2025 ASEAN Cosmetics Regulation Year-End Review

For cosmetics companies planning to enter the Southeast Asian market, the complex and rapidly changing regulations of various countries are thresholds that must be crossed for successful product launch. In 2025, regulatory actions in ASEAN countries were frequent, from major overhauls of ingredient lists and mandatory Halal certification to strict management of label claims and upgrades of digital platforms, resulting in a comprehensive tightening of compliance requirements.

To help you grasp the overall picture and accurately avoid risks, this article systematically reviews the core regulatory updates in major ASEAN countries such as Thailand, Indonesia, Malaysia, Vietnam, and the Philippines in 2025, and summarizes typical penalty cases to reveal regulatory red lines. Mastering these trends is the first step in formulating a market strategy for 2026.

ASEAN Cosmetic Directive (ACD) Updates

The ASEAN Cosmetic Committee (ACC) and the ASEAN Cosmetic Scientific Body (ACSB) held meetings in April (41st) and November (42nd) 2025, revising the ACD Annexes as follows:

Summary of 2025 ASEAN Cosmetic Directive (ACD) Revisions

Member states have gradually adopted the above updates through official documents. Export companies need to adjust formulations and labels promptly and synchronously.

Quick Look at Regulatory Developments in Member States

• Thailand

Ingredients & Technical Standards

April 2025: The Thai Food and Drug Administration (TFDA) announced new regulatory requirements for cosmetics containing powdered titanium dioxide with inhalation risk, requiring certification for such high-risk cosmetics.

May 2025: TFDA launched a new electronic notification system (e-Certificate) , covering products such as cosmetics, food, and medical devices.

July 2025: The Thai Ministry of Industry published a revised standard for sunscreen product SPF testing methods (TIS 2882-2567) .

August 2025: TFDA introduced application templates (F-CH7-1 and F-CH7-2) for new cosmetic ingredient assessments to facilitate the submission of applications for academic document evaluation, used for reviewing substances with no prior history of use in cosmetics.

October 2025: TFDA revised the Cosmetic Prohibited and Restricted Ingredients Lists:

□ Prohibited List: Added 24 items, revised 3 items.

□ Restricted List: Added Piperonal (CAS: 120-57-0), revised usage conditions for Salicylic Acid (CAS No. 69-72-7) and added children's warning statements.

November 2025:

□ TFDA issued a clarification on the exemption for using Piperonal (CAS: 120-57-0) in cosmetics. When the concentration of Piperonal is ≤10% in the ingredient and ≤1% in the finished product, it will no longer be classified as a Category 4 narcotic.

□ TFDA published three draft notifications on Microneedle Cosmetics, proposing a comprehensive ban on most microneedle cosmetics, while specifying certain exemptions ------ including certain dissolving microneedle patches and products intended for export only ------ and adding mandatory warning label requirements for exempted items.

Labeling & Claims Management

October 2025: TFDA issued and revised the "Clarification on the Guideline for Cosmetic Notification in Cases of Formula Changes While Intending to Use the Original Product Name" , clarifying the notification procedure if the ingredient formula changes but the company wishes to retain the original product name.

November 2025: TFDA published the revised "Guideline on Prohibited Words for Cosmetic Names" , clarifying prohibited words for Thai cosmetic trade names and product names, introducing clearer classifications and exception application procedures.

December 2025:

□ Thailand approved amendments to the cosmetic ingredient lists and labeling management requirements, including adding 17 prohibited ingredients and 2 restricted ingredients, revising 4 existing ingredient entries, and removing 2 allowed preservatives.

□ Thailand approved two draft announcements on labeling requirements for fluoride toothpaste, revising existing warning statements for fluoride cosmetics and introducing new mandatory labeling requirements for fluoride toothpaste.

Notification & Production/Business Management

July 2025: The Thai Ministry of Public Health revised and issued standards for cosmetic review fees, expert service fees, and academic document evaluation.

October 2025: TFDA revised the Cosmetic Manufacturing and Import Establishment Inspection Guide (2nd Edition) , providing clearer and more comprehensive guidance for inspecting cosmetic production, import, and storage facilities within Thailand.

December 2025: TFDA published an infographic on "Steps for Notifying Low-Risk Cosmetics" , providing graphical operational guidance for manufacturers and importers on the notification process for low-risk cosmetics.

