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Thailand Reports a Non-Compliant Batch of Imported Cosmetics with Microbiological Violations

Under the Cosmetic Act B.E. 2558 (2015) (the Cosmetic Act 2015), Thailand’s overarching cosmetic regulation, the Thai Food and Drug Administration (Thai FDA) has been empowered to release the findings of any inspection or analysis of cosmetics not in compliance, or suspected of non-compliance, with the Act.

On July 26, 2024, the Thai FDA announced that a batch of hair dye product imported from India had failed inspection due to significant microbiological contamination. The batch was found to contain Clostridium spp., a harmful microorganism, as well as excessive bacterial counts. Specifically, the total bacterial count in the affected batch were 520,000 colony-forming units per gram (CFU/g), far exceeding the legal limit of 1,000 CFU/g set by Thai cosmetic regulations.

Thailand’s Cosmetic Microbial Standards

According to the 2016 Announcement of the Ministry of Public Health Regarding Determination of Characteristics of Cosmetics Prohibited for Production, Import, or Sale, cosmetics containing pathogenic microorganisms such as Pseudomonas aeruginosa, Staphylococcus aureus, Candida albicans, and Clostridium spp. (limited to cosmetics products containing herbal ingredients) are prohibited from production, import and sale. Cosmetic products designed for use around the eyes, mucous membranes, or children under three years old must not exceed a total bacterial count of 500 CFU/g or CFU/ml. For all other cosmetics, the limit is set at 1,000 CFU/g or CFU/ml.

Under the Cosmetic Act 2015, manufacturers or importers of cosmetic products violating these microbial limits is subject to imprisonment for a period not exceeding 2 years, a fine not exceeding 200,000 baht, or both. Retailers selling such non-compliant cosmetics may face up to 6 months of imprisonment or fines up to 50,000 baht, or both.

Companies exporting cosmetics to Thailand must strictly adhere to these microbial standards to avoid relevant legal and financial repercussions.

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