A Foreign Investor’s Guide to Cosmetic Product Registration in Thailand

Cosmetic product registration is a must for any foreign investor who want to dip their toes into Thailand's beauty market. According to the US Department of Trade and Commerce, Thailand’s skincare market alone is valued at US$2.5 billion. This robust demand highlights Thailand's position as a significant player in the Southeast Asian beauty market. 

For foreign investors hoping to get a piece of Asia’s beauty frontier, navigating the Thai Food and Drug Administration (FDA) is essential for compliance and a successful market entry. In this article, we will learn about the process for cosmetic product registration in Thailand, highlighting key requirements and the process of importing foreign-imported goods. 

The Cosmetic Product Registration Process in Thailand

Cosmetic product registration in Thailand is governed by the Food, Drug, and Cosmetic Act which mandates all cosmetics be registered with the Thai FDA before they can be marketed. The primary goal of this regulation is to ensure consumer safety by verifying that products meet specific standards regarding safety, efficacy, and labeling. 

What are considered ‘Cosmetics’ by the Thai FDA?

According to Section 4 of the Cosmetics Act, B.E. 2558, a cosmetic product is defined as any product applied to the external parts of the human body, including teeth and oral mucous membranes, for purposes such as cleaning, beautifying, altering appearance, or preventing odors:

How to Register your Cosmetic Products in Thailand

Registering cosmetic products in Thailand is crucial to gain market access and ensure regulatory compliance. In the country’s competitive market, FDA-registered products are not only viewed as more credible by consumers, but failure to register can result in confiscation of unregistered products and potential legal penalties. 

Emerhub can help you navigate through all the FDA’s key steps for cosmetic product registration in Thailand:

1. Document preparation – our team will gather all necessary documents and submit all the following documents to the FDA:
   • Product Information – detailed information about the cosmetic product, including its formulation, intended use, and any claims made about its benefits.
   • Labeling information – Labels must comply with Thai regulations, including ingredient listings in both Thai and English, usage instructions, and any necessary warnings.
   • Safety Data – documentation demonstrating the safety of the product is required, including toxicological data or evidence from clinical studies and FDA-approved laboratories.
   • GMP Certification – manufacturers must comply with Good Manufacturing Practices (GMP) as stipulated by the Thai FDA. This ensures that products are consistently produced and controlled according to quality standards.
   • Free Sale Certificate – documentation issued from the origin country that verifies that goods are legally sold and distributed in the local market. It helps expedite the FDA approval process by giving Thai FDA authorities access to inspection reports and manufacturing processes. 
   • Power of Attorney – To register a product in Thailand as a foreigner, you must appoint a local representative to act on your behalf. This is often facilitated through an Importer of Record service.
2. Product Information – detailed information about the cosmetic product, including its formulation, intended use, and any claims made about its benefits.
3. Labeling information – Labels must comply with Thai regulations, including ingredient listings in both Thai and English, usage instructions, and any necessary warnings.
4. Safety Data – documentation demonstrating the safety of the product is required, including toxicological data or evidence from clinical studies and FDA-approved laboratories.
5. GMP Certification – manufacturers must comply with Good Manufacturing Practices (GMP) as stipulated by the Thai FDA. This ensures that products are consistently produced and controlled according to quality standards.
6. Free Sale Certificate – documentation issued from the origin country that verifies that goods are legally sold and distributed in the local market. It helps expedite the FDA approval process by giving Thai FDA authorities access to inspection reports and manufacturing processes. 
7. Power of Attorney – To register a product in Thailand as a foreigner, you must appoint a local representative to act on your behalf. This is often facilitated through an Importer of Record service.
8. Submission to Thai FDA – We will submit the complete application package to the Thai FDA for review including the application form. Following the approval, a thorough review of the product will be conducted by the FDA especially for “controlled” or “high-risk” cosmetics such as eye or alcohol-based products. The post-audit can take between 15 to 25 days or longer, depending on the complexity of the product and any additional information required from the applicant.

