A hair care line is usually briefed as a set — shampoo, conditioner, a treatment, perhaps a leave-in oil — with one scent and one story across all of them. To a Japanese factory those are separate products. Each has its own product-type limits, its own container questions and its own permitted claims, and one word on the shampoo label, “medicated”, can move it into a different legal category altogether. This guide sets out how to brief a hair care line so that each product is checked on its own terms and the set still holds together.
💬 Sunsho Trade manages Japan-made own-brand cosmetics projects in English for brands outside Japan. Send us your hair care line and target claims and we will tell you what the factory needs before it quotes.
Brief the line as separate products
Treat each item in a hair care line as its own product, with its own format, use, container and claims, and say which items must share a scent and look.
The first question a factory asks is whether each product is rinsed off or left on, because Japan’s ingredient limits differ by product type. Shampoo, conditioner and rinse-off treatments are rinse-off products. Leave-in oils, milks and mists stay on the hair and scalp. Sprays raise extra points if they are aerosols.
| Product | Use | Questions for the brief |
|---|---|---|
| Shampoo | Rinse-off, scalp and hair | Lather on wet hair, rinsing speed, how hair feels wet and dry |
| Conditioner | Rinse-off, mainly lengths | Slip when combing wet hair, weight, residue on the scalp |
| Rinse-off treatment or mask | Rinse-off, longer contact | Time on hair, richness, jar or tube |
| Leave-in oil or milk | Leave-on, lengths and ends | Weight, shine, greasiness on fine hair |
| Hair mist or spray | Leave-on, sometimes aerosol | Pump or aerosol, nozzle, shipping class |
If the line shares one fragrance, say so. The factory may need to adjust the fragrance level or composition between a rinse-off shampoo and a leave-in oil, and the ingredient lists will differ even if the scent seems the same.
A Japanese factory will normally start from its existing bases. Whether that suits you, and who owns the result, is covered in stock base or custom formula.
The medicated shampoo boundary
A shampoo built around an active ingredient to claim anti-dandruff action as a “medicated” product is a quasi-drug (医薬部外品), as are hair growth products, permanent hair dyes and perm agents; each needs product-by-product approval.
Under Japan’s PMD Act, shampoo falls within the definition of a cosmetic: something applied to the body to clean it or keep the skin or hair healthy, with a mild action. Quasi-drugs are a separate category. The hair care quasi-drugs typically include anti-dandruff medicated shampoo, hair growth products, and permanent hair dyes and perm agents. These need product-by-product marketing approval (製造販売承認), built around an approved active ingredient, while a cosmetic needs only a product notification before it goes on the Japanese market.
The cosmetic efficacy range also has hair items that mention dandruff and itching. So the line between a cosmetic shampoo and a medicated one is not simply whether the word “dandruff” appears; it depends on whether the product is designed and approved as a quasi-drug with an active ingredient. Decide which route you are on before formula work starts, and keep the artwork consistent with it. The full decision is set out in cosmetic or quasi-drug: the first decision.
Permanent hair dye belongs on the quasi-drug side as well. If your line includes a colour product, ask the factory which category it falls into; a dye product is briefed as its own quasi-drug project.
Restricted ingredients, preservatives and colours
Each hair product is checked against Japan’s Standards for Cosmetics for its product type: preservatives from the Appendix 3 positive list, restricted ingredients within Appendix 2 limits, and colours under 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). Several limits differ between rinse-off products such as soap and shampoo and leave-on products, so a preservative level that fits the shampoo may not fit the leave-in oil in the same line.
Three hair-specific points:
- Colours. Tar colours follow the Ministerial Ordinance on tar colours (Ordinance No. 30 of 1966). Red No. 219 and Yellow No. 204 are permitted only in products used solely on hair and nails, so a hair product has a slightly wider choice than a face product. If the same tinted base is shared with a face or body product, the narrower rule applies to that product.
- Aerosol sprays. Appendix 2 does not permit zirconium in aerosols.
- UV filters. If a hair mist is meant to protect hair from UV, any substance used specifically to absorb UV must come from Appendix 4.
A formula written for another market can fail because a preservative is not on Japan’s positive list or exceeds Japan’s limit for that product type. The check runs ingredient by ingredient before samples, including preservatives carried in by surfactant premixes and extracts. See 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.
💬 Bringing a shampoo or conditioner formula from another market? Send the draft INCI list and we will have it checked against Japan’s lists before any sample is made.
Containers for the shower
Choose hair care containers for wet hands and a hot, humid bathroom, and have the factory test compatibility in the bottle, pump or tube you will sell.
Questions to raise with the factory:
- Pumps. Can the pump handle the shampoo’s viscosity, and does it keep working after water gets on the head?
