A cream looks like the simplest product in a skincare line, and it is the one that most often goes round the sample loop several times. The brand wants it “rich but not heavy”, the jar on the mock-up was chosen for the shelf rather than for the formula, and the claim on the box was written before anyone checked Japan’s efficacy list. All-in-one gels add a second problem: one product is expected to do the work of a toner, serum and cream, which is a marketing idea and has to be turned into a formula and a set of permitted label phrases. This guide covers the decisions that shorten that loop.
💬 Sunsho Trade runs Japan-made own-brand cosmetics projects in English for brands outside Japan. Tell us about the cream or gel you want to make and we will list what the factory needs before it quotes.
Cream, gel or all-in-one: three different briefs
A cream is an emulsion of oil and water, a gel is usually a thickened water phase with little or no oil, and an all-in-one gel is a gel designed to replace several steps — each needs a different brief.
The difference is not only the name on the box. An emulsion needs an emulsifier system and a balance of oils chosen for feel and stability. A water gel depends on its thickener and on how it breaks when it is spread. An all-in-one gel is usually a gel with more humectants and functional ingredients, so the customer can stop after one step. Say which one you want, and send a reference product for each texture you have in mind.
A Japanese factory will normally propose one of its existing bases and adjust it. That is often the fastest route, but it affects who owns the formula. The trade-offs are in stock base or custom formula.
| Format | What defines it | Questions to settle in the brief |
|---|---|---|
| Cream (emulsion) | Oil and water held together by emulsifiers | How rich, how fast it absorbs, day or night use, fragrance |
| Gel | Thickened water phase, little or no oil | Firmness in the jar, how it breaks on the skin, residue |
| All-in-one gel | Gel carrying the roles of several steps | Which steps it replaces, which claims you want, feel when layered under sunscreen |
| Gel-cream | Gel with a small oil phase | Where it sits between the two, with a reference product |
How to describe texture so the factory can hit it
Send a physical reference and describe the behaviour you want at three moments — in the container, while spreading and a few minutes after — rather than adjectives alone.
“Rich”, “light” and “fresh” are not specifications. A factory can work with statements like these:
- In the container. Does it hold a peak when scooped? Should it move when the jar is tilted?
- While spreading. Does it glide, drag or turn watery? Should it break into droplets, as some water-gels do?
- After a few minutes. Matte or with a sheen? Slightly tacky or dry to the touch? Does it pill under makeup or sunscreen?
Climate matters. A cream that feels right in a cool office may feel heavy in a humid summer, so test samples where your customers live. If you sell in more than one climate, say which one comes first.
Keep each round focused on a small number of changes, and record the sample code you approve. The approved sample becomes the production standard. Anything changed after approval is a new sample.
Jar, tube or pump: choose with the formula, not after it
A jar suits thick creams but exposes the product to fingers and air at every use; a tube or airless pump protects it but limits viscosity — the choice changes the preservative design and must be tested with the formula.
This is where brands most often lose time. A heavy glass jar may be what the brand image calls for, while the factory would prefer an airless pump for a gel with a lighter preservative system. A tube needs a formula that flows through the nozzle without separating. A pump needs a viscosity range the mechanism can handle, and you should ask how much product is left inside when it stops dispensing.
The stability programme is run in the container you will sell. The factory designs it — typically storage at different temperatures, light exposure, temperature cycling and contact with the container — since there is no single Japanese statutory protocol. If you change the container afterwards, ask whether compatibility testing has to be repeated. See containers and packaging and stability and compatibility testing.
💬 Have a container in mind already? Send us its specification with your brief and we will raise any formula or filling issue with the factory before sampling.
Preservatives, colours and the restricted lists
Every preservative in a cream or gel must be on Appendix 3 of Japan’s Standards for Cosmetics, within the limit for a leave-on product, and every colourant must follow Japan’s tar-colour rules.
Japan’s Standards for Cosmetics (化粧品基準), Ministry of Health and Welfare Notification No. 331 of 2000, set a prohibited list (Appendix 1), maximum amounts for restricted ingredients (Appendix 2) and positive lists for preservatives (Appendix 3) and UV filters (Appendix 4). The limits differ by product type: a face cream is a leave-on product, not a rinse-off one like soap or shampoo, and some limits apply only to products used on mucous membranes.
Creams and gels are often water-based and, in a jar, meet fingers and air at every use, so the preservative system carries real weight. A formula that came from another market can fail because its preservative is not on Japan’s positive list or exceeds Japan’s limit for this product type. Ingredients carried in by extracts and premixes count too. The check runs ingredient by ingredient before samples; how it works is explained in checking a formula against Japan’s Standards for Cosmetics.
Two more points worth knowing:
- Colour. Tar colours must follow the Ministerial Ordinance on tar colours usable in pharmaceuticals (Ordinance No. 30 of 1966). Some colours, such as Red No. 219 and Yellow No. 204, are allowed only in products used solely on hair and nails, so they cannot go into a face cream.
