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Indonesia Proposes to Amend Cosmetic Ingredient Use Requirements: 1 Ingredient Added and 11 Ingredients Revised

The main amendments include: 1) Appendix I: List of Restricted Ingredients – 1 added and 6 revised 2) Appendix II: List of Permitted Colorants – 1 revised 3) Appendix III: List of Permitted Preservatives – 2 revised 4) Appendix IV: List of Permitted Sunscreens – 2 revised

Background: Current Ingredient Use Requirements

Cosmetic ingredients in Indonesia shall comply with Technical Requirements for Cosmetic Ingredients and its appendices:

  • Appendix I: restricted ingredients

  • Appendix II: permitted colorants with limitations and conditions of use (excluding hair dyes only for dyeing hair)

  • Appendix III: permitted preservatives with limitations and conditions of use

  • Appendix IV: permitted sunscreens with limitations and conditions of use

  • Appendix V: prohibited ingredients

 

Prohibited cosmetic ingredients in Indonesia are:

  • Ingredients listed in Appendix I that do not comply with the allowable limit and conditions of use;

  • Ingredients listed in Appendix II, III and IV that do not comply with the requirements specified in the Appendices;

  • Colorants, preservatives, and sunscreens not listed in Appendix II, III, and IV;

  • Prohibited ingredients listed in Appendix V.

 

Notes:

  • Other cosmetic ingredients not listed in Appendix I can be used as long as it meets the safety, efficacy, and quality requirements. Relevant scientific or empirical evidence shall be provided and included in Product Information File (PIF).

  • When natural ingredients not listed in Appendix II, III, and IV are used as colorants, preservatives, or sunscreens in cosmetics, relevant scientific or empirical evidence shall be provided and included in PIF.

On August 24, 2023, Indonesia introduced draft amendments to the Appendices in the Technical Requirements for Cosmetic Ingredients. 1 The main amendments are summarized as follows. Added requirements are highlighted in red and deleted requirements are marked with a strikethrough.

1) Adding 1 restricted ingredient to Appendix I List of Restricted Ingredients

No.

Ref. No.

ACD #

Ingredient name/CAS No.

Restrictions

Conditions of use and warnings which must be printed on the label

Field of application and/or use

Maximum authorized concentration

Limitations and other requirements


a

b

c

d

e

f

219

339

Methyl-N-methylanthranilate*

CAS No. 85-91-6

(a) Leave-on products

 

(b) Rinse-off products

(a) 0.1%

 

(b) 0.2%

(a) Not to be used in sunscreen preparations and products marketed for exposure to UV rays, both natural and artificial.*

 

(a) and (b)

- Not to be used with compounds that can form nitroso;

- Maximum nitrosamine content: 50 μg/kg (in raw materials);

- Stored in a nitrite-free container.

/

*This restriction does not apply to products with secondary UV protection claims as described in the preamble of ASEAN Sunscreen Labeling Guidelines. This kind of products include moisturizing and skin lightening products, to name a few.

2) Amending the use requirements of 6 restricted ingredients in Appendix I List of Restricted Ingredients

No.

Ref. No.

ACD #

Ingredient name/CAS No.

Restrictions

Conditions of use and warnings which must be printed on the label

Field of application and/or use

Maximum authorized concentration

Limitations and other requirements


a

b

c

d

e

f

124

98

Salicylic acid (INCI)

CAS No. 69-72-7

 

Benzoic acid, 2-hydroxy-

(a) Rinse-off hair products

 

(b) Other products except skin, body, hand care; eye shadows; mascara; eyeliners; lipstick; roll-on deodorant

 

(c) Skin, body, hand care*; eye shadows; mascara; eyeliners; lipstick; roll-on deodorant**

 

*Preparations included in skin, body and hand care are body cream, body serum, body oil, body butter, body balm, etc. Apart from these preparations, follow point (b).

**Preparations included in roll-on deodorants are deodorants, antiperspirants and antiperspirant deodorants.

(a) 3.0%

 

(b) 2.0%

 

(c) 0.5%

(a), (b), and (c)

Not to be used in preparations for children under three years of age, except shampoo;

 

Not to be used in applications that may lead to exposure of the end user's lungs by inhalation***;

 

Not to be used in dental and oral care preparations.

