INDONESIA · COSMETICS

Indonesia Cosmetics Compliance: Ingredient, Labelling and Advertising Checks under BPOM 25/2025 and 18/2024

Before launching cosmetics in Indonesia, review the formula, label and promotion in one exercise. An ingredient being permitted does not mean every concentration, body area and claim is permitted, and an existing notification number does not exempt a product from later regulatory changes. Formulas should be reviewed under BPOM 25/2025, and labelling, promotion and advertising under BPOM 18/2024; both are shown as in force in the official regulation database. (Source: 25/2025 official record, 18/2024 official record)

This article offers a shared checking method for brands, manufacturers and design teams; it does not replace an ingredient-by-ingredient assessment of a specific formula.

Confirm versions first: which old rules have been replaced?

These replacements are listed in BPOM’s official regulation records. If you are still using an old checklist, update the cited versions first and then re-check each SKU — changing the year in the header is not enough.

The adjustment deadline for existing notified products has passed. BPOM required affected products to comply with 25/2025 by 3 October 2026 at the latest, so this date can no longer be treated as a future buffer. Where non-compliance is found, check the specific product, batches and regulatory handling requirements; do not conclude in general terms that all stock can stay on sale or must be destroyed. (Source: BPOM notice on adjustment of existing products)

A formula review is more than checking whether an ingredient is listed

Obtain the full quantitative formula from the factory and build an ingredient check table: INCI name, CAS identifier, concentration, function, product type, area of application, leave-on or rinse-off, and related warnings. Trace the composition of blended raw materials as well; trade names or the ingredient list on the pack are not a substitute.

25/2025 sets out prohibited and restricted ingredients and permitted colourants, preservatives and UV filters. A general ingredient not on the restricted list is not automatically prohibited; conversely, ingredient classes managed through positive lists cannot be cleared just because they are “not prohibited”. Safety, efficacy and quality evidence must still be in place. (Source: 25/2025, Articles 3–10 and annexes)

In practice, let R&D explain how an ingredient is used, regulatory review decide whether that use complies, and marketing then decide which benefits can be claimed — so that the three sets of documents do not contradict each other.

What must the pack show, and what must be in Bahasa Indonesia?

Article 3 of 18/2024 covers the product name, purpose, directions for use, ingredients, country of manufacture, name and full address of the notification holder, batch number, net content, expiry date, notification number, 2D barcode and warnings. Purpose, directions and warnings must be in Bahasa Indonesia; other required items may be in Bahasa Indonesia or a foreign language as the articles allow. The application of the 2D barcode must also be checked against the relevant specific rules. (Source: 18/2024, Articles 3–10)

Before artwork starts, give the designer an approved text that marks each mandatory item and its position on inner and outer packs. After proofs, check the actual type size, contrast, durability and legibility. Small packs may use specific arrangements, but designers must not drop mandatory information on their own; exceptions such as obvious purpose or use must be assessed against the articles.

What extra checks apply to sunscreens, AHA products and tooth whitening?

These three categories have dedicated labelling annexes in 18/2024, so a standard face-cream template is not enough.

• Sunscreens: check evidence for SPF and other claims, directions and sun-protection warnings.
• Skin care containing AHAs: consider concentration, pH and use to decide on warnings, target users and whether professional use applies.
• Tooth-whitening products containing or releasing hydrogen peroxide: check peroxide content, users, professional-use conditions and warning text.

Specific thresholds and mandatory warnings should be transferred from the official annexes into the product review record, not inferred from other brands’ labels. (Source: 18/2024, Article 12 and Annexes II–IV)

How should online listings, influencer content and advertising be reviewed together?

BPOM requires promotion to be truthful, verifiable and consistent with the notification, and not to suggest that a cosmetic is a drug or prevents disease. Appearances or endorsements by medical and health professionals, or the use of professional imagery, are also restricted. (Source: BPOM statement on labelling and advertising)

Give the marketing team a “claim — evidence — approved version” list, and review product titles, detail pages, video voice-overs, subtitles, influencer scripts and shared testimonials together. An approved pack does not mean that words such as “treat” or “cure” added by a channel are also acceptable.

Before working with partners, agree who reviews copy, who approves edits, who keeps final screenshots and how content is removed if a problem is found. These approval points are internal controls; they do not mean the regulator has approved each advertisement.

How can notified products be fully re-checked?

A practical sequence: list SKUs on sale and awaiting shipment; collect current formulas, packaging and advertising; mark differences and risks; have R&D confirm reformulation plans and the local responsible party assess the notification route; then update the DIP, labels and channel materials together. The DIP must be kept current, not left at the version first submitted. (Source: BPOM Batam: DIP Q&A)

Every issue should have an owner, supporting evidence, planned action and closure status. For organising the file, see How to Prepare an ASEAN Cosmetic PIF; for linking to batch imports, see Importing Cosmetics into Indonesia.