Last updated 20 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Regulation numbers refer to the Health Products (Cosmetic Products — ASEAN Cosmetic Directive) Regulations 2007 and section numbers to the Health Products Act 2007 on Singapore Statutes Online as at 20 October 2026. Where we infer how a rule applies, we say so.
Cosmetics are one of the easiest products in Singapore to bring to market. There is no product licence, no advertising permit and no approval of your ads in advance. A homegrown serum brand can file a notification with the Health Sciences Authority (HSA) for a few dollars, launch on Shopee and run Instagram ads the same week.
That ease is exactly why the advertising rules catch so many brands. Because nobody checks your claims before they go out, the first time anyone checks them is after a complaint, an HSA online sweep or a marketplace takedown. And the line that matters — between a cosmetic claim and a therapeutic claim — runs right through the words beauty marketing likes most: “repairs”, “treats acne”, “regrows hair”, “burns fat”, “reverses ageing”.
This guide is for skincare, make-up, hair-care and fragrance brands selling in Singapore, and for the agencies and KOLs who write their copy. Our wider guide to health product advertising rules in Singapore covers medicines, medical devices and supplements; this one goes deep on cosmetics only.
First question: is your product actually a cosmetic?
Everything in this article depends on the product being a cosmetic. If it is not, a different and much stricter set of rules applies, and claims that are fine for a cosmetic may become claims for an unregistered medicine.
The Health Products Act defines a cosmetic product in item 2 of its First Schedule. In plain terms, it is a substance or preparation intended to be placed on the external parts of the body (skin, hair, nails, lips, external genitals), or the teeth and the lining of the mouth, exclusively or mainly to clean them, perfume them, change their appearance, correct body odours, protect them, or keep them in good condition. Notice what is missing: treating, curing or preventing anything.
HSA’s classification page (updated 13 March 2026) gives concrete examples that settle many arguments before they start:
| Usually a cosmetic | Not a cosmetic (different rules apply) |
|---|---|
| Skin-whitening and whitening masks | Acne, eczema and psoriasis creams |
| Anti-wrinkle products | Antifungal and antiseptic creams |
| Sunbathing and self-tan products | Collagen drinks and beauty supplements |
| Make-up, shampoo, deodorant, toothpaste, perfume | Lip fillers and tattoo ink |
| Moisturisers, cleansers, body lotions | False eyelashes, antiseptic hand sanitisers, diffuser oils, massage oils sold for circulation or stress |
Two points follow. First, marketing can change a product’s category: a cream sold “for acne-prone skin” is a cosmetic, but the same cream sold as “treats acne” is presented as a medicine. Second, collagen drinks are not cosmetics at all; their ads fall under the supplement rules in our health product guide.
The setup obligations that sit behind every ad
Advertising rules assume the product is lawfully on the market. Three setup duties matter to marketers, because a campaign for a product that fails them is a campaign for an illegal product.
Notification before supply (regulation 4)
No one may supply a cosmetic in Singapore unless the “person responsible” — a Singapore-registered company that causes it to be sold, such as the importer or distributor (reg 2(2); HSA guidelines) — has notified HSA, renewed every year (reg 4(1)). HSA charges S$13 per product (S$28 for eye, lip and oral products and diamine hair dyes). Since 1 February 2023, regulation 4(2A) also makes it an offence for anyone else to supply an un-notified product, so resellers cannot rely on “the brand should have done it”. The penalty is up to S$20,000 and/or 12 months (reg 4(3)).
Labelling (regulations 7 and 8)
Regulation 7(1) requires, among other things, the product’s function, the full ingredient list, the batch number, the Singapore address of the person responsible, the country of manufacture and an expiry date where the product keeps for under 30 months, in English (reg 7(5)).
Regulation 8 is the one marketers trip over. It bans any statement, trademark or picture on a label that (a) implies HSA promotes or endorses the product, or (b) is likely to create an erroneous impression about the product’s formulation, composition, quality or safety. So “HSA-approved”, “HSA-certified” and “registered with HSA” are all out. A notification is not an approval, and HSA says plainly that it does not evaluate cosmetics.
