Indonesia’s National Agency of Drug and Food Control, BPOM, has pulled cosmetic products from the market on two separate grounds that brands keep collapsing into one. The first is composition — mercury and lead are prohibited, and a product containing them is off the shelf regardless of how it was advertised. The second is what the packaging and the campaign said, which is a different failure with a different fix.
Conflating them is expensive. A composition problem is solved in the lab. A claims problem is solved in the documentation, and often before the formula was ever finalised.
What BPOM is actually enforcing
The agency has tightened ingredient screening and disclosure requirements, and it now backs those requirements with actions that reach the commercial side of the business: recalls, and withdrawal of the permits a product needs to be sold at all. Losing a notification is not a fine you absorb — it removes the SKU from the market until the file is rebuilt.
Surveillance has moved online alongside the sales channel. BPOM operates reporting routes through dedicated apps and websites, which matters because cross-border e-commerce is where non-compliant product circulates most easily. A listing that never passed through an importer’s compliance check is still a listing an Indonesian consumer can buy from.
The ingredient side of this sits inside a broader annex revision programme; brands should be reading the current permitted-ingredient rules against their existing notifications rather than assuming a file cleared years ago is still valid.
The claims that triggered it
Whitening, anti-ageing and sun protection are the three promises that recur in the flagged cases. All three are efficacy claims, all three are testable, and all three were being made on products where the supporting evidence either did not exist or was never assembled in a form a regulator would accept.
Sun protection is the clearest example of why this happens. An SPF value belongs to the finished formula and comes from a defined test. It cannot be estimated from the filters on the ingredient list, and a BB cream carrying an unearned SPF number is making a safety claim, not a cosmetic one — which is why regulators treat it more seriously than a texture claim.
Whitening is messier, because the word means different things in different regulatory systems. Korea treats certain brightening claims as functional-cosmetic claims requiring registered evidence. Other markets read the same word as a straightforward efficacy assertion. A single line of copy can be compliant in one country and a violation next door, which is the whole problem with a global claim set. Similar patterns show up in other markets’ labelling and advertising enforcement against the category.
Why the hybrid format attracts this
The category’s commercial promise is that one product does the work of several. That promise is also its regulatory exposure. Every function named in the pitch — coverage, hydration, brightening, protection — is a separate claim with a separate evidence requirement, and a brand launching a BB cream is effectively launching four products’ worth of substantiation in one tube.
Consumer expectations have shifted in a way that raises the stakes further. Buyers now read for skin irritation and allergen risk as much as for finish, and interest in naturally derived formulations reflects that concern rather than a purely aesthetic preference. A brand answering that demand with softer ingredient choices still has to prove the performance claims it kept.
On the manufacturing side, Korea’s food and drug safety authorities have been building out safety evaluation support for exporters, and ISO 22716 — the GMP standard for cosmetics — is the baseline most overseas buyers now expect a factory to hold before they open a serious conversation.
Where the category is moving
Enforcement pressure has pushed formulation toward ingredients with a documented story behind them. PDRN, niacinamide, glutathione, peptides and hyaluronic acid keep appearing in briefs, partly because they perform and partly because they give a brand something specific to point at when asked what the product does and why.
That is a real shift in how a claim gets built. “Radiance boosting” as a standalone phrase is a liability. The same idea, tied to a named ingredient at a stated inclusion level with test data behind it, is a defensible position — and it survives translation into markets that read the original phrase as an efficacy claim.
The parallel trend is ESG expectation reaching into sourcing and packaging decisions. It is not yet enforced with the same force as claims compliance in most markets, but it is entering buyer questionnaires early enough that it belongs in the initial brief rather than in a later revision.
Practical sequence for a Southeast Asia launch
Settle the claim set before the formula locks. Every claim you intend to print determines a test, and tests have lead times that do not compress. Deciding at artwork stage that the product should carry an SPF figure means either delaying launch or dropping the number.
Then split the claim set by market. Build the strictest version first and relax it where a market permits, rather than building a permissive version and trying to defend it everywhere. Brands moving between Korea and Indonesia in particular should map their Korean documentation requirements against BPOM’s before committing to packaging artwork, because the overlap is smaller than it looks.
The manufacturer should be issuing a written statement of what the finished formula can support. If that document does not exist, the claims in the campaign are being written on assumption.
“What we’re hearing from brands after news like the Indonesia ban isn’t panic about the regulation itself — it’s a question of how to talk about their products without sounding like the next headline. Buyers are increasingly asking us to help them separate genuine formulation strengths from the kind of inflated claim language that regulators are now cracking down on across Southeast Asia. It’s a positioning shift: ‘sounds impressive’ is losing ground to ‘can be substantiated,’ and brands that get ahead of that now are better placed as more markets tighten labeling rules.” — Hyejin Cho, Digital Marketing Specialist, Marketing and Communication Team at SPSCOS