Cosmetic Product Registration in Indonesia: What You Need to Know

Companies that want to import and distribute cosmetic products to Indonesia must register the products with the National Agency of Food and Drug Control (BPOM).

Below, you will find which products companies must register and the registration process. We also explain some common issues companies face when registering cosmetic products.

Which cosmetic products need to be registered in Indonesia?

Companies involved in the import and sale of cosmetic products in Indonesia must register all of the products. Such products also include personal care items and toiletries. The National Agency of Food and Drug Control (BPOM), regulates cosmetic product registration.

The BPOM requires businesses to register every variation of a cosmetic product as a separate item. So if, for example, you wish to sell lipstick, you will have to register each shade as a separate product. This is unlike food registration where you can register variants under one registration.

All member nations in ASEAN follow the same directive for cosmetic products. You will need to register your cosmetic products in the Philippines with the Food and Drug Authority. Similarly, you must also register cosmetic products in Vietnam with the Drug Administration. Emerhub can assist in registering your products in Indonesia, Vietnam, and the Philippines.

Who can register cosmetic products in Indonesia?

Only legal entities established in Indonesia can register cosmetic products. They must register as either a manufacturer or an importer and distributor. Below are the options to meet this requirement.

Option A: Emerhub as your nominee product holder

By assigning us as the product holder, you won’t need to set up a company in Indonesia. This is a hassle-free option for businesses that do not have a legal presence in Indonesia. As your nominee product holder, we will hold the product registration number on your behalf. In addition to that, you also won’t need to worry about renting warehouse space for your goods.

Option B: Set up a foreign-owned company in Indonesia (PT PMA)

Foreign investors can set up a company in Indonesia to be an importer or distributor of cosmetics. Foreigners can own 100% of a company operating as an importer of cosmetic products. Meanwhile, foreigners can own up to 67% of a cosmetic distribution company.

Indonesia requires a minimum paid-up capital of IDR 2.5 billion (approx. USD 170,000) for foreign-owned. Note that in Indonesia, a company with any foreign ownership is a foreign-owned company.

Emerhub can assist in registering your PT PMA in Indonesia. We can also facilitate product registration on your behalf after your company registration.

Option C: Set up a special purpose vehicle in Indonesia

Another option is to set up a special purpose vehicle. A special purpose vehicle is a local entity set up to hold shares on your behalf. With Emerhub as your special purpose vehicle, we will set up a legal structure to protect your rights as the business owner.

How to register cosmetic products in Indonesia

After setting up a legal entity making arrangements with a product holder, you can proceed with product registration. We detail the product registration process below.

#1 Warehouse Audit

As of June 2020, Local BPOM authorities will check on your warehouse. This is to ensure that you have adequate facilities to safely store and distribute your cosmetic products. You will receive a recommendation letter from the BPOM upon passing inspection. This recommendation letter is a required document when registering products.

By appointing Emerhub as your product holder, you won’t have to worry about this. We will take care of warehousing and storage for your cosmetic products.

#2 Submission of documents for product registration in Indonesia

You must prepare the following documents relevant to the company or appointed importer:

• The company’s legal documents. The documents must show that the company can import or distribute cosmetics. The documents must also indicate that the company has technical experts with knowledge on cosmetics safety.
• A copy of the manufacturer’s Good Manufacturing Process certificate. The Indonesian Embassy in the manufacturer’s country must legalize the certificate.
• Certificate of Free Sales. The governing body of the principal’s location must issue this certificate. The Indonesian Embassy in the manufacturer’s country must also legalize this document.

You must also prepare documents and information for each variant of your product:

• Product name.
• Product description. The description must indicate product specifications. You must also provide information on how to use or administer the product.
• Ingredients. You must list all ingredients used to manufacture the product as well as the function of each ingredient.
• Packaging.

Emerhub can assist in preparing and submitting company and product documents on your behalf.

#3 Payment for each of cosmetic product undergoing registration

There are also fees relevant to product registration in Indonesia. The fees apply to each product that a company wants to register. The fees depend on the origin of the product.

It is important to note that the fees are non-refundable even if the BPOM denies your product registration.

#4 BPOM notification or Notifikasi kosmetik

If your product meets all requirements, the BPOM will approve product registration. You will then receive the BPOM notification. The BPOM will issue the notification number within 14 days after validating your payment of fees.

You must import your goods within six months of receiving the BPOM notification. Otherwise, your product registration will become invalid. The BPOM notification is valid for three years and extendable after that. You must comply with Indonesia’s regulations to maintain the validity of the BPOM notification.

Common problems with cosmetic product registration in Indonesia

The process to register cosmetic products in Indonesia is straightforward. The BPOM will approve your application if:

• You submit all necessary documents
• You comply with application requirements
• Your product meets safety and quality standards

However, it is still possible for the BPOM to delay or reject your application. Below are some common examples of reasons why the BPOM delayed or denied an application.

The cosmetic product manufacturer is not able to provide a GMP certification

The BPOM only accepts Good Manufacturing Practice (GMP) certifications issued by government institutions. The BPOM does not accept certifications issued by private sector entities. If the manufacturer’s country allows GMP certifications from private sector entities, the BPOM may allow it. However, the applicant will have to provide additional documents.

You can avoid this issue by making sure that all documents are in order before submitting the application. Our consultants at Emerhub will advise you on documents you need to prepare.

The name of the cosmetic product is misleading and/or overclaiming

The BPOM aims to protect consumers. As such, they will determine if a cosmetic product’s name may be misleading to Indonesian consumers.

For example, a cosmetic brand cannot have the word “rose” in it if the product does not contain roses as an ingredient. Another example is the product name, “Magic White.” In this case, the BPOM considers the word “magic” as overpromising.

The product formula does not comply with Indonesian regulations

The BPOM also has specific regulations on the use of ingredients in cosmetic products. They will deny registration applications for products that do not comply with such regulations.

One example is the use of Phenoxyethanol as a preservative. The maximum allowed percentage of Phenoxyethanol in cosmetic products is 1%. If a formula goes even 0.01% over this, the BPOM will reject the application.

The BPOM will also reject an application if the usage of an ingredient does not match the product. For example, the BPOM will reject an application for long-wear cosmetics that use pigments meant for short-term use.

Compliance after cosmetic product registration in Indonesia

Prepare the Product Registration Document for Cosmetic Products

You must have a product registration document or Dokumen Informasi Produk (DIP) for the products you import into Indonesia. The BPOM frequently audits importers to make sure they have the DIP.

The DIP can be in English or Indonesia and must contain the following information:

• Administration documents and a summary of the products
• Cosmetics ingredients
• Quality data of cosmetics
• Safety and usage data of cosmetics

Our consultants at Emerhub can help you prepare the DIP to ensure compliance with local regulations.

Labeling requirements for cosmetic products in Indonesia

You must also follow Indonesia’s labeling requirements for cosmetic products. The product’s labels and packaging must include the following:

• Name of the product
• Product functions
• Application method
• Composition
• Name of the manufacturer
• Name and address of the importer
• Batch number
• Net weight
• Expiration date
• Any warnings regarding the ingredients. For example, potential allergic reactions or safety indications for children.

Do you need to register cosmetic products in Indonesia? Our consultants at Emerhub are ready to assist you through each step. We will help you prepare and submit all requirements and we will also advise you regarding regulations you need to know. Fill out the form below to get started or send us an email at [email protected].