Indonesia has notified the WTO of a draft BPJPH decree establishing Guidelines for the Implementation of the Halal Assurance System for Cosmetics. The measure is intended to guide business operators, halal supervisors, halal auditors, halal product assurance inspectors and other stakeholders in applying Indonesia’s halal assurance requirements to cosmetic products.

The draft is open for comments until 2 August 2026. The proposed adoption and entry into force dates are still to be determined under the WTO notification, while the draft decree itself states that it would apply three months after the date of enactment.

Key regulatory scope

The draft guideline applies to cosmetic products and supports the implementation of Indonesia’s halal product assurance framework. It refers to Government Regulation No. 42 of 2024, under which cosmetics are included among products required to obtain halal certification.

The guideline covers two main areas:

1. Halal Assurance System criteria for cosmetics
2. Critical halal control points for cosmetic products

Main compliance requirements

Business operators would be expected to establish and consistently implement a documented Halal Assurance System, including:

• a written halal policy;
• appointment and development of halal supervisors or halal management teams;
• control of raw materials, additives, processing aids, packaging, applicators, lubricants, grease, sanitizers and cleaning agents;
• verification of halal status for materials and supporting documents;
• separation of halal and non-halal materials, facilities and tools;
• control of production, storage, packaging, distribution and transport;
• halal labeling once certification is obtained;
• internal audits at least once a year;
• reporting of internal audit results and material composition / halal production process data to BPJPH.

Materials and halal-critical ingredients

The draft identifies several halal-critical material categories for cosmetics, including materials of animal origin, plant origin, microbial origin, chemically processed materials, biologically processed materials, genetically engineered materials, human-derived materials, gold particles, alcohol or ethanol, shellac, silk cocoons, placenta, snail-derived materials, and other materials covered by MUI fatwas.

For animal-derived cosmetic materials, the guideline distinguishes between prohibited animals, halal animals, animal hair, horn, hide, placenta and insects. Human-derived materials such as placenta, blood, hair and urine are considered prohibited for cosmetic use under the draft guideline.

Critical halal control points

The guideline identifies critical control points across the cosmetic production chain, including:

• receipt of materials;
• sampling and verification;
• quarantine and storage of incoming materials;
• weighing and measurement;
• processing;
• bulk product handling;
• packaging;
• labeling;
• finished product storage;
• distribution and transportation.

Industry impact

The draft is significant for cosmetic manufacturers, importers, brand owners and distributors placing cosmetic products on the Indonesian market. Companies should review ingredient origin, supplier halal documentation, shared-facility controls, cleaning validation, halal traceability, packaging controls and product labeling readiness.

For international cosmetic companies, the most important practical step is to map all formulation ingredients and processing aids against halal-critical sources, especially alcohols, animal-derived ingredients, fermentation inputs, enzymes, solvents, emulsifiers, waxes, fatty acids, surfactants, sanitizers and packaging materials that may come into contact with the product.