NADFC (BPOM) Regulations of Cosmetics in Indonesia
- Induja Ratakonda
- Sep 28, 2024
- 6 min read
The cosmetic industry in Indonesia is one of the fastest-growing sectors, driven by a large population, rising income levels, and increasing interest in beauty and personal care products. The country’s young demographic and the growing influence of social media also contribute to the market’s expansion. As of 2023, Indonesia's cosmetic industry was valued at over USD 7 billion, with steady annual growth rates of approximately 5-7%. The market is expected to grow significantly in the coming years due to increasing consumer demand. In this blog, we explore on the key regulations to bring cosmetic products into Indonesian market.
Agencies overseeing Regulation of Cosmetics in Indonesia
Cosmetic regulations in Indonesia are governed by the National Agency of Drug and Food Control (NADFC), also known as BPOM. The regulatory framework ensures the safety, quality, and labeling compliance of cosmetic products before they are allowed to enter the market.
Key Regulations for cosmetics under NADFC / BPOM
Mandatory Registration: All cosmetic products must be registered with BPOM before being marketed in Indonesia. This includes both locally produced and imported products.
ASEAN Harmonization: Indonesia follows the ASEAN Cosmetic Directive (ACD), The ASEAN Cosmetic Directive (ACD) is a harmonized regulatory framework established by the Association of Southeast Asian Nations (ASEAN) to ensure the safety, quality, and efficacy of cosmetic products across member states. It was adopted in 2003 and implemented in 2008 with the goal of eliminating technical barriers to trade and ensuring consumer safety.
Key elements of the ASEAN Cosmetic Directive:
The ACD applies to all cosmetic products marketed in ASEAN member states, including Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand, and Vietnam.
It defines cosmetics as "substances or mixtures intended for contact with external parts of the body, teeth, or mucous membranes for the purpose of cleaning, perfuming, changing appearance, correcting body odors, protecting, or keeping them in good condition."
NADFC / BPOM Classification of Cosmetics in Indonesia
In Indonesia, BPOM / NADFC classifies cosmetic products based on their intended use, function, and risk level. This classification helps determine the regulatory requirements for registration, safety, and labeling. The classification system follows general principles but can also align with the ASEAN Cosmetic Directive (ACD).
Here’s an overview of BPOM’s cosmetic product classification:
Skin Care Products: These products are designed to protect, enhance, or maintain the health and appearance of the skin.
Examples: Moisturizers, Sunscreens
Hair Care Products: Hair care cosmetics focus on cleansing, protecting, or styling hair.
Examples: Shampoos and conditioners, Hair oils and serums
Oral Care Products: These are products used for the hygiene and cosmetic maintenance of the teeth and mouth.
Examples: Toothpaste, Mouthwash (non-medicinal)
Makeup and Decorative Cosmetics : Products designed to enhance appearance, often used for beautification.
Examples: Foundations, Lipsticks, lip balms, and lip glosses
Fragrances: Products used to add a pleasant scent to the body or environment.
Examples: Perfumes and colognes, Body sprays and mists
Personal Hygiene Products: Products designed for general body hygiene and cleanliness.
Examples: Body washes and soaps, Hand sanitizers (non-medicated)
Children’s Cosmetics: Cosmetic products designed specifically for infants and children, which require additional safety measures.
Examples: Baby lotions and creams, Baby shampoos and washes
Men’s Grooming Products: Specific cosmetic products tailored to men's grooming needs.
Examples: Shaving creams and gels, Aftershaves
Cosmetic Devices: Some tools or devices can be classified as cosmetics if their primary function is non-medical or for cosmetic purposes.
Examples: Mechanical exfoliators, Facial brushes (non-electrical)
Cosmeceuticals: While not an official category, BPOM monitors products that have both cosmetic and therapeutic effects. Products like these may have active ingredients that provide additional skin benefits (e.g., anti-aging, acne control) but should not make medicinal claims.
NADFC / BPOM Classification of Cosmetics in Indonesia based on Risk Level:
NADFC/ BPOM also classifies cosmetic products based on their risk level, which influences the extent of regulatory scrutiny:
Low-Risk Cosmetics: Products intended for everyday use with minimal risk to the user. These products undergo a relatively simpler registration process with BPOM.
Examples: Lotions, Shampoos, Lip balms
High-Risk Cosmetics: Products that involve higher potential safety risks or require stricter regulation due to their active ingredients or specific functions. These products may require additional documentation and testing, including safety assessments and more comprehensive registration with BPOM.
Examples: Hair dyes, Whitening/brightening products, Sunscreens (with UV filters)
NADFC / BPOM Classification of Cosmetics in Indonesia based on Function
BPOM further classifies products based on their specific function, such as:
Cleansing Products: Soaps, body washes, and cleansers.
Protective Products: Sunscreens, anti-pollution products.
Conditioning Products: Moisturizers, creams, and serums.
Color Cosmetics: Lipsticks, foundations, and eye makeup.
