On October 23, 2026, the Head of the Indonesian Food and Drug Authority (BPOM) signed in Jakarta the BPOM Regulation No. 20 of 2026 on the Procedure for Submission of Cosmetic Notifications. The Regulation was published in the State Gazette of 2026 No. 753 on November 3, 2026, and entered into force on the date of publication; the former BPOM Regulation No. 21 of 2022 on the Procedure for Submission of Cosmetic Notifications was simultaneously repealed.
Background
In Indonesia, notification is a form of marketing authorization for cosmetics, referring to the approval granted by the Head of BPOM for an application to circulate a cosmetic after the enterprise has met the requirements for the cosmetic market entry application. Before this revision, the cosmetic notification procedure in Indonesia was governed by BPOM Regulation No. 21 of 2022.
The new Regulation contains 60 articles in total, with 5 annexes, namely:
- Annex I: Table of product types and cosmetic categories (following the ASEAN classification framework)
- Annex II: Format of the summary table for cosmetic manufacturing implementation
- Annex III: Procedure for changes to the data of notification applicants
- Annex IV: Procedure for the issuance of recommendation letters for notification applicants
- Annex V: Priority service mechanism.
Compared with the old Regulation, the new Regulation makes adjustments in the circumstances exempt from notification, notification categories, rules on notifications under the same product name, overseas contract manufacturing, review time limit mechanisms, validity period transition, and administrative sanctions, with some provisions notably tightened.
Main Content of This Revision
This revision can be summarized in eight aspects:
1. The circumstances exempt from notification are expanded from one to three, newly adding domestic cosmetics for research/exhibition purposes and refillable perfumes;
2. The product categories covered by notification are refined into five categories — domestic cosmetics, domestic contract manufacturing, overseas contract manufacturing, imports, and cosmetic sets — and notification for cosmetics exclusively for export is newly added; the scope of the domestic cosmetics industry is further extended to cover the production of intermediate products and the import and repackaging of bulk products;
3. The rule that a single cosmetic product name may only be notified by one applicant is tightened, deleting the exception of "targeting different target markets" under the old Regulation;
4. New substantive conditions are added for notifications of overseas contract manufactured cosmetics, and phased technology transfer obligations are established; existing overseas contract manufacturing notifications must complete adjustment within 12 months;
5. The review time limit mechanism explicitly adopts the "time to respond" mechanism, and the number of clarification responses is limited to a maximum of 3;
6. The sales grace period for cosmetics whose notification has expired without renewal is abolished; products past the deadline are classified as "cosmetics without notification" and prohibited from circulation;
7. After the termination of an agency relationship or a contract manufacturing agreement, the arrangement for consuming remaining stock allowed under the old Regulation is no longer retained;
8. The types of administrative sanctions are expanded from four to seven, and it is clarified that abuse of system access rights, provision of false information, or forgery of documents will lead to the cancellation of the notification.
Circumstances Exempt from Notification
The new Regulation stipulates that enterprises must circulate cosmetics that have obtained notification as a form of marketing authorization, but the following circumstances are exempt from notification:
- Domestic cosmetics used for research and/or exhibition purposes, in limited quantities, not used for market testing, and not circulated within the territory of Indonesia;
- Imported cosmetics entering Indonesia through the special access scheme;
- Refillable perfumes.
All of the above circumstances must comply with the relevant laws and regulations.
Among them, "refillable perfumes" is a newly added exemption in this revision, directly relevant to the compliance path of in-store perfume repackaging/refilling businesses.
Notification Categories and Applicants
The new Regulation classifies the products subject to notification into five categories: domestic cosmetics, domestically contract manufactured cosmetics, overseas contract manufactured cosmetics, imported cosmetics, and cosmetic sets; in addition, cosmetics exclusively for export may also be notified if the destination country requires a BPOM export certificate letter as an import certification document.
