The ASEAN Cosmetic Directive and Its Ingredient Annexes Explained

The ASEAN Cosmetic Directive (ACD) is the regional framework that ten Southeast Asian states use to align their cosmetic ingredient rules. It is not a single law that applies directly in any country. Each member state adopts it into its own national legislation, and enforcement, timing and occasional local carve-outs stay with the national regulator. This piece explains what the ACD actually is, who updates its annexes, how the annexes map onto the EU's, and what four real records from the site's ASEAN dataset show about where the two regimes match and where they part ways.

What the ASEAN Cosmetic Directive is

According to Singapore's Health Sciences Authority (HSA), the ACD is an agreement among ASEAN countries to harmonise the requirements for cosmetic products so as to reduce technical barriers to trade in the region. Singapore implemented it on 1 January 2008. The ten member states that implement the ACD through their own national law are Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. In practice this means the ACD sets a shared ingredient framework, and each country's own cosmetics act, regulation or notification system is what actually binds a company selling in that market.

Who updates the annexes: the ASEAN Cosmetic Committee and Scientific Body

Two ASEAN bodies keep the ingredient annexes current. The ASEAN Cosmetic Committee (ACC), which sits under the ASEAN Consultative Committee on Standards and Quality, coordinates and monitors implementation of the ASEAN Harmonized Cosmetic Regulatory Scheme (including the ACD and the ASEAN mutual-recognition arrangement for product registration) and reviews and updates the technical annexes when necessary. The ASEAN Cosmetic Scientific Body (ACSB), made up of representatives from national regulators, industry and academia, assists the ACC by reviewing the technical and safety data behind ingredient-list changes before the ACC adopts them. HSA's own description of the process states that the ACC and ACSB meet twice a year to discuss regulation and harmonisation across the region, including amendments to the annexes. That twice-yearly cadence is the main reason ASEAN annex updates tend to arrive in batches rather than as one-off changes, and why a member state's transposition into national law can lag the ACC/ACSB meeting date by months.

How Annexes II-VII are organised, and how they map to the EU annexes

The ACD's ingredient annexes follow the same broad shape as the EU Cosmetics Regulation's, because the ACD was built to track it, but the numbering is not identical everywhere. Based on the site's own ASEAN records: Annex II is the list of prohibited substances (the largest annex by far). Annex III is the list of substances allowed only under stated restrictions and conditions, such as maximum concentration, product type or required warnings. Annex IV covers permitted colouring agents. Annex VI is the positive list of permitted preservatives. Annex VII is the positive list of permitted UV filters.

That is the point worth double-checking before quoting a number from memory: in the EU Cosmetics Regulation, preservatives sit in Annex V (54 entries in the site's EU data) and UV filters sit in Annex VI (33 entries, for example Octocrylene as entry VI/10). In the ACD, the equivalent positive lists are one letter further along: preservatives in Annex VI and UV filters in Annex VII. A record found in "ASEAN Annex VII" is therefore the UV-filter counterpart of an EU Annex VI entry, not a mismatch or a numbering error. Annex II (prohibited) and Annex III (restricted) keep the same letters in both systems, and for entries that ASEAN carried over unchanged, the ASEAN and EU entry numbers can match exactly too, as the worked examples below show. Readers can browse the ASEAN annex pages directly at cosingchecker.com/regulations/asean/, and use cosingchecker.com/market-compare/ or cosingchecker.com/market-divergence/ to line an ASEAN record up against the EU one for the same CAS number.

How many ASEAN records the site holds

As of this writing, the site's jurisdictions endpoint reports 2,224 published ASEAN records, each one a single ingredient entry drawn from the ACD annexes with its own status, source annex, reference number and source-update date. That is a record count, not a substance count: a handful of entries list more than one CAS number under one heading (see the hydrolyzed wheat protein example below), and some substances appear once as a prohibition and again, separately, as a restricted or positive-list entry.

Four worked examples from the ASEAN annex III and other ASEAN records

These four are drawn directly from the site's ASEAN dataset and cross-checked against the matching EU CosIng entry for the same CAS number. They are examples of what a comparison across two live regulatory datasets actually looks like, not a verdict on whether any of these ingredients is safe to use.

1. Musk ketone, musk xylene and hydroquinone: identical entry numbers

Musk ketone (CAS 81-14-1) is restricted entry 97 in the site's EU Annex III data, with limits of 1.4% in fine fragrance, 0.56% in eau de toilette and 0.042% in other products. The site's ASEAN record for the same CAS number is "ASEAN Annex III, reference 97", with the same three concentration limits and the same product scope. Musk xylene (CAS 81-15-2) matches the same way: EU Annex III entry 96 and ASEAN Annex III reference 96 carry the same 1.0%/0.4%/0.03% tiered limits. Hydroquinone used in artificial nail systems (CAS 123-31-9) matches too: EU Annex III entry 14 and ASEAN Annex III reference 14 both cap it at 0.02% after mixing, for professional use only. For these three substances, the ACD appears to have carried the EU's restricted-list entry number straight across.

