On June 4, 2026, Indonesia notified the WTO/TBT Committee of the "Draft Decree of the Head of the Halal Product Assurance Organizing Agency (BPJPH) on Guidelines for the Implementation of the Halal Assurance System for Cosmetics" (G/TBT/N/IDN/187). The draft provides guidance on the standards for the Halal Assurance System (SJPH) applicable to cosmetics, identifies critical halal control points throughout the production process, promotes consistent implementation of halal requirements, supports compliance with applicable regulations and standards, and ensures that cosmetic products meet halal requirements in accordance with Islamic principles.
The draft is currently open for public comments, with a comment deadline of August 2, 2026. CIRS Group has summarized the core content of the draft for reference.
Background
Under Indonesia's Halal Product Assurance Law (Law No. 33 of 2014) and its implementing regulation, Government Regulation No. 42 of 2024, cosmetics are classified as products subject to mandatory halal certification. The Indonesian government has mandated that, effective October 17, 2026, all cosmetic products distributed within Indonesia must hold halal certification.
To support the implementation of this mandatory requirement, BPJPH has developed the draft "Guidelines for the Implementation of the Halal Assurance System (SJPH) for Cosmetics" pursuant to Article 74 of the Halal Product Assurance Law. The guidelines aim to provide enterprises with specific operational guidance for implementing SJPH and ensuring the halal compliance of cosmetic products.
Scope
These guidelines apply to all cosmetic products produced, imported, or sold within Indonesia, covering two main areas:
1. Halal Assurance System (SJPH) criteria for cosmetics;
2. Critical halal control points for cosmetic products.
Halal Assurance System (SJPH) Criteria
1. Commitment and Responsibility
Enterprises must establish a written halal policy committing to the use of halal cosmetic ingredients, the implementation of the Halal Product Process (PPH), and the production of halal cosmetics. The halal policy should cover: the use of halal ingredients, provision of human resources and facilities for PPH, compliance with halal assurance regulations, ensuring the policy is understood and implemented by all personnel, communicating the policy to stakeholders, and consistently executing the policy.
Enterprises must appoint a Halal Supervisor (Penyelia Halal) and may establish a halal management team to ensure that all personnel maintain the integrity of the halal assurance system.
2. Ingredient Requirements
Cosmetic ingredients include: raw materials, additives, processing aids, materials in direct contact with the production line (e.g., lubricants, cleaning agents), washing validation media, packaging materials, and product applicators. All ingredients must be accompanied by halal certificates or other supporting documentation.
The draft specifies detailed halal requirements for ingredients from different sources and the following sections outline four main categories:
(1) Animal-derived ingredients: Ingredients derived from pigs and their by-products are prohibited; ingredients derived from animals not slaughtered in accordance with Islamic law may not be used in cosmetic preparations applied to the lips, teeth, or oral area; leather from halal animals that have been tanned is considered clean and may be used in cosmetics other than those applied to the lips, teeth, and oral area.
(2) Plant-derived ingredients: Presumed halal by default, but if additives or processing aids of questionable halal status (e.g., solvents, stabilizers) are added during processing, their halal status must be verified.
(3) Microbial-derived ingredients: Their halal status depends on the halal status of the microorganism itself, the growth medium, additives, and post-fermentation materials.
(4) Biotechnology/genetic engineering-derived ingredients: Cosmetics containing genetically engineered microorganisms involving pig or human genes are considered haram (prohibited); enzymes, solvents, and separation materials used in biotechnology processes must have their halal status verified.
3. Halal Product Process (PPH)
Enterprises must strictly separate the production facilities and equipment used for halal products from those used for non-halal products. Enterprises must establish written procedures for all production stages, ensuring that PPH only uses ingredients and production facilities that comply with SJPH criteria, and that washing procedures are documented with implementation records.
4. Products and Labeling
(1) General product requirements: Applications for cosmetic halal certification must comply with the mandatory halal certification product type provisions; product names, forms, and packaging must not contravene Islamic law or prevailing social ethics; waterproof cosmetics may still apply for halal certification provided they meet SJPH criteria and MUI fatwa requirements.
(2) Halal labeling: Enterprises may only affix halal labels after obtaining a halal certificate issued by BPJPH. The halal label must be placed in the most visible position on the packaging and must not be easily erased, removed, or damaged. For products with excessively small packaging, the halal label may be affixed to accompanying labeling materials. Where mutual recognition agreements exist with foreign halal certification bodies, both the Indonesian halal label and the foreign halal certificate registration number must be displayed.
(3) Traceability: Enterprises must identify ingredients and products (e.g., with entry dates, storage locations, barcodes, production dates) to ensure consistent halal status, and retain samples from each production batch. Products that do not meet halal criteria must be handled in accordance with written procedures, and products already on the market must be recalled under BPJPH supervision.
5. Monitoring and Evaluation
Enterprises must conduct internal audits at least once a year to monitor the implementation of SJPH, and carry out periodic management reviews. Internal audit results must be reported to BPJPH, and ingredient composition lists and PPH information must be reported to BPJPH every six months.
Critical Halal Control Points
The draft identifies 11 critical halal control points in the cosmetic production process:
1. Ingredient receipt: Ensure halal and non-halal ingredients are not mixed, storage facilities are separated, and ingredient quality meets requirements.
2. Verification and sampling: Sampling equipment must be used separately for halal and non-halal materials.
3. Incoming ingredient storage and quarantine: Halal and non-halal ingredients must be stored in separate areas, free from contamination by non-halal ingredients and najis (impurities).
4. Initial ingredient storage: Halal and non-halal ingredients must be stored separately, free from najis contamination.
5. Weighing and measuring: Weighing and measuring tools and areas must be separated for halal and non-halal materials, free from najis contamination.
6. Processing: All PPH equipment must be used separately for halal and non-halal products; auxiliary equipment must not originate from non-halal materials. Washing and sterilization facilities must not be shared with equipment that has been in contact with porcine-derived substances.
7. In-process quality control: Production quality control must ensure halal compliance.
8. Packaging: Packaging facilities and materials must be separated for halal and non-halal products; products must be sealed.
9. Labeling: Halal labels must be affixed in accordance with regulatory requirements.
10. Finished product storage: Finished products must be stored in accordance with regulatory requirements.
11. Distribution and transportation: Distribution and transportation must comply with regulatory requirements.
CIRS Reminder
This draft implementing guideline for the halal assurance system for cosmetics is a key supporting document for Indonesia's mandatory halal certification requirement for cosmetics. Effective October 17, 2026, all cosmetic products circulating in the Indonesian market must obtain halal certification. CIRS Group reminds cosmetics enterprises exporting to Indonesia to pay attention to the following:
- Initiate halal certification preparation as early as possible. Enterprises should promptly review export product formulations, verify the halal status of all ingredients, and collect halal certificates or supporting documentation. Pay special attention to animal-derived, microbial-derived, and biotechnology-derived ingredients.
- Establish an internal halal assurance system. Develop a halal policy, appoint a Halal Supervisor, and set up ingredient management, production control, washing verification, and internal audit procedures in accordance with SJPH criteria.
- Assess production facility compliance. Halal and non-halal production facilities must be strictly separated. Export enterprises should evaluate whether their existing production lines meet the separation requirements and prepare for on-site audits by Indonesian halal inspection bodies.
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