A wholesale order of Japanese cosmetics fails in a different way from an order of snacks. The goods arrive in good condition, and then sit in a warehouse because the importer cannot complete its product notification: there is no letter of authorisation from the manufacturer, the ingredient list is only in Japanese, or the local label needs a date that the Japanese pack does not show.
Each of these problems can be seen before the order is placed. This guide sets out what an importer or wholesaler should settle first: what the Japanese label already gives you, which documents the import side will ask for, how dates and lot numbers work on Japanese cosmetics, and how to build a range that can travel with other Japanese goods.
💬 Building a range of Japanese cosmetics for your market? Sunsho Trade buys Japanese cosmetics and household goods in Japan and exports them, alone or with Japanese food. Send us your product list.
Start from what the Japanese label already tells you
Japanese law fixes what must be printed on a cosmetic’s container, so the pack itself is the first source for the information your notification and local label will need.
Under Japan’s Act on Pharmaceuticals and Medical Devices (the PMD Act), Article 61 lists what must appear on the immediate container or wrapping of a cosmetic. The list includes the name and address of the marketing authorisation holder, the product name, a manufacturing number or code, the names of ingredients designated by the Minister of Health, Labour and Welfare, and a use-by date for cosmetics the Minister designates. Since April 2001, the ingredient designation has meant the full ingredient list, so a Japanese cosmetic lists all its ingredients on the pack.
A quasi-drug (医薬部外品), the Japanese category that includes many medicated skincare products, has its own list in Article 59. It must carry the words “医薬部外品” on the container, along with the marketing authorisation holder, the name, a manufacturing number or code and the net content. That is the quickest way to tell from a photo which Japanese category a product sits in. The difference matters for sunscreens and skincare, and is covered in our guide to Japanese sunscreen and skincare for export.
| Item on the Japanese pack | Japanese rule | What your import side uses it for |
|---|---|---|
| Marketing authorisation holder name and address | PMD Act Article 61(i) | Identifying the responsible company in Japan, and who to ask for a letter of authorisation |
| Product name | Article 61(ii) | Matching the product to every document in the file |
| Manufacturing number or code (lot) | Article 61(iii) | Traceability, and the batch number on your local label |
| Full ingredient list | Article 61(iv) and the 2001 designation | Checking against your market’s ingredient lists, and the ingredient list on your label |
| Use-by date | Article 61(v), only for designated cosmetics | Your local date requirement (see below) |
| The words “医薬部外品” | Article 59(ii), quasi-drugs only | Flagging the product for a classification check in your market |
The Japanese ingredient list is written in Japanese label names, not in INCI names. Turning one into the other is a careful job, explained step by step in Japan ingredient labelling versus INCI. Ask for the list in INCI names before ordering, and treat a list nobody has checked as a draft.
Settle the authorisation letter before you order
Many markets ask for a letter of authorisation from the manufacturer or brand owner before a cosmetic can be notified, some also ask for a certificate of free sale, and both depend on the manufacturer, so ask about them product by product before the order is placed.
In many Asian markets, the importer notifies or registers each cosmetic product before it goes on sale. The file usually needs a letter of authorisation (LOA) from the manufacturer or brand owner, naming the importer. Some markets also require a certificate of free sale (CFS) from the country of manufacture. The exact list is set by each country, so the importer confirms the current rule in its country.
Vietnam is an example of how the CFS requirement can differ by origin. Article 4(4) of Circular 06/2011/TT-BYT, as amended by Circular 29/2020/TT-BYT (which replaced Circular 32/2019/TT-BYT, where the change first appeared), exempts cosmetics manufactured in a CPTPP member country from the CFS with no further document required, and cosmetics circulated in and exported from a CPTPP member country on proof of circulation there. Japan is a CPTPP member, so cosmetics made in Japan do not need a CFS for Vietnam, while the letter of authorisation, consular-legalised, is still required. The rule has been amended more than once, so the Vietnamese importer should confirm it against the text in force when it files.
Here is the practical point. Sunsho Trade buys from suppliers in Japan, and the supplier for a given product may be a wholesaler rather than the manufacturer. A wholesaler can sell you genuine goods, but it cannot sign a letter of authorisation on the manufacturer’s behalf. Whether a letter can be obtained depends on the manufacturer’s own policy. For each product on your list, we tell you before you order whether a letter of authorisation can be obtained for it, so you do not buy stock you cannot notify.
The same applies to Japanese certificates. Under the Ministry of Health, Labour and Welfare notice of 27 July 2026 on export cosmetics certificates, applications go through the Japan Cosmetic Industry Association, and the attachments include copies of the cosmetics marketing authorisation holder’s licence and, for a certificate of manufacture and sale, the product’s Japanese notification. In practice, that means the certificate is applied for by, or with the help of, the licence holder. Which certificate answers which request is covered in export documents and certificates for Japan-made cosmetics.
| Document | Who can produce it | What to settle before ordering |
|---|---|---|
| Letter of authorisation | The manufacturer or brand owner | Whether the manufacturer will issue one for this product and this importer |
| Certificate of free sale or Japanese export certificate | Applied for through the Japan Cosmetic Industry Association, with the licence holder’s documents | Whether your market needs one for Japanese products, and in which form |
| Full ingredient list in INCI names | The manufacturer’s information, converted and checked | Who converts it, and who checks it |
| Product photos and label text | From the product itself | Photos of all faces of the pack, for your label and file |
| Safety data sheet (SDS) | The manufacturer | Needed for products that may be dangerous goods in transport |
💬 Not sure which products on your list can come with a letter of authorisation? Send the list and your market, and we will tell you product by product before you order. Ask about documents.
Expect a lot number on the pack, not always a date
Many Japanese cosmetics carry a manufacturing number but no printed date, so agree in advance how your local label’s date will be filled in and what remaining life you need on arrival.
