Singapore's beauty and personal care market is poised for sustained growth, with projected revenues estimated to have reached US$1,244 million in 2024, according to the International Trade Administration1.
For instance, the local aesthetics industry is thriving, fueled by a societal shift towards inclusive and technologically advanced beauty solutions, such as personalized skincare regimes. These trends reflect a broader consumer emphasis on holistic wellness and self-care, intensified by the global pandemic, which localized demand due to travel restrictions2.
However, as more businesses and entrepreneurs rush to capitalize on this expanding market, they face the intricate challenge of adhering to stringent import regulations and safety standards, particularly for products classified as dangerous goods.
As such, navigating the regulatory landscape requires a meticulous understanding of the Health Sciences Authority (HSA) mandates, which govern the import and sale of cosmetic products in Singapore. This is especially important since every cosmetic product introduced into the market must undergo a thorough registration process with HSA to ensure compliance with national health and safety standards.
So, how do you go about importing cosmetics into Singapore while still complying with all the cosmetic import regulations to ensure your business operates smoothly within legal boundaries?
What is a cosmetic product?
But first, to navigate the regulatory landscape of Singapore’s cosmetic market, one must understand what constitutes a cosmetic product3.
Defined broadly, cosmetic products are substances or mixtures intended for external use on various parts of the body—such as skin, hair, nails, lips, and teeth. Their purposes range from cleansing, perfuming, and enhancing appearance to protecting or maintaining them in good condition.
It’s, however, crucial to note that cosmetic products are distinct from medical or therapeutic goods like injections or treatments, and they don't include items ingested orally.
And as mentioned, in Singapore, all cosmetic products must adhere to strict safety regulations and require a formal notification before they can be distributed or sold. In this case, the HSA plays a pivotal role in this process, ensuring that all cosmetics meet stringent health and safety standards.
This oversight helps maintain the high quality of cosmetic products available in the market, safeguarding consumer interests and fostering trust in Singapore's beauty sector.
Cosmetic products regulatory requirements
Before any cosmetic product can hit the market in Singapore, manufacturers and importers must notify the HSA about their products. This essential step is conducted through the Product Information Management System (PRISM), a platform akin to the European Union's Cosmetic Products Notification Portal (CPNP).
The notification process is not just a formality but a critical step done after ensuring that all cosmetic products comply with the stringent standards set by the ASEAN Cosmetic Directive (ACD)4.
This directive establishes a harmonized set of rules across ASEAN member states aimed at simplifying the regulatory obligations for cosmetic products. It ensures that all cosmetic products comply with unified standards that include prohibiting certain harmful substances and enforcing stringent safety protocols for labeling, claims, and ingredient disclosure.
Understanding dangerous goods in cosmetics
As a supplier of cosmetic products, you inevitably carry the responsibility for their safety and quality. This includes having efficient systems to manage, report, and address any adverse effects or defects directly to the HSA of Singapore.
However, suppliers are not only responsible for the quality and safety of their products since certain products may also face strict prohibitions if deemed hazardous when exporting to or importing into Singapore.
For instance, in cosmetics, items such as perfumes, aftershave, and nail polish removers are often categorized as dangerous goods since they fall under the category of Flammable Liquids. Shipping these dangerous goods requires careful handling during transportation to prevent accidents and ensure compliance with safety standards.
Importing dangerous goods: Regulations and compliance
And as always, all imports into Singapore require detailed documentation to facilitate customs clearance. When shipping with DHL Express, this includes a:
- Waybill: Complete & accurate goods descriptions and the total value and currency code must be indicated.
- Commercial invoice: Specifying details such as the importer/exporter of record, harmonized system (HS) codes, country of origin, and line-item value. Notably, proforma invoices are not accepted by Singapore Customs.
For importing controlled goods like cosmetics containing hazardous substances, obtaining proper authorization from the relevant Competent Authorities (CA) before shipment is crucial. Importers must possess an import license or authorization and present it during customs clearance to avoid potential retention of the items by the authorities5.
Proper labeling, packaging, and documentation are also paramount to ensure the safe transportation of these goods. Each item must be securely packed to prevent any spillage, with robust internal measures to handle contingencies.
Additionally, shipments must be accurately labeled with the type and hazards of the dangerous goods and accompanied by a Dangerous Goods Declaration (DGD), along with the aforementioned detailed shipping invoice and the Air Waybill.
Resources for detailed information on importing dangerous goods:
Importing cosmetics into Singapore: A step-by-step guide
To import cosmetics into Singapore, whether you operate a thriving e-commerce platform or are starting a small home-based business, understanding the local regulatory framework is crucial.
