On October 12, 2026, the Halal Product Assurance Organizing Agency (BPJPH) of Indonesia issued Decree No. 370 of 2026 of the Head of BPJPH on the Guidelines for the Implementation of the Halal Product Assurance System for Cosmetics, which took effect on October 18, 2026.
Background and Scope of Application
Pursuant to Law No. 33 of 2014 on Halal Product Assurance and its implementing Government Regulation No. 42 of 2024, cosmetic products fall within the scope of products subject to mandatory halal certification in Indonesia, and business operators are required to establish and operate a Halal Product Assurance System (SJPH).
BPJPH had already established general SJPH criteria in 2023 by Decree No. 20 of the Head of BPJPH; Decree No. 370 issued on this occasion builds on those criteria and lays down detailed requirements tailored to the cosmetics sector in respect of the origin of materials, production processes and product forms.
The Guidelines apply to business operators, halal supervisors, halal auditors, halal product assurance supervisory personnel and other relevant parties in the implementation of SJPH in the cosmetics field.
Five Key Requirements Established by the Guidelines
1. Establish an SJPH covering the entire product life cycle, make a written halal commitment and put halal supervisors in place.
2. Provide evidence for materials by category of origin, with separate criteria laid down for materials of animal, plant and microbial origin and of chemical and genetic engineering origin.
3. Separate the sites, equipment and utensils used for halal products from those used for non-halal products in the production process, and establish procedures for the purification of najis (impurity).
4. Regulate packaging materials, the use of the halal label and product traceability, and specify how non-conforming products are to be handled.
5. Establish the obligation to conduct an annual internal audit and management review and to report to BPJPH on a regular basis.
Halal Management System and Personnel Requirements
With regard to commitment and responsibility, business operators must make a written halal policy commitment covering the following:
- Providing the human and facility resources needed to support the Halal Product Process (Proses Produk Halal, PPH);
- Complying with the laws and regulations in the field of halal product assurance;
- Using halal cosmetic materials, carrying out PPH and producing halal cosmetics that comply with the regulations;
- Ensuring that the policy is understood and implemented by all personnel within the organization;
- Communicating and disseminating the policy to relevant parties and implementing the policy consistently and on a continuing basis.
In addition, business operators must ensure that sufficient resources are available for the establishment, implementation and continual improvement of SJPH, and must appoint halal supervisors and report them as prescribed.
Material Requirements
For the purposes of the Guidelines, materials cover raw materials, additives, processing aids, other materials that come into direct contact with materials or products on the production line (lubricants, greases, disinfectants, cleaning agents), media used to verify the cleaning of facilities that come into direct contact with materials or products, product packaging materials, and product applicators (where present).
Evidence of the halal status of materials is provided in three ways:
- For materials included in the list of products subject to mandatory halal certification, by a halal certificate or the registration number of a foreign halal certificate;
- For materials falling within the scope exempted from mandatory certification, in accordance with the applicable exemption provisions;
- For materials falling under neither of the above, by the production process flow, product composition, a certificate of analysis (CoA) and other supporting documents, the latter including a statement of freedom from heavy najis, a halal questionnaire, a material safety data sheet (MSDS), laboratory test results and a statement of freedom from animal-derived ingredients.
A foreign halal certificate that has been registered with BPJPH but has since expired may still be used as supporting evidence, provided that the material concerned was produced within the validity period of that certificate. Materials must at the same time meet the requirements on safety, efficacy and quality.
The Guidelines lay down the following criteria according to material origin:
- animal origin
- plant origin
- microbial origin
- chemical, biological and genetic engineering origin
- human origin
- gold microparticles
- other materials
Production Process and Halal Critical Points
Business operators must provide sites, premises and equipment that are separate from those used for non-halal products containing heavy najis, covering the entire process from the receipt of materials to the packaging of products, and must implement this separation at three stages: processing, storage (of raw materials, semi-finished products and finished products) and packaging. Utensils must not be used alternately between halal and non-halal products; cleaning and maintenance tools must be kept separate; storage areas for equipment must also be separated; and written procedures covering the three aspects of materials, processes and products must be established.
The Guidelines also list 11 halal critical points: receipt of materials; verification and sampling; storage and segregation of incoming materials; storage of initial materials; weighing and measuring; processing; semi-finished products; packaging; labeling; storage of finished products; and distribution and transportation.
