The National Agency of Drug and Food Control (Badan Pengawas Obat dan Makanan, or “BPOM”), has introduced Regulation No. 18 of 2024 on the Marking Promotion and Advertising of Cosmetics Products (“Regulation 18/2024”). Regulation 18/2024 brings about several revisions and clarifications to the previous regulatory frameworks, particularly to differentiate the mandatory information displayed on regular and refillable products, the applicable language requirements, and available administrative sanctions.
Regulation 18/2024 amends and adds several previous regulations on cosmetic marking such as BPOM Regulation No. 30 of 2020 on Technical Requirements of Cosmetics, BPOM Regulation No. 32 of 2021 on the Supervision of Cosmetic Advertising, and BPOM Regulation No. 12 of 2023 on the Supervision of the Manufacture and Circulation of Cosmetics Products.
Scope of Regular and Refillable Cosmetic Products
Regular cosmetic products as defined by Regulation 18/2024 are materials or preparations intended for use on external parts of the human body such as the epidermis, hair, nails, lips and external genital organs, or teeth and oral mucous membranes, especially to clean, perfume, change the appearance and/or improve body odor, or protect or maintain the body in good condition.
Whereas refillable cosmetics refer to cosmetics that are repackaged into containers according to consumer requests made at Cosmetic refill facilities.
Marking Requirements: Difference Between Regular and Refillable Products
There are several requirements that must be complied both by regular and refillable cosmetic products. A cosmetic product information must be clear and easy to read, and not easily damaged, detached, or faded from the packaging.
Previously, cosmetics markings were regulated under Regulation of the BPOM No. 30 of 2020 on Technical Requirements for Cosmetics Markings (“Regulation 30/2020”). Regulation 18/2024 differentiates between regular and refillable products, with the mandatory information for refillable products being separate from regular products. The mandatory information for both regular and refillable products are summarized in the table below:
| Mandatory Information | Regular Products (Article 3 of Regulation 18/2024) | Refillable Products (Article 7 of Regulation 18/2024) |
| Name of the Cosmetic Product | ✔ | ✔ |
| Relevant Benefits & Uses (exception for obvious benefits & uses of product) | ✔ | |
| User Guide | ✔ | |
| Composition of Product | ✔ | |
| Country of Manufacture | ✔ | |
| Name and detailed address of the holder of the relevant cosmetics notification number | ✔ | |
| Batch Number | ✔ | ✔ |
| Name and Address of Refilling Cosmetics Facility | ✔ | |
| Refill Date | ✔ | |
| Size, Content or Net Weight | ✔ | |
| Expiration Date | ✔ | ✔ |
| Notification Number | ✔ | ✔ |
| 2D Barcode | ✔ | |
| Relevant Warnings and/or Cautions | ✔ |
There are several requirements that must be complied both by regular and refillable cosmetic products. A cosmetic product information must be clear and easy to read, and not easily damaged, detached, or faded from the packaging.
Marking Requirements: Primary and Secondary Packaging
There are two types of packaging for cosmetic products, which includes primary and secondary packaging. Primary packaging refers to packages that have physical contact with the cosmetics. In comparison, secondary packaging refers to a package that protects the primary cosmetics.All mandatory marking requirements for regular products mentioned above must be complied both on primary and secondary packaging.
In the case that a cosmetic product is packaged with primary and secondary packaging, or have limitations in its size and shape, the product must include at least this following information:
- name of the cosmetic product;
- batch number; and
- size, volume, and net weight.
If the primary packaging has limitations in size and shape, the information must also include a hang tag, brochure, display panel, shrink wrap, or other labelling media accompanying the cosmetic product.
Other Marking Requirements
Aside from the mandatory marking requirements mentioned above, there are several requirements that businesses must comply that includes:
- halal label for products that obtain halal certificate; and
- information on origin of cosmetics with certain composition.
Language Provisions of Regulation 18/2024
As regulated in Article 9 of Regulation 18/2024, there are some cosmetic marking information that must be written in Bahasa Indonesia, while some can be written in another language that still must use Latin letters and/or Arabic numerals. The relevant requirements are summarized below:
| Mandatory Information | Must be Written in Indonesian | May Use Other Languages (with Latin Letters and/or Arabic Numerals) |
| Name of Cosmetics | ✔ | |
| Relevant Benefit and Uses | ✔ | |
| User Guide | ✔ | |
| Composition of Product | ✔ | |
| Country of Manufacture | ✔ | |
| Name and detailed address of the holder of the relevant cosmetics notification number | ✔ | |
| Batch Number | ✔ | |
| Size, Content or Net Weight | ✔ | |
| Notification Number | ✔ | |
| 2D Barcode | ✔ | |
| Relevant Warnings and/or Cautions | ✔ |
Specific Requirements for Certain Cosmetic Product
The new Regulation 18/2024 also regulates specific requirements for certain cosmetic products as following:
- sunscreen;
- products containing alpha hydroxy acid; and
- teeth whitening products and/or products that uses hydrogen peroxide.
Non-Compliance Sanction
There are several administrative sanctions that BPOM imposes under Article 21 of Regulation 18/2024 to enforce stakeholders to comply with the new regulations and to ensure consumer safety. These non-compliance sanctions shall be imposed by the Head of the Agency from the cosmetic products. This sanction includes:
- written warnings;
- temporary ban on the distribution of cosmetics for a maximum of 1 (one) year;
- withdrawal of cosmetics from circulation;
- destruction of cosmetic product;
- temporary cessation activities;
- revocation of cosmetic notification; and/or
- public announcement.
Conclusion and Transition Challenges
Regulation 18/2024 represents a significant step forward in ensuring transparency, consumer safety, and accountability within Indonesia’s cosmetic industry. By distinguishing between regular and refillable cosmetic products, standardizing mandatory marking requirements, and reinforcing language provisions, the regulation seeks to provide consumers with clear and reliable product information while holding businesses accountable.
The introduction of specific labelling requirements for certain cosmetic products, such as sunscreens and teeth whitening products, further strengthens consumer protection by addressing potential health concerns. Additionally, the enforcement of administrative sanctions underscores BPOM’s commitment to regulatory compliance and product integrity.
All cosmetic businesses that have pre-existing cosmetics notification numbers must comply with Regulation 18/2024 within 12 months, which stands as 15 November 2025.
While the transition to full compliance by November 2025 poses challenges for cosmetic businesses, early adaptation will be crucial in avoiding potential penalties and ensuring seamless market operations. Ultimately, adherence to these new guidelines will foster greater consumer trust, enhance industry standards, and align Indonesia’s cosmetic sector with international best practices.
Should you have any inquiries related to this regulation or wish to ascertain its impact on your business or personal interests, please feel free to contact us.
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