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Indonesia Clarifies Cosmetic Test Parameters for Import Certificate Application

Background

Importers of cosmetic products must obtain an SKI Border (import certificate) before goods are released from customs. One of the required documents for SKI Border issuance is a Certificate of Analysis (CoA), which must comply with the following provisions:

a. Issued by an accredited manufacturer or laboratory; and

b. Include test parameters as specified by BPOM.

On June 3, 2025, Indonesia’s Directorate of Standardization of Traditional Medicines, Health Supplements, and Cosmetics (OTSKK) released a draft Regulation Concerning Cosmetic Test Parameters in Certificate of Analysis (CoA) for Import Certificate Application. 1 Stakeholders are invited to submit feedback by June 10, 2025, via the following:

This draft Regulation outlines the mandatory cosmetic test parameters that must be included in the CoA, which is a key document for obtaining the SKI Border. The required test parameters cover microbial and heavy metal contamination, applicable to the following 20 cosmetic product categories:

1. Creams, emulsions, liquids, thick liquids, gels, and oils for skin (face, hands, feet, etc.)

2. Facial masks (excluding chemical peeling products)

3. Foundations (thick liquid, paste, powder)

4. Make-up powders, body powders, antiseptic powders, etc.

5. Bath soaps, including antiseptic variants

6. Perfume products

7. Bath products (salts, foams, oils, gels, etc.)

8. Depilatory products

9. Deodorants and antiperspirants

10. Hair care products

11. Shaving products (cream, foam, liquid, thick liquid, etc.)

12. Eye and facial make-up, and make-up removers

13. Lip care and make-up products

14. Dental and oral care products

15. Nail care and make-up products

16. Products for external intimate areas

17. Sun bath and sunscreen products

18. Self-tanning products

19. Skin lightening products

20. Anti-wrinkle products

Test Parameter Example: Facial Masks

Product Type

HS Code

Testing

Rinse-off/leave-on

Microbial contamination

Minimum heavy metals tested

Facial masks (excluding chemical peeling products)

Masks

3304.99.90

√ (Hg and Pb)

Rinse-off/leave-on

Peeling

3304.99.90

√ (Hg)

Rinse-off

Eye masks

3304.99.90

√ (Hg)

Rinse-off/leave-on

For the complete list of test parameters, please refer to Chapter 2: Cosmetic Test Parameters in the Certificate of Analysis section of the Regulation’s Annex. For translation services, feel free to contact us at [email protected].

Other Requirements for CoA Submission

Beyond the specified test parameters, the Regulation further clarifies that the CoA must also fulfill the following two requirements:

  • Validity: CoAs for microbial and heavy metal testing can only be used for a maximum of one year from the date of issuance;

  • For the import of the same product with a different batch, the CoA must also include the dosage form and organoleptic characteristics.

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