Product development & OEM

Before you choose a cosmetic manufacturer in Thailand or sign an Original Equipment Manufacturing (OEM) contract, it helps to know how Thai law splits duties between the brand and the factory, which ingredients are banned or limited, and what the label must show. These points are decided on the day formulation starts. This guide summarises the Cosmetic Act and related Thai FDA notifications for foreign and Thai brand owners, and explains which company in our group handles which part of the work.

Cosmetic OEM in Thailand: who does what

In a cosmetic OEM arrangement, the brand owner hires a factory to make products under the brand's own trade name. Private label cosmetics follow a similar arrangement. The brand owner handles marketing, image and sales. The factory handles production to the quality and formula agreed. Many factories also develop the formula, so a brand does not need its own laboratory or production line.

Formulation and manufacturing on this page are split by product type:

Production terms such as minimum order, price and timing depend on the product type, packaging and the complexity of the formula. The team sets them out in a quotation once it understands your brief.

Choosing a cosmetic manufacturer in Thailand: what to check besides price

Most people comparing cosmetic manufacturers in Thailand start with price and minimum order. From a legal point of view, there are other questions worth asking every manufacturer you are considering:

• Does the site follow the Ministry of Public Health rules on criteria, methods and conditions for producing cosmetics? These rules apply to both manufacturers for sale and contract manufacturers.
• Does the factory hold a Thai FDA certificate for its cosmetic manufacturing site, and is it still valid?
• Who will file the cosmetic notification, and who will keep the notification records?
• Does the factory prepare and keep the product information that the law requires?
• Does the contract state clearly who owns the formula, the trade name and the label artwork?
• How are complaints and product recalls handled?

Ask to see the original certificate, or a copy showing a name and address that match the actual production site. Do not rely on advertising alone.

Contract manufacturing in Thailand: who files the Thai FDA cosmetic notification?

Thai cosmetic law uses a notification system rather than the product registration used for medicines: details of each product are filed with the Thai FDA, and the product can be made or imported only after a notification receipt is issued. Section 14 of the Cosmetic Act B.E. 2558 (2015) says that anyone who manufactures for sale, imports for sale or manufactures under contract must file this notification before production or import (Cosmetic Act B.E. 2558 (2015)). B.E. stands for the Buddhist Era, 543 years ahead of the Western calendar. The law therefore treats a contract manufacturer as a party with a duty to notify.

The notification receipt form attached to the Ministry of Public Health Notification on cosmetic notification, dated 22 August 2018, has fields for both the contract manufacturer and the hiring company, so both names appear on the same document (Ministry of Public Health Notification on cosmetic notification, 2018). In practice, agree in the contract who files, who holds the user account in the online system, and what happens if you change factory later.

Another duty that is often overlooked is keeping product information ready for inspection. A Ministry of Public Health notification requires manufacturers for sale, importers for sale and contract manufacturers to prepare this information and keep it at the manufacturing or import site (Ministry of Public Health Notification on keeping cosmetic product information, 2017). The first part includes:

• A copy of the notification receipt and proof of ownership of the product, such as the manufacturing contract
• The full formula, with ingredient names under the International Nomenclature of Cosmetic Ingredients (INCI), the function of each ingredient and the amount of each as a percentage by weight
• The label and any leaflet
• The manufacturing process and the batch coding system
• A summary of adverse reactions reported from use

If officers ask for further documents, they must be provided within 30 days, or within 48 hours in urgent or potentially life-threatening cases. After a product stops being sold, the information must be kept for at least three years.

Ingredient checks before formulation: banned, restricted and preservative lists

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A formula that works well in the lab may still be impossible to notify if it contains a banned ingredient or uses one above the permitted limit. Checking ingredients against Thai notifications should therefore come before you invest in samples or order packaging. Thai cosmetic ingredient lists are split into several groups, such as prohibited substances, substances allowed under conditions, preservatives, colours and UV filters.

