Thailand Revises Cosmetic Ingredient Requirements: 7 Prohibited and 2 Restricted Ingredients Added, 3 Permitted Preservatives Deleted

On Feb. 28, 2022, Thailand’s Ministry of Public Health (MOPH) announced to amend the cosmetic ingredient standards in Cosmetic Act B.E. 2015. The amendments have taken effect from March 1, 2022. Many of which brings Thailand in line with the updates to ASEAN Cosmetic Directive (ACD) adopted by the past ASEAN Cosmetic Committee Meetings.

Details of the amendments are as follows (The text in red indicates a revision to the previous standards. Strikethrough indicates removal from the previous standards.):

1. List of Prohibited Ingredients for Use in Cosmetics ¹

• The exception conditions for the following two prohibited ingredients have been reduced from two to one.

• Seven prohibited ingredients have been newly added. They are:

1. Dibutyltin hydrogen borate (CAS No. 75113-37-0)

2. Paraformaldehyde (CAS No. 30525-89-4)

3. Methanediol; methylene glycol (CAS No. 463-57-0)

4. 1,2,4 -Trihydroxybenzene (CAS No. 533-73-3), when used as a substance in hair dye products

5. 4-Amino-3-hydroxytoluene (CAS No. 2835-98-5) when used as a substance in hair dye products

6. 2-[(4-Amino-2-nitrophenyl)-amino]-benzoic acid (CAS No. 117907-43-4) when used as a substance in hair dye products

7. Formaldehyde (CAS No.50-00-0)

Cosmetic stakeholders shall note that the manufacture, import, sell and distribution of new products containing the above nine prohibited ingredients shall comply with the notice from March 1, 2022. Products already existing on the market prior to that date are allowed with a 180-day grace period and shall follow the new requirements from August 28, 2022.

2. List of Restricted Ingredients for Use in Cosmetics ^{2, 3}

• The maximum concentration limit for the ingredient Piroctone Olamine in leave-on products has been raised from 0.1% to 0.5%.

• The entries of Formaldehyde (CAS No. 50-00-0) and Lead Acetate have been removed from the List of Restricted Ingredients for Use in Cosmetics and the labeling requirements associated with these ingredients were deleted accordingly.

  Cosmetic stakeholders who have manufactured, imported, or sold products that contain these two ingredients before March 1, 2022, shall comply with this new requirement within 180 days thereafter.

• Two new restricted ingredients (HEMA and DI-HEMA TRIMETHYLHEXYL DICARBAMATE) have been added, along with their labeling requirements. Notably, cosmetic stakeholders who already manufactured, imported, or sold products containing these ingredients before March 1, 2022, are allowed a one-year grace period to comply with the new requirements.

3. List of Preservatives Allowed for Use in Cosmetics ^{4, 5}

MOPH has also deleted three entries of ingredients from the List of Preservatives Allowed for Use in Cosmetics. Their labeling requirements were abolished accordingly. The deleted preservatives are:

• Formaldehyde (CAS No. 50-00-0) and Paraformaldehyde (CAS No. 30525-89-4)

• Thiomersal (CAS No. 54-64-8)

• Phenylmercuric salts, including borate (CAS No. 62-38-4 / 94-43-9)

Cosmetic manufacturers, importers, distributors, and retailers are all prohibited from using these ingredients as preservatives in new products from March 1, 2022. For products already existing on the market before February 28, 2022, they shall follow the new requirements from August 28, 2022.