Organic skin care is among the fastest-growing categories in Indonesia’s cosmetic market. Indonesians are now more in favor of recognizable, plant-based ingredients over synthetic ones. Botanicals like turmeric, moringa, and centella asiatica with visible sustainability practices are now more in-demand in the country.
If you are looking to sell organic skincare products in Indonesia, this article will walk you through the entire process from legalities to product registration.
How is "Organic" Classified in Indonesia
Indonesia does not establish organic cosmetics as a separate BPOM product category requiring a dedicated organic cosmetic registration pathway. Organic and natural skincare products are classified the same way as any other cosmetic.Unlike organic food (which falls under a formal SNI organic standard) an "organic" or "natural" skincare product in Indonesia is treated as a marketing claim instead of a regulated category under BPOM Regulation No. 3 of 2022
Under BPOM Regulation No. 18 of 2024, every claim on your packaging must be truthful, substantiated, and free of anything that could mislead a buyer. Therefore, you can use the word organic on your label, but you have to be able to prove it.
Here are the documents that can be used to substantiate the claim under BPOM Regulation No. 3 of 2022:
- A certification from a recognized international organic body, such as Ecocert or COSMOS
- Certificates or supporting documentation from suppliers confirming the origin or characteristics of relevant raw materials; and
- Product formulation record and other supporting documentation demonstrating the composition and sourcing of the ingredients
Although you don’t need a special certification for organic products, you still need to have the right documentation to prove its natural sources.
Regulatory Update: On July 27, 2026, BPOM issued Decree of the Head of BPOM No. 366 of 2026 concerning the List of Pharmaceutical Raw Materials Used in Natural Ingredient Medicines, Health Supplements, Quasi-Drugs, and Certain Cosmetic Preparations. The decree provides a list of pharmaceutical raw materials applicable to specified product categories, including certain cosmetic preparations, and is currently in force. Businesses developing cosmetic products should review the applicable list when assessing the ingredients used in their formulations.
Key Requirements for Organic Skin Care in Indonesia
Organic skin care is managed by BPOM (Badan Pengawas Obat dan Makanan), Indonesia's National Agency of Drug and Food Control. They are the sole authority overseeing cosmetic products, including organic skincare. Its mandate covers everything from ingredient safety and product notification to labeling standards, import approvals, and post-market surveillance.
To start an organic skin care business, you would need to adhere to requirements set by BPOM:
1. A Legal Vehicle for Holding Licenses
Before you can register a single product, you need a legal presence in Indonesia. BPOM does not allow foreign companies to hold a cosmetic notification directly. To start an organic skin care business, you have two main pathways:
- Establish a PT PMA: a PT PMA or Limited Liability Company is a foreign-owned limited liability company. You have full control over your product registration, import rights, and distribution strategy. However, you need to wait until your business is fully incorporated before you can process any of the required licenses (see below). This route is ideal for long-term and scaled presence in Indonesia.
- Appoint a Local License Holder / Authorized Representative (LAR): Instead of starting your own entity, you can partner with an Indonesian company to register and hold your products on your behalf. This route allows you to enter faster and test the market first with less upfront investment.
Before you engage with a local representative, you need to agree on notification transfer terms. This is common for brands that start out with a license holder and later decide to incorporate their own in Indonesia. Transferring an existing product notification to a new entity is neither free nor automatic. You would need to deregister or cancel the existing notification under the current holder and then re-apply for a new notification from BPOM.
Regardless of the pathway, Emerhub can help you establish your own entity or act as your LAR. Contact our local experts to help you weigh your options.
2. Mandatory Business Permits
Whichever route you choose, your Indonesian entity or your partner needs to have the following permits:
- NIB (Business Identification Number): Issued through the OSS online licensing system, registered under the correct KBLI business classification codes for cosmetic manufacturing, importing, or distribution.
- Sertifikat Standar: Issued by OSS but needs to be verified by the relevant ministry
- API (Importer Identification Number): grants the legal right to import. In most cases, the NIB also functions as your API.