Some examples you can look up with the Ingredient search tool on this site:

These examples come from the three main lists: the 2023 notification on prohibited substances, the 2018 notification on substances allowed with names, amounts and conditions, and the 2018 notification on permitted preservatives (Ministry of Public Health Notification on prohibited cosmetic substances, 2023; Ministry of Public Health Notification on restricted cosmetic substances, 2018; Ministry of Public Health Notification on cosmetic preservatives, 2018). Each list has been amended several times since.

Ingredient lists change often. Check the latest version every time before you confirm a formula. The Ingredient search tool shows the source notification and a link to the original document for each entry.

Beyond the substance name, also check product types that a rule restricts, such as rinse-off or leave-on, user groups such as children, and warnings that must be printed on the label when certain substances are used.

Private label cosmetics in Thailand: from brief to a notification-ready formula

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A smooth private label or OEM project usually starts with a clear brief, with legal checks running alongside formulation. A typical sequence is:

1. The brand owner describes the product type, target customers, skin type, key selling points, packaging and sales channels
2. The team checks that the product really falls under cosmetic law and does not cross into a medicine or another category, based on its purpose and the claims you want to make
3. Ingredients are selected and checked against the prohibited, restricted and preservative lists
4. Samples are made and adjusted for texture, scent and colour until the brand owner is satisfied
5. Testing is done where appropriate, such as stability testing through the testing service of VISBIO Co., Ltd.
6. Notification data is prepared and the label is designed to meet the notifications
7. The notification receipt is obtained first, and only then does full production begin

The time each step takes depends on the complexity of the formula, the number of sample rounds and how complete the documents are. The team estimates this in the quotation.

Thai cosmetic label requirements to plan during formulation

Section 22 of the Cosmetic Act requires manufacturers for sale, importers for sale and contract manufacturers to provide labels with clearly legible Thai text that is true. For imported products, this means a Thai label is needed even if the original packaging is in another language. The details are in the Cosmetic Committee Notification on cosmetic labels, B.E. 2562 (2019), which requires the label to show (Cosmetic Committee, 2019):

1. The name of the cosmetic and its trade name, which must be larger than other text
2. The type or kind of cosmetic
3. The names of all ingredients, in descending order
4. Directions for use
5. The name and address of the manufacturer, or of the importer together with the manufacturer's name and country of manufacture
6. Net quantity
7. The batch number or code
8. The month and year of manufacture
9. The month and year of expiry, for products with a shelf life under 30 months or products listed in the annex
10. Warnings required by the notification on warnings, if any
11. The notification number

Several details relate directly to the formula. Ingredients below 1% and colours do not need to be in order, but must follow the ingredients above 1%. Nanomaterials must have '(nano)' after the ingredient name. If the container is so small that the label area is under 20 square centimetres, the label must show at least the name, batch, month and year of manufacture, expiry date where required, and the notification number, with the rest on a leaflet.

If the formula changes after labels are printed, the ingredient list may no longer match the product. Lock the formula before you order printed packaging.

Brand names and claims must pass Thai rules too

Building a cosmetic brand does not end with the formula and packaging. Product names and label text are also regulated. The label notification says that words, pictures and symbols on the label must not be false or materially misleading, and must not suggest that the product contains an ingredient it does not contain, or contains so little that it cannot have the effect claimed.

In practice, these problems often come up at the notification stage:

• A trade name with words that suggest a medicine or treatment, such as STEROID, which the Thai FDA lists among words that cannot be used in cosmetic names
• A product name that highlights one extract that is present only in a very small amount
• Claims that go beyond what a cosmetic may do, such as treating acne or melasma
• Using words like doctor, Dr. or CLINICAL in the name without the supporting documents the Thai FDA requires

Before choosing a name, test yourself with the Banned-words game on this site, or ask the RA Advisor, an AI assistant for Regulatory Affairs (RA) questions that gives initial guidance and cites the notifications it relies on. Then have the team review the name again before filing.

