Buyer questions · Purchase decisions
Launching a skincare product (serum or cream) in Indonesia: what does the OEM factory need to prepare, and how long does notification take?
For skincare launch in Indonesia, an Indonesian legal entity (importer/license holder) must submit a pre-market notification via BPOM's Notifkos e-system. Formula must meet ingredient limits under PerBPOM 25/2025 (deadline 2026-10-03), and labels require Bahasa Indonesia (PerBPOM 18/2024, in force 2024-11-15). The OEM factory must prepare a letter of authorisation, GMP/CPKB proof, and raw-material compliance data. Notification processing time is based on the latest official BPOM announcement; no fixed days are promised. Halal certification by BPJPH becomes mandatory for all cosmetics from 2026-10-17; no Halal marks on labels before certificate is issued.
1Documents the OEM factory must prepare
The legal entity submitting to BPOM must be an Indonesian corporate body. The factory must provide: 1) a stamped letter of authorisation from the local responsible party; 2) GMP/CPKB compliance proof (ISO 22716 or local CPKB No.); 3) formulation sheet with INCI names and percentages, plus raw-material compliance and supplier sourcing files; 4) prior safety assessment, stability and microbial test reports (challenge per ISO 11930 / USP <51>); 5) label and claim drafts in Chinese, English and Bahasa Indonesia.
2Notification reference issuance timing
The issuance timing of BPOM Notifkos reference numbers is not committed to a fixed number of days; it follows the latest official BPOM announcement and actual system processing status. Fees: IDR 500,000 for ASEAN-made / IDR 1,500,000 for non-ASEAN-made products, charged per notification and variant. Validity: 3 years. The client must accept shipment deferral if the reference number has not been issued, and should not write fixed issuance dates into contract delivery clauses.
3Halal and labelling hard limits
From 2026-10-17, BPJPH halal certification becomes mandatory for all cosmetics (PP 42/2024). Before certificate issuance, no packaging drafts, samples or e-commerce images may display Halal marks or wording. Non-halal products must carry a red 'NON HALAL' mark after a 12-month transition period (BPJPH Regulation 3/2026). Minimum legal label requirements: Indonesian-language benefits, directions and warnings, full ingredient list, notification number, batch, expiry, and manufacturer/importer names (PerBPOM 18/2024, in force 2024-11-15; subject to the latest official text).
Follow-up questions
- Q:Can China's domestic filing be used directly?
- A:No. Domestic filing is only valid for sales in China; its reference number holds no legal status in the BPOM system. A new Indonesian notification is required.
- Q:Can the OEM factory itself hold the licence and apply?
- A:No. The legal responsible party must be an Indonesian corporate entity (importer or licence holder). The OEM factory does not act as the domestic licence holder.
Figures sourced from:各国法规 · 印度尼西亚印尼护肤代工东盟化妆品指令附录配方库
Updated 2026-09-18
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