Records and the claim evidence file
Supply records must be kept for two years (reg 10) and serious adverse events reported to HSA (reg 11). Under the ASEAN Cosmetic Directive the brand also keeps a Product Information File, whose Part IV holds the support for on-pack claims; the ASEAN guideline recommends keeping it at least three years, and HSA can ask for it. In practice it is your evidence for every claim in your ads, so build it before the campaign.
The advertising rule: regulation 9 and the Health Products Act
Three provisions do almost all the work on cosmetic advertising.
- Regulation 9, made under section 21(1) of the Health Products Act, prohibits any advertisement that claims, expressly or by implication, that the product has a therapeutic benefit or purpose, or that is likely to create an erroneous impression about its formulation, composition, quality or safety. Breach carries up to S$20,000 and/or 12 months (HPA s 21(3)).
- Section 20 of the Act bans false or misleading advertisements of health products. “Misleading” includes an erroneous impression about formulation, composition, quality, safety, efficacy or uses. Same penalty ceiling.
- Section 23 lets HSA order an advertisement stopped or removed and require a corrective advertisement, published at the advertiser’s cost. Not complying is a further offence.
The definition of “advertisement” in section 2 is wide: any notice, statement or representation, by any means, that promotes the sale or use of a health product directly or indirectly, expressly including the internet, public demonstrations and offers of trials. A product listing, an Instagram reel, a TikTok live, a pop-up demo and a “free trial” sign-up page are all advertisements for this purpose.
HSA’s guidelines add that claims must be “justified by scientific data” and substantiated on request; its overview page gives the textbook example that a cosmetic cannot claim to reverse hair loss.
The ASEAN claim test HSA uses
Singapore implements the ASEAN Cosmetic Directive, and HSA points brands to the ASEAN Cosmetic Claim Guideline (Appendix III). It sets a five-step test for whether a claim is a cosmetic claim at all. A claim has to pass every step.
Steps one to three are formulation and product-design questions for your regulatory team. Steps four and five are where marketing lives. Presentation is judged on everything around the product: the claims, the label and inserts including graphics, promotional literature including testimonials and third-party material, the advertising, the product’s form, and who it is aimed at. Function asks whether the product claims to permanently restore, correct or modify a physiological function through pharmacological, immunological or metabolic action. “Boosts collagen production” and “repairs the skin barrier at a cellular level” are the kinds of phrases that push a cosmetic towards step five.
The guideline also has a nuance that most summaries miss. It lists areas — dandruff, caries, cellulite, hair loss, bust contouring, acne, anti-bacterial — where a cosmetic may make a secondary claim, as long as the primary purpose stays cosmetic and the claim stays cosmetic in nature. A shampoo whose main job is cleaning can say it helps control dandruff. It cannot say it cures it.
Claims that are off-limits, and wording that usually works
Section 3 of the ASEAN guideline gives examples of unacceptable claims, and says the list is not exhaustive. The useful thing for copywriters is that it also shows how a softening modifier can turn an unacceptable absolute into an acceptable cosmetic claim. The guideline’s own worked example: “removes all oil from skin” becomes “helps to remove oil from skin”, “reduces the shine of oily skin”, “suitable for oily skin types” or “makes your skin feel less oily”.
