Cosmetic Packaging NMPA Registration Number / Filing Number Printing: 4 Type Layout Boundaries: 1.8mm Font Size / 4.5:1 Contrast Ratio — Printers Most Commonly Fail at “Reverse Type”
💡 💡 At a Glance
When printing NMPA filing numbers/registration numbers on cosmetic packaging, printing plants most often stumble over three common pitfalls: “the specified character height is 1.8mm, but the actual discernible strokes are less than 1.8mm”; “knockout text printed over a gold hot-stamping ground has a contrast ratio of only 3:1”; and “the filing number is placed on the inside of the carton or on a curved bottle body.” This article explains the four checks that cosmetic printing plants must proactively complete from four dimensions—character height, contrast, placement, and color—and provides practical recommendations.
The NMPA registration or filing number on cosmetics packaging is a mandatory labeling requirement under the Cosmetics Supervision and Administration Regulation (2020). However, for printing companies, it is more “sensitive” than ordinary text: if any of these 4 dimensions—font size, contrast, placement, or color—falls short, the product may be rejected when the brand takes it to the drug administration authority for re-examination, yet responsibility often falls on the printing company. The contract will usually state that the printing company “shall print according to the approved artwork,” but the phrase that procurement staff fear most is: “The printing company failed to check this for us.”
In 2024, a local makeup brand in Wuxi received a corrective action notice from the drug regulatory authority. The reason was that the NMPA filing number on the product’s outer packaging had been printed in a “skin tone” color similar to the background, making the lettering almost impossible to read when the regulator photographed and enlarged it during a spot inspection. The brand blamed the issue on the printing factory, which produced a sample approval form confirming the design. The brand’s procurement representative pointed to the clause stating “produce according to the approved sample,” but the factory was ultimately held 30% responsible because “the printing factory is a professional and should have warned us that this color combination would be difficult to read against this background.”
These are the frequently encountered pitfalls when cosmetic printing plants in 2024-2025 receive orders requiring NMPA filing numbers or registration numbers. This article does not discuss regulatory details (that is not the printing plant’s job), but focuses on the four checks that cosmetic printing plants must proactively perform across four dimensions—layout, font size, contrast, and color—when receiving design files from cosmetic brand owners.
1. Character Size: 1.8mm Is the Minimum, but What the Printing Factory Cares About Is Not "Character Size"
The hard requirement for the character height of cosmetic filing/registration numbers is “no less than 1.8mm”—a unified requirement under the Cosmetic Label Management Measures (2021). However, the printer’s job is not simply to print the text at 1.8mm; there are 3 hidden considerations during actual operation:
In actual orders, a font size of 1.8mm may result in an inadequate visual effect with hot stamping and embossing. The hot-stamping layer is 0.05-0.08mm thick, so properly stamped characters may appear slightly “shorter.” The maximum embossing depth is 0.3mm; if the impression reaches the bottom and creates a depression, the effective character height loses another 0.15-0.25mm. When encountering either of these processes, the printer should increase the font size to 2.2-2.5mm to ensure a satisfactory result.
II. Contrast Ratio: 4.5:1 Is the National Standard Requirement, but Printers Must Calculate the "Measured Value"
The contrast requirements for cosmetic labels are 4.5:1 for normal type and 7:1 for small type, as specified in GB/T 19305. Upon receipt of the design file, the printing plant must not rely on the color differences displayed on the designer’s screen and must conduct actual measurements:
Brand designers often see two color schemes that look consistent on a MacBook, yet achieve only around 3:1 on printed materials—this is determined by the difference between the display gamut and the CMYK printing gamut. The print shop must use at least two tools for actual measurements:
A domestic brand used "gold ink printed on a light beige background" for its 2024 registration number. The designer believed that "gold lettering is darker than the beige background," but the measured contrast ratio was only 2.8:1. Regulatory sampling determined that the "labeling was unclear," and the brand was required to make corrections. The printing factory was blamed again for having "failed to proactively provide guidance."
III. Locations: Printing plants should focus on 4 types of frequently recurring non-compliant areas
The placement requirements for cosmetics filing numbers/registration numbers may appear simple ("prominent location"), but among cases returned by the drug administration authorities during random inspections in 2024-2025, there are 4 types of frequently occurring placement violations:
In 2024, a contract printing factory in Wuxi had 80,000 units returned by a customer. The root cause was that the brand's design placed the registration number in a “window” position, where the transparent PVC film covering the window obscured the registration number, leaving consumers able to see only the glare on the PVC and no registration number at all.
