3 Easiest Compliance Traps in the New Cosmetics Labeling Management Measures: Net Content Font / PAO Symbol / Ingredient Order — 3 Clauses Print Shop Owners Should Check First on Cosmetics Orders

Last April, a print shop in Guangzhou specializing in e-commerce cosmetics gift boxes had 2,800 face mask boxes returned by the brand. The reason was neither printing color deviation nor box cracking — it was that the net content marking's font height was 0.6mm short. The brand's internal audit followed Article 9 of NMPA Announcement No. 77 of 2021 (Cosmetics Labeling Management Measures), which requires a font height of ≥2mm, while the print shop's actual print was only 1.4mm.

The print shop owner complained on the phone: Q('I've never had such strict requirements on cosmetics gift boxes before — a 1.4mm font height looks pretty clear, right?') — The root of this mistake is that Announcement No. 77 of 2021 is not Q('a guiding suggestion') but a departmental regulation issued by the State Administration for Market Regulation. Every number in the clauses is a hard requirement, and the brand's internal audit Q('close enough') check almost certainly means the brand had already calculated the loss before returning the goods.

I. First, Clarify the Positioning of Announcement No. 77 of 2021

The full name of this announcement is the Cosmetics Labeling Management Measures, issued on May 31, 2021, and officially implemented from January 1, 2022. Its legal level is a departmental regulation; the penalty basis for violations is Article 71 of the Cosmetics Supervision and Administration Regulations — serious cases are subject to a fine of 1-3 times the illegal gains, and severe cases result in license revocation.

The question print shop owners ask most often: Q('Isn't the cosmetics label the brand's responsibility? What does it have to do with us as the print shop?') — It does. Because the print shop is the Q('direct producer') of the label. When regulators conduct on-site inspections, they first check the print shop's retained samples, signed proofs, and pre-production records. If the print shop cannot provide evidence Q('printed in accordance with legal requirements'), it will be penalized together with the brand.

II. The 3 Categories of Details Print Shops Most Easily Fail On

The announcement contains 23 clauses in total. The places where print shops actually stumble during proofing and mass production are concentrated in the following 3 categories:

Category 1: Net Content Font Height

Article 9, paragraph 2, original text: The net content marking shall use Chinese characters, numerals, and legal units of measurement, with a character height of no less than 2mm. Note 3 details:

• The character height refers to the visual height of the Arabic numerals, not the height of the English unit — many print shops convert based on the font size of English cm/mm, which is actually incorrect
• The character refers to the netic numerals themselves (e.g., the Q('50') in Q('50g')), not the entire marking text
• 2mm is the lower limit, not the standard value. Because cosmetics packaging has a small area, some brands require ≥3mm. Print shops must follow the brand's internal control standards

Real case: The Guangzhou print shop's 2,800 returned face mask boxes resulted in a direct loss of 16,000 yuan in printing fees + lamination + die-cutting, plus another 4,000 yuan for a second production run — a net loss of 20,000 yuan. The print shop owner later recalled: Q('No one mentioned the 2mm font height during the client's proofing stage. The numbers on the proof looked quite large, but when actually measured they were only 1.4mm.')

Category 2: PAO Symbol (Period After Opening)

Article 13 original text: When a product's shelf life exceeds 30 months, the PAO graphic symbol (Period After Opening) shall be marked, following GB/T 29336 for the marking method. Common violations:

• The graphic symbol size is too small — the announcement requires a symbol width of ≥5mm, but many print shops only print 3-4mm
• The Q('M') letter position is incorrect — Q('M') must be on the right side of the open-jar graphic, vertically centered; some print shops place Q('M') on the left side of the graphic
• The number position is incorrect — Q('6M'), Q('12M'), Q('18M') and other specific numbers should be close to the graphic; some print shops place the numbers on a separate line below the graphic

Real case: In June 2023, a Shanghai print shop received a Q('toner') order. The PAO graphic symbol was printed as Q('open jar + 12M'), but Q('M') was placed on the left side of the graphic. The brand returned 1,500 units for Q('non-compliance with GB/T 29336'), and a re-print and rush order followed.

Category 3: Full Ingredient Ordering

Article 10 original text: All ingredients in a cosmetic formula shall be listed in descending order of content — ingredients above 1% shall be listed from highest to lowest, and ingredients at or below 1% may be listed in any order after the above-1% ingredients.

The way print shops stumble on this clause is very specific — not because they print incorrectly, but because they fail to verify the formula total when receiving the ingredient list:

• The ingredient list provided by the brand usually notes Q('to 100%'), but the actual formula total may be 99.x% (due to moisture evaporation or process loss)
• After the print shop lays out at 100%, the brand sends a second version of the ingredient list and changes the order of two ingredients. The print shop does not re-verify the total and directly changes the version for printing. Then the third version of the ingredient list reverts the order

Real data: In a 2024 return statistics from a Hangzhou print shop, Q('wrong versions') caused by repeated ingredient list revisions accounted for 17% of cosmetics orders. The most serious case involved a single serum whose ingredient list was revised 4 times. The print shop printed 4 versions, and on the final print, the brand found that the order of Q('preservatives') did not match the actual formula, resulting in 6,000 gift boxes being returned.

III. 3-Step Self-Inspection Process When Print Shops Receive Cosmetics Orders

There are 3 things that must be locked down at the proofing stage:

IV. What Liability Do the 3 Parties — Print Shop and Brand — Each Bear

• Brand (Article 71 of the Cosmetics Supervision and Administration Regulations): For non-compliant labels, a fine of 1-3 times the illegal gains; serious cases result in filing revocation
• Print shop (Article 56 of the Consumer Rights Protection Law): For knowingly or should-knowingly printing non-compliant labels, a fine of 3-10 times the Q('printing fee')
• Joint liability (Article 28 of the Advertising Law): If label content involves false advertising (e.g., writing Q('24-hour moisturizing') as Q('48-hour moisturizing'), the brand and the print shop each bear liability according to their respective fault

The print shop owner's biggest concern — Q('I'm just a contract printer') — the basis for determining Q('knowingly or should-knowingly') is: Did the print shop require the brand to provide a filing number when taking the order? Did it verify the net content font height and PAO graphic symbol at the proofing stage? Did it confirm the ingredient list version before mass production? If none of these three were done, it is equivalent to Q('should have known').

V. 3 Summary Sentences for Print Shop Owners

1. Cosmetics labels are legal markings, not decoration — when a client asks you to Q('make the font a bit smaller for a more refined look'), you must cross-reference the original text of Announcement No. 77 of 2021
2. Lock down 6 items at the proofing stage: net content font height / PAO graphic / ingredient list order / filing number / warning statement. When these 6 items match on the proof, you can print blind during mass production
3. A print shop is not Q('a contract manufacturer') — regulators and brands will both pursue liability back to the print shop, so compliance self-inspection cannot be skipped. One retained sample, one signed proof, and one ingredient list version record — these 3 documents are the print shop's Q('liability exemption trio')

Practical advice: When a print shop receives a cosmetics order, the first document should be a copy of the Cosmetics Filing Certificate. The second document should be the brand's signed and sealed Q('Label Content Confirmation Letter') + ingredient list version number. If these two documents are not complete, do not start the machine.

Further Reading

• 3 Categories of Regulatory Requirements for Printing Cosmetics Filing Numbers on Packaging
• 4 Categories of Labeling Standards for Cosmetics Labels: Ingredients / Shelf Life / Batch Number / Usage Instructions
• 3 Categories of Cosmetics Packaging Regulations Landing Rapidly
• 4 Categories of EU Compliance Requirements for Cosmetics Packaging