2. Triclosan: two ASEAN annex entries where the EU has one

Triclosan (CAS 3380-34-5) is entry 25 in the site's EU Annex V (preservatives) data, capped at 0.3% in toothpastes, hand soaps, body soaps and shower gels, non-spray deodorants, face powders and blemish concealers, and nail-cleaning products used before artificial nail systems, and not in toothpaste for children under 3. The ASEAN list is longer. In the site's ASEAN data, the corresponding positive-list preservative entry, "ASEAN Annex VI, reference 25", adds shampoo, hair conditioner and facial cleanser at 0.3% and mouthwash at 0.2% - uses the EU entry does not list. A product built to the ASEAN list is not automatically compliant in the EU. But the site's ASEAN data also carries a second, separate Triclosan record, "ASEAN Annex III, reference 288", restricted for the same, longer ASEAN product list at the same 0.3%/0.2% limits. Annex III is the ACD's general restricted-substances list, distinct from Annex VI's preservatives-only positive list, so the same active substance is captured twice under two different ACD annexes with matching limits. That double listing is a feature of the source annexes themselves, not a site error, and it is a reminder that checking only one ASEAN annex for a given ingredient can miss a second, parallel entry.

3. Hydrolyzed wheat protein: same technical limit, different entry number, and a country carve-out

Hydrolyzed wheat protein (CAS 94350-06-8, among others) is EU Annex III entry 307 (as consolidated) under Regulation (EU) 2017/2228, which introduced a maximum peptide molecular weight of 3.5 kDa after reports of wheat-allergy sensitisation from cosmetic use. The site's ASEAN record for the same CAS numbers is "ASEAN Annex III, reference 323": the same 3.5 kDa ceiling, but a different reference number (323, not 307) and an added national condition, "Except Indonesia". The site's data does not explain why Indonesia is excepted, and that has to be checked against Indonesia's own national implementation rather than assumed; the point for this example is that the ACD can adopt an EU technical limit essentially unchanged while still renumbering the entry and layering a member-state-specific exception on top.

4. UV filters: an annex-letter shift, not a discrepancy

Among the site's ASEAN Annex VII records tris-biphenyl triazine (CAS 31274-51-8), "ASEAN Annex VII, reference 29", permitted at up to 10%, including as a nanomaterial, and not in sprays. The EU permits the same substance in its Annex VI, and the EU's UV filters sit in the site's EU Annex VI data (33 entries total, including Octocrylene as entry 10 and Ethylhexyl Methoxycinnamate as entry 12). Anyone comparing the two datasets by annex letter alone would conclude ASEAN has no UV-filter annex matching EU Annex VI; in fact it does, one letter over, in Annex VII, for the reason explained above.

What these records do and do not tell you

A record on this site, ASEAN or EU, is identity evidence: it tells you that a named substance appears in a specific annex, under a specific reference number, with specific conditions, as last synchronised from the official source. It is not a permission slip and not a safety verdict. The absence of a substance from the site's ASEAN data means it is absent from the data the site has ingested, not that it is unregulated in any of the ten member states; national gazettes, circulars and transition periods can add restrictions the regional annexes have not yet caught up with, or vice versa. Anyone formulating for the ASEAN market should treat the ACD annexes as the regional baseline and still confirm the current national position with the relevant regulator, such as HSA in Singapore or NPRA in Malaysia, before relying on a limit or an exception.

Sources

• ASEAN Cosmetic Directive — Health Sciences Authority, Singapore — https://www.hsa.gov.sg/cosmetic-products/asean-cosmetic-directive/
• Regulation (EU) 2017/2228 (hydrolyzed wheat protein peptide molecular weight limit) — EUR-Lex — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R2228
• Regulation (EU) 2024/996 (Triclosan restriction update) — EUR-Lex — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R0996
• Regulation (EC) No 1223/2009 on cosmetic products, Annexes II-VI — EUR-Lex — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223
• cosingchecker.com ASEAN jurisdiction data — https://cosingchecker.com/api/v1/jurisdictions/
• cosingchecker.com ASEAN annex records — https://cosingchecker.com/api/v1/jurisdictions/asean/rules/
• cosingchecker.com EU CosIng entries — https://cosingchecker.com/api/v1/entries/
• cosingchecker.com EU annex statistics — https://cosingchecker.com/api/v1/stats/
• cosingchecker.com ASEAN regulations page — https://cosingchecker.com/regulations/asean/