Clarifying Licenses for Private-Label Cosmetics Made by OEM
CC-04 | PMD Act | Cosmetics | OEM | License structure
When you sell OEM-made cosmetics under your own brand. The licenses you need depend on who becomes the marketing authorization holder.
When you sell OEM-made cosmetics under your own brand, the licenses you need depend on who becomes the marketing authorization holder. There are three patterns: the OEM manufacturer also acts as the marketing authorization holder, you obtain the marketing license yourself, or you use an overseas OEM. Procedures and responsibilities differ for each. With domestic OEMs, the manufacturer often also acts as the marketing authorization holder. With overseas OEMs, a Japanese party needs the marketing license. Package labeling (the marketing authorization holder statement) and advertising responsibility are also decided by this choice. We learn about your business plan and the transaction structure with the OEM manufacturer, clarify which pattern fits, and help with the required licenses and notifications, through to checking package labeling.
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basic information
[For] Businesses selling OEM-made cosmetics under their own brand [Services] Clarifying the pattern from the transaction structure / checking required licenses and notifications / checking package labeling / connecting to license applications [Legal basis] PMD Act Articles 12 and 61
Price information
We provide a quote based on the transaction structure and required procedures. The first consultation is free.
Delivery Time
※Please contact us before signing a contract with the OEM manufacturer.
Applications/Examples of results
Typical situations: - You want to sell OEM-made cosmetics under your own brand - Your OEM manufacturer said no license is needed - You want to manufacture at an overseas plant - You do not know how to state the marketing authorization holder on the package
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Company information
Our office is run by an administrative scrivener (gyoseishoshi) who completed a master's course at Kyoto University Graduate School of Engineering and then worked as a researcher at a chemical manufacturer, developing cosmetics, detergents, adhesives, semiconductor and optical materials. Hands-on experience also includes SDS preparation, waste liquid management and risk assessment. Because we can read structural formulas, SDSs and process flow diagrams as they are, you do not need to spend time explaining your technology. We prepare documents grounded in both science and law, and handle communication with the authorities. As a Class A Hazardous Materials Engineer and a 1st Grade Certified Skilled Worker of Financial Planning, we also support capital investment subsidies and business plans from the perspective of profitability and cash flow. The first consultation is free.
