On October 1, 2026, the Center for Cosmetics and Household/Urban Hazardous Substances Regulation and Research (CCHUHSRR) under the Philippine Food and Drug Administration (FDA) issued Advisory No. 2026-1544, announcing the pilot implementation of the Automatic Notification of cosmetic products, through which pilot products can automatically obtain a Certificate of Product Notification (CPN) via the FDA ePortal system. CIRS Group has summarized the main contents as follows for reference.
Pilot Overview
According to the Advisory, the pilot aims to assess the functionality, efficiency, and operational readiness of the automatic notification process prior to its full implementation. The pilot will run for three months (October 1 to December 31, 2026), initially covering perfumes, toilet waters, and eau de Cologne.
Depending on the results of the pilot, the FDA may modify, expand, suspend, or terminate the implementation of the automatic notification of cosmetic products; the inclusion of additional cosmetic products in the pilot will be announced by the FDA separately.
Notification Application and CPN Issuance Requirements
The Advisory reiterates the requirements for submitting cosmetic product notification applications during the pilot:
Application procedure: Applications shall be filed by licensed cosmetic establishments (holding a License to Operate, LTO) following the procedures stipulated in FDA Memorandum Circular No. 2015-011 and the FDA Citizen’s Charter. All products for notification shall comply with all applicable standards, including the ASEAN Cosmetic Directive (ACD) as issued by the FDA, together with its amendments and updates.
CPN issuance: The acceptance of a product notification does not constitute, in any way, an agreement that the product meets all the regulatory requirements (Appendix 5 of the ACD). The automatic issuance of a CPN only acknowledges the successful submission of a notification and does not constitute FDA approval of, or prior technical evaluation of, the product. The FDA reserves the right to disapprove an application, or suspend or cancel an authorization, as provided under Book II, Article I, Section 4 of the Implementing Rules and Regulations of Republic Act (RA) No. 9711 (the Food and Drug Administration Act of 2009).
Additional documents and non-compliance: The FDA reserves the right to request additional documents as prescribed under the ACD as part of its post-market surveillance. Where an application contains banned or restricted ingredients, or claims beyond the scope of a cosmetic product under the ACD, the FDA may take appropriate regulatory action, including the suspension or cancellation of the CPN, in accordance with existing laws, rules, and regulations.
MAH Responsibilities and Post-market Surveillance
The Market Authorization Holder (MAH) remains primarily responsible for ensuring compliance with all applicable laws and regulations, and shall ensure that each consignment of the product meets the requirements of the ACD and will not cause damage to human health under normal or reasonably foreseeable conditions of use.
Products notified through the pilot automatic notification pathway shall be subject to immediate post-market surveillance by the FDA, including but not limited to product recall (FDA Circular No. 2016-012), Product Information File (PIF) audit (FDA Circular No. 2023-001), and other regulatory and enforcement actions. Non-compliance with a request for information for post-evaluation or product verification may constitute a ground for regulatory action, including the suspension or cancellation of the CPN.
Key Impacts on Cosmetics Companies
(1) Faster notification for perfumes and other pilot products: During the pilot, a successful submission for perfumes, toilet waters, and eau de Cologne automatically generates a CPN without waiting for manual technical evaluation, which is expected to significantly shorten the time to market; companies in these categories may take advantage of the pilot window to accelerate market entry.
(2) Automatic issuance does not mean exemption from regulation: A CPN merely confirms a successful submission, and products must still fully comply with all ACD requirements; products containing banned or restricted ingredients or making claims beyond the cosmetic scope will have their CPNs suspended or cancelled. Companies should not relax the compliance management of formulas and claims on this account.
(3) PIF and other documents must be readily available: Pilot products are immediately subject to post-market surveillance. MAHs shall ensure that the PIF and other technical and safety information are readily accessible to the FDA upon request, properly keep records of manufacturing, importation, and distribution, and report serious adverse events as required; otherwise, they face the risk of CPN suspension or cancellation.
(4) Watch for expansion of the pilot: The scope of the pilot may be expanded to cover more cosmetic categories, or automatic notification may be fully implemented after evaluation. Companies exporting other categories of cosmetics to the Philippines should closely follow the FDA’s subsequent announcements.
CIRS Reminder
The Philippines implements a management system for cosmetics that combines the License to Operate (LTO) for establishments with product notification. This pilot of automatic notification simplifies the notification process for perfumes and other initially covered products and will notably shorten the compliance timeline for such products.
CIRS reminds relevant cosmetics companies to confirm before notification that product formulas comply with the ACD’s requirements on banned and restricted ingredients, that claims are confined to the cosmetic scope, and that the PIF, records of manufacturing/importation/distribution, and other documents are readily available as required. Products granted a CPN through the pilot remain subject to immediate post-market surveillance — automatic issuance should never be taken as “once and for all”. In addition, the updated CPN template (Annex A) and the Declaration and Undertaking (Annex B) are attached to the Advisory, and companies should use the latest versions when filing.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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