Chemical Compliance
Intelligence & Solutions
China Detergent & Soap Regulations
Jun 24, 2016
Jane Zhou
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CONTENTS

What are Dtergents and Soaps?

Detergents and soaps are cleansing products containing surface active agents (surfactant compounds), exclusive of dry-cleaning agents or industrial cleaning products which mainly consist of organic solvents. They may be in any forms of liquid, powder, paste, bar, slide, etc.

China Detergent/Soap Market at a Glance

China has both high productive capacity and tremendous demand for consumer chemical products, creating profitable business opportunities. Statistics from China National Light Industry Council show that in 2013, China’s enterprises above the designated size (annual income > 20 million RMB) consumer chemical sector earned over 386 billion RMB from their major businesses with a profit margin of 9.8%, higher than the average level of the whole light industry at 3.33%. 


fig1.png

Fig. 1 - Profit margins of China's consumer chemical manufacturing sector in 2013

Import value of consumer chemical products in 2013 is 3.68 billion USD, increased by 10.28% on a year-on-year basis.


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Fig.2 - Consumer chemicals China imported in 2013

Quality Inspection Statistics and Alerts

On Jan 4, 2016, AQSIQ released the report of the national quality inspection program of food-related products 2015. Among the 440 batches of dishwashing liquids  from 372 enterprises, 409 batches (93.0%) and 341 enterprises (91.7%) are up to standard. Non-conformances mainly relate to total active matters, total bacterial count, methanol content and detergency. 

Classification

From a regulatory perspective and in accordance with GB/T 26396-2011, detergents and soaps are classified into Type A, B and C based on the intended uses and the associated safety and health risks to people:

  • Type A – Detergents used on food, food utensils and devices/equipment, fruits and vegetables, etc.

  • Type B – Detergents used on human body, such as toilet soap, shampoo, bath products, hand wash, etc.

  • Type C – Detergents used on other objects, such as laundry detergent (including softener), sanitary ware/kitchen/glass/floor cleaner, etc.

Each type of detergent may be further classified according to their uses or compositions. For example, in GB 14930.1-2015 Type A detergents are further classified into detergents directly used on food (A) and detergents used on food contact surfaces (B). Laundry detergents in Type C are further classified into phosphorus (HL) and phosphate-free (WL), or non-concentrated (A) and concentrated (B). So, concentrated phosphate-free laundry powders can be coded as “WL-B”. 

Regulations & Policies

Pre-market and Post-market Inspections

To protect consumers’ safety and health, detergents and soaps manufactured and/or marketed in China are subject to Product Quality Selective Inspections in accordance with Product Quality Law of the People’s Republic of China. Samples are taken from either the domestic market or enterprises’ finished goods warehouses. National inspection programs are organized by General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) while regional inspections are carried out by local commodity inspection and quarantine (CIQ) bureaus.

In addition, import and export of detergents and soaps are controlled under Law of the People's Republic of China on Import and Export Commodity Inspection. Products listed in Catalogue of Inbound-Outbound Commodities Subject to Compulsory Inspection Enforced by the Commodity Inspection Authorities (hereinafter referred to as “Compulsory Inspection Catalogue”) should comply with China’s mandatory standards and relevant regulations and pass compulsory commodity inspections before customs clearance. Importing products that have failed to pass the compulsory inspection could result in a fine equal to 5%~300% the value of commodities or even criminal liability and all illegal gains will be confiscated.

Table 1 – Detergents and soaps listed in Compulsory Inspection Catalogue (2016)

HS Code

HS Name

3305100010

含濒危植物成分的洗发剂

Shampoos containing composition of   endangered vegetable

3305100090

其他洗发剂(香波)

Other shampoos

3307300000

香浴盐及其他沐浴用制剂

Perfumed bath salts and other bath   preparations

3401110000

盥洗用皂及有机表面活性产品(包括含有药物的产品、呈条状、块状或模制形状)

Soap; organic surface active products   and preparations for toilet use including medicated products, in the form of   bars, cakes, molded pieces or shapes

3401300000

洁肤用有机表面活性产品及制品(液状或膏状并制成零售包装的,不论是否含有肥皂)

Organic surface active products and   preparations for washing the skin, in the form of liquid or cream and put up   for retail sale, whether or not containing soap

There are chances for imported detergents not in the Compulsory Inspection Catalogue to be inspected by CIQs at the ports of unloading, stations of arrival or the sites of receiving enterprises. Such inspections are carried out in accordance with Administrative Measures on Selective Inspection of Import and Export Commodities which tends to targets products that have been the subject of complaints by domestic consumers and/or brands that have had quality issues. Inspection results are disclosed to the public. CIQs will issue an order to return or destroy unqualified products for which there is no effective remedial measure.

