Philippines FDA Proposes Regulatory Sandbox for Cosmetic Refilling Activities

On June 29, 2026, the Philippines Food and Drug Administration (FDA) released a draft introducing a regulatory sandbox for cosmetic and household product refilling activities. The draft, titled Guidelines of the Adoption of the Regulatory Sandbox for the Implementation of Regulations for the Licensing of Establishments Engaged in Refilling Activity of Certain Cosmetics and Household/Urban Hazardous Substances (HUHS) Products Amending Administrative Order No. 2024-0008, invites comments until July 24, 2026.¹

In May 2024, the Philippine FDA issued Administrative Order No. 2024-0008, establishing licensing guidelines for refilling activities involving cosmetics and HUHS products, with the aim of promoting the standardized development of refilling systems for such products. However, the implementation review found that existing licensing and operational restrictions may impose a higher compliance burden on micro, small, and medium-sized enterprises, and may also constrain the adoption of innovative refilling models.

In response, the Philippine FDA introduced a regulatory sandbox approach, allowing pilot testing under a controlled and time-bound framework to assess the feasibility of refilling models in a more flexible environment, and to support the refinement of future regulatory requirements.

Overview of the Regulatory Sandbox Tracks

To accommodate different business models, the regulatory sandbox is structured into two primary tracks—the FDA-led Track and the proponent-led Track—and operates on a 12-month duration. The former applies to standardized physical refilling stations, while the latter is designed for innovative or non-standard technological refilling models requiring case-by-case assessment.

A comparative overview of the two tracks is provided in the table below.