NPRA publishes the actual wording it will and will not accept on a cosmetic product. For massage and relief products the list is short, specific, and catches almost every brand that writes its label before checking.
Written & researched by Lai Gek Yan, regulatory & export contributor · Technical input by ORIZI Group R&D Team · Fact-checked by Creaton Poh · Published by ORIZI Group · Last reviewed August 2026
Disclosure: This article is published by ORIZI Group and may refer to our own manufacturing experience, services and capabilities. External factual claims are supported by cited sources.
Quick Answer
For a cosmetic product notified in Malaysia, NPRA’s published guideline on cosmetic claims lists “reference to relieve pain/ache of body, muscle or joint” and “improve blood circulation” as unacceptable claims for massage-assist products, while “calming, relaxing, refreshing, uplifting” and “moisturizing” are acceptable. Separately, the product name itself may not refer to muscles, joints, nerves or medical conditions. A claim outside the cosmetic scope does not just get edited — it moves the product to the medicine route.
Key Takeaways
- NPRA publishes an explicit unacceptable-versus-acceptable claims table by product type; massage-assist products are category 7 on that list.
- “Relieves muscle and joint pain”, “improves blood circulation” and a “numbing effect” are all named as unacceptable for cosmetics.
- The word “Medicated” is on the unacceptable list, as are GMP or ISO 22716 certification logos on the pack and any claim of Ministry of Health approval.
- Claims and the product name are governed by two different annexes — passing one does not mean passing the other.
- If your entire proposition is pain relief, the answer is not better wording; it is the MAL registration route.
In this guide:
- Where these rules come from
- The five-step test NPRA applies
- The claims table for massage and relief products
- The traps outside the claims table
- The product name is a separate rule
- Turning a non-compliant line into a compliant one
- What we check before artwork goes to print
- Frequently asked questions
Where these rules come from
Two documents govern this, both published by the National Pharmaceutical Regulatory Agency (NPRA) as annexes to the Guidelines for Control of Cosmetic Products in Malaysia:
- Annex I, Part 8 — Guideline for Cosmetic Claims. Contains the five-step decision process and a table of unacceptable and acceptable claims arranged by product type.
- Annex I, Part 2 — Non-Permissible Product Name for Cosmetic Product. Governs the product name itself, which is assessed separately from the claims.
Both state that their lists are not exhaustive, and NPRA reserves the right to disallow any wording it considers misleading, improper or not factual. Treat them as the floor, not the ceiling.
The five-step test NPRA applies
Annex I, Part 8 sets out a five-question decision process. A product proposition has to pass all five to be a cosmetic:
- Composition — does it contain only ingredients permitted under the ASEAN Cosmetic Directive, and none that are banned?
- Target site — is it for the external parts of the body, the teeth, or the mucous membranes of the oral cavity?
- Main function — is it intended mainly to clean, perfume, change appearance, correct body odour, or protect and keep those parts in good condition?
- Presentation — is it presented as treating or preventing disease? If yes, it is not a cosmetic.
- Function — does it permanently restore, correct or modify physiological function by pharmacological, immunological or metabolic action? If yes, it is not a cosmetic.
Step four is where relief products usually fail, and it is worth noting what counts as “presentation”: the guideline explicitly includes the claims and their context, labelling and packaging inserts including graphics, promotional literature and third-party testimonials, advertisements, the product form, and who the marketing is aimed at. A compliant tube undermined by the brand’s own social media is still a presentation problem.
The claims table for massage and relief products
NPRA’s category 7 covers “products to assist body massage” — the category most cooling gels, warming balms and massage creams fall into.
| Unacceptable | Acceptable |
|---|---|
| Reference to relieve pain or ache of the body, muscle or joint Stomach wind, bloat Improve blood circulation | Calming Relaxing Refreshing Uplifting Moisturizing |
Two of those unacceptable entries deserve attention because they are so widely used in this category. “Improves blood circulation” appears on a great many massage and warming products, and it is named on the unacceptable list. So is any reference to relieving pain or ache — which means the category’s most obvious selling line is precisely the one a notified cosmetic cannot use.
