By Tam Nguyen | CEO, GOL Solution | 24+ years in international trade & cross-border logistics

Last Updated: September 2026

Shopee’s cross-border program handles fulfilment for overseas sellers, including getting the parcel into Singapore. It does not handle the regulatory side. For cosmetics in Singapore, a notification with the Health Sciences Authority (HSA) has to be in place before you list, and the company named on that notification has to be based in Singapore.

If you want the step-by-step HSA notification process, read our cosmetics registration guide. This article covers what changes when your fulfilment runs through Shopee’s cross-border program.

What Does Shopee’s Cross-Border Program Cover, and What Stays With the Brand?

The program covers one of four jobs in a cross-border cosmetics sale: moving the parcel into Singapore.

The program is private, and its terms are between Shopee and the seller, so we describe it only as it works for the sellers we have spoken with: fulfilment is covered and the notification stays with the brand. Check your own program terms before you rely on either point.

What Does Shopee Require From Cosmetic Sellers in Singapore?

Shopee requires the HSA notification number on every cosmetic listing, and it bans listings that lack one.

• A notification number on every listing. Sellers must fill in the HSA notification number attribute on cosmetic listings. The number comes from HSA’s Acknowledgement of Notification.
• Real consequences for skipping it. Supplying an un-notified cosmetic product is an offence. The seller must stop supply and take reasonable measures to recall it, and can face a fine of up to S$20,000 and/or up to 12 months in prison. Shopee bans flagged listings.
• Documents to get a listing back. After a ban, sellers submit the HSA Acknowledgement of Notification as a PDF for each variation in the listing. If the entity name on the acknowledgement differs from the name registered with Shopee, they also need a signed and stamped Letter of Authorisation.

Why Does an Overseas Brand Need a Local Responsible Person?

An overseas brand without a Singapore entity cannot file the HSA notification itself. HSA requires a cosmetic product to be notified before it is supplied, and the online system requires an entity registered with ACRA and a Corppass account. You can start selling once you receive the acknowledgement.

The label also has to carry the name and address of the company or person responsible for placing the product on the local market. That is the Responsible Person’s name and address, not the overseas brand’s.

The role carries duties beyond filing. HSA lists them as keeping supply records for two years, providing safety data when asked, monitoring adverse events and recalling unsafe products. HSA can also ask to see the product information file, and the notification holder has to produce it.

A brand with its own Singapore entity can hold the notification itself. Everyone else appoints a Responsible Person.

How Does This Work for One Sunscreen Entering Singapore through Shopee cross-border program?

Can one notification cover a single tube and a bundle?

Yes, a single tube and a two-tube bundle of the same formulation could be covered under one notification, with no additional notification or service fee from us.

What does the Responsible Person service include?

It runs for 12 months, with GOL acting as the named Responsible Person and notification holder with HSA. It includes an independent review of the manufacturer’s product information file against the ASEAN PIF standard.

What is charged only if triggered?

Four items are billed as optional.

• PIF development: only if the manufacturer’s file is incomplete, or the safety assessment lacks a qualified assessor’s sign-off.
• Label compliance review: only if classification finds missing mandatory label content or a claim that is not acceptable for a cosmetic. Classification service from us will help answer this for brands.
• PIF update: only if a change to the formula, an ingredient or the label means the file must be revised.
• Adverse event report: only if one is required.

If the manufacturer’s file is complete and signed by a qualified assessor, and the label is compliant, none of these items arise.

What happens at renewal for HSA notification, and what about the security deposit?

The notification renews every year the product stays notified, and the Responsible Person term is 12 months. A refundable security deposit is standard, and the refund timing after termination is 30-45 days.

What Should You Ask Before Appointing a Responsible Person?

Ask these questions to decide the right service provider for you:

1. Does the notification fee include HSA’s government fee, or is that billed separately?
2. Who reviews the product information file, and what happens if the manufacturer’s file is incomplete?
3. Is formula, UV filter and claims review included, or only label review?
4. Which items are charged only if triggered, and what triggers each one?
5. What is the renewal total, and what are the terms if the formula or label changes mid-term?
6. How are HSA queries, adverse events and recalls handled, and what is charged separately?
7. What happens at termination, including the return of any deposit?

When Does This Approach Not Apply?

It does not apply in three cases.

• Products with treatment claims. A cosmetic notification covers products for cleaning, protecting, perfuming or improving appearance. Shopee’s own guidance lists products intended for treatment, such as acne treatment creams, as not cosmetics. A sunscreen stays on the cosmetic pathway only if its claims are cosmetic and UV-protection claims, with no medicated or drug claims.
• Brands with their own Singapore entity. They can hold the notification themselves and only need help with the file, label and claims.
• Samples and trials. Products supplied solely as samples for promotion, or solely for testing or trial, do not need notification.

FAQ

If Shopee’s cross-border program handles fulfilment, do I still need an HSA notification?

Yes. Fulfilment and notification are separate. Shopee asks for the HSA notification number on cosmetic listings, and supplying an un-notified cosmetic product is an offence whatever route the parcel takes.

Is the Responsible Person the same as the importer?

No. The importer deals with the shipment at the border. The Responsible Person is the Singapore company named on the label and the notification, which answers to HSA on safety, adverse events and recalls. One company can do both, but they are separate jobs and can be quoted separately.

Can one notification cover different variants of the same product formula?

Ask your provider how it treats pack variants, because the answer depends on the formulation and how the products are presented.

What if Shopee bans my listing for a missing notification?

Prepare the HSA Acknowledgement of Notification as a PDF for each variation, and a signed and stamped Letter of Authorisation if the notifying company’s name differs from your Shopee registration. Documents must be in date and unedited. Once verified, you can relist.

Does the sunscreen SPF claim change anything?

SPF and UV-protection claims fit the cosmetic pathway. Claims that imply treatment or a change to how the body works do not. We screen the formula against the permitted UV filters and their limits under the ASEAN Cosmetic Directive before anything is notified.

Does GOL classify the product before anything is filed?

Yes. We classify the product first to confirm whether it can enter Singapore and under which pathway, in the same way we do for food. For a cosmetic, that means confirming it qualifies as a cosmetic under HSA’s definitions, screening the ingredients and UV filters against the ASEAN Cosmetic Directive annexes, and reviewing the label and claims. You receive a written classification report that lists any issues to fix before the notification is filed.

Does GOL require a security deposit?

Yes. We require a refundable security deposit from every brand that uses our IOR service, and the same applies to a regulatory-only Responsible Person engagement. The deposit is refundable to the brand 30 to 45 days after the contract is terminated.

How Do You Get Started?

Start by sending us your ingredient list and label artwork if you sell, or plan to sell, cosmetics into Singapore through Shopee’s cross-border program. We will tell you whether the product classifies as a cosmetic, whether the formula and UV filters clear ASEAN limits, and what a Responsible Person engagement covers, before you commit to anything.

Talk to our Singapore team about Responsible Person and HSA notification support.