- BPOM physical audit: Before your entity can register its first product, BPOM inspects your warehouse and operations to confirm you meet Good Distribution Practice standards (locally known as CDKB). Inspectors check your storage conditions, your documentation systems, and your standard operating procedures for handling complaints and recalls.
- Notifkos account activation: Passing the BPOM audit is what activates your account on Notifkos (BPOM's digital notification platform) and lets you start submitting product notifications.
BPOM Physical Audit typically happens after your NIB and API are in place and before your first Notifkos submission. However, the exact sequencing can shift depending on your case. Confirm with our local experts before you plan around it.
2. Halal Certification
Starting October 17, 2026, Halal certification becomes a legal requirement for every cosmetic product sold in Indonesia, imported or locally made, under Government Regulation 42/2024 and Law 33/2014. There are three key changes to note:
- Self-declaration is no longer applicable. A formal Halal certificate from BPJPH is now required.
- Halal status extends to the raw materials used on your formulation. Your suppliers need to be able to document the halal status of ingredients.
- BPJH has also confirmed that there will be no further extensions for the October deadline.
If you are planning a product launch, you must process your Halal certification in parallel with BPOM notification. Products that reach the market without it after October will have to be withdrawn.
3. GMP Certification
Article 2 of BPOM Regulation No. 8 of 2026 updated the GMP framework for cosmetics manufacturing or CPKB (Sertifikasi Cara Pembuatan Kosmetik yang Baik). The update shifts more of the compliance burden onto manufacturing and logistics processes rather than formulation alone. This means your production facility's handling, storage, and distribution practices now carry as much regulatory weight.
Import brands do not register under CPKB directly, but their overseas manufacturing plant must possess a valid GMP certificate (e.g. ISO 22716 certificate or equivalent). BPOM requires this proof, along with a Certificate of Free Sale (CFS) from the country of origin, before approving product notifications (NIE).
Brands looking to enter Indonesia via local contract manufacturing (maklon) must ensure their manufacturing partner holds a full CPKB Certificate. Local facilities operating under temporary or "staged" GMP fulfillment certificates (Sertifikat Pemenuhan Aspek) are legally banned from taking third-party contract work.
BPOM Regulation No. 8 of 2026, also aligns with Indonesia’s mandatory Halal obligations. Facilities audited for GMP under BPOM are simultaneously expected to maintain clean, traceable supply chains that pass Halal assurance audits.
4. Organic Skin Care Labeling Requirements
BPOM Regulation No. 18 of 2024 outlines how your skin care products are labeled and packaged. Your label needs to include the following information in Bahasa Indonesia:
- Product name and its intended function
- Your notification number
- Full ingredient list in descending order of concentration
- Name and address of the manufacturer and, for imports, the local importer
- Batch number and expiration date
- Directions for use and relevant warnings, including allergen information
If your product is refillable, you also need to list the refill facility's name, address, and refill date. Under the same regulation, BPOM also mandates 2D barcodes for better traceability. When consumers or BPOM field inspectors scan the code using the official BPOM Mobile application, it dynamically retrieves:
- Product distribution permit status (Notification Number / NIE).
- Validity period of the notification.
- Name and legal address of the notification holder / brand owner.
Any ingredient used in nano form must be labeled with "(nano)" after its name. If your formula uses animal-derived ingredients, such as certain emollients or glycerin sources, their origin needs to be declared on the label.
5: Marketing Your Organic Products
Marketing materials must be presented in Indonesian, though foreign or regional terms that are commonly understood are permitted. BPOM doesn't restrict which channels or formats you use to promote your product. However, whatever you publish needs to meet the same truthfulness and substantiation standard as your label.
How to Register Your Organic Skincare Products with BPOM
Product registration is managed through BPOM’s digital notification platform (Notifkos). During this process, Emerhub’s regulatory team can manage your registration on your behalf.
