A Thai factory can fill a serum or a sunscreen under your brand quickly. What takes longer is the question nobody puts in the first email: is this product going to be sold in Thailand, or only exported? Thailand’s cosmetics law treats those two routes differently, and the answer decides who files with the regulator, what goes on the label, and which certificates your importer can later be given.
💬 Looking for a Thai manufacturer for a cosmetic under your own brand? For each project we find, vet and manage the factory that fits the product, and map the filing route before the first sample. See sourcing from across Asia, or send us the product brief. How we work there: our sourcing agent service for Thailand.
Finding and checking Thai companies, and obtaining a certificate of origin, are covered in our buyer’s guide to sourcing from Thailand. This article starts where that one stops: the factory exists, and now the product has to be made and filed correctly.
The two routes under Thailand’s Cosmetics Act
A cosmetic made in Thailand is either notified to the Thai FDA for manufacture and sale, or made for export to the buyer’s own requirements under the Act’s export provision, and a product on the export route may not be sold in Thailand.
The Cosmetics Act B.E. 2558 (2015) sets the frame. Article 14 says anyone wishing to manufacture, import for sale, or subcontract for the manufacture and sale of cosmetics must file a notification, and may start manufacture or import only after the notification receipt is issued. The Act defines “manufacture” widely, to include mixing, preparing, packing in portions and repackaging, so a site that only fills your bulk into tubes is still manufacturing.
Article 35 is the export provision. In the interest of exporters, cosmetics made for export may follow the quality, standards, labelling or other requirements of the buyer abroad. The manufacturer or exporter must give the regulator complete details and follow the rules the Secretary-General issues, and products made this way may not be sold in Thailand.
| Route A: notified for sale in Thailand | Route B: made for export to the buyer’s requirements | |
|---|---|---|
| Legal basis | Article 14, notification before manufacture | Article 35, export provision |
| Formula and label follow | Thai rules | The buyer’s destination requirements |
| Sale in Thailand | Allowed once the receipt is issued | Prohibited |
| Thai-language label | Required before sale (Article 22) | Not required for the export pack, unless the destination requires it |
| Regulator still informed | Yes, by notification | Yes, the Act requires complete details to be given |
Checked against the English translation of the Cosmetics Act B.E. 2558 (2015) published by the Thai FDA, and the Thai FDA’s cosmetics pages, on 17 October 2026. The Act has been amended since 2015 and translations can lag behind; confirm the article numbers against the current Thai text before you rely on them in a contract.
Choose the route on commercial grounds. If there is any chance you will sell in Thailand or use a Thai-sold product as a reference market for another country’s filing, plan for Route A from the start.
Who files, and why it matters to a foreign brand
The Act lets the party who subcontracts manufacture be the notifying party, but the Thai FDA’s filing system is built around a business operator in Thailand, so a foreign brand usually files through the factory or a Thai company acting for it.
The Act’s definition of “notifying party” covers manufacture for sale, import for sale, and subcontracting for manufacture. In other words, the brand that hires the factory can in principle be the notifier, not only the factory itself. The Thai FDA’s application page lists manufacturers, contract manufacturers and importers as notifiers, and says an e-submission account needs the national identification number of the business operator or its representative.
For a brand based outside Thailand, that leaves the same choice as with food:
- The factory notifies. Fast, but the notification receipt is in the factory’s name. If you move production, the next factory notifies again.
- A Thai company acting for the brand notifies, naming the factory as manufacturer. Slower to set up, but the brand keeps control of the record.
The notification receipt is valid for three years from issue (Article 15), and the Thai FDA’s page says it may be renewed in the six months before expiry. Write into the manufacturing agreement who holds the receipt, who renews it, and what happens to it if the contract ends.
Check the facility documents, not just the certificates on the wall
Every site that manufactures, contract-manufactures, imports or stores cosmetics needs a Thai FDA facility inspection report under the 2018 Ministry of Public Health notification, so ask to see it for the exact site that will make your product.
The Thai FDA refers businesses to the Notification of the Ministry of Public Health on Rules, Procedures and Conditions on the Manufacture or Importation of Cosmetics, B.E. 2561 (2018), and to a process for issuing inspection reports for manufacturing, import and storage facilities. The process also applies when a facility is new or relocated.
| Document to see | What it tells you |
|---|---|
| Thai FDA facility inspection report for the site | The site has been assessed for cosmetic manufacture under the 2018 notification |
| Notification receipts the factory holds for comparable products | The factory files with the Thai FDA routinely, and for which product types |
| Ingredient documentation from raw-material suppliers | Whether the factory can support an ingredient list for your destination |
| Any private certification your retailer or importer requires | Not a Thai legal requirement; agree it in writing if your customer needs it |
A group with several plants may hold an inspection report for one site and propose to fill at another. Match the address on each document to the site you visit. How to run that visit is covered in our factory audit checklist, which applies to a Thai cosmetics plant with these documents added.
💬 Need to know which route your product should take, and whether the factory’s documents match the site? We check this before any formula is frozen. Tell us the product and where it will be sold.
Formula, claims and samples
Agree who owns the formula, keep every claim to what the destination allows, and use the Act’s sample exemption for pre-launch samples rather than notifying a product that is not final.
Formula ownership. A factory may offer a ready formula it has developed and sells to several brands, or develop one for you. Both are common. The difference is what you own at the end: with the factory’s formula, you may own the brand and artwork but not the formula, and you may not be able to take it to another factory. Put the answer in the agreement.
Ingredient list. Ask for the full ingredient list in the naming convention your destination uses, and for any ingredient restrictions the factory has checked against your destination. Thai compliance does not establish compliance elsewhere.
