Packaging Certification

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”

📅 2026-10-17 ✍️ Wuxi Lexiang Printing & Packaging ⏱ 3min read

💡 💡 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:

  • Small font + reversed type: Although the font size is set to 1.8mm, reversed type (white text against a dark background) is often identified as "smaller than 1.8mm" in regulatory inspection sample photos because of edge feathering on the reversed type. Regulatory assessment is based on the "height of legible strokes" rather than the "font size."
  • Mixed letters/numbers and Chinese characters: Filing numbers are usually in the form of “National Cosmetic Approval Number XXXXXXXX,” a combination of Chinese characters and letters. The actual height of the letters may be 10-15% shorter than that of the Chinese characters—the print shop should raise the letters separately by 0.1-0.2mm during typesetting.
  • Multi-line version: When the filing number appears together with multiple lines such as "Cosmetics Production License Number" and "Product Execution Standard Number," the printing plant must verify the font size of each line individually and cannot scale the entire layout using PS.
  • 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:

  • Densitometer: Measures the difference in reflectance between white paper and ink, then converts it to the Weber contrast formula
  • Visual inspection + grayscale printing: Print a black-and-white copy of the color artwork. If the registration number characters almost blend into the background under grayscale printing, the measured contrast will definitely fail to meet the 4.5:1 requirement.
  • 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:

  • Inside of the box: The filing number should be printed on the inside of the gift box lid or in the footer of the instruction manual. Most brand owners believe that “the outer box has been contaminated, while the inside is cleaner,” but drug regulators require that “consumers can see the identifier on the main display without opening the package,” so printing it on the inside does not meet the requirement.
  • Curved/Cylindrical Bottle Body: The registration number is printed on the curved surface of the bottle, and the curvature causes a loss in the text’s horizontal height—the characters on some essential oil bottles and lip gloss tubes are almost “distorted along the curve.”
  • Embossing / Foil Stamping Bottom: The registration number is located at the very bottom of the embossed foil stamping and is obscured by the raised effect created by the thickness of the gold foil/embossing.
  • Color separation plate joins: On the box dieline, the registration number happens to fall near the dividing line of the cutting die layout (within 1.5mm of the cutting line), so there is a chance that the character edges will be cut during box cutting
  • 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:

  • White text overprinted on a gold hot-stamped background: Many premium cosmetics packaging designs use large-area hot stamping as the background, with the filing number overprinted in white on top of the gold stamping. The result looks attractive, but measured contrast reaches only 3:1. Because gold stamping has a high reflectance rate, the "halo" around the white text makes the characters disappear.
  • Spot-color text (Pantone metallic): Using Pantone metallic ink for the registration number, the measured contrast is often below 4:1—differences in the angle at which metallic ink reflects light blur the edges of the characters
  • Transparent ink (varnish/UV spot application): Apply a UV spot varnish over the registration number; the refractive effect of the transparent varnish layer will make the characters appear “blurred”—therefore, the printer must test and compare contrast after UV varnishing during proofing, rather than measuring the characters without varnish
  • Black Text Overprinting a Spot-Gold Background: For the registered text, black is used, while the background is spot gold (or gold spot-color overprinting). The “flat black” of black text against a gold background looks jarring and prints poorly—many printing plants have found that this color combination cannot produce a perfect “rich black” on a 4-color printing press
  • 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:

  • Font Size Check: For foil stamping, embossing, curved surfaces, or reversed-out text, add +0.4mm. The measured stroke height does not count toward the PS font size.
  • Contrast Check: Dual verification using a densitometer and black-and-white grayscale printing. If it fails 4.5:1, the brand must be notified immediately
  • Placement check: Must not be placed within 1.5mm of the inner edges / cutting lines of the box / on curved surfaces with a curvature of > 15° / in areas partially covered by PVC/UV
  • Color Scheme Check: Gold stamping + reversed-out lettering / Pantone metallic colors / transparent gloss varnish overlay / gold overprint on a black background—these 4 categories are proactively marked as "measured below 4.5:1" and require written confirmation from the brand before proceeding
  • 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:

  • Add a separate line item in the quotation for "pre-review of filing number placement/font size/contrast", turning this from a "free obligation" into a "quotable service" that both reminds the brand owner and gives the printer time to conduct a substantive review
  • List the filing number field separately on the sample approval form: require separate signatures from the brand’s procurement, legal, and filing personnel, rather than including it in the overall approval form—distributing the signing responsibility among the brand’s internal departments
  • Measured Contrast Ratio Report Archiving: Archive one set of measured contrast ratio data (spectrophotometer screenshot) for each cosmetics order and retain it for 3 years, so that evidence is available when required by regulatory authorities or courts
  • 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

  • Cosmetic Labeling Standards for 4 Types of Information: Ingredients / Shelf Life / Batch Number / Directions for Use—The Batch Number Is Most Likely to Be Illegible, a Common Printing Pitfall
  • Cosmetics Packaging PAO Symbol Printing: 3 Real-World Cases Penalized for Insufficient 6mm Height
  • Cosmetic Packaging Advertising Law: 4 Categories of Prohibited Terms in Practice—3 Real Cases of Penalties for "Discovering It Only After Printing at the Printer's Office"
  • Three Types of Regulatory Requirements for Printing Cosmetic Filing Numbers on Packaging
  • #cosmetics packaging #NMPA filing number #font size 1.8mm #contrast 4.5:1 #layout boundaries #cosmetics labels

    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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