• Indonesia

Ingredients & Technical Standards

September 2025: The revised "Regulation on Cosmetic Contaminant Limits" came into effect, further clarifying its scope of application.

October 2025: The "Technical Requirements for Cosmetic Ingredients" (PerBPOM No. 25/2025) officially came into effect:

□ Appendix I (Restricted Substances List): Revised 4 items, added 2 items.

□ Appendix II (Allowed Colorants): Revised 1 item.

□ Appendix III (Allowed Preservatives): Removed 1 item.

□ Appendix IV (Allowed UV Filters): Revised 2 items, added 2 items.

□ Appendix V (Prohibited Substances List): Added approximately 100 substances.

This regulation was promulgated and took effect on October 3, 2025. BPOM provided a 12-month transition period for the industry, requiring all cosmetics (new products, renewal products, or products with formula changes) to comply with the new regulations by October 3, 2026.

October 2025: Indonesia's National Agency of Drug and Food Control (BPOM) issued new regulations on risk assessment for ingredients used in certain traditional medicines, health supplements, quasi-drugs, and cosmetics, requiring that the quality and standards of raw materials used in certain forms (dosage forms) of traditional medicines, supplements, quasi-drugs, and cosmetics must meet the same requirements as medicinal ingredients.

December 2025:

□ BPOM revoked Decree No. 479 (2023) "Concerning Amendments to Regulations on Allowed Ingredients for Cosmetics" . The reason for revocation was that the content of the decree had been comprehensively regulated in "BPOM Regulation No. 25 (2025) ------ Technical Requirements for Cosmetic Ingredients".

□ BPOM issued the final version of "Regulations on Cosmetic Testing Parameters in Certificates of Analysis (CoA) for Import License Applications" . This regulation takes effect on January 8, 2026, and specifies the mandatory cosmetic testing parameters that must be included in the Certificate of Analysis (CoA), a crucial document for obtaining SKI Border.

Halal Certification Management

March 2025: Indonesia's Halal Product Assurance Agency (BPJPH) updated the Halal certification system "SIHALAL" and published two guides for companies applying for Halal certification.

April 2025: BPJPH opened 1 million free Halal certification quotas for Small and Medium Enterprises (SMEs) , providing support from Halal Product Process Assistants (P3H) during the certification process.

July 2025:

□ BPJPH reiterated requirements for using the Halal label. The use of the Halal标识 must comply with "BPJPH Decree No. 145 of 2022: Provisions on the Use of Halal Logos and Labels for Halal-Certified Products" and its subsequent amendments. The old MUI logo will expire on October 17, 2026.

□ BPJPH issued the "Notification on the Implementation of Staged Halal Certification Obligations for Foreign Products" , clarifying the phased Halal certification obligations for imported cosmetics.

□ BPJPH initiated work on drafting the "Guidelines for Halal Certification of Cosmetics" .

August 2025: BPJPH issued new operating procedures for Halal certification for micro and small enterprises, introducing a post-paid option for Halal certification fees.

September 2025:

□ BPJPH issued and implemented "Circular No. 7 of 2025 concerning the Public Disclosure of Halal Products and the Marking of the Indonesian Halal Logo" .

□ BPJPH enacted "Decree No. 221 of 2025 concerning Procedures for Registration of Foreign Halal Certificates (SHLN)" (effective December 15, 2025).

November 2025:

□ Indonesia notified the WTO of a draft Harmonized System (HS) code list corresponding to product types subject to mandatory Halal certification. Relevant products must apply for Halal certification from BPJPH or its recognized foreign institutions.

□ BPJPH notified the WTO of a draft guideline on Halal Assurance Systems for Cosmetic Logistics Services, stipulating that logistics services related to cosmetics, food, beverages, medicine, and other regulated products (including warehousing, packaging, and distribution) must obtain Halal certification.

Notification & Production/Business Management

January 2025: The OTSKK Registration Bureau under BPOM announced the official launch and operation of Cosmetic Notification System 3.0.

April 2025:

□ BPOM published its 2025 legislative plan, with cosmetics-related regulations covering various aspects such as cosmetic notification, ingredient requirements, labeling, testing, production, and online and offline sales.

□ BPOM proposed amendments to the application documents for cosmetic safety, quality, and efficacy evaluation.

May 2025: BPOM published the second revised draft of the "Regulation on the Importation of Pharmaceutical and Food Products into the Territory of Indonesia" .

