On July 30, 2026, Indonesia’s Halal Product Assurance Organizing Body (BPJPH) notified the WTO via G/TBT/N/IDN/190, soliciting comments on the "Draft Regulation on the Conformity Assessment of Foreign Halal Products Entering the Territory of Indonesia". The draft introduces a key additional step for halal products exported to Indonesia, including cosmetics: any imported product that must obtain halal certification or bear a "Non-Halal Statement" is required to complete a "Halal Product Conformity Assessment" before the import customs declaration is filed.
CIRS Group has summarized the cosmetics-relevant main content below for your reference.
I. Background and Scope
Indonesia implements a mandatory halal certification system for cosmetics — cosmetics circulated and sold in Indonesia must obtain halal certification; cosmetics made from forbidden (haram) ingredients, while exempt from halal certification, must bear a "Non-Halal Statement". This draft is the conformity assessment mechanism established to implement this system and targeted at foreign (imported) products. Its "product" definition explicitly includes cosmetics, while also covering categories such as food, beverages, pharmaceuticals, chemicals, biological products, genetically engineered products, and daily-use articles.
II. Core Requirements for Cosmetic Exporters: Conformity Assessment Must Be Completed Before Customs Declaration
Applicable products: Imported cosmetics (and other imported products) that must obtain halal certification or bear a "Non-Halal Statement".
Key timing: The conformity assessment must be completed and the Halal Product Conformity Report (LPPH) obtained before the import customs declaration (pemberitahuan impor barang) is submitted; the declaration is processed via electronic data exchange through the Indonesia National Single Window (SINSW).
Exemptions: Personal effects of passengers, non-commercial shipments, samples for testing, and transit/transhipment goods (provided they are not circulated or sold in Indonesia), etc.
III. Implementing Body and Assessment Method
Implementing body: State-owned and/or private inspection bodies (Lembaga Inspeksi) designated by BPJPH; private bodies must coordinate with the designated state-owned body.
Qualification requirements for inspection bodies: holding a risk-based business license, accredited by the National Accreditation Committee of Indonesia (KAN), having branches or partners at home and abroad, certified to ISO 9001/17020/17029/27001/37001, etc., and employing at least four competent verifiers; designated through a transparent, accountable, objective, non-discriminatory, and conflict-of-interest-free selection process.
Location of assessment: Conducted directly on-site at the loading warehouse in the country of loading and/or country of origin, before shipment.
IV. Main Items Checked During the Conformity Assessment (Draft Article 6)
- Verify the product type against the halal certificate or the annex to the Foreign Halal Certificate (SHLN) registration, and validate the halal certificate number or SHLN registration number on the cosmetic packaging;
- Check the product HS code, quantity/volume, production code, and production date, etc., for consistency with the purchase documents and order list;
- Verify whether the halal label or "Non-Halal Statement" is marked as required;
- The SHLN must be registered and issued by a Foreign Halal Institution (LHLN) from the same country as the place of production, which has established a mutual recognition arrangement (MRA) with BPJPH;
- For cosmetics bearing a "Non-Halal Statement", check supporting documents such as the Certificate of Analysis (CoA), Certificate of Origin (CoO), and MSDS;
- Verify the conformity of administrative documents and SJPH (Halal Product Assurance System) documents.
V. Application Process and Timeline (Draft Articles 8–13)
- Application method: The importer submits an application through BPJPH’s Integrated Electronic System and freely chooses a BPJPH-designated inspection body.
- Documents the importer must hold: NIB (Business Identification Number) and importer identity, halal certificate or SHLN registration number (or Non-Halal Statement), product list with HS codes, a valid API (Importer Identification Number), corporate tax number (NPWP), purchase documents and order list (including product description, quantity, production code/date, unit), etc.
- Fees: Paid at 100% of the invoice amount issued by BPJPH; any difference arising from the actual assessment is settled by supplementary payment or refund.
- Timeline: Within a maximum of 30 calendar days after payment, the importer/exporter must provide the timing information for the assessment, otherwise the application will be rejected and the fee refunded; the inspection body must carry out the assessment within a maximum of 15 calendar days of receiving this information (extendable by up to 15 days upon application to BPJPH).
- Validity of LPPH: Valid for a single shipment (1 kali pengapalan) only.
VI. Supervision and Administrative Sanctions (Draft Articles 17–21)
- Supervision: BPJPH supervises the implementation of the conformity assessment at least once a year, and may involve relevant authorities.
- Sanctions on inspection bodies: written warning → operational suspension (pembekuan) → revocation of designation.
- Sanctions on importers: written warning, revocation of halal certificate, revocation of registration number, withdrawal of products from circulation, destruction of products, etc.
VII. Entry into Force
Article 25 of the draft provides that this Regulation shall officially enter into force 30 days after its promulgation (publication in the State Gazette of the Republic of Indonesia).
CIRS Reminder
The core impact of this draft on cosmetic exporters is that, going forward, halal cosmetics exported to Indonesia will be subject to an additional "pre-shipment halal conformity assessment" step before import customs declaration: the assessment must be carried out on-site at the warehouse in the country of origin/loading in cooperation with the inspection body, and the LPPH obtained before customs declaration can proceed — adding corresponding time and cost. Please note in particular that even "non-halal" cosmetics (containing forbidden ingredients) must bear a "Non-Halal Statement" and undergo checks such as CoA/CoO/MSDS.
It is recommended that companies exporting cosmetics to Indonesia:
- closely follow the progress of this draft and submit comments within the WTO TBT comment period;
- confirm in advance the halal certification/SHLN registration status of products, and align HS codes and supporting documents;
- establish contact with qualified foreign inspection bodies and allow sufficient time for the pre-shipment on-site assessment, so as not to affect the shipping schedule.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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