Cleansers are judged in the first moments of use: how the makeup lifts, how the oil turns milky under water, whether the foam is dense enough, whether the face feels tight afterwards. Those are exactly the things a brief tends to leave vague. A Japanese factory needs to know what the cleanser must remove, how it will be used and what you plan to say on the label, because a face wash that claims to prevent acne as an active effect is a different legal product from one that does not. This guide sets out those decisions and the tests to run on the samples.
💬 Sunsho Trade manages Japan-made own-brand cosmetics projects in English for brands outside Japan. Tell us which cleanser you want to make and we will list what the factory needs before it quotes.
Pick the format by what it has to remove
Choose between oil, balm, gel, milk and foaming wash by what the product must remove and how it will be used — makeup removal and everyday washing are different briefs.
A cleansing oil, balm or gel is aimed mainly at makeup and sunscreen. A foaming face wash is aimed mainly at everyday washing. Some brands pair the two as a “double cleanse”. Each format brings different formula and container questions:
| Format | Main job | Questions for the brief |
|---|---|---|
| Cleansing oil | Dissolves makeup, then rinses off | Which makeup it must remove, use with wet hands or dry hands only, feel after rinsing |
| Cleansing balm | Solid at rest, melts on the skin | Firmness in the jar, melting speed, spatula or not |
| Cleansing gel | Water- or oil-based gel for makeup | Use on dry or wet skin, residue, eye-area use |
| Cleansing milk | Emulsion that is wiped or rinsed off | Wipe or rinse, skin feel afterwards |
| Foaming face wash | Everyday washing with lather | Foam density and stability, tight or soft skin feel, tube or pump foamer |
Tell the factory which makeup the product must handle. “Removes waterproof mascara” is a requirement the factory can test against; “deep cleansing” is not. If you plan an eye-area use instruction, say so in the brief, for reasons explained in the next section.
The factory will normally start from one of its existing bases. Whether that suits you, and who owns the result, is covered in stock base or custom formula.
Rinse-off limits, preservatives and the eye area
Cleansers are rinse-off products, so they are checked against Japan’s limits for that product type; any preservative must still be on the positive list, and products used on mucous membranes have limits of their own.
Japan’s Standards for Cosmetics (化粧品基準), Ministry of Health and Welfare Notification No. 331 of 2000, set maximum amounts for restricted ingredients in Appendix 2 and positive lists for preservatives (Appendix 3) and UV filters (Appendix 4). Several limits differ by product type: rinse-off products such as soap and shampoo can have different limits from leave-on products, and products used on mucous membranes have their own limits.
For a cleanser this means three things in practice:
- Rinse-off does not mean anything goes. A preservative must still be on Appendix 3 and within the limit for this product type. A formula written for another market can fail on this.
- Eye-area use deserves a question. If the cleanser is meant for use around the eyes, ask the factory whether the formula check applies the limits for products used on mucous membranes. Confirm this against the current text before you rely on either answer.
- Oils and extracts bring passengers. Plant oils and extracts may carry antioxidants or preservatives from the raw material. The check covers those too.
The check runs ingredient by ingredient before samples. How it works is explained in checking a formula against Japan’s Standards for Cosmetics.
Checked against the published texts of the Ministry of Health, Labour and Welfare, the Japan Cosmetic Industry Association and prefectural guidance on 17 October 2026.
Containers and use in the shower
Choose the container with the way the product will be used: a pump oil, a balm jar and a pump foamer each behave differently with wet hands, and the factory tests compatibility in the container you will sell.
Cleansers are often used in the bathroom with wet hands, which matters more for them than for most skincare. Ask the factory these questions:
- Pump oils. Is the oil compatible with the pump and bottle material over the product’s life? What happens if water gets into the bottle?
- Balm jars. Will customers scoop with wet fingers? Does the formula need a spatula or a different closure?
- Pump foamers. The formula must be thin enough for the foaming head. Does the foam density meet your brief through that head, not only when lathered by hand?
- Tubes. Does the face wash flow cleanly, and does it stay stable at the temperatures of a bathroom shelf in your market?
The factory designs the stability programme — typically storage at different temperatures, light, temperature cycling and contact with the container — and there is no single Japanese statutory protocol for it. What you need is the result in the container you will ship. See stability and compatibility testing and containers and packaging.
💬 Already chosen a pump or foamer? Send us its specification with your brief and we will raise filling and compatibility questions with the factory before sampling.
What to test on the samples
Test every cleanser sample against the makeup it must remove, with the hands and water conditions customers will use, and record the sample code you approve.
A useful sample review covers:
- Removal. Apply the makeup and sunscreen you named in the brief, including any waterproof products, and check what the cleanser lifts.
- Rinsing. For oils and balms, check how readily the product turns milky and rinses away, and whether a film is left behind.
- Wet-hand use. Try the oil or balm with wet hands if your instructions allow it.
- Lather. For face washes, check foam density and how long the foam holds, by hand and through the pump if there is one.
- After-feel. Note whether skin feels tight, soft or coated a few minutes after drying.
- Smell. Including the base smell of an unfragranced version.
