Quick Answer: Review an ASEAN cosmetic formula against the current ACD annexes using each ingredient’s exact identity, intended function and finished-product exposure. Annex II covers prohibited substances; Annex III sets restrictions; Annex IV covers permitted colouring agents; Annex VI covers preservatives; Annex VII covers UV filters. Confirm destination implementation and any transition before releasing the formula, label or batch.
ASEAN ingredient compliance is a formula review task, not a search for a universal approved ingredient list. A material can have several names, a blend can contain more than one controlled substance, and an entry can apply only to a particular use. The result needs to explain why the actual product meets the relevant conditions. A supplier’s broad statement that a raw material is suitable for cosmetics does not provide that explanation.
This guide helps brand teams prepare an evidence package for their manufacturer and destination reviewer. Discuss technical disclosure with your cosmetics OEM/ODM manufacturer early, before the formula is priced and packaging is printed. Regulatory acceptance, safety assessment and commercial claims should be checked together but recorded as distinct decisions.
Start with the actual ASEAN annex structure
The HSA-linked official annex document carries version 2026-1, dated 22 June 2026, at the start of Annex II. Use the annex heading and entry reference in your assessment. Do not transfer annex numbers from a different regulatory system.
| ACD annex | Purpose | Review question |
|---|---|---|
| II | Substances prohibited from cosmetic composition | Does the identity fall within a listed substance or group? |
| III | Substances permitted subject to restrictions and conditions | Does the specific product meet every applicable condition? |
| IV | Permitted colouring agents | Is the colourant and its intended application within the listed scope? |
| VI | Permitted preservatives | Is the preservative use covered by the applicable entry? |
| VII | Permitted UV filters | Is the UV-filter use covered by the applicable entry? |
The annex map helps route the review; it does not replace reading an entry. Read its substance description, scope, conditions, warnings and footnotes as a whole. Where an entry points to another annex or distinguishes functions, resolve that cross-reference before reaching a conclusion. Keep the reviewed entry with the formula record so a second reviewer can reproduce the reasoning.
Establish ingredient identity before checking restrictions
Create a full quantitative formula with one row for each supplied raw material and an expanded composition for mixtures. Connect the supplier’s trade name to its INCI name, chemical identity where relevant, CAS number where available, grade, function and composition range. A marketing name such as botanical complex is insufficient for screening. Ask the supplier to identify carriers, solvents, preservatives, colours and other components that enter the finished product.
Investigate ambiguous matches instead of relying on spelling alone. A salt, derivative or family entry may require more careful interpretation than a direct name match. Conversely, similar names do not automatically mean identical regulatory treatment. Keep the supplier clarification and identity rationale in the review record. If confidential composition is needed, agree a secure disclosure route to the qualified reviewer rather than omitting the material.
For botanical and fragrance mixtures, collect specifications appropriate to the substance and use. Record what is known, which declaration is relied on, and any remaining question. This avoids treating a short public ingredient list as a complete technical disclosure. Certification documents can support a separate commercial claim, but they do not substitute for ingredient compliance; our halal versus vegan cosmetics guide explains why those claims require their own evidence.
Match each condition to the finished product and exposure
The finished product is the assessment unit. Record whether it is rinse-off or leave-on, the application site, intended users, frequency and method of application, and any relevant incidental exposure. The same ingredient can require different reasoning in products with different uses. A formula spreadsheet that only records the ingredient percentage cannot capture those distinctions.
Calculate the contribution from every raw material containing the substance, using the concentration basis required by the relevant entry. A preservative may arrive through more than one premix. Document the calculation and assumptions, including uncertainty in a supplier’s composition range. Do not compare a raw material addition rate directly with a limit that applies to a constituent in the finished product. Ask for clarification when the data cannot support a defensible calculation.
| Destination record | Official source to check | Release question |
|---|---|---|
| Singapore | HSA-linked current ACD annex compilation and applicable local requirements | Does the product meet the relevant entry and current local implementation? |
| Malaysia | NPRA annex releases and relevant national implementation notices | Which revision and transition apply to the proposed activity? |
| Other ASEAN destinations | Respective competent authority publications | Has a qualified local reviewer confirmed the applicable national position? |
This article deliberately provides no shortcut concentration table. The official entry and its current conditions should control the calculation. For Malaysia, NPRA provides the June 2026 Annex III release and June 2026 Annex VI release. Reviewers should use the documents appropriate to the destination rather than copying an isolated value from a supplier presentation.
