Home / Guides / If a product claims both SPF and whitening, which category applies
Guide
If a product claims both SPF and whitening, which category applies
If a product claims both sun protection and whitening or spot-removal, it remains a special cosmetic and must be registered. Both uses are listed in the Cosmetics Supervision and Administration Regulation. You should prepare classification codes, tests, efficacy evaluation and labels that cover both claims, rather than choosing the “faster” category or filing the product as an ordinary cosmetic.
How to judge the combination
SPF, PA, broad-spectrum or waterproof statements call for sunscreen evaluation. Whitening or spot-removal statements call for the corresponding human efficacy evaluation. A claim that works only by physically covering spots is not the same evaluation as whitening and should not be written as if it were. Children’s products that combine these claims must also meet children’s cosmetics rules.
What to prepare and how long it takes
Plan both sets of tests. Sunscreen toxicology is about 35 working days and SPF and PA about 30 working days each, with review about 10–12 months after testing. Whitening human efficacy method I is about 6 months and method II about 8 months, with review about 12 months after testing. A combination product usually follows the longer testing path and the special-cosmetics review path. The overall calendar depends on completeness and supplementary requests. The 10–20 day ordinary-filing cycle does not apply.
Cautions
Do not run only sunscreen tests and then print a whitening claim, or the reverse. Online pages must not add the missing half of the pair after registration.
Questions we are often asked
Can we register first as sunscreen and add whitening later?
Adding a whitening claim later is a change to a special cosmetic’s claims and evidence, not a small label decoration. Plan both claims before submission if both will appear on the pack.
Does physical coverage let us skip whitening human tests?
A claim that only covers spots physically is assessed differently from whitening or spot-removal. Do not mix the two wordings to avoid a study.
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.
Contact us