Claims. The Thai FDA says label claims must be truthful, within the scope of a cosmetic and supported by evidence. Treat this as a floor, not a ceiling: the destination’s own boundary between cosmetics and medicines or quasi-drugs decides what you may say there. Do not let a factory’s marketing sheet supply your claims.
Samples. Article 16 exempts samples manufactured or imported for exhibition or promotional display, or for study, research or laboratory analysis, from the notification requirement, subject to the Minister’s rules. That is the route for development samples and lab testing, before the formula is final. Confirm the conditions with the factory before shipping samples abroad.
How to freeze each sample stage so the production lot matches what you approved is covered in sample approval stages.
Labels: what the Thai label must say, and what the export label follows
A cosmetic sold in Thailand must carry a Thai-language label that names the manufacturer and its location, so a private-label product sold in Thailand will show the factory, while an export-route product follows the destination’s label rules instead.
Article 22 lists what a label must contain. For products made in Thailand this includes the name and trade name of the cosmetic, the name and location of the manufacturer, the quantity, directions for use, cautions and warnings, the month and year of manufacture and the expiry date, the batch number, and the names of all ingredients. The information must be in Thai and easily legible, with foreign-language text allowed alongside.
Two consequences for a brand owner:
- On Route A, the factory’s name and location appear on the Thai label. If your commercial plan depended on not disclosing the manufacturer, raise it before choosing Route A.
- On Route B, the destination decides. Japan, for example, requires a licensed marketing authorisation holder in Japan and Japanese labelling; see importing cosmetics into Japan. Design the export artwork to the destination’s rules and have it checked there.
Export certificates: which ones exist, and which route can get them
The Thai FDA issues three cosmetic e-Certificates, a Certificate of Free Sale, a Certificate of Manufacturer and a Certificate of Product Origin, and the free-sale certificate is the one most likely to depend on the product being notified for sale in Thailand.
| Importer’s request | Thai document that usually answers it | Check before you promise it |
|---|---|---|
| Proof the product is freely sold in the country of manufacture | Thai FDA Certificate of Free Sale | A Route B product may not be sold in Thailand, so it may not qualify; confirm with the factory and the Thai FDA |
| Proof that a named site manufactures the product | Thai FDA Certificate of Manufacturer | The site named must be the site that produces your lot |
| A statement of where the product was made | Thai FDA Certificate of Product Origin | This is not a preferential certificate of origin under a trade agreement |
| A preferential certificate of origin for a lower duty rate | Department of Foreign Trade | Issued under a specific agreement; see the Thailand buyer’s guide |
The Thai FDA’s e-Certificate system came into effect on 1 May 2025, and certificates can be checked through its online verification system. The same announcement says English company and site addresses now follow a standardised format, while the Thai address is unchanged. Use the factory’s English address exactly as it appears on its Thai FDA documents in your own invoices and filings.
Checked against the Thai FDA’s e-Certificate pages on 17 October 2026.
If your destination’s cosmetic filing needs a free-sale certificate from the country of manufacture, that alone may push you to Route A. Ask your importer before the route is fixed, not after the first lot is packed.
Step by step: from brief to first shipment
Fix the route, the notifier, the site documents, the formula ownership and the certificates, and only then compare prices.
| Step | Decision | Output |
|---|---|---|
| 1. Route | Sold in Thailand (Article 14) or export only (Article 35) | One line in every request for quotation |
| 2. Notifier | Factory or a Thai company acting for the brand | Clause in the manufacturing agreement |
| 3. Site documents | Facility inspection report for the actual site | Copies matched to the site visited |
| 4. Formula | Factory formula or developed for you; who owns it | Written ownership terms |
| 5. Label | Thai label (Route A) or destination label (Route B) | Approved artwork per market |
| 6. Certificates | Which Thai FDA and origin documents the importer needs | Agreed list before production |
| 7. Price | Quotations rebuilt on the same basis | See comparing Asian quotations on landed cost |
If the same brand also plans food or supplement lines, the food version of this route is in food contract manufacturing in Thailand.
💬 Want the filing route and certificate list settled before you compare factories? We handle this for cosmetics projects in Thailand and across Asia. Send us your brief.
Frequently asked questions
1. Does a cosmetic made in Thailand for export need a Thai notification?
The Act’s export provision, Article 35, lets cosmetics made for export follow the buyer’s requirements, but the manufacturer or exporter must still give the regulator complete details under the Secretary-General’s rules. Products made this way may not be sold in Thailand.
2. Can my overseas company be the notifier?
The Act allows the party who subcontracts manufacture to notify, but the Thai FDA’s e-submission system is built around a business operator identified in Thailand. In practice a foreign brand files through the factory or a Thai company acting for it.
3. Will the factory’s name appear on my product?
For a cosmetic sold in Thailand, yes. Article 22 requires the label to show the name and location of the manufacturer for products made in Thailand. For an export-route product, the destination’s label rules apply.
4. How long is a Thai cosmetic notification valid?
Three years from the date of issue under Article 15. The Thai FDA’s page says it can be renewed in the six months before expiry.
5. Is the Thai FDA Certificate of Product Origin the same as a certificate of origin for duty?
No. It is a Thai FDA product certificate. Preferential certificates of origin under trade agreements are issued through the Department of Foreign Trade under the specific agreement.
Sources: Cosmetics Act B.E. 2558 (2015), English translation published in the Thai FDA data catalogue (catalog.fda.moph.go.th), Articles 4, 14, 15, 16, 22 and 35; Thai Food and Drug Administration, “How to Apply for Permission on Cosmetics?”, cosmetics FAQ listings, and e-Certificate pages and announcement (en.fda.moph.go.th). Checked on 17 October 2026.