friendly, cruelty-free, and uphold humanitarian and social accountability represent a major trend.

As such, cosmetic companies and relevant stakeholders should consider the entire product lifecycle when designing clean beauty items - from ingredients, formulas, packaging to manufacturing. There should be transparency and traceability at every stage.

Brands also need to understand which standards to comply with and which certifications to obtain in order to make legitimate clean beauty claims in the Chinese market.

While still an emerging niche, clean beauty resonates with Chinese consumers concerned about health, social responsibility and environmental impacts. Brands that genuinely embrace clean beauty's ethos throughout the product lifecycle, without resorting to greenwashing, are poised for success in this rapidly evolving landscape.

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