PIF and lab tests
🇸🇬 SingaporeWhat a PIF is, and when you need a lab test
A Product Information File, or PIF, is the evidence behind a cosmetic: what is in it, how it was made, and why it is considered safe. Here is what goes in it, who keeps it, and what a lab test adds.
What this guide covers
- →What a PIF is
- →What goes in it
- →Who keeps it, and who sees it
- →Why test when HSA doesn't ask you to
- →When you need a lab test
A Product Information File (PIF) is the evidence behind a cosmetic: what is in it, how it was made, and why it is considered safe. It is not sent in with the HSA notification. It is kept ready at the Singapore address on the label. A lab test is a different thing: it finds what an ingredient list cannot show, such as heavy metals.
- The ASEAN Cosmetic Directive says the company placing a product on the market must keep this file.
- It holds the formula, quality data, a signed safety assessment, known effects and proof of claims.
- HSA expects safety and technical information when it asks.
- HSA does not ask for a lab test to file, but it samples and tests products on the market.
- We require an accredited heavy-metal result before we notify any whitening or brightening product.
What a PIF is
It is the file that backs up what the notification declares. HSA does not review your product before sale, so this is where the evidence lives if anyone asks for it.
To be precise about the rule: the requirement is in Article 8 of the ASEAN Cosmetic Directive. Singapore's own cosmetic regulations do not name a PIF, and HSA's published requirement is that you submit safety and technical information when requested. In practice, the file is how you can answer.
What goes in it
Article 8 lists six things. ASEAN's guidelines suggest organising them into four parts, but the content is what matters.
| What is required | In plain terms |
|---|---|
| Composition | The full formula with amounts, and for fragrance, the composition's name, code and supplier |
| Specifications | What the raw materials and the finished product should measure up to |
| Method of manufacture | How it is made, in line with good manufacturing practice |
| Safety assessment | A qualified assessor's signed opinion on the finished product, its ingredients and how much of them people are exposed to |
| Undesirable effects | Any known effects on health from using the product |
| Claim support | Evidence for what the product says it does |
The safety assessment is the piece brands most often lack. HSA's filing portal does not ask to see it, but Article 8 requires one, and the filing declaration commits you to keeping technical and safety information available to HSA. Ask your manufacturer who signed yours, and what their qualifications are.
Who keeps it, and who sees it
The company responsible for the product in Singapore keeps it, at the address on the label. ASEAN's guidelines recommend keeping it for at least three years after the product was last on the market. If we are your Responsible Person, we hold it.
If you have a BPOM notification, you should already have a DIP, Indonesia's version of the same file. It is a real head start, but check it against Singapore's lists before relying on it. See BPOM vs HSA.
Why test when HSA doesn't ask you to
Because an ingredient list only shows what you declared. HSA's labelling rules do not treat impurities in raw materials as ingredients, so they never appear on the list. ASEAN's guidance notes that heavy metals occur naturally in rocks, soil and water, so they can turn up in pigments and other raw materials. Microbes can come in through ingredients, manufacturing or distribution.
HSA samples and tests products on the market, so a contaminant can be found after you are selling. The ASEAN limits are:
- Heavy metals: no more than mercury 1 ppm, lead 20 ppm, arsenic 5 ppm and cadmium 5 ppm.
- 1,4-dioxane: no more than 10 ppm.
- Microbes: no more than 1,000 cfu per gram or ml, or 500 for eye-area products, mucous membranes and children under three, with named bacteria and yeast absent from the test sample.
When you need a lab test
It depends on the product and what you claim about it.
| Your product | What we'd expect |
|---|---|
| Whitening, brightening or skin-lightening | A heavy-metal certificate for the batch being supplied, from an accredited lab, before we notify. This is our rule, not a filing requirement |
| Marketed as brightening, whatever the formula | The same. The claim counts as part of the product |
| Colour cosmetics, clay or mineral products | Ask your manufacturer for a heavy-metal certificate per batch. Pigments and minerals are the likely source |
| Any finished product | Your manufacturer's microbial and heavy-metal results belong in the file. BPOM's DIP asks for these too |
| Fragrance, or skincare with no lightening claim | We may ask if the formula, the claim or the supply chain gives a reason |
FAQ
Do I send the PIF to HSA when I notify? No. It is kept ready, and HSA can ask for the safety and technical information in it.
Can my BPOM DIP be used as my PIF? It is the right starting point, because both follow the same ASEAN approach. Singapore's position on reusing one has not been spelled out, so we check it item by item.
Will the ingredient checker find contamination? No. The checker screens the list you declare. Contaminants need a lab test.
Does a lab test mean my product is approved? No. It tells you that batch met the limits it was tested against. Nobody in Singapore approves cosmetics before sale.
Do fashion brands need a PIF? No. Clothing is not a cosmetic.
Ready?
Check your ingredients → · See how we handle this for you →
Sources: ASEAN Cosmetic Directive documents on HSA's site, including the ASEAN PIF Guidelines and the ASEAN Guidelines on Limits of Contaminants; HSA notification and responsibilities; HSA regulatory overview; Cosmetic Regulations 2007. Updated November 2026. Operational guidance, not legal advice.