Jun 11, 2025 | Indonesia Issues Regulatory Draft on Cosmetic Test Parameters in Certificates of Analysis for Import Certificate Applications
Indonesia Issues Regulatory Draft on Cosmetic Test Parameters in Certificates of Analysis for Import Certificate Applications

On June 2, 2025, the Indonesian Food and Drug Supervisory Agency (BPOM) introduced a new draft aimed at strengthening the safety and quality oversight of imported cosmetic products. This important update outlines the mandatory test parameters that must be included in Certificates of Analysis (CoA) submitted during the import certification process.
Key Update:
The new guidelines have been issued in accordance with Article 16(6) of BPOM Regulation No. 27/2022 (amended by No. 28/2023) and supported by Presidential and BPOM regulations issued between 2017 and 2025.
Key Requirements for Importers:
-
Border Import Certificate (SKI):
All cosmetic imports must obtain an SKI prior to entering Indonesia.
-
Certificate of Analysis (CoA):
The CoA must be issued by either:
-
The product manufacturer, or
-
An accredited laboratory.
-
Mandatory Test Parameters in the CoA:
The CoA must include testing results for:
-
Heavy metals (including lead (Pb), mercury (Hg), arsenic (As), and other specified metals)
-
Microbial contamination.
-
Batch-Specific Information:
For multiple batches of the same product, the CoA must also specify:
-
Dosage form
-
Organoleptic properties such as appearance, smell, and texture.
-
Cosmetic Categories & Test Parameters:
Product Type |
HS Code |
Required Tests |
Rinse Type |
Notes |
Creams, Lotions, Oils |
3304.99.30 |
Pb, Hg (based on type), Microbial |
Non-Rinse |
Includes day/night creams, moisturizers |
Foot Care Products |
3304.99.30 |
Pb, US metal (if talc), Microbial |
Non-Rinse |
Talc-based products included |
Skin Freshener |
3304.99.90 |
Hg, Microbial |
Non-Rinse |
|
Massage Cream/Oil |
3304.99.30 |
Microbial (oil only Pb & Microbial) |
Non-Rinse |
|
Acne Preparations |
3304.99.20 |
Hg, Microbial |
Non-Rinse |
|
Foundation & Concealers |
3304.99.30 |
Pb, Hg, As, Microbial |
Non-Rinse |
|
Face & Body Powders |
3304.91.00 |
US metal, Microbial |
Non-Rinse |
|
-
Certificate Validity:
Each Certificate of Analysis is valid for one year from the date of issue.
-
Purpose of the Regulation
This decision is intended to:
-
Provide legal clarity and compliance certainty to business actors
-
Ensure consumer safety
-
Enhance BPOM's ability to supervise cosmetic imports effectively.
Effective Date: The decision comes into force on the date of enactment.
We acknowledge that the above information has been compiled from Indonesian Food and Drug Supervisory Agency (BPOM)
Originally published on Global Product Compliance.
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