This guide is for companies planning to act as the notification applicant for cosmetics in Indonesia, including importers, contract-production businesses, and cosmetic manufacturers, together with foreign brands assessing whether an Indonesian partner is actually eligible to apply.
After reading, you will understand what the technical person in charge BPOM requirement is, how the expected qualification changes by applicant type, and why it belongs at the start of a registration project rather than the middle.
In our experience, the technical person in charge is the single requirement most responsible for cosmetic registration timelines becoming unachievable. It is not a document that can be requested, corrected, or expedited. It is a real, qualified person who must be identified, hired, and formally engaged before a company is even eligible to submit its facility for a BPOM inspection.
Companies routinely build a registration timetable around product documentation, then discover this staffing requirement only when the facility inspection stalls, at which point the project has quietly turned from a paperwork exercise into a recruitment search.
What Is the Technical Person in Charge (PJT Cosmetics) Requirement?
The technical person in charge, referred to in Indonesian as penanggung jawab teknis kosmetik or PJT cosmetics, is a named individual whom a cosmetic notification applicant must employ and document before BPOM will issue a Rekomendasi sebagai Pemohon Notifikasi, the Recommendation as Notification Applicant.
Importers and businesses conducting contract production with an Indonesian cosmetic industry must hold this recommendation before they are eligible to submit a cosmetic notification at all. Obtaining it requires an application for inspection of the applicant’s facility, and BPOM examines, as part of that inspection, whether a technical person in charge is genuinely in post rather than named on paper only.
Regulatory Basis: Peraturan BPOM Nomor 21 Tahun 2022
The requirement is set out in Peraturan Badan Pengawas Obat dan Makanan Nomor 21 Tahun 2022 tentang Tata Cara Pengajuan Notifikasi Kosmetika, which governs the procedure for submitting a cosmetic notification.
The regulation states how the requirement is evidenced, and it expresses the importer-specific obligation in functional rather than purely administrative terms: an importer must have a technical person in charge who understands the Product Information Document and the technical information relating to the cosmetic products it handles.
Two features of that formulation carry practical weight. First, the requirement is evidenced by a named individual with a stated qualification and a documented relationship to the company, which forecloses any arrangement in which the role exists only on an organisation chart.
Second, the functional wording for importers signals that the role carries substantive responsibility, not merely a formality to be satisfied once and forgotten.
What Documents Prove the Requirement Is Met?
Under the regulation, the applicant must provide:
- A copy of the technical person in charge’s identity card (KTP)
- The individual’s academic qualification certificate, matching the qualification required for the applicant’s category
- A signed working agreement between the technical person in charge and the company’s leadership
An informal understanding or an unsigned arrangement does not discharge this requirement. In our experience, applicants that treat the working agreement as a formality to finalise later are the ones most likely to have their facility inspection application returned.
Qualification Requirements Differ by Applicant Type
The qualification expected of the technical person in charge is not uniform across applicant types. Cosmetic manufacturers are generally divided into Golongan A and Golongan B, with the higher category expected to engage a pharmacist as technical person in charge and the lower category a pharmaceutical technical worker. Importers and contract-production businesses are subject to their own, separate expectations.
| Applicant Type | Typical Technical Person in Charge Qualification | Regulatory Basis |
|---|---|---|
| Cosmetic manufacturer, Golongan A | Pharmacist (apoteker) | PerBPOM 21/2022; categorisation under PerBPOM 8/2026 |
| Cosmetic manufacturer, Golongan B | Pharmaceutical technical worker (tenaga teknis kefarmasian) | PerBPOM 21/2022; categorisation under PerBPOM 8/2026 |
| Importer | Person who understands the Product Information Document and cosmetic technical information, commonly an apoteker importir kosmetik | PerBPOM 21/2022 |
| Contract-production business | Subject to separate BPOM expectations; confirmed per applicant profile | PerBPOM 21/2022 |
Because this allocation determines the recruitment brief, and because the categorisation of cosmetic industries was itself addressed in Peraturan BPOM Nomor 8 Tahun 2026 tentang Sertifikasi Cara Pembuatan Kosmetik yang Baik, the applicable qualification for a specific applicant should be confirmed against the current regulation and with the relevant BPOM technical implementation unit rather than assumed from general guidance.
In our experience, engaging a person with the wrong qualification is a more expensive error than engaging nobody yet, because it consumes the recruitment lead time without producing eligibility.
Why the Technical Person in Charge Becomes a Timetable Problem
Three consequences follow for any company building a cosmetic registration timetable around this requirement.
The requirement sits upstream of product work. Product documentation prepared while no technical person in charge is in place has not moved the applicant any closer to being eligible to submit that documentation.
Recruitment duration sits outside the company’s control and varies by location. Qualified individuals are not evenly distributed across Indonesia, and a company establishing outside Jakarta or other major centres should plan for a longer search.
The engagement must be documented, not merely agreed. Because the regulation contemplates a signed working agreement between the individual and company leadership, an informal or verbal arrangement does not satisfy the requirement, however genuine the intention behind it.
Where This Fits in the Cosmetic Product Registration Process
The technical person in charge is examined during the facility inspection stage that precedes eligibility to submit a cosmetic notification, and it sits ahead of most of the work covered under 化粧品登録. Companies that confirm this staffing requirement before scoping the rest of the registration project generally keep their overall timetable intact.
What Foreign Brands Should Ask Their Indonesian Partner
A foreign brand relying on an Indonesian distributor or service provider to act as applicant is, in effect, relying on that party’s eligibility. Eligibility is not a matter of intention, and it is worth confirming before a commercial timetable is set.
- Does the proposed applicant already hold a valid Rekomendasi sebagai Pemohon Notifikasi?
- Is the technical person in charge named in that recommendation still employed by the company today?
- Is there a signed working agreement on file, or only a verbal understanding?
The second question is the one that gets skipped most often. A recommendation obtained on the basis of an individual who has since left the company raises an obvious issue, and in our experience it is far better identified by the brand before the project starts than by the regulator once it is underway.
Two Structural Options for Meeting the Requirement
A company that must satisfy this requirement has, broadly, two routes available.
Option 1: Recruit and Employ a Technical Person in Charge Directly
This route gives the company control and permanence over its own notification applicant status. It carries a recruitment lead time that varies by location and qualification, plus an ongoing salary cost, and the working agreement must be documented as described above.
Option 2: Work Through an Already-Established Applicant
The alternative is to act through a distributor or an independent ライセンス所有者サービス that already holds a valid recommendation and an in-post technical person in charge. This removes the recruitment lead time, which is often decisive when a commercial launch date is already fixed, though it means the notification itself sits with a third party. For a closer look at who is legally entitled to hold that notification and what that means for a foreign brand, see our related article on cosmetic notification holder requirements in Indonesia.
The choice between the two options is not principally about cost. It is about whether the company wants to control the notification directly or wants to be in the market as quickly as possible, and those two objectives are in tension at the outset of most projects.
Limitations of This Guidance
This article confirms the existence and documentary form of the technical person in charge requirement as set out in PerBPOM 21/2022. It does not state the precise qualification applicable to every applicant profile, since that allocation should be confirmed against the current regulation and with the relevant technical implementation unit.
It does not give a recruitment duration, because that varies by location and market conditions and any general figure would be unreliable. It also does not address the separate employment or professional licensing obligations that attach to the individual once hired.
Talk to Our Team About Cosmetic Product Registration
If you are assessing whether your company, or your Indonesian partner, meets the technical person in charge requirement, our team can review your position against PerBPOM 21/2022 and the current BPOM guidance for your applicant category. Contact our team by sending your message through the form below to plan your staffing and registration timetable together.
