What Is a Cosmetic Notification Holder (CNH)?
A Cosmetic Notification Holder (CNH) is a Malaysian-registered company or individual that is legally responsible for notifying cosmetic products with NPRA (National Pharmaceutical Regulatory Agency) and for ensuring those products comply with Malaysian cosmetic regulations throughout their market life.
The CNH is the legal point of contact between the brand and NPRA. They hold the NOT number, respond to any regulatory queries or enforcement actions, and bear responsibility if a product is found to be non-compliant after sale.
Who Needs a Cosmetic Notification Holder?
All cosmetic products sold in Malaysia need a CNH. The key distinction is:
- Malaysian brands and manufacturers — typically notify products under their own company, acting as their own CNH.
- Foreign brands without a Malaysian entity — must appoint a separate Malaysian company as their CNH. This is the most common scenario for overseas brands from China, South Korea, Taiwan, Japan, Europe, and the US entering the Malaysian market.
If you are a brand owner based outside Malaysia and do not have a registered Malaysian company (Sdn Bhd or otherwise), you cannot submit an NPRA notification yourself. You must appoint a CNH before any product can legally be notified or sold.
What Are the Legal Responsibilities of a CNH?
A Cosmetic Notification Holder in Malaysia takes on significant legal obligations. These include:
- Holding the NOT number — the CNH is the registered holder of the Notification Number for each product
- Ensuring product compliance — the CNH is responsible for confirming that ingredients comply with NPRA's permitted and restricted lists
- Maintaining the Product Information File (PIF) — the CNH must keep all technical documentation on file and make it available to NPRA upon request
- Post-market surveillance — if a safety issue or adverse event is reported, the CNH is responsible for communicating with NPRA
- Responding to enforcement actions — if NPRA conducts an inspection or recall, the CNH is the primary point of contact
CNH vs. Setting Up a Malaysian Company: Which Is Better?
Foreign brands entering Malaysia face a choice: appoint an existing company as their CNH, or incorporate their own Malaysian entity. Here's a comparison:
| Factor | Appoint a CNH Representative | Set Up a Malaysian Company |
|---|---|---|
| Speed to market | Fast — can begin notification immediately | Slow — company incorporation takes 1–3 months minimum |
| Cost | Lower — pay a service fee per product or annually | Higher — incorporation fees, annual compliance costs, local director requirements |
| Complexity | Low — CNH handles all NPRA-related filings | High — requires ongoing corporate governance, tax filing, SSM compliance |
| Control | Lower — dependent on CNH's processes | Full — your own entity, your own decisions |
| Best for | Brands testing the market, 1–20 products, cost-conscious entry | Brands with large product portfolios and long-term Malaysian operations |
For most overseas brands entering Malaysia for the first time, appointing a CNH representative is the most practical choice. It gets products to market faster and avoids the overhead of running a local entity.
How to Appoint a CNH Representative in Malaysia
The process of appointing a CNH representative involves:
- Select a qualified CNH — the CNH must be a registered Malaysian company with an active Quest 3+ account and experience managing cosmetic notifications
- Sign an authorisation agreement — a formal agreement between your brand and the CNH, granting them authority to notify products on your behalf
- Provide product information — full ingredient lists, formulations, label artwork, CoA, and other required documentation
- CNH submits via Quest 3+ — the CNH creates the notification under their registered account and submits to NPRA
- NOT number issued to CNH — upon approval, the NOT number is held by the CNH on your brand's behalf
What Happens If You Sell Cosmetics in Malaysia Without a CNH?
Selling cosmetics in Malaysia without a valid NOT number — which requires a CNH — is a criminal offence under the Control of Drugs and Cosmetics Regulations 1984. Penalties include:
- Seizure and confiscation of non-compliant products
- Fines and potential criminal prosecution
- Ban from the Malaysian market and reputational damage
NPRA conducts regular market surveillance and can act on complaints from competitors or consumers. Online marketplaces (Shopee, Lazada) also increasingly require proof of NPRA notification for cosmetic listings.
We Offer CNH Representation for Overseas Brands
Our firm provides full Cosmetic Notification Holder (CNH) representation services for international brands entering the Malaysian market. We act as your legal CNH, handle all NPRA notifications, maintain your Product Information Files, and manage all regulatory correspondence — so you can focus on selling.
We currently represent brands from China, South Korea, Japan, Taiwan, Hong Kong, Singapore, Europe, and the US in the Malaysian cosmetics market.