IV. Colors: The “Reverse White” and “Gold” Pitfalls Prone to Cause Problems at the Printing Plant
When a cosmetics package goes to print, color options are limited (white text on dark backgrounds, dark text on light backgrounds), but there are 4 pitfalls that the industry repeatedly falls into:
5. Four Checks Requested Proactively by the Printing Plant
Based on the above 4 types of boundaries, there are 4 checks that cosmetic printing plants should proactively perform when receiving packaging orders for products with filing numbers or registration numbers:
VI. Practical Recommendations for Procurement Managers/Bosses of Cosmetic Printing Plants
For cosmetics NMPA filing numbers/registration numbers, 80% of the compliance risks cannot be deflected with the procedural explanation that “the printing factory produced according to the approved proof,” because although the Cosmetics Supervision and Administration Regulations state that “the printing party bears direct responsibility where the identification is unclear,” this is not a mandatory provision; nevertheless, when a sample is rejected by the drug regulatory authority, brands often shift responsibility to the printing factory.
In practice, 3 things can directly help printing plants reduce risks:
The cosmetics filing number may look like a minor matter of "printing a few characters" on the package, but behind the 1.8mm figure lies a comprehensive balancing act involving four dimensions: font size, contrast, placement, and color. When a printing plant receives a cosmetics order, taking the initiative to check once more is far more valuable than simply saying, "We'll print according to the approved artwork."
Further Reading
FAQ
Must the NMPA filing number on cosmetics packaging be printed? Can the printer refuse?
Both the Cosmetics Supervision and Administration Regulations (2020) and the Cosmetics Label Management Measures (2021) mandate that the filing / registration number appears on the sales packaging and must be in a "conspicuous position on the main panel." The printer cannot "refuse to print" — but it can proactively pre-review layout, font size, and contrast at the proofing stage, blocking non-compliant designs before production.
If the filing number uses hot foil stamping, how should the printer calculate font size for compliance?
The hot foil layer thickness is 0.05–0.08mm, plus minor character distortion at the edges. Industry experience is to set the PS font size to 2.2–2.5mm for stability — the theoretical 1.8mm is enough, but hot foil's actual effect often only yields about 1.7mm, which will be judged non-compliant under the drug administration's "legible stroke height" criterion.
When the filing number is reverse-knocked out on a gold foil substrate, what number does the measured contrast typically stall at?
Under the measured Weber contrast formula, reverse knockout characters on a gold foil substrate typically only reach 2.8–3.2:1, falling short of the 4.5:1 national standard requirement — the gold foil's high reflectivity causes a "halo effect" on the knockout characters that eats into the strokes, and 60–70% of drug administration samples reject this layout.
When the printer discovers a layout issue with the filing number, how should it communicate with the brand owner without damaging the relationship?
Three steps: ① Produce a measured contrast report using a densitometer; ② Mark the specific position + regulatory basis (GB/T 19305 / Cosmetics Label Management Measures); ③ Provide the brand owner with 2–3 modification options for them to choose — this is easier to accept than simply saying "this position won't work," and both the brand owner's design and legal teams can sign off.
When the cosmetics filing number is rejected by drug administration sampling, what is the typical responsibility split for the printer?
If the contract only states "printed according to the confirmed draft," industry practice splits it as printer 20–40% + brand owner 60–80%; if the contract states "printer bears layout compliance review responsibility," the printer may take 50–70%. It is recommended that the printer list a separate line item "filing number layout pre-review" in the quotation, turning review into a billable service and using the service fee to diversify compliance risk.
The customer's filing number font size is set to 1.5mm by the designer — can the printer simply enlarge it to 1.8mm?
No. The printerwithout authorization enlarging the font size will disrupt the overall layout, and the brand owner may pursue liability on the grounds of "printerwithout authorization changed the draft." The correct approach is: the printer proposes "based on measured process recommendation, 2.2mm," and requires the brand owner to re-sign and confirm the revised version before producing to that version — this is also the key step for documentation and evidence preservation.
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