The first decision: cosmetic or quasi-drug
In Japan, what the label claims decides the regulatory category — and the category decides how the product is made, approved and documented.
Japan’s Act on Pharmaceuticals and Medical Devices defines a cosmetic as something applied to the body to clean, beautify, add attractiveness, change the appearance or keep the skin or hair healthy, with a mild action on the body (Article 2(3)). Products that claim certain active effects — the quasi-drug wording for whitening, acne prevention as an active effect, anti-dandruff medicated shampoo, deodorants, hair growth — are quasi-drugs (医薬部外品) instead. A cosmetic is notified; a quasi-drug needs product-by-product approval and a manufacturing site licensed for quasi-drugs.
Many overseas briefs mix the two without knowing it: a “brightening serum” or a “wrinkle cream” is an ordinary cosmetic in some markets and a quasi-drug claim in Japan. We settle the category with you before any formula work. See how to decide between a cosmetic and a quasi-drug.
The formula check: Japan’s Standards for Cosmetics
Japan controls cosmetic ingredients through positive lists and limits, so a formula that sells elsewhere can still fail in Japan.
The Standards for Cosmetics (Ministry of Health and Welfare Notification No. 331 of 29 September 2000, applied from 1 April 2001) prohibit medicinal ingredients and a list of named substances, set maximum amounts for restricted ingredients — often different for rinse-off and leave-on products — and allow preservatives and UV filters only from positive lists. Tar colours follow a separate ministerial ordinance. We run that check ingredient by ingredient before samples, and suggest a compliant alternative where one exists. See the formula check in detail.
What a Japanese label may say
A cosmetic in Japan may claim only effects from a fixed list of 56 items, and must list every ingredient.
The efficacy range covers wording such as “moisturises the skin”, “prevents rough skin” and “prevents sunburn”. The 56th item, “makes fine lines caused by dryness less noticeable”, was added on 21 July 2011 and may be used only after the effect has been confirmed by testing. Since April 2001 every cosmetic has had to list all ingredients, in Japanese label names and in descending order of amount, with ingredients at 1% or less and colourants allowed in any order. For export, the same list has to be prepared in INCI names for your market. See the 56-item efficacy range.
Documents your importer will ask for
The Japan side can provide the manufacturing and product documents; what the destination authority wants is confirmed with your importer first.
| Document | What it shows | Who issues it |
|---|---|---|
| Export manufacturing notification | A product made to an export-only specification, notified before production starts | Filed with the Minister of Health, Labour and Welfare through PMDA |
| Certificate of manufacture and sale (Form 3) | A named product is manufactured and sold in Japan — product name only, not ingredients | Ministry of Health, Labour and Welfare, where the destination’s law requires it; applied for through JCIA |
| Industry certificates | Licence status, manufacture, and manufacture in line with ISO 22716 | Japan Cosmetic Industry Association |
| Ingredient list in INCI | The full formula in the names your market uses | Prepared from the factory’s formula |
| Certificate of analysis, SDS | Batch test results; hazard and transport information | The factory |
Checked against the Ministry of Health, Labour and Welfare notice on certificates for export cosmetics of 27 July 2026, JETRO’s Q&A on exporting cosmetics from Japan and the published pages of the Japan Cosmetic Industry Association on 17 October 2026. See the export documents guide.
Manufacturing quality in Japan
Japanese cosmetic manufacturing works to good manufacturing practice based on ISO 22716, which the industry adopted as its own standard in April 2008.
The Japan Cosmetic Industry Association adopted ISO 22716 as the industry’s voluntary cosmetics GMP standard in April 2008, and the Ministry withdrew its older technical guideline in response. Our production takes place at a GMP-certified partner factory in Japan. If you want to sell in Japan itself as well, the licence route is different — see the licences needed to sell cosmetics in Japan.
From brief to shipment
Six steps, each agreed in writing before the next starts.