BackgroundIn Indonesia, PIF shall be prepared by manufacturers or importers before cosmetics are notified and provided when the Indonesia Food and Drug Supervisory Agency (BPOM) conducts an examination. The PIF must be maintained in electronic and/or written form, stored appropriately, and updated whenever changes occur. The language can be either English or Indonesian. |
On October 31, 2022, BPOM released a draft of the Guidelines for Product Information File (PIF) for public consultation. 1 Nine months later, on August 2, 2023, BPOM finalized and implemented the Guidelines. 2 For products that received the notification number before August 2, 2023, the notification number owner must update the PIF within six months.
The Guidelines consists of six chapters, sixteen articles, and one appendix, covering requirements for documents, language, retention, storage format, PIF review methods, etc. The purpose of the Guidelines is to assist cosmetic companies in preparing and compiling the PIF and provide guidance to BPOM officials during PIF reviews.
Compared with the previous Guidelines for Product Information File released in 2017, the main amendments are as follows.
1. Clarifying the standards for documents included in PIF
The Guidelines categorizes the documents to be included in the PIF into four types. It provides explicit standards that these four types of documents must adhere to.
No. | Documents Type | Standards |
1 | Administrative documents | 1. Scientific or empirical evidence’s fulfillment of the ingredients’ technical requirements stipulated in Technical Requirements for Cosmetics Ingredients; 2. Fulfillment of contamination requirements stipulated in Limitations for Contamination in Cosmetics; 3. Fulfillment of the requirements stipulated in the Regulation for Cosmetics Adverse Reaction Monitoring in terms of the monitoring results of cosmetic adverse reactions; 4. Fulfillment of the requirements stipulated in the Technical Requirements for Cosmetic Labeling in terms of cosmetic labeling; 5. Fulfillment of the requirements stipulated in the Technical Requirements for Cosmetics Claims in terms of cosmetic claims. |
2 | Cosmetic ingredient’s quality and safety data | |
3 | Cosmetic product’s quality data | |
4 | Safety and efficacy data of cosmetic product |
2. Amending the documents required in PIF
Administrative documents | Indonesian cosmetics | Imported cosmetics | Commissioned produced cosmetics |
1. photocopy of business registration number
2. photocopy of the GMP certificate or the fulfillment certificate for GMP aspects
3. photocopy of the license agreement between the brand owner and the notification applicant (for the notification applicant who is appointed as the trademark licensee)
4. photocopy of the statement regarding brand which is consistent with the one submitted when conducting notification
5. photocopy of the statement letter with stamp duty which proves directors and/or leaders are not involved in criminal acts in the field of cosmetics
6. photocopy of valid cosmetics production license | 1. photocopy of the agency’s appointment letter which is consistent with the one submitted when conducting notification
2. photocopy of the contract cooperation agreement between the notification applicant and overseas cosmetic company that is legalized by a notary public and includes the brand and/or product name and the expiration date of the agreement
3. photocopy of the Certificate of Free Sale (CFS) which is consistent with the one submitted when conducting notification
4. photocopy of the GMP certificate or the statement of GMP application which is consistent with the one submitted when conducting notification
5. photocopy of the statement regarding brand which is consistent with the one submitted when conducting notification
6. photocopy of the statement letter with stamp duty which proves directors and/or leaders are not involved in criminal acts in the field of cosmetics
7. photocopy of Importer Identification Number (API) | 1. photocopy of cosmetics production license and the GMP certificate
2. photocopy of the contract cooperation agreement between the contractor and the recipient of the production contract, which is consistent with the one submitted when conducting notification
3. photocopy of the statement regarding brand which is consistent with the one submitted when conducting notification
4. photocopy of the statement letter with stamp duty which proves directors and/or leaders are not involved in criminal acts in the field of cosmetics
5. photocopy of business license in the cosmetics sector from the contractor | |
Cosmetics ingredient’s quality and safety data | 1. Cosmetics ingredient’s quality data
2. Cosmetics ingredient’s safety data
Notes: Safety data can be stored separately from other PIF documents. | ||
Cosmetic product’s quality data | 1. Cosmetics formula which contains
1) name 2) fragrance composition code number in accordance with International Fragrance Association (IFRA) guidelines 3) supplier identity
2. Cosmetics manufacturing
3. Cosmetics specifications and analytical methods:
4. Cosmetics stability data
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Safety and efficacy data of cosmetic product | 1. Safety assessment
2. Regularly updated and reported cosmetic adverse reaction monitoring results.
3. Data that support cosmetic claims
4. Cosmetics labeling and other information, at least contain:
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Notes:
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3. Other noteworthy points
The Guidelines revises the retention time of the PIF from a minimum of 6 years after the latest production or importation of cosmetics to a minimum of 1 year after the expiration date of the last cosmetics produced or imported. Additionally, the Guidelines specifies that the PIF change history must be documented and incorporated as an integral part of the PIF;
The Guidelines provides clear clarification on the PIF review method, allowing for reviews to be conducted either at the facility of the notification number owner or through an online platform;
The Guidelines introduces amended penalties for companies found to be in violation of the Guidelines:
1) written warning; 2) temporary closure of online access for notification applications for 1 year at most; 3) temporary closure of online access for import certificate applications for 1 year at most; 4) temporary prohibition to distribute cosmetics for 1 year at most; 5) cosmetics recall; 6) temporary suspension of production and/or importation of cosmetics for 1 year at most; 7) revocation of notification number.
Notes: Added or amended penalties are marked in red. |
The Guidelines does not modify PIF's language requirements or retention form.


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