1. Document Preparation
Every product needs a complete dossier before submission. At minimum, this includes:
- Certificate of Free Sale (CFS) from your product's country of origin, notarized and legalized (for imported products)
- Good Manufacturing Practice certificate (GMP/CPKB) for your production facility
- Letter of Authorization naming your local entity as the official Notification Holder
- Certificate of Analysis, less than a year old, meeting current BPOM testing parameters
- Full ingredient formula using INCI naming conventions
- Product Information File (PIF/DIP), the core dossier proving your product's safety, quality, and claims
- Halal certificate, where applicable to your product category
Every product claim you do make needs to trace back to evidence held in your Product Information File. If what's on the label doesn't match what's in that file, you're looking at regulatory friction the moment BPOM checks.
2. Compliance Screening and Submission
Before submission, Emerhub runs a cross-check for every ingredient against the current restricted and prohibited substance list. We will review your label copy for Indonesian-language and formatting requirements. This step catches the issues that would otherwise trigger a rejection months into the process.
We submit your documents, formula details, and label artwork through Notifkos and handle the government fee (PNBP). This can vary depending on where your product is manufactured, with lower rates for products made within ASEAN and higher rates for products from outside the region.
4. BPOM verification
Standard review takes about 14 working days for imported products and around 7 working days for locally manufactured ones. Simpler categories like fragrances are faster, often requiring only 3 working days. We track the application and respond to any BPOM queries during this window.
5. Notification number issuance
Once approved, your product receives an 11-digit notification number that must appear on your packaging. This is your official market authorization, valid for three years before renewal.
Keep in mind that this timeline covers only the BPOM review itself. The total timeline is somewhere between four to nine months. This factors in entity setup (if you take this route), the pre-registration audit, document collection, and halal certification.
Heavy enforcement for product registration: In mid-2026, BPOM seized more than two million units of unregistered cosmetics worth an estimated IDR 27.6 billion in a single sweet. Products found without proper registration get pulled from shelves and destroyed. Many online marketplaces are becoming a target for these sweeps, and not just physical retail.
Emerhub can help you set up the right legal entity, whether that's a PT PMA or acting as your local product and license holder.
Fill out the form below to talk through your plans with our regulatory team.
Frequently asked questions
Does Indonesia have an official certification for "organic" cosmetics?
Unlike organic food, which follows a formal SNI standard, organic and natural skincare in Indonesia is treated as a labeling claim rather than a certified category. You can market your product as organic, but you need documentation, such as a recognized international organic certificate or a detailed ingredient sourcing dossier, to back that claim up if BPOM ever asks.
Do organic skincare products need BPOM registration even if they use only natural ingredients?
Every cosmetic product sold in Indonesia needs a BPOM notification number regardless of whether it's formulated with natural, organic, or synthetic ingredients. Natural ingredients don't exempt a product from safety testing or the registration process.
Is halal certification mandatory for organic skincare brands specifically?
Halal certification applies to every cosmetic product, organic or otherwise. From October 17, 2026, it becomes mandatory for all cosmetics sold in Indonesia under Government Regulation 42/2024, and self-declaration no longer satisfies the requirement. A formal certificate from BPJPH is needed, and BPJPH has confirmed there will be no further extensions.
Can a foreign investor own 100% of an organic skincare company in Indonesia?
You can start an organic skin care company through a PT PMA structure. This lets a foreign investor retain full ownership of a manufacturing or distribution company, though it comes with more setup time and a higher capital requirement than appointing a local representative.
How long does BPOM registration take for a new skincare product?
The formal review takes around 14 working days for imported products once your documents are submitted, based on current published timelines. The realistic end-to-end timeline, including entity setup, the pre-registration audit, document preparation, and halal certification, typically runs four to nine months for a first-time market entrant.
What happens if I sell organic skincare in Indonesia without BPOM registration?
Selling unregistered products exposes you to shipment seizures, marketplace takedowns, and potential criminal liability under Indonesia's 2023 Health Law, including fines and imprisonment for serious violations. BPOM's enforcement sweeps, including a mid-2026 seizure of more than two million unregistered units, show this isn't just a paperwork risk.
Does every variant of my organic skincare line need a separate BPOM registration?
You need BPOM registration for every product, including its variant. BPOM treats each variant, whether that's a different scent, shade, or packaging size, as a distinct product requiring its own notification and its own registration fee.