FDA Thailand 
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Selling essential oils in Thailand: cosmetic, herbal product or hazardous substance?
Essential oil Thailand rules: why one bottle has no single answer
The first surprise about essential oil Thailand rules is that Thai law has no separate category called "essential oils". The same bottle of oil can be a cosmetic, a herbal product, a hazardous substance, or a general consumer product outside the Thai FDA altogether. What decides the category is what the product is used on, how it is used, and what the label, product name and advertising say it does.
Technically, an essential oil is a fragrant liquid obtained from plants, most often by steam or water distillation, by cold-pressing citrus peel, or by solvent extraction to give an absolute. Those preparation methods are listed in the Thai FDA herbal products division's specification for aromatherapy essential oils. Chemically, each oil is a mixture of dozens of fragrance compounds such as linalool, limonene or citral, and some of them carry specific rules in some markets.
This guide is written for foreign brands, Thai importers, contract manufacturers and wholesalers of essential oils and aroma products. We separate what the Thai FDA notifications and guidelines actually say from our own interpretation. Where a product sits on a borderline, confirm with the Thai FDA before you produce or import.
FDA regulations for essential oils: how Thai FDA decides the category
The key document is the Thai FDA's Criteria for Considering Cosmetic Notification (revised 2021). It applies the definition of a cosmetic in section 4 of the Cosmetic Act B.E. 2558 (2015): something used on the external parts of the body for cleansing, beauty, masking body odour or keeping the body in good condition. The criteria use a five-point decision chart, and failing any one point means the product is not a cosmetic.
- The formula contains no prohibited substances, and restricted substances stay within legal limits.
- It is used on the external body, or on the teeth and mouth.
- Its main purpose matches the cosmetic definition.
- It does not show an intention to cure or prevent disease.
- It has no lasting effect on body function through pharmacological, immunological or metabolic action.
What the criteria say: the same document gives a direct example. Essential oil (AROMATHERAPY) products that use scent for therapeutic purposes, state relief of symptoms, or are inhaled for relaxation are not cosmetics. Air freshener sprays, clothing sprays and shoe sprays are not cosmetics either. The criteria then explain where such products go instead: anything claiming a therapeutic effect or a change in body function falls under drugs or herbal products, skin-applied insect repellents are hazardous substances, and products outside Thai FDA scope, such as air fresheners, belong to the Office of the Consumer Protection Board (OCPB).
So before choosing which authority to file with, answer three questions: is the product used on skin or in a room, is it applied or inhaled, and does any label, name or ad talk about effects on the body? If you are not sure, start with our product classification tool.
Source: Criteria for Considering Cosmetic Notification (revised 2021) · Guideline on words prohibited in cosmetic names (22 Aug 2025)
Essential oils sold as cosmetics: perfumes, body oils and lotions
Products used on the skin for fragrance, cleansing or skin care, with no claim about effects on the body, are likely to be cosmetics. Examples include body mists and perfumes, lotions containing essential oils, body oils sold for scent and skin conditioning, soaps and bath salts. In Thailand these follow the cosmetic notification system, not drug registration.
Under the Cosmetic Act, anyone who manufactures for sale, imports for sale or manufactures under contract must notify the product first, and may only produce or import once the notification receipt is issued. The notifier must be a Thai individual or a company registered in Thailand with a qualifying manufacturing or import site. A foreign brand therefore cannot notify directly and needs a Thai importer. The full process is in our guide on how to notify cosmetics in Thailand.
Points that trip up fragrance and body oil brands
- Product names: the Thai FDA guideline on words banned from cosmetic names (revised 22 August 2025) bans the Thai words for medicine, inhalant (ya dom), massage medicine, balm (ya mong) and herbal compress (luk prakob), as well as terms such as SENSORIAL THERAPY and SENSORY THERAPY. The notification criteria also give CURE, MED and THERAPY as examples of names that go beyond a cosmetic.
- Label and ad wording: once the pack says the product helps you sleep, reduces stress or relieves symptoms, it stops being a cosmetic, even if the formula has not changed.
- Formula: it must pass the prohibited and restricted substance lists, which include some fragrance materials (see the safety section below).
- Label: it must meet the Cosmetic Committee notification on cosmetic labelling B.E. 2562 (2019). See our guide to Thai cosmetic labelling requirements.
Aromatherapy regulations: inhalation oils, ya dom and herbal compresses
When an aroma product is inhaled, or claims an effect on the body, the cosmetic criteria say plainly that it is not a cosmetic, and that therapeutic or symptom-relief claims put it under drugs or herbal products. Herbal products are governed by the Herbal Products Act B.E. 2562 (2019), which has three levels of authorisation: a licence to manufacture, import or sell; a product registration certificate; and a detailed-notification or notification receipt. Ministerial notifications decide which product types need which level.
