SINGAPORE · COSMETICS

Who Must Notify Cosmetics in Singapore? Importers, Distributors and Overseas Brands

An overseas brand entering Singapore should first appoint the local company that will place the product on the market, and only then arrange notification and supply. A notification submitted by another company for the same product does not replace an independent importer’s own HSA notification. However, a channel that buys compliant stock locally is in a different position from a company importing directly from overseas. (Source: HSA notification requirements)

Start by identifying who places the product on the Singapore market

The brand owner decides on the product and commercial rights; the manufacturer provides production and technical information; the local responsible company carries the notification and product responsibilities; and the freight forwarder performs the agreed logistics. These roles may sit with one company or several, so the label “agent” in a contract is not enough to decide who is responsible.

HSA’s guidelines give the example of commissioned import: Company D engages a forwarder to bring products into Singapore for local supply, and the notification responsibility stays with Company D. Outsourcing transport or customs clearance does not transfer product responsibility to the forwarder. (Source: HSA guidelines, Section 5)

Before signing, map the transaction as a clear chain — overseas supplier → local responsible company → distribution or retail channel — and check that the entities named on purchase orders, invoices, import arrangements and labels are consistent.

Which importers must notify separately?

HSA states that a company importing a product itself must notify it, even if the product has already been notified by another company and comes from the same manufacturer. One brand-level receipt is not an “import licence” covering every channel. (Source: HSA: who must notify)

In practice, ask each channel two questions: who does it buy from overseas, and who brings the product into Singapore? A channel that only buys existing stock from a local supplier should not automatically need its own importer notification simply because more stores are added. If the channel starts importing directly, its own responsibilities must be reassessed.

How can local notification and import services support your channels?

One structure worth assessing is for a single responsible entity to notify the product, handle import, and then supply several local channels nominated by the brand. HSA’s guidelines describe an importer supplying local distributors after import, with that importer submitting the notification. (Source: HSA guidelines, Section 5)

For example, if a brand plans to sell through both retail and e-commerce, first confirm whether both channels buy from the same local supply chain, then set up delivery and traceability procedures. The number of channels alone does not decide the notification arrangement.

When discussing such an arrangement with MediPass, agree in writing on the notifying entity, the actual importer, title to goods and delivery terms, and each party’s maintenance obligations. A service name cannot replace an assessment of actual responsibility.

What should the brand hand over to its local partner?

Use the following as a handover checklist rather than sending only product images:

HSA requires products to meet ingredient and labelling rules, and the label must show the name and address of the company or person placing the product on the local market. Safety issues, defects and recalls still have to be handled after notification. (Source: HSA regulatory overview)

Adding a distributor versus adding an importer: what to check

New local distributor: Confirm which local supplier it buys from, whether it uses the same product and label, and how batch records are passed on. If only the sales route grows and the import and responsibility arrangements stay the same, the focus is on bringing the new channel into supply traceability and complaint handling.

New independent importer: Confirm its local entity and its own notification arrangements; it cannot rely on another company’s receipt. HSA’s submission requirements include an ACRA-registered local entity, Corppass and a CRIS account. (Source: HSA submission process)

If a channel change also involves a new responsible company, brand name or product name, assess these changes together rather than treating it as “adding a distributor”. For maintenance rules, see Singapore Cosmetic Notification Maintenance.

Who maintains compliance after launch?

An HSA notification is valid for one year, and re-notification is required each year to continue selling. Supply records must be kept for two years, and the responsible company must provide safety and technical information on request and handle adverse events and recalls. (Source: HSA ongoing obligations and re-notification)

The brand and its local partner should set out in the contract who tracks expiry dates, who receives regulatory enquiries, who notifies the factory of changes, and who coordinates channel withdrawal and traceability. While keeping the freedom to choose channels, the brand should also keep workable arrangements to obtain documents, receive records and deal with historical batches.