The skin-product category adds two more that matter for relief formats:
| Also unacceptable for cosmetics | Why it catches relief products |
|---|---|
| Numbing effect to the skin | A strong menthol product is often described this way in marketing copy |
| Treatment on compromised skin, e.g. bruises, wound, burn | Sports positioning frequently drifts into bruise and injury language |
For aromatherapy and essential-oil products, category 6, the boundary sits in the same place: calming, relaxing, refreshing, uplifting, moisturizing and soothing are acceptable, while references to diseases and conditions — including migraine, period pain and PMS — and claims about mental wellbeing such as stress or tension relief are not.
The traps outside the claims table
Annex I, Part 8 also lists general claims that are unacceptable regardless of product type. Several catch OEM brands specifically:
| Not allowed | What brands usually get wrong |
|---|---|
| “Medicated” | Used as a positioning word to imply strength. It is on the unacceptable list. |
| GMP logo or certification statement, including ISO 22716 | Brands want to show the factory’s certification on the pack. The certification is real; putting its logo or statement on a cosmetic label is not accepted. Non-GMP marks such as ECOCERT may be acceptable if substantiated. |
| “Approved by Ministry of Health (MOH)” | Notification is not approval, and it may not be presented as such. |
| “No side effects”, “no harmful effects”, “no toxic or adverse effects” | Safety claims may not imply the product is free from side effects — and a natural ingredient list does not license the implication either. |
| Graphics referring to internal organs or body parts — nerve, capillary, lymph, hormone | A diagram of nerves or muscle fibres on the pack is caught by the same rule as the words. |
| Religious references; supernatural or superstitious elements | Includes quoting scripture on a cosmetic pack. |
One useful permission sits in the same section: numerical performance claims such as “99.9%”, “in 3 days” or “10x” are acceptable if they are substantiated by relevant evidence. Specific numbers are allowed; unsupported ones are not.
The product name is a separate rule
A compliant claim set does not save a non-compliant name. Annex I, Part 2 governs the name on its own, and it prohibits, among others:
- Words involving a disease or medical condition — the published examples include eczema, psoriasis, dermatitis, rash, alopecia, menopause, period pain and PMS, inflammation, allergy, sinus and fever.
- Words referring to an internal organ or body part outside the cosmetic scope — the published examples include muscle, joint, nerve, chest rub, calamine, capillary, lymph, spleen, cervical, pelvic, ortho, hormone, and the Malay terms otot and sendi.
- Prohibited indications — including insect bite, insect repellent, heal or healing, and acne treatment.
- Ingredient names the product does not contain — a “Collagen Cream” with no collagen in it is not acceptable, though a name based on an ingredient’s characteristic is allowed, such as a Jasmine Shower Gel scented with a jasmine-type fragrance.
- Slimming references — slim, trim, fat loss, fat burn, inch loss, kurus, langsing, ramping.
This is why a formula can be perfectly cosmetic and the submission still fail. The name is assessed on its own terms.
Turning a non-compliant line into a compliant one
First, the honest version of this advice: if the product’s whole reason to exist is that it relieves pain, rewording the label is the wrong answer. That product belongs on the MAL registration route, and dressing it in cosmetic language creates a compliance exposure that sits with the notification holder, not the factory. See our guide to choosing between the NOT, MAL and MDA routes.
Where rewording is legitimate is the common case we see most often: the product genuinely is a cosmetic — a menthol cooling gel for tired legs after a long shift — but it has been written up in medicine language out of habit, because that is how the category is spoken about in the market. In that case the job is to describe what the product actually does.
| Written as a medicine | Written as what it actually is |
|---|---|
| Relieves muscle and joint pain | An immediate cooling sensation on tired, hard-working legs |
| Improves blood circulation | Warms on application, for a comfortable massage |
| Numbing relief for aches | A refreshing cool that lasts through the evening |
| Medicated sports rub | Cooling sports gel |
| Treats bruises after training | Refreshing post-training cool-down |
The right-hand column is not a euphemism for the left. It is a description of a different product proposition — sensation and comfort rather than treatment — and the brand has to be willing to sell on that proposition. Brands that are, launch on the cosmetic route in weeks. Brands that are not should budget for a registration measured in months.
