Indonesia’s Cosmetic Ingredient Regulations

As one of the world's most dynamic and rapidly expanding cosmetics markets, Indonesia presents significant opportunities for global brands. However, navigating its regulatory landscape requires a clear understanding of its unique requirements, which are designed to ensure product safety, quality, and efficacy. A defining feature of Indonesia's framework is the mandatory Halal certification, which adds a crucial layer of compliance for all cosmetic products.

This guide provides a streamlined overview of Indonesia's cosmetic ingredient regulations, focusing on the core requirements set by the National Agency of Drug and Food Control (BPOM), key differences with the ASEAN Cosmetic Directive (ACD), and the critical considerations for Halal compliance.

Part 1: Regulatory Framework and Competent Authority

1.1 Main Regulations on Cosmetic Ingredient Use

1.2 Competent Authority

The primary regulatory bodies overseeing cosmetics in Indonesia are the National Agency for Drug and Food Control (BPOM) and the Halal Product Assurance Organizing Agency (BPJPH).

• BPOM: Responsible for the pre-market notification and post-market surveillance of cosmetics. BPOM ensures that products comply with safety, efficacy, quality, and labeling requirements before they can be distributed in Indonesia.

• BPJPH: The government agency responsible for implementing Halal product assurance in Indonesia. BPJPH oversees the Halal certification process, sets Halal standards, and issues Halal certificates for various products, including cosmetics and their ingredients.

Part 2: Key Regulatory Requirements for Cosmetic Ingredients

2.1 Core Technical Standards

All cosmetic ingredients used in Indonesia must meet stringent technical requirements for safety, efficacy, and quality. Claims of safety and efficacy must be substantiated with scientific evidence, such as laboratory test results or established scientific literature. The quality of ingredients must conform to recognized standards or prevailing regulatory provisions.

2.2 Ingredient Management System

BPOM Regulation No. 25 of 2025 organizes cosmetic ingredients into specific annexes to control their use:

• Annex I - Permitted Ingredients with Restrictions: This list contains ingredients that are allowed for use but are subject to specific conditions, such as maximum concentration limits, prescribed uses, and mandatory warning statements on the product label.

• Annex II - Permitted Colorants: Lists all colorants approved for use in cosmetic products (excluding hair dyes).

• Annex III - Permitted Preservatives: Details the preservatives that are permitted in cosmetic formulations.

• Annex IV - Permitted UV Filters: Outlines the UV filters that can be legally used in cosmetic products.

• Annex V - Prohibited Ingredients: This is a comprehensive list of ingredients that are strictly forbidden in any cosmetic product sold in Indonesia.

Using an ingredient as a colorant, preservative, or UV filter that is not on the respective permitted list is prohibited. An exception exists for natural ingredients native to Indonesia used in locally made cosmetics, provided their safety and efficacy are scientifically proven and documented in the Product Information File (PIF).

2.3 Approval of New Ingredients

For new ingredients not listed in the annexes, or for Indonesian native natural ingredients intended for use as colorants, preservatives, or UV filters, prior approval from the Head of BPOM is required. The process involves:

1. Application Submission: The applicant must electronically submit a request to BPOM for a safety assessment.

2. Dossier Submission: The application must be supported by a comprehensive technical dossier that includes a full data package proving the ingredient's safety and quality. For nanomaterials, BPOM may request additional data to evaluate potential risks associated with their unique properties.

3. Review and Approval: BPOM conducts a thorough assessment of the submitted data. If the evaluation is successful, BPOM will issue an approval, permitting the ingredient's use in cosmetics in Indonesia.

2.4 Differences from the ASEAN Cosmetic Directive (ACD)

While Indonesia, as an ASEAN member, largely harmonizes its regulations with the ACD, notable differences exist in the management of certain ingredients. Companies marketing products across the ASEAN region must be aware of these variations.

• Restricted Ingredients: Some ingredients, like Camphor and Menthol, are restricted in Indonesia but are not on the ACD's restricted list. Conversely, the ACD restricts substances such as peanut oil derivatives and hydrolyzed wheat protein, which are not listed in Indonesia's regulation.

• Prohibited Ingredients: Indonesia's list of prohibited ingredients includes HC Red No. 7 and plastic microbeads, which are not prohibited under the ACD. On the other hand, certain parabens (e.g., Isopropylparaben, Isobutylparaben) banned by the ACD are not currently on Indonesia's prohibited list.

For a detailed list of ingredients with different requirements, please visit ChemLinked article.

2.5 Halal Requirements

With mandatory Halal certification for cosmetics set to take effect on October 18, 2026, the Halal status of every ingredient is a paramount concern.

To be Halal-certified, a product's formulation must be completely free of haram (forbidden) materials, and its production process must guarantee no cross-contamination with non-halal substances. Ingredients are typically categorized as:

• High-Risk Ingredients: These require a valid Halal certificate from a BPJPH-recognized body. They include materials of animal origin (e.g., gelatin, collagen), animal-derived glycerin, and certain enzymes.

• Low-Risk Ingredients (Halal Positive List): These are materials considered inherently Halal, such as mined minerals, most plant-derived substances, and certain synthetic chemicals. For these, a full certificate may not be required; compliance can often be shown with supporting documents like a Certificate of Analysis (CoA), specifications, or a declaration of origin.

• Ethanol: The use of ethanol is permissible as long as it is not derived from khamr (alcoholic beverages) or the khamr industry.

2.6 Ingredient Labeling Rules

Clear and accurate ingredient labeling is mandatory under BPOM Regulation No. 18 of 2024. Key requirements include:

• Nomenclature: Ingredients must be listed by their International Nomenclature of Cosmetic Ingredients (INCI) names.

• Order of Concentration: Ingredients must be listed in descending order of their concentration in the formula. Ingredients at less than 1% and colorants can be listed in any order after those present at higher concentrations.

• Nanomaterials: Any ingredient in nano-form must be clearly identified with the word "(nano)" following its name (e.g., Titanium Dioxide (nano)).

• Animal-Derived Ingredients: The origin of specific animal-derived ingredients must be declared on the label.

• Non-Halal Labeling: A draft regulation mandates that any cosmetic product containing non-halal ingredients must bear a distinct "NON HALAL" label, featuring red capital letters inside a red rectangular box on a white background.

Further Reading

• Indonesia Cosmetic Ingredient Compliance Guide: BPOM Requirements, ACD Differences, and Halal Considerations

• Indonesia Cosmetic Regulation

• ASEAN Cosmetic Halal Certification Regulation