Execution Pitfalls for Small and Medium-Sized Printing Plants Regarding the Four Mandatory Labeling Requirements for Cosmetic Packaging: Filing Number, Ingredients, Shelf Life, and Wording—A Mismatch in “Font Placement” Can Lead to Returned Goods

Last year, a skincare client in Hangzhou reached out to us. They had already printed 5000 labels for their serum bottles. All four required items—the filing number, ingredients, shelf life, and warning statements—were included, but the labels were rejected during a spot inspection by the market supervision authority because the filing number was printed in a smaller font than the product name. The client asked, “Everything is correct. Why was it rejected?” The answer is that Clause 7.1 of GB 5296.3-2008 states: “The font height of the filing number, product name, product batch number, production date and shelf life, or production batch number and date of minimum durability, shall not be less than 1.8 mm”—the printing plant missed this during prepress inspection.

The pitfalls in cosmetic labeling are not about whether information is provided, but whether it is provided and printed correctly. The practical execution traps that printing plants face with these 4 types of markings are even more subtle than GB 4806 food packaging testing.

Where exactly are the “printing execution standards” for the four types of markings?

The regulatory framework for cosmetic labels has 3 levels, and printers should conduct self-inspections level by level:

Regulatory framework: Regulations for the Supervision and Administration of Cosmetics (State Council Order No. 727 of 2020), Measures for the Administration of Cosmetic Labeling (SAMR Order No. 49 of 2021)

General Standards: GB 5296.3-2008 Instructions for Use of Consumer Products—General Labeling for Cosmetics; GB/T 29680-2013 Product standards for Facial Cleansers, Shampoos, Shampoo, etc.

Implementation: The four printing execution requirements specified in Articles 12-16 of the "Cosmetic Label Management Measures"—"visible surface, font height, contrast, and durability"—are what printing factories actually need to implement

Regulations and standards specify what must appear on the package, while the execution layer addresses how it is printed. The execution layer is the part most likely to be overlooked by printing plants, because it is buried in the detailed provisions of implementation methods and is not as immediately recognizable as a GB/T number.

Type 1: the "font-size position" trap in filing numbers

The filing number is the marking most likely to be overlooked on a cosmetic label. Common printing errors include placing the filing number at the bottom or on the side of the bottle rather than on the primary display panel; printing it in a font size smaller than the product name; and using light-colored ink on a light-colored background.

Article 12 of the "Administrative Measures for Cosmetic Labeling" provides:

The filing number must appear on the product's "visible surface" (the side of the sales packaging shown to consumers, not the bottom of the bottle or the inner wall)

The font size height shall not be less than 1.8 mm, and shall not be less than 1/2 of the font size of the product name

There must be a clear contrast with the background: use white text on dark backgrounds and black text on light backgrounds, with a contrast ratio of no less than 4.5:1

Printing Factory Self-Inspection Checklist:

Whether the filing number appears on the “main display surface” (the surface consumers see first)

Is the filing number font size ≥ 1.8 mm (measure the character height with a vernier caliper, not the text height)

Record number font size / Product name font size ≥ 0.5

Use light-colored ink on dark backgrounds and dark-colored ink on light backgrounds

Whether the registration number is obscured by any pattern or decorative element

For the 5000 labels for the Hangzhou customer above, the filing number was printed in 1.5 mm black text at the bottom of the bottle against a dark blue background, and all 3 inspection points were hit. Reprinting 5000 labels cost another 18,000 yuan and delayed shelf stocking by half a month.

Type 2: “Font and Ordering” Traps in the Full Ingredient List

The pitfalls in the ingredient list concern the order and fonts, not the content itself. Article 14 of the "Cosmetic Labeling Management Measures" states:

Ingredients must be listed in descending order of content. Ingredients with a content of less than 1% may be listed in any order after ingredients exceeding 1%

Ingredient names must use the standard Chinese names in the "Catalog of Cosmetic Ingredient Names" (2021 Edition); trade names may not be used

Font height must not be less than 1.5 mm (the registered value is 1.8 mm; the ingredient list is slightly smaller, but this is the minimum limit)

Preservatives, flavorings, and colorants must be labeled separately; the combined format “+ other minor ingredients” has been prohibited since the 2021 measures were issued

The most common mistake made by printing plants:

The customer’s product ingredient list mixes product names with INCI names, and the printing plant reproduced it without checking the “Cosmetic Ingredient Name Catalogue”—“hyaluronic acid” must be written as “sodium hyaluronate,” and “vitamin E” must be written as “tocopherol”

Minor components are not listed separately and are written as “+ other minor components”

Font height in the ingredient list: 1.2-1.4 mm (below the 1.5 mm minimum)

The colorant does not list a CI number (such as “CI 19140”), and is identified only as “yellow colorant”

Real-world case: A printing plant in Nanjing printed facial mask packaging for a client last year. In the ingredient list, “glycerin” was written as “propanetriol” (the commercial name), and the regulatory authority rejected the filing and required the plant to reprint 8,000 copies. Therefore, before printing cosmetics labels, a printing plant must obtain a comparison table based on the “Directory of Cosmetic Ingredient Names” from its client. This is essential expertise for cosmetics printing plants—although it is not a regulatory requirement, it is an industry convention.