Fragrance Products: Perfumes and deodorants.
NADFC / BPOM Labeling Requirements for Cosmetics in Indonesia
In Indonesia, the NADFC / BPOM have established specific labeling requirements for cosmetics to ensure consumer safety and transparency. All product labels must be presented in Bahasa Indonesia. Importantly, cosmetic products cannot make any medical or therapeutic claims, such as curing diseases, to comply with regulatory standards. The Cosmetic Product labels include essential mandatory information -
Product name and function.
Full list of ingredients (in descending order of concentration).
Manufacturer’s name and address.
Importer’s name and address (for imported products).
Batch number and expiration date.
BPOM registration number.
NADFC / BPOM Good Manufacturing Practices (GMP) for Cosmetics in Indonesia
GMP compliance is mandatory for both local and foreign manufacturers. NADFC / BPOM or relevant authorities inspect facilities to ensure proper hygiene, quality control, and production processes. The manufacturing facility must follow the ASEAN GMP guidelines for cosmetics, ensuring consistent product quality.
Product Notification of Cosmetics in Indonesia with NADFC / BPOM
The Cosmetic product registration in Indonesia is a notification process rather than a pre-market approval, meaning products can be marketed once BPOM acknowledges the notification.
E-Registration System: All cosmetic products must be registered with BPOM through an online e-registration system.
Required Documentation for Cosmetic Product Notification in Indonesia:
Detailed product information (ingredients, intended use, product formulation).
Manufacturer’s details (address, GMP certification).
Labeling information (including claims, expiration date, batch number).
Safety data, including any adverse effects reported for the product.
NADFC / BPOM Review: NADFC/BPOM reviews the documentation to ensure the product complies with the ASEAN Cosmetic Directive (ACD) and local standards.
NADFC / BPOM Requirements for Importation of Cosmetics into Indonesia
Foreign cosmetic companies must appoint a local distributor or representative in Indonesia to handle BPOM registration. The local distributor or importer must have a valid import license, and the product must follow all local regulatory pathways, including safety and labeling requirements.
Validity and Re-Notification of Cosmetic Product Notification in Indonesia
Cosmetic products registration is valid for period of 5 years. Cosmetic products must be re-registered after every 5 years to ensure they continue to meet regulatory requirements.
NADFC / BPOM Fees for Notification of Cosmetics in Indonesia
Typically, the fee for local cosmetic product registration ranges from IDR 500,000 to IDR 1,500,000 per product.
For imported cosmetic products, the registration fee usually ranges from IDR 2,000,000 to IDR 3,000,000 per product.
Halal Certification of Cosmetics in Indonesia
Although not mandatory, many cosmetic products in Indonesia seek Halal certification due to the significant demand from Muslim consumers. This certification is regulated by the Indonesian Halal Product Assurance Agency (BPJPH) in collaboration with BPOM.
NADFC / BPOM Post-Market Surveillance Requirements for Cosmetics in Indonesia
BPOM Monitoring: Once the product is on the market, BPOM conducts post-market surveillance to ensure ongoing compliance. This includes:
Random sampling and testing of products.
Monitoring advertising and labeling claims.
Tracking consumer complaints and adverse reactions.
Adverse Event Reporting: Companies must report any adverse events or product safety issues to BPOM. This reporting is crucial for ensuring that the products remain safe for public use.
Penalties for Non-Compliance: Products that do not meet BPOM standards can be recalled, and manufacturers or distributors may face penalties, fines, or legal action.
NADFC / BPOM Product Recall of Cosmetics in Indonesia
If a cosmetic product is found to be non-compliant or unsafe, BPOM may issue a recall notice. This can happen due to issues such as banned ingredients, safety concerns, or false claims.
Summary of the NADFC / BPOM Regulation of Cosmetics in Indonesia
Classify the product and ensure compliance with ingredient restrictions.
Ensure GMP compliance for manufacturing.
Prepare a Product Information File (PIF) with all necessary safety and quality data.
Submit a product notification through BPOM’s e-registration system.
Comply with labeling requirements, ensuring the label contains all necessary information in Bahasa Indonesia and the BPOM registration number.
For imported products, appoint a local distributor or importer and follow the local registration process.
Post-market surveillance and reporting of adverse events are mandatory to ensure continued product safety.
Halal certification (optional) may be sought for products targeting Muslim consumers.
BPOM’s cosmetic regulations in Indonesia ensure that all cosmetic products marketed in the country meet strict safety, labeling, and quality standards. Navigating the Indonesian cosmetic market requires a strategic approach due to its unique consumer preferences, regulatory landscape, and rapidly growing beauty industry.
By focusing on consumer trends, complying with BPOM regulations, and strategically utilizing e-commerce and distribution channels, brands can successfully navigate and thrive in Indonesia’s dynamic cosmetic market. To get assistance with regulatory needs to penetrate through the Indonesian cosmetics market, contact info@artixio.com.
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