Regulation & Compliance FAQ

Yes, but regulation is tightening and requirements differ significantly by market. The single most important rule is that cosmetic talc must be confirmed free of asbestos, a baseline shared by all major markets.

China's Safety and Technical Standards for Cosmetics explicitly requires cosmetic talc to be asbestos-free, supported by test reports from the raw material supplier. The EU has revised its talc restrictions several times in recent years, with additional requirements for powders used in the perineal area, and the US FDA is advancing related testing guidance.

For products intended for export or multi-market filing, prepare two tracks: keep the talc version with complete asbestos test reports, and have a substitution option ready using mica, boron nitride or starch-based powders.

Yes, but powder spray formats that could be inhaled are effectively excluded. The EU restriction logic for nano TiO2 and nano ZnO centres on inhalation risk, not dermal application.

That means creams, liquid foundations and pressed powders that do not form inhalable aerosols remain usable provided concentration and labelling requirements are met, while spray sunscreens and spray powders containing nano TiO2 or ZnO face strict limits.

Two practical checks: confirm the nano status of the raw material and whether the finished product's use pattern could generate an inhalable aerosol. If you export spray sunscreens to the EU, consider switching to non-nano grades or changing the dosage form.

China's Safety and Technical Standards for Cosmetics sets limits of lead at or below 10 mg/kg, arsenic at or below 2 mg/kg, mercury at or below 1 mg/kg and cadmium at or below 5 mg/kg. These apply to finished products, while raw materials are usually controlled to tighter internal specifications.

Because mineral powders are naturally sourced, lead and arsenic deserve the most attention. Mica, talc and kaolin from different deposits have very different impurity profiles, so a stable raw material source matters more than single-batch testing.

The practical approach is to require a certificate of analysis for every batch, keep third-party test reports on file, and run type testing on finished products per the standard. For export, compare against the destination market as EU limits are stricter for some metals.

Three categories matter most: composition and regulatory compliance statements, safety assessment support data, and explicit nano labelling.

For composition, provide full INCI names, CAS numbers and a statement on compliance with the restricted and prohibited lists in EC 1223/2009. For safety, the EU requires a Cosmetic Product Safety Report prepared by a qualified safety assessor, and raw materials must supply supporting toxicological data. If the material contains nanoscale particles, this must be declared on the label and in documentation.

Also account for REACH SVHC screening, SCIP database notification obligations and packaging recycling labelling. These are not powder-specific, but they come up on every shipment.

The core principles for children's cosmetics are simplified formulas, safe ingredients and controlled use scenarios. At the powder level that translates into fewer unnecessary colorants, avoiding inhalable powder formats and tighter microbiological control.

China's regulation on supervision and administration of children's cosmetics requires safety-first formulation, only necessary efficacy claims and minimal formulas, along with a dedicated child safety assessment. Powders with debated profiles, such as talc and nanomaterials, warrant extra caution in these products.

For baby powder type products, inhalability is the primary concern and many markets already discourage loose powder formats in infant products. Define the use scenario during formula assessment rather than judging raw material compliance in isolation.

Yes, but the focus differs from liquid raw materials. Powders have low water activity, so microbial proliferation is limited and risk comes mainly from cross-contamination during production and recontamination after packaging.

Routine tests cover total aerobic count, total yeast and mould count, and specified pathogens such as Staphylococcus aureus, Pseudomonas aeruginosa and coliforms. Acceptance criteria follow the relevant standard for the intended use and finished product type.

Control measures matter more than end-product testing: production area cleanliness, equipment and packaging sanitation, and finished-product water activity. Relying on final testing alone usually means discovering a problem too late.

Always work from the English INCI name. Chinese names are reference translations, mismatches are normal, and you should never derive the INCI from the Chinese name.

There is no single official Chinese naming standard, so one INCI such as Silica appears as 二氧化硅, 硅石 or 无定形二氧化硅 across different documents, and 高岭土 corresponds to Kaolin rather than Kaolin Clay. Regulatory filings, product labels and customs declarations all key off the English INCI; Chinese names are for consumer-facing copy only.

Three reliable sources: the EU CosIng database, which is free and carries the official INCI list with function categories; the PCPC INCI dictionary; and the INCI stated on your supplier COA or TDS. If a supplier document omits the INCI, ask for it — any reputable raw material supplier should provide it.

One common trap: blends and surface-treated powders need the full INCI. Silica treated with triethoxycaprylylsilane must be declared as both Silica and Triethoxycaprylylsilane, listed in descending order of content. Declaring only Silica is incomplete.

Powder suppliers generally cover three categories: basic quality documents, regulatory compliance statements, and third-party test reports. Not every grade has all of them, so confirm before you order.

Basic quality documents are COA per batch with measured values, TDS with typical properties, and MSDS/SDS in 16 sections to GB/T 16483 or REACH format. Regulatory statements include REACH SVHC declarations, RoHS statements, conformity to the Chinese Safety and Technical Standards for Cosmetics, and for some customers an EU 1223/2009 compliance statement. Third-party reports commonly cover heavy metals such as Pb, As, Hg and Cd, microbiology, asbestos for talc, and particle size distribution for certain grades.

Asbestos deserves special attention. For talc an internal asbestos-free statement is usually not enough — international customers typically require a third-party report to ISO 22262-1 or NIOSH 9002 that is traceable to the batch. A one-line declaration rarely satisfies EU or US buyers.

By product type, talc carries the strictest documentation burden, mica and silica come next, and boron nitride and kaolin are comparatively simple. Put the documentation list into your technical agreement at the purchasing stage; retrofitting it later is far more painful.