Product Compliance
filing/registration/consulting/training
On June 5, 2025, the Indonesian Food and Drug Control Agency (BPOM) released a landmark draft law that specifies the mandatory testing parameters in the analysis certificate (Sertifikat Analisis) submitted for imported cosmetics. The new regulations aim to ensure that cosmetics entering the Indonesian market meet safety and quality standards, and Chinese export companies need to pay immediate attention!
one Quick overview of the core content of the new regulations
Implement background
In response to the surge in cosmetics consumption in the Indonesian market, BPOM has encouraged industry development through simplified marketing authorization (notification system) while strengthening quality control in the import process. The new regulations are formulated in accordance with Article 16, Paragraph 6 of BPOM Regulation No. 27/2022 (revised by No. 28/2023).
Key requirements
Testing items: According to the product category, microbial contamination+specific heavy metals (lead Pb, mercury Hg, arsenic As, cadmium Cd, etc.) become mandatory testing items (see table below for details).
Certificate validity: The test report is only valid for one year from the date of issuance.
Institutional qualification: It must be issued by a manufacturing enterprise or an accredited laboratory.
Batch import simplification: When the same product is imported in different batches, the analysis certificate can only include the dosage form and sensory indicators, except for microorganisms and heavy metals.
two Comparison Table of Key Product Testing Parameters (Partial Summary)
Example of Special Requirements:
Foot care products containing talcum powder (Talk):
Additional measurement of arsenic (As) and zinc (Zinc) in powder:
Extra cadmium (Cd) testing for stage/bridal makeup products:
Must be tested for lead (Pb) and arsenic (As)
two weightOrder productComparison Table of Testing Parameters Partial Summary
Example of Special Requirements
• Containing talc powder(Talk) Foot care products Additional arsenic testing(As)
• Containing zinc(Zinc) The loose powder Extra cadmium testing(Cd)
• Stage/Bridal Makeup Products Lead must be tested(Pb) & arsenic(As)
three Impact on Enterprises and Suggestions for Response
Cost and time increase
The addition of heavy metal testing will extend the testing cycle and increase pre export costs, requiring companies to plan their supply chain in advance.
Compliance risk escalation
Failure to submit a complete parameter analysis certificate by product category will result in the inability to obtain an import license (SKI Border), leading to goods being delayed or returned.
Urgent action recommendations
Immediately verify the product classification: refer to the draft attachment (HS code and category correspondence table) to confirm the testing requirements for the category to which your own product belongs.
Update testing protocol: Confirm with the laboratory whether a report containing specified parameters can be issued in accordance with Indonesian regulations.
Attention Policy Window Period: The draft is open for public consultation until June 10, 2025. Enterprises can provide feedback through the following channels:
Submit link: http://bit.ly/Masukan_ParameterUjiSKI
Email : subdit_standarkosmetik@yahoo.com
The services provided by Zoop
• Account registration service;
• Packaging, labeling, and formula review services;
• Product filing services (review, filing submission);
• DIP review and organization services;
• Product testing services.