Other Regulations: HazChems, New Chemical Substances, Food-related Products & Cosmetic Products

Stakeholders should identify if the detergents are hazardous chemicals defined under State Council Decree 591 or contain any new chemical substance thus are subject to new chemical substance notification under MEP Order 7.

Type A detergents that may directly contact food and Type B detergents that are classified as cosmetic products are subject to industrial production licensing in accordance with Regulations of the People's Republic of China on the Administration of Production License for Industrial Products (State Council Decree 440). They should also comply with other regulations of food-related products (food contact materials) or cosmetic products, which may require new ingredient registration, administrative approval for market entry, record filing, import control, etc.

contact.pngConsumer Products Service Department (CPSD) of REACH24H Consulting Group provides market access and regulatory compliance analysis to help you understand the complex and ever-changing atmosphere of Chinese regulations. Contact us with any questions about exporting your products to China >>> 

National Standards & Industrial Standards

For domestically manufactured products or imported products, compliance with relevant national or industrial standards is a fundamental requirement.

A standard starting with “GB” is a national standard, or “QB”, a standard for light industry. “/T” indicates the standard is recommended. However, in absence of mandatory national or industrial standards, sometimes “GB/T” and “QB/T” are seen as mandatory standards by law enforcement authorities. 

General Standards

> GB/T 26396-2011 Technical Specification for Safety of Soaps and Detergents

The standard is applicable to detergents for food, food utensils and devices/equipment, personal care, laundry, etc. It is not applicable to dry-cleaning agents which mainly consist of organic solvents. It comprehensively outlines criteria on the ingredients (namely surfactants, preservatives, colorants, and fragrances), product hygiene and safety, packaging and labeling, test methods and inspection rules by quoting or referring to existing national or industrial standards.

In principal, surfactants in detergents should be degradable and their degradation products should be environmentally friendly, which means either of the following criteria should be met:

  • Primary biodegradation degree of the surfactant >= 90%;

  • or Primary biodegradation degree of the surfactant >= 80%, and the ultimate biodegradation degree >= 60%.

It’s known that alkylphenol polyoxyethylene and tetrapropylene benzene sulfonate surfactants shall not be used.

> QB/T 2952-2008 Requirements for Detergent Marks and Packaging

Generally, labeling should appear on both the sales packaging and transport packaging, whether printed or affixed. The contents should be legible, accurate and in standard Chinese, and contain at least the following information:

Table 2 – Minimum labeling requirements for different packagings

Normal Sales Packaging

Small Sales Packaging
  (Largest surface area < 10cm2)

Transport Packaging

1. Product name

2. Trade mark

3. Name and address of the manufacturer; for imported   products, indicate the country of origin and name and address of the importer   or distributer in China

4. Net content

5. Manufacture date and shelf life; or batch number and expiration date

6. Code of product standard (Any applicable national,   industrial or enterprise standard)

7. Product type and quality grading

8. License/certificate number & mark for products   subject to licensing/certification

 

1. product name

2. name of the manufacturer

3. manufacture date and shelf life

 

* Other information can be included in   additional product manuals, etc.

1. Product name

2. Name and address of the manufacturer

3. License/certificate number & mark for products   subject to licensing/certification

4. Code of product standard

5. Product size

6. Quantity

7. Manufacture date and shelf life; or batch number and expiration date

8. Mark, seal or certificate showing the products have   passed quality inspection (either by internal quality system or by third   party)

Recommended contents for labeling of disinfectants include place of origin, bar code, ingredients, use instructions, information on safe storage and transport, and other qualification or brand recognition marks.

> QB/T 2850-2007 The Antibacterial and Bacteriostatic Detergent

In this standard, antibacterial and bacteriostatic detergents and conditioners for textiles are classified to Type B, meaning their safety and health risk ranks after food-related detergents and ahead of detergents used on other objects’ surfaces.

Compared with other detergents, antibacterial and bacteriostatic detergents have higher hygienic standard as indicated by stricter total bacterial count limit. In addition, they should go through antibacterial and/or bacteriostatic efficacy evaluation and live up to the criteria specified in QB/T 2738-2012.

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Fig. 3 - China environmental label

> HJ 458-2009 Technical Requirement for Environmental Labelling Products – Household Detergents

In line with ISO 14020 series, China implements environmental labelling with a view to promoting sustainable production and consumption. HJ 458-2009 specifies the technical criteria for environmental labelling of laundry detergents and fabric conditioners, dishwashing liquids, hand cleaners, and detergents for other hard surfaces.