Keep a national implementation and transition record
A regional technical update and a national implementation deadline are different records. Identify every destination country and check its authority’s current publications, implementation notices and transition arrangements. A document’s upload date alone does not establish when an existing product must change. Record the precise notice and the activity to which a deadline applies, such as notification, manufacture, import or supply, where the notice distinguishes them.
NPRA’s official guideline index lists June 2026 versions for Annexes II, III, IV and VI and a December 2025 version for Annex VII at the time of review. This is useful for version selection, but it is not a statement that every annex shares one effective date. Ask the destination reviewer to resolve any implementation uncertainty before production release. Do not infer a grace period or use another country’s transition for your target market.
Maintain a market matrix with the reviewed source, applicable revision, unresolved questions, next review date and responsible contact. If a new annex appears while orders are in progress, identify affected formulas and inventory first. Then decide whether reformulation, artwork revision, notification action or another documented step is needed for that destination. Keep batch and shipment decisions traceable to the reviewed rule.
Assign manufacturer, brand and local reviewer responsibilities
The manufacturer should provide controlled composition data, supplier evidence and a workable change notification process. The brand should define product positioning, intended use and claims, and ensure the artwork matches the approved review. The eligible local company or reviewer should confirm destination requirements and the appropriate local procedures. A purchase order should make these handoffs explicit so technical questions do not surface only after filling.
| Workstream | Lead role to agree | Required handoff |
|---|---|---|
| Formula identity and calculations | Manufacturer with ingredient suppliers | Controlled formula and supporting composition evidence |
| Product use and artwork | Brand owner with manufacturer | Agreed directions, claims and approved print master |
| Destination interpretation | Qualified local reviewer or responsible company | Documented annex review and implementation check |
| Change and batch release | Manufacturer, brand and local company | Approval record identifying formula, artwork and market |
Agree how commercially confidential information will be shared and who can answer authority questions. A brand does not need to circulate every manufacturing instruction to every distributor, but it does need a reliable route to the necessary evidence. Use the project contact page to begin a discussion with a clear product brief, target destinations and existing technical documents.
Turn the review into a controlled release process
| Stage | Action | Release evidence |
|---|---|---|
| 1. Define | Fix target markets, product type and intended exposure | Approved assessment brief |
| 2. Identify | Expand blends and resolve ingredient identity | Complete controlled composition record |
| 3. Assess | Read current entries, conditions and national implementation | Reviewed annex worksheet and open-issue log |
| 4. Align | Reconcile directions, warnings, artwork and safety evidence | Signed formula and artwork revisions |
| 5. Maintain | Screen supplier and regulatory changes before use | Change decision linked to affected batches |
Do not treat the first approval as permanent. A supplier substitution, revised blend composition, new application method or new target audience can change the assessment. Require the purchasing and production teams to flag substitutions before use. Review the impact on concentration calculations, warnings and safety evidence, then approve the change through the same controlled record. Preserve the earlier revision so a complaint or authority enquiry can be traced to the product actually sold.
Compliance with an ingredient entry is also only part of the product evaluation. The finished product still needs a suitable safety assessment and supporting quality evidence. A review should clearly distinguish a resolved ingredient question from an unresolved product safety or labelling question. Release only when the responsible teams have closed the issues relevant to the destination.
Frequently asked questions
Does absence from Annex II mean an ingredient is approved?
No. Check applicable restrictions, function-specific positive lists, identity, intended use and the finished product’s safety evidence. A negative-list search is one screening step.
Which ASEAN annex covers UV filters?
Annex VII covers permitted UV filters. Annex VI covers preservatives. Confirm the heading and the actual entry in the current ACD document rather than importing another system’s numbering.
Can the factory screen only the label ingredient list?
A label list is not a substitute for a quantitative technical formula and expanded blend information. The reviewer needs enough composition data to identify controlled substances and assess their finished-product contribution.
Does an updated annex create one deadline across ASEAN?
Do not assume that. Check destination implementation and any transition notice, documenting which product activity and inventory it covers. Resolve unclear timing with the local reviewer before release.
When should a previously reviewed formula be checked again?
Recheck when relevant rules, raw materials, composition, intended use, claims, directions or destinations change. Maintain a planned source-monitoring process and document the decision for affected stock and future batches.
Last reviewed: 20 October 2026. This guide provides general project-planning information, not a product-specific legal or safety determination. Confirm the current official requirements and destination implementation with a qualified reviewer before manufacturing, notification, import or sale.