What actually moved
The ASEAN Cosmetic Committee held its 39th, 40th, 41st and 42nd meetings between late 2024 and November 2025. HSA's ACD landing page reflects the December 2025 annex version, and the Philippine FDA's Circular 2025-002 reproduced the 39th ACC outcomes verbatim. The substantive moves: Acid Yellow 3 (CI 47005) shifted from Annex II (prohibited) to Annex III (restricted), with a 24-month grace period. Per the FDA Circular, "All AMS agreed to ACA's proposal and adopted to move the Acid Yellow 3 into ACD Annex III with a grace period of 24 months – Effective 14 May 2026, only compliant products shall be made available in the market and non-compliant products shall be withdrawn from the market." Zinc Pyrithione kept its restricted-use carve-outs at 1.0% in rinse-off hair products and 0.1% in leave-on hair products.
The July 2025 (version 2025-1) update added 2-Ethylhexanoic acid and its salts, phenacetin, and several acrylate monomers (trimethylolpropane triacrylate among them) to the prohibited list. The December 2025 update revised Annexes II, III and VII and removed the "Except Cambodia" exemption clause on Item 1721. UV filter changes — including a 10% combined-use cap on Bis-(Diethylaminohydroxybenzoyl Benzoyl) Piperazine variants and a trace-level requirement for benzophenone as an impurity in octocrylene — take effect 15 November 2026.
Why this matters for SEA importers and cosmeceutical brands
HSA does not pre-approve cosmetic products — Singapore runs a notification regime under the Health Products Act and ACD Regulations 2007. Notification is instant once filed via PRISM. That speed cuts both ways: an annex change does not retrigger any HSA review, so the responsibility to detect and reformulate sits entirely with the Responsible Person on each notification.
This is the practical difference from EU practice. In the EU, equivalent changes to Annex II/III come through Commission Implementing Regulations and pull formal industry consultation periods. In Singapore and across ASEAN, the ACC meets twice a year, annex updates publish on HSA's site, and the burden of catching them is on the brand. We have seen distributors fail to register an ACD revision for 6+ months — only to discover at a routine post-market sampling that a notified product carries a now-prohibited ingredient.
What practitioners and distributors should do this quarter
First, pull the December 2025 ACD annexes from HSA's site and cross-check every active SKU against Annex II, III and VII. Second, flag any product containing Acid Yellow 3 (common in older hair colouring formulations) for reformulation before 14 May 2026 — same date applies in Singapore, Malaysia, Philippines, Thailand, Vietnam and Indonesia. Third, if you carry UV products containing benzophenone or octocrylene, request from your manufacturer a Certificate of Analysis confirming benzophenone is at "trace level" — the November 2026 effective date will arrive faster than reformulation cycles.