Exporting Cosmetics to Malaysia: NPRA Notification, Labels and Halal

Who notifies: the Cosmetic Notification Holder

Regulation 18A bans the manufacture, sale, supply, import or possession of a cosmetic that is not notified. The notification is filed by the Cosmetic Notification Holder (CNH), the company responsible for placing the product on the market. The CNH must be a locally incorporated company or legal entity in the field of cosmetics, with a permanent address, registered with the Companies Commission of Malaysia (SSM). A foreign brand therefore appoints a Malaysian importer, distributor or subsidiary.

The product owner issues a Letter of Authorisation (LOA) that lists the products or brands and authorises the CNH to notify them and handle all notification matters. If the CNH owns the brand, it gives a Letter of Declaration instead; contract-manufactured products also need the appointment and acceptance letters between owner and manufacturer.

The notification belongs to the CNH. Under Annex I Part 5, a change of company because distribution rights change needs a new notification, while a change of importer or distributor listed in the file is only an amendment. Agree in the distribution contract what happens to the notifications if you part ways.

Filing in QUEST3+: fee, timing and renewal

The CNH first registers as a QUEST3+ member. Access uses a digital certificate on a USB token; Annex I Part 3 (August 2022) lists RM 260 for one year or RM 290 for two years for a main user, so confirm the current charge. Since 8 July 2026 members can also log in with MyTrustID in Chrome, Firefox or Edge, and the older Java login remains available.

Each product and each variant is filed separately, with product particulars, manufacturer and assembler, importer, formula and label. The processing fee is RM 50 per product or variant and is not refundable. Once NPRA confirms payment, the CNH can print the Notification Note from QUEST3+ straight away if all requirements are met. NPRA checks compliance after launch, through sampling and testing, GMP audits and PIF audits.

The number reads NOTyymmxxxxxK (year, month, serial number). A notification is valid for 2 years; renew no later than 1 month before expiry, for another RM 50, to keep the same number. A product not renewed in time gets a new number. A new brand name, product name, formula, manufacturer, product type or intended use also needs a new notification.

What the brand owner supplies

Send the CNH the LOA, the full ingredient list by INCI name, label artwork and evidence of GMP. The QUEST3+ manual makes percentages mandatory for substances listed in Annexes III to VII (restricted substances, colourants, preservatives and UV filters), and makes it mandatory to attach a GMP certificate or equivalent for a foreign manufacturer or primary assembler. The guideline says GMP evidence must be issued or endorsed by an authorised body in the country of manufacture.

The CNH must also hold a Product Information File (PIF) in four parts: administrative documents and product summary, quality data of raw materials, quality data of the finished product, and safety and efficacy data, including a safety assessment. Most of this comes from you or your manufacturer, so prepare it before filing.

The guideline and the QUEST3+ manual do not list a Certificate of Free Sale for notification. Some importers still ask for one or for notarised copies, so confirm their list before you order documents.

Ingredients: ASEAN annexes and 2025–2026 updates

Malaysia adopts the ASEAN Cosmetic Directive annexes and announces each update by NPRA circular. The current NPRA files for Annexes II, III, IV and VI are dated 10 June 2026 and Annex VII 12 December 2025. Heavy metals must not exceed mercury 1 ppm, lead 20 ppm, arsenic 5 ppm and cadmium 5 ppm (Annex I Part 14).

Recent circulars with deadlines: Circular 3/2024 (December 2024) added substances such as benzophenone to the prohibited list and set BHT limits, with compliance due by 19 November 2026. Circular 1/2025 (July 2025) prohibited 2-ethylhexanoic acid and trimethylolpropane triacrylate and restricted salicylic acid.

Circular 1/2026 (January 2026) prohibited miconazole at once and 4-methylbenzylidene camphor (4-MBC), with products to comply by 17 November 2028. Circular 2/2026 (6 July 2026), after the 43rd ASEAN Cosmetic Committee meeting, added 16 prohibited substances, including several antifungals, set limits for kojic acid and changed colourant and preservative entries. Check its transition dates in the circular itself. A reformulated product needs a new notification.

• Annex II: prohibited substances
• Annex III: restricted substances, with limits and conditions
• Annex IV: permitted colourants
• Annex VI: permitted preservatives
• Annex VII: permitted UV filters
• Annex I Part 8: claims guideline (no medicinal claims)

Labels in Bahasa Malaysia or English

Label information must be in Bahasa Malaysia and/or English, easily legible and indelible (Annex I Part 7). The outer pack, or the container if there is no outer pack, shows the items below. Ingredients go in descending order of weight; those under 1% may follow in any order, and botanicals are named by genus and species.

On a container too small for everything, only the product name and batch number are required; the rest can go on the outer pack, a leaflet or a tag. Part 7 does not list the notification number as a label item; buyers can check a product's status in NPRA's QUEST3+ product search. A halal logo may be used only on a product certified by JAKIM or an Islamic body recognised by JAKIM.

• Product name and function
• Directions for use, unless clear from the name
• Full ingredient list
• Country of manufacture
• Name and address of the CNH
• Contents by weight or volume (metric)
• Batch number
• Manufacturing or expiry date; expiry date required if durability is under 30 months
• Special precautions, if any

Import, halal and duties after launch

NPRA does not issue a separate import licence or per-shipment permit for notified cosmetics: under the guideline the CNH may import once it has the Notification Note. Ship only after that, and keep product names identical on the notification, commercial invoice and packing list; Triplicate's free invoice and packing list generator and HS code lookup can help. Customs duty and sales tax are assessed at import on the HS code.

Halal certification is not required for cosmetics. If you want a halal logo, use a certificate from JAKIM or a foreign halal certification body on JAKIM's recognised list (last updated 21 August 2026), because only certified goods may be described as halal.

After launch the CNH keeps the PIF at the address on the label; NPRA recommends keeping it for at least 3 years after the product was last on the market, and asks for the technical parts within 15 to 60 calendar days, or sooner if urgent. It reports serious adverse events within 7 calendar days if fatal or life-threatening and within 15 days otherwise, keeps distribution records, and informs NPRA at least 24, 48 or 72 hours before starting a recall, depending on its degree. NPRA can cancel a notification; its 2025–2026 cancellations were for mercury, hydroquinone, tretinoin or betamethasone 17-valerate.