In Indonesia the so-called negative list approach is employed for chemicals control. Hazardous and toxic chemicals are regulated by making lists of specified hazardous chemicals to be controlled. Indonesia does not have a risk-based chemical control approach to regulated chemicals based on assessment results of their hazards and exposure as is employed in for example EU-REACH. However, the Indonesia government is working to improve the current method of chemical control. Indonesian government published the Chemical Substance Bill that aims to regulate from import/export, production, transportation, usage to disposal in 2012. As of 2018 the Bill has not been promulgated but is still under consideration.
Jun-11-2025
On June 2, 2025, the Indonesian Food and Drug Supervisory Agency (BPOM) introduced a new draft aimed at strengthening the safety and quality oversight of imported cosmetic products. This important update outlines the mandatory test parameters that must be included in Certificates of Analysis (CoA) submitted during the import certification process.
Key Update:
The new guidelines have been issued in accordance with Article 16(6) of BPOM Regulation No. 27/2022 (amended by No. 28/2023) and supported by Presidential and BPOM regulations issued between 2017 and 2025.
Key Requirements for Importers:
Border Import Certificate (SKI):
All cosmetic imports must obtain an SKI prior to entering Indonesia.
Certificate of Analysis (CoA):
The CoA must be issued by either:
The product manufacturer, or
An accredited laboratory.
Mandatory Test Parameters in the CoA:
The CoA must include testing results for:
Heavy metals (including lead (Pb), mercury (Hg), arsenic (As), and other specified metals)
Microbial contamination.
Batch-Specific Information:
For multiple batches of the same product, the CoA must also specify:
Dosage form
Organoleptic properties such as appearance, smell, and texture.
Cosmetic Categories & Test Parameters:
Product Type |
HS Code |
Required Tests |
Rinse Type |
Notes |
Creams, Lotions, Oils |
3304.99.30 |
Pb, Hg (based on type), Microbial |
Non-Rinse |
Includes day/night creams, moisturizers |
Foot Care Products |
3304.99.30 |
Pb, US metal (if talc), Microbial |
Non-Rinse |
Talc-based products included |
Skin Freshener |
3304.99.90 |
Hg, Microbial |
Non-Rinse |
|
Massage Cream/Oil |
3304.99.30 |
Microbial (oil only Pb & Microbial) |
Non-Rinse |
|
Acne Preparations |
3304.99.20 |
Hg, Microbial |
Non-Rinse |
|
Foundation & Concealers |
3304.99.30 |
Pb, Hg, As, Microbial |
Non-Rinse |
|
Face & Body Powders |
3304.91.00 |
US metal, Microbial |
Non-Rinse |
|
Certificate Validity:
Each Certificate of Analysis is valid for one year from the date of issue.
Purpose of the Regulation
This decision is intended to:
Provide legal clarity and compliance certainty to business actors
Ensure consumer safety
Enhance BPOM's ability to supervise cosmetic imports effectively.
Effective Date: The decision comes into force on the date of enactment.
Feb-24-2025
The Indonesian Cosmetics Notification System 3.0 officially launched on January 2, 2025, bringing with it a number of significant updates designed to enhance the product notification process. With a primary focus on improving regulatory compliance, this updated system introduces several new features and requirements aimed at streamlining the way cosmetic companies manage their product notifications.
Below is a detailed overview of the key features and new requirements within the Indonesian Cosmetics Notification System 3.0. This guide will help to navigate the system more efficiently and ensure that products comply with the latest regulations.
Key Features of the Cosmetics Notification System 3.0:
Improvements of the Cosmetic Distribution Permit
The updated system introduces improvements to the distribution permit process, now covering:
New Products: Enterprises can submit new products for notification.
Export-Only Products: The system now includes provisions for products intended for export only.
Product Clustering: Businesses can now cluster products for streamlined notification and approval.
Cosmetic Notification Updates:
The system now allows notifications for the following:
Product Updates: Notify any changes or updates to existing products.
Cosmetic Kit Updates: Provide updates for cosmetic kits.
Export-Only Product Updates: Submit notifications for products intended exclusively for export.
Company and Manufacturer Changes Notifications:
Notifications can be made for changes such as:
Company Changes: Notify when there are changes within the company structure.
Factory Changes: Report all changes related to factories.
Multi-Factory Changes: Manage updates for businesses operating multiple factories.
Packaging Changes/Variations Notifications:
Now, it is possible to notify about changes to:
Packaging Variations for Cosmetic Products: Notify variations in product packaging.
Packaging Variations for Cosmetic Kits: Notify packaging changes for cosmetic kits.
Cosmetic Kit Notifications:
The new system now accommodates notifications for cosmetic product kits, improving the management of kit-related products.
New Requirements for Product Submission:
In order to ensure smoother processing and regulatory compliance, the following steps and requirements must be observed when submitting product notifications:
Intended Use of the Cosmetic Product: Ensure that the intended application site for each product is clearly specified based on its intended use.
Product Information File (PIF) Link: Notifiers can now provide a direct link to the Product Information File (PIF) for products being notified.
OSS Permit ID: If the newly created PB UMKU OSS permit ID is not visible, go to the Administrator menu, select "OSS permit ID," and click the "inquire permit ID" button.
Notification Letter Access: If the notification letter is not accessible, go to the Administrator menu, enter the product license ID, click "Show," and then click "Query File DS" in the product list.
Important Points to Remember When Entering Ingredient Information:
The updated system now includes the International Nomenclature of Cosmetic Ingredients (INCI) for each ingredient. Please follow these guidelines when entering ingredient data:
Ingredient Identification: Ingredients must be listed by either their INCI name or CAS number.
Ingredient Percentage: The "Percentage" column must be completed accurately. Ensure that ingredients listed in Appendices I-IV of the Technical Requirements for Cosmetic Ingredients are not marked with a.
Formula Consistency: When updating product information, ensure that the updated ingredient names and concentrations are consistent with previously submitted data.
Non-Listed Ingredients: If an ingredient is not listed in the system, businesses should consult the Directorate of Standardization of Traditional Medicines, Health Supplements, and Cosmetics for further guidance.
For complete details and official guidance, visit the Notifikos 3.0 system here.
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