Jakarta, October 2025
Indonesia’s National Agency of Drug and Food Control (BPOM) has issued a major update under PerBPOM No. 25 of 2025, introducing significant changes to ingredient policies for cosmetic products. This new regulation officially replaces PerBPOM No. 23 of 2019 and PerBPOM No. 17 of 2022, and will take full effect by 3 October 2026.
This update marks one of the most comprehensive reforms to Indonesia’s cosmetic regulation in recent years. It directly impacts formulation, labeling, and product registration for both local and imported cosmetic brands.
What Changed in the New BPOM Regulation
Under PerBPOM No. 25 of 2025, the following key revisions were made across BPOM’s ingredient annexes:
1. Lampiran I – Permitted Ingredients (with concentration limits)
New limits and usage conditions now apply to:
- Salicylic Acid
- Zinc Pyrithione
- Acid Yellow 3
- Etidronic Acid
- BHT (Butylated Hydroxytoluene or 2,6-di-tert-butyl-4-methylphenol)
These ingredients must now meet stricter safety and labeling requirements based on updated ASEAN Cosmetic Directive references.
2. Lampiran IV – UV Filters
Two key sunscreen ingredients have been revised:
- Benzophenone-3 (Oxybenzone)
- Homosalate
Both are now subject to lower concentration limits due to safety reassessment by international regulatory bodies.
3. Lampiran V – Prohibited Ingredients
The following substances are now officially banned in all cosmetic formulations marketed in Indonesia:
- Lilial (Butylphenyl Methylpropional)
- D4 (Octamethylcyclotetrasiloxane)
- Styrene
- Quaternium-15
Implementation Timeline
The regulation provides a 12-month transition period from the date of issuance.
All cosmetic products — new, renewed, or reformulated — must comply with PerBPOM No. 25 of 2025 by 3 October 2026.
During this period, companies are expected to:
- Review existing formulas and raw material compliance
- Update Product Information Files (PIF) and safety assessments
- Adjust labeling and claims where necessary
- Re-submit modified dossiers through BPOM’s e-Notifikasi system
Why This Matters for Cosmetic Importers and Brand Owners
Failure to update formulations and dossiers within the transition window may lead to:
- Rejection of renewal applications
- Product delisting or withdrawal from BPOM database
- Import suspension at customs
For brands already active in Indonesia, this is a crucial moment to future-proof compliance and avoid regulatory disruptions.
How Product Registration Indonesia (PRI) Can Help
At Product Registration Indonesia (PRI), we support both local and international cosmetic brands through every stage of regulatory transition.
Our services include:
- Ingredient & formulation gap assessment — to check compliance with the new annexes
- Re-formulation and dossier updates — aligning PIF, SDS, and labeling
- Strategic transition planning — ensuring smooth re-notification within BPOM’s system
- License-holding & import support — for principals without a legal entity in Indonesia
We also provide regulatory monitoring and alerts for future BPOM changes affecting cosmetics, supplements, and personal care products.
Stay Ahead of the Regulation
The new BPOM regulation signals Indonesia’s commitment to harmonizing with global safety standards. For companies that act early, this transition can be an opportunity — not a setback.
