All cosmetics sold on the ASEAN market shall comply with the cosmetic regulation “ASEAN Cosmetic Directive” (ACD) as well as the ingredient lists attaching to it, which include:

1) Annex II: List of Substances Which Must Not Form Part of the Composition of Cosmetic Products

2) Annex III: List of Substances that Cosmetic Products Must Not Contain Except Subject to Restrictions and Conditions Laid Down

3) Annex IV: List of Colouring Agents Allowed for Use in Cosmetic Products

4) Annex VI: List of Preservatives Which Cosmetic Products May Contain

5) Annex VII: List of UV Filters Which Cosmetic Products May Contain

The ASEAN Cosmetic Committee (ACC) and ASEAN Cosmetic Scientific Body (ACSB) meet twice a year, discussing regulation amendments across the region to reduce the technical trade barriers, which include the amendments to the ingredient lists attaching to the ACD. Therefore, the ingredient lists update at least twice a year. Cosmetic companies need to make sure that their products comply with the most up-to-date regulatory requirements. ChemLinked will keep tracking the changes to these lists. Please stay tuned to get the updates.

In the 38th ACSB meeting held in Novebmer 2023, ASEAN amended the cosmetic ingredient lists, including 

- adding 15 entries to the prohibited ingredients list and 2 entries to the permitted UV filters list;

- revising 5 entries in the restricted ingredients list, 1 entry in the permitted colorants list, and 1 entry in the permitted UV filters list, as well as

- deleting 1 entry from the permitted preservatives list.

Additional details are available here.

The ACD as well as its ingredient lists apply to all Member States. However, when imposing the Directive, it is required to transpose it into the national law of each Member State appropriately. As a result, it is possible to see that the use requirement for an ingredient is not exactly the same for all ASEAN Member States. Take Formaldehyde as an example. It is a prohibited ingredient regulated by the ACD, while based on the latest ingredient lists (the lists updated in the 34th ACSB meeting), it is permitted for use in Lao PDR. Considering the potential difference in the supervision of cosmetic ingredients among the Member States, before placing products on the ASEAN market, cosmetic companies need to check the ingredient requirements of the Member State where the product will be sold to ensure compliance.

The way that ASEAN regulates ingredients is inspired by the EU. ASEAN adopted the ingredient lists of the “EU Cosmetic Directive 76/768/EEC” as well as the regulations that followed, and updates the lists with reference to the changes adopted by “EU Cosmetic Regulations”. However, the ingredient lists of these two regions are not exactly the same. For example, the fragrance allergens identified in the “EU Cosmetics Regulation” are not transposed to the ACD. In addition, the restrictions for whitening ingredients are stricter in ASEAN than in the EU.

Heavy metals and microorganisms are not included in the ASEAN cosmetic ingredients regulatory database. But in the production process of cosmetics, there are restrictions on these substances. Please refer to specific lists under Cosme-list for more details about these limit requirements.

Category 1 material shall comprise the following animal by-products:

1) Entire bodies and all body parts, including hides and skins, of the following animals: (i) Animals suspected of being infected by a Transmissible Spongiform Encephalopathy (TSE) or in which the presence of a TSE has been officially confirmed; (ii) Animals killed in the context of TSE eradication measures; (iii) Animals other than farmed and wild animals, including in particular pet animals, zoo animals and circus animals; (iv) Animals used for experiments; (v) Wild animals, when suspected of being infected with diseases communicable to humans or animals;

2) Specified risk material, or entire bodies or parts of dead animals containing specified risk material at the time of disposal;

3) Animal by-products derived from animals which have been submitted to illegal treatment;

4) Animal by-products containing residues of other substances and environmental contaminants, if such residues exceed the permitted level laid down by national legislation;

5) Animal by-products collected during the treatment of waste water;

6) Catering waste from means of transport operating internationally;

7) Mixtures of Category 1 material with either Category 2 material or Category 3 material or both.

Category 2 material shall comprise the following animal by-products:

1) Manure, non-mineralized guano and digestive tract content;

2) Animal by-products collected during the treatment of waste water;

3) Animal by-products containing residues of authorized substances or contaminants exceeding the permitted levels laid down by National legislation;

4) Products of animal origin which have been declared unfit for human consumption due to the presence of foreign bodies in those products;

5) Animals and parts of animals: (i) that died other than by being slaughtered or killed for human consumption, including animals killed for disease control purposes; (ii) Fetuses; (iii) Oocytes, embryos and semen; and (iv) Dead-in-shell poultry;

6) Mixtures of Category 2 material with Category 3 material;

7) Animal by-products other than Category 1 material or Category 3 material.

Category 3 material shall comprise animal by-products other than those described in Category 1 or Category 2, including:

1) Bristles;

2) Feathers;

3) Ruminants which have been tested for TSE, with a negative result;

4) Blood, placenta, wool, feathers, hair, horns, hoof cuts and raw milk originating from live animals that did not show any signs of disease communicable through that product to humans or animals;

5) Aquatic animals, and parts of such animals, except sea mammals, which did not show any signs of disease communicable to humans or animals;

6) Animal by-products from aquatic animals originating from establishments or plants manufacturing products for human consumption;

7) The following material originating from animals which did not show any signs of disease communicable through that material to humans or animals: (i) Shells from shellfish with soft tissue or flesh; (ii) The following originating from terrestrial animals: hatchery by-products, eggs, egg by-products, including egg shells;

8) Aquatic and terrestrial invertebrates other than species pathogenic to humans or animals.