Detailing Standards of Cosmetics Labeling, Claim and Advertisement in Indonesia

With Indonesia' s growing middle class and increasingly prosperous consumers, the country' s cosmetic sector has performed well up until 2018. According to Indonesia' s BPOM (National Agency of Drug and Food Control) 33,823 registered cosmetic products were sold in the country as of September 2017. Indonesia' s cosmetic industry growth was recorded at a remarkable 12% with a total sales value of IDR 19 trillion (~US$1.3 billion). On top of that, cosmetic product exports have also increased by almost 3.6% for the last five years. 

In the next 10 to 15 years, it is predicted that Indonesia will become one of the top five ranked Asian markets for cosmetics. This rise to prominence of Indonesia’s cosmetic sector will present more business opportunities for many other cosmetic brands. 

Cosmetic Businesses in Indonesia

With Indonesians becoming more aware of their well-being and lifestyle, the demand for cosmetic and personal care products in Indonesia is rising and has shows no sign of slowing down. The major sales in Indonesian cosmetic and personal care sector include hair care products (37%), skin care products (32%), and makeup (10%). Females in the country are the main consumers for makeup products (Indonesia' s female population now numbers over 130 million).

Labeling Standards of Cosmetics in Indonesia

Understanding regulations regarding the labeling of cosmetics is crucial for any manufacturing or distribution of cosmetic products in Indonesia. Here are some of the major requirements.

a. Label should not easily wear off, fade, or be separated from the packaging.

b. Labeling should contain complete and clear information. This information must not be misleading. Accurate information should be provided and the information should be deliberately or accidently misleading.

c. Specific requirements for use of the Indonesian language are made, especially for uses/claim, direction of use and warning/caution.

d. The use of a foreign language is permitted provided it is written using standard alphanumeric.

e. The information on the packaging shall contain the following points:

• Name of cosmetics

• Uses

• How to use

• Composition

• Name and country of origin

• Name and full address of the manufacturer

• Net size, content, and weight

• Warning/attention

• Etc.

These points are included in the primary and secondary packaging.

f. In case there are limitations to size and shape of the primary packaging, the minimum information required is cosmetics name, batch number and net size/content/net weight. Other important information can be included in secondary packaging or in a brochure, hanging tag, or shrink wrap.

g. The ingredient list/contents must comply with the following conditions:

• Using International Nomenclature of Cosmetic Ingredients (INCI)

• Use the genus and species name for raw materials derived from plants or plant extracts

• Written from highest to lowest concentration.

Claim Standards

Cosmetic claims are statements on labeling that include information about benefits, safety, etc. As mentioned earlier in the labeling of the packaging, cosmetic claims on the packaging must be objective, not exaggerated, have been proven scientifically and written in Indonesian language.

Cosmetic claims cannot state things outside the cosmetic function. 

There are claims that are prohibited in cosmetics such as:

• Using medical terminology or directly or indirectly inferring medical efficacy  (treatment, restore, recover, prevention of disease)

• Using words such as "safe", "free", "harmless", "no side effects"

• Using recommendations from healthcare workers

• Using words such as removing or killing bacteria

• Etc.

In addition, claims such as "whitening" are not allowed to be used on cosmetic products, because these claims can be misleading to consumers. However, the use of "brightening" claim is allowed.

In addition to that, "safe" is not permitted to be used in cosmetics claims, because it can imply that other products that do not claim "safe", are by omission unsafe products. 

Following are claims that are not allowed for cosmetics (these are just some examples):

• Improving skin texture

• Removing dandruff permanently

• Improving skin elasticity

• Safe for daily use

• Etc.

It is recommended to seek professional assistance for claim review to ensure this claim is acceptable by BPOM.

Advertisement Standards for Cosmetics

Cosmetic advertisement is a form of communication about cosmetic products and / or brands to a target consumer. Media that can be used to advertise cosmetics are print media such as magazines, newspapers and leaflets; electronic media such as television and social media; and outdoor media such as billboards and panels. These advertisements are done for the purpose of marketing or trading cosmetics.

Cosmetics that are not registered with the BPOM are prohibited from advertising. Before being advertised, cosmetics must be registered at BPOM to obtain marketing approval. It is not necessary for a company to register their cosmetic advertising at the BPOM. However, all advertisements of registered cosmetic products should fulfill the provisions set out by the BPOM. 

On a side note, winning testimonials, award agency logo such as “Superbrand” logo, logo of a health or professional organizations are all permitted in cosmetic advertisements. 

Religious leaders, healthcare professionals or actors that resemble healthcare personnel are not allowed to appear in cosmetic advertisements. The BPOM supervises cosmetic advertisements through a post-market system throughout Indonesia. Monitoring will be carried out on all media (print, electronic, etc.). If a cosmetic advertisement does not meet the requirements, it will be followed up according to the regulations and sanctions will be imposed based on the specifics of the violations.

Halal Product Claim Creates More Opportunities

Indonesia is a country with the largest percentage of Muslims in the world. This is a good opportunity for both domestic and foreign investors to develop halal cosmetic products. Marketing products with halal claims can help gain the trust of and attract Indonesian customers.