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Indonesia Revises Cosmetic Safety, Quality, and Efficacy Assessment Application Dossiers

Background

To ensure that products in circulation meet safety, quality, and efficacy standards, registration or notification to the BPOM must be completed before distribution. However, some products submitted for registration or notification contain new ingredients or are classified as new products. In such cases, an assessment must be conducted by the Directorate of Standardization of Traditional Medicines, Health Supplements, and Cosmetics (OTSKK).

 

This assessment supports the registration or notification process for products that either lack specific regulations or standards, or contain ingredients not yet listed in the ASROT and NOTIFKOS e-registration databases. It also applies to ingredients that are regulated or under consideration for regulation by the BPOM.

 

The safety and quality assessment of cosmetic ingredients determines their suitability for use in cosmetics. Other assessments in the field of cosmetics are conducted on cosmetic dosage forms permitted for manufacture by enterprises holding a class B production license, as well as on cosmetic products intended for sale at refill facilities.

On April 29, 2025, the Directorate of Standardization of OTSKK in Indonesia released a draft amended Regulation concerning Service Standards for the Directorate. 1 Subsequently, the finalized version was issued and came into effect on June 18, 2025. 2

Scope of the Service Standards

The Service Standards outlines services provided by the Directorate, including:

  • Assessment of the safety, quality, and efficacy of natural medicines, quasi medicines, health supplements, and cosmetics;

  • Consultation on norms, standards, procedures, and criteria in these sectors.

Key Changes for the Cosmetics Sector

The amendments affecting cosmetics companies include updates to general requirements, dossier submission criteria, and assessment timeframes for assessing the safety, quality, and efficacy of cosmetics. Revised sections are highlighted in red below.

1. General Requirements

a. Applications must be submitted directly by business operators intending to notify cosmetics;

b. Intermediaries are not permitted;

c. Applications must include a formal request letter for the assessment of cosmetics.

2. Required Dossiers

Assessment Types

Required Dossiers

Safety of cosmetic ingredients

Plant ingredients

Supporting data must include:

i. Ingredient manufacturer

a. Manufacturer name

b. Manufacturer address (including country)

 

ii. Ingredient information

a. Ingredient name (INCI name)

b. CAS No.

c. Dosage form

d. Intended use

e. Concentration used as rinse and/or non-rinse

f. Use frequency and method of products containing the ingredient

g. Target population

h. Other necessary documents

 

iii. Characterization of ingredients

a. Source of plant ingredients

b. Physical characteristics

c. Preparation method

d. Chemical characterization (if applicable)

e. Contamination

 

iv. Safety data

a. History of traditional use

b. Potential internal exposure routes (dermal, inhalation, oral) based on product use

c. Dermal absorption data

d. Acute toxicity studies (oral, dermal, inhalation)

e. Subchromic/chronic toxicity studies (oral, dermal, inhalation), including NOAEL values

f. Irritation studies (skin, ocular/mucous membranes)

g. Skin sensitization studies

h. Carcinogenicity studies

i. Mutagenicity and genotoxicity studies (in vitro, in vivo)

j. Reproductive toxicity studies; Reproductive and fertility toxicity; developmental toxicity/teratogenicity

k. Phototoxicity studies (required for ingredients used in products exposed to sunlight)

 

v. Efficacy data/research (only applicable for natural cosmetic ingredients in Indonesia, specifically as colorants, preservatives, or sunscreen agents for cosmetics manufactured in Indonesia)

 

vi. Other data

a. Regulatory status and usage data in various countries (minimum 4 countries)

b. Data on cosmetics containing the proposed ingredients, which have been distributed in other countries along with reports of side effects

 

vii. Results of Independent Material Safety Studies (made by the applicant)

Non-plant cosmetic ingredients

Supporting data must include:

i. Ingredient manufacturer

a. Manufacturer name

b. Manufacturer address (including country)

 

ii. Ingredient information

a. Ingredient name (INCI name)

b. CAS No.