August 2025: The OTSKK Registration Bureau updated cosmetic notification service standards, simplifying certain procedures and slightly optimizing the service timeline.

September 2025: BPOM published the second draft revision of the "Regulation on Cosmetic Notification Procedures" , optimizing recommendation letter management processes, adjusting review and update procedures, expanding exemption scopes, etc.

October 2025: BPOM promulgated and implemented the "Standards for Business Activities and Products under the Risk-Based Business Licensing System for the Pharmaceutical, Food, and Cosmetic Sub-sectors" (Standar Kegiatan Usaha dan Produk pada Penyelenggaraan Perizinan Berusaha Berbasis Risiko Subsektor Obat dan Makanan). This standard sets new business and product standards for the cosmetics industry (and pharmaceuticals, food).

November 2025: Indonesia revised the "Regulation on the Control of Pharmaceutical and Food Distribution via Electronic Systems" , which clarifies compliance requirements and criminal liabilities for online sales of cosmetics.

• Malaysia

Ingredient Lists Synchronized with ACD

July 2025: Malaysia's National Pharmaceutical Regulatory Agency (NPRA) issued Notification No. 1/2025, updating the annexes of the "Guidelines for Control of Cosmetic Products in Malaysia" :

□ Prohibited Ingredients: Revised the entry for 2-Ethylhexanoic acid, prohibiting its salts; added Trimethylolpropane triacrylate, with a sales transition period until April 24, 2027.

□ Restricted Ingredients: Revised conditions for Salicylic Acid, specifying a maximum concentration of 2% in nail polish.

Halal Certification Digitalization

May 2025: Malaysia's Department of Islamic Development (JAKIM) announced the full implementation of electronic Halal certification (e-Cert) . All SPHM applications approved through JAKIM, the State Islamic Religious Councils (MAIN), or the State Islamic Religious Departments (JAIN) will be issued electronically via the MYeHALAL system.

August 2025: JAKIM launched the MyHALALINGREDIENTS digital system for recording and evaluating all ingredients used in the Halal industry.

• Vietnam

Ingredient Lists Synchronized with ACD

July 2025: Vietnam's Drug Administration of Vietnam (DAV) issued Official Dispatch No. 1938/QLD-MP , updating the ingredient lists based on the 41st ACSB meeting, synchronizing additions to prohibited ingredients, adjustments to restricted ingredients, etc.

December 2025: DAV issued Official Dispatch No. 4984/QLD-MP , implementing the conclusions of the 42nd ASEAN Cosmetic Committee (ACC) meeting, requiring corresponding adjustments in the annexes.

Notification & Production/Business Management

July 2025: The Ministry of Health of Vietnam officially promulgated Decision No. 34/2025/TT-BYT , amending Circular No. 06/2011/TT-BYT on the Management of Cosmetics, clarifying electronic submission, consolidated notification, ingredient labeling specifications, import sample management, etc.

August 2025:

□ DAV issued Official Dispatch No. 2272/QLD-MP . This notice emphasizes that cosmetic manufacturers, importers, and distributors must strictly review and ensure their product classification and efficacy claims comply with Vietnamese legal definitions and cosmetic regulatory requirements.

□ DAV published a new draft of the "Decree on Cosmetic Management" (proposed to replace the old regulation). Key changes include: shifting product notification from "pre-approval" to "post-market surveillance", specifying that production conditions must comply with CGMP/ISO 22716, and introducing options for electronic cosmetic labels.

□ The Vietnamese government issued Decision No. 1838/QĐ-TTg . This implementation plan aims to ensure the timely, unified, and effective implementation of "Law No. 75/2025/QH15" (amending and supplementing several articles of the "Law on Advertising"). The amended law takes effect on January 1, 2026.

December 2025:

□ DAV issued Official Dispatch No. 5138/QLD-MP , launching a special inspection campaign from December 15, 2025, to March 31, 2026, focusing on combating smuggling, commercial fraud, and counterfeit products in the pharmaceutical and cosmetics sectors, especially targeting the market during the Lunar New Year period.

• Philippines

June 2025: The Philippines' Food and Drug Administration (FDA) officially reinstated the application period for License to Operate (LTO) renewal to 90 days before expiry.

July 2025: Philippines FDA published updated annexes to the ASEAN Cosmetic Directive (ACD) ingredients (consistent with the 41st ACSB meeting).

