Home / Guides / Are “antibacterial,” “sterile” or “disinfectant” claims allowed on cosmetics exported to China?

Guide

Are “antibacterial,” “sterile” or “disinfectant” claims allowed on cosmetics exported to China?

“Antibacterial,” “sterile” and “disinfectant” claims are generally not acceptable ways to describe a cosmetic exported to China. Cosmetics are not products whose purpose is to treat disease, and several ordinary efficacies expressly exclude products that work by killing or inhibiting microorganisms—including certain deodorant and anti-acne definitions. A product whose intended use is disinfection belongs to other regulatory regimes, not to ordinary cosmetics filing or special-cosmetics registration.

How to judge the path

Cleaning that removes dirt is a cosmetic function. Killing bacteria as the selling purpose is not the same thing.

“Sterile packaged” manufacturing language, if used at all, should not be turned into a consumer claim that the product sterilizes skin. Follow the labelling and claim rules in force rather than copying hospital marketing.

Typical documents, tests and labels

If you want to remain on the cosmetic path, rewrite the intended use and claims so they are truly cosmetic, and make sure the formula story matches. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform.

Cautions

See deodorant, anti-acne products and the cosmetic–drug or disinfectant border.

Questions we are often asked

Can I say “helps keep skin clean” instead?

Cleaning is a listed cosmetic efficacy when it refers to removing dirt or residue. Do not use that phrase to smuggle a disinfectant purpose onto the label.

Are hand-sanitizing gels cosmetics?

Products whose purpose is to disinfect hands are not assessed as ordinary cosmetic cleansers or moisturizers. Do not file them as cosmetics to obtain a faster timeline.

Next step

Discuss your China market path

Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.

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