Cosmetic Product Registration in Indonesia

If you’re planning to import, manufacture, or distribute cosmetic products in Indonesia, registering with the National Agency of Drug and Food Control (BPOM) is a legal requirement. 

Without proper registration, your products cannot be sold in the Indonesian market, and non-compliance can lead to penalties, product recalls, or a ban on distribution.

This guide walks you through the cosmetic product registration process in Indonesia, including BPOM requirements, necessary documents, and step-by-step process to help you launch your products legally and efficiently.

Legal Framework for Cosmetic Product Registration in Indonesia

What is Classified as a Cosmetic Product?

Cosmetic products in Indonesia are defined as substances or mixtures intended for use on the body. This includes products for cleansing, perfuming, altering appearance, and keeping the body’s external appearance in good condition.

Following are the categories of cosmetic products in Indonesia as per their function:

Category	Examples
Skin Care Products	Moisturizers, Sunscreens
Hair Care Products	Shampoos, Conditioners, Hair Styling Products
Oral Care Products	Toothpaste, Mouthwash (non-medicinal)
Makeup and Decorative Cosmetics	Foundations, Lipsticks, Blushes
Fragrances	Perfumes, Deodorants
Cosmeceuticals	Products with cosmetic and therapeutic effects (e.g., anti-aging serums)

BPOM further classifies cosmetics products based on their risk levels:

• Low-Risk Cosmetics: Everyday products with minimal risk (e.g., basic moisturizers).
• High-Risk Cosmetics: Products requiring stricter regulation due to active ingredients or specific functions (e.g., acne treatments)

Who Can Register Cosmetic Products in Indonesia?

All businesses involved in the production, importation, and distribution of cosmetic products must register with the National Agency of Drug and Food Control (BPOM). This includes the following:

1. Local manufacturers – companies that produce cosmetics domestically.
2. Importers and Distributors – Entities that import cosmetics from abroad and distribute them within Indonesia.
3. Contract Manufacturers – Individual businesses or entities that partner with domestic manufacturers to produce cosmetics.

Keep in mind that only Indonesian legal entities can register products with BPOM. Foreign companies must appoint a local distributor or representative in Indonesia to handle the BPOM registration process. This means you cannot directly register without a local partner as a foreign company.

Emerhub can act as your local agent for BPOM registration in Indonesia. We can provide you with end-to-end support as your local representative. We can help facilitate communication with BPOM and handle any audits or inspections needed for registration.

How to Register Cosmetic Products in Indonesia

1. Document Preparation for BPOM Registration

To apply for cosmetic product registration in Indonesia, you must have the following documents as outlined under the BPOM Regulation No. 22 of 2017:

1. Must be a legally established entity in Indonesia with an active Business Identification Number (NIB).
2. Safety Assessment Report to demonstrate that the product is safe for consumption. 
3. Comply with BPOM regulations regarding ingredients, labeling, and marketing claims.
4. Good Manufacturing Practices (GMP) certification.
5. Document of Product Information (DIP) containing details about quality, safety, and benefits.
6. Completed BPOM application form. 
7. Certificate of Analysis for further verification of product safety and quality assurance.
8. Trademark Registration Certificate (if applicable). 
9. Product sample.

Our regulatory experts will help you compile all the requirements for cosmetic product registration to ensure accuracy and avoid rejections.

2. Labeling Regulations for Cosmetics in Indonesia

As a requirement enforced by BPOM, cosmetic products must also comply with labeling regulations to ensure product transparency with consumers. According to BPOM Reg 18/2024, all cosmetic labels must include the following information:

• Name of the product 
• Intended function or use of the product
• A full list of ingredients in descending order of concentration
• Manufacture and importer details including the name and address (for imported products)
• Production batch number 
• Expiration date
• BPOM registration number
• Warning labels to highlight any potential allergens or safety information relevant to consumers. 

For refillable cosmetic products, labels must also indicate the name and address of the refill facility along with refill dates. The inclusion of 2D barcodes for better traceability is also recommended on the label. 

3. Submission to BPOM

Once all documents are prepared, visit the BPOM e-registration platform (Notifkos) and upload all required documents electronically.  It is crucial that all documents are legalized by the Indonesian embassy or consulate in the country of origin if necessary. 

4. BPOM Approval Process

Once the application is submitted along with the required documentation and payment, BPOM conducts an initial review. During this phase, BPOM checks whether all necessary documents are included and correctly filled out. The approval process generally takes between 14 days to 2 months from the date of submission depending on the complexity of the product and BPOM’s workload. 

5. Issuance of Registration Certificate

Upon successful approval, BPOM will issue a notification number (notifikasi kosmetik) valid for five years. It is essential to renew this certificate before expiration to continue selling the product legally in Indonesia. If the application is rejected, BPOM will provide reasons for the denial, allowing applicants to address any issues before reapplying.

6. Obtaining a Halal Certification

The most recent updates to BPOM regulation is the inclusion of a Halal certification to reflect compliance with Islamic Dietary Laws. Given Indonesia’s majority Muslim population, obtaining halal certification is also essential for cosmetic products to succeed in the market. 

Common Issues with Cosmetic Product Registration in Indonesia

Cosmetic product registration in Indonesia can be challenging due to various regulatory requirements and compliance requirements. Here are the most common problems faced by companies during the process:

1. GMP Certification: Delays or rejections due to the lack of a valid GMP certification, which must be issued by recognized government bodies.
2. Ingredient Compliance: Products containing prohibited substances or exceeding allowable limits face rejection. For instance, certain preservatives like Phenoxyethanol have strict limits; exceeding these can lead to application denial. Additionally, the use of prohibited substances such as mercury or lead can result in immediate rejection of the product registration
3. Incomplete Documentation: Submitting incomplete or inaccurate documentation can lead to delays or denials. Inadequate or improperly formatted documents can lead to significant delays. All required documents must be thoroughly prepared. 
4. Language Barriers: Miscommunication due to language differences can complicate compliance and understanding of BPOM requirements. This issue is particularly pertinent for foreign companies that may not have proficient Indonesian speakers on their teams.
5. Counterfeit Concerns: The prevalence of counterfeit cosmetics poses challenges for legitimate brands, necessitating protective measures during registration.

Emerhub’s local regulatory experts offer end-to-end services for your cosmetic product registration in Indonesia. We will handle the entire process on your behalf, from choosing the right classification to document preparation, application submission, and post-issuance compliance.

Fill out the form below to discuss your plans and needs with our regulatory experts.