Every cosmetic product imported to Indonesia must first get approval from BPOM (Indonesian Agency for Drug And Food Control). Just like in any other country, right?
There’s just one thing… BPOM considered every variation of a product a separate item. So if you’d want to import a lipstick brand that has brown, red and orange color, you would have to register it as three separate products.
For big brands it means hundreds of cosmetic product (notifikasi kosmetik) registrations.
Now that we gave you an idea of what to expect, let’s look at the process and the preconditions you need to meet before we can start registering your cosmetics in Indonesia.
The decision of whether to approve your cosmetic products or not will be done by BPOM (Indonesian Agency for Drug and Food Control). It’s under the governance of Ministry of Health. Here’s the author of the article together with Minister of Health Ibu Nafsiah Mboi (photo taken in 2009 before she became Minister):
Preconditions before submitting the products
In order to start the process, the company that is going to import the products needs to be verified by BPOM. In order to do so, the following documents need to be presented:
- Company incorporated in Indonesia
- API-U importer license
- Good Manufacturing Process certificate from the producer
- Letter of Authorization from the principal
If the product has been already distributed in other ASEAN countries, add a Letter of Notification of distribution of the products in an ASEAN country. BPOM will take is a strong argument for your products.
Product registration process at BPOM
Once BPOM verifies the importing company, the process of registering products can start. Here is the step by step guide.
1# Requesting notification
You will need to request a notification for every product you want to import. Every SKU is a separate product, so each color or size will have to get its own notification.
2# PNBP payment
BPOM will collect the payment for each of the notification. We will advise you on exact fees once we start working together and see exactly the products you want to import.
3# BPOM notification
BPOM will issue notification 14 working days after the PNBP payment. Once it’s issued, you must import each SKU within 6 months to keep your product registration valid.
The notification will be valid for three years and can be extended.
Common problems with product registrations
If the cosmetic product registration seemed simple then it’s because it actually is so. As long as your documentation is in order, application is done correctly and your product meets the safety and quality regulations.
However, there are reasons that cause your product registration to be delayed or even refused. Here are some real life examples.
Product name is misleading (for BPOM)
BPOM makes sure the products won’t be misleading for Indonesian consumers. For example a company cannot register a cosmetic brand ROSE if the product itself doesn’t have rose as an ingredient. The ingredients will be seen from the COA.
Product is seen as not fitting for the category
A company tried to register skin foundation of color index No. 10006 (pigment green 8). BPOM refused it because No. 10006 is for a short term use while the skin foundation is used for long term. A lipstick of the same color, which BPOM sees as a short term use product, was approved.
If you don’t understand the following example, forward it to your product team and they’ll know what I’m talking about.
As you can see BPOM is thorough and you must be well prepared.
Product registration document (DIP)
For every SKU you are importing you are required to have a product registration document (DIP). BPOM is frequently auditing the importers to make sure they have DIP in order.
DIP can be either in English or in Bahasa Indonesia and include the following information:
- Administration documents and summary of the products;
- Cosmetics ingredients Quality and Safety ;
- Quality data of cosmetics;
- Safety and Usage data of cosmetics.
Strictly regulated based on:
- Cosmetic ingredients which are allowed to use with limitation
- Color index allowed to use
- List of preservatives allowed
Ready to start? Send an email to firstname.lastname@example.org and let us know the products you need to register and whether you already meet all the preconditions or you need us to help with those as well.