To navigate through the process of successfully shipping these overseas to Singapore and ensure your products meet the country's stringent standards, especially those listed on the dangerous goods list, consider the following steps:
1. Determine if the product meets the definition of cosmetics
In Singapore, a product is considered a cosmetic product if it is intended for external use on the body, including the skin, hair, nails, lips, and teeth6.
The main purposes of these cosmetic products are to clean, perfume, change appearance, correct odors, protect, or keep in good condition. This includes items such as skin creams, shampoos, makeup, and toothpaste.
Some of the products that fall under the cosmetics category in Singapore include:
- Skincare products like creams, lotions, and facial masks.
- Haircare products include hair tints, conditioners, and styling solutions.
- Makeup items for the face, lips, and eyes.
- Perfumes, deodorants, and antiperspirants.
- Nail care products and sunbathing cosmetics.
Conversely, several products do not meet the cosmetic definition and are regulated under different frameworks. Some of these include:
- Oral supplements aimed at beauty enhancement.
- Injectable products such as fillers.
- Medical devices and therapeutic goods like eczema creams or acne treatments.
- Essential oils used primarily for therapeutic purposes, not as part of beauty regimens.
- Products like insect repellents, hand sanitizers, and detergents, which are regulated under health or chemical safety standards.
2. Consider if the manufactured product meets specifications and testing criteria
Before submitting a cosmetic product notification in order to sell it in Singapore, it is imperative to ensure that your offerings not only meet the aesthetic desires of consumers but also adhere to stringent regulatory standards. This commitment to compliance begins with verifying that all ingredients conform to the Annexes of the ASEAN Cosmetic Directive7, which lists prohibited substances, permissible colorants, preservatives, and UV filters.
For instance, certain ingredients and substances8 like Propyphenazone (INN) and Metethoheptazine (INN) and their salts, amongst many others, are explicitly banned under these regulations.
Equally important is compliance with labeling requirements9. Every cosmetic product must accurately disclose:
- The product’s name and function.
- Usage instructions.
- A comprehensive list of ingredients.
- The country of manufacture.
- Net contents in terms of weight or volume.
- A batch number for traceability.
- The manufacturing or expiry date.
- Contact details of the responsible company in Singapore.
- Any necessary precautions (especially those listed in Annex III, VI, VII in the ASEAN Cosmetic Directive).
The labeling must also be clear, truthful, and in English to ensure that all potential users can understand the product details and usage guidelines.
For example, labels that state "for professional use only" designate products that are intended exclusively for use by professionals in settings like hair salons, nail salons, spa salons, and skin clinics. Such labeling restricts the sale of these products directly to consumers, emphasizing that these items require application by individuals with specialized training and a deep understanding of the product's use and potential risks.
Moreover, cosmetic products must not make misleading claims about their benefits. This means that claims must strictly relate to the product’s observed effects and not imply medical or therapeutic benefits.
Furthermore, to preemptively address potential health risks, it’s recommended that local testing for contaminants and adulterants be conducted10, even if test reports are provided by the manufacturer. Such testing is crucial for products like teeth whiteners or skin-lightening creams, where the presence of heavy metals can pose significant health risks. Ensuring that your products meet the stringent heavy metal limits specified in the ASEAN Guidelines on Limits of Contaminants for Cosmetics is vital for market compliance and consumer safety.
If exporting out of Singapore, cosmetic product manufacturers are not obligated to obtain a manufacturer's license. Nonetheless, manufacturers have the option to secure a voluntary Good Manufacturing Practice (GMP) certificate, which can aid in the exportation of their cosmetic products. Adoption of the GMP as outlined in ISO 22716:2007 ensures consistency in product quality and safety. This standard covers the manufacturing, control, storage, and shipment of cosmetic products.
3. Essential items to be kept on-site
Importers must also maintain three critical types of documentation on-site to meet regulatory obligations and safeguard consumer safety:
- Product Information File: This comprehensive file should include all quality and safety records for each cosmetic product, ensuring adherence to the relevant standards. Regular updates are required to stay current, especially in terms of the manufacturing level specifics that could affect product safety.
- Records of Cosmetic Supply11: Documentation of the cosmetic products supplied in the market should be kept for at least two years after the date of supply. This must include details such as the product’s name, notification number, supplier’s information, and records of batch numbers, dates, and quantities distributed.
- Monitoring and Incident Reporting12: Importers must actively monitor and report any adverse events or product defects to the HSA. This includes the obligation to execute prompt product recalls if necessary. Reporting must occur within seven days for serious adverse events and within 15 days for those resulting in hospitalization or significant disability.
Navigating the cosmetics import compliance labyrinth
