On 21 November 2024, the two-year grace period for cosmetic products to comply with the updated ASEAN Cosmetic Directive (ACD) ended. The updates were introduced during the 36th ASEAN Cosmetic Committee (ACC) meeting and its related sessions in November 2022. Products that do not meet the updated standards must be withdrawn immediately. The amendments reflect the ASEAN region’s approach to aligning with global safety standards and protecting the health of consumers in its 10 member states.

Key Updates to the ACD

• Annex II – List of substances which must not form part of the composition of cosmetic products

A consolidated list of 37 substances previously banned in the EU, has been added to Annex II of the ACD. These include entries from EU regulations (2019/831, 2019/1966, 2021/850, 2021/1902) that are not currently used in ASEAN countries. Specific compounds such as perboric acid, sodium perborate, boron compounds, octamethylcyclotetrasiloxane (D4), and p-BMHCA have also been included in Annex II.

• Titanium Dioxide Regulation

Revised safety criteria for the use of titanium dioxide as a colouring agent (Annex IV) and as a UV filter (Annex VII) have been adopted as per EU standards.

• Salicylic Acid Regulation

New limits have been introduced for salicylic acid in the Restricted Substance List (Annexes III) and in the Preservatives list (Annex VI), used in body creams, lotions, and other specific applications.

Implications for Industry

Cosmetic manufacturers, traders, and distributors were granted a two-year grace period to reformulate, test and phase out non-compliant products. With the end of this period concluded, compliance is now mandatory, ensuring that products meet updated safety requirements.

Detailed guidelines for compliance can be found here.

On August 29, 2024, Indonesia’s National Agency of Drug and Food Control (BPOM) released a draft amendment to the Regulation Concerning Cosmetic Labeling, Promotion, and Advertising for public consultation which ended on 2 September 2024. The draft amendment includes business obligations and supervision requirements for the labeling, promotion and advertising of cosmetics.  

Draft to Revoke Existing Cosmetic Labeling and Advertising Regulations 

The draft regulation by BPOM is intended to replace several existing regulations related to cosmetic labeling, promotion, and advertising. Specifically, it will revoke the following regulations once enacted: 

• BPOM Regulation No. 30 of 2020 on Technical Requirements for Cosmetic Labeling. 

• BPOM Regulation No. 32 of 2021 on Cosmetic Advertising Supervision. 

• BPOM Regulation No. 12 of 2023 on Supervision of Cosmetic Manufacturing and Distribution, particularly the sections related to cosmetic labeling and advertising, as well as the supervision of labeling for refillable cosmetics. 

This regulation will take effect on the day of its promulgation. This Agency Regulation will be promulgated by the person in charge by publishing it in the Republic of Indonesia's State Gazette to ensure that everyone is aware of it. 

Comprehensive Labeling Requirements  

The amendment sets out detailed requirements for product labeling, including the following information:  

• Product name  

• Usage  

• Composition  

• Country of origin  

• Full name and address of the Notification Number Owner  

• Batch number  

• Size, content, or net weight  

• Expiration date  

• Notification number  

• 2D barcode  

• Warning and/or caution  

• Benefits or uses   

In addition businesses may include a halal label on the packaging, provided they own the product’s notification number.  

Clear Guidelines for Refillable Cosmetics  

The draft also addresses   

refillable cosmetics, which are cosmetics that are repackaged in containers according to consumer requests made at cosmetic refill facilities. The labeling for refillable cosmetics must include at least the following information:   

• Product name  

• Notification number  

• Name and address of the cosmetic refill facility  

• Batch number  

• Refill date and expiration date  

Promotion and Advertising Rules  

Advertising is a promotion in the form of a communication message regarding cosmetics and/or refillable cosmetics and/or cosmetics and/or refill cosmetics brands to the target audience, in the form of images, writing, sound, audiovisual or other forms delivered by various means for marketing and/or trade of cosmetics and/or refill cosmetics.  

Promotion and advertising may only be carried out for cosmetics that have obtained a distribution permit in the form of a notification from the Head of the Agency. Promotional and advertising publications must be in accordance with the data and information contained in the notifications and comply with advertising ethics.