When developing and submitting children’s cosmetics for the Chinese market, companies often encounter practical questions. How should the safety assessment be prepared? Which ingredients require particular attention? How should the official Little Golden Shield mark be displayed on the product label?
To help companies better understand the applicable requirements, this article summarizes official Q&As published by China’s national and local regulatory authorities. It covers six key areas: product classification, ingredient selection, formula design, labeling, testing and safety assessment. Overseas companies preparing to place cosmetics on the Chinese market may also refer to REACH24H’s overview of China cosmetic product registration and notification requirements.
Need help interpreting China’s children’s cosmetics requirements for your product?
Product Classification and Permitted Claims for Children’s Cosmetics in China
What is the difference between “infants and young children” and “children” under China’s cosmetic classification system?
Under Appendix III of the Cosmetic Classification Rules and Classification Catalogue, the intended user groups are defined as follows:
Infants and young children: 0 to 3 years of age, including three-year-olds;
Children: 3 to 12 years of age, including 12-year-olds.
Cosmetics intended for infants and young children may only make claims relating to:
Cleansing;
Moisturizing;
Hair care;
Sun protection;
Soothing;
Body refreshing.
Cosmetics intended for children aged 3 to 12 may make claims relating to:
Cleansing;
Makeup removal;
Moisturizing;
Beautifying or decorative effects;
Fragrance;
Hair care;
Sun protection;
Repair;
Soothing;
Body refreshing.
The selected user group must therefore be consistent with the product’s efficacy claims. For example, where a children’s cosmetic makes a repair claim, the intended user group should be classified as “children” rather than “infants and young children.”
Is a bitter nail solution intended to discourage thumb-sucking classified as a general cosmetic?
Generally, no.
These products usually contain bitter substances, such as denatonium benzoate or bitter melon extract. The bitter taste is intended to discourage children from sucking their fingers and help them stop the habit.
As this intended purpose falls outside the legal definition of a cosmetic, this type of product should not be classified as a general cosmetic in China.
China Children’s Cosmetics Ingredient Restrictions and Selection Principles
What should companies consider when selecting ingredients for children’s cosmetics?
Ingredient selection for children’s cosmetics should follow three fundamental principles:
Safety first;
Efficacy necessity;
Formula minimalism.
Companies should pay particular attention to ingredients that are prohibited or not recommended for use in children’s cosmetics.
1. Ingredients that must not be used
New cosmetic ingredients under safety monitoring
Children’s cosmetics must not contain new cosmetic ingredients that remain within the statutory safety monitoring period.
Overseas ingredient manufacturers and cosmetic brands may refer to REACH24H’s overview of China new cosmetic ingredient registration and notification when assessing whether an ingredient has completed the required regulatory procedure.
Ingredients manufactured using genetic, nanotechnology or other new technologies
Ingredients manufactured using genetic technology, nanotechnology or other new technologies must not normally be used in children’s cosmetics.
Where no suitable alternative is available and the ingredient must be used, the product safety assessment materials should explain the reason. The supporting information should include, at a minimum:
An analysis demonstrating why the ingredient is essential to the formula;
An explanation of why other ingredients cannot provide an equivalent function;
Evidence showing that the ingredient is only available through genetic, nanotechnology or another new manufacturing technology;
A full assessment of its safety for use by children.
Where necessary, safety assessment test results should also be provided as supporting evidence.
Ingredients prohibited in cosmetics for children under three
Cosmetics whose intended users include infants and young children must not contain ingredients specifically prohibited for children under three under China’s Safety and Technical Standards for Cosmetics.
Examples include:
Iodopropynyl butylcarbamate, except in bath products and shampoos;
Salicylic acid and its salts, subject to the current shampoo exception;
Silver chloride deposited on titanium dioxide.
From January 1, 2028, salicylic acid and its salts will also no longer be permitted in shampoos intended for children under three.
2. Ingredients that are not recommended
Ingredients associated with specific safety risks
Ingredients presenting specific safety concerns, such as formaldehyde-releasing substances, are not recommended for use in children’s cosmetics.
Ingredients listed as prohibited substances in other countries or regions are also not recommended.
Where such an ingredient must be used, the company should explain the reason in the product safety assessment materials and conduct an adequate child-specific safety evaluation.
