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Halal certification for cosmetics

Audited against MS 2634:2019. The application is per product, and each one needs its NPRA notification document attached — which is where multi-SKU brands lose weeks.

The notification bottleneck

Cosmetics differ from food in that the halal file is assembled product by product. The manual requires the NPRA Notification Detail(s) document for every cosmetic product in the application. A brand with forty SKUs therefore needs forty notification records in order, and the application moves at the speed of the slowest one.

There is one exception worth knowing: a product manufactured solely for export can proceed on an NPRA letter permitting manufacture of a non-notified product, rather than full notification. If you are certifying for an export line, check that route before notifying everything.

What you must already hold before applying — cosmetics
RequirementWhat the manual says
NPRA notificationEvery cosmetic product must be notified, or hold an NPRA letter permitting manufacture of a non-notified product for export only
Cosmetic GMP complianceProcessing premises must meet Annex I, Part 10: Guideline for Cosmetic GMP of the Guidelines for Control of Cosmetic Products in Malaysia
Notification Details documentThe NPRA Notification Detail(s) document must be submitted for every cosmetic product in the halal application

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, Prosedur 19, page 32 · edition of 2020

What you are audited against

Standards and legislation applied to cosmetics
InstrumentReference
Malaysian StandardMS 2634:2019 — Halal Cosmetics — General Requirements (First Revision)
LegislationControl of Drugs and Cosmetics Regulations 1984
LegislationGuidelines For Control of Cosmetic Products In Malaysia 2017

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, Prosedur 19, page 32 · edition of 2020

Where cosmetics applications actually fail

The ingredient risk profile is different from food, and the failures cluster in places a food-trained team does not look:

  • Glycerine. The single most common problem. Animal-derived unless documented otherwise, and "vegetable glycerine" on a spec sheet without a certificate behind it is not documentation.
  • Stearic acid, stearates and emulsifiers. Same origin question, usually with a longer supply chain and a trader rather than a manufacturer at the end of it.
  • Collagen, keratin, placenta and silk derivatives. Animal origin by definition; these need a documented source, not a reassurance.
  • Denatured alcohol in toners and fragrances. Type, source and concentration all have to be on record.
  • Contract manufacturing. If a third party fills for you, their premises are in scope. Brand owners often discover this late.

Staffing and system requirements

Common to the product schemes, scaling with company size. Note that the Muslim staffing requirement applies to the processing area — for a brand owner using a contract manufacturer, that means their floor, not your office.

Muslim staffing and halal management requirements, by company size
Company sizeMuslim employeesAppointmentCommitteeSystem
Large and medium industryMinimum two permanent Malaysian Muslim employees on duty in the processing area throughout every operating period or shiftHalal Executive at every branch premisesInternal Halal Committee for the premises and for each branch under separate operational managementHAS developed and implemented per the MHMS 2020 manual
Small industryMinimum one permanent Malaysian Muslim employee on duty in the processing area throughout every operating period or shiftHalal Supervisor at the premisesNot separately requiredIHCS developed and implemented per the MHMS 2020 manual
Micro industryMinimum one permanent Malaysian Muslim employee on duty in the processing area throughout every operating period or shiftNot separately requiredNot separately requiredIHCS developed and implemented per the MHMS 2020 manual

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, Prosedur 19, page 31 · edition of 2020

Fees

Cosmetics sit on the same turnover-banded schedule as other product schemes: RM100 a year for a micro business, RM1,000 for the largest, plus RM20 processing. The per-product work is where the effort goes, not the fee. See the full gazetted fee schedules.

Note: We are independent consultants, not JAKIM or NPRA. Notification and certification are issued by those authorities; we prepare the documentation and the team behind them.

Certifying a cosmetics range?

Tell us how many SKUs and whether they are notified, and we will tell you what the sequence looks like.

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Other schemes

Start with the ingredient list

Most cosmetics gap analyses resolve to glycerine and stearates.

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