INDONESIA · COSMETICS
Indonesia Cosmetics Halal Requirements: Timelines, Foreign Certificates and Market Entry
The phased halal implementation deadline for cosmetics in Indonesia has been formally moved to 17 October 2028. The basis is PP 40/2026, which amends Article 161 of PP 42/2024 — it is no longer only a policy announcement. The amendment was enacted on 14 October 2026. Companies still need to determine which products are in scope and then arrange certification or foreign-certificate registration; the extension does not mean halal obligations have been removed. (Source: PP 40/2026 official text, pp. 3–5)
This article is for brands and manufacturers planning to sell cosmetics in Indonesia. Halal arrangements are separate from BPOM cosmetic notification and the applicable import formalities.
How do the current rules differ from the old timeline?
| Instrument | Nature and date | What it means for cosmetics projects |
|---|---|---|
| PP 42/2024, original Article 161(1)(d) | 2024 government regulation | Original phase-in until 17 October 2026; must be read with the later amendment |
| PP 40/2026, Article I | Enacted 14 October 2026 | Moves the phase-in for cosmetics and other categories to 17 October 2028 |
| PP 40/2026, Article II | Accompanying provision in the same amendment | Revokes provisions on conformity assurance for foreign halal products; does not remove registration of foreign halal certificates |
Sources: PP 42/2024 original text, PP 40/2026 official record and full text. The official record also lists PP 40/2026 as revoking BPJPH Regulation 4/2026, so the foreign conformity procedure described in earlier materials should no longer be applied as is.
Brands should record which version of the rules they rely on in the project checklist. Where old news or training materials differ from the current official text, re-check against the later amendment rather than combining requirements from different years into one list.
How do BPOM notification, halal and import formalities divide the work?
Split launch preparation into three parallel workstreams:
- BPOM notification: cosmetic notification and related product compliance.
- Halal certification / registration: applicable halal requirements, certificate route and logo.
- Import formalities: the actual importer, SKI and batch documents.
Completing one does not mean the others are done. (Source: BPOM notification FAQ, BPOM import control amendment, PP 42/2024, Articles 145–154)
Also distinguish “not yet halal certified” from “made with non-halal ingredients”. Article 2 of PP 42/2024 exempts products derived from prohibited materials from halal certification but requires them to be labelled as non-halal. This does not let any uncertified product avoid its obligations by adding a “non-halal” label. Categories and exemptions must be assessed product by product, and “natural” or “plant-based” formulas are not a basis for conclusions.
We already have a foreign halal certificate — can it be used directly in Indonesia?
First check whether the issuing body has a mutual recognition arrangement with BPJPH, and whether its recognised scope covers the products. A foreign certificate meeting the recognition conditions can follow the registration route without repeating the same halal certification, but it must still be registered in Indonesia. Where no applicable arrangement exists or the products fall outside the body’s scope, assess an application for certification through a local importer or official representative. (Source: PP 42/2024, Articles 146–148)
The current registration procedure is set out in BPJPH Decree 221/2025, with applications made by the Indonesian importer and/or official representative through SIHALAL. Review the certificate, manufacturing site, product list and actual sales names together — not just whether “the factory has a halal certificate”. (Source: BPJPH 221/2025 and annexes)
What product and supply-chain information should manufacturers gather first?
Start with two sets of documents.
Product and manufacturing core: full formula, ingredient sources and supplier details, manufacturing sites, production process, shared production lines, product names and specifications. This is a gap-analysis checklist, not a statutory application list common to all routes.
Foreign certificate registration: existing certificates and validity, issuing body, product scope, local applicant and NIB, authorisation documents, products to be imported and HS codes, warehouse details and a statement of document authenticity. Confirm the exact materials for the applicable procedure. (Source: BPJPH 221/2025, Annex I, Chapter II)
Use one table recording “document owner, current version, products covered, gaps, next step” to align R&D, purchasing, the factory and the Indonesian partner. Resolve unclear ingredient sources or certificates that do not cover the products before finalising packaging.
How should the halal logo on packaging and the local responsible party be arranged?
Packaging design should follow the confirmed certification or registration route. PP 42/2024 requires the importer or official representative that registered a foreign certificate to show the registration number near the halal logo, and the registration validity follows that of the foreign certificate. Build certificate renewals and label versions into the maintenance plan. (Source: PP 42/2024, Articles 152–154)
The halal labelling provisions in BPOM 18/2024 should not be read on their own as meaning “halal is always voluntary”. Packaging must meet both the halal rules and the cosmetic labelling rules that apply. (Source: 18/2024, Article 5)
Check the basis for the logo, the number and product coverage before signing off print artwork. For Indonesian-language information and other packaging checks, see Indonesia Cosmetics Compliance: Ingredient, Labelling and Advertising Checks.
How should halal requirements fit into the launch timeline?
Confirm the product category and applicable route, then check recognition, complete documents, handle certification or registration, review packaging, and finally connect import and channel delivery. The extension gives more preparation time, but do not wait until the deadline approaches to ask the factory for ingredient and production records.
Frequently asked questions
Is the cosmetics deadline 2026 or 2028?
The formal PP 40/2026 amendment moves the end of the relevant phase-in to 17 October 2028; the original 2026 date should not be used without reference to the amendment.
If a foreign certificate is recognised, is local registration unnecessary?
No. The applicable foreign certificate registration must still be checked and completed. Recognition of the body and registration of a specific certificate are two different levels.
Does revoking the foreign conformity procedure also remove BPOM notification or SKI?
No. BPOM notification and import formalities follow their own rules — see Importing Cosmetics into Indonesia.
Official References
- PP 40/2026: amended timeline and revocation provisions
- PP 42/2024: halal assurance framework and foreign certificate registration
- BPJPH 221/2025: foreign certificate registration procedure
Classification, certification eligibility and documents for individual products still require separate review.