- Day creams with UV protection. If you want a day cream to carry an SPF, its UV filters must come from Appendix 4 and the SPF and PA values must be measured. That is a sunscreen project in itself; see sunscreen OEM, SPF and PA.
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.
The quasi-drug boundary for creams and gels
A cream or gel becomes a quasi-drug (医薬部外品) if it is meant to claim whitening, acne prevention as an active effect or wrinkle improvement — claims that need an approved active ingredient and product approval.
Under the PMD Act, quasi-drugs are a separate category from cosmetics. The cream-type quasi-drugs are “medicated cosmetics”: products whose label claims, in Japan’s quasi-drug wording, to suppress melanin production to prevent spots and freckles; to prevent acne as an active effect; or, for approved products only, to improve wrinkles. These are regulatory categories, not results a cosmetic can promise.
The consequence is procedural. A cosmetic is notified before it goes on the Japanese market. A quasi-drug needs product-by-product marketing approval (製造販売承認) and a factory licensed in the quasi-drug categories. Decide this before the formula work starts, because changing category half-way means starting the formula again. The full decision is in cosmetic or quasi-drug: the first decision.
What a cream or gel label may say
As a cosmetic, a cream or gel may use only the applicable items of Japan’s 56-item efficacy range — for example “moisturises the skin”, “prevents rough skin” or “gives the skin firmness” — plus true sensory descriptions.
The items that suit creams and gels include “moisturises the skin”, “keeps the skin healthy”, “prevents rough skin”, “prevents dryness of the skin”, “softens the skin”, “gives the skin firmness”, “gives the skin lustre” and “makes the skin smooth”. Item 56, “makes fine lines caused by dryness less noticeable”, is available only after the marketing authorisation holder confirms the effect through testing such as the Japanese Society of Cosmetic Chemists’ guideline. Prefectural guidance treats wrinkle prevention or removal, and removal of sagging, as outside the range.
For all-in-one gels, the claim problem is specific. “Replaces your toner, serum and cream” is a description of use, not an efficacy claim, and it should be true of how the product is used. The efficacy wording itself must still come from the list. Sensory feel may be described as long as it is true and does not guarantee a result. The full list, and why it matters for export, is in what a cosmetic label may claim in Japan.
| Draft wording | Where it sits in Japan |
|---|---|
| ”Moisturises and softens the skin” | Within the cosmetic efficacy range |
| ”Prevents rough skin” | Within the cosmetic efficacy range |
| ”Makes fine lines caused by dryness less noticeable” | Cosmetic item 56, after testing confirms it |
| ”Prevents acne” as an active effect | Quasi-drug category |
| ”Whitening” in the melanin sense, “wrinkle improvement” | Quasi-drug category |
| ”Lifts sagging skin” | Outside the cosmetic range under prefectural guidance |
Ingredient list, dates and documents
The factory produces a full ingredient list in Japanese labelling names, which you must convert 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, in descending order of amount, using the Japanese labelling names from the Japan Cosmetic Industry Association’s list. Ingredients at 1% or less, and colourants, may be listed in any order among themselves. Premixes are listed ingredient by ingredient, and fragrance may be listed collectively as “fragrance” (香料). Creams often contain emulsifier premixes and oil blends, so the list can be longer than the brief suggested. Converting it 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 may also require a period-after-opening symbol; check with your importer.
If the cream is made with export-only labels, the work counts as manufacturing and 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. Your importer files the destination notification; we prepare the Japan-side documents described in export documents and certificates. For the sequence from approved sample to loaded container, see the export shipping flow.
💬 Want to brief a cream, gel or all-in-one gel? See our Japan-made cosmetics OEM service, read the Japan cosmetics OEM guide, or send us your brief.
Frequently asked questions
1. Is an all-in-one gel a cosmetic or a quasi-drug in Japan?
It depends on what it is meant to claim, not on its format. An all-in-one gel that stays within the 56-item efficacy range is a cosmetic. If it is meant to claim whitening, acne prevention as an active effect or wrinkle improvement, it falls into the quasi-drug category and needs product approval.
2. Can I use a jar for a light gel?
You can, but tell the factory early. A jar exposes the product to fingers and air at every use, which affects the preservative design. The factory will run stability and compatibility checks in the jar, and may suggest a tube or airless pump if the formula needs more protection.
3. Why does the factory want a reference product for texture?
Words like “rich” or “light” mean different things to different people. A physical reference, plus a description of how the product should behave in the container, while spreading and after a few minutes, lets the factory reach the target in fewer sample rounds.
4. Can a day cream carry an SPF?
Yes, if its UV filters come from Appendix 4 of Japan’s Standards for Cosmetics and the SPF and PA values are measured by the recognised methods. In practice this is handled like a sunscreen project, with its own testing and labelling rules.
5. Can my cream label say it reduces wrinkles?
Not as a cosmetic. Wrinkle improvement is a quasi-drug category in Japan, and prefectural guidance treats wrinkle prevention or removal as outside the cosmetic range. A cosmetic may use item 56, “makes fine lines caused by dryness less noticeable”, only after the effect is confirmed by testing.