This guide is for regulatory affairs staff, formulators, and product managers who need to confirm that a cosmetic formula can lawfully be sold in Indonesia. After reading it, you will know how a cosmetic ingredient review is structured under current rules.
You will also know which annexes apply, and where reviews typically fail even after the prohibited-ingredient list has already been checked.
In our experience reviewing client formulas against PerBPOM 25 2025 bahan kosmetik requirements, most rejections we see at the pre-submission stage are not prohibited substances at all.
They are restricted substances used at a concentration that is correct for one product type and unlawful for another, such as a leave-on limit applied to a rinse-off claim, or a body-care limit carried into a product later reclassified for the eye area.
A search against a prohibited-ingredient list will not catch this. Only a review that checks the conditions attached to each annex entry, against the specific product type and label, will.
What PerBPOM 25/2025 Changed
For six years, cosmetic ingredient compliance in Indonesia was governed by Peraturan BPOM Nomor 23 Tahun 2019, later amended by Peraturan BPOM Nomor 17 Tahun 2022, with permitted-ingredient changes issued separately under Keputusan Kepala BPOM Nomor 479 Tahun 2023.
All three were replaced on 3 October 2025 by Peraturan BPOM Nomor 25 Tahun 2025 tentang Persyaratan Teknis Bahan Kosmetik, issued by the Badan Pengawas Obat dan Makanan (BPOM) as an implementing instrument under Peraturan Pemerintah Nomor 28 Tahun 2024, itself implementing Undang-Undang Nomor 17 Tahun 2023 tentang Kesehatan.
Keputusan Kepala BPOM Nomor 479 Tahun 2023 was formally revoked by Keputusan Kepala BPOM Nomor 633 Tahun 2025. Because the 2019-2022 framework was in force for so long, a large volume of secondary guidance online still cites it as though it were current.
A formula screened against those older instruments, or against an internal checklist built before October 2025, is being checked against repealed law rather than the current PerBPOM 25 2025 bahan kosmetik text.
Cosmetic Ingredient Review: What It Covers and Why It Matters
A cosmetic ingredient review under PerBPOM 25/2025 evaluates a formula across three dimensions set out in the regulation: safety, benefit, and quality.
Two features of the regulation change the practical stakes of that review. Article 10 addresses prohibited substances present as technically unavoidable contamination during production, a distinct question from intentional use.
The sanctions provisions also now extend to revocation of the CPKB manufacturing certificate for ingredient breaches. This links a formulation error directly to the plant’s manufacturing authorization, not only to the individual product notification, which is a materially higher stake than under the previous framework.
ASEAN Cosmetic Directive Indonesia Alignment: What It Does and Doesn’t Cover
BPOM presents PerBPOM 25/2025 as aligning Indonesian ingredient requirements with the ASEAN Cosmetic Directive Indonesia follows as a member state. In practice, this alignment is structural, not a guarantee of equivalence between markets.
A formula lawfully sold in Malaysia, Singapore, Thailand, or another ASEAN member state has not automatically cleared the Indonesian annexes. Product-type conditions, concentration limits, and required label warnings under PerBPOM 25/2025 must still be checked on their own terms, ingredient by ingredient.
This is the assumption we see cause the most avoidable delay in a regional rollout: a brand treats ASEAN-wide compliance as a single pass or fail, when Indonesia’s own annexes require a separate, formula-specific check regardless of where else the product is already registered.
The Core Question, Answered: How Do You Screen a Cosmetic Formula Against PerBPOM 25/2025?
Cosmetic ingredient screening Indonesia work requires five steps: obtaining a complete quantitative formula, normalising every ingredient to its regulatory name, checking each ingredient against every relevant annex, applying the concentration and product-type conditions attached to each restricted entry, and reconciling any required warning statements against the intended label.
Skipping the third step, checking every relevant annex rather than only the prohibited list, is the most common cause of a late-stage rejection we see in practice.
The Five-Step Screening Method
- Obtain a complete quantitative formula. A packaging ingredient list is ordered by concentration but does not state it, and restriction limits are concentration-based and product-type-based. A qualitative list can only catch prohibited substances, not restriction breaches, which is the more frequent failure.
- Normalise ingredient nomenclature. Ingredients arrive under trade names, supplier codes, and regional naming conventions. Each has to be resolved to its annex name before it can be checked. A meaningful share of screening errors happen here, when the reviewer checks the annex correctly but against the wrong ingredient name.
- Check against every relevant annex. PerBPOM 25/2025 carries multiple ingredient annexes by substance category, and a single substance can appear in more than one with different conditions attached. Reviewing only the prohibited list gives false confidence.
- Apply the conditions attached to each entry. A restricted-substance entry typically specifies a maximum concentration, the product types it applies to, and any mandatory label warning. The same substance can be compliant in one product type and non-compliant in another.
