Indonesia Proposes to Amend Cosmetic Labeling Requirements

On November 9, 2023, Indonesia issued an amended draft of Technical Requirements for Cosmetic Labeling for public consultation. This amended draft newly specifies the mandatory labeling items for refillable cosmetics, extends the scope of labeling requirements to cover refillable cosmetics, and details additional requirements to enhance the overall labeling standards.

Term:

Refillable cosmetics: It refer to cosmetics that are repackaged into containers according to consumer's request, which is done at cosmetic refill facilities.

On November 9, 2023, Indonesia released the amended draft of Technical Requirements for Cosmetic Labeling for public consultation. ¹ This Regulation provides clarification on the necessary labeling items and requirements for cosmetics. Additionally, it includes administrative sanctions possibly imposed on companies in violation of the Regulation.

Main Amendments

Compared with the current Regulation, the draft

1. Newly specifies 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: The draft does not modify the information required for labeling of non-refillable cosmetics; The newly added requirements are marked in red.

2. Extending the scope of the labeling requirements to cover refillable cosmetics

a. Completeness: The labeling should include all necessary information.

b. Objectivity: Information provided 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. Non-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 that have obtained halal certificates are allowed to label the halal logo;
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 using a distinctive mark, batch number, or any other distinguishing feature accompanied by an explanation;
Labeling requirements for cosmetic kit are added.

Packaging	Labeling Requirements
Cosmetic kit with primary packaging only	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	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 red.

Indonesia Proposes to Amend Cosmetic Labeling Requirements

Main Amendments

Further Reading