In November 2026, the National Agency for Drug and Food Control of Indonesia (BPOM) released the draft revision of the Regulation on the Supervision of Cosmetic Manufacturing and Distribution for public comment, with feedback due by November 20, 2026.
The draft brings refill cosmetics and refill perfume under the supervision of manufacturing and distribution for the first time; once officially issued, it will replace the current Regulation on the Supervision of Cosmetic Manufacturing and Distribution (BPOM Regulation No. 12 of 2023).
Background of the Revision
BPOM stated that the current Regulation No. 12 of 2023 does not yet provide for the supervision of refill perfume or for good distribution practices for cosmetics, and that the regulation therefore needs to be comprehensively revised.
The draft contains 4 chapters and 29 articles in the main body, with 3 attachments:
- Proposal format for applications to sell refill cosmetics (Attachment 1)
- Guidelines on good manufacturing practice for refill perfume (Attachment 2)
- Report form for cosmetic production, importation, and distribution (Attachment 3)
Refill Cosmetics
Definition
According to the draft, refill cosmetics refer to cosmetics that are repackaged into containers at a cosmetic refill facility upon consumer request.
Specific Requirements
Notification number holders or refill facility operators that intend to carry out refill distribution at a cosmetic refill facility must obtain BPOM approval in advance, submit an application proposal in the format given in Attachment 1, and meet the following conditions:
- the cosmetics to be refilled have obtained notification numbers;
- the facility meets the corresponding requirements;
- if the refill distribution is carried out by an operator other than the notification number holder, a cooperation agreement on the refill distribution of cosmetics must also be submitted.
Permissible Categories, Labelling and Storage Rules for Refilled Cosmetics
The draft specifies that only 6 categories of cosmetics may be produced and distributed in refill form: liquid body soap, antiseptic liquid body soap, liquid hand soap, shampoo, anti-dandruff shampoo, and conditioner; baby cosmetics are prohibited from being manufactured and distributed in refill form.
Refill cosmetics must be labeled on the refill containers with the relevant information as required, and must be stored in their original packaging.
Refill Perfume
Definition
Refill perfume refers to a perfumery cosmetic that is prepared on-site by mixing fragrance concentrate (with or without a solvent, in a specified formulation ratio) according to the personal use needs of consumers who come to the store in person.
Specific Requirements
Attachment 2 of the draft sets out the good manufacturing practice for refill perfume, covering 6 aspects: premises design and production facilities, raw materials and packaging materials, sanitation and hygiene, storage, sales and labeling, and documentation.
The draft sets out 8 prohibited acts for refill perfume facility operators:
- producing refill perfume in aerosol form;
- using denatured alcohol with a methanol content exceeding 5% of the total content of ethanol and isopropyl alcohol as the solvent;
- using methanol to clean equipment;
- storing refill perfume stock ready for direct distribution;
- selling refill perfume using the labels of other cosmetics that have obtained notification numbers;
- distributing refill perfume through online channels;
- filling more than 100 mL at a time;
- accepting or using packaging materials that already bear the labels of other products.
In addition, each consumer may purchase no more than 3 pieces.
Labeling Requirements
The label of refill perfume must indicate the product name (including the word “parfum” and the product code as the product variant), the production date, the net content, and the name and city of the production facility.
Implementation Arrangements
Once the draft is officially promulgated, the current Regulation No. 12 of 2023 will be repealed at the same time, and the new regulation will take effect on the date of promulgation.
Existing refill perfume facility operators must complete compliance adjustments within 12 months after the promulgation of the regulation; the draft does not set a transition period for cosmetic refill facilities.
CIRS Reminder
The refill business model has grown rapidly in Indonesia's beauty retail sector. This revision brings refill cosmetics and refill perfume under regulation for the first time: refill operations must be approved by BPOM, the products to be refilled must have obtained notification numbers, the refillable categories are limited to 6 wash-and-care product categories, refill perfume may not be sold online, purchases are limited to 3 pieces per consumer, and a single filling must not exceed 100 mL.
Notification number holders, importers, and distributors that are conducting or planning to conduct such businesses in Indonesia should review their business models against the draft.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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