Mandatory Items on a Malaysia Cosmetic Label (NPRA Annex I Part 7)

For a cosmetic label to be lawful in Malaysia, it must comply with the NPRA Guidelines for Control of Cosmetic Products, Annex I Part 7: Cosmetic Labelling Requirements. This part makes very clear "what must appear on the label" — product name and function, all ingredients (INCI), net content, country of manufacture, CNH name and address, batch number, manufacture / expiry date, plus directions for use and warnings; none may be missing. This article lists the mandatory content item by item, along with common gaps. (For the complete overview, see the Malaysia Cosmetic Regulations and Labelling Guide.)

What must a cosmetic label carry?

These eight items are the most direct checkpoints during inspections and consumer complaints. A gap in any one may lead to a demand for correction or withdrawal.

Item-by-item breakdown: easily overlooked details

• Product name and function: the key is whether "the function is immediately obvious." If the use cannot be seen from the appearance, add a function statement on the label to prevent misuse by consumers.
• All ingredients (INCI): the ingredient list is hard evidence and must use INCI standard nomenclature; common names may only appear in marketing copy. For naming and prohibited/restricted details, see INCI Naming and Prohibited/Restricted Ingredients.
• CNH name and address: this is the field imports most easily get wrong. What goes on the label is the name and address of the Malaysian notification holder, not the overseas brand headquarters; for the CNH's role, see Imported Cosmetics CNH Notification Holder.
• Batch number and dates: the batch number is for traceability, and the manufacture / expiry date indicates shelf life; once a recall is needed, these two are the key to locating the problem product.
• Directions for use and warnings: when restricted ingredients are present, a corresponding warning and use precautions are often required — this is safety information and cannot be omitted.

Language requirements

Label information must be in Malay and / or English; beyond that, translations in other languages may be added. If an imported product's original label is in another language (such as Chinese, Japanese, or Korean), it usually needs translation or over-labelling to add the mandatory information in Malay or English. Having only a foreign language and lacking Malay or English is a common reason for rejection.

What to watch out for with over-labelling

The most common compliance approach for imports is "over-labelling" — sticking a supplementary label on the original packaging to fill in the mandatory information in Malay or English and the local CNH's name and address. Over-labelling looks simple but has several pitfalls in practice:

• Must not cover key information: the over-label must not obscure the original ingredients, batch number, or expiry date.
• Must adhere firmly: the label must withstand transport and display, and not easily fall off or be peeled away.
• Content must match the notification: the product name, function, and ingredients added by over-labelling must match what was notified to NPRA; you cannot "change the claim" via over-labelling.

Managing over-labelling as a formal part of the label, rather than as a patch applied after the fact, is what avoids being asked to relabel or being withdrawn after going on shelf.

Common mistakes

• Missing CNH name and address, batch number, or manufacture / expiry date.
• Ingredients not using INCI, or using only common names.
• The label in a foreign language only, lacking Malay or English.
• Imported products omitting the country of manufacture.
• Restricted ingredients present but no corresponding warning added.
• Claimed functions exceeding the cosmetic scope (medicalised / therapeutic) — see Cosmetic Claim Red Lines.

Frequently asked questions (FAQ)

Q: Must the label be in Malay? It must be in Malay and / or English — either one or both — and translations in other languages may be added. A foreign language alone without Malay or English is non-compliant.

Q: How do I handle an imported product's foreign-language label? Usually by translation or over-labelling to add the mandatory information. When over-labelling, ensure the original label's key information is not covered and that the over-label adheres firmly and does not easily fall off.

Q: There isn't enough space on small packaging — can I omit the ingredients? Mandatory items may not, in principle, be omitted. When space is limited, find a solution in the layout design (such as a fold-out or outer box) rather than deleting ingredients or warnings outright.

Q: Must the function be labelled? If the product's function cannot be judged from its appearance, the function must be stated to prevent misuse by consumers.

Self-check list

• [ ] Product name and function are complete, with the use stated where necessary
• [ ] All ingredients listed in INCI
• [ ] Net content and country of manufacture are both labelled
• [ ] The CNH name and address are the Malaysian holder's, not the overseas brand owner's
• [ ] Batch number and manufacture / expiry date are complete
• [ ] Directions for use and warnings (including restricted-ingredient warnings) are in place
• [ ] The label includes Malay or English

Summary

The compliance formula for a cosmetic label: product name and function + INCI all-ingredients + net content + country of manufacture + CNH name and address + batch number + manufacture / expiry date + directions for use / warnings, presented in Malay or English. Imports in particular should keep a close eye on the two most commonly omitted fields: country of manufacture and CNH name and address.

Want to confirm whether your label is complete? Run a free label check now.

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