Thailand Proposes Amendments to the Lists of Prohibited Ingredients and Permitted Preservatives

Thailand proposes to release a new list of prohibited ingredients for use in cosmetics and amend the use requirements for two permitted preservatives, so as to bring its regulations further in line with the updated ASEAN Cosmetic Directive.

On September 5, 2022, the Thai Food and Drug Administration (Thai FDA) launched a 15-day public consultation on three draft notifications, planning to revise the requirements for prohibited ingredients and permitted preservatives in cosmetics.¹

The proposed revisions are summarized as follows:

1. Issuing a new list of 1,610 prohibited ingredients to replace the current list, which was first published in 2016. The new list compiles all the updates made from 2016 to 2022 by Thai FDA to the 2016 version and adds 220 additional prohibited ingredients.

Below is an excerpt of the newly added prohibited ingredients. The complete list is available here.

Ref No.	Ingredients Prohibited from Use in Cosmetics (Excerpt)	CAS No.
1391	Silver nitrate, except for use in export-only black hair dye cosmetics, manufacturers or importers are prohibited from selling all kinds of cosmetics containing silver nitrate for export only in Thailand.	7761-88-8
1392	Cis-1-(3-chloroallyl)-3,5,7-triaza-1-azoniaadamantane chloride (cis-CTAC)	51229-78-8
1393	2,2'-((3,3',5,5'-Tetramethyl-(1,1'-biphenyl)-4,4'-diyl)-bis(oxymethylene))- bis-oxirane	85954-11-6
1394	1-Cyclopropyl-6,7-difluoro-1,4-dihydro-4-oxoquinoline-3-carboxylic acid	93107-30-3
1395	Diboron trioxide; boric oxide	1303-86-2
1396	Nickel bis(tetrafluoroborate)	14708-14-6

2. Revising the use requirements for the permitted preservative polyaminopropyl biguanide.

	Ref No.	Substances			Maximum Authorized Concentration	Conditions
	Ref No.	Chemical Name	Name of Common Ingredients Glossary	CAS No.	Maximum Authorized Concentration	Conditions
Before revision	26	Poly(1-hexamethylenebiguanide hydrochloride) Poly(methylene),.alpha.,.omega.-bis[[[(aminoiminomethyl)amino]iminomethyl]-amino], dihydrochloride	Polyaminopropyl biguanide	70170-61-5/ 28757-47-3/ 133029-32-0	0.3%	-
After revision	26	Poly(1-hexamethylenebiguanide hydrochloride) Poly(methylene),.alpha.,.omega.-bis[[[(aminoiminomethyl)amino]iminomethyl]-amino], dihydrochloride], dihydrochloride	Polyaminopropyl biguanide	32289-58-0 / 27083-27-8 / 28757-47-3 / 133029-32-0	0.1%	Not to be used in applications that may lead to exposure of the end-user's lungs by inhalation
Notes: The added information and requirement are marked in red, and the deleted information are marked with strikethrough.

3. Adding a new permitted preservative hydroxyethoxyphenyl butanone (HEPB).

Ref No.	Substances			Maximum Authorized Concentration	Conditions	Warnings on the Label
	Chemical Name	Name of Common Ingredients Glossary	CAS No.
57	4-(3-ethoxy-4-hydroxyphenyl)butan-2-one	Hydroxyethoxyphenyl Butanone	569646-79-3	0.7%	-	-

Chemlinked Comments

Thai FDA’s proposed addition of 220 prohibited ingredients to its new prohibited ingredients list is in line with part of the updates on the prohibited ingredients list in the ASEAN Cosmetics Directive (ACD) adopted at the 34^th ASEAN Cosmetic Scientific Body (ACSB) meeting. The updates to the preservatives list in ACD adopted at the 35^th ACSB meeting serve as the reference for the proposed revisions to the use requirements for the two permitted preservatives.

It is also worth noting that Thailand and ASEAN have slightly different requirements for using the banned ingredient silver nitrate. Thailand has added some additional requirements, stipulating that "this ingredient is allowed to be used in hair dye cosmetics for export only, but manufacturers or importers are prohibited from selling all kinds of cosmetics containing silver nitrate for export only in Thailand’s market”.