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Regulation

New Cosmetic Notification Rules in Indonesia Come Into Effect

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Indonesia updates its regulations on cosmetic notifications, introducing new exemptions and stricter rules for compliance.

Introduction of Updated Regulation

On October 23, 2026, the Head of the Indonesian Food and Drug Authority (BPOM) signed Regulation No. 20 of 2026 regarding the procedure for submitting cosmetic notifications. Officially published on November 3, 2026, in the State Gazette, this regulation repeals the previous BPOM Regulation No. 21 of 2022, marking a significant shift in cosmetic product marketing authorization.

Overview of the New Regulation

This updated regulation consists of 60 articles accompanied by five annexes that detail various aspects of cosmetic submissions:

  • Annex I: Types of products and cosmetic categories.
  • Annex II: Summary table format for cosmetic manufacturing.
  • Annex III: Procedure for updating applicant data.
  • Annex IV: Issuance process for recommendation letters.
  • Annex V: Priority service mechanisms.

The new framework adjusts existing provisions and tightens several rules regarding exemptions, categories of notification, and administrative consequences.

Key Changes in the Regulation

The key revisions can be grouped into eight significant aspects:

  1. Expanded Exemptions: Now includes domestic cosmetics for research or exhibition and refillable perfumes.
  2. Refined Product Categories: The regulation classifies cosmetics into five distinct categories, including new categories for export-exclusive cosmetics.
  3. Tighter Product Name Rule: A single product name can only be notified by one applicant, eliminating previous exceptions related to different market segments.
  4. New Conditions for Overseas Manufacturing: Additional requirements are now necessary for cosmetics produced abroad, including phased technology transfer obligations.
  5. Set Review Timelines: Introduces a clear mechanism for review response times and limits clarifications to three rounds.
  6. No Grace Period for Notification Renewal: Products cannot circulate if their notification expires without a renewal.
  7. End of Stock Management After Agreements: No allowance for continued consumption of stock post-termination of contracts.
  8. Expanded Administrative Sanctions: Types of sanctions increase to seven, including serious penalties for misinformation or document forgery.

Details on Exemptions

The new regulation stipulates that while all cosmetics must be notified for market authorization, certain conditions now exempt specific products:

  • Domestic cosmetics utilized for research or exhibitions may be distributed in limited amounts without market testing.
  • Imported cosmetics through special access are exempt.
  • Refillable perfumes have been newly classified as exempt from notification.

Categories and Applications

Cosmetics are divided into five notification categories:

  • Domestic cosmetics
  • Cosmetics produced under contract domestically
  • Overseas contract manufactured cosmetics
  • Imported cosmetics
  • Cosmetic sets

Applications for these notifications must come from businesses holding relevant licenses, including domestic manufacturers and registered importers.

New Conditions for Overseas Manufacturing

New regulations impose stricter conditions on notifications related to overseas contract manufacturing:

  • Only selected domestic companies can submit these notifications.
  • Producers must ensure that the production technologies are not currently available in Indonesia.
  • Final products must exhibit safety and efficacy based on known standards.

Phased technology transfer must enable these products to be produced locally over time.

Notification Validity and Renewals

The maximum validity period for a notification is set at three years, with strict procedures surrounding renewals:

  • No grace period after expiration; products are deemed illegal to circulate if not renewed.
  • Reapplication is required if renewal is attempted after expiration.

Implementation Timeline

The new regulation is enacted as of its publication on November 3, 2026. Previously submitted notifications under the old regulations will still be processed, maintaining their validity until their expiration, with overseas contract manufacturers granted a 12-month period to comply with the new rules.

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