ASEAN's cosmetics market is rapidly growing, making it an increasingly important region for global brands. Regulatory frameworks are evolving alongside market demands, with ingredient restrictions being a critical compliance focus for regulators across member countries.
This article provides a clear overview of the ASEAN Prohibited Cosmetic Ingredients List (Annex II Part 1), outlines key categories of prohibited substances, and highlights important considerations for companies referencing the list.
The ASEAN Prohibited Cosmetic Ingredients List corresponds to Annex II Part 1: List of Substances Which Must Not Form Part of the Composition of Cosmetic Products under the ASEAN Cosmetic Directive. This list applies to all ASEAN member states, including Singapore, Indonesia, and Vietnam.
The ASEAN Cosmetic Committee (ACC) holds biannual meetings to update cosmetic regulations and related guidelines. ASEAN member states may directly adopt these updated regulations or incorporate them into their local legal frameworks to better oversee cosmetic product safety and compliance.
The most recent update to this prohibited ingredients list was finalized by the ASEAN Cosmetic Committee on July 2, 2025, involving revisions and additions to several substances, including 2-Ethylhexanoic acid and its salts, Benzophenone, 3-ethyl-2-[[(1-oxoallyl)oxy]methyl]-1,3-propanediyl diacrylate, 2,2-bis(acryloyloxymethyl)butyl acrylate, trimethylolpropane triacrylate, and Phenacetin.
*Click here to download the full list (version no.: 2025-1, 2nd July 2025)
The ASEAN Prohibited Cosmetic Ingredients List contains 1,714 substances that must not be used in cosmetic products across ASEAN member states. These include chemical substances (e.g., organic compounds, heavy metals and their compounds, pesticides, and insecticides), colorants, and natural ingredients or extracts derived from plants and animals.
Chemical Substances
This category includes organic compounds (e.g., Benzene), heavy metals and their compounds (e.g., Mercury), and pesticides or insecticides (e.g., Binapacryl).
Colorants
Certain colorants are restricted from use in ASEAN cosmetics. For example, CI 26100 may only be used in specific product types and under defined conditions.
Plant-derived Ingredients
Examples include Apocynum cannabinum L. (Indian hemp) and Atropa belladonna L. (deadly nightshade). For plant-derived substances not explicitly listed as prohibited, companies should verify permissibility with local regulatory authorities.
Animal- and human-derived Ingredients
These include Cantharis vesicatoria (blister beetle) and cells, tissues, or products of human origin. Some member states enforce additional restrictions due to religious or cultural requirements. In Indonesia, for example, ingredients must comply with halal standards. Other countries may require animal-derived substances to be declared on product labels, with bovine- and porcine-derived ingredients requiring the species to be specified.
When referring to the ASEAN Prohibited Cosmetic Ingredients List, companies should keep the following points in mind:
Due to ASEAN's unique structure, the ASEAN Cosmetic Committee develops and updates the list based on the specific circumstances of each member state. For example, the newly added prohibited substance No. 1722, Phenacetin, is currently banned in all ASEAN countries except Malaysia.
According to Article 6.1.b of the ASEAN Cosmetic Directive, ingredients that are technically unavoidable during manufacturing under Good Manufacturing Practice (GMP) conditions may be present, provided they comply with regulatory limits. For example, Furocoumarins (No. 358) in sunscreen products are limited to less than 1 mg/kg.
According to Article 6.1.c of the ASEAN Cosmetic Directive, certain prohibited substances may be permitted if regulatory conditions are met. For instance, Petrolatum (No. 904) can be used if the entire refining process is clearly understood and it is proven that the resulting substance is non-carcinogenic.
The ASEAN Prohibited Cosmetic Ingredients List is regularly updated based on assessments and discussions among ASEAN member states. Companies planning to export cosmetics to ASEAN markets should thoroughly verify their products against the prohibited ingredients specific to the target country. If any prohibited substances are identified, formulas should be promptly adjusted with safe alternatives to ensure both product safety and regulatory compliance.
ZMUni Compliance Centre offers comprehensive services to support cosmetic exports to ASEAN countries. For inquiries, please feel free to contact us at info@zmuni.com. Additionally, we will be hosting an online webinar on Thai cosmetic compliance on September 10th. Interested parties are welcome to register.
