Process for Cosmetic Registration in Indonesia

The beauty and cosmetics market in Indonesia is growing fast with a 14% growth in cosmetics sales in 2012 totaling USD 1.01 billion (Euromonitor). Sales of cosmetics in Indonesia's urban areas for the first half of 2013 increased by 9.4% to USD 53.8 million compared to the same period in 2012 (Nielsen Indonesia 2013 Survey). Rural areas in Java offer huge potential evidenced by the positive growth seen in cosmetics sales which have increased by 27.5% year-on-year to USD 7.3 million in the first half of 2015. The spread of retail outlets throughout Indonesia has also diversified the sales channels available for potential investors. Modern supermarkets, department stores, convenience stores and pharmacies offer a wider product range, making global brands available to new customers.

The ASEAN Harmonized Cosmetic Regulatory Scheme states that ASEAN member countries must accept products that have been registered in another ASEAN member country; however, the regulation leaves final approval up to member states so it is still not yet valid and you need to register your cosmetic product in Indonesia.

The process of cosmetic product registration in Indonesia is regulated by Indonesian Agency for Drug and Food Control, also call BPOM which is under Indonesian Ministry of Health.

Product registration in Indonesia requires that you have your own company in Indonesia and/or distributor/agent which can register your product.  This requirement can look simple but actually can be very tricky since according to the Indonesian regulation you can only register your product in Indonesia through a single legal entity. It means that this company will have a degree of exclusivity on your products since this company is the sole holder of the product license (usually for 3 years) and without their approval, you can't make use of any other distributors. Choosing the correct partner in Indonesia can be a key factor in your future success.  In this case we suggest you to register your products with a third party with a proven track record that will offer the flexibility to cooperate with multiple local distributors.

Once you decide which company you will use for product registration, you need to initially submit an online form with all requested supporting documents to BPOM E-application to obtain a user ID and password for your company.

This user application can be conducted 1 (one) time, as long as there is no change in the applicant data. If data changes are required your company must submit a data change notification or filed for readmission.

The List of requested supporting documents:

a. Original Application Letter signed by the Director or the Proxy of Director and duly stamped

b. Duly stamped Original Letter of Statement of the Responsible Person

c. Photocopy of Import Identification Number (API)

d. Photocopy of Trading Business Permit (SIUP)

e. Photocopy of the Tax Identification Number (NPWP)

f. Photocopy of Importation Letter of Authorization in the form of General Certificate by Notary, in the case where the application is a company that has been authorized for import

g. Pharmaceutical Industry Permit in case of Drug importation; h. PBF permit, for PBF that has been authorized by the pharmaceutical industry to conduct importation of drug

i. List of HS Code that will be imported.

Process of Cosmetic Product registration:

Once your company is registered at BPOM, you can start the process of product registration by following these steps:

1) Document Preparation

You will need to prepare a set of documents related to each of product. 

2) Product Submission

You will need to submit and receive a notification from BPOM for each product you want to register.

3) Payment to BPOM

BPOM will collect the payment for each product registered.

4) BPOM notification

In the regular process, BPOM will issue the notification in 2 weeks after they receive payment. Once it's issued, you can import your product to Indonesia. The notification will be valid for three years and you can extend it.

During your product registration and import process you have to be aware also that:

• All cosmetics products must comply with Indonesian National Standards (SNI), of testing. These include testing and limitations on microbial issues, the presence of heavy metals and the prohibited material.

• All cosmetic products must meet safety, benefit, labeling, quality and claim requirements. These are spelled out in Indonesia Codex Cosmetics and other official lists of national standards.

• All cosmetic products must follow precise rules for the labeling, production, packaging and advertising of cosmetics products in Indonesia.

• Translation. Labels on all products have to be translated into Bahasa Indonesian. Proper translation is essential to ensure that all instructions, uses and cautions are accurate.