Cosmetics Export Compliance Testing for ASEAN

JJR LAB provides one-stop services for enterprises exporting cosmetics to ASEAN, including but not limited to preservative challenge testing, contaminant monitoring, safety assessment, label & ingredient review and product notification services, fully supporting enterprises in overseas market expansion.

Challenges of Cosmetics Export to ASEAN

✓ Enterprises must understand and comply with provisions stipulated in ASEAN cosmetic directives to meet regulatory requirements of all ASEAN member states.
✓ Enterprises need to continuously update product ingredients in response to the latest safety standards and regulatory revisions.
✓ Enterprises shall ensure product labels and packaging fully conform to ASEAN labelling regulations.
✓ Enterprises must respond rapidly to market changes and complete official notification procedures before products enter the ASEAN market.

Service Background

According to statistics released by the General Administration of Customs of the People’s Republic of China, China’s total import and export volume with ASEAN reached 4.5 trillion RMB in the first 8 months of 2024, a year-on-year increase of 10%, accounting for 15.7% of China’s total foreign trade. The export volume hit 2.69 trillion RMB, rising by 13.1%. ASEAN remains China’s largest trading partner, export market and import source.

Driven by the Belt and Road Initiative and the broad market potential of Southeast Asia, an increasing number of cosmetic brands have expanded into Southeast Asian markets in recent years. However, ASEAN has distinct cosmetic regulations and import requirements compared with mainland China. A clear understanding of local rules helps enterprises avoid operational risks and improve export efficiency. Below are the general requirements specified in the ASEAN Cosmetic Directive.
(Data Source: General Administration of Customs of the People’s Republic of China)

Definition of Cosmetics

Any substance or preparation intended for external contact with any part of the human body (epidermis, hair, nails, lips, external genitalia, etc.) or oral mucous membranes and teeth. Its primary purposes include cleaning, fragrance enhancement, appearance modification, skin protection, body odour correction and physical conditioning.
— ASEAN Cosmetic Directive (ACD)

Common Cosmetic Categories (Non-exhaustive List)

Ingredient Safety Requirements

The ASEAN Cosmetic Directive adopts the ingredient lists defined in EU Cosmetic Regulation (EC) No 1223/2009 and its latest amendments, supplemented by independent national requirements of individual ASEAN member states. All lists are updated irregularly every year.

• Annex II – Part 1: List of Prohibited Cosmetic Ingredients

• Annex III – Part 1: List of Restricted Cosmetic Ingredients

• Annex III – Part 2: List of Temporarily Permitted Ingredients

• Annex IV – Part 1: List of Permitted Colorants

• Annex VI: List of Permitted Preservatives

• Annex VII: List of Permitted UV Filters

Member states may authorise the use of substances not included in the approved ingredient lists within their territories, subject to the following three conditions:

1. The validity period of authorisation shall not exceed three years.

2. Member states shall conduct official inspections on cosmetics manufactured with authorised substances or preparations.

3. Cosmetics produced with authorised ingredients must be marked with a unique official authorisation logo.

Product Information File (PIF)

The ASEAN Cosmetic Directive (ACD) mandates that marketers or enterprises placing cosmetics on the market shall maintain a complete Product Information File.
In accordance with Article 6 of the Directive, regulatory authorities of relevant member states may access the PIF at the address stated on the product label at any time.

The PIF shall contain the following documents:
a) Qualitative and quantitative ingredient composition of the product; for fragrances, including ingredient names, codes and supplier information.
b) Specifications of raw materials and finished products.
c) Manufacturing processes complying with Good Manufacturing Practice (GMP) guidelines of ASEAN.
d) Human health safety assessment covering chemical structures and exposure levels of cosmetic ingredients in finished products.
e) Existing data on adverse human health effects caused by cosmetic use.
f) Supporting evidence to verify cosmetic efficacy claims.

Labelling Requirements

Cosmetics can only be launched for sale after complying fully with ASEAN labelling regulations. All label information must be clearly visible and easy to understand.

Mandatory content for outer packaging labels:
a) Product name and functions
b) Instructions for use
c) Full ingredient list
d) Country of origin
e) Name and address of local responsible company or authorised marketer
f) Net content
g) Production batch number
h) Production date / shelf life
i) Warning statements

Note:
Labels shall be printed in English, official local languages or other languages understandable by local consumers.
Items a), b), e), f) and i) must be labelled in the official language of the selling country.

Cosmetic Product Notification

Cosmetic manufacturers or importers must submit product notification applications prior to launching products in ASEAN markets.

Separate notifications are required for each importing member state, with varying validity periods. Timely renewal is mandatory before expiration.

Notification information shall be updated promptly if there are formula, label or other product changes for marketed cosmetics. Notification cancellation is required in a timely manner if products are no longer sold in ASEAN.

One-Stop Cosmetic Export Service for ASEAN

JJR LAB delivers customised one-stop solutions for cosmetics exported to ASEAN, covering preservative challenge testing, contaminant monitoring, safety assessment, label & ingredient review and official notification services. We provide comprehensive guarantees for your overseas business expansion. Feel free to contact us for enquiries.

1. Preservative Efficacy Testing

2. Contaminant Monitoring

Customised testing solutions for Singapore, Indonesia and other regions are available upon consultation.

3. Safety Assessment

The ASEAN Cosmetic Directive (ACD) stipulates that cosmetics placed on the market shall not cause harm to human health under normal or reasonably foreseeable use conditions. Relevant assessment shall take into account product features, label content, instructions for use, warning statements and all other information provided by manufacturers, authorised agents or market responsible parties.

4. Label Review & Notification