Details of the Implementation of the 2025 Cosmetic Labeling Regulations: 3 Key Areas — Claims and Marketing Language / Fragrance Labeling / Transition Period for the "Golden Shield" Symbol

In April this year, a cosmetics contract manufacturer in Hangzhou with annual revenue of 80 million printed an entire new packaging series for its anti-wrinkle product line. Before the products were filled and launched, they were selected for inspection by the market regulation authority. Three SKUs were ruled noncompliant because of the words “anti-wrinkle.” Although “anti-wrinkle” is not included in the list of prohibited terms in Annex 1 of the Measures for the Administration of Cosmetic Labeling, it directly conflicts with the “prohibition of implied therapeutic effects” standard set forth in Announcement No. 46 of 2021 issued by the State Administration for Market Regulation. The entire batch of 18,000 sets had to be reworked, and the printing plant was also required to compensate approximately 46,000 yuan in plate-making fees (calculated at a plate-making fee of 2.6 yuan per set).

After the 2025 revised Administrative Measures for Cosmetic Labeling came into effect, the most common yet easily overlooked pitfall in the cosmetic packaging and printing process lies in the fact that the prohibited-claims list is only the “baseline,” while 27 additional categories of therapeutic-implying terms remain outside that “baseline” and constitute “danger zones.” If the printing factory does not involve the client in reviewing the design draft, problems often surface at the last minute. A Hangzhou contract manufacturer conducted a post-project review and found that the design draft contained a list of 14 efficacy descriptors, four of which—“anti-wrinkle,” “plump and moisturized,” “intense hydration,” and “firming and lifting”—fell within the danger zones. If the prepress review had followed these criteria, the client could have made the changes during the design stage rather than having to redo the work after printing. Revising the draft takes 2-3 days, whereas rework takes 12-15 days—a cost difference of more than 6 times.

Category 1: The three terms “prohibited” and “prohibition by implication”

Article 12 of the "Measures for the Administration of Cosmetic Labels" explicitly lists a prohibited list, including "special efficacy, all-in-one, powerful efficacy, miraculous efficacy, rapid efficacy, miraculous effect, spot removal, acne removal, slimming, face slimming, dandruff removal, hair growth, hair loss prevention, hair loss cessation, breast enhancement, breast enlargement, body slimming, body beautification, repair, revitalization, wrinkle smoothing, scar removal, scar elimination, stretch mark removal, anti-wrinkle, anti-allergy, anti-inflammatory, antibacterial, bacteriostatic, sterilization, disinfection, detoxification, purification, energizing, refreshing, endocrine regulation, hormone regulation, improvement of skin elasticity, improvement of visible capillaries, improvement of skin allergies, lightening of hyperpigmentation, dark circle removal, visible capillary removal, red blood stain removal, and dark circle removal" — a total of 47 terms — but this is only the "blacklist."

Most pitfalls in practice involve “implied” claims, such as “anti-aging,” “age reversal,” “frozen age,” “revitalization,” “renewal,” “skin rejuvenation,” “reactivation,” “age defense,” “youthful appearance,” “elasticity and firmness,” “firming and lifting,” “plumpness and hydration,” “high moisture retention,” “deep hydration,” “24-hour moisture lock,” “overnight rescue,” “sensitive skin rescue,” and “pregnancy skin rescue,” along with similar terms. Since 2025, the State Administration for Market Regulation has found such terms to be violations in multiple spot inspections by classifying them as “implying therapeutic efficacy.” Even when such terms are not included on the prohibited list, they remain in violation.

When a printing plant receives a packaging design for cosmetics, it should first conduct a two-way check of the “prohibited list” and the “implied claims list” during pre-press review. A common practice is to extract all adjectives in the customer’s original design that “appear to describe product benefits” and check each one against regulatory requirements. In typical customer-submitted designs, 30%-40% of these adjectives fall within regulatory red zones and require the wording to be revised.

Category 2: The number of flavor allergen labels increases from 26 to 80

In addition to the new label rules introduced in 2025 under the Administrative Measures for Cosmetic Labeling, China has issued a set of Rules for the Labeling of Cosmetic Ingredients. The most significant change is the expansion of allergen disclosure from the original 26 allergens to 80. Of these 80, nearly 54 are new additions—including α-isomethyl ionone, benzyl alcohol, benzyl salicylate, and other substances—alongside existing allergens such as linalool, citronellol, geraniol, citral, and cinnamal.

In practice, a common pitfall for printing plants is that the customer-provided ingredient list is an outdated version from 2023, and the print run made from it is subsequently judged noncompliant under the new regulations. There are three remediation options at different cost levels: ① apply a self-adhesive allergen label (approximately 0.08-0.15 yuan/set, suitable for already printed inventory); ② reprint and replace the entire updated version (suitable for unprinted inventory); or ③ reserve print space for allergen labeling during the design stage of the new version (suitable for new products). The costs of these three options vary substantially, and customers often discover only during the remediation stage that the printing plant lacks the necessary technical capabilities.

After the allergen list expanded to 80 items, the plate layout occupied 25%-30% more space than it did with 26 items. If the customer’s original artwork did not reserve space for this section, the cost of making corrections would be far higher than expected. A cosmetics contract manufacturer in Zhejiang conducted a test in May, squeezing 80 allergens into an ingredient panel originally 8mm high. The font size was reduced to 1.2mm, and the label was immediately judged by regulators as “difficult to identify.” In the end, they had to switch to a new version, at more than 3 times the cost of the self-adhesive label solution.

Category III: The Little Golden Shield label expands from “Children’s Cosmetics” to “Hair Coloring and Perming”

The Little Golden Shield mark was originally introduced in 2021 specifically for children's cosmetics—a gold shield bearing the silhouette of a black child. The 2025 revised guidelines expanded the use of this mark to certain hair-dyeing and hair-perming products: whenever the formulation contains “hair dye” or “hair perm” ingredients, the mark must appear on the sales packaging.

A common pitfall for printing plants is that the customer’s design file does not reserve space for the Small Golden Shield. It is not until the printing stage that they discover a shield-shaped label needs to be applied, requiring the file to be revised and the layout to be rearranged. A complete layout adjustment takes 5-7 working days, or more than 15 days during the peak season.

Practical recommendation: For all hair coloring, perming, and setting cosmetics, the prepress review must confirm whether space of 8mm × 10mm or more has been reserved for the Small Golden Shield. If not, we recommend returning the design for revision rather than forcing it in. Forcing it in will distort the layout, and the brand’s dissatisfaction will be worse than a delay.

Further Reading