Author | Yao Lifan
"Beauty Headlines" new media
"The sunscreen you buy at a high price is actually a 'set of certificates' factory goods!"
"Beauty Circle Revealed! Don't buy these sets of sunscreen! ”
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Recently, many beauty bloggers seem to have mastered new traffic passwords. Taking advantage of the upcoming sun protection season, some beauty bloggers have begun to become popular on Douyin and Xiaohongshu under the pretext of exposing the chaos of sunscreen products.
These beauty bloggers believe that there are some domestic brands of sunscreen, in essence, some cheap factory goods, but after changing the packaging and changing the name, the price doubled to re-sell, and pointed out that the brand side "commissioned processing is equal to no strength, no research and development, the product is not passed", but also named Huaxizi, UNNY, turtle dad and many other well-known brands, attracting the attention of many consumers.
01
What is a set of certificates?
In fact, all sunscreens are "licensed." The "certificate" here refers to the "special cosmetics registration certificate" (hereinafter referred to as the "special certificate"), which is issued by the unified review and approval of the State Food and Drug Administration and is valid for 5 years. Nine types of special cosmetics, including whitening and sunscreen, need to obtain a "special certificate" before they can be legally sold and used.
Because the "special certificate" application threshold is high, the product audit standard is strict, and the special certificate declaration cycle is long, the phenomenon of "set of certificates" has emerged. The "set certificate" refers to the use of someone else's filing number/approval number on the packaging after the product is produced. At present, there are two forms of "arbitrage" in the cosmetics industry.
The first is that the brand party directly diverts the "special certificate" of other products for its own use, that is, "hanging on the sheep's head to buy dog meat", the supervision bureau has clearly stated that this behavior is an illegal production without obtaining a special purpose approval number, and a number of enterprises have been investigated and punished.
On August 3, 2021, the State Food and Drug Administration also issued a notice on the suspension of the operation of the series of cosmetics labeled "Elizabeth Early Cream and Night Cream", and the approval numbers on the labels of these two products were "National Cosmetics Special G20190065" and "National Cosmetics Special Word G20111108", but in the State Food and Drug Administration's "Domestic Special Purpose Cosmetics" database, the corresponding products of the two approval numbers were "Mitchell Whitening Spot Cream" and "Youshuang Zhen White Spot Cream". This is an obvious violation of the "arbitrage" behavior.
The second is the act of OEM processing in the name of the dealer, which belongs to the "set of certificates" behavior of rubbing the edge ball. At present, there are no penalty cases. And in this case, it is easy to appear the phenomenon of "one certificate and multiple standards/brands", that is, the factory will sell the same product formula that has been registered for the record to different brands.
For example, the domestic brand "KONO" that has been questioned has the phenomenon of "one certificate and multiple standards". It is understood that the special approval number of KONO's hot-selling product "Ginger Anti-Shedding Shampoo" is "National Makeup Special Word G20150716". After inquiry, it was found that the product corresponding to the approval number and the status of "current batch" was "Gaotiya Anti-Hair Loss Shampoo". Under the bottle of KONO Ginger Anti-Shedding Shampoo, it also identifies GaoTia Anti-Hair Loss Shampoo.
Not only that, in addition to the "Gaotiya" and "KONO" brands, "Magic Fragrance", "Old Ginger King", "Star Moon Bee", "Miki Baba" and other brands are also the same special evidence, but their prices range from twenty yuan to hundreds of yuan.
However, this behavior of wandering in the "gray area" of supervision is also coming to an end.
On June 3, 2021, the State Food and Drug Administration issued an announcement on the implementation of the Measures for the Administration of Cosmetic Labeling, which clearly pointed out that "the number of the registration certificate for special cosmetics shall be the registration certificate number issued by the State Drug Administration, and marked on the visual surface of the sales packaging." Cosmetics that have previously applied for registration or filing must complete the renewal of their product labels before May 1, 2023, so that they meet the regulations and requirements. ”
This means that after May 1, 2023, all specially certified products need to upload product labels to avoid inconsistencies between the packaging of commercially available products and the packaging of registered products, and fundamentally eliminate the loopholes of individual enterprises. Therefore, the phenomenon of "arbitrage" will eventually disappear and become history.
02
It is not advisable to stigmatize domestic goods with "arbitrage certificates"
In fact, the brand or directly with the help of mature factory qualification certificates for sales, or the brand and the factory to create products, or by the factory to apply for special certificates, brand promotion and sales, no matter which case, the product filing, production, sales process are under the supervision of the state, a special certificate strictly corresponds to a formula, the product regularly accepts the national sampling inspection, in line with relevant laws and regulations, is not in the category of violations.
The phenomenon of entrusted processing and authorized use of cosmetics is a common phenomenon of socialized production division of labor. Not only domestic products, but also for the needs of social division of labor and specialization, the same is true of international cosmetics brands. The simple and crude understanding of this behavior as "no strength, no research and development, and no product pass" is a typical layman's misreading.
In fact, many brands with R&D strength do not simply "take away" the special certificate to use, but on the basis of legal compliance, as far as possible to participate in the optimization and upgrading of the product.
For example, in a similar topic recently, Chinese beauty brand Hua Xizi was named by a beauty blogger as having a "set of certificates" phenomenon of "yurong cloud yarn sunscreen pre-cream" (approval number is "national makeup special word G20201257"). In this regard, Huaxizi officially responded that there is no "set of certificates" for the product, which is a product jointly developed by Huaxizi and Kema Cosmetics (Wuxi) Co., Ltd. in 2018, which is first sent by Kema for inspection and filing, and then renamed after Huaxizi determines the specific name of the product.
In fact, due to the complexity of the special certificate application, in order to improve the efficiency of the whole process, many of the formulas co-created by the brand and the factory will first apply for the special certificate, and then through the name change procedures, the product name corresponding to the special certificate will be updated to the product name of the brand's final sale.
It is understood that in 2018, Huaxizi and Coma agreed to jointly innovate and develop the product. Huaxizi put forward the product concept, responsible for providing active additives of natural plant ingredients, conducting biological research, human efficacy evaluation, consumer evaluation at the effectiveness level such as makeup and sunscreen SPF value, and based on the above research and evaluation results, proposing the idea of adjusting the formula or research and development program, Coma carried out the combination and adjustment of the formula.
Therefore, this behavior of Hua Xizi is not a "set of certificates", but only the renaming and transfer of existing products, still following the principle of "one certificate and one brand".
In today's rapid rise of domestic beauty and China's beauty supply chain, it is a behavior worth encouraging for brands to complement the advantages of factories and fully interact to co-create formulas. It is not advisable to use the so-called "set of certificates" to "buckle the hat" of domestic brands, and it is easy to cause ambiguity in dwarfing domestic brands, which is not conducive to the healthy development of the industry and the market.
Reference:
1. Maternal and infant industry observation: how to comply with cosmetics cooperative processing? "Set of certificates" Oolong has become a popular science lesson
2. Peng Boshe: Hua Xizi and KONO are caught in the whirlpool, and the "set of certificates" brand is not much time?