October 2025: Philippines FDA published a draft introducing an online user account registration and renewal system within the eServices platform, aiming to centralize and automate user access management to various FDA portals (ePortal, ePortal2, and RRDPortal), simplifying the application process.

Typical Penalty Cases in ASEAN Countries for 2025

Production of Unregistered Cosmetics with Prohibited Ingredients Fined 5 Billion Indonesian Rupiah

Violation: Production of unregistered cosmetics containing prohibited ingredients

In March 2025, Indonesia's BPOM cracked down on two illegal cosmetic products from a certain brand. Both products were not registered with BPOM, lacked legal sales permits, and did not meet safety, efficacy, and quality standards. Tests revealed they contained prohibited harmful ingredients such as mercury and hydroquinone. Additionally, some products were labeled with Thai production information, while others did not indicate the producer. A total of 7 related products (including day cream, night cream, skincare lotion, etc.) were banned from circulation in Indonesia.

Penalty: BPOM has requested the Indonesian E-commerce Association to delist the related products and is collaborating with the Ministry of Communication to shut down sales links. The involved company faces a maximum penalty of 12 years imprisonment or a fine of 5 billion Indonesian Rupiah (approx. 206,000 RMB).

False Claims of Cosmetics Being Ingestible

Violation: Falsely claiming cosmetics could be used orally

In April 2025, during an inspection, Indonesia's BPOM found that 4 cosmetic products, which had already obtained sales permits, had violated labeling claims. They were promoted for "oral use," contradicting the definition of cosmetics in "BPOM Regulation No. 18 of 2024" ------ cosmetics are for external use only and not for oral consumption.

Penalty: BPOM revoked the sales permits/notification numbers for these 4 products, ordered the manufacturer to recall and destroy the related products, and coordinated with the E-commerce Association to remove related promotional content.

Production of Cosmetics Containing Prohibited Ingredients

Violation: Production of cosmetics containing prohibited ingredients like hydroquinone, tretinoin, and miconazole

In May 2025, Malaysia's NPRA inspections revealed two batches of non-compliant cosmetics. Tests showed these products contained ingredients such as hydroquinone, tretinoin, and miconazole, violating Malaysian cosmetic regulations.

Penalty: NPRA cancelled the registration notifications for the two non-compliant cosmetic batches and urged the public not to purchase or use these products.

Crackdown on Large Illegal Imported Cosmetic Warehouse

Violation: Selling illegally smuggled imported cosmetics that were not notified/registered, had incorrect labels, etc.

In October 2025, Thailand's FDA and the Consumer Protection Police Division (CPPD) cracked down on an illegally operating cosmetic warehouse. The involved products were not registered with TFDA, lacked Thai labels, and were illegally smuggled imports.

Penalty: All products were seized and sent to a laboratory for analysis of harmful ingredients. According to the Thai Cosmetics Act, selling un-notified cosmetics can result in a maximum penalty of 3 months imprisonment and a fine of 30,000 Baht for individuals; illegal import carries a maximum fine of 20,000 Baht.

Selling Unnotified Cosmetics with False Efficacy Claims

Violation: Selling unnotified cosmetics with false efficacy claims

In November 2025, Vietnam's Ministry of Health found during market inspections that a company's "** Whitening Sun Protection Body Lotion" had severely false SPF claims. The packaging claimed "SPF 45+", but the actual test value was only 2.0. Furthermore, the marketed version of "** Whitening Sun Protection Body Lotion" differed from the version notified by the company.

Penalty: The Vietnam Ministry of Health confiscated and publicly destroyed the batch of products and issued a nationwide consumer warning advising the public to stop using them.

Selling Unnotified Cosmetics with Illegally Added Medicinal Ingredients

Violation: Selling unnotified cosmetics with illegally added restricted medicinal ingredients

In December 2025, an investigation by Singapore's Health Sciences Authority (HSA) revealed that the products sold by the involved party had not undergone pre-market notification with HSA and contained illegally added restricted medicinal ingredients such as tretinoin, mercury, and hydroquinone.

Penalty: The State Courts of Singapore fined the two responsible individuals 12,000 Singapore Dollars each.

The ASEAN cosmetic regulatory system is developing in a more unified, stringent, and transparent direction. Besides ingredient list updates, compliance in labeling claims, mandatory Halal certification requirements, and the digital transformation of product notification processes are all critical compliance points that companies must pay close attention to.

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