1. Approval Notification –  Once approved, we will provide you with a registration number and receipt that allows you to market your product in Thailand.
2. Post-Registration Compliance – After registration, your company must ensure ongoing compliance with several Thai regulations:
   • Renewal of Notification – The initial cosmetic notification is valid for three years. Companies must apply for renewal before the expiration date to maintain compliance and avoid interruptions in product availability. Emerhub can also help manage notification renewals to ensure that your product remains compliant with regulatory requirements to minimize risk and disruptions.
   • Advertising Regulations – when marketing your cosmetics, claims made about the product’s benefits should be substantiated and documented for inspection.
   • Record Keeping – detailed records of production, distribution, and any changes made to the product must be maintained for regulatory review.
3. Renewal of Notification – The initial cosmetic notification is valid for three years. Companies must apply for renewal before the expiration date to maintain compliance and avoid interruptions in product availability. Emerhub can also help manage notification renewals to ensure that your product remains compliant with regulatory requirements to minimize risk and disruptions.
4. Advertising Regulations – when marketing your cosmetics, claims made about the product’s benefits should be substantiated and documented for inspection.
5. Record Keeping – detailed records of production, distribution, and any changes made to the product must be maintained for regulatory review.

Our team can help gather all the necessary documentation, ensuring that you have everything in order for your registration process. With our comprehensive support, you can navigate the complexities of cosmetic product registration with confidence.

How to Import Cosmetic Products to Thailand

Importing cosmetic products to Thailand with an Import License

To import cosmetics into Thailand, foreign companies must navigate the complex regulatory landscape. You need to establish a registered company, obtain an FDA authorization, and secure an import license. Here’s an overview of the process:

1. Personal Verification – Importers must register for the personal verification system (Open ID) through the Thai e-Government portal.
2. Location Approval Request – You must submit a request for approval of the import location and cosmetic products to the Thai FDA or the Provincial Public Health Office.
3. Cosmetics Notification Application – You’ll need to file a cosmetics notification application with the FDA at least 15 days before the intended import date.
4. Payment of Fees – Pay applicable fees for the notification, which include:
   • 100 Baht per product
   • 900 Baht per formula (or 500 Baht for community enterprises registered with the Ministry of Agriculture).
5. 100 Baht per product
6. 900 Baht per formula (or 500 Baht for community enterprises registered with the Ministry of Agriculture).
7. e-Submission System – Request permission to access the cosmetic e-Submission system, which facilitates electronic communication with regulatory authorities.
8. Health Product Import Notification – request a health product notification (LPI) from the SKYNET and National Single Window system.
9. Customs Declaration – If importing directly, companies must create a goods declaration through the NSW system. You can Import cosmetics through one of the 52 authorized customs checkpoints designated for cosmetics imports by the Customs Department.

What is an Importer of Record (IOR)?

As an alternative, you can also use Emerhub’s Importer of Record (IOR) service to ensure compliance with local customs and regulations. Our IOR service handles all the necessary paperwork for importing goods into Thailand. For foreign investors, an IOR enables you to establish a local distribution company without needing to navigate the importation logistics.Our IOR’s responsibilities include: 

1. Customs Clearance – manages all aspects of customs clearance for imported goods.
2. Payment of Duties and Taxes – responsible for paying any applicable tariffs or taxes on behalf of the foreign company.
3. Documentation Management – Ensuring all import documentation is accurate and compliant with Thai laws is a primary responsibility.
4. Storage Solutions – many IOR service providers offer warehousing solutions for imported goods until they are ready for distribution.

Emerhub offers an Importer of Record (IOR) service that acts as your consignee, managing the entire import process through our established logistics network. This allows companies to start importing cosmetics virtually immediately without an import license. We’ll also handle any and all issues regarding customs clearance.

Are you planning to expand into Thailand’s cosmetics industry? Contact Emerhub via the form below to get in touch with our product registration experts!