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Editor's note: This article was originally published on September 4, 2024, and was updated on December 4, 2024, as per the latest developments. The updated contents are marked in red below.
On August 29, 2024, Indonesia released a draft amendment to the Regulation Concerning Cosmetic Labeling, Promotion, and Advertising for public consultation. 1 This was followed by the finalized BPOM Regulation No. 18 of 2024 Concerning Cosmetic Labeling, Promotion, and Advertising, which was released and implemented on November 28, 2024. 2 Companies with a cosmetic notification number obtained prior to this date must comply with the new regulation no later than November 28, 2025.
BPOM Regulation No. 18 of 2024 replaces BPOM Regulation No. 30 of 2020 Concerning Technical Requirements for Cosmetic Labeling, BPOM Regulation No. 32 of 2021 Concerning Technical Guidelines for Cosmetics Advertising, and the supervision requirements for cosmetic (including refillable cosmetics) labeling and advertising outlined in BPOM Regulation No. 12 of 2023 Concerning Supervision on Manufacture and Circulation of Cosmetics.
The amendments primarily focus on the following key points regarding cosmetic labeling, promotion, and advertising.
1. Newly specifying the mandatory labeling items for refillable cosmetics
Mandatory Information on the Labels | Refillable Cosmetics | Cosmetics Other than Refillable Cosmetics |
Cosmetics name | √ | √ |
Efficacy/Function | √ | |
Instructions for use | √ | |
List of ingredients | √ | |
Manufacturing country | √ | |
Name and complete address of the notification number owner | √ | |
Batch number | √ | √ |
Net size, content, or net weight | √ | |
Expiration date | √ | √ |
Notification number | √ | √ |
2D Barcode | √ | |
Warnings/Attention | √ | |
Name and address of cosmetic refill facility | √ | |
Refilling date | √ | |
Notes:
| ||
2. Extending the scope of the labeling requirements to cover refillable cosmetics
The below labeling requirements are supposed to cover refillable cosmetics after the amendment get officially released:
a. Completeness: The labeling should include all necessary information.
b. Objectivity: Information provided on the label should reflect the actual properties and efficacies of the cosmetics that should not deviate from safety standards.
c. Non-misleading: The labeling should provide honest, accurate, and accountable information, avoiding exploitation of public health concerns.
d. Without claim of drug status: The labeling should not make claims of drug or assert prevention of diseases.
e. Clarity and readability: The labeling should be clear and easily legible.
f. Durability: The labeling should remain intact, legible, and undamaged, avoiding easy separation and fade from the packaging.
3. Introducing additional detailed requirements to enhance the overall labeling standards
Halal cosmetics with halal certificates are allowed to have the halal logo labeled;
Cosmetics containing certain ingredients must include information on the origin of ingredients in the labeling. The certain ingredients will be separately specified by other regulations;
For imported cosmetics, instructions for use must be bilingual, i.e., Indonesian and the language on the original packaging;
For cosmetics produced by multiple factories in Indonesia under a single notification number, the packaging must clearly label the names of the production factories and their respective cities. If the factories have different names and/or locations, they shall be indicated on the packaging with a distinctive mark, batch number, or any other distinguishing feature accompanied by an explanation;
Cosmetics packaged in ampoules and/or vials must be labeled with the warning: “For external use only and not for injection;”
Labeling requirements for cosmetic kit are added as listed in the below table.
Packaging | Labeling Requirements |
Cosmetic kit with primary packaging only | When labeling information on cosmetic kit’s primary packaging, it is important to adhere to the following provisions: a. The notification number labeled should be the notification number of the cosmetic kit instead of the single cosmetic product; b. The 2D Barcode labeled should be derived from the notification number of the cosmetic kit; c. The labeled information should include images and/or information that clearly indicate the layout of each cosmetic within the kit; d. The expiration date shall be provided based on the earliest expiration date among all the cosmetics in the kit. |
Cosmetic kit with both primary and secondary packaging | When labeling information on cosmetic kit’s secondary packaging, it is important to adhere to the following provisions: a. The notification number labeled should be the notification number of the cosmetic kit instead of the single cosmetic product; b. The 2D Barcode labeled should be derived from the notification number of the cosmetic kit; c. The expiration date shall be provided based on the earliest expiration date among all the cosmetics in the kit. |
Notes: The newly added requirements are marked in green. | |
4. Clarifying the form and implementation of cosmetics promotion
Form | Implementation |
Cosmetic promotions may take the following forms: a. Sales aimed at increasing direct purchases. b. Direct selling, where products are offered directly to consumers through various communication media. c. Face-to-face selling (personal selling) involving direct interaction with consumers. d. Publications that include written information about products and/or manufacturing processes/technologies, disseminated via community media, mass media, electronic media, and other platforms in line with advancements in science and technology. | Cosmetic promotions can be implemented through: a. Activities or events such as seminars, meetings, public education sessions, press conferences, or similar gatherings. b. Competitions, contests, or related activities that engage the public, whether conducted directly or indirectly. c. Written or graphic media delivered directly to the public, such as letters. d. Direct communication with the public through various communication tools and technologies. e. New information technology platforms with advancements in science and technology. |
5. Adding supervision methods for cosmetic advertisements
Officers are authorized to have the following powers. The newly added methods are marked in green.
a. To examine and collect data, information, and documents, including images, photos, and videos, that are reasonably suspected to relate to labeling, promotion, and/or advertising, including duplication or quotation of such information;
b. To inspect facilities involved in labeling, promotion, and/or advertising;
c. To access identity data, names, and addresses of business actors engaged in labeling, promotion, and/or advertising;
d. To evaluate labeling, promotion, and/or advertising during circulation;
e. To take follow-up actions based on the results of monitoring labeling, promotion, and/or advertising.
ChemLinked Comments
The revisions of labeling, promotion, and advertising regulations clarify the requirements for refillable cosmetics and introduce new detailed criteria in these areas. The government has provided a one-year transition period for businesses that have already obtained a notification number to adapt to the changes. Companies must ensure that their labeling, promotions and advertising comply with the new regulations by November 28, 2025.
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