How to correct a non-compliant Chinese product name

A non-compliant Chinese product name is not fixed by a homophone or a new main visual. The Cosmetics Labeling Rules generally require a Chinese name to be composed of a trademark name, a generic name and an attribute name. The name must not suggest a medical effect or use letters, pinyin, numbers or symbols except in allowed cases such as a registered trademark, an SPF value, a shade number or a series number. If the product is already filed, the name should not be changed without a proper reason; a justified change should be submitted before the renamed product is listed.

Published 11 November 2026 · Updated 11 November 2026

How the three parts work

The trademark name must not claim a medical effect or an efficacy the product does not have. If it hints that a class of ingredient is present, explain the purpose when the formula contains that ingredient, or state that the wording is only a trademark when it does not. The generic name may describe an ingredient, a use or a site of application, but it must match the product. Letters, pinyin, numbers and symbols should not be used for naming except where the rules allow, and a trademark that uses them should be explained on the visible panel.

What to do if the name is already filed

Submission through the platform completes ordinary filing. A wrong name usually cannot be treated as if it were never submitted. Prepare a name-change file with reasons under the dossier provisions. If the formula has also changed enough to create a new product, file again rather than only renaming.

Cautions

It is more stable to correct the name before the first submission than to change it later. The new name must stay consistent with the label, the standard and online listings.

Questions we are often asked

Can we keep English letters if they are part of our global brand?

A registered trademark that uses letters may appear, but the rules require the meaning to be explained on the visible panel. The rest of the Chinese name should still meet the naming structure.

Is adding “cream” enough to fix a name that claims a medical effect?

No. Removing or rewriting the non-compliant part is what matters, not adding an attribute name while leaving a medical suggestion in place.