FAQ Vol. 28 | Regulatory Insights from Indonesia’s BPOM on Cosmetic Labeling Requirements

In this issue, ChemLinked summarizes the official responses published by Indonesia’s Food and Drug Supervisory Agency (BPOM) to questions raised by cosmetic companies. The focus is on cosmetic labeling requirements.

1. How should the composition be listed on cosmetic labels?

Ingredients must be listed in descending order based on their concentration. However, cosmetic ingredients with a concentration of less than 1% may be listed in any order after those present at concentrations above 1%.

2. How should the expiration date be written on cosmetic packaging?

1) The expiration date must be written in the order of day, month, and year, or month and year.

2) It must be preceded by the phrases “tanggal kedaluwarsa”, “baik digunakan sebelum”, or equivalent English terms such as “EXP”, “Exp. Date”, “Best Before”, “Expired Date”, and similar expressions, as applicable.

3. Is it necessary for notified cosmetics to include the product's call center (manufacturer/importer) on the packaging?

Including the call center number on the packaging is not mandatory and depends on the policies of each company.

4. Is it permissible to use stickers for imported cosmetics? Can the distributor or importer affix the label?

Cosmetic labeling is permitted to use stickers, provided that they are not easily removed, separated from the packaging, faded, or damaged. However, the labeling must be affixed by the manufacturer in the country of origin and may not be attached by the distributor or importer.

5. Do claims need to be written in Indonesian? If there is no exact equivalent, is English or bilingual labeling allowed?

Labeling must use Indonesian or an equivalent term in Indonesian. If an exact equivalent is not available, a foreign language may be used, provided the meaning is clearly understandable to consumers. Additionally, all efficacy claims stated on the labeling must align with BPOM regulations.

6. Can the claims or labeling submitted in the notification system differ from those printed on the primary or secondary packaging?

In the notification system, business actors are not required to upload labeling and/or claims during the notification submission process. Therefore, the claims entered in the notification template are not subject to review. However, all claims and labeling used on the product's primary or secondary packaging must comply with BPOM Regulation on Technical Requirements for Cosmetic Labeling and BPOM Regulation on Technical Requirements for Cosmetic Claims. As long as they meet the requirements set forth in these regulations, they are permitted.

7. Is it mandatory to include the words "BPOM RI" above the 2D barcode used for cosmetic product identification?

The phrase "BPOM RI" must be displayed near the BPOM 2D barcode only if there are two 2D barcodes on the product packaging, in order to clearly distinguish the BPOM identification code from any other barcode.

FAQ Vol. 28 | Regulatory Insights from Indonesia’s BPOM on Cosmetic Labeling Requirements

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