China has signed mutual recognition agreement of environmental labelling with Germany, Japan, South Korea and Australia. 

Product-specific Standards

The following tables are provided for the purpose of helping stakeholders navigate China's convoluted standard system. They sort out the most relevant and essential standards though the listing is not exhaustive.

> Food-related Detergents (Table 3)

Product

Standard

Key Inspection Items

Hand dishwashing

GB/T 9985

  • Total active matters

  • pH (0.1%, 25℃)

  • Detergency

  • Fluorescent brightening agents

  • Methanol

  • Formaldehyde

  • Arsenic (in 1% solution)

  • Heavy metal (in 1% solution)

  • Total bacterial count

  • Coliform bacteria

Detergents for food tools and   installations

GB 14930.1

  • Fluorescent brightening agents

  • Arsenic (in 1% solution)

  • Heavy metal (in 1% solution)

  • Total bacterial count

  • Coliform bacteria

Disinfectant detergents for food and  food-contact surfaces

GB 14930.2

  • Arsenic (in 1% solution)

  • Heavy metal (in 1% solution)

  • Additives

  • Microbiological indicators, including coliform bacteria,   staphylococcus aureus, & poliovirus

* Also pay attention to the restrictions and controls on raw materials/ingredients of food contact materials. 

> Personal Cleansing Products (Table 4)

Product

Standard

Key Inspection Items

Hand cleaner

(For both concentrated and   non-concentrated formula)

 

QB/T 2654-2013

  • Organoleptic properties

  • Physical and chemical properties, including stability,   total active matters, pH, contents of mercury, lead & arsenic

  • Microbiological indicators, including total bacterial   count, fecal coliform, pseudomonas aeruginosa, staphylococcus aureus, molds   & yeasts

Bath agents and shower agents

(For both concentrated and   non-concentrated formula, for adults and children)

QB/T 1994-2013

Toilet soaps

QB/T 2485-2008

Special hand cleaner

(“Special” means antibacterial and   bacteriostatic, the same below)

GB 19877.1-2005

  • Organoleptic properties

  • Physical and chemical properties, including total   active matters, pH, contents of methanol, formaldehyde, mercury, lead &   arsenic

  • Microbiological indicators, including total bacterial   count, fecal coliform, rate of reproduction and growth inhibition/rate of   killing

Special bath agents and shower agents

 

GB 19877.2-2005

Special toilet soaps

 

GB 19877.3-2005

Hair Shampoo

GB/T 29679-2013

  • Organoleptic properties

  • Physical and chemical properties, including heat &   cold stability, pH, foaming (40℃), effective matters, content of active ingredients,   lead, mercury & arsenic

  • Microbiological indicators, including total bacterial   count, molds & yeasts, fecal coliform, staphylococcus aureus, pseudomonas   aeruginosa

* Also pay attention to the restrictions and controls on raw materials/ingredients of cosmetics. 

> Laundry Detergents (Table 5)

Product

Standard

Key Inspection Items

Liquid Laundry detergent

QB/T 1224-2012

  • Total active matters

  • pH (0.1%, 25℃)

  • Total phosphorus pentoxide (for phosphate-free   products)

  • Detergency

Laundry powders (phosphorous)

GB/T 13171.1-2009

  • Apparent density

  • Total active matters

  • Nonionic surfactant

  • Total phosphorus pentoxide

  • Free alkali (NaOH)

  • pH (0.1%, 25℃)

  • Detergency

Laundry powders (phosphate-free)

GB/T 13171.2-2009

Laundry paste

QB/T 2116-2006

  • Stability

  • Total active matters

  • pH (0.1%, 25℃)

  • Phosphate (P2O5)

  • Detergency

Laundry bar soap

QB/T 2486-2008

  • Dried sodium soap

  • Foaming capacity (5 min)

  • Chlorides (NaCl)

  • Free caustic alkali (NaOH)

  • Total phosphorus pentoxide

  • Transparency (6.50±0.15 mm slide)

Compound laundry bar soap

QB/T 2487-2008

  • Total active matters

  • Performance in hard water (0.20%, 50.0 mL, 40±2℃)

  •  Foaming capacity (5 min)

  • Free caustic alkali (NaOH)

  • Total phosphorus pentoxide

 

> Hard Surface Cleaners (Table 6)

Product

Standard

Key Inspection Items

Toilet bowl and ceramic tile cleansers

GB/T 21241-2007

  • Organoleptic properties

  • Total acidity

  • Content of surfactant

  • Corrosiveness