Cosmetic

Indonesia Releases Updated Technical Requirements for Cosmetic Ingredients Under BPOM Regulation No. 25/2025

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News Brief

The Indonesian National Agency for Drug and Food Control (BPOM) has officially issued a new regulation concerning cosmetic ingredient technical requirements: BPOM Regulation No. 25 of 2025 on Technical Requirements for Cosmetic Ingredients, enacted on 3 October 2025. The regulation was further socialized through a hybrid dissemination format on 7 November 2025.

This regulatory update aligns Indonesia’s requirements with recent amendments to the ASEAN Cosmetic Directive (ACD) Annexes. It also reflects ongoing developments in the cosmetic sector and incorporates feedback from stakeholders.

Revoked Regulations

With the issuance of this new regulation, several previous regulatory provisions and annexes are no longer valid:

  • BPOM Regulation No. 23 of 2019

The main body of this regulation, which had still been partially referenced, is now fully invalid.

  • BPOM Regulation No. 17 of 2022

Previously, Annex V (Prohibited Ingredients) remained in effect. Under the new regulation, this annex has been revoked.

  • BPOM Decree No. 479 of 2023

This decree, which previously regulated Annexes I–IV, has now been entirely replaced by BPOM Regulation No. 25 of 2025

Highlights of the Amendments

Amendments to the main body of the regulation are primarily editorial revisions and clarification edits. However, several substantive updates have been introduced under Article 5, Article 10, Article 12, and Article 13, paragraph (1) point g. For changes affecting technical implementation, detailed modifications have been outlined across the respective annexes. Below is a summary of the key updates found in each annex:

Annex I – List of Ingredients Permitted for Use in Cosmetics with Restrictions and Conditions of Use

Updates include:

  • Revised limits for Zinc Pyrithion, CAS No. 13463-41-7.

  • New requirements for Etidronic acid and its salts, CAS No. 2809-21-4.

  • Updated exception for Hydrogen Peroxide, CAS No. 7722-84-1.

  • Addition of newly restricted substances: Acid Yellow 3 (CI 47005) Cas No. 8004-92-0, and Butylated Hydroxytoluene, CAS No. 128-37-0.

Annex II – List of Colorants Permitted for Use in Cosmetics

Removal of additional conditions for CI 45430, aligned with the latest ACD updates.

Annex III – List of Preservatives Permitted for Use in Cosmetics

Updates include:

  • Chlorophene (2-benzyl-4-chlorophenol) is removed and transferred to Annex V (Prohibited Ingredients).

  • Modification of the name Sodium N-(hydroxymethyl) glycinate, CAS No. 70161-44-3 in accordance with the latest ACD Annex.

Annex IV – List of UV Filters Permitted for Use in Cosmetics

Notable updates include:

  • Updates to ingredient CAS Numbers:

  1. 3,3’-(1,4-Phenylene) bis (5,6-diphenyl-1,2,4-triazine) → corrected so that the CAS No. is now listed as 55514-22-2.

  2. Titanium dioxide (nano) → addition of a CAS No., which was not specified in the previous regulation.

  • Addition of two new UV filters (including nano forms): Bis-(Diethylaminohydroxybenzoyl Benzoyl) Piperazine, and Bis-(Diethylaminohydroxybenzoyl Benzoyl) Piperazine (nano).

  • Editorial improvements to Zinc Oxide (nano), including new definitions D50 and D1.

  • Homosalate is now restricted to facial products only, excluding propellant spray formats.

  • Addition of the alternative name Avobenzene for 1-(4-Tert-butylphenyl)-3-(4- methoxy phenyl) propane-1,3-dione CAS No. 70356-09-1.

  • The use of Benzophenone-3 is now restricted in concentration depending on the type of cosmetic formulation.

Annex V - List of Ingredients Prohibited from Use in Cosmetics

A total of 101 newly prohibited ingredients have been added. Among them, these ingredients had previously been notified in Indonesia, including:

  • cis-CTAC (Quaternium-15)

  • 2-Chloroacetamide

  • Octamethylcyclotetrasiloxane (D4)

  • Acetaldehyde

  • N-Methyl-2-pyrrolidone

  • Cyclohexylamine

  • Quinoline

The other ingredients not listed are known to have carcinogenic, mutagenic, and reproductive toxicity effects, and these substances are not present in cosmetics currently notified in Indonesia. 

Transition Period and Compliance Implications

A 12-month transition period has been granted for the implementation of this regulation, ending on October 3, 2026. During this period, companies with existing notified products are required to ensure compliance with the updated provisions. If a product contains any ingredient newly listed under Annex V (Prohibited Ingredients), the notification will not be eligible for renewal, and the product will subsequently no longer be permitted for sale in Indonesia. 

For new product notifications, companies are strongly encouraged to thoroughly review all amended annexes and updated technical requirements to ensure full regulatory compliance from the outset. Staying proactive will help prevent future complications in the notification process.

For more information and inquiries, please feel free to contact us at customer@reach24h.com.


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