Certification and Registration
Cosmetics Testing in the ASEAN Market
Category:
Cosmetics Testing in the ASEAN Market
Cosmetics Testing in the ASEAN Market
The Association of Southeast Asian Nations (ASEAN) consists of ten member states: Indonesia, Malaysia, the Philippines, Singapore, Thailand, Brunei, Vietnam, Laos, Myanmar, and Cambodia. As a major regional economic bloc with a population of more than 600 million people, ASEAN has become one of China’s largest trading partners in recent years. Its large young consumer population and rapidly expanding cosmetics market have attracted increasing attention from Chinese cosmetic companies seeking international expansion.
To promote regional market access and regulatory harmonization, ASEAN has established a unified regulatory framework centered on the ASEAN Cosmetic Directive (ACD). However, despite this harmonized framework, individual member states still maintain differences in areas such as enforcement practices, notification procedures, labeling languages, and specific ingredient requirements. Therefore, a complete “one-stop notification” system applicable across all ten ASEAN countries has not yet been achieved.
Definition and Scope of Cosmetics in ASEAN
Under the ASEAN Cosmetic Directive, cosmetics are defined as:“Any substance or preparation intended to be placed in contact with the various external parts of the human body, including the skin, hair, nails, lips, and oral mucous membranes, with the primary or exclusive purpose of cleansing, perfuming, changing appearance, correcting body odors, protecting, or maintaining them in good condition.”
|
Serial number |
Cosmetics category |
|
01 |
Creams, lotions, cleansers, gels, and oils for the skin (hands, face, feet, etc.) |
|
02 |
Face masks (excluding chemical exfoliants) |
|
03 |
Color-correcting foundation (liquid, cream, powder) |
|
04 |
Cosmetic powders, post-bath talcum powders, and sanitary powders, among others. |
|
05 |
Soap, deodorizing soap, etc. |
|
06 |
Perfume, floral water, eau de cologne, etc. |
|
07 |
Bath and shower products (bath salts, bubble baths, bath oils, gels, etc.) |
|
08 |
Hair removal cream |
|
09 |
Deodorants and antiperspirants |
|
10 |
Hair care products (hair dyes and bleaches; curling, straightening, and styling products; styling products; cleansing products—lotions, talcum powders, shampoos); skincare products—lotions, creams, oils; hair‑care products—lotions, hairsprays, hair oils. |
|
11 |
Shaving products (shaving cream, shaving foam, shaving lotion, etc.) |
|
12 |
For facial and eye makeup application and removal products |
|
13 |
Products for the lips |
|
14 |
Dental and oral care products |
|
15 |
Nail care and manicure products |
|
16 |
Topical personal hygiene products |
|
17 |
Sunbathing products |
|
18 |
Sunless tanning products |
|
19 |
Skin whitening products |
|
20 |
Anti-wrinkle product |
|
* Whitening and sunscreen products are also classified as cosmetics. |
|
This definition covers 20 major cosmetic product categories, including skincare, makeup, hair care, oral care, and other personal care products. Notably, within the ASEAN market, skin whitening products and sunscreen products are classified as cosmetics and regulated under the ASEAN Cosmetic Directive, which differs from the classification systems applied in some other markets.
ASEAN Cosmetics Testing Services
(1) GMP Review and Verification (ISO 22716)
All cosmetic products marketed in ASEAN countries must be manufactured by companies complying with Good Manufacturing Practices (GMP) for cosmetics. ISO 22716 is a widely recognized international GMP standard. Chinese cosmetic manufacturers can satisfy this requirement by undergoing GMP audits and obtaining a certificate of compliance.
(2) Product Testing
Microbial Limit Testing
Heavy Metal Testing
|
Heavy metal |
Limited Quantity Requirement |
|
Mercury(Hg) Mercury |
≤1mg/kg or 1 mg/L |
|
Lead (Pb) Lead |
≤20mg/kg or 20 mg/L |
|
Arsenic(As) Arsenic |
≤5mg/kg or 5 mg/L |
|
Cadmium(Cd) Cadmium |
≤5mg/kg or 5 mg/L |
|
Test Method Description: The test methods for mercury, lead, arsenic, and cadmium follow ACMTHA05, as adopted at the 8th ACSB Meeting (December 10–11, 2007, Vietnam). |
|
|
Special Provisions: Due to national regulatory requirements and other special circumstances, Thailand’s cadmium limit is 3 mg/kg or 3 mg/L. |
|
Preservative Efficacy Testing
Hazardous Substance Testing(e.g., dioxane and other restricted substances)
(3) Human Safety Testing
Human Repeat Insult Patch Test (HRIPT)
Human Patch Test (24/48 hours)
Human Clinical Safety Evaluation
Sensitive skin compatibility assessment
(4) Clinical Efficacy Evaluation
Including:Whitening, sunscreen efficacy (SPF, PFA), water resistance, repair, soothing, anti-wrinkle, firming, nourishing, oil control, moisturizing, exfoliation, long-lasting makeup performance, coverage performance, cleansing efficacy, and other cosmetic efficacy evaluations.
(5) Labeling and Declaration Requirements
Mandatory labeling information includes:
Product name, intended function, full ingredient list, net content, production batch number, instructions for use, country of origin, name and address of the responsible party, and necessary precautions.
Malaysia-Specific Requirements:Products containing animal-derived ingredients, such as beef or pork derivatives, must be clearly labeled.
Philippines-Specific Requirements:Labels may be provided in English or Filipino.
Vietnam-Specific Requirements:Labels may be provided in English or Vietnamese.
Special Requirements for Sunscreen Products:Sunscreen products must indicate both UVB protection (SPF) and UVA protection levels. They must also include the mandatory warning:“Even when using sunscreen, do not stay in the sun for too long.”;Claims such as “100% protection” or “all-day protection” are prohibited.
(6) Cosmetic Ingredient Review
(7) Product Information File (PIF)
Companies must prepare and maintain a Product Information File (PIF) containing product descriptions, safety reports, manufacturing information, and supporting evidence for product safety and efficacy. The PIF must be available for inspection by market surveillance authorities when required.
(8) ASEAN Toxicological Safety Risk Assessment
Toxicological evaluation and safety risk assessment according to ASEAN cosmetic requirements.
(9) Halal Certification
In Indonesia and other ASEAN countries with significant Muslim populations, Halal certification is an important market access requirement. According to Indonesian regulations, from October 17, 2026, all cosmetics distributed in Indonesia must obtain Halal certification. Early preparation and timely certification can significantly improve product competitiveness in the market.
SATISFY has long been dedicated to cosmetic testing, regulatory research, and compliance services. Our expertise covers major global markets, including the United States, Canada, the European Union, Australia, ASEAN countries, and China. We provide customized efficacy assessments, regulatory consulting, safety evaluations, and testing solutions tailored to the requirements of different countries and regions. For more information, please contact SATISFY customer service.
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