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Indonesia Proposes to Amend Cosmetic Ingredient Use Requirements: 75 Newly Prohibited Ingredients, 2 Amended Restricted Ingredients and 2 Deleted Preservatives

The main amendments include: 1) Deleting requirements specifically related to cosmetics containing alpha arbutin or beta arbutin; 2) Appendix I: List of Restricted Ingredients – 1 revised; 3) Appendix III: List of Permitted Preservatives – 1 deleted; 4) Appendix IV: List of Permitted Sunscreens – 1 revised; 5) Appendix V: List of Prohibited Ingredients – 75 added.

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;

  • Ingredients listed in Appendix II, III and IV that are not used as the colorant, preservative and sunscreen agent, and do not comply with the requirements in Appendix II, III and IV;

  • Colorants not listed in Appendix II (except for colorants specifically used for hair dyeing)

  • Preservatives and sunscreen agents not listed in Appendix 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 the Product Information File (PIF);

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

On March 1, 2024, the Indonesian Agency for Food and Drug Control (BPOM) released the amended draft of the Technical Requirements for Cosmetic Ingredients for public consultation until March 19, 2024. 1 The proposed amendments include:

1) Deleting requirements specifically related to cosmetics containing alpha arbutin or beta arbutin;

2) Appendix I: List of Restricted Ingredients – 1 revised;

3) Appendix III: List of Permitted Preservatives – 1 deleted;

4) Appendix IV: List of Permitted Sunscreens – 1 revised;

5) Appendix V: List of Prohibited Ingredients – 75 added.

1. Deleting requirements specifically related to cosmetics containing alpha arbutin or beta arbutin

The requirements proposed to be deleted are as follows:

1) The mandatory attachment of hydroquinone content test results to the PIF. The test results can be in:

a. Certificate of cosmetic analysis

b. Cosmetic stability test

2) The labeling of cosmetics' storage conditions on the packaging.

2. Slightly adjusting the expression in the use requirements for Salicylic acid in Appendix I List of Restricted Ingredients

Ref. No. in

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

98

Salicylic acid (INCI)

 

CAS No. 69-72-7

 

Benzoic acid, 2-hydroxy-

(a) Rinse-off hair products

 

(b) Other products except body and hand skin care; preparations used in the eye area; preparation of lip care and makeup; roll-on deodorant

 

(c) Body and hand skin care*; preparations used in the eye area; preparation of lip care and makeup; roll-on deodorant **

 

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

 

**Preparations included in roll-on deodorant 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;

 

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.

 

As a preservative, see Appendix III List of Permitted Preservatives, No.46.

 

***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.

3. Deleting 1 preservative from Appendix III List of Permitted Preservatives

Ref No. in ACD

Substance

Maximum authorized concentration

Limitations and requirements

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

40

2-Benzyl-4-chlorophenol

 

Chlorophene (INCI)

 

CAS No. 120-32-1

0.2%

/

/

4. Amending the use requirements for Benzophenone-3 in Appendix IV List of Permitted Sunscreens

Ref No. in ACD

Substance

Maximum authorized concentration

Other limitations and requirements

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

4

2-Hydroxy-4-methoxy-benzophenone/Oxybenzone (INN)

 

Benzophenone-3 (INCI)

 

CAS No. 131-57-7

a) Face products, hand products, and lip products, excluding propellant and pump spray products: 6%

 

b) Body products, including propellant and pump spray products: 2.2%

 

c) Other products: 0.5%

For a) and b): Not more than 0.5% to protect product formulation

 

For a): If used at 0.5% to protect product formulation, the levels used as UV filter must not exceed 5.5%

 

For b): If used at 0.5% to protect product formulation, the levels used as UV filter must not exceed 1.7%

For a) and b): Contains Benzophenone-3 (4)

(4): Not required if the Oxybenzone level is ≤ 0.5% and when it is used only for product protection purposes.

5. Adding 75 prohibited ingredients to Appendix V List of Prohibited Ingredients

The prohibited cosmetic ingredients in Appendix V are increased from 1,606 to 1,681. Find the 75 newly prohibited ingredients here (highlighted items).

Newly Prohibited Cosmetic Ingredients (Excerpt)

No.

Ref No. in ACD

Substance

CAS No.

1608

1387

2-Chloracetamide

79-07-2

1609

1388

Octamethylcyclotetrasiloxane; D4

555-67-2

1610

1391

Acetaldehyde; ethanal

75-07-0

1611

1393

N-Methyl-2-pyrrolidone; 1-methyl-2-pyrrolidone

872-50-4

1612

1397

Sodium perborate [1];

Sodium peroxometaborate; sodium peroxoborate [2]

15120-21-5 [1]

7632-04-4 [2]

10332-33-9 [2]

10486-00-7[2]

1613

1398

Perboric acid (H3BO2(O2)), monosodium salt trihydrate [1]; Perboric acid, sodium salt, tetrahydrate [2]; Perboric acid (HBO(O2)), sodium salt, tetrahydrate sodium peroxoborate hexahydrate [3]

13517-20-9 [1]

37244-98-7 [2]

10486-00-7 [3]

ChemLinked’s Notes

  • The proposed additions to Indonesian Appendix V List of Prohibited Ingredients align with the amendments made to the ingredient annexes of the ASEAN Cosmetic Directive (ACD) during the 36th, 37th, and 38th ASEAN Cosmetic Scientific Body (ACSB) meetings;

  • The proposed revisions to Appendix III List of Permitted Preservatives and Appendix IV List of Permitted Sunscreens correspond to the amendments adopted during the 37th and 38th ACSB meetings;

  • For salicylic acid in Appendix I List of Restricted Ingredients, the only adjustment is the serial number in the usage requirements, which is a result of the removal of two preservatives from Appendix III. The usage limit and conditions for salicylic acid remain unchanged.

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