Ingredients associated with certain efficacy functions
Children’s cosmetics must not contain ingredients used primarily for the following purposes:
Freckle removal or whitening;
Acne treatment;
Hair removal;
Deodorizing;
Anti-dandruff;
Anti-hair-loss;
Hair dyeing;
Hair perming.
Where an ingredient capable of producing one of these effects is used for another technical purpose, the company should evaluate:
The necessity of using the ingredient;
Its safety when used in a children’s cosmetic.
Quaternary ammonium cationic surfactants
The use of quaternary ammonium cationic surfactants and similar ingredients is not recommended.
Where such ingredients are used, the company should provide a scientific analysis of their suitability and necessity. Human safety test data may also be required as supporting evidence.
China Children’s Cosmetics Formulation Requirements for Fragrances, Colorants, Preservatives and UV Filters
What requires particular attention when designing a children’s cosmetic formula?
Companies should pay particular attention to fragrances and perfume ingredients, colorants, preservatives, surfactants and UV filters.
China’s three formulation principles do not impose a fixed maximum number of ingredients. Instead, companies should evaluate the safety, stability, function, compatibility and necessity of each ingredient in light of children’s physiological characteristics.
1. Fragrances and perfume ingredients
The company should explain the scientific basis and necessity for the types and concentrations of fragrances and perfume ingredients used.
Where potentially allergenic fragrance components are present in the finished product at concentrations exceeding:
0.001% in leave-on products; or
0.01% in rinse-off products,
their safety for children should be fully assessed. The relevant fragrance components should also be declared on the product label.
2. Colorants
Where a formula contains four or more colorants, including exactly four, the company should explain the scientific basis and necessity for the types and concentrations used.
Relevant studies should be conducted to ensure that the product is safe under the intended conditions of use. Where necessary, human safety test data should also be submitted as supporting evidence.
3. Preservatives
Additional scientific evidence should be provided in either of the following circumstances:
A preservative in a leave-on product is used at 90% or more of the maximum permitted concentration under the Safety and Technical Standards for Cosmetics;
The formula contains five or more preservatives permitted under the standards.
The supporting evidence should explain why the selected preservative system and use concentrations are scientifically justified and necessary.
Where necessary, the company may provide:
Formula optimization research data;
Human safety test data for the final formula.
4. Surfactants
Quaternary ammonium cationic surfactants and similar ingredients are not recommended.
Where they are used, their scientific suitability and necessity should be analyzed. Human safety test data may be required where appropriate.
5. UV filters
In principle:
A formula should contain no more than five chemical UV filters;
Each chemical UV filter should be used below its maximum permitted concentration;
Where titanium dioxide and zinc oxide are used together, their combined concentration should not exceed 25% of the formula.
The scientific basis and necessity for the selected concentrations should be fully demonstrated where one or more of the following conditions apply:
The formula contains six or more chemical UV filters;
An individual chemical UV filter is used at 90% or more of its maximum permitted concentration;
The combined concentration of titanium dioxide and zinc oxide exceeds 25% of the formula.
Where necessary, formula optimization research data should be provided as supporting evidence.
China Children’s Cosmetics Labeling Requirements and the Little Golden Shield
What labeling information requires particular attention for children’s cosmetics?
Children’s cosmetics should comply with both the general cosmetic labeling requirements and the specific requirements applicable to products intended for infants and children.
The principal requirements are set out in the NMPA’s Provisions for the Supervision and Administration of Children’s Cosmetics and Announcement No. 143 of 2021 on the Children’s Cosmetics Mark.
1. The Little Golden Shield mark
The official children’s cosmetics mark, commonly known as the Little Golden Shield, should:
Use the pattern prescribed by the NMPA;
Be displayed proportionally;
Appear in the upper-left corner of an easily visible display panel on the sales packaging;
Be clear, prominent and easy to identify.
The presence of the mark identifies the product as a children’s cosmetic but does not represent regulatory approval or quality certification.
2. Adult supervision warning
The visible area of the sales packaging should include a warning introduced by wording equivalent to “Caution” or “Warning.”
The warning should state that the product should be used under adult supervision, or use wording with an equivalent meaning.
3. Declaration of potentially allergenic fragrance components
Where a fragrance or aromatic plant oil contains potentially allergenic fragrance components identified by authoritative Chinese or international organizations, the relevant components should be declared when their concentration in the finished product exceeds:
0.001% in a leave-on product;
0.01% in a rinse-off product.