The corresponding applicants fall into three categories, all of which must hold the relevant business licenses:
- Cosmetics industries located within the territory of Indonesia;
- Individual business operators/corporate entities that have signed contract manufacturing agreements with domestic cosmetics industries (must obtain a recommendation letter for notification applicants issued by the head of the local BPOM technical implementing agency);
- Importers engaged in the cosmetics business.
Cosmetics exclusively for export may only be applied for by domestic cosmetics industries, individual business operators/corporate entities that have signed contract manufacturing agreements, or domestic industries/affiliated companies conducting overseas contract manufacturing, and are strictly prohibited from circulation within the territory of Indonesia.
Cosmetic sets may be notified in the form of "one inner package containing multiple notified cosmetics" or "one outer package containing multiple notified cosmetics"; the validity period of the set notification follows the notification validity periods of the cosmetics it contains.
Tightened Rules on Notifications under the Same Product Name
The new Regulation makes clear that applicants must ensure that a cosmetic product name (brand name + product name) is notified by only one applicant, with the only remaining exception being "notification by an affiliated company." An affiliated company refers to enterprises that are legally independent of each other but controlled by the same parent company or the same owner, which must be evidenced by a duty-stamped declaration letter that has been notarized (created, certified, or registered).
Compared with the old Regulation, this revision deletes the exception of "targeting different target markets"; marketing under the same product name through different channels will no longer be able to obtain separate notifications.
Overseas Contract Manufacturing: New Conditions and Technology Transfer Obligations
Notifications for overseas contract manufactured cosmetics may only be submitted by domestic cosmetics industries or affiliated companies, and must satisfy one or a combination of the following conditions:
- The production technologies and facilities used are not yet available in Indonesia;
- Centralized production overseas by multinational enterprises with factories in Indonesia, with import and export activities kept in balance;
- Use of ingredients or ingredient combinations with known safety and efficacy.
The new Regulation also establishes phased technology transfer obligations: cosmetics manufactured overseas under contract should gradually become producible within Indonesia; the transfer may cover product development, production technologies and methods/processes, quality control, etc., and may be made to the Indonesian representative office of the overseas industry or to other industries within Indonesia.
As for transitional arrangements, overseas contract manufactured cosmetics notified under the old Regulation must complete alignment with the requirements of the new Regulation within a maximum of 12 months after the publication of the Regulation (i.e., by November 3, 2027).
Validity Period Transition: Prohibited from Circulation Once Expired without Renewal
A notification is valid for a maximum of 3 years and may be extended through renewal (pembaruan); renewal applications must be submitted before the notification expires. The transition rules in this regard are notably tightened:
- Cosmetics whose notification has expired and for which no renewal application has been submitted are prohibited from circulation in Indonesia and are classified under the "cosmetics without notification" category;
- Where a notification expires while a renewal application is being processed, production may continue provided that the CPKB certificate (or the phased CPKB Category A/B certificate of conformity) remains valid, but circulation is only allowed after the renewed notification is issued;
- If a renewal application is submitted only after the notification has expired, a new application must be made under the new notification procedure.
Comparison with the old Regulation: the old Regulation allowed products already on the market to continue circulating for up to 6 months after the notification expired while a renewal or new notification was being processed; the new Regulation abolishes this sales grace period. Meanwhile, the arrangement allowed under the old Regulation — "after the termination of an agency relationship or a contract manufacturing agreement, consuming remaining stock (for up to 6 months) with BPOM approval and the consent of the commissioning party" — is also no longer retained in the new Regulation.
After changes such as the enterprise name and address (including the addition of production facilities at other locations) are approved, products with old labels may still circulate for up to 6 months; this remains consistent with the old Regulation.
Transitional and Implementation Arrangements
The new Regulation enters into force on the date of publication (November 3, 2026) and repeals BPOM Regulation No. 21 of 2022. The transitional arrangements are as follows:
- Notification applications submitted before the entry into force of the Regulation will still be processed under Regulation No. 21 of 2022;
- Notifications issued under the old Regulation remain valid until the expiration of their validity period;
- Exception: existing notifications for overseas contract manufactured cosmetics must complete alignment with the requirements of the new Regulation within a maximum of 12 months.
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