Regulatory & Licensing Advisory

Cosmetic Registration Indonesia

In Indonesia, cosmetics reach the market through BPOM notification. MDM helps international brands and importers prepare the local notification holder, the principal’s documents and the product file before submission.

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Who needs this service?

This service supports overseas cosmetic brands and manufacturers, Indonesian importers adding a cosmetic range, and companies that have their products made abroad under contract. Bring the product list, the country of manufacture and the company you expect to act as importer to the first review.

“Cosmetic registration” is the common commercial term. The BPOM procedure for cosmetics is a notification, and it is a different route from food or health-supplement registration. If a product makes therapeutic claims or sits between categories, check its classification first using the BPOM product pathways.

Who holds the notification

BPOM Regulation No. 21 of 2022 on cosmetic notification procedures limits applicants to an Indonesian cosmetic manufacturer, a business that contracts production with an Indonesian manufacturer, or an importer operating in the cosmetics sector. Every applicant needs an Indonesian business identification number (NIB). Imported cosmetics are notified by the importer. A business that contracts a manufacturer outside Indonesia is treated as an importer. Read the regulation (PDF, Indonesian).

For imported products, the regulation lists these importer documents:

  • A stamped statement from the directors confirming they are not involved in criminal offences in the cosmetics sector.
  • A recommendation as a notification applicant, issued through the local BPOM technical unit (UPT).
  • An agency appointment from the brand owner or manufacturer with at least six months of remaining validity. It must name the importer and the brands, and grant the right to notify, import and distribute.
  • A technical responsible person who understands the product information file and the product’s technical data.

The importer holds the notification number, so choose that company carefully. If the brand later appoints a different importer, the regulation requires documents covering the change of agency, and BPOM may ask the previous importer for clarification.

Manufacturer documents and the product file

Prepare these for an initial project review. Exact filing requirements depend on the product and the manufacturer’s location.

  • Certificate of Free Sale (CFS): required for imported cosmetics from outside ASEAN, issued by an authority or recognised body in the country of origin. Contract-manufactured products are an exception.
  • Good manufacturing practice (GMP): a GMP certificate, or for ASEAN manufacturers a GMP certificate or statement, with at least three months of remaining validity.
  • Legalisation: foreign CFS and GMP certificates need an apostille, or legalisation by the Indonesian embassy or consulate where the apostille convention does not apply.
  • Product information file (DIP): safety, benefit and quality data for each product. The notification holder must keep it available for BPOM inspection.
  • Product definition: full formula, product name and variants, packaging, current labels and the claims you plan to use in Indonesia.

BPOM updated its technical requirements for cosmetic ingredients in 2025. Check each formula against the current rules rather than relying on approval in another market. See BPOM’s cosmetic regulation list.

Add halal readiness to the cosmetic launch review

Keep the BPOM notification project and the applicable halal review visible as separate workstreams. Organise the exact formula, ingredient specifications, manufacturing-site information, production details and available halal certificates for each product range.

Before finalising Indonesian packaging, check which halal or non-halal provisions apply to the product and what evidence supports the proposed labelling. A product without a halal certificate should not automatically be described as a product made from prohibited ingredients.

For imported products, verify the scope of any foreign certificate and the Indonesian steps required for the relevant pathway. Record unresolved questions before committing to a shipment date. BPJPH’s announcement of special provisions under preparation should not be presented as an issued exemption. (BPJPH statement, 9 October 2026)

After notification: imports and inspections

A cosmetic notification is valid for three years and can be renewed. BPOM’s 2025 import FAQ states that the importer must also obtain an import certificate (SKI) through its e-BPOM account for each import. That account requires the company’s NIB, tax number, the HS codes it plans to import and photographs of its office and warehouse. See BPOM’s cosmetic import FAQ (PDF, Indonesian).

BPOM Regulation No. 12 of 2023 sets out what inspectors check at an importer’s facility. The list includes procurement, stock, complaint and recall records, the import certificates and product information files. The technical responsible person must hold at least a bachelor’s degree in pharmacy, medicine, biology or chemistry. The warehouse must be at the address stated in the applicant recommendation. See the regulation.

How MDM supports the project

  1. Review the range. Check the product category, formulas, intended claims and current labels.
  2. Confirm the notification holder. Review the proposed importer’s licences, recommendation status, warehouse and technical responsible person.
  3. Organise the principal’s documents. Plan the agency appointment, CFS, GMP evidence and legalisation with the brand owner.
  4. Prepare the product file. Coordinate the DIP, Indonesian label text and submission data with the parties responsible.
  5. Support submission and the first imports. Coordinate follow-up within the agreed engagement and plan SKI and renewal responsibilities.

BPOM makes the regulatory decision. Advisory support does not replace its evaluation.

Timeline and budget dependencies

The schedule usually depends on work done before submission: legalising foreign certificates, obtaining the importer’s recommendation, completing product files and revising labels. Separate these steps from BPOM’s review in your plan, and allow time for any queries.

BPOM’s official fees are set by government regulation and were revised in 2026, so confirm current charges when you plan the budget. Ask for an estimate that separates advisory work, official fees, legalisation, translation and any testing.

Issues to review early

  • The agency appointment expires soon, omits a brand or does not grant the right to notify.
  • The CFS or GMP certificate names a different manufacturer, address or product than the product file.
  • An ingredient or concentration needs review against current BPOM ingredient requirements.
  • Packaging claims go beyond what a cosmetic may claim, or do not match the notified product name.
  • The importer has no suitable warehouse or technical responsible person yet.

Frequently asked questions

Is cosmetic registration the same as notification?

For BPOM purposes, cosmetics are notified rather than registered as food or supplements are. “Cosmetic registration” is the common commercial term for the same process.

Can an overseas brand hold the notification itself?

Imported cosmetics are notified by an Indonesian importer in the cosmetics sector, appointed by the brand owner or manufacturer. The brand chooses that importer and sets the terms of the appointment.

What happens if we change importer later?

The new importer needs its own appointment. BPOM’s procedure also requires documents covering the change of agency, and it may ask the previous importer for clarification. Agree exit terms when you first appoint an importer.

How long is a notification valid?

Three years, renewable through a renewal application. Plan renewals alongside the validity of the appointment and the manufacturer documents.

Is a separate approval needed for each shipment?

Yes. According to BPOM’s 2025 FAQ, the importer applies for an import certificate (SKI) through e-BPOM for each import of notified cosmetics.

Does a BPOM notification number complete every launch requirement?

Build a launch checklist that also covers the applicable halal pathway, labelling, importer arrangements and shipment documentation. A notification milestone should not conceal outstanding work in another part of the project.

BPOM Registration Indonesia · Importer of Record Indonesia · Import License Indonesia · All regulatory services

Official references

BPOM consulted on a revised cosmetic notification procedure in 2025. Check whether a replacement for Regulation No. 21 of 2022 is in force before filing. This page summarises the requirements as of October 2026.

Discuss your cosmetic range

Share the product list, formulas, current labels and country of manufacture. Tell us whether an Indonesian importer has been chosen and which certificates the manufacturer can provide.

Request a Cosmetic Launch Assessment