The specific component names may be declared:
In the full ingredient list; or
Elsewhere on the product label.
4. Ingredient-specific conditions of use and warnings
Where required under the Safety and Technical Standards for Cosmetics, the applicable conditions of use and precautions should be printed on the label.
For example:
Products containing strontium chloride should carry a warning equivalent to “Not suitable for frequent use by children”;
Powder products intended for infants and young children that contain talc—hydrated magnesium silicate—should carry a warning instructing users to keep the powder away from the child’s nose and mouth.
5. Spray sunscreen warnings
The directions for use of spray sunscreen products should include warnings such as:
“Do not spray directly onto the face”;
“Spray onto the palm before applying to the face”;
“Avoid inhalation.”
Product Format Requirements for Children’s Cosmetics in China: Sprays, Makeup and Sunscreens
What should companies consider when selecting the product format or intended use scenario?
1. Requirements for spray and aerosol children’s cosmetics
Spray cosmetics are not recommended for children.
Where their use is necessary, the company should fully consider inhalation exposure and include appropriate directions, such as:
Do not spray directly onto the face;
Spray onto the palm before applying to the face;
Avoid inhalation.
Pressurized aerosols and other flammable products should also carry fire and explosion precautions in accordance with applicable Chinese regulations and technical standards. Graphic warnings may be used where appropriate.
2. Requirements for children’s makeup and makeup-removal products
For children’s cosmetics classified as makeup-removal or beautifying products, the intended use scenario should be clearly defined.
The product label should include instructions such as:
“Clean promptly after use”;
“Discontinue use immediately if discomfort occurs.”
3. Additional requirements for children’s sunscreen products
Children’s sunscreen products must not use claims that:
Encourage consumers to remain in the sun for extended periods;
Guarantee the sunscreen effect;
Present sun protection in absolute terms.
The requirements concerning sprays, makeup products and sunscreens are addressed together in the Guangzhou regulator’s official Q&A on children’s cosmetic formats and use scenarios.
Little Golden Shield Labeling Requirements for Children’s Toothpaste in China
How should the Little Golden Shield mark be displayed on children’s toothpaste?
Under the Provisions for the Supervision and Administration of Children’s Cosmetics and the NMPA announcement concerning the children’s cosmetics mark, the mark should:
Use the official pattern prescribed by the NMPA;
Be displayed proportionally;
Appear in the upper-left corner of the principal display panel;
Be clearly visible and easy to identify.
The children’s toothpaste mark should generally be gold. However, compliance with the precise color specifications provided in the NMPA announcement is not mandatory.
Companies may make minor adjustments to the color and font according to the packaging design, provided that the mark remains:
Clear;
Durable;
Easily recognizable;
Easy to read.
Where the surface area of the principal display panel exceeds 100 square centimeters, the widest part of the mark should be at least two centimeters.
Where the surface area is 100 square centimeters or less, the widest part of the mark should be at least one centimeter.
Does the Little Golden Shield indicate NMPA approval or safety certification?
No.
The Little Golden Shield is used to distinguish children’s cosmetics from adult cosmetics, disinfectants, toys and other products that may be easily confused with them.
Products that are not children’s cosmetics must not use this mark.
The presence of the Little Golden Shield only indicates that the product is presented as a children’s cosmetic. It does not mean that:
The product has obtained government approval;
The product has passed a government quality certification;
The regulatory authority endorses the product’s quality or safety.
Testing Requirements for Children’s Cosmetics Notification in China
What testing reports must be submitted for children’s cosmetics?
Under the Provisions for the Administration of Cosmetic Registration and Notification Dossiers and the NMPA measures concerning the optimization of general cosmetic notification testing, general cosmetics claimed for use by infants and children are not eligible for the exemption from submitting toxicological test reports.
The testing report must be issued by a qualified cosmetic registration and notification testing institution.
The cosmetic notifier or contract manufacturer may not replace the required report with a self-inspection report prepared according to the applicable cosmetic technical standards.
The Beijing Medical Products Administration explains these requirements in its official Q&A on children’s cosmetics notification dossiers. The NMPA government service portal also identifies products intended for infants and children as an exception to the toxicological testing exemption available to certain imported general cosmetics.
What results are required for toxicological testing of children’s cosmetics?