 

For uses other than as a preservative, the use must be explained on the product labeling.

 

These levels are inclusive of any use of salicylic acid.

 

As a preservative, see Appendix III List of Permitted Preservatives, No.49.

 

***Should not be used in spray preparations. Permitted for use in body powder and face powder as long as it is proven safe by a safety assessment issued by a safety assessor.

(a), (b), and (c)

Not used for children under 3 years of age

 

Notes:

This warning applies to all preparations that may be used in children under 3 years of age and in prolonged skin contact.

206

324

Tagetes minuta flower extract

CAS No. 91770-75-1

 

Tagetes minuta flower oil

CAS No. 91770-75-1/8016-84-0

(a) Leave-on products

 

(b) Rinse-off products

(a) 0.01%

 

(b) 0.1%

(a) Not to be used in sunscreen preparations and products marketed for exposure to UV rays, both natural and artificial.

 

Notes:

This restriction does not apply to products with secondary UV protection claims as described in the preamble of ASEAN Sunscreen Labeling Guidelines. This kind of products include moisturizing and skin lightening products, to name a few.

 

(a) and (b)

- Alpha terthienyl (terthiophen) content in extract/oil: 0.35%.

- When used in combination with Tagetes patula (No. 207) or Tagetes erecta (No. 208), the total content of Tagetes in ready-to-use cosmetics must not exceed the maximum concentration limit stated in column d.

/

207

325

Tagetes patula flower extract

CAS No. 91722-29-1

 

Tagetes patula flower oil

CAS No. 91722-291/8016-84-0

(a) Leave-on products

 

(b) Rinse-off products

(a) 0.01%

 

(b) 0.1%

(a) Not to be used in sunscreen preparations and products marketed for exposure to UV rays, both natural and artificial.

 

Notes:

This restriction does not apply to products with secondary UV protection claims as described in the preamble of ASEAN Sunscreen Labeling Guidelines. This kind of products include moisturizing and skin lightening products, to name a few.

 

(a) and (b)

- Alpha terthienyl (terthiophen) content in extract/oil: 0.35%.

- When used in combination with Tagetes minuta (No. 206) or Tagetes erecta (No. 208), the total content of Tagetes in ready-to-use cosmetics must not exceed the maximum concentration limit stated in column d.

/

208

327

Tagetes erecta flower extract

CAS No. 90131-43-4

 

Tagetes erecta flower oil

CAS No. 90131-43-4

(a) Leave-on products

 

(b) Rinse-off products

(a) 0.01%

 

(b) 0.1%

(a) Not to be used in sunscreen preparations and products marketed for exposure to UV rays, both natural and artificial.

 

Notes:

This restriction does not apply to products with secondary UV protection claims as described in the preamble of ASEAN Sunscreen Labeling Guidelines. This kind of products include moisturizing and skin lightening products, to name a few.

 

(a) and (b)

- Alpha terthienyl (terthiophen) content in extract/oil: 0.35%.

- When used in combination with Tagetes minuta (No. 206) or Tagetes patula (No. 207), the total content of Tagetes in ready-to-use cosmetics must not exceed the maximum concentration limit stated in column d.

/

209

328

2-Hydroxyethyl Methacrylate

HEMA

CAS No. 868-77-9

Preparations for the care and make-up of nails

/

Applied by professionals

 

Notes: Professionals are people who have been professionally trained in their fields.

- Only applied by professionals.

- May cause an allergic reaction.

210

329

11,14-Dioxa-2,9-diazaheptadec-16-enoic   Acid, 4,4,6,16-tetramethyl-10,15-dioxo, 2-[(2-methyl-1-oxo-2-propenyl)oxy]ethyl ester

 

Di-HEMA Trimethylhexyl Dicarbamate

CAS No. 41137-60-4/72869-86-4

Preparations for the care and make-up of nails

/

Applied by professionals

 

Notes: Professionals are people who have been professionally trained in their fields.

- Only applied by professionals.

- May cause an allergic reaction.

3) Amending the use requirements of 1 colorant in Appendix II List of Permitted Colorants

No.

