Exporting Cosmetics to the Philippines: FDA Notification and Labels

Who can notify: a licensed Philippine company

RA 9711 and its implementing rules prohibit importing, selling or distributing a health product, cosmetics included, without the FDA authorisation it requires. For a cosmetic, that authorisation is the CPN, issued under the ASEAN notification scheme that the Philippines adopted through DOH Administrative Order 2005-0015.

Only a company registered to do business in the Philippines can notify, and the FDA accepts applications only from licensed cosmetic establishments: a distributor (importer, exporter or wholesaler), a trader or a manufacturer with an LTO from the FDA's Center for Cosmetics and Household/Urban Hazardous Substances Regulation and Research (CCHUHSRR). A foreign brand therefore appoints a Philippine importer or distributor, or sets up its own Philippine company. The FDA citizen's charter lists an initial LTO for a cosmetics distributor at PHP 3,000 plus a 1% legal research fee (LRF). Licensing rules were revised by DOH AO 2024-0015, in force since 12 January 2025.

The company that files becomes the marketing authorisation holder (MAH). Its name and address go on the label, and it keeps the product information file. A change of company needs a new notification, so agree in the distribution contract who holds the CPNs and what happens if you change importer.

Filing in the ePortal: fees, timing and renewal

The MAH files each product online in the FDA ePortal. Under FDA Circular 2025-006, user accounts are now registered and renewed online through the FDA eServices platform. The form covers the brand and product name, variants or shades, product type, intended use, presentation, the manufacturer and the full ingredient list.

The FDA citizen's charter (2025) lists PHP 500 per year of validity, so PHP 500, 1,000 or 1,500 for 1, 2 or 3 years, plus PHP 100 for each additional variant and a 1% LRF of at least PHP 10. Payment is by LinkBiz, Bancnet or over the counter, and the total processing time is about 23 working days. A new FDA fee schedule (DOH AO 2024-0016) has been suspended since June 2025, most recently extended by Department Circular 2026-0329, so check the amount on the payment order.

A CPN can be revalidated only on or before its expiry date, and only if nothing in the original notification has changed (FDA Advisory 2023-1160). After expiry you must file a new application. A change of brand or product name, formula, product type, intended use or manufacturer also needs a new notification. Acceptance of a notification does not mean the FDA has confirmed that the product complies; the MAH remains responsible.

What the brand owner supplies

The filing itself needs the importer's LTO and the product data, but the FDA can ask for more before it decides: label artwork, instructions for use, the product's mechanism of action, a certificate of origin for the product or its ingredients, safety data sheets and certificates of analysis. Have these ready before the importer files.

The product information file (PIF) must also be in place. Under FDA Circular 2023-001, Part I holds a copy of the MAH's LTO, the distribution agreement, a foreign agency agreement or letter of authorisation from the supplier or manufacturer, and the CPN. Parts II to IV hold quality data for raw materials and the finished product, and a signed safety assessment. The PIF is written in English and/or Filipino.

The FDA citizen's charter does not list a Certificate of Free Sale or a GMP certificate for notification. Some importers still ask for them, so confirm their list before you order documents.

Ingredients: the ASEAN annexes and FDA circulars

The Philippines applies the ASEAN Cosmetic Directive (ACD) annexes and adopts each update by FDA circular. FDA Circular 2025-002 adopted the changes from the 39th ASEAN Cosmetic Committee (ACC) meeting. FDA Circular 2026-0001, issued in May 2026, consolidated the 40th to 42nd ACC amendments, with compliance dates running from 2026 to 2028. Check each formula against the current annexes:

Products are also checked against the ASEAN limits for contaminants: mercury 1 ppm, lead 20 ppm, arsenic 5 ppm and cadmium 5 ppm. FDA advisories have repeatedly named skin-lightening products containing mercury, so test for heavy metals before you notify.

• Prohibited substances (ACD Annex II)
• Restricted substances and their conditions (Annex III)
• Permitted colourants (Annex IV)
• Permitted preservatives (Annex VI)
• Permitted UV filters (Annex VII)
• ASEAN limits for heavy metals and microbes

Labels in English or Filipino

The Philippines follows the ASEAN Cosmetic Labeling Requirements. The items below must appear in English and/or the national language (Filipino) or another language understood by consumers. On very small packs, only the product name and batch number must be on the immediate container; the other items can go on the outer pack or a leaflet.

The ASEAN list does not include the notification number. Buyers, platforms and inspectors check a product by name in the FDA Verification Portal, so the brand and product name on the pack must match the CPN exactly. Misbranding is a prohibited act under RA 9711.

• Product name and function, unless clear from the presentation
• Instructions for use, unless clear from the name
• Full ingredient list in descending order of weight
• Country of manufacture
• Name and address of the company placing the product on the Philippine market
• Contents by weight or volume (metric, or metric and imperial)
• Batch number
• Manufacturing or expiry date
• Special precautions

Customs, online sales and duties after launch

At import, the Philippines' WTO import-licensing notification lists two authorisations: the importer's LTO and the product's CPN. The importer must also be accredited with the Bureau of Customs (BOC). Under the 2015 DOH-FDA-BOC Joint Circular, cosmetics above personal-use quantities that lack FDA clearance are seized and forfeited. Keep product names on the commercial invoice and packing list identical to the CPN; Triplicate's free generator makes both, and its HS code lookup helps with classification.

Online sales follow the same rules: a cosmetic sold to Philippine consumers needs a CPN, whoever sells it. Under the Internet Transactions Act (RA 11967), fully enforced since 20 June 2025, e-marketplaces must bar regulated goods unless the seller provides the permit and licence details. The FDA regularly warns the public against unauthorised cosmetics found in post-marketing surveillance, for example in FDA Advisory 2026-1153 of 16 September 2026, and asks local governments and law enforcement to keep them off the market. Under RA 9711, manufacturers, importers and distributors face 5 to 10 years' imprisonment and fines of PHP 500,000 to PHP 5,000,000.

After launch, the MAH keeps the PIF at the address declared in the CPN for at least 3 years after the product was last placed on the market, including records of undesirable effects. The FDA audits PIFs with one month's notice, or without notice after complaints or adverse events; critical findings must be corrected within 30 days and major ones within 60.