| Category | Unacceptable (from the guideline’s examples) | Safer direction (our suggestion; still needs evidence) |
|---|---|---|
| Hair | Stimulates hair growth; hair loss arrested or reversed; restores hair cells; eliminates dandruff permanently | “Fuller-looking hair”; “reduces hair breakage from brushing”; “helps control visible flakes with regular use” |
| Skin and ageing | Prevents, reduces or reverses ageing changes; removes scars; numbing; fungicidal or virucidal | “Reduces the appearance of fine lines”; “skin looks smoother”; “helps protect against the visible effects of sun and pollution” |
| Acne | Prevents, heals, treats or stops acne | “Suitable for acne-prone skin”; “helps unclog pores”; “reduces the look of oiliness” |
| Body and slimming | Treatment of cellulite; lose centimetres; removes or burns fat; reduces swelling | “Skin looks smoother and firmer”; “moisturises and tones the look of skin” |
| Deodorants | Completely prevents sweating | “Helps reduce underarm wetness”; “24-hour odour protection” (if tested) |
| Oral care | Treats or prevents gum disease or mouth infections; whitens tetracycline stains | “Helps remove surface stains”; “freshens breath” |
| Depilatories and nails | Stops, retards or prevents hair growth; nail growth from nourishment | “Removes hair for smoother skin”; “nails look stronger” |
| Perfume | Aphrodisiac; hormonal attraction | Describe the scent, not a biological effect |
Two warnings about that right-hand column. First, softer wording is not a free pass. Each claim still has to be true and backed by evidence, because regulation 9(b) and section 20 catch claims that mislead about efficacy, not only therapeutic claims. Second, the pictures and the context count. A soft headline next to dramatic before-and-after photos of a cleared acne breakout still presents the product as an acne treatment. HSA’s presentation test reads the ad as a whole.
The Singapore Code of Advertising Practice (SCAP)
HSA’s guidelines tell brands to follow the Singapore Code of Advertising Practice (2008 edition, administered by ASAS). It is self-regulatory, but because HSA cross-refers to it, it is the substantiation standard you will be measured against.
Substantiation and testimonials (Part III)
- Clause 1.1: factual claims must be capable of substantiation, with the evidence held ready for immediate production to ASAS.
- Clause 3: testimonials must be genuine and current, must reflect the experience a typical user can expect (and the advertiser must be able to show this), and must not carry claims the ad itself could not make. A customer review saying “it cured my eczema” cannot be reposted in your ad just because a customer said it.
Cosmetics (Appendix F, clause 6.9)
- Ingredient claims need evidence, and the ingredient’s effect must be distinguished from the whole formula’s (6.9.1, 6.9.4). “With 5% niacinamide” is fine; crediting the niacinamide alone with a result measured on the full formula is not.
- No rejuvenation claims, no claims that hormones or vitamins remove or delay wrinkles, and no claims to prevent or reverse ageing (6.9.2, 6.9.6) — though ads may refer to the appearance of premature ageing from environmental factors (6.9.7).
- Physiological-effect claims need scientific evidence, and novel ones need human trials (6.9.3). References to tests, doctors or hospitals must be fully substantiated (Appendix F, cl 4.3), so “dermatologist-recommended” needs a documented basis.
Slimming (Appendix H) and hair loss (Appendix I)
- For slimming, user testimonials do not count as substantiation (cl 1.2), and slimming claims are unacceptable for wraps, osmosis products, bath essences and soaps, massage or vibrating machines, and “metabolism boosters” (cl 5.4.1). A body cream marketed with “lose 3cm in a week” fails both the ASEAN guideline and SCAP.
- For hair and scalp, ads may not claim to prevent baldness, reverse hair loss, stimulate growth, nourish roots, or improve the health of hair as distinct from its appearance (cl 1.1). Where an ad deals with hair loss, SCAP requires a clearly legible disclaimer that there is no scientific proof that any product (except certain registered medicinal products) or service can retard hair loss or promote hair growth (cl 1.2). Dandruff claims must not say “permanent” and must say control depends on regular use (cl 2.1).
Words with no legal definition: “natural”, “clean”, “hypoallergenic”
Brands often ask whether “natural”, “organic”, “clean”, “free-from”, “hypoallergenic” or “dermatologically tested” have legal definitions in Singapore. We found none, in the cosmetics regulations, HSA’s guidance or the ASEAN claim guideline. That does not make them safe to use loosely. They are policed through the general rules:
- Regulations 8(b) and 9(b) catch anything likely to create an erroneous impression about formulation or composition. “Natural” on a product that is mostly synthetic, or “paraben-free” on a product with a different preservative that customers would equally want to avoid, is a composition claim.