Category 3: Pitfalls in How Shelf Life Is Labeled

There are 3 ways to label the shelf life, and products in different forms must use the corresponding method. Confusing them will result in the print job being rejected:

Product FormMandatory Labeling MethodCommon ErrorsShelf life ≥ 30 monthsMark the production batch number + period of use after opening (PAO symbol 6M / 12M, etc.)State both “Shelf life 3 years” + “PAO 12M”—the regulatory authority considers “3 years” misleading because the product must be used within 12 months after openingShelf life < 30 monthsMark the production date + shelf life, or production batch number + date of minimum durabilityOnly stating “Shelf life 24 months” without indicating the production date violates Article 13 of the Measures for the Administration of Cosmetic LabelingSingle-use products (face masks, makeup remover wipes, etc.)Mark the production date + expiration date, or production batch number + expiration date“Use within 24 hours after opening” is another way of expressing the PAO symbol and is non-compliant for single-use products

Printing Factory Self-Inspection Checklist:

Confirm the actual shelf life of the customer's product (check the product standards or filing records)

Choose the appropriate labeling method; do not let the customer write “anything works”—the regulatory authority will not accept that

Use “YYYY-MM-DD” or “YYYY/MM/DD” as the standard production date format. Do not use the plain numeric format “20260101”, as the regulatory authority will consider it “illegible”

The best-before date must be accurately calculated from the production date + shelf life; “see packaging” must not be used

The production batch number format is consistent with the production date (e.g., 「20260912A1」); do not use a combination of a date and numbers

Real case: A client of a skincare water manufacturer in the Suzhou Industrial Park had “Production date: 2026/01/01; Shelf life: 36 months” printed on the bottles, although the product’s actual shelf life was 24 months. The printing plant followed the data provided by the client, but a regulatory inspection found that the date after which the product must be used should have read “2028/01/01” but was printed as “2029/01/01.” Labels overstated the shelf life by 1 year and entered the market. The result was a recall and a fine of 120,000.

Category 4: Pitfalls in the “Placement and Typography” of Warning Statements

Warning statements are one of the most error-prone elements of cosmetics labeling, because their placement, font size, and contrast are subject to mandatory requirements, which vary by product category:

Children's cosmetics: The words "Children's cosmetics" must appear on the visible surface of the sales packaging, and the font height must be no less than 1.5 times that of the other marked text (excluding the product name)

Hair coloring, perming, freckle removal and whitening, sun protection, anti-hair loss, and products claiming “new efficacy”: must bear the “Special National Cosmetic Approval Number”

Special cosmetics (hair dye/perming/whitening/sunscreen/anti-hair loss/new efficacy claims): Must be labeled with the wording 「This product is a special cosmetic」

All products: Warnings such as "Avoid contact with eyes" and "Keep out of reach of children" must appear immediately adjacent to the product name or instructions for use

The most common mistake made by printing plants:

The wording “Children’s Cosmetics” on children’s cosmetics is in the same font size as the product name and is not enlarged by 1.5 times

The “National Cosmetic Special Approval” designation on special cosmetics is smaller than 1.8 mm

The warning statement “Avoid contact with eyes” is printed on the bottom or inner wall of the bottle, not on a visible surface of the retail packaging

Half of the warning statement is obscured by decorative patterns, which shall be deemed invalid labeling

Warnings shall be displayed in italics or a modified font, as determined by the regulatory authority to be “difficult to identify”

Real case: A printing factory in Shanghai printed cartons for a children's face cream client. The warning “Children must be used under adult supervision” was printed on the inner wall of the carton bottom, making it completely invisible to consumers on the shelf, and the cartons were rejected by the regulatory authority during random inspection. Correct practice: The warning must be printed on the primary or secondary display panel of the sales packaging (that is, one of the two largest visible surfaces of the carton), and must never be printed on the bottom or inner wall.

4-Step Printing Factory Self-Inspection Process

The 4 types of markings on cosmetic labels: follow these 4 steps during the printer’s self-inspection to avoid 90% of potential pitfalls:

Obtain the customer’s product registration documentation—registration number, ingredient list, shelf-life data, and approval document number for special cosmetics (if applicable). Do not rely solely on the customer’s verbal statements.

Check the ingredient list against the Catalogue of Cosmetic Ingredient Names—product names must be replaced with standard Chinese names

Four prepress proof measurements: Filing number/product name font size (measured with calipers), ingredient list font size (measured with calipers), contrast ratio (using a colorimeter or visual comparison with a color chart), and warning statement placement (photograph the unfolded box)

Post-print spot check of 5%-10%—Focus on verifying whether the filing number and warning statement are genuinely visible on the “visible surfaces”; do not rely solely on the design proof; inspect the actual printed product

LeXiang’s approach is to add “4 pre-print measurements + 10% post-print sampling” to all cosmetics label orders. This increases the unit cost by 0.05-0.10 yuan, but avoids reprinting losses of 10,000-20,000 yuan. This is the easiest way for small and medium-sized printing companies to “spend a little to save a lot” on cosmetics labels.

Further reading: 3 Types of Product Barcode Label Standards: EAN-13 / Code 128 / QR Code, 4 Compliance Pitfalls in Cosmetic Packaging Labels, 4 Practical Forms of Cosmetic QR Code Labels, 5 Regulatory Red Lines in Food Packaging Design.