INDONESIA · COSMETICS

Importing Cosmetics into Indonesia: BPOM Notification Holders, Authorised Importers and SKI

After obtaining a BPOM notification number, the applicable import formalities still have to be completed. For commercial imports of finished cosmetics, first confirm the notification holder and the actual importer, then prepare the SKI Border and supporting documents for each shipment. An authorised importer can take part, but authorisation does not automatically grant every import qualification, nor does it let any distributor use the notification number freely. (Source: BPOM 28/2023, Article I amending Article 1)

This article is for overseas brands and manufacturers importing finished products; raw materials, bulk products and non-commercial samples need separate assessment.

Separate four roles: who supplies documents, who imports, who sells

Before signing a distribution agreement, put the actual division of work on a one-page responsibility table.

One company can hold several roles, but each should be confirmed. Exclusive sales rights, brand ownership and notification-holder status are different questions. The contract should also cover handover of documents when the relationship ends, not just the sales territory.

How should BPOM notification be arranged for the same product?

BPOM’s official FAQ distinguishes the “same brand” from the “same product name”: the same brand may be notified by different companies under an authorisation that clearly allocates product names, but a product name already notified cannot simply be notified again by another company. A notification number is valid for three years and should be maintained according to its actual status. (Source: BPOM cosmetic notification FAQ)

Brands should therefore keep a mapping table: brand, full product name, size, manufacturer, holder, notification number and expiry date. Before changing local partner, review the existing notifications and authorisations, then decide on the route — do not assume in the contract that “the certificate can be transferred to the next partner at any time”.

Can the notification holder and the importer be different companies?

An arrangement involving an authorised importer is possible. After the 28/2023 amendment, importers authorised by the holder fall within the scope of SKI Border applicants. This concerns the right to apply for import; it does not remove the notification or the actual business requirements. (Source: BPOM 28/2023, Article I amending Article 1(7))

Before going ahead, check three things: is the grantor entitled to authorise; does the authorisation cover the products to be imported; and does the applicant’s entity, account and business activity meet current requirements? Business standards should be checked against the current BPOM 27/2025 and its annexes, not the superseded 10/2021 list. (Source: BPOM 27/2025 official record)

A distributor that buys only from a compliant local supply chain is in a different position from one importing directly from overseas. When adding a channel, first ask “who imports the goods?”, then decide what is needed.

With a notification number, what is still needed for each shipment?

BPOM’s SKI guidance for finished products lists notification data, a certificate of analysis (CoA) and invoice requirements; raw materials and bulk products have different items. The table below is a pre-shipment cross-check, not a full case-specific list. (Source: BPOM cosmetic SKI guidance)

Check documents first, then confirm shipping. Small differences in names, a CoA that does not match the batch, or insufficient remaining validity on arrival should be resolved before dispatch. SKI Border must be satisfied before goods are released from the customs area, so “already shipped” does not mean the process is complete. (Source: BPOM 28/2023, Article I amending Article 1(3))

Who maintains the DIP, product changes and later batches?

Indonesia’s product information file is called the DIP. It covers administrative and product summary data, ingredient quality, finished-product quality, and safety and efficacy data. The notification holder must be able to provide it, and the manufacturer should have a process for ongoing updates and confidential delivery. (Source: BPOM Batam: DIP Q&A)

Projects can agree that any change to formula, factory, label or claims is notified to the local responsible party first, which then checks whether it affects the notification, the DIP or labels for later batches. Keep records of batch distribution, complaints and recall cooperation. For organising the file, see How to Prepare an ASEAN Cosmetic PIF.