- Reconcile against the intended label and claims. Where an annex entry requires a specific warning, it has to appear on the label. Labelling and claims sit under separate instruments, so a formula that clears every ingredient annex can still fail because the label is missing a mandated statement.
Prohibited Cosmetic Ingredients BPOM Bans vs. Restricted Ones
The distinction between prohibited cosmetic ingredients BPOM bans outright and substances that are merely restricted is where most avoidable failures occur.
A prohibited substance is banned at any level and is usually caught by even a basic check. A restricted substance is conditionally permitted, subject to a maximum concentration, an approved product type, and sometimes a required label warning.
A breach of those conditions is far less likely to be caught without a full quantitative review, because nothing about the ingredient’s presence looks wrong on its own. Only the concentration and product-type context reveals the failure.
| Check point | Prohibited substance | Restricted substance |
| Basis for failure | Presence at any level (subject to Article 10 contamination provisions) | Concentration or product type outside the annex condition |
| Typically caught by | A basic prohibited-list search | A full quantitative, product-type-specific review |
| Common oversight | Rare once a formula reaches submission stage | Frequent, especially after a product is reclassified or reformulated |
Failure Modes That Survive a Superficial Cosmetic Ingredient Review
- Checking the prohibited list only, and treating that as the full review.
- Assuming ASEAN or another market’s compliance transfers automatically to Indonesia.
- Screening against the superseded 2019 regulation or its 2022 amendment instead of PerBPOM 25/2025.
- Ignoring contamination limits, which are governed separately from intentional-use ingredient limits.
- Treating the review as a one-time exercise, when annexes are amended periodically.
Adjacent Regulations a Cosmetic Ingredient Review Should Not Ignore
Ingredient compliance under PerBPOM 25/2025 does not stand alone. Peraturan BPOM Nomor 16 Tahun 2024 tentang Batas Cemaran dalam Kosmetik governs contamination limits and replaced Peraturan BPOM Nomor 12 Tahun 2019.
Peraturan BPOM Nomor 26 Tahun 2025 addresses risk assessment for raw materials used in natural medicines, health supplements, quasi-drugs, and certain cosmetic preparations.
Labelling and claims sit under Peraturan BPOM Nomor 18 Tahun 2024 tentang Penandaan, Promosi, dan Iklan Kosmetik and Peraturan BPOM Nomor 3 Tahun 2022 tentang Persyaratan Teknis Klaim Kosmetika. A formula review confined to the ingredient annexes alone is incomplete.
Cosmetic Reformulation BPOM Guidance: When It Is (and Isn’t) the Right Response
A screening finding does not have one automatic fix. The right response under any cosmetic reformulation BPOM scenario depends on the product and the brand’s tolerance for change to performance or claims.
- Reducing a restricted substance below its permitted limit, where this does not materially change performance.
- Substituting the substance, accepting that this may change texture, stability, or sensory performance.
- Reclassifying the product into a different type where the substance is permitted, while checking this does not create a labelling or claims conflict.
- Withdrawing the product from the Indonesian range, which can be the rational choice for a minor line item.
What should not happen is submission without resolving a known breach. Under PerBPOM 25/2025, the sanctions available extend to the CPKB manufacturing certificate, so the cost of a finding after market entry is materially higher than the cost of resolving it beforehand.
A structured 化粧品登録 process should include this ingredient screening as a formal pre-submission step, not an informal check.
How Ingredient Compliance Connects to Your BPOM Cosmetic License
A BPOM cosmetic license (notification) is issued against the specific formula submitted. Any later change, including a reformulation made to resolve an ingredient finding, needs to be reflected in the notification record.
This connects to who holds the notification: see our guide on who can legally act as a cosmetic notification holder in Indonesia for how that responsibility is assigned.
Where manufacturing is involved, ingredient findings can also affect ライセンス所有者 obligations and, as covered above, the CPKB certificate itself.
Verify Before You Rely
This article describes the structure of the current framework and a screening method. It does not reproduce the ingredient annexes, which must be consulted in their current form, and it does not assess any specific substance. Annexes are amended periodically.
Always verify the current text through BPOM’s official legal documentation portal (JDIH BPOM) または BPOM website before relying on any screening result, and cross-check submission mechanics against OSS (Online Single Submission) where relevant.
For a related step in the compliance chain, see our guide on what GMP certificate BPOM will actually accept for cosmetics.
Get Your Formula Reviewed Before You Submit
A formula that clears a superficial check can still be rejected, or worse, cleared for submission and found non-compliant after market entry, with sanctions now reaching the manufacturing certificate itself. That risk is best resolved before a dossier is filed, not after.
Product Registration Indonesia’s 化粧品登録 service includes formula-level ingredient screening against PerBPOM 25/2025 as part of the pre-submission process. Book a consultation to have your formula reviewed before you file.
