Introduction
Entering overseas cosmetic products into Indonesia requires compliance with a structured regulatory framework, which includes product notification, GMP compliance, ingredient standards, labeling, claims, advertising, PIF documentation, and post-market supervision of cosmetics.
To successfully complete these processes, overseas companies must also ensure their products comply with product requirements and remain attentive to evolving regulations. Notably, beginning October 17, 2026, Halal Certification will become an additional mandatory requirement for imported cosmetics marketed in Indonesia.
What is the ASEAN Cosmetic Directive (ACD)?
The ASEAN Cosmetic Directive (ACD) is a key component of the ASEAN Harmonised Cosmetic Regulatory Scheme (AHCRS). It was introduced to establish uniform safety and quality standards for cosmetics across ASEAN member states, including Indonesia, Malaysia, Thailand, Vietnam, Myanmar, Cambodia, Laos, Singapore, the Philippines, Brunei, and Timor-Leste.
Since its implementation in 2008, the ACD allows cosmetic products approved in one ASEAN country to be marketed in other member states. However, businesses must meet the local notification requirements of each country, including Indonesia, to ensure compliance with individual regulations.
Key Regulations on Cosmetic Notification in Indonesia
| Document Title | Implementation Date |
| Regulation Concerning Cosmetic Notification | 2011-01-01 |
| Procedure for Submission of Cosmetics Notification | 2022-10-05 |
BPOM: Indonesia's Competent Authority
In Indonesia, cosmetic products are regulated by the BPOM (BADAN POM, Badan Pengawas Obat dan Makanan), the National Agency of Drug and Food Control. BPOM ensures that cosmetic products meet the safety, quality, and efficacy standards required for sale in Indonesia. It is the agency to grant cosmetic production licenses and cosmetic notification before market entry.
Here are the steps to notify cosmetics in Indonesia:
Step 1: Determine the Product Notification Holder
This can be achieved by either:
Establishing a local subsidiary in Indonesia, or
Appointing a third-party representative (e.g., REACH24H), who will be legally responsible for product compliance, safety, and post-market surveillance throughout the lifecycle of the product.
Step 2: Document Preparation and Compliance Check
Before submitting a notification, products must comply with BPOM regulatory standards, including:
Completion and readiness of the Product Information File (PIF) according to ASEAN and BPOM Guidelines,
Compliance of formula,
Compliance of labeling, including claims, artwork, and mandatory information.
Step 3: Start Notifkos Account Registration
The company must register an account in the Notifkos System by submitting essential documents, including:
Certificate of Free Sale (CFS) (legalized and notarized, required for non-ASEAN imported products),
Good Manufacturing Practice (GMP) certificate (legalized and notarized),
Letter of Authorization (LoA),
Contract Manufacturing Agreement, and
Other required administrative documents.
Step 4: Submit Cosmetic Product Notification & Payment
Once the company account is approved, product notification can be submitted online:
Fees
IDR 1,500,000 for non-ASEAN products
IDR 500,000 for ASEAN-manufactured products
Validity:
The issued notification number is valid for 3 years and is renewable.
Upon approval, BPOM will issue a Notification Number, authorizing the product to be marketed in Indonesia.
What Documents Are Required for the Indonesia Cosmetic Notification?
Key documents typically include:
Legalized and notarized Certificate of Free Sale (CFS)
Legalized and notarized Good Manufacturing Practice (GMP) certificate
Letter of Authorization (LoA) appointing the Product Notification Holder
Contract Manufacturing Agreement (if applicable)
Full ingredient list
Packaging information and labeling design
Certificate of Analysis
Complete Product Information File (PIF) according to ASEAN Guidelines and BPOM requirements.
Any additional documents requested by BPOM, depending on product type and classification.
Important Notes for Indonesia BPOM Cosmetic Notification
Language Requirement: Product functions, usage instructions, and warnings/precautions must be written in Indonesian on the product label.
Certification: Both the Certificate of Free Sale (CFS) and Good Manufacturing Practices (GMP) certificates need to be notarized and certified before being accepted in Indonesia.
To know your ingredient regulatory status, try our COSMETIC INGREDIENT SEARCH TOOL for a comprehensive search.
Product Information File (PIF) Requirements in Indonesia
It is regulated in Indonesia that the Product Information File (PIF) must be available before the notification process is started
How REACH24H Can Help with Indonesia Cosmetic Notification
At REACH24H, we offer expert regulatory support to navigate Indonesia’s BPOM cosmetic registration process, ensuring compliance and minimizing risks. Our services include:
Product License Holder Service
Facility Building Inspection (PSB) Assistance
Company Registration at Notifkos System Service
Ingredient and Labeling Compliance Review Service
Cosmetic Notification Submission Service
Product Information Files (PIF) Maintenance Service
Import Process Assistance Service
Cosmetics Notification Maintenance Service
Halal Certification for Cosmetics Product Service
Why Choose REACH24H for Your Cosmetic Regulatory Needs
With years of experience assisting over 1,000 global cosmetic companies, REACH24H provides effective regulatory solutions tailored to Indonesia’s cosmetic market. Our team ensures your products meet BPOM’s requirements and are ready for market entry without unnecessary delays. For more information, contact us at customer@reach24h.com.
FAQ
Q: Do I need to have a local Indonesian company to register cosmetics?
No. If you appoint REACH24H as your Product Holder, you do not need to establish a company in Indonesia. REACH24H will act as the responsible party for your product notification
Q: How long does the Product Notification process take?
If you appoint REACH24H as your Product Holder, the process typically takes 3–4 months, depending on the number of manufacturers involved and the total number of SKUs.
Q: What are the requirements for the Technical Responsible Person?
According to the Ministry of Health Regulation No. 11 of 2025 on Business Activity Standards and Product/Service Standards for Risk-Based Licensing in the Health Subsector, distributors of cosmetics under KBLI 46443 are required to appoint a licensed pharmacist.
However, if you appoint REACH24H as your Product Holder, you do not need to source a Technical Responsible Person yourself, as this role is already included in our service.
Q: What if the cosmetic ingredients used are not yet listed in the Indonesian notification system?
Ingredients not registered in the system must undergo evaluation through a scientific assessment by the Directorate of Traditional Medicine, Health Supplement, and Cosmetic Standardization. Approval must be obtained before the ingredient can be used in a cosmetic product.
Q: What happens if, during the labeling compliance review, there are elements that are not permitted in Indonesia?
During notification or post-market inspection, BPOM may require non-compliant claims to be removed, covered, or modified to match allowed terminology in Indonesia. This may include physically covering certain claims on the packaging.
Q: Can in vitro SPF and PA (UVB & UVA) test results be used to support sunscreen claims in Indonesia?
A: No. According to Indonesia’s National Agency of Drug and Food Control (BPOM RI), in vivo testing data is required to substantiate any SPF value or claim on sunscreen products. This requirement was officially clarified in BPOM Document No. HM.01.1.2.08.23.33, dated September 4, 2023. In vitro test results alone are not sufficient to support SPF or PA claims.
Q: Is Annex V of BPOM’s cosmetic regulation different from the prohibited list in the ASEAN Cosmetic Directive (ACD) annexes?
A: Annex V of BPOM’s cosmetic regulation lists the prohibited ingredients for cosmetic products and generally follows the ACD framework. However, in practice, the ACD prohibited list is usually more up-to-date than the version published in BPOM regulations. BPOM is in the process of updating its annexes to align more closely with the latest ACD requirements.