The Act's definition of a herbal product excludes anything that is a cosmetic, a food or a hazardous substance, so one oil can only sit in one category at a time, depending on how it is used and sold.
What the herbal products division has published
- Aromatherapy essential oils specification: it lists 49 permitted oils with their scientific names and plant parts. The forms covered are diluted external-use products and undiluted oils in dropper bottles for massage, bathing, compresses and inhalation, for adults aged 18 and over. It sets concentration tables for each oil and allows only the specific claim wording written in the document, not claims a brand writes itself.
- Ya dom (herbal inhalants): the guideline for external-use herbal medicines has a dedicated inhalant section with permitted actives and concentration ranges.
- Herbal compresses, foot soaks and herbal steam: a Thai FDA notification of 2026 (published in the Royal Gazette on 31 August 2026) sets criteria for these three product types when exempt from registration, detailed notification or notification. Their labels need nine items, and the label section requires the caution "use with care in people allergic to essential oils".
Our interpretation: the aromatherapy specification does not name its issuing unit or date, and does not say which application type it supports. We also found no notification that defines "aromatherapy" itself. For inhalation aroma products, confirm with the Thai FDA whether you need registration, detailed notification or notification before you plan production.
Thai essential oils and lavender: one oil, several routes
Many buyers search for Thai essential oils such as lemongrass, citronella, kaffir lime or plai, or for imported favourites like lavender. The regulatory answer depends on the finished product, not the oil. Here are four hypothetical products using the same lavender oil.
- A lavender-scented body lotion whose label only mentions moisturising and fragrance. Likely a cosmetic, so it needs cosmetic notification.
- Lavender oil in a dropper bottle to drip on a tissue and inhale. The cosmetic criteria say oils inhaled for relaxation are not cosmetics, and lavender is on the herbal division's aromatherapy specification list, so it likely follows the herbal products route.
- A lavender room or pillow spray. Air freshener and fabric sprays are not cosmetics, and air fresheners fall under the OCPB.
- A lavender skin spray labelled as a mosquito repellent. The cosmetic criteria classify skin-applied insect repellents as hazardous substances.
The point is that "which Thai FDA permit does this oil need?" cannot be answered from the oil's name. You need the format, the directions for use and the exact wording on the box. A brand selling several formats may need to work under several laws at once.
Room sprays, reed diffusers and diffuser oils
What the criteria say: air freshener sprays, clothing sprays and shoe sprays are not cosmetics because they are not applied directly to the body, and air fresheners are under the OCPB.
Our interpretation: diffuser oils, reed diffusers and scented candles sold only to scent a room, not used on skin, and making no claim about the body are likely outside the cosmetic system and would follow OCPB general product labelling. Once the label says the product helps sleep, reduces stress or supports breathing, it moves towards the drug or herbal route. If it says it repels mosquitoes, hazardous substance rules come into play.
A common mistake is one bottle with two sets of directions, such as "add to your diffuser" and "blend into massage oil". That puts one product in two categories. It is safer to split the products clearly, or to keep the directions consistent with the authorisation you actually hold.
Essential oil regulations on safety: banned materials, insect repellents and Piperonal
Three safety-related areas of Thai essential oil regulations matter to sellers: fragrance materials that are banned or restricted in cosmetics and herbal products, products that become hazardous substances because they claim to repel insects, and Piperonal, which is linked to narcotics law.
Banned and restricted fragrance materials
Thailand's list of substances prohibited in cosmetics includes several fragrance materials, such as HICC, atranol, chloroatranol, musk ambrette and Lilial. Methyleugenol is allowed only at the levels naturally present in fragrant extracts, within set limits. A Thai FDA allergen document (updated 21 February 2026), which maps the EU allergen list against Thai legal status, places nine entries in the group that counts as prohibited in cosmetics, including Lilial, Lyral, Lippia citrodora (lemon verbena) extract and Myroxylon pereirae (Peru balsam). For herbal cosmetics, the prohibited list includes certain essential oils such as lemon verbena leaf oil and savin oil.
Insect repellent claims bring in the Hazardous Substance Act
The Thai FDA guideline on classifying chemicals and products lists chemicals used to make perfumes or fragrances, without any property to control, repel or kill insects and other animals, as not being Thai FDA hazardous substances. Once a product repels or kills insects, the status changes. For example, d-Limonene appears on the list of hazardous substances that require active-ingredient analysis, in the context of use as an insect-repellent or insecticidal active. At the same time, the summary of controlled product group 4.3 (updated 8 July 2025) contains a specific exemption for essential oil or plant-derived products processed as specified and containing no synthetic chemical active. Citronella or orange-peel mosquito products therefore need a case-by-case check of formula and wording. Confirm with the Thai FDA.
