Mastering Information Verification - A Case Study of Hua Xizi He Shou Wu eyebrow pencil (花西子何首烏眉筆)

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As Internal auditors, our primary responsibility is to ensure the accuracy and reliability of information. Verification is a crucial part of this process, enabling us to build trust with stakeholders and uphold the integrity of our work.

Background: The Hua Xizi Controversy

In 2023, the Chinese beauty brand Hua Xizi came under public scrutiny following a controversial remark made by a well-known livestream host, Li Jiaqi. This case, which captured significant media attention, highlighted important issues around crisis management, product claims, and marketing transparency—particularly in the highly competitive fast-moving consumer goods (FMCG) cosmetics sector.

While working with a leading Hong Kong-based FMCG cosmetics company, I closely observed this incident, especially how it related to product integrity and consumer trust. One product that became a focal point of the discussion was the Hua Xizi He Shou Wu Eyebrow Pencil. It provided a practical example for analyzing the importance of factual verification in product marketing.

Verifying Ingredient Claims Using Official Sources 

To verify product claims, it is essential to refer to primary sources of data. In this case, the most authoritative reference is the National Medical Products Administration (NMPA) general cosmetics filing database, available publicly at:

https://hzpba.nmpa.gov.cn/gccx/

To verify the ingredient composition of the Hua Xizi eyebrow pencil, we can begin by visiting the brand's official website. The product page lists its filing number:

📦 浙G妆网备字2023012960

Entering this number into the NMPA’s query portal returns the official filing for the Hua Xizi Luodai Shenghua Eyebrow Pencil, which includes: 

  • Filing number

  • Filing company

  • Filing date (June 6, 2023)

  • Manufacturer information

  • Full ingredient list

Ingredient Disclosure and Regulatory Thresholds

By entering this filing number into the query website and clicking search, we find the entry for the Hua Xizi Luodai Shenghua eyebrow pencil. This includes its filing number, the filing company, and the filing date of June 6, 2023.

 Upon clicking to view the details, we can access information about the production company and the complete ingredient list.




According to Chinese cosmetic regulations, the product formula content must be expressed as a percentage by weight, with all ingredients listed in descending order of their concentration. This means that in the formula list, ingredients are arranged from highest to lowest content. The last ingredient listed is He Shou Wu (何首烏). Preceding it is Butylated Hydroxytoluene (丁基羥基甲苯), an antioxidant. Based on national standards, Butylated Hydroxytoluene is classified as a low-toxicity substance, although it does possess certain toxic properties. The maximum allowable concentration for its use as a preservative is 0.15%.

This indicates that the He Shou Wu content in this Hua Xizi eyebrow pencil must be less than 0.15%, as Butylated Hydroxytoluene can only be included at a maximum concentration of 0.15%. Given this limitation, how can the product still be marketed as an He Shou Wu eyebrow pencil while promoting its efficacy? Is it truly effective? By examining this information, we gain a clearer understanding. 

Conclusion

This case illustrates how internal auditors can apply their skills in fact-checking, regulatory interpretation, and risk assessment—even in areas such as product marketing and brand reputation. In an age where consumers are increasingly sensitive to transparency and authenticity, verifying product claims through authoritative sources is not only good practice—it's essential.


Reference:

https://www.globaltimes.cn/page/202309/1298571.shtml


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