New Regulatory Draft on Cosmetic Test Parameters in Certificates of Analysis for Import Certificate Applications

Date
11 Jun 2025

Certