I. Core Testing Items
1. Safety Testing (Most Critical)
- Microbial Contamination Testing:
Tests total bacterial count, total mold and yeast count, and pathogenic bacteria (such as Staphylococcus aureus, Pseudomonas aeruginosa, Escherichia coli, etc.). Excessive microorganisms may cause skin infections and inflammation (e.g., folliculitis, pustules).
Example: Skincare products (especially toners and lotions) are prone to bacterial growth; infant and children's cosmetics have stricter microbial requirements. - Heavy Metal and Harmful Element Testing:
Key tests include lead, mercury, arsenic, cadmium, chromium, etc. Excessive heavy metals can accumulate through skin absorption; long-term use may damage the nervous system and kidneys, or lead to skin hyperpigmentation and increased cancer risk.
Note: China expressly prohibits the addition of mercury in cosmetics (illegal addition as a whitening ingredient is relatively common); lead and arsenic have strict limits (e.g., lead ≤10 mg/kg). - Prohibited/Restricted Ingredient Testing:
Prohibited Ingredients: Such as glucocorticoids (long-term use leads to steroid-dependent dermatitis), antibiotics (such as chloramphenicol, metronidazole, which may cause drug resistance), hydroquinone (illegal whitening ingredient, highly corrosive), fluorescent whitening agents, etc.
Restricted Ingredients: Such as preservatives (phenoxyethanol, parabens), sunscreen agents (such as oxybenzone, homosalate), hair dyes (such as p-phenylenediamine), etc. Testing is required to verify whether their content complies with specified limits (e.g., total preservatives typically ≤1%).
- Irritation and Sensitization Testing:
Certain products must undergo human skin patch testing (similar to 'patch tests') or animal alternative testing (such as in vitro skin irritation models) to assess whether they may cause allergic or irritant reactions.
2. Efficacy Testing (For Products with Claimed Efficacy)
Human Efficacy Trials: Such as moisturizing tests (measuring skin moisture content), whitening tests (measuring melanin content), sunscreen tests (SPF value, PA value), anti-wrinkle tests (skin texture changes), etc.
Laboratory In Vitro Testing: Efficacy is assessed through cell models, 3D skin models, etc. (such as antioxidant capacity, collagen synthesis capacity).
Literature or Data Support: Published scientific literature must be provided to demonstrate the correlation between ingredients and claimed efficacy.
3. Physicochemical Property Testing
Basic indicators: pH value (to avoid excessive acidity/alkalinity that may irritate skin; e.g., skincare product pH is typically close to the skin's slightly acidic environment at 5.5-7.0), viscosity, stability (high/low temperature cycling tests to prevent separation and degradation), odor, color, etc.
Specific ingredient content: such as whether the actual content of active ingredients (e.g., vitamin C, niacinamide) is consistent with claimed amounts, to avoid 'false labeling.'
4. Label and Compliance Testing
Verify whether product labels meet requirements: such as whether the ingredient list is complete (sorted by 'INCI name'), whether prohibited/restricted ingredients are indicated, shelf life, batch number, whether efficacy claims are compliant (medical claims such as 'treats eczema' are not permitted), etc.
II. Applicable Standards and Regulations
- Domestic Standards:
Core basis: 'Cosmetic Safety Technical Specification' (2015 Edition, currently in effect), which stipulates prohibited/restricted ingredient lists, contaminant limits, testing methods, etc.
Regulatory framework: 'Cosmetic Supervision and Administration Regulation' (implemented in 2021), 'Cosmetic Registration and Filing Management Measures,' etc., requiring testing to be completed and filing/registration before market launch.
Specific standards: such as GB/T 35916-2018 (Sunscreen Cosmetic Testing), QB/T 1645-2013 (Facial Cleanser), and other industry standards.
- International Standards:
Exported products must comply with target market standards, such as the EU (EC 1223/2009 Regulation), the United States (FDA cosmetic regulatory requirements), Japan (Pharmaceutical Affairs Law), etc. Their prohibited/restricted ingredient lists and testing items may be more stringent (e.g., the EU prohibits over 1,300 ingredients, far more than domestic regulations).
III. Testing Procedure
- Sample Collection:
Enterprise submission: Before market launch, commission a testing institution and provide product samples and formulation information;
Regulatory sampling: Market supervision authorities randomly select products on sale to ensure representativeness.
- Sample Preparation:
Samples undergo extraction and purification (e.g., removal of matrix interference) to facilitate instrumental analysis (e.g., heavy metals must be digested into solution form). - Laboratory Testing:
Professional instrumental analysis is employed, such as: Heavy metals: Inductively Coupled Plasma Mass Spectrometry (ICP-MS), Atomic Absorption Spectroscopy (AAS);
Prohibited/restricted ingredients: High-Performance Liquid Chromatography (HPLC), Gas Chromatography-Mass Spectrometry (GC-MS);
Microorganisms: Culture method (plate counting).
- Result Determination and Reporting:
Compare against standard limits to determine compliance, and issue a test report (must indicate testing institution credentials, such as CMA certification).
IV. Common Testing Types
Pre-market Testing: Enterprise-initiated or commissioned testing for product registration/filing (e.g., special cosmetics require registration, ordinary cosmetics require filing).
Supervisory Sampling Inspection: Regulatory authorities (such as the Market Supervision Administration) conduct random inspections of products in the distribution market; non-compliant products are recalled, removed from shelves, and penalized.
Third-Party Rights Protection Testing: Consumers who suspect product issues (such as allergic reactions after use) may commission testing by a qualified institution as evidence for rights protection.
V. Considerations
Testing Institution Credentials: Select institutions with CMA (China Metrology Accreditation) credentials; their reports carry legal validity (credentials can be verified on the official website of the 'Certification and Accreditation Administration of China').
Cost and Timeline: Depending on the number of testing items, costs range from several hundred to tens of thousands of yuan (e.g., a full safety testing package costs approximately several thousand yuan, while efficacy testing is more expensive), with a typical turnaround of 1-4 weeks.
Standard Differences: Standards vary across different countries/regions; exported products require targeted testing (e.g., the EU prohibits formaldehyde-releasing preservatives, while some are permitted domestically).
Authenticity of Efficacy Claims: Since 2024, China has strictly regulated cosmetic efficacy claims; 'exaggerated advertising' (such as 'whiten in three days') may result in substantial fines. Testing is the core means of verifying claims.