We have collected the latest FAQs on ordinary cosmetics filing from the Guangzhou Administration for Market Regulation and translated them into English for your reference.

1. Are products such as bitter nail polish, designed to deter children from thumb-sucking, classified as ordinary cosmetics?

Bitter nail polish typically contains bitter substances such as denatonium benzoate or bitter melon extract, which taste bitter when children suck their fingers, thus discouraging the habit. The purpose of this kind of product goes beyond the definition of cosmetics and cannot be classified as ordinary cosmetics.

2. Are products that use dihydroxyacetone to adjust skin color and cover white spots considered ordinary cosmetics?

Dihydroxyacetone (DHA) is an active ingredient used in sunless tanning products. The ketone functional group in DHA reacts with the amino groups in skin keratin to form brown polymers, resulting in a darkening effect. Products that adjust skin color and cover white spots through this mechanism do not classify as ordinary cosmetics.

3. Can silver nitrate be used in hair products?

According to the "Safety and Technical Standards for Cosmetics" in China, silver nitrate is limited to use in "eyelash and eyebrow dye products". Therefore, it is prohibited in hair products.

Some hair products on the market contain silver nitrate and dye the hair black by utilizing the photosensitive properties of silver ions. The use of silver nitrate as hair dyes goes beyond the permissible range of hair dyes for cosmetics.

4. What precautions should be taken when using products with nebulizers or sprayers?

(1) It is necessary to ensure that the method of use complies with the definition of cosmetics. After being atomized by the device, the product should act on the skin, hair, nails, lips, or other external parts of the human body. If the product acts on the body through inhalation after atomization, it does not fall under the category of cosmetic use.

(2) Ensure that the registration management system indicates whether the product is marked as "to be used with devices".

(3) In the safety assessment, evaluate the safety of using the product with devices or tools. Provide documentation on whether these devices or tools have cosmetic functions, participate in the re-manufacturing process, or alter the mechanism of interaction between the product and the skin.

(4) Assess whether there is a potential for inhalation exposure. For products with potential inhalation risks, conduct a safety evaluation of their inhalation toxicity.

5. What should be pay attention regarding target users in cosmetic labeling?

Labels such as "suitable for all ages", "for the whole family", "for teenagers", "for students", or using trademarks, images, homophones, letters, Pinyin, numbers, symbols, or packaging that imply the product is suitable for children should be managed as children's cosmetics.

For ordinary cosmetics labeled with "use with caution during pregnancy and breastfeeding", which do not exclude the possibility of use by pregnant or breastfeeding women, the safety warning should be more explicit, such as stating "not for use during pregnancy and breastfeeding".

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