Cosmetics Classification: The Three Tiers
Not every cosmetic product in Thailand clears the same door. The Cosmetics Act B.E. 2558 (2015) sorts every product into one of three tiers before notification or registration can even begin, and the tier determines the documentation burden, the review depth, and how long a brand should plan for before market entry. Getting the tier wrong is one of the fastest ways to stall a Thai cosmetics launch.
Last reviewed: July 2026
Why tier assignment comes before anything else
Thailand does not run a single cosmetics approval pathway. It runs three, and the formulation itself decides which one applies. A brand that assumes its product qualifies as standard because the finished item looks and behaves like a typical cosmetic can be wrong if a single ingredient in the formula sits on a controlled or specially controlled list. That mismatch does not surface as a minor correction; it surfaces as a rejected filing that has to be resubmitted under the correct tier.
The tier also shapes what a brand needs to have ready before it files. A standard notification and a specially controlled submission draw on the same underlying safety data in principle, but the depth of documentation, the type of supporting evidence, and the level of Thai FDA scrutiny differ substantially between them. Confirming the tier early lets a brand build the right file the first time, rather than discovering mid-process that more evidence is required.
What Are the Three Tiers of Cosmetics Under Thai Law?
The Cosmetics Act B.E. 2558 (2015) is the governing statute for every cosmetic product sold or imported into Thailand. It defines three product categories based on the ingredients a formulation contains and the potential for those ingredients to cause harm if used incorrectly or in excess concentration. The examples below are illustrative of each tier, not an exhaustive ingredient list.
General (standard) cosmetics
Products that contain no controlled or specially controlled ingredients. This is the largest category by volume and covers everyday items such as soap, shampoo, lipstick, perfume, and face powder. Standard cosmetics are cleared through notification rather than a fuller registration process.
Controlled cosmetics
Products containing ingredients that may cause harm to the user if the concentration exceeds a defined maximum, even though the ingredient itself is permitted for cosmetic use within that limit. Sunscreen products, anti-dandruff formulations, and sanitary or cooling pads are representative of this tier. Notification for controlled cosmetics receives closer scrutiny of the formulation and supporting safety data than a standard filing.
Specially controlled cosmetics
Products containing ingredients that may cause serious harm to the user if misused or present above the permitted concentration. Hair dyes and bleaching agents, sunscreens carrying high UV-filter concentrations, and antibacterial soaps built on restricted active ingredients fall into this tier. Specially controlled cosmetics do not move through notification. They require formal product registration, a separate and heavier procedure in which Thai FDA reviews the formulation itself before the product can reach the market, rather than clearing it through the same filing used for the other two tiers. The manufacturer or importer submits a registration application together with the full technical file, typically GMP certification and ingredient safety or toxicological data, and Thai FDA issues a distinct registration number, not a notification number, once the review clears. Registration for this tier runs around 30 working days, about six weeks, longer than notification for the other two tiers.
What's the Difference Between the Three Cosmetic Tiers?
The dividing line between the tiers is not the product's cosmetic function, its price point, or its intended audience. It is the specific ingredient profile of the formulation, assessed against Thailand's lists of controlled and specially controlled substances. Two products that look similar on the shelf, such as two facial sunscreens, can sit in different tiers entirely depending on the UV filter concentration each one uses.
This is why a formulation review against Thailand's current ingredient lists should happen before a brand commits to a filing timeline. The Thai FDA periodically updates its permitted ingredient lists; most recently, two Ministry of Public Health notifications signed October 8, 2024 and published in the Royal Gazette November 18, 2024 (effective November 19, 2024, with a 180-day transition period for products already on the market) added titanium dioxide, including nanoform, as a permitted colorant (Notification Re: Colors Permitted as Cosmetic Ingredients (No. 3) B.E. 2567) with specific use conditions and concentration limits (Notification Re: Names, Quantities and Conditions of Substances Permitted as Cosmetic Ingredients (No. 8) B.E. 2567). A formulation that was compliant and correctly tiered under an older list is not guaranteed to remain so after an update, which is a reason to confirm tier status close to the filing date rather than relying on a review done months earlier.