Piperonal (heliotropin) in fragrance compounds
The Ministry of Public Health notification naming Category 4 narcotics (No. 3) B.E. 2568 (2025) made Piperonal (CAS 120-57-0) a Category 4 narcotic, with exemptions for fragrance use within concentration limits. The Ministry then issued a 2026 notification on the use of Piperonal in cosmetics: it is allowed in all cosmetic types at no more than 1% in the finished product, the raw material must contain no more than 10% Piperonal, and it may only act as a fragrance or skin-conditioning agent. Otherwise it is a prohibited substance. The notification applies from 13 September 2025. Anyone buying ready-made fragrance compounds should ask the supplier to confirm the Piperonal content and check section 3 of the SDS every time.
Fragrance ingredients on Thai cosmetic labels: is 'Fragrance' enough?
The 2019 cosmetic labelling notification requires every ingredient to be listed by its name in the reference texts set by the Thai FDA, in descending order, with ingredients below 1% in any order. The natural question is whether an essential oil blend or fragrance compound with dozens of components must be broken down.
From our research: Thailand and ASEAN do not yet require individual fragrance allergens to be named on the label. The ASEAN labelling appendix allows fragrance ingredients to be grouped as perfume, fragrance, aroma or flavor, and in practice the Thai FDA notification system accepts Perfume, Parfum or Fragrance as a collective name. Thailand's restricted substance list has no EU-style condition requiring linalool, limonene or citral to be named above a threshold.
The EU is different. It has expanded its list of allergens that must be named to around 80, and products placed on the market from 31 July 2026 must already follow the new list. Brands that also export to Europe usually end up with two label versions.
If you want to show allergen names on your Thai label too
Some brands voluntarily list allergens EU-style on the Thai label. Before changing the label of a product that is already notified, read the Thai FDA explanation on notifying cosmetics with a changed formula under the same product name (revised 29 October 2025), which lists changing the allergen display on the label without changing the formula as an example of a reason that does not qualify for the same-name route with a letter. In that case you cancel the existing notification first and then notify again under the same product name through the normal procedure.
Check fragrance ingredients one by one with our Thai FDA ingredient search, which now shows EU fragrance-allergen notes and essential oil notes, and check your draft with the label checker.
Can you call an essential oil 'therapeutic grade' in Thailand?
"Therapeutic grade" is common in online essential oil marketing. We found no Thai notification that defines such a grade, so it is a marketing phrase, not a legally recognised quality level.
What the rules say: the cosmetic notification criteria state that a trade name or cosmetic name must not suggest a drug or another product type, giving CURE, MED and THERAPY as examples, and that a registered trademark is not an exception. The guideline on banned cosmetic names also bans words implying therapy or symptom relief, including SENSORIAL THERAPY.
Our interpretation: if you sell as a cosmetic, putting "therapeutic grade" on the label, in the product name or on your online store risks a refused notification and makes the product look like something other than a cosmetic. If you sell as a herbal product, claims must stay within what was authorised. A safer approach is to give verifiable facts: the botanical name, plant part, extraction method, country of origin and a batch number linked to a certificate of analysis (COA).
Factories, importers and essential oil wholesale Thailand
Contract manufacturers and brand owners
A factory producing finished essential oil products must know which category each product falls into, because cosmetic and herbal manufacturing sites follow different criteria. The Herbal Products Act requires a manufacturing or import licence first. For cosmetics, both the brand that hires the factory and the factory itself carry legal duties, and the notification must include the contract. Our article on who owns the notification when you use an OEM covers this.
Importers
Because a foreign brand cannot notify a cosmetic directly, the Thai importer files. Importers of essential oils should separate shipments from the purchase order stage: which lots are finished cosmetics, which are herbal products, and which are raw materials. See our guide to importing cosmetics into Thailand.
Essential oil wholesale as raw material
Our interpretation: essential oil sold wholesale in drums or jerry cans to manufacturers is not yet a consumer product, so the raw material itself is usually not notified. The burden moves to the finished-product maker, who must show the formula passes the substance lists. Once you refill into small bottles with directions for skin use or inhalation, the bottle becomes a finished product that must fit one of the categories. Confirm with the Thai FDA if you are unsure which status a bottle you sell has.
Documents to request from your supplier for every lot
- A certificate of analysis (COA) with botanical name, plant part and production method
- An SDS with composition in section 3, especially for fragrance compounds that may contain Piperonal
- GC-MS results showing the percentage of key components and allergens, if you export to markets that require allergen naming
- An IFRA certificate, if your customer requires one in the contract
Checklist before you sell essential oils in Thailand
Before you produce, import or list a product containing essential oils, work through these steps in order.
- Write clear directions: on skin, inhaled, or in a room.
- Read every word on the label, box, product name and online listing, and remove wording about effects on the body if you intend to sell a cosmetic.