Change a small number of things per round and keep notes by sample code. The approved sample becomes the production standard, and anything changed afterwards is a new sample.
The quasi-drug boundary for face washes
A face wash becomes a quasi-drug (医薬部外品) when it is meant to claim acne prevention as an active effect, which needs an approved active ingredient and product approval; the cosmetic range has its own narrower item for face washes.
Under the PMD Act, soap and similar cleansers fall within the definition of cosmetics, and cosmetics need only a product notification before they go on the Japanese market. Quasi-drugs are a separate category and need product-by-product marketing approval (製造販売承認). Acne prevention as an active effect is one of the typical quasi-drug claims for “medicated cosmetics”.
The cosmetic efficacy range contains a face-wash item worded “(by cleansing) prevents acne and heat rash”. The words in brackets are a limit that comes from the product’s form: the effect is tied to cleansing, not to an active ingredient. These are the rule’s words. They describe what a label is allowed to say, not a result anyone can promise. Do not let the artwork drift from this wording towards an active-effect claim. The decision is set out fully in cosmetic or quasi-drug: the first decision.
What a cleanser label may say
A cosmetic cleanser may use only the items of Japan’s 56-item efficacy range that apply to it, plus true descriptions of use and feel that do not guarantee a result.
Japan’s efficacy range for cosmetics (化粧品の効能の範囲) lists 56 items, and a product may use only those applicable to it. For a face wash, “(by cleansing) prevents acne and heat rash” is the item written for that form. Other skin-care items such as “prevents rough skin” or “keeps the skin healthy” should be used only where they are true of a rinse-off product; settle this with the factory and the marketing authorisation holder rather than assuming. Descriptions of use and feel, such as how the oil turns milky or how the skin feels after rinsing, may be stated if they are true. The full list is in what a cosmetic label may claim in Japan.
| Draft wording | Where it sits in Japan |
|---|---|
| ”(By cleansing) prevents acne and heat rash” on a face wash | Within the cosmetic efficacy range |
| ”Prevents acne” as an active effect | Quasi-drug category |
| ”Removes waterproof mascara” | A description of use, which must be true |
| ”Leaves skin feeling soft” | Sensory description, true and without a guarantee |
| ”Treats breakouts” | Medical wording, not available to a cosmetic |
Ingredient list, dates and documents
The full ingredient list is produced in Japanese labelling names and must be converted to INCI for export labels; dates and export documents follow Japanese rules on the Japan side and your importer’s rules at destination.
Every cosmetic in Japan lists all ingredients using the Japanese labelling names from the Japan Cosmetic Industry Association’s list, in descending order of amount, with ingredients at 1% or less and colourants in any order among themselves. Cleansers often use surfactant premixes and oil blends; premixed raw materials are listed ingredient by ingredient, so the list may be longer than your brief. Carry-over ingredients present at levels where they have no effect need not be listed, and fragrance may be listed collectively as “fragrance” (香料). Converting to INCI is a separate, checked step; see full ingredient labelling and INCI.
On dates, Japanese rules require an expiry date only for cosmetics whose quality may change within a defined period after manufacture under appropriate storage. The threshold usually cited is three years from manufacture — confirm this against the current ministerial notice before you rely on it. Your destination market may have its own rules, such as a period-after-opening symbol; check with your importer.
If the cleanser is made with export-only labels, the work counts as manufacturing: the factory side needs a cosmetics manufacturing licence and an export manufacturing notification (輸出用化粧品製造届) filed before manufacture starts. Ask for the safety data sheet early as well, since section 14 states the transport classification. Your importer files the destination notification; we prepare the Japan-side documents described in export documents and certificates, and the sequence to shipment is in the export shipping flow.
💬 Ready to brief a cleansing oil or face wash? See our Japan-made cosmetics OEM service, the Japan cosmetics OEM guide, or send us your brief.
Frequently asked questions
1. Is a face wash a cosmetic or a quasi-drug in Japan?
A face wash is a cosmetic unless it is meant to claim acne prevention as an active effect, which belongs to the quasi-drug category and needs an approved active ingredient and product approval. The cosmetic range has its own face-wash item, “(by cleansing) prevents acne and heat rash”.
2. Do preservative rules apply to a rinse-off cleanser?
Yes. Any preservative must be on Appendix 3 of Japan’s Standards for Cosmetics and within the limit for that product type. Limits for rinse-off products can differ from those for leave-on products, but the positive list applies to both.
3. Does a cleansing oil for eye makeup need a different check?
Ask. Japan’s Standards set separate limits for products used on mucous membranes, so tell the factory if the cleanser is meant for the eye area and confirm how the formula check treats it.
4. What should I send the factory to describe cleansing power?
Name the makeup and sunscreen the product must remove, including waterproof products, and say whether it will be used with wet or dry hands. The factory can test against that; a phrase like “deep cleansing” cannot be tested.
5. Can I write that my cleanser treats breakouts?
No. Treatment wording is medical language and is not available to a cosmetic. A face wash may use the cosmetic item “(by cleansing) prevents acne and heat rash”; an active-effect acne claim belongs to the quasi-drug category.