When hair dye, perm or anti-hair-loss products must be registered

Q: When hair dye, perm or anti-hair-loss products must be registered

Cosmetics used for hair dyeing, perming or preventing hair loss are special cosmetics under the Cosmetics Supervision and Administration Regulation and must be registered. Ordinary shampoos, conditioners or styling products that do not have those functions and do not claim them are usually ordinary cosmetics. The product name alone—“colour care,” “elastic curls” or “stronger hair”—does not decide the path.

Published 11 November 2026 · Updated 11 November 2026

How to judge each category

A hair-dye product is judged by whether it is used to change hair colour and whether the formula and claims belong to that function, including oxidative and non-oxidative systems. A perm product is judged by whether it is used to change the curl or shape of hair through a waving function, often with a chemical process or a defined waving procedure, rather than by ordinary conditioning claims. An anti-hair-loss product is judged by whether it is used to prevent hair loss; the evaluation and the wording must support that special efficacy without sliding into treatment of pathological hair loss.

What to prepare and how long it takes

Hair dye: oxidative testing about 50 working days, non-oxidative about 35 working days; review about 8 months after testing. Perm: testing about 35 working days; review about 8 months after testing. Anti-hair-loss: testing about 4–8 months; review about 12–16 months after testing. Timing depends on completeness and supplementary requests. Announcement No. 70 of 2026 describes toxicology-report waivers for perm products and non-oxidative hair dyes when the manufacturer has a government-issued quality-system certificate and the safety assessment can fully confirm safety. Oxidative hair dyes are not described in the same sentence; apply the announcement as written.

Cautions

Hair dyes must use permitted colorants within the limits and labelling conditions of the Safety and Technical Standards for Cosmetics. Anti-hair-loss claims should not be written as if the product were a drug. None of these categories may use the ordinary-filing cycle of about 10–20 days.

Questions we are often asked

Is a colour-depositing conditioner always a hair dye?

If the product is used to change hair colour or its formula and claims belong to a dyeing function, assess it as a hair-dye special cosmetic even if the marketing name sounds like a conditioner.

Can a styling cream that “creates curls” skip perm registration?

If it does not have a waving function and does not claim to perm hair, it may remain ordinary hair care. Do not write waving claims onto an ordinary styling product.