- Bottles. Is the bottle material compatible with the formula, including the fragrance, over the product’s life?
- Tubes and jars for treatments. A jar is easy to scoop from but takes in water from wet fingers. A tube avoids that.
- Refills. If you plan refill pouches, they are a separate container and need their own compatibility check.
The factory designs the stability programme — typically temperature, light, cycling and container contact — and there is no single Japanese statutory protocol for it. Ask for the result in the container you will ship. See stability and compatibility testing and containers and packaging.
What to test on the samples
Test hair care samples on real hair, in the water and climate where you will sell, and judge each product both wet and dry before you approve a sample code.
A useful review covers:
- Lather. How quickly the shampoo foams on wet hair, and how the foam holds during washing.
- Rinsing. Whether shampoo and conditioner rinse cleanly or leave a coated feel.
- Wet feel. For conditioner and treatment, how easily a comb moves through wet hair.
- Dry result. Volume, weight and softness once hair is dry, on more than one hair type if your customers vary.
- Scent on hair. How the fragrance smells during use and after drying.
- Line consistency. Whether shampoo, conditioner and treatment look and smell as one set.
Climate matters: a conditioner that suits a dry climate may feel heavy in a humid one. Record the sample code you approve for each product. That sample becomes the production standard, and any change afterwards is a new sample.
What a hair care label may say
As cosmetics, hair products may use only the hair items of Japan’s 56-item efficacy range that apply to them, such as “cleans the scalp and hair” or “gives hair body and firmness”, plus true descriptions of feel.
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 hair, the items include “cleans the scalp and hair”, “gives hair body and firmness” and an item on removing or suppressing dandruff and itching. Sensory descriptions, such as how hair feels after drying, may be stated if they are true and do not guarantee a result. These are the rule’s words; they describe what a label may say, not a promised outcome. The full list, and why Japanese claim rules matter even for export, is in what a cosmetic label may claim in Japan.
| Draft wording | Where it sits in Japan |
|---|---|
| ”Cleans the scalp and hair” | Within the cosmetic efficacy range |
| ”Gives hair body and firmness” | Within the cosmetic efficacy range |
| Dandruff and itching wording from the cosmetic list | Within the cosmetic range, if it applies to the product |
| ”Medicated anti-dandruff shampoo” | Quasi-drug category, needs an approved active and product approval |
| ”Promotes hair growth” | Quasi-drug category |
| Permanent hair dye or perm product | Quasi-drug category |
Ingredient list, dates and documents
Each product gets its own full ingredient list in Japanese labelling names, which 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 Japan Cosmetic Industry Association’s labelling names, in descending order of amount, with ingredients at 1% or less and colourants in any order among themselves. Shampoos and conditioners are often built from surfactant and conditioning premixes; premixed raw materials are listed ingredient by ingredient. Fragrance may be listed collectively as “fragrance” (香料). Quasi-drugs are not under the same full-listing obligation; under the industry’s voluntary standard they list active ingredients and other ingredients separately. 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 may have its own rules, such as a period-after-opening symbol; check with your importer.
If the line 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. Aerosol sprays may be classed as dangerous goods; section 14 of the safety data sheet states the transport classification. Your importer files the destination notification. We prepare the Japan-side documents described in export documents and certificates; the sequence to shipment is in the export shipping flow. If you want to sell in Japan itself, see importing cosmetics into Japan.
💬 Planning a Japan-made hair care line? See our cosmetics OEM service, the Japan cosmetics OEM guide, or send us your brief.
Frequently asked questions
1. Is shampoo a cosmetic or a quasi-drug in Japan?
Shampoo falls within the PMD Act’s definition of a cosmetic. An anti-dandruff “medicated” shampoo built around an approved active ingredient is a quasi-drug and needs product-by-product approval.
2. Can a cosmetic shampoo mention dandruff?
The cosmetic efficacy range includes a hair item on removing or suppressing dandruff and itching, used only where it applies to the product. A medicated anti-dandruff claim built on an active ingredient belongs to the quasi-drug category.
3. Can the shampoo and leave-in oil use the same preservative level?
Not necessarily. Japan’s Standards for Cosmetics set limits that can differ between rinse-off and leave-on products, so each product in the line is checked for its own product type.
4. Are some colours allowed in hair products but not in face products?
Yes. Under Japan’s tar-colour rules, Red No. 219 and Yellow No. 204 are permitted only in products used solely on hair and nails.
5. Can I add a hair colour product to the line?
Yes, but permanent hair dyes and perm agents are quasi-drugs in Japan. Ask the factory which category your colour product falls into, and brief a dye product as its own quasi-drug project, with product-by-product approval.