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Guide
What evaluation is needed for SPF, PA or water-resistant claims
A cosmetic that claims SPF, PA or water resistance is a sunscreen special cosmetic and must be registered. The labelled values or grades should be supported by the corresponding sunscreen-efficacy evaluation. The methods and pass criteria follow the Safety and Technical Standards for Cosmetics, the Efficacy Claim Evaluation Standard and the inspection requirements for sunscreen registration. The ordinary-filing cycle of about 10–20 days does not apply.
What each claim requires
SPF and PA should each be evaluated by the specified methods before the corresponding number or grade is printed. A water-resistant or similarly durable or water-proof statement needs a water-resistance evaluation; it cannot be added only because the formula “looks water resistant.” Adding PA, broad-spectrum or post-bathing SPF information later is a claim or label change and should be supported by the corresponding efficacy reports required by the dossier rules.
Timing
For sunscreen products we describe toxicology as about 35 working days, SPF and PA as about 30 working days each, and review as about 10–12 months after testing is finished. Actual time depends on completeness and supplementary requests. Children’s sunscreens also have to meet children’s cosmetics requirements.
Cautions
Do not print an SPF on an ordinary moisturizer filing. Test protocols and sample requirements should follow the technical standards and inspection rules then in force.
Questions we are often asked
Can we display SPF from an overseas test report?
Registration inspection and evaluation should meet Chinese technical standards and inspection rules. An overseas report may be useful background, but it does not automatically replace the required Chinese evaluation.
Is “sweat resistant” the same as water resistant?
Use the wording that the evaluation method actually supports. Do not invent a stronger water-resistance claim than the study covers.
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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