According to the Technical Guidelines for Children’s Cosmetics:
The acute eye irritation/corrosion test result should be non-irritating or mildly irritating;
A tear-free claim may only be made when the acute eye irritation test result is non-irritating;
The skin irritation/corrosion test result should be non-irritating;
The skin sensitization test conclusion should be non-sensitizing;
The skin phototoxicity test result should be non-phototoxic.
Where a product makes a tear-free, repair, soothing, gentle or other specific efficacy claim, its label should remain consistent with the relevant efficacy evidence. More information is available in REACH24H’s overview of China cosmetic efficacy claim evaluation requirements.
Should a pH range be established in the microbiological and physicochemical specifications?
In principle, a pH range should be established for children’s cosmetics, except for product forms for which pH cannot be measured.
The expected ranges are:
Leave-on products: pH 4.5–7.5, inclusive;
Rinse-off products: pH 4.5–8.5, inclusive.
A different pH range may be established when justified by factors such as:
The physiological characteristics of a specific application area, such as the infant diaper area;
Product characteristics;
Ingredient stability.
A scientific explanation and a full safety assessment should be provided when the proposed range falls into any of the following categories:
The lower limit is at least 3.5 but below 4.5;
The upper limit for a leave-on product is above 7.5 but no higher than 10.5;
The upper limit for a rinse-off product is above 8.5 but no higher than 10.5.
The detailed pH requirements are provided in the Beijing Medical Products Administration’s official children’s cosmetics technical Q&A.
Safety Assessment Requirements for Children’s Cosmetics in China
What should companies consider when conducting a safety assessment for children’s cosmetics?
Children’s cosmetic formulas should follow the principles of safety first, efficacy necessity and formula minimalism.The safety assessment should also reflect the physiological and behavioral characteristics of children.
Companies preparing China dossiers may refer to REACH24H’s dedicated service page on the China Cosmetic Safety Assessment Report.
1. Physiological differences
Compared with adults, children have:
A higher body-surface-area-to-body-weight ratio;
A less mature skin barrier;
Potentially higher absorption of chemical substances.
These characteristics should be considered when evaluating product exposure and safety.
2. Behavioral characteristics
The assessment should consider additional exposure arising from children’s behavior, including:
Sucking;
Hand-to-mouth contact;
Scratching;
Potential oral exposure.
3. Intended use scenarios
Special exposure conditions should be considered where the product is intended for use on particular areas, such as the diaper area.
In addition to the general ingredient and risk-substance assessment requirements, companies should pay attention to the following issues.
4. Propellants presenting inhalation toxicity risks
Propellants such as propane, butane and isobutane should be assessed for inhalation toxicity.
5. Aloe-derived ingredients
Where the formula contains Aloe barbadensis-derived ingredients, anthraquinones should be identified and assessed as potential risk substances.
The assessment may refer to conclusions issued by authoritative organizations.
6. Cocamidopropyl betaine
Where the formula contains cocamidopropyl betaine, the following associated substances should be identified and assessed:
Cocamidopropyl dimethylamine;
3,3-Dimethylaminopropylamine;
Monochloroacetic acid.
Applicable limits may refer to assessments issued by authoritative organizations or relevant Chinese standards.
7. Fragrances, plant essential oils and perfume ingredients
Where the formula contains fragrances, plant essential oils or perfume ingredients, potentially sensitizing components should be identified and assessed.
For example, where the formula contains Melaleuca alternifolia leaf oil, methyl eugenol should be identified and evaluated as a potential risk substance.
The applicable limit may refer to conclusions issued by authoritative organizations.
8. Glycerin
Where glycerin is used:
Its purity should be at least 95.0%;
Diethylene glycol should be identified and assessed;
The diethylene glycol content should not exceed 0.1%.
These child-specific exposure factors and risk-substance examples are taken from the Guangzhou regulator’s 2026 official Q&A on children’s cosmetic ingredient selection, formulation and safety assessment.
Official Regulatory References for China Children’s Cosmetics
The requirements summarized in this article are based primarily on the following official sources:
NMPA — Provisions for the Supervision and Administration of Children’s Cosmetics
NMPA — Announcement No. 143 of 2021 on the Children’s Cosmetics Mark
Guangdong Evaluation and Certification Center — Toothpaste Notification Q&A
Beijing MPA — Q&A on Imported Children’s Cosmetics and Technical Requirements
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