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Selling cosmetics and beauty products in New Zealand

In New Zealand, cosmetics are hazardous substances regulated under the Hazardous Substances and New Organisms (HSNO) Act 1996, through the Cosmetic Products Group Standard administered by the Environmental Protection Authority (EPA). Cosmetics may not make therapeutic claims or contain scheduled medicines, a line Medsafe draws. Sunscreens must meet AS/NZS 2604:2012 under the Sunscreen (Product Safety Standard) Act 2022.

Updated · Each section links to the official source it comes from

Main instrument
Cosmetic Products Group Standard, under HSNO
Regulator
Environmental Protection Authority (EPA)
Therapeutic claims
Not permitted; Medsafe draws the line
Sunscreen
AS/NZS 2604:2012, mandatory since the 2022 Act
Before sale
No government agency approves products for sale

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is it a cosmetic, or does its purpose or presentation make it a medicine or related product? Read more
  2. 2Is each ingredient allowed under the Cosmetic Products Group Standard? Read more
  3. 3Do the label, website and social media avoid therapeutic claims? Read more
  4. 4Does it carry an SPF, and has it been tested to AS/NZS 2604:2012? Read more
  5. 5Who answers for it in New Zealand if it has to be recalled? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Cosmetic or therapeutic product

Where a cosmetic ends and a medicine or related product begins.

  • Medsafe describes a product as a cosmetic if it is used to beautify, cleanse or protect the hair, skin, teeth or complexion.
  • Categorisation depends on a product's ingredients, its purpose for use and the way it is presented in the market.
  • Cosmetics are not permitted to contain controlled drugs, or substances scheduled as prescription, restricted or pharmacy-only medicines.
  • A related product is a cosmetic, dentifrice or food for which a therapeutic claim is made, such as a fluoride toothpaste.
  • Regulations 22, 24 and 26 to 36 of the Medicines Regulations 1984 set requirements that apply to cosmetics.

How we help: Compliant Always reads your formula and positioning against the categorisation factors and keeps the reasoning with the product. Ask about this

The Cosmetic Products Group Standard

The EPA's rules for cosmetics as hazardous substances.

  • The EPA publishes the Cosmetic Products Group Standard under HSNO; it lists chemicals whose use in cosmetics is restricted, with conditions.
  • The substances in the group standard do not include controlled drugs or scheduled medicines.
  • The EPA sets the rules for classification, labelling, safety data sheets, packaging and disposal of hazardous substances.
  • The EPA enforces that importers and manufacturers have HSNO approvals for their substances and the right label, packaging and safety data sheets.
  • On 30 April 2021 New Zealand adopted the Globally Harmonised System (GHS) for classifying hazardous substances, with four years for importers, manufacturers and suppliers to update labels, safety data sheets and packaging.

How we help: Compliant Always reads your ingredient list against the group standard's restrictions and keeps supplier specifications with each product. Ask about this

Claims, and products excluded from medicines law

What a cosmetic may say, and the borderline products with conditions.

  • Therapeutic claims are not permitted for products supplied as cosmetics.
  • Purpose can be implied by label statements, websites, advertising images, testimonials, social media and influencer material.
  • Some oral hygiene, anti-dandruff, anti-acne, barrier cream and antibacterial skin products are excluded from medicines law under section 58A of the Medicines Regulations 1984, if their claims stay within set limits and they contain no scheduled medicine.
  • Those excluded products must comply with the Cosmetic Products Group Standard.
  • Under the Fair Trading Act a business needs reasonable grounds for a claim when it makes it.

How we help: Compliant Always reads your claims against the therapeutic-purpose line and the conditions for excluded products, wherever the claims appear. Ask about this

Sunscreen

A mandatory product safety standard for SPF products.

  • The Sunscreen (Product Safety Standard) Act 2022 makes AS/NZS 2604:2012 Sunscreen products, evaluation and classification, mandatory for manufacturers, importers and retailers.
  • It covers products whose primary purpose is protecting the skin from ultraviolet radiation, insect repellents labelled SPF 4 or more, and skin care products labelled above SPF 15, but not lip products or tinted bases and foundations.
  • Manufacturers and importers should have sunscreens independently tested to the standard before supply.
  • Products are marked with the SPF in durable, legible characters, with clear instructions for use.
  • The Commerce Commission enforces the standard, and Customs treats sunscreen that does not meet it as a prohibited import.

How we help: Compliant Always keeps the SPF test report with each sunscreen and checks the label's SPF marking and instructions against it. Ask about this

Product safety and recalls

The general duties that sit beside the cosmetics rules.

  • No government agency in New Zealand approves products for sale; suppliers are responsible for their products' safety.
  • Hazardous substances, including cosmetics, sit with the EPA among the agencies that look after product safety.
  • A business leading a product safety recall notifies MBIE within 2 working days of the recall being made public, unless the recall falls under other legislation and another agency.

How we help: Compliant Always keeps the safety evidence and batch records you would need to scope a recall, by product and lot. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Importer or manufacturerHSNO compliance: the substance meets the group standard, with the right label, packaging and safety data sheet.Formulas, specifications and labels kept together and dated.
BrandThe claims and presentation that decide whether the product stays a cosmetic.Copy read against the therapeutic-purpose line before it goes out.
RetailerSupplying sunscreens that meet the standard, and products that are safe.Test reports and documents ready when a retailer asks.

Questions businesses ask

Do I need to register cosmetics in New Zealand?
No government agency in New Zealand approves products for sale. Cosmetics must instead meet the Cosmetic Products Group Standard under the HSNO Act, administered by the Environmental Protection Authority.
Who regulates cosmetics in New Zealand?
The Environmental Protection Authority, under the Hazardous Substances and New Organisms Act 1996, through the Cosmetic Products Group Standard. Medsafe deals with products that cross into medicines.
Are any ingredients banned in New Zealand cosmetics?
The Cosmetic Products Group Standard lists chemicals whose use in cosmetics is restricted. Cosmetics must not contain controlled drugs or substances scheduled as prescription, restricted or pharmacy-only medicines.
Can a cosmetic make therapeutic claims in New Zealand?
No. Therapeutic claims are not permitted for products supplied as cosmetics. A cosmetic with a therapeutic claim becomes a related product or a medicine under the Medicines Act 1981.
Is an anti-dandruff shampoo a cosmetic or a medicine?
It can be excluded from medicines law if it contains no scheduled medicine and its claims relate only to preventing or controlling dandruff by cleansing, moisturising, exfoliating or drying the scalp. It must then meet the Cosmetic Products Group Standard.
Do sunscreens have to be tested in New Zealand?
Yes. The Sunscreen (Product Safety Standard) Act 2022 makes AS/NZS 2604:2012 mandatory, and the Commerce Commission says sunscreens should be independently tested to it before supply.
Does a moisturiser with SPF count as sunscreen?
Skin care products such as moisturisers, oils, creams and gels labelled above SPF 15 are covered, but products for the lips and tinted bases or foundations are not.
What labelling rules apply to cosmetics as hazardous substances?
The EPA sets the rules for labelling, safety data sheets and packaging of hazardous substances. New Zealand adopted the GHS classification system on 30 April 2021, with four years for suppliers to update labels.
Do I have to notify a cosmetic recall?
A business leading a product safety recall notifies MBIE within 2 working days of making it public, unless the recall falls under other legislation and another agency.
How does Compliant Always help with selling in New Zealand?
Our team reads the rules for the markets you sell in, including the Food Standards Code New Zealand shares with Australia. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in New Zealand and what your paperwork needs to show.

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