Colour Index (CI) No.

Ingredient name

Color

Field of application and/or use

Maximum authorized concentration and other requirements

1

2

3

4

147

77891

Pigment White 6

White

X




Titanium dioxide in powder form, which contains 1% or more particles with an aerodynamic diameter of 10 μm, shall be used in accordance with the requirements set out in Appendix I List of Restricted Ingredients, No. 218.

 

Notes: For the use of titanium dioxide as a sunscreen agent, see Appendix IV List of Permitted Sunscreens.

Notes:

Field 1: Permitted colorants in all cosmetics.

Field 2: Permitted colorants in cosmetics except for cosmetics used around the eyes.

Field 3: Permitted colorants in cosmetics except for cosmetics that come into contact with mucous membranes.

Field 4: Colorants which are only permitted in rinse-off products.

4) Amending the use requirements of 2 preservatives in Appendix III List of Permitted Preservatives

No.

Ref.   No. ACD #

Ingredient name/CAS No.

Maximum authorized concentration

Limitations and other requirements

Marking/Warning


a

b

c

d

e

49

3

Salicylic acid (INCI) and garamnya (1)

CAS No. 69-72-7

 

Calcium salicylate (INCI)

CAS No. 824-35-1

 

Magnesium salicylate (INCI)

CAS No. 18917-89-0

 

MEA-salicylate (INCI)

CAS No. 59866-70-5

 

Sodium salicylate (INCI)

CAS No. 54-21-7

 

Potassium salicylate (INCI)

CAS No. 578-36-9

 

TEA-salicylate (INCI)

CAS No. 2174-16-5

Salicylic acid:

0.5% (as acid)

 

Salicylic acid salts:

0.5% (as acid)

Salicylic acid:

- Not to be used in preparations for children under 3 years of age.

 

- Not to be used in dental and oral care preparations.

 

- Not to be used in applications that may lead to exposure of the end user's lungs by inhalation.

 

Salicylic acid salts:

Not to be used in preparations for children under 3 years of age, except shampoo.

Salicylic acid:

Not to be used for children under 3 years of age (2)

 

Salicylic acid salts:

Not to be used for children under 3 years of age (3)

51

51

Sodium hydroxymethylamino acetate

 

Sodium hydroxymethylglycinate (INCI)

CAS No. 70161-44-3

0.5%

Not to be used unless the maximum theoretical concentration of releasable formaldehyde, irrespective of the source, can be less than 0.1% w/w in the mixture as placed on the market.

/

Notes:

1. For use other than preservatives, see Appendix I List of Restricted Ingredients, No.124.

2. This marking/warning applies to all preparations that may be used in children under 3 years of age.

3. This marking/warning applies to all preparations that may be used in children under 3 years of age in prolonged skin contact.

5) Amending the use requirements of 2 sunscreens in Appendix IV List of Permitted Sunscreens

No.

Ref.   No. ACD #

Ingredient name/CAS No.

Maximum   authorized concentration

Limitations and other requirements

Marking/Warning

a

b

c

d

e

4

10

2-Cyano-3,3-diphenyl acrylic acid, 2-etylhexyl ester(1)

 

Octocrylene (INCI)

CAS No. 6197-30-4

a. Spray propellant   preparation: 9%

 

b. Other preparations: 10%

/

/

24

27

Titanium dioxide(2)

 

Titanium dioxide (INCI)

CAS No. 13463-67-7/1317-70-0/1317-80-2

25%(3)

Titanium dioxide in powder form, which contains 1% or more particles with an aerodynamic diameter of 10 μm, shall be used in accordance with the requirements as stated in Appendix I List of Restricted Ingredients, No. 218. The maximum content of this ingredient is 25% when used in products other than facial cosmetics in powder form and hair preparations in aerosol form.

/

Notes:

1. Benzophenone used as a contaminant and/or degradation of Octocrylene must be suppressed below the limit of contamination;

2. In the case of using a combination of titanium dioxide and titanium dioxide (nano), the concentration must not exceed 25%;

3. For the use of titanium dioxide as a colorant, see Appendix II List of Permitted Colorants, CI 77891.

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