Malaysia Hair Dye Ingredient Restrictions and Mandatory Warnings

Hair dye is a cosmetic in Malaysia, managed by NPRA under the Control of Drugs and Cosmetics Regulations 1984 and the ASEAN Cosmetic Directive (ACD), and likewise follows the notification system. It warrants special attention because most oxidative hair dyes contain sensitising colorants such as p-Phenylenediamine (PPD) — these are listed in ACD Annex III (Restricted Substances), carry a concentration limit, and also require specified warnings to be printed on the label. Using the wrong concentration or omitting a warning can render the product non-compliant and pulled from shelves, even if it has been notified.

Key restricted ingredients and concentrations

The most common contentious ingredient in oxidative (permanent) hair dyes is PPD and related toluenediamines. Under the restrictions in ACD Annex III:

• PPD: the maximum concentration after mixing with oxidiser and applied directly to hair is 2%, calculated as free base.
• Oxidative hair dyes for professional or general use only: must be used under the conditions listed in Annex III, with the corresponding warnings attached.
• Whether an ingredient is compliant is governed by the latest Annex lists published by NPRA/ACD; NPRA updates the prohibited and restricted lists in line with ASEAN Cosmetic Committee (ACC) decisions (for example, Circular No. 1/2026 in 2026).

Because the lists are updated on a rolling basis, always verify against the "current" version of Annex III before formulating, and do not reuse old values.

Mandatory label warnings

Oxidative hair dyes must present a set of warnings on the label (in Malay/official language alongside), the core of which includes:

• The mixing ratio must be printed on the label.
• "Hair colorants can cause severe allergic reactions. Read and follow instructions."
• "This product is not intended for use on persons under the age of 16."
• "Temporary 'black henna' tattoos may increase your risk of allergy."
• Do not colour your hair if: you have a rash on your face or sensitive, irritated or damaged scalp; you have ever experienced a reaction after colouring your hair; you have experienced a reaction to a temporary 'black henna' tattoo in the past.
• Contains toluenediamines.
• "Can cause an allergic reaction. Do not use to dye eyelashes or eyebrows." (specific to PPD)
• It is recommended to carry out a patch test according to the instructions before use, and to wear suitable gloves.

Other restricted colorants and claim risks

Besides PPD, common oxidative dye precursors and couplers (such as toluene-2,5-diamine, resorcinol, p-aminophenol) are mostly also listed in Annex III, each with its own concentration limit and conditions of use, and must be checked one by one when formulating. Another frequently overlooked minefield is advertising claims: touting absolute or misleading wording such as "PPD-free, absolutely safe, zero allergy" may breach cosmetic claim rules; even when substitute dyes are used, allergies can still occur and "zero risk" should not be claimed. Claims should be consistent with formulation facts, with supporting evidence retained.

Imported vs. local

Whether locally manufactured or imported, hair dye must pass the same notification and ingredient restrictions; the difference is that the notification is held by the local Company Notification Holder (CNH) who bears market responsibility, and an imported product's ingredient documentation, GMP and safety assessment should be filed in the Product Information File (PIF). Common overseas formulations (such as PPD >2% after mixing, or missing the 16-year warning) may not meet Malaysian requirements, so check item by item before importing, and in particular confirm that warnings are translated into a locally recognisable language and presented in full.

Common mistakes

• PPD concentration after mixing exceeds the 2% free-base limit.
• Omitting the "do not use on eyelashes or eyebrows" or 16-year age warning.
• Reusing old Annex III values and ignoring NPRA's latest circular updates.
• Treating hair dye as an ordinary cosmetic, ignoring the mixing ratio and patch-test prompt.

Frequently asked questions (FAQ)

Q: Does hair dye need to be notified in Malaysia? Yes. Hair dye is a cosmetic and must be notified to NPRA, complying with the ingredient restrictions and label warnings of ACD Annex III.

Q: What is the PPD concentration limit? In oxidative hair dyes, the maximum concentration of PPD after mixing with oxidiser and applied directly to hair is 2%, calculated as free base; the actual limit is still governed by the latest NPRA/ACD Annex.

Q: Can hair dye be used to dye eyebrows or eyelashes? No. The label of PPD-containing hair dye must state "do not use to dye eyelashes or eyebrows" — this is a mandatory warning.

Q: Must the label state an age restriction? Yes. Oxidative hair dyes must display warnings such as "not intended for use on persons under 16" and note that they may cause severe allergic reactions.

Q: Are the ingredients of imported hair dye as strict as local? The same. Imported and local products are subject to the same ingredient restrictions and warnings; overseas formulations may not meet Malaysian limits, so check against the current Annex III item by item before importing.

Self-check checklist

• [ ] Every ingredient checked against the current NPRA/ACD Annex III restricted list
• [ ] PPD concentration after mixing ≤ 2% (as free base)
• [ ] Label prints the mixing ratio, severe allergy warning and 16-year age restriction
• [ ] "Do not use on eyelashes or eyebrows" and patch-test prompt printed
• [ ] Ingredient/GMP/safety assessment documents filed in the PIF

Summary: The compliance focus for hair dye is two things — "ingredient limits" plus "mandatory warnings" — and Annex III is updated on a rolling basis, so check the PPD concentration against the current version and print the full warnings to get the product safely on shelf. Want to confirm whether your hair dye label is missing any warnings? Run a free label check now

Further reading: Malaysia Cosmetic NPRA Notification Overview, Cosmetic Restricted Ingredients and Concentration Limits, Cosmetic Prohibited Ingredients List.

This article is compiled from official sources for reference only; actual compliance is subject to the latest official text and review by the competent authority.