Requirements for Products, Packaging and Labeling
Products:
- An application must be filed in accordance with the list of products subject to mandatory halal certification;
- The name, form and packaging must not contravene Islamic law or social ethics and public order;
- Products in the shape of pigs or dogs, and packaging or labels containing pornographic, vulgar or obscene content, are not eligible for halal certification;
- Waterproof cosmetic products may still be certified, provided that they meet the SJPH requirements and the relevant fatwas of the Indonesian Ulema Council (MUI).
Packaging:
- Materials containing or consisting of non-halal ingredients must not be used, and the design of the packaging, marks, symbols, names and images must not contravene Islamic law or social ethics and public order;
- Relabeling may only be carried out by the marketing authorization holder registered with the relevant authority, using the same trademark;
- Semi-finished products that have already obtained a halal certificate may be certified under the product category of that material.
Labeling:
- The halal label may only be affixed once the product meets all regulatory requirements, and must be applied to the product packaging and to specific parts of the product, in a position that is easy to see and read and is not readily erased, removed or damaged, with the halal certificate as the basis for its affixing.
- Materials or products of foreign origin may be evidenced by a certificate issued by a foreign halal institution (Lembaga Halal Luar Negeri, LHLN) that has signed a mutual recognition agreement with BPJPH, provided that the Indonesian halal label is also affixed and the registration number of the foreign halal certificate is indicated;
- Where the packaging is too small for the full labeling to be applied, the halal label may be applied to the secondary packaging, a label, the package insert or other media that comply with the labeling provisions of the Indonesian Food and Drug Authority (BPOM);
- Business operators that use materials that are haram or whose production process does not comply with the SJPH criteria must affix a non-halal statement as prescribed.
Traceability:
- Business operators must identify stored materials and products (by date of receipt, storage location, location code, barcode, date of production, etc.), ensure that materials under the same code share the same halal status and that the origin of materials is traceable at every stage, and retain an adequate quantity of retained samples by production batch.
Internal Monitoring and the Obligation to Report to BPJPH
Operators shall perform at least one internal audit and one management review per year, establish relevant procedures and keep records. Internal audit results shall be submitted to BPJPH. Material ingredient lists and/or PPH status shall be filed every six months, with immediate submission upon any ingredient or PPH changes.
Non-conforming products shall be isolated, investigated, risk-assessed and disposed of per procedures, with notification to BPJPH and relevant authorities and recall and halal label control where needed. They shall not be reworked, downgraded or reformulated and claimed as halal. Items unfit for non-halal consumers shall be destroyed. Products already distributed shall be recalled by the operator under BPJPH supervision together with relevant ministries and bodies.
BPJPH, jointly with relevant parties, shall assess the applicability of this Guideline at least once yearly, focusing on on-site practice, technological advances, regulatory changes and workforce competence. Assessment outcomes shall support revision of the Guideline.
Impact on Companies Concerned and Recommendations
Companies concerned are advised to carry out the following work set out below:
- Conduct a gap analysis: review the existing production process against the 11 halal critical points set out in the Guidelines, with a focus on checking whether sampling utensils, weighing utensils and cleaning and maintenance tools are kept separate for halal and non-halal use, and whether cleaning validation has been completed for shared production lines.
- Complete the material evidence dossiers: classify each material according to whether it is of animal, plant, microbial, or chemical and genetic engineering origin; for materials that appear neither on the mandatory list nor on the exemption list, prepare the full set of supporting documents, including the production process flow, the composition, the CoA and a statement of freedom from animal-derived ingredients, and check whether any foreign halal certificate has expired.
- Secure personnel qualifications: overseas companies and medium-sized and large business operators must arrange for their halal supervisors to sit the competency assessment (uji kompetensi) organized by an institution holding the relevant professional certification authority, and must keep records of the training and assessment.
- Review the label design: confirm that the name, form and packaging artwork of the products intended to be placed on the market do not cross the red lines of Islamic law or public order and good morals; for products whose packaging is too small, determine in advance the alternative position for the halal label; and for products intended to bear a non-halal statement, use the format prescribed by the relevant BPJPH provisions.
- Establish a regular reporting mechanism: incorporate the annual internal audit, the management review and the six-monthly submission of the ingredient list into the company compliance calendar, so as to avoid affecting the validity of the certificate through missed submissions.
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