- SCAP Part III clause 1.1 requires evidence for every factual claim. “Dermatologically tested” means you hold the test report; “hypoallergenic” means you can show a reduced allergy risk, not just that you left out fragrance.
- The Consumer Protection (Fair Trading) Act’s list of unfair practices includes claiming that goods have ingredients, qualities or benefits they do not have. We cover that in our guide to trade descriptions and false claims in Singapore.
Our working rule: if you would struggle to explain a word to an HSA officer with a document in your hand, either define it on the page (“free from parabens, sulphates and synthetic fragrance”) or drop it.
Sunscreen and whitening: two claims that need extra care
Sunscreen
For products whose primary function is UV protection, the ASEAN Sunscreen Labeling Guideline (revision 2, 18 November 2025) applies. It bans claims of 100% UV protection and claims that reapplication is unnecessary, such as “whole day protection”. It sets no UV claim below SPF 6, labels anything above SPF 50 as “50+”, and requires the warning “Do not stay too long in the sun, even while using a sunscreen product.” It lists “waterproof” and “sweatproof” as applicable only in Malaysia and Thailand, so use tested water-resistance wording in Singapore.
Whitening
Whitening products are cosmetics, so “brightening” and “evens out the look of skin tone” are legitimate claims. The risk is safety: HSA’s 2024 summary reported a hospitalisation linked to a mercury-containing whitening cream bought online, and the ASEAN limits HSA tests against allow mercury at only 1 ppm. Get batch test certificates before you advertise imported whitening products. A product that breaks the ingredient rules is treated as unwholesome under section 16 of the Act, which carries up to S$50,000 and/or two years. Meta’s ad policy separately bans products that cause a permanent change in skin colour.
Influencers, marketplaces and resellers
Because the Act defines an advertisement as anything promoting sale “directly or indirectly”, a paid KOL review of your serum is an advertisement for the serum. Our reading is that the same claim rules apply to it as to your own ad, and the brand should treat the KOL’s script as its own copy. Practically:
- Brief the claims. Give creators approved and banned claim lists; live streams are where unscripted therapeutic claims happen.
- Disclose the relationship. ASAS’s Guidelines on Interactive Marketing Communication and Social Media (2016) require any material connection — payment, free products, invitations — to be fully disclosed (cl 3.1(c)), early and clearly, not hidden behind a link (cl 3.5(b)). Bought likes and fake accounts are out (cl 3.6). Our influencer and KOL marketing guide for Singapore covers running these programmes well.
- Check notification before you list. Regulation 4(2A) makes any supplier of an un-notified product liable. If you resell, ask the brand for its notification record before you run ads.
- Before-and-after content is now platform-dependent. Meta’s Health and Wellness ad standards (change log dated 22 July 2026) allow before-and-after transformation ads for cosmetic products and procedures but require targeting at people aged 18 and over, with an exemption for non-permanent cosmetics such as creams, make-up and hair products. Meta also bans ads that attack a person’s appearance. None of this changes HSA’s rules: a before-and-after that implies acne was treated is still a therapeutic claim.
What enforcement actually looks like
Cosmetic enforcement in Singapore is mostly online and mostly about listings. HSA’s annual figures show the scale:
The figures cover all illegal health products, but skin, hair and aesthetic products are among the largest categories. HSA’s 2024 release also recorded a S$266,500 fine in September 2024 for counterfeit cosmetics sold on Lazada and Shopee, which it described as the largest of its kind. (A later HSA release restates 2024 removals as 7,190.)
For a legitimate brand the usual outcome is not prosecution but a listing pulled mid-campaign, a warning, a request for evidence or a section 23 correction order — each one wasting committed ad spend.
