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Thailand Updates the List of Restricted Cosmetic Ingredients and the List of Permitted Cosmetic Colorants

Jul 16, 2021
Winnie Xu
Thailand made several revisions to its cosmetic ingredient standards, including revising the use restrictions on two restricted tagetes ingredients, adding a new restricted tagetes ingredient, and issuing a new list of permitted colorants.

These revisions aim to align the Thai regulations with the updated ASEAN Cosmetic Directive.

On June 21, 2021, Thailand Food and Drug Administration issued three notices to amend the cosmetic ingredient standards in Cosmetic Act B.E. 2015, which came into force from June 22, 2021. Details of the latest amendments are as follows (The text in red indicates a revision or an addition to the previous standards. Strikethrough indicates removal from the previous standards.):

1. Amendments to the List of Restricted Cosmetic Ingredients

As per the notice, the use restrictions on the following two tagetes ingredients have been updated to include tagetes erecta in the requirements for combined use of tagetes.

Entry No.

Substance

Application Field

Previous Maximum

Concentration (w/w)

Current Maximum

Concentration (w/w)

199

Tagetes minuta flower extract (91770 -75 - 1)

 

Tagetes minuta flower oil (91770 -75 - 1 / 8016 -84 – 0)

Leave-on products

0.01%

(In case of combined use with Tagetes patula, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.01%)

0.01%

(In case of combined use with Tagetes patula or Tagetes erecta, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.01%)

Rinse-off products

0.1%

(In case of combined use with Tagetes patula, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.1%)

0.1%

(In case of combined use with Tagetes patula or Tagetes erecta, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.1%)

200

Tagetes patula flower extract (91722 -29 - 1)

 

Tagetes patula flower oil (91722 -29 - 1 / 8016 -84 - 0)

Leave-on products

0.01%

(In case of combined use with Tagetes minuta, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.01%)

0.01%

(In case of combined use with Tagetes minuta or Tagetes erecta, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.01%)

Rinse-off products

0.1%

(In case of combined use with Tagetes minuta, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.1%)

0.1%

(In case of combined use with Tagetes minuta or Tagetes erecta, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.1%)

Besides, a new entry of tagetes erecta flower extract/oil has been added to the List of Restricted Cosmetics Ingredients and the Standards for Warnings on Labels for Cosmetics Containing Restricted Ingredients. The basic information of the ingredient is listed below:

New Entry No.

Substance

Application Field

Maximum

Concentration (w/w)

Conditions

Warnings on the label

201

Tagetes erecta flower extract (90131 -43 - 4)

 

Tagetes erecta flower oil (90131 -43 - 4/ 8016 -84 - 0)

Leave-on products

0.01%

(In case of combined use with Tagetes minuta or Tagetes patula, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.01%)

  1. Alpha terthienyl (terthiophen) content in the extract/oil is not more than 0.35 %.

  2. Not allowed to be used in sunscreen products and products marketed for exposure to natural/artificial UV light.

-

Rinse-off products

0.1%

(In case of combined use with Tagetes minuta or Tagetes patula, the total combined content of Tagetes in ready for use preparation shall not exceed the maximum concentration limits of 0.1%)

Alpha terthienyl (terthiophen) content in the extract/oil is not more than 0.35 %.

-

Cosmetic stakeholders who had already manufactured, imported, or sold products containing the above three ingredients (No. 199-201) before the notices took effect shall comply with the new requirements by June 21, 2022.

2. Amendments to the List of Permitted Cosmetic Colorants

Apart from amendments to the restricted ingredients, Thailand has also issued a new List of Permitted Colorants. Compared with the previous colorant list, the new list removed the “Technical/Other Name(s)” column of permitted colorants, added two new entries for mica and carbon black (nano), and increased the use restrictions on carbon black and zinc oxide. 

Entry No.

Permitted Colorants

Field Of Application

Other Limitations or Requirements

Chemical Name

Technical/Other Name(s)

CI No.

Color

CAS No.

124

Mica


77019

Lustre

12001-26-2

All cosmetic products

-

129

Carbon black

Carbon Black Pigment Black 6 Pigment Black 7

77266

Black

1333-86-4 / 7440-44-0

All cosmetic products

Its purity is above 97% and it meets the following contamination requirements:

  1. Ash content ≤ 0.15%

  2. Total sulphur ≤ 0.65%

  3. Total PAH ≤ 500 ppb

  4. Benzo(a)pyrene ≤ 5 ppb

  5. Dibenz(a,h)anthracene ≤ 5 ppb

  6. Total As ≤ 3 ppm

  7. Total Pb ≤ 10 ppm

  8. Total Hg ≤ 1 ppm

129a

Carbon black (nano)


77266 (nano)

Black

1333-86-4 / 7440-44-0

All cosmetic products

  1. The maximum concentration in ready for use preparation is 10%.

  2. Not allowed to be used in applications that may lead to exposure of the user’s lungs by inhalation.

  3. Its purity is above 97% and it meets the following contamination requirements:

    3.1 Ash content ≤ 0.15%

    3.2 Total sulphur ≤ 0.65%

    3.3 Total PAH ≤ 500 ppb

    3.4 Benzo(a)pyrene ≤ 5 ppb

    3.5 Dibenz(a,h)anthracene ≤ 5 ppb

    3.6 Total As ≤ 3 ppm

    3.7 Total Pb ≤ 10 ppm

    3.8 Total Hg ≤ 1 ppm

  4. Primary particle size ≥ 20 nm

147

Zinc oxide

Flowers of Zinc Pigment White 4

77947

White

1314-13-2

All cosmetic products

Not allowed to be used in applications that may lead to exposure of the user’s lungs by inhalation.

Notably, cosmetic stakeholders who already manufactured, imported, or sold products containing ingredient No. 129 (carbon black) and ingredient No. 147 (zinc oxide) before the notices took effect are also allowed a one-year grace period to comply with the new requirements.

ChemLinked Comments

  • Thailand and other ASEAN member states have signed the Agreement on the ASEAN Harmonized Cosmetic Regulatory Scheme (AHCRS) to harmonize the cosmetic regulations and eliminate cosmetic trade restrictions within ASEAN countries. Therefore, Thailand’s cosmetic ingredient lists are periodically updated to align with the ASEAN Cosmetic Directive (ACD).

  • Thailand’s revisions to the three restricted tagetes ingredients are in line with part of the updates to the List of Restricted Ingredients (Annex III) under ACD adopted by the 32nd ASEAN Cosmetic Committee.

  • Thailand’s new colorant list is almost the same as the List of Colouring Agents Allowed for Use in Cosmetic Products (Annex IV) under ACD, with two minor differences in the use conditions for Carbon black and Carbon black (nano). According to ACD, the total mercury impurity in Carbon black and Carbon black (nano) shall not higher than 10 ppm, while in Thailand, it cannot be detected higher than 1 ppm.

*Chemlinked will team up with the leading law firm Tilleke & Gibbins to host a webinar on Aug 11th to specify the compliance requirements for exporting cosmetics to Thailand. Register for free and join now! 
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