1. The short answer: the ACD harmonises what must be printed, not how
Cosmetic labelling across Southeast Asia rests on one document: Article 6 of the ASEAN Cosmetic Directive (ACD) and its Annex I, Part 7, ASEAN Cosmetic Labelling Requirements. It lists the particulars that must appear on the label, so roughly eight tenths of a label designed in China transfers unchanged to any ASEAN market.
Three things are left to each country: the language, whether the local notification number goes on the label (the one that trips up most suppliers — see section 3), and what may be dropped when the container is small. A single version for ten countries does not work. One artwork file with a reserved switch area, printed in market-specific rolls, does.
2. The nine ACD particulars
| # | Particular | Requirement | What it means at press |
|---|---|---|---|
| 1 | Name and function | An invented name plus trade mark is acceptable; function may be omitted if obvious from the presentation | Do not bury the function in 4 pt type beside the product name — reviewers look for it |
| 2 | Directions for use | May be omitted if clear from the name or presentation | Reserve two or three lines; keep it in its own column, not fighting the ingredient list |
| 3 | Full ingredient listing | Descending order by weight; below 1% any order, after those above 1%; perfume may be declared as fragrance/perfume/aroma; colourants may use CI numbers, listed last, with "may contain" or "+/-" for shade ranges; botanicals by genus and species | The longest block on the label — 30 to 50 ingredients is normal. Legibility here decides whether the label passes inspection |
| 4 | Country of manufacture | Stated on the label | Must match the certificate of origin and customs paperwork — pick one wording and keep it |
| 5 | Responsible company | Name and address of the company placing the product on the market — usually the local notification holder or importer | Not the factory address. This line changes per market and is the first thing to put in the switch area |
| 6 | Nominal content | Weight or volume, metric (imperial may be added) | Must match the actual fill; leave room for both g and ml conventions |
| 7 | Batch number | Manufacturer's batch code | Plan a coding window — see section 5, point 5 |
| 8 | Manufacturing or expiry date | Clearly expressed (month/year or day/month/year). Expiry date is mandatory when minimum durability is under 30 months; at 30 months or more, a PAO symbol may be used | The PAO symbol needs a minimum readable size you define yourself; avoid ambiguous all-numeric dates |
| 9 | Special precautions | Warnings listed in the ingredient annexes, professional-use statements, and declaration of animal-origin ingredients (bovine or porcine must be named) | Warnings are the first line an inspector reads. Leave white space rather than shrink the type |
One general rule is often missed: labelling must be easily legible, clearly comprehensible and indelible. In press terms that rules out varnishes that rub off, type that cannot be read at arm's length, and label positions worn by handling.
3. Where the three main markets differ
Indonesia: Bahasa Indonesia, the BPOM number, a 2D barcode
- BPOM Regulation 18/2024 (labelling, promotion and advertising) has applied since 28 November 2024; the 12-month transition for existing products has ended.
- Language: benefits, directions and warnings must be in Bahasa Indonesia; other items may be in Indonesian or in a foreign language written in Latin letters and Arabic numerals.
- Required on the label: product name, benefits and directions, composition, country of manufacture, full name and address of the notification holder, batch number, net content, expiry date, notification number, 2D barcode, warnings.
- Notification number format: N plus a region letter (NA Asia, NB Australia, NC Europe, ND Africa, NE Americas) plus 11 digits. One notification per product, valid three years, and only an Indonesian entity can hold it — in practice your importer.
- Imported packs may carry an added Indonesian sticker, provided every item matches the notified data.
- The halal logo may only be used on certified products — never printed ahead of certification.
Thailand: all Thai, and only six items when the label is tiny
- Under the Cosmetics Act B.E. 2558 and the Cosmetics Committee labelling notification B.E. 2562 (2019), a Thai-language label must be affixed before sale — clearing customs without one is not compliance. Other languages may appear alongside, but cannot replace the Thai text.
- Twelve items: name/trade name, type or function, full ingredients (descending; under 1% and colourants may follow), directions, manufacturer or importer name and address (imports also name the manufacturer and country of origin), net content, batch number, manufacturing date, expiry date (only when shelf life is under 30 months), warnings, the cosmetic notification number, and the red statement that injection is prohibited and the product is for external use only, on both primary and secondary packaging.
- Labels under 20 cm² may carry only six items: name, batch number, manufacturing date, expiry date, notification number, and the red statement. The rest goes on a leaflet or outer carton.
- The cosmetic notification number must not be placed inside the food or medicine อย. frame — a routine artwork error that reviewers flag immediately.
Malaysia: the notification number must not be printed
- Language: Bahasa Malaysia and/or English — one of the two is enough, bilingual is not required.
- The name and address on the label belong to the CNH (Cosmetic Notification Holder), not the importer and not the factory.
- The notification number is not printed on the label. NPRA states that since 1 January 2008 the notification number (format NOTyymmxxxxxK, valid two years) is not to be printed on the product label. This is the single most common error we see from overseas suppliers: the same artwork needs the number added for Indonesia and Thailand, and removed for Malaysia.
- Small packages may use a leaflet, hang tag, display panel or shrink wrap for the full information, but the immediate packaging must still carry at least the product name and batch number; bulk containers at least the product name, manufacturer's name and batch number.
- A halal logo may be used voluntarily, only if certified by JAKIM or a JAKIM-recognised body.
