Starting in 2026, Japan’s PMDA requires all imported cosmetic ingredients to submit detailed impurity declarations, including exact concentrations of metals like Fe, Cu, and Ni—typically below 5 ppm.
Many Chinese exporters are caught off guard: their Certificates of Analysis (COAs) only state “complies with standards,” lacking numerical data. Japanese reviewers now reject such vague documentation, demanding ICP-MS reports per batch.
The issue stems from industrial-grade silicones used in cost-driven formulations. These often contain trace catalyst residues that push metal levels beyond limits. To comply, brands must source true cosmetic-grade silicones with full INCI names, valid ingredient submission codes, and element-specific test results—not generic assurances.