What we check before artwork goes to print
Based on ORIZI Group’s manufacturing experience, label problems surface later than they should, because artwork tends to be developed in parallel with the formula and reviewed only at the end — by which point plates are cut and a launch date is committed.
So we check four things together, before artwork is finalised, rather than sequentially:
- The product name against Annex I, Part 2 — the cheapest item to fix and the most expensive to discover late.
- Every claim line on the pack against the Annex I, Part 8 table for the relevant product category.
- The graphics — diagrams of muscles or nerves, and certification logos, are caught by the same rules as the words.
- The launch marketing copy, because presentation includes advertising and third-party material, not only the tube.
The fourth is the one most often skipped. A brand can hold a valid notification and still create exposure through a product video that promises what the pack does not.
Limitation: this is our pre-production review practice as a manufacturer. It is not a regulatory clearance, and NPRA may take a different view on any specific wording. Regulatory responsibility rests with the notification holder.
Where this goes wrong
- Translating the claim instead of changing it. A Malay or Chinese version of a prohibited claim is still a prohibited claim.
- Relying on a competitor’s label. The product you are copying may hold a MAL registration that permits language your notified cosmetic cannot use.
- Marketing written by a different team. The pack passes, the campaign does not, and advertising is assessed under its own guideline.
- Putting the factory’s certifications on the pack. Understandable instinct, explicitly not accepted for GMP and ISO 22716.
- Assuming the list is complete. Both annexes state they are not exhaustive and NPRA may disallow other wording.
Frequently asked questions
Can a cosmetic in Malaysia say it relieves muscle pain?
No. NPRA’s cosmetic claims guideline lists reference to relieving pain or ache of the body, muscle or joint as an unacceptable claim for products assisting body massage. A product whose proposition is pain relief requires a MAL registration rather than a cosmetic notification.
Can I say my cream improves blood circulation?
No. “Improve blood circulation” is named as an unacceptable claim for massage-assist products, and reference to blood circulation or microcirculation is also unacceptable for skin products generally.
What can I say instead?
For massage-assist products the acceptable claims listed are calming, relaxing, refreshing, uplifting and moisturizing. Describing the sensory experience — how cool it feels, how quickly it absorbs, how long the sensation lasts — is legitimate and is usually what the customer is actually buying.
Can I put the factory’s ISO 22716 or GMP logo on my label?
No. The use of a symbol, logo or statement related to GMP certification, including ISO 22716, is listed as unacceptable on a cosmetic label. Non-GMP marks such as ECOCERT may be acceptable if substantiated.
Is the word “medicated” allowed?
No. “Medicated” appears on the unacceptable list of general claims for cosmetic products.
Can I use numbers like “cools in 5 seconds”?
Yes, if substantiated. NPRA states that numerical claims of product performance or effectiveness are acceptable when supported by relevant evidence, so the requirement is the evidence rather than the number itself.
Do these rules apply to my TikTok videos as well as the pack?
Yes. The presentation assessment expressly covers claims and their context, packaging and inserts including graphics, promotional literature, third-party testimonials and advertisements. Cosmetic advertising has its own NPRA guideline in addition to the claims rules.
Sources & references
- NPRA — Annex I, Part 8: Guideline for Cosmetic Claims — the five-step decision process and the unacceptable versus acceptable claims table by product type.
- NPRA — Annex I, Part 2: Non-Permissible Product Name for Cosmetic Product — the names that cannot be used on a notified cosmetic.
- NPRA — Annex I, Part 10: Guideline for Cosmetic Advertisement — the separate rules that apply to advertising.
- NPRA — Guidelines for Control of Cosmetic Products in Malaysia — section 3.5 on cosmetic claims and the notification framework.
Update history
August 2026 — First published.
Next step: if you are still deciding which route your product belongs on, start with our guide to cosmetic notification, MAL and MDA registration for pain relief products, then see the formats and ready formulas on our OEM pain relief and cooling gel page. Send your draft name and claim lines through the ORIZI Group contact page and we will review them against both annexes before you commit to artwork.
