Indonesia Proposes Amendments to Cosmetic Notification Requirements

Indonesia released a draft amended Regulation concerning the Procedure for Submission of Cosmetics Notification. The amendments include: 1. Clarifying definitions and expanding exemptions from notification; 2. Revising qualifications and documentary requirements for notification applicants; 3. Updating procedures for issuing and amending letters of recommendation; 4. Adjusting timelines and requirements for notification review, updates, and cancellation.

Terms:

Refillable perfume: It is a perfume preparation made directly at the manufacturing facility by mixing fragrance concentrates with solvents in certain compositions according to consumer's demand;
Letter of recommendation as the notification applicant: Importers or business entities engaged in a production contract must obtain a recommendation as a notification applicant. This recommendation is secured by submitting a facilities inspection application to the Head of the local UPT BPOM;
Good manufacturing practice (GMP) certificate: It is a legal document serving as a proof that the cosmetic enterprise has fully implemented GMP in the manufacture of cosmetics;
Certificate of GMP fulfillment: It is a legal document serving as a proof that the cosmetic enterprise has gradually implemented GMP. The Certificate is divided into Class A and Class B. Class A is applicable to enterprises that can produce all types of cosmetics, while Class B is applicable to enterprises that can only produce certain types of cosmetics. Class A requires enterprises' compliance in 10 aspects in GMP, while Class B requires compliance in 2 aspects in GMP.

The Indonesian Food and Drug Supervisory Agency (BPOM) is revising the Regulation on the Procedure for Cosmetic Notification. The first draft was released on December 9, 2024, ¹ followed by a second draft for public consultation on September 11, 2025. ² Stakeholders may submit feedback through the official consultation link (bit.ly/KP-TCPNK) by September 21, 2025. Below is a summary of the key changes that will impact cosmetic companies looking to import products into Indonesia, with newly added or modified requirements highlighted in red.

Key Amendments

1. Clarification of Definitions

1) Indonesian Domestic cosmetics: Expanded to include intermediate products processed and packaged in Indonesia;

2) Imported cosmetics: Defined as cosmetics manufactured abroad for distribution in Indonesia;

3) Bulk products: Defined as processed materials requiring only packaging to become finished products.

Indonesia Proposes Amendments to Cosmetic Notification Requirements

Key Amendments

1. Clarification of Definitions

2. Expanded Notification Exemptions