Worked example: rewriting a serum launch
Consider a hypothetical Singapore brand launching a vitamin C serum with this draft Instagram caption: “Our clinically proven serum repairs damaged skin, clears acne scars and reverses ageing in 14 days. HSA-approved and 100% natural. Dermatologist recommended!”
| Draft phrase | Problem | Rewrite |
|---|---|---|
| “Repairs damaged skin” | Implies modifying a physiological function (ASEAN step 5) | “Helps skin look smoother and more even” |
| “Clears acne scars” | “Removes scars” is an unacceptable example in the ASEAN guideline | “Reduces the look of dark spots” |
| “Reverses ageing in 14 days” | Unacceptable ageing claim; SCAP Appendix F cl 6.9.2 and 6.9.6 | “Visibly brighter skin in 14 days*” with *the test basis stated |
| “Clinically proven” | Needs a real study you hold (SCAP Part III cl 1.1; Appendix F cl 4.3) | Keep only if you hold the study; say what was measured |
| “HSA-approved” | Prohibited by regulation 8(a); HSA does not evaluate cosmetics | Delete |
| “100% natural” | Composition claim; misleading if any synthetic ingredient is present (reg 9(b)) | “Made with plant-derived vitamin C” if true |
| “Dermatologist recommended” | Needs a documented, substantiated basis | Name the basis or delete |
The rewrite still sells. Strong cosmetic copy promises how skin looks and feels, backed by a test, rather than what the product does to the biology underneath.
A pre-launch checklist for cosmetic ads
- Confirm it is a cosmetic on HSA’s classification page, and that the notification is current for every variant you advertise.
- Run every claim through the five-step test, reading images, captions and testimonials together.
- Match each claim to evidence in the Product Information File before the ad runs.
- Scrub banned words: treat, cure, heal, regrow, burn fat, permanent, 100% protection, HSA-approved.
- Add mandatory text: the SCAP hair-loss disclaimer, the sunscreen warning, KOL disclosure.
- Brief creators in writing and check platform targeting rules.
How this fits your wider marketing
In this category, compliance decides whether a campaign keeps running. Build the claims file first, then test creative hard within it. For channels and the wider beauty market, see our digital marketing guide for beauty businesses in Singapore.
If you would like help building compliant creative that still performs, our performance marketing team in Singapore can design and test it with you, and you can see how we work in our client case studies. For the measurement side, start with our complete guide to performance marketing in Singapore.
If you sell treatments rather than products, a different set of rules applies. Our companion guide to aesthetic clinic and beauty salon advertising in Singapore covers the before-and-after ban, banned titles and which machines a salon may use.
Frequently asked questions
Do I need HSA approval to advertise cosmetics in Singapore?
No. Cosmetics need no advertising permit or pre-approval, and HSA does not evaluate cosmetic products. You must notify HSA before supplying the product, and your ads must not make therapeutic claims or mislead about formulation, composition, quality or safety.
Can I say my cosmetic is “HSA-approved”?
No. Regulation 8(a) prohibits any label statement implying HSA promotes or endorses the product. Notification is not approval, and HSA says it does not evaluate cosmetics, so “HSA-approved” and similar wording are misleading.
Can a skincare product claim to treat acne in Singapore?
No. “Prevents, heals, treats or stops acne” is an unacceptable cosmetic claim under the ASEAN Cosmetic Claim Guideline. Cosmetic wording such as “suitable for acne-prone skin” or “helps unclog pores” can work, if it is true and you can back it up.
Are “natural” and “hypoallergenic” regulated in Singapore?
We found no Singapore definition for them. They are still covered by the general rules against misleading claims about formulation or composition and by SCAP’s substantiation requirement, so you need evidence for them, or a clear on-page definition.
Do influencer posts about cosmetics count as advertisements?
Yes. The Health Products Act defines an advertisement as anything promoting sale directly or indirectly, including on the internet. Paid KOL content should follow the same claim rules as your own ads and disclose the commercial relationship clearly.
What is the penalty for a misleading cosmetic ad?
Up to S$20,000 and/or 12 months’ imprisonment under the Health Products Act. HSA can also order the ad removed and require a corrective advertisement at the advertiser’s cost, and marketplace listings can be taken down.
