In October 2025, Indonesia’s National Agency of Drug and Food Control (BPOM) issued PerBPOM No. 25 of 2025, revising the country’s permitted ingredient annexes. The headline arithmetic: 102 substances added, usage conditions revised for 6, and 1 removed from the approved list.
The additions are the easy part — more permitted substances means a wider formulation palette, and nobody has to do anything. The six revisions and the single deletion are where existing products break, because a formula that was notified under the old conditions is not automatically valid under the new ones.
“Revised usage conditions” is doing a lot of quiet work in that sentence. In practice it usually means a lower maximum concentration, a narrower set of product types the substance may appear in, or a mandatory warning statement on the label. Any of the three can invalidate an existing notification without the ingredient ever leaving the permitted list, and the second and third variants tend to be the ones brands miss, because a concentration change is at least numerically obvious.
What changed, and who has to act
The Indonesia cosmetic ingredient regulation does more than adjust a list. It sharpens the split of responsibility between the manufacturer and the responsible sale agent — the local entity that holds the notification and answers to BPOM. For an overseas brand manufacturing in Korea and selling through an Indonesian partner, that division determines who owns the safety dossier and who is liable when a substance is reclassified.
- Safety evaluation and documentation requirements have been tightened for both domestic and export-facing products.
- Product registration and label updates run through BPOM’s e-Notifikasi system, and existing files need checking against the revised annexes rather than assumed valid.
- E-labelling provisions are being introduced to improve traceability and give consumers direct access to ingredient information.
- Unauthorised medicinal claims on cosmetic products are explicitly prohibited — a line Indonesia is enforcing rather than merely stating.
The alignment target is the ASEAN Cosmetic Directive, with the EU framework as the broader reference point. That matters practically: a dossier built to EU expectations transfers into Indonesia with less rework than one built ad hoc, which is worth knowing before the dossier gets built.
Enforcement is the real signal
BPOM has reported seizures of illegal cosmetics valued at roughly 5 billion Indonesian Rupiah, which says something about the scale of non-compliant product circulating and about the agency’s appetite for acting on it. Indonesia’s regulator has a track record here — earlier actions against labelling and advertising violations followed the same pattern of stated rule first, visible enforcement second.
Local manufacturers and SMEs have pushed back on compliance cost and process complexity, which is the predictable objection and not an unreasonable one. Registration timelines and documentation burden fall hardest on companies without a dedicated regulatory function. For an incoming foreign brand, the same burden is usually absorbed by the local partner — which is exactly why the responsibility split in the new rule deserves reading closely before a distribution agreement is signed.
There is a second-order effect here that gets underestimated. When compliance cost rises, the number of local partners genuinely capable of carrying a notification file shrinks, and the remaining ones gain pricing power. Brands that treated agent selection as a commodity decision tend to discover this at renewal rather than at signature.
Planning a launch around it
The mistake we see most often from brands entering Southeast Asia is treating ingredient verification and halal certification as parallel workstreams that finish together. They don’t. Halal certification carries its own audit chain back through raw material suppliers, and a single ingredient with unclear provenance can hold the whole file. Indonesia’s earlier action on BB cream products showed how quickly a certification or composition question turns into a market access problem.
A workable sequence looks like this. Confirm every INCI in the formula against the revised annexes before committing to artwork, since a substance with changed usage conditions may cap your concentration below the level your claim depends on. Then run halal traceability on the raw materials, because that is the step with the longest and least predictable tail. Registration comes last, and goes faster when the first two are clean.
Treat the Indonesia cosmetic ingredient regulation as a gating item on the launch calendar rather than a parallel task, and the sequence stops fighting itself.
Brands running multiple Asian markets should also be checking whether their existing documentation travels. India’s IS 4707 ingredient standards use different categorisation logic from the ASEAN approach, so a formula cleared in one is not thereby cleared in the other. Building the dossier once, to the stricter of the two, costs less than building it twice.
One further point on positioning. Indonesian consumers are paying visible attention to certification and ingredient sourcing, which means the compliance work has marketing value if you choose to use it. Regulatory transparency reads as a trust signal in this market in a way it doesn’t everywhere, and brands that treat the documentation purely as a cost are leaving that on the table.
“Regulatory updates like PerBPOM No. 25 rarely make headlines outside the industry, but they’re exactly the kind of thing our export-focused clients need flagged early. In practice, we’ve found that brands entering Southeast Asia underestimate how much lead time ingredient re-verification and halal certification can add to a launch timeline — it’s a market-entry planning issue as much as a compliance one. From a marketing standpoint, we increasingly advise clients to treat regulatory transparency itself as a trust signal in their messaging for the Indonesian market, since local consumers are demonstrably paying closer attention to certification and ingredient sourcing than they were even a couple of years ago.” — Hyejin Cho, Digital Marketing Specialist, Marketing and Communication Team at SPSCOS