Vietnam, the Philippines and Singapore also build on the ACD, with their own language and notification rules. We only write in detail about the three markets whose official documents we could check line by line. For the others, ask your importer for the current notice before the artwork is finalised — that is cheaper than printing a whole run against the wrong version.
4. What to drop when the label is small
- ACD general rule: where size, shape or nature of the container does not allow the full particulars, leaflets, hang tags, display panels or shrink wrap may carry them — but the immediate packaging keeps the product name and batch number, and bulk containers keep the product name, manufacturer's name and batch number.
- Thailand sets a number (20 cm², six items). Indonesia and Malaysia do not, so for sample bottles and travel sizes, ask the market first and lay out second. Do not apply the Thai rule everywhere.
- A leaflet is printed matter, not an exemption: the ingredient list on the leaflet and on the bottle must be the same revision. Update both together, or the warehouse ends up holding two versions.
5. Five things that actually fail on cosmetic labels
1. The ingredient block
Thirty to fifty INCI names below 6 pt, reversed out, on a clear substrate, is where labels get printed but not read. Use solid K100 black for regulatory text, no smaller than 6 pt, leading at 1.2 or more; when reversing out of a dark solid, add about 0.5 pt to compensate for dot gain; avoid four-colour builds for small type — one plate drifting blurs the lot; print at 175 lpi or above, or digitally, rather than saving money on a coarse screen.
2. Split the artwork into a regulatory zone and a brand zone
Fix the nine particulars inside one rectangle; when the market changes, only the text in that rectangle changes. Three market versions then cost one design fee, and the logo stops wandering between editions.
3. The bottle decides the adhesive, not the price
- PE / PP / PET: low surface energy — use a modified acrylic adhesive. A standard adhesive looks fine for two weeks and then lifts.
- Glass: general-purpose permanent adhesive, but test for condensation if the product is chilled.
- Curvature radius under 30 mm: thin face stock with a soft adhesive, or the edges lift. This is the most common cause of returns on round bottles.
- Body wash, sunscreen, essential oils: oils, alcohol and surfactants demand a chemical-resistant adhesive, proven by a 72-hour immersion test before the run.
4. The other side of the "no-label look"
A clear PET label on a clear bottle looks right until the regulatory text sits over a dark product and disappears. Print a white base coat under the regulatory zone and keep the brand zone clear. Decide this at proof stage — adding a white plate later means new plates.
5. The coding window
Batch and expiry need at least 8 × 3 mm of clean white, away from the tightest part of the curve. Thermal transfer is sharpest and resists alcohol; inkjet is fast but wipes off with alcohol; laser suits paper only and can burn through film. On curved surfaces allow a tolerance, or depth varies across the run.
6. An eight-line pre-press checklist you can paste into an email
1 Market / channel: Indonesia / Thailand / Malaysia (which market, which channel)2 Notification number: NA… / CNN… / not printed in Malaysia (attach the notification document)3 Holder name and address: character-for-character as notified, including postcode4 Language version: Indonesian / Thai / Malay or English (bilingual or not)5 Ingredient list: INCI revision date, number of entries, any nano declaration, "may contain" shade list6 Net content and dates: g/ml; manufacturing and expiry dates (or PAO symbol)7 Container: material, diameter/curvature, capacity, clear or opaque, direct food/body contact8 Format and adhesive: roll (unwind direction, core, labels per roll) or sheet; water/oil/alcohol resistance or removable
7. Six checks before the cartons ship
- Hold the notification document against the label: number, name and address, product name. For Malaysia, confirm the number is absent.
- Ingredient order: above 1% descending, below 1% after, CI numbers last, fragrance declared in the accepted wording.
- Dates: expiry present when shelf life is under 30 months; PAO present and readable otherwise; no ambiguous numeric-only format.
- Thai, Indonesian or Malay copy proofread by a local speaker or your importer — machine translation of warnings is a leading cause of rejection.
- Apply one label to the actual bottle and inspect at 24 and 72 hours for lifting and bubbles.
- Carton marking: product, market, language version, notification number, batch, quantity per carton — so mixed runs cannot be shipped to the wrong market.
8. Three questions buyers ask us
Can one version cover all three markets?
No. The nine particulars are shared, but Indonesia needs Bahasa Indonesia plus the BPOM number and a 2D barcode; Thailand needs full Thai plus the notification number and the red statement; Malaysia needs Malay or English and must not carry the number. Use one artwork, three text layers, and market-specific rolls marked on the carton. The extra cost is small next to a rejected shipment.
Can we print in China and add the notification number locally?
Indonesia explicitly allows an importer to add an Indonesian sticker, provided every item matches the notified data; Thailand requires the Thai label to exist before sale. Over-stickering is a fallback, not a method: the labour and error rate usually cost more than printing it correctly.
The ingredient list is long — can we set it at 4 pt?
The ACD asks for legibility, not a millimetre figure, but 4 pt fills in on an offset press and disappears on a curve, and inspections are done by eye. Our working floor is 6 pt at 1.2 leading; if it does not fit, use a leaflet or a larger label rather than shrinking the type.
9. Three things to send with your next label order
- The target market and the local notification document (PDF or scan, with number and holder address);
- Your current artwork (AI or PDF with live text) and a photo of the container, including diameter and capacity;
- Quantity, format (roll or sheet) and how the label is applied (manual or automatic line).
Related reading: Food labels in Southeast Asia: language and format, Indonesia's halal label, Over-stickering on arrival in Hong Kong, Specifying a roll label.
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