Under Article 61(v), a use-by date is required only for cosmetics the Minister designates. Many Japanese cosmetics therefore show a manufacturing number or code and no date at all. That is lawful in Japan, but it can leave a gap on your side.
The ASEAN cosmetic labelling requirements, published by the ASEAN Secretariat as part of the ASEAN Cosmetic Directive framework, list the manufacturer’s batch number and “the manufacturing date or expiry date of the product in clear terms” among the particulars to appear on the label. If your market follows that model, the importer’s label needs a date that the Japanese pack may not give.
Three things follow:
- Ask how the manufacturing date can be confirmed. The manufacturing code on a Japanese cosmetic is the maker’s own code. Whether the maker will state the manufacturing date for a given lot is something to ask, not to assume.
- Agree a minimum remaining life in writing. Transit, customs and your own notification time come out of the time your customers have to sell the goods. Put the minimum in the order, and decide how it is measured when the pack shows no date.
- Keep lot numbers on every document. Record the lot of each product when it reaches the consolidation point, so the packing list, your label and any later query refer to the same batch.
For food, the equivalent agreement on best-before dates is set out in our Japanese snacks wholesale guide. The principle is the same: the date you need on arrival is a commercial term, agreed before the order.
Check the ingredients against your market’s lists
A product sold freely in Japan can still contain an ingredient your market restricts, so the full ingredient list should be checked against your market’s lists before the product is bought.
Japan sets its own cosmetic ingredient standards, and the ASEAN Cosmetic Directive sets its own annexes of prohibited, restricted and permitted substances, including Annex VII for UV filters. The two systems are similar in purpose but are not the same list, and both are updated. A Japanese formula is a good starting point, not a guarantee.
A workable order of checks:
- Ingredient list first. Get the full list for each product, converted to INCI names.
- Your market’s annexes second. The importer checks the list against the version of the annexes or national lists in force on the filing date.
- Claims third. Claims on the Japanese pack were written for Japanese rules. They should not be translated into your label until the importer has checked that they are allowed for the category the product will take in your market.
The ASEAN labelling requirements list the Japanese Standard Cosmetic Ingredient and the Japanese Cosmetic Ingredients Codex among the standard references for ingredient names. Your national authority may prefer INCI, so ask which naming it expects.
Build the range, then consolidate it with your other Japanese goods
Buy many cosmetic lines in modest quantities and consolidate them in Japan, together with household goods or food if you buy those too, so one shipment covers a whole range.
A shop or distributor rarely wants one cosmetic in large volume. It wants a shelf: cleansers, lotions, sunscreen, hair care, body care and some make-up. Japanese suppliers would rather sell one line by the case, so the way to bridge that is consolidation: lines are bought from several suppliers in Japan, delivered to one point, checked and loaded together.
Useful questions before you send a list:
- Which lines must be available again in three or six months, and which are a test?
- Which lines are quasi-drugs in Japan and need a classification check in your market first?
- Which lines are sprays, mists or alcohol-rich toners that may be dangerous goods in transport?
The last question matters for the shipment as a whole. Aerosols and products with a high alcohol content may be classed as dangerous goods for sea and air transport; the SDS of each product is the source, and the carrier’s rules decide how it travels. How that affects a load shared with food and household goods is covered in Japanese food, cosmetics and household goods in one container.
On brand rights: buying genuine goods through the ordinary Japanese market is different from holding a distribution agreement with the brand owner. The trade-offs are set out in sourcing Japanese consumer goods for export. Sunsho Trade does not represent itself as any manufacturer’s official distributor.
💬 Ready to price a first mixed order of Japanese cosmetics? Send the lines, your country and whether you are adding food or household goods. Request a quotation.
Frequently asked questions
1. Who files the cosmetic notification in our country?
The importer in your country, because that is the party the law there makes responsible. Sunsho Trade does not act as the importer or file notifications. We supply the ingredient lists, label photos, lot numbers and manufacturer details the notification depends on.
2. Can you always provide a letter of authorisation?
No. A letter of authorisation can only be issued by the manufacturer or brand owner, and the supplier we buy a product from in Japan may be a wholesaler. For each product, we tell you before you order whether a letter can be obtained.
3. Do Japanese cosmetics need a certificate of free sale?
It depends on your market. Some require one and some do not. In Vietnam, for example, Circular 06/2011/TT-BYT as amended by Circular 29/2020/TT-BYT exempts cosmetics manufactured in CPTPP member countries, which include Japan, from the CFS, while the letter of authorisation is still needed. The importer confirms the current rule in its country.
4. Why is there no expiry date on some Japanese cosmetics?
Japanese law requires a use-by date only for cosmetics the Minister designates. Others carry a manufacturing number or code. If your label needs a date, agree before ordering how it will be confirmed.
5. Can we order many different cosmetics in small quantities?
Yes. Mixed orders are what consolidation is for. We buy the lines from suppliers in Japan, bring them together and ship them as one load, with food and household goods if you want. The sensible quantity per line is confirmed at quotation.
Sources: Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices (Act No. 145 of 1960), Articles 59 and 61, e-Gov law search; Ministry of Health and Welfare notice of 29 September 2000 (医薬発第990号) on the full ingredient labelling designation, applied from 1 April 2001; Ministry of Health, Labour and Welfare notice of 27 July 2026 on export cosmetics certificates (医薬薬審発0727第4号 / 医薬安発0727第6号); ASEAN Secretariat, ASEAN Definition of Cosmetics and Illustrative List, ASEAN Cosmetic Labelling Requirements (Appendix II); Circular 06/2011/TT-BYT, Article 4(4), as amended by Circular 29/2020/TT-BYT (Vietnam Ministry of Health). Checked on 24 October 2026.