Evaluation of Cosmetic Efficacy Claims

I. Core Responsibilities and Procedures

At the time of registration or notification, cosmetic registrants and notifiers must upload a summary of the basis for product efficacy claims to the specialized website designated by the National Medical Products Administration (NMPA). The registrant or notifier is responsible for the scientific validity, authenticity, reliability, and traceability of the submitted summary.

Cosmetic efficacy claims must be supported by sufficient scientific evidence. This evidence includes scientific literature, research data, or the results of cosmetic efficacy evaluation tests. The methods used for evaluation must be scientific, reasonable, and feasible, and they must fulfill the purpose of the evaluation.

Registrants and notifiers may conduct the evaluations themselves or entrust an evaluation balanced with appropriate capabilities to follow the requirements listed in Table 1. A summary of the efficacy claim basis will then be prepared and published based on the evaluation conclusions.

II. Specific Evaluation Requirements by Category

• Moisturizing and Hair Care: Products claiming only these effects can be evaluated through literature reviews, research data analysis, or efficacy evaluation tests.
• Anti-wrinkle, Firming, Soothing, Oil-control, Exfoliating, Anti-breakage, and Anti-dandruff: These products, as well as those claiming to be “mild” (e.g., non-irritating) or using quantitative indicators (e.g., duration of effect, statistical data), must be evaluated through efficacy evaluation tests. Literature or research data can be used as supplementary support.
• Spot-clearing/Whitening, Sunscreen, Anti-hair loss, Anti-acne, Nourishing, and Repairing: These must be evaluated through human efficacy evaluation tests.
• Special Requirements for Spot-clearing, Sunscreen, and Anti-hair loss: Tests for these three categories must be conducted by a designated cosmetic registration and notification testing agency in accordance with mandatory national standards and technical specifications.
• Specific Claims (e.g., “Suitable for Sensitive Skin” or “Tear-free Formula”): These must be evaluated through human efficacy evaluation tests or consumer use tests.
• Ingredient-based Claims: If a product claim is based on the efficacy of a specific ingredient, research or testing must confirm that the ingredient possesses said efficacy, and there must be a clear correlation between the ingredient’s function and the final product’s claim.

Table 1: Requirements for Cosmetic Efficacy Claim Evaluation

No.	Efficacy Claim	Human Efficacy Test	Consumer Use Test	Lab Test	Literature or Research Data
1	Spot-clearing & Whitening ①	√
2	Sunscreen	√
3	Anti-hair loss	√
4	Anti-acne	√
5	Nourishing ②	√
6	Repairing ②	√
7	Anti-wrinkle	*	*	*	△
8	Firming	*	*	*	△
9	Soothing	*	*	*	△
10	Oil-control	*	*	*	△
11	Exfoliating	*	*	*	△
12	Anti-breakage	*	*	*	△
13	Anti-dandruff	*	*	*	△
14	Moisturizing	*	*	*	*
15	Hair Care	*	*	*	*
16	Specific Claims (Sensitive skin, Tear-free)	*	*
17	Specific Claims (Ingredient efficacy)	*	*	*	*
18	Claims of “Mild” (Non-irritating)	*	*	*	△
19	Claims with Quantitative Indicators	*	*	*	△
20	New Efficacy Claims	Choose appropriate evidence based on the specific claim.

Key:

• √: Mandatory item.
• *: Optional item (at least one from this group must be selected).
• △: Supplementary item (must be used in combination with a human test, consumer test, or lab test).

Notes:

① If the whitening effect is achieved only through physical covering and is clearly labeled as such, the submission of evaluation data may be exempted.

② If the claim applies only to the hair (not the scalp), evaluation can be performed using in vitro real hair.