The sample is approved, and the brand expects the next message to be a shipping date. In practice several things still have to happen in a fixed order: the export labels must be final, a filing must be made in Japan before manufacture, your importer must file in the destination market, the product must be screened for dangerous-goods rules, and someone must decide who pays for which leg of the journey. Most delays at this stage come from doing these out of order, so this guide sets out the order.
💬 Sunsho Trade manages own-brand cosmetics made in Japan for brands outside Japan, from brief to shipment, with a GMP-certified partner factory in Japan. Tell us your destination and your importer and we will lay out the sequence for your product.
The sequence at a glance
From an approved sample, the order is: confirm testing, finalise export labels, file the export manufacturing notification, let your importer file in the destination, produce and release the batch, screen for dangerous goods, pack, book under the agreed Incoterm, and ship with the documents.
The table shows who acts at each step and what must already be in place. We do not give durations, because each depends on the product, the factory’s schedule, the destination authority and the carrier.
| Step | Who acts | Must be ready before it starts | What goes wrong if it is skipped |
|---|---|---|---|
| 1. Confirm stability and compatibility | Factory | Approved sample in the final container | A formula or container problem found after production |
| 2. Finalise export labels and artwork | Brand, with importer’s input | Importer’s list of required label items | Labels reprinted, or rejected at the destination |
| 3. File the export manufacturing notification | Licensed manufacturing side in Japan | Final label and specification | Manufacture cannot lawfully start |
| 4. Destination notification | Your importer | Ingredient list, label and documents your importer needs | Goods arrive with no right to be sold |
| 5. Production and batch release | Factory | Materials, containers and printed packaging on hand | Release delayed waiting for a component |
| 6. Dangerous-goods screening | Factory, forwarder and carrier, from the SDS | Safety data sheet for the final formula | Booking refused, or goods held |
| 7. Packing | Factory | Agreed carton and pallet specification | Damage or leaks in transit |
| 8. Booking under the agreed Incoterm | Seller or buyer’s forwarder, as agreed | Incoterm and named place agreed in writing | Nobody books, or both sides do |
| 9. Ship with documents | Exporter and forwarder | Commercial and product documents ready | Clearance delayed at either end |
Export labels make the job “manufacture” in Japan
Putting export-only labels on a cosmetic, or making it to an export-only specification, counts as manufacturing under Japan’s rules, so it needs a manufacturing licence and an export manufacturing notification filed before manufacture starts.
According to JETRO’s Q&A on exporting cosmetics (last updated August 2025), a product already on the Japanese market can be exported unchanged with no special procedure under the PMD Act (Japan’s Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices). Taking returns back into Japan, however, needs a marketing authorisation holder licence. Once labels are changed for export, by translation or by a new container or box design, the work is manufacturing. A product designed for export from the start is treated the same way.
For an own-brand product made for an overseas market, this is the normal case. The export manufacturing notification (輸出用化粧品製造届) goes to the Minister of Health, Labour and Welfare through PMDA. What it is, and how it relates to the certificates your importer may want, is explained in export documents and certificates. For this flow, the consequence is simple: the label must be final before manufacture is scheduled, and a late label change means a late production date.
Checked against the published texts of JETRO and the Ministry of Health, Labour and Welfare on 17 October 2026.
When your importer should file in the destination
Your importer files the destination notification, and should start as soon as the formula, ingredient list and label are final, because many authorities expect the product to be notified before it is sold and some before it is imported.
We prepare the Japan-side documents; your importer handles the destination filing and knows what the authority wants. The handover works best when the importer receives, at the same time, the final ingredient list in the names the destination uses, the final label artwork, and the list of Japan-side documents they can expect. Ask your importer two questions early: must the notification be accepted before the goods arrive, and must the label be approved before it is printed?
The answer to the second question decides whether printing can run in parallel with the filing or must wait for it. Printing a full run of labels before the importer has confirmed the content is a risk you can avoid by asking. For Vietnam, the filing is covered in Vietnam’s cosmetics import notification. How the ingredient list is converted for export labels is in full-ingredient labelling and INCI names.
💬 Want the importer’s filing and the factory’s production planned together? Send us your importer’s contact and destination and we will coordinate the handover.
Dangerous-goods screening from the SDS
Alcohol-rich products, such as some toners and fragrance mists, and aerosols may be classed as dangerous goods for air and sea transport; section 14 of the safety data sheet states the transport classification, and the carrier’s rules decide whether and how it travels.
Check this before booking, not at the forwarder’s desk. A product classed as dangerous goods for transport needs suitable packaging, marks and labels on the outer cartons, a dangerous-goods declaration, and a carrier and route that accept it. Some carriers or routes will not take certain classes at all, and air and sea rules differ. A product that is not classed as dangerous goods ships as general cargo.
