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Guide
What happens if the label, packaging and product standard do not match
Inconsistencies among the label artwork, the printed sales packaging and the product executive standard are a frequent reason for correction. Ordinary filing is completed on submission, but if later review finds that the materials do not meet requirements, the authority may order correction within a specified time and, where safety is involved, may also order a pause in sale or use. The result is the same for the brand: the public information cannot proceed smoothly until the file is aligned.
What must line up
The dossier provisions require the method of use, safety warnings, storage conditions and period of use on the label artwork to match the product executive standard. Pictures of the sales packaging should not go beyond what the artwork states. The full ingredient list, the labelled ingredient list and the actual formula should correspond. Consumers rely on the pack to understand use and risk, so a warning that exists only in the standard, or a claim that exists only on the box, is a problem.
How to avoid it
Freeze the executive standard and the label artwork before final packaging design. Compare use directions, warnings, storage and shelf-life statements word for word. Then compare the printed pack with the artwork uploaded to the system.
Cautions
Packaging is often finished last, which is why mismatches appear. Correct them before submission when you can. After filing, use the change process rather than quietly reprinting a different warning.
Questions we are often asked
Is this only an ordinary-filing problem?
No. Special cosmetics also have to keep the registered label, the uploaded sales images and the standard consistent, including the registration number on the pack.
What if only the font size is wrong?
Some labelling defects that do not affect safety or mislead consumers may be handled under the lighter provisions of the Labeling Rules, but that is not a reason to submit a file you already know is inconsistent.
Next step
Discuss your China market path
Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.
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