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

Indonesia is a rapidly growing market for cosmetics, characterized by its large population and increasing consumer awareness. The regulatory landscape is dynamic, with stringent requirements aimed at ensuring product safety, efficacy, and quality. Notably, Indonesia places a strong emphasis on Halal compliance, adding a unique dimension to its cosmetic ingredient regulations. This article provides a comprehensive overview of the regulatory framework and specific requirements for cosmetic ingredients in Indonesia.

1. Core Technical Requirements: Standards for Ingredient Use

Cosmetic ingredients must meet stringent technical requirements regarding safety, efficacy, and quality. Compliance with safety and efficacy standards must be supported by laboratory test results and/or relevant scientific or empirical references. The quality of ingredients must adhere to recognized standards or prevailing regulatory provisions.

2. Ingredient Management

The BPOM Regulation No. 25 of 2025 categorizes cosmetic ingredients into specific lists to regulate their use:

• Permitted Ingredients with Restrictions: Ingredients listed in Annex I may be used subject to specified concentration limits, conditions of use, and mandatory warning statements on product labels.

• Permitted Colorants: Annex II lists colorants allowed in cosmetics (excluding those used specifically for hair dyeing).

• Permitted Preservatives: Annex III details the preservatives permitted for use in cosmetics.

• Permitted UV Filters: Annex IV outlines the UV filters allowed in cosmetic products.

• Prohibited Ingredients: Annex V contains a comprehensive list of ingredients that are strictly prohibited from being used in cosmetics.

The use of ingredients not listed in Annexes II, III, and IV as colorants, preservatives, or UV filters is prohibited, except for natural ingredients native to Indonesia used in locally manufactured cosmetics, provided their safety and efficacy are scientifically proven and documented in the PIF.

3. Approval Mechanism for New Ingredients and Natural Cosmetic Ingredients