What to do in practice:
- Ask the factory for the SDS of the final formula, not an earlier version. A change in alcohol level or propellant can change the classification.
- Send the SDS to your forwarder before you choose air or sea, and ask them to confirm the classification and the carrier’s acceptance.
- If the product is classed as dangerous goods, agree who prepares the declaration and the packing marks. It is usually the shipper’s responsibility, so settle this in the Incoterm discussion below.
We do not state flash points or UN numbers here; the SDS for your formula and the carrier’s classification are the only reliable sources.
Packing and temperature
Agree the carton, partition and pallet specification with the factory before production, and check that the stability data covers the conditions your route and destination warehouse will expose the product to.
Cosmetics travel in primary containers designed for shelves, not for freight. The export carton, any inner partitions, how cartons are stacked on a pallet, and whether the pallet is wrapped all affect whether pumps arrive intact and caps stay closed. Agree these with the factory, and ask your importer whether the destination warehouse or retailer has carton or pallet requirements of its own, such as carton markings or a maximum pallet height.
Temperature is the other question. A sea container on a long route can see heat; an air shipment can sit on a tarmac. The factory’s stability programme tested the formula at a range of conditions it chose. Ask whether those conditions reasonably cover your route and storage, and if they do not, whether a temperature-controlled option is needed. What the stability programme covers is explained in stability and compatibility testing.
Choosing the Incoterm
The Incoterm decides who arranges and pays for each leg, who clears Japanese export customs, who insures the goods, and where risk passes; agree it, with a named place, before the batch is released.
The rules most often used for this kind of shipment, under the International Chamber of Commerce’s Incoterms 2020, are:
- EXW (Ex Works). The buyer collects from the seller’s premises and handles everything after that, including Japanese export clearance. A foreign buyer then needs a forwarder able to clear exports in Japan.
- FCA (Free Carrier). The seller clears the goods for export and hands them to the buyer’s carrier at a named place. Works for any transport mode.
- FOB (Free on Board). For sea freight: the seller clears for export and loads the goods on board at the named port.
- CIF or CIP. The seller also pays main carriage and insurance to the named destination. CIF is for sea; CIP for any mode.
- DAP (Delivered at Place). The seller delivers to a named place in the destination, not cleared for import; your importer still handles import clearance.
If the product is classed as dangerous goods, make sure the party arranging carriage is ready to handle a dangerous-goods booking. For the general Japanese export paperwork that comes with any of these terms, see export from Japan: documents and flow.
Documents travelling with the cargo
The cargo travels with the commercial documents, the transport document and whichever product documents your importer’s clearance needs; the product documents are prepared in advance, not at the port.
The commercial set is the same as for other goods: a commercial invoice, a packing list, and the bill of lading or air waybill. Add a dangerous-goods declaration if the product is classed as dangerous goods, and a certificate of origin if your importer intends to claim a tariff preference; ask them whether one is needed and in which form.
The product documents, such as an export certificate, the certificate of analysis for the batch, the ingredient list and the SDS, are the ones your importer listed at the start. What each one proves is explained in export documents and certificates. Whether they travel with the cargo or go to the importer separately depends on the destination’s clearance practice; your importer will know.
💬 Approved sample in hand and ready to plan the shipment? See how our Japan cosmetics OEM service works, browse the Japan cosmetics OEM guide, or send us your destination and quantity.
Frequently asked questions
1. Why can’t production start as soon as the sample is approved?
Because the export labels must be final and, for a product made with export labels or to an export specification, an export manufacturing notification must be filed before manufacture starts. Stability and compatibility testing in the final container also has to be confirmed.
2. When should my importer file the destination notification?
As soon as the formula, ingredient list and label are final. Many authorities expect a cosmetic to be notified before it is sold, and some before it is imported. Ask your importer whether the label must be approved before it is printed.
3. Will my toner or mist be treated as dangerous goods?
It may be, if it contains a high level of alcohol, and aerosols may be too. Section 14 of the safety data sheet states the transport classification, and the carrier’s rules decide. Send the SDS for the final formula to your forwarder before choosing air or sea.
4. Which Incoterm should I use?
It depends on who is better placed to arrange each leg. EXW leaves Japanese export clearance to the buyer; FCA and FOB have the seller clear for export; CIF, CIP and DAP extend the seller’s role further. Agree the term and a named place in writing before the batch is released.
5. Which documents travel with the shipment?
The commercial invoice, packing list and transport document, plus a dangerous-goods declaration if needed and a certificate of origin if your importer claims a preference. Product documents, such as certificates and the CoA, follow your importer’s list.