In recent years, the cosmetics industry has faced multiple challenges, including raw material shortages, demand for environmentally friendly alternatives, technological updates, and changes in international regulations. To alleviate the burden on businesses, the Thai Food and Drug Administration (FDA) issued the latest revised “Cosmetic Notification Guidelines” on October 29, 2025, clarifying that companies can continue to use the original product name even when certain formula ingredients are changed.
This policy aims to help businesses maintain brand continuity under compliance requirements, reducing market and consumer confusion caused by product name changes.
1. Policy Highlights
1) Continued use of original product names
Companies that modify certain formula ingredients can apply for a new notification number while retaining the original product name.
2) Re-submission required
After changing the formula, companies must re-submit the notification via the FDA system or the One Stop Service Center (OSSC), including the original notification number and supporting documents.
3) Required documents
- Original product notification certificate
- New product notification application form
- Official letter explaining the reasons for the changes
4) Only reasonable reasons will be approved
✅ The FDA accepts the following reasonable justifications:
- Raw material shortages or substitutions leading to a change in suppliers.
- Changes in foreign cosmetics regulations requiring formula adjustments to comply.
- Use of environmentally friendly substitutes or removal of non-essential ingredients.
- Technological updates affecting the formula.
- Consumer complaints or reports of adverse product reactions.
- Other reasons (must be detailed).
❌ The following reasons will not be accepted:
If your reason does not meet the above criteria, you must first cancel the original product notification before reapplying under the normal process.
Examples of unacceptable reasons:
- Simple submission errors or incomplete information
- Only adjusting allergen labels
- Discontinuation of production or import of the original product
2. Simplified Operational Process
- Enter the new formula notification information into the FDA system and print the application form (no fee required at this stage).
- Draft an official letter explaining the necessity of continuing to use the original product name and attach relevant documents.
- Submit the materials to the FDA Cosmetic and Hazardous Substances Control Department via in-person submission, mail, or email.
- Pay the 100 THB application fee upon notification.
- After the system unlocks, the formal review process begins:
- Low-risk products: Pay 900 THB and receive the new notification number immediately.
- High-risk products: Wait 3–10 working days for product/label review before receiving the new notification number.
3. Summary
This new regulation provides cosmetic companies with a more flexible compliance pathway, ensuring consumer safety while maintaining brand stability in the market. For export-oriented businesses, understanding and following this process can significantly reduce compliance risks associated with formula adjustments.