- Pick the legal category: cosmetic, herbal product, hazardous substance, or general OCPB product.
- Check the formula against the prohibited and restricted lists, including Piperonal in fragrance compounds.
- Keep raw material documents for every lot: COA, SDS and GC-MS.
- Complete the label under the rules of that category, including required warnings.
- If the product sits on a borderline, confirm with the Thai FDA before ordering volume.
If you would like our team to look at it, use contact our consultants or ask the Thai FDA advisor a first question.
- ✓Write clear directionsOn skin, inhaled, or in a room
- ✓Check every wordLabel, box, product name and online listing
- ✓Pick the legal categoryCosmetic, herbal product, hazardous substance or OCPB
- ✓Check the formula against substance listsProhibited, restricted, and Piperonal in fragrance compounds
- ✓Keep raw material documents per lotCOA, SDS and GC-MS
- ✓Complete the labelUnder the rules of the chosen category, with required warnings
- ✓Confirm borderline cases with Thai FDABefore ordering production or imports in volume
Source: Summary of the Criteria for Considering Cosmetic Notification (revised 2021) and the notifications cited in this article
Frequently asked questions
Do essential oils need Thai FDA approval?
It depends on the format and wording. Oils used on skin for fragrance or skin care, without claims about the body, are likely cosmetics that need notification. Inhaled oils or oils with therapeutic claims are not cosmetics under Thai FDA criteria and fall under drugs or herbal products. Air fresheners belong to the OCPB.
Can a product called ya dom or ya mong be notified as a cosmetic?
No. The Thai FDA guideline on banned cosmetic names (revised 22 August 2025) bans these words and the word for herbal compress. Such products sit in the herbal products system.
Can a Thai perfume label just say 'Fragrance'?
Yes under current Thai rules. Thailand and ASEAN do not yet require fragrance allergens to be named, and the notification system accepts Perfume, Parfum or Fragrance as a collective name. For the EU, you must name allergens on the EU list.
What permit does a citronella mosquito repellent need?
Skin-applied insect repellents are hazardous substances under the Thai FDA criteria. Controlled product group 4.3 has a specific exemption for essential oil products with no synthetic chemical active, so formula and format must be checked case by case. Confirm with the Thai FDA before production.
Can fragrance compounds containing Piperonal be used in cosmetics?
Yes, under the 2026 Ministry of Public Health notification: no more than 1% in the finished product, no more than 10% Piperonal in the raw material, and only as a fragrance or skin-conditioning agent. Otherwise it is prohibited.
Can I market an oil as 'therapeutic grade' in Thailand?
We found no Thai notification defining that grade, and the cosmetic notification criteria give THERAPY as an example of a name beyond a cosmetic. If you sell as a cosmetic, avoid it and use verifiable facts such as botanical name, extraction method and batch number.
Sources
- Cosmetic Act B.E. 2558 (2015) · Open source · Search our archive
- Criteria for Considering Cosmetic Notification (revised 2021) · Open source · Search our archive
- Guideline on words prohibited in trade names and cosmetic names (revised 22 August 2025) · Open source · Search our archive
- Cosmetic Committee notification on cosmetic labelling B.E. 2562 (2019) · Open source · Search our archive
- Ministry of Public Health notification on substances prohibited in cosmetics B.E. 2566 (2023) · Open source · Search our archive
- Thai FDA list of allergens under Commission Regulation (EU) 2023/1545 mapped to Thai legal status (updated 21 February 2026) · Open source · Search our archive
- Thai FDA explanation on notifying cosmetics with a changed formula under the same product name (revised 29 October 2025) · Open source · Search our archive
- Ministry of Public Health notification on the use of Piperonal in cosmetics B.E. 2569 (2026) · Open source · Search our archive
- Ministry of Public Health notification naming Category 4 narcotics (No. 3) B.E. 2568 (2025) · Open source · Search our archive
- Herbal Products Act B.E. 2562 (2019) · Open source · Search our archive
- Herbal product specification: aromatherapy essential oils · Open source · Search our archive
- Thai FDA notification on herbal compresses, foot-soak herbs and herbal steam products exempt from registration, detailed notification or notification B.E. 2569 (2026) · Open source · Search our archive
- List of substances prohibited in herbal cosmetics (List 3 of the 2023 Ministry of Public Health notification) · Open source · Search our archive
- Hazardous Substance Act B.E. 2535 (1992), consolidated · Open source · Search our archive
- Thai FDA guideline on classifying chemicals or products as hazardous substances · Open source · Search our archive
- List of hazardous substances requiring active-ingredient analysis · Open source · Search our archive
- Summary of hazardous substance list 4.3 (updated 8 July 2025) · Open source · Search our archive
This article is for general information. It is not a Thai FDA ruling or legal advice, and rules change — check the latest notification or ask an expert before filing or producing.
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