Supplement manufacturer in Thailand: food formulation and active-ingredient extraction

If you are looking for a supplement manufacturer in Thailand, the formula needs to be right before production. For food and dietary supplements, TIBD Co., Ltd. handles formulation, as well as extraction and development of active ingredients from plants. The approach is the same as for cosmetics: check ingredients against the law before you invest. The law is different, however. Food and supplements fall under the Food Act and the Ministry of Public Health notifications issued under it.

Points to check from the start include:

• Whether a plant or plant part is on the list of foods that may not be produced, imported or sold. For example, seeds of Abrus precatorius L. (rosary pea) and extracts from them are listed in the annex to Ministry of Public Health Notification No. 424, B.E. 2564 (2021) (Ministry of Public Health Notification No. 424)
• For dietary supplements, the Ministry of Public Health notification on dietary supplements and its amendments, including the related lists of ingredients and maximum amounts
• If you plan to extract ingredients yourself, the solvent must be one the notifications allow for extraction in food production
• New ingredients without a history of consumption may need a safety assessment first

Legal requirements for food production sites also matter. The rules on food production methods require production records, traceability data and a recall procedure, and mention dietary supplements specifically.

A finished formula does not mean the Thai FDA will approve it. The Thai FDA decides every application. The team helps make the formula and documents as consistent with the notifications as can be checked.

Talk to our team about formulation and OEM

If you are looking for a cosmetic OEM partner in Thailand, or have an idea for a food or dietary supplement you want to turn into a product, send the details through the web form on the Talk to our team page, message LINE @tibdglobal, or email info@tibdglobal.com. The team works in Thai and English.

Information that helps the team understand your project quickly:

• The product type and format, such as serum, cream, powder or capsule
• Ingredients you would like to use, or the selling points you want to communicate
• Your target market, in Thailand or for export
• Reference products or labels, if you have them

The team will contact you to understand the work, then propose a scope and a quotation. Work starts once you agree. In the meantime, try the free Ingredient search to check your ingredients one by one.

Frequently asked questions

References

1. Thai Food and Drug Administration. (2015). [Cosmetic Act B.E. 2558 (2015)] (in Thai). Open document ↗
2. Ministry of Public Health. (2018). [Notification of the Ministry of Public Health on cosmetic notification, issuance, renewal and amendment of notification receipts and issuance of replacement receipts, dated 22 August 2018] (in Thai). Thai Food and Drug Administration. Open document ↗
3. Ministry of Public Health. (2017). [Notification of the Ministry of Public Health on criteria, methods and conditions for manufacturers for sale, importers for sale and contract manufacturers to keep cosmetic product information for inspection B.E. 2560 (2017)] (in Thai). Thai Food and Drug Administration. Open document ↗
4. Ministry of Public Health. (2023). [Notification of the Ministry of Public Health on names of substances prohibited as ingredients in cosmetics B.E. 2566 (2023)] (in Thai). Thai Food and Drug Administration. Open document ↗
5. Ministry of Public Health. (2018). [Notification of the Ministry of Public Health on names, amounts and conditions of substances that may be used as ingredients in cosmetics B.E. 2561 (2018)] (in Thai). Thai Food and Drug Administration. Open document ↗
6. Ministry of Public Health. (2018). [Notification of the Ministry of Public Health on preservatives that may be used as ingredients in cosmetics B.E. 2561 (2018)] (in Thai). Thai Food and Drug Administration. Open document ↗
7. Cosmetic Committee. (2019). [Notification of the Cosmetic Committee on cosmetic labels B.E. 2562 (2019)] (in Thai). Thai Food and Drug Administration. Open document ↗
8. Ministry of Public Health. (2021). [Notification of the Ministry of Public Health (No. 424) B.E. 2564 (2021) on foods prohibited from production, import or sale] (in Thai). Thai Food and Drug Administration. Open document ↗