c. Dosage form

d. Intended use

e. Concentration used as rinse and/or non-rinse

f. Use frequency and method of products containing the ingredient

g. Target population

h. Other necessary documents

 

iii. Characterization of ingredients

a. Chemical structure

b. Molecular weight

c. Purity and isomer composition (if the ingredient is a mixture of isomers)

d. Solubility

e. Partition coefficient (Log Pow)

f. Homogeneity

g. Stability

h. Organoleptic data

i. Melting point

j. Boiling point, relative density, pKa, density, viscosity (for liquid preparations (liquid, thick liquid, suspension) cream, lotion and gel)

k. Shape, melting point, pKa (For solid powder preparations)

l. Density (For solid powder preparations, aerosol)

m. UV light absorption spectrum (For UV filter or UV absorbent)

n. For cosmetic ingredient in the form of nanomaterials, in addition to the requirements above, must be accompanied by particle size distribution data and material absorption data

 

iv. Safety data

a. History of traditional use

b. Potential internal exposure routes (dermal, inhalation, oral) based on product use

c. Dermal absorption data

d. Acute toxicity studies (oral, dermal, inhalation)

e. Subchromic/chronic toxicity studies (oral, dermal, inhalation), including NOAEL values

f. Irritation studies (skin, ocular/mucous membranes)

g. Skin sensitization studies

h. Carcinogenicity studies

i. Mutagenicity and genotoxicity studies (in vitro, in vivo)

j. Reproductive toxicity studies; Reproductive and fertility toxicity; developmental toxicity/teratogenicity

k. Phototoxicity studies (required for ingredients used in products exposed to sunlight)

 

v. Efficacy data/research (only applicable for natural cosmetic ingredients in Indonesia, specifically as colorants, preservatives, or sunscreen agents for cosmetics manufactured in Indonesia)

 

vi. Other data

a. Regulatory status and usage data in various countries (minimum 4 countries)

b. Data on cosmetics containing the proposed ingredients, which have been distributed in other countries along with reports of side effects

 

vii. Results of Independent Material Safety Studies (made by the applicant)

Forms and types of preparations that can be produced by the class B cosmetic production enterprise

The required dossiers remain unchanged.

i. Cosmetic formula;

ii. Manufacturing method;

iii. Dosage form;

iv. Product usage;

v. BPOM-approved production facilities;

vi. Product photos (if available);

vii. Other necessary dossiers.

Cosmetic sales at cosmetic refill facilities

The required dossiers remain unchanged.

i. Proposal for the application to sell cosmetics at cosmetic refill facilities in accordance with applicable regulations;

ii. Notification number of the cosmetics to be refilled;

iii. Cosmetic refill facilities to be used;

iv. Cooperation agreement document for the sale of cosmetics at refill facilities, if the sales are conducted by a business entity other than the holder of the notification number.

3. Introduction of a Fast-Track Assessment Process

In addition to the regular application, the regulation introduces a fast-track assessment. Fast-track assessment is available for cosmetic ingredients that meet the following criteria:

i. Plant-based cosmetic ingredients:

  • The simplicia or all mixed simplicia are already listed in the NOTIFKOS database;

  • There is empirical evidence of safe use on the skin, aligned with the intended method of application;

  • Have skin and eye irritation test data, as well as skin sensitization test data;

  • The ingredient is listed in the NOTIFKOS database but the INCI name has changed;

  • The ingredient is already regulated as a cosmetic ingredient in other countries.

ii. Non-plant cosmetic ingredients:

  • A safety assessment report is available from recognized scientific bodies, such as the EU Scientific Committee on Consumer Safety (SCCS) or the US Cosmetic Ingredient Review (CIR);

  • The ingredient is listed in the NOTIFKOS database but the INCI name has changed.

The steps for regular and fast-track assessments are similar, but the processing timeframes differ.

1) Steps

a. Applicants submit their assessment request via http://standar-otskk.pom.go.id

b. The Directorate checks for document completeness. If incomplete, applicants are asked to revise.

c. If complete, the assessment is conducted and the result issued.

d. Applicants receive an official assessment response letter.

e. Applicants are invited to complete a customer satisfaction survey.

2) Timelines:

Regular assessment: up to 85 working days

Fast-track assessment: up to 10 working days

Further Reading

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