Labelling a cosmetic for Singapore

Singapore requires nine things on a cosmetic label, in English, and one of them is the name and address of the local company responsible for placing the product on the market. That last one is what forces a relabel, because it cannot be your Indonesian address. Get the label right before you print, not after — a reprint is the slowest and most expensive step in a cosmetic launch.

• Nine mandatory particulars, in English. Other languages may be added and must say the same thing.
• The local responsible party's name and address goes on the pack. That is the relabel trigger.
• Ingredients in descending order of weight, using standard nomenclature.
• An expiry date is mandatory where minimum durability is under 30 months.
• Tiny packaging gets an exemption — but name and batch number must still be on it.

What has to be on the label

These are the particulars that must appear on the outer packaging, or on the immediate packaging where there is no outer packaging.

#	Particular	The detail that catches people
1	Product name and its function	Function can be omitted only if obvious from presentation
2	Instructions for use	Same exemption — only if genuinely clear
3	Full ingredient list	Descending order of weight; standard nomenclature
4	Country of manufacture	Where it was made, not where your company is
5	Name and address of the local responsible party	The relabel trigger
6	Contents by weight or volume	Metric, or metric and imperial
7	Manufacturer's batch number	Must also survive onto small packaging
8	Manufacturing or expiry date	Day (if applicable), month, year, in that order
9	Special precautions	Including warnings the ACD Annexes require for specific ingredients

Everything must be in English. You may add Bahasa or any other language alongside it, and the other-language version must say the same thing as the English one.

The one that forces a relabel

Item 5 is the reason most Indonesian brands reprint their packaging for Singapore. The label must carry the name and address of the company or person responsible for placing the product on the Singapore market — and a foreign brand cannot fill that role itself.

So whoever is acting as your Responsible Person is whose name and Singapore address appears on your pack, alongside your branding rather than instead of it. Your brand identity is untouched; what changes is that a Singapore address now has to be printed somewhere on it.

Time this around a print run. Deciding your RP arrangement after packaging has been printed is how a launch loses six weeks, because the reprint moves at your packaging supplier's speed, not at anyone's regulatory speed. See Singapore's Responsible Person rule.

Getting the ingredient list right

Descending order of weight at the time the ingredients were added, using the nomenclature from the standard references. That is more specific than most brands' existing lists.

The rules that most often need applying:

Ingredients under 1% may be listed in any order, but only after everything above 1%. Colouring agents may be listed in any order after the other ingredients, by colour index number. For a decorative product sold in several shades, all the colourants in the range may be listed together with "may contain" or "+/-".

Perfume and aromatic compositions may be declared as "perfume", "fragrance", "aroma" or "flavour" rather than broken out. Botanicals should be identified by genus and species, and the genus may be abbreviated.

Three things are not ingredients and should not be listed: impurities in the raw materials, subsidiary technical materials used in preparation but absent from the final product, and materials used purely as solvents or carriers for perfume.

Dates, batches and durability

An expiry date is mandatory where the product's minimum durability is less than 30 months. Above that, a manufacturing date is acceptable instead.

The format matters: day where applicable, then month, then year, in that order, and the expiry indication should be preceded by "expiry date" or "best before". A date printed in another convention is a real finding, not a technicality, because the whole point is that a customer can read it unambiguously.

The batch number is the item brands most often leave to a sticker applied later. That works, provided it survives — and on very small packaging the batch number is one of only two particulars that must be on the container itself.

When the packaging is too small

If the size, shape or nature of the container will not carry all nine particulars, you may use a leaflet, pamphlet, hang tag, display panel or shrink wrap instead.

But the exemption is not total. Two particulars must still appear on the small immediate packaging itself: the product name and the manufacturer's batch number. Everything else can move to the accompanying material.

This matters for sample sizes, sachets, lip products and anything travel-sized — exactly the formats an Indonesian brand is most likely to bring to a first pop-up.

What you can claim

Labelling and advertising claims are governed too, and the boundary is the definition of a cosmetic. A cosmetic cleans, perfumes, changes appearance, corrects body odour, protects, or keeps in good condition.

Claims may not assert that the product modifies a physiological process, or prevents or treats a disease or medical condition — reversing hair loss is the example the regulator itself gives. Claims must be justifiable by scientific data, evidence, or the formulation itself, and must align with the ASEAN cosmetic claims guideline and Singapore's advertising code.

This is where translated Indonesian marketing copy most often fails. Language that is unremarkable at home can read as a treatment claim in English, and the claim is assessed on what it says, not what was meant.

FAQ

Does my BPOM-compliant label work in Singapore? Not as-is. Different mandatory particulars, English required, and a Singapore responsible party's address that your Indonesian label will not have.

Can I put a sticker over the existing label? Commonly done and acceptable in principle, provided the result is legible, durable and complete. A sticker that peels, or that covers something else required, creates a new problem.

Do testers and samples need the same label? Products supplied solely as samples in connection with advertising or promotion, or solely for research and development testing, sit outside the notification requirement. Whether a specific tester at your booth falls inside that exemption is worth confirming for your situation rather than assuming.

Is the label checked before I can sell? No. Notification is a filing, not an approval, and nobody signs off your artwork in advance. That is precisely why getting it right before printing matters — the check, if it comes, comes after the product is on sale.

What about fragrance specifically? Fragrance is a cosmetic under this framework and the same nine particulars apply. There is a separate ASEAN guideline for sunscreen labelling if you sell SPF products.

Does any of this apply to fashion? None of it. Apparel is not a cosmetic and Singapore sets no clothing labelling requirement at all. See do fashion brands need any approvals?

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Sources: Health Sciences Authority — Regulatory overview of cosmetic products (labelling requirements; notification exemptions; advertising and claims), last updated 7 August 2026; Health Products (Cosmetic Products — ASEAN Cosmetic Directive) Regulations 2007; ASEAN Cosmetic Directive Appendix II labelling requirements and Appendix III claims guideline. Updated August 2026. Operational guidance, not legal advice.