Some cosmetic toys for children, like kids' dressers that include eye shadow, powder blush, lipstick and nail polish, are very popular in the market now. In fact, many of them are produced by toy manufacturers and can only be used to do make-up for dolls. They are not under the regulation of cosmetics. Therefore, there are some potential safety hazards for children to misuse such toys as cosmetics.

1. It's necessary to accurately distinguish between cosmetics and toys.   

Cosmetics and toys are two different types of products. They are regulated in accordance with different laws and regulations as well as different measures and requirements. According to the Regulations on Supervision and Administration of Cosmetics, cosmetics refer to the products of the chemical industry for daily use, designed to be applied by spreading, spraying or other similar ways to the surfaces of human body, such as skin, hair, nails, and lips, for the purpose of cleaning, protecting, beautifying and putting on make-up. In short, the products applied to the human body surface are cosmetics, which should be regulated in accordance with the laws and regulations of cosmetics. Products only applied to toys such as dolls are not cosmetics and should be regulated in accordance with the laws and regulations of toys or other products. If a product meets the definition of cosmetics, whether it is sold alone or together with other products such as toys, it is categorized as cosmetics.

2. Children's cosmetics are subject to the most stringent regulations in China.

According to the Regulations on Supervision and Administration of Cosmetics, cosmetics, as health-related products, are regulated stringently in China. In September 2021, the National Medical Products Administration (NMPA) issued the Provisions on the Supervision and Administration of Children's Cosmetics, which put forward stricter regulatory requirements than the regulations on cosmetics for adults. Manufacturers of cosmetics shall obtain a cosmetics manufacturing license. The environment of the factories where children's cosmetics with skincare functions are produced shall comply with the relevant provisions of the Good Manufacturing Practice for Cosmetics. Before the cosmetics go on the market, a report on technical details, including the product formula, test report and safety assessment data, should be submitted as required. They can be sold on the market only after registration or filing. The formula design of children's cosmetics shall follow the principle of "safety as priority, efficacy as necessity and formula minimization" and should undergo safety evaluation through related assessments and necessary toxicological tests. The use of ingredients and the limit of microorganisms and harmful substances in the final products shall meet the requirements of the technical specifications for safety of cosmetics. In addition, post-market regulation on safety of cosmetics, including sampling and testing, adverse reaction monitoring and risk monitoring, will also be carried out.

3. Infants and young children under three years old should not use "make-up".

According to the classification standards and catalogue of cosmetics issued by the NMPA, the efficacy claims of cosmetics used by children aged three to 12 can include beautification, modification and make-up removal, while those of cosmetics used by infants and young children aged zero to three are limited to cleaning, moisturizing, hair care, sunscreen, soothing and refreshing. In other words, cosmetics used by infants and young children under the age of three do not include "make-up". Therefore, it is illegal if a label of make-up claims that infants and young children under the age of three can use the product.

Unlike adults, children under 12 years old, especially infants and young children under three years old, have immature skin barrier functions. Their skin is more sensitive to the stimulation of external substances and more vulnerable to damage. Lipstick, powder blusher and other products manufactured in accordance with general standards for toys may contain substances that should not be used as cosmetic ingredients, such as colorants with relatively high safety risks. They may irritate children's skin. In addition, such "make-up toys" may contain excessive heavy metals, such as lead. Excessive amount of lead, if absorbed, can damage multiple systems of the body, for example, it may affect children's intellectual development.

Therefore, it should be noted that the label of children's cosmetics should be marked with full composition of the product. Domestic cosmetics should be marked with cosmetics manufacturing license number. Special cosmetics should be marked with special cosmetics registration certificate number. Imported cosmetics should have Chinese labels. The NMPA has released the mark of children's cosmetics — "gold shield". From May 1, 2022, all children's cosmetics applying for registration or filing should be marked with a "gold shield". Children's cosmetics that have previously applied for registration or filing should be marked with a "gold shield" before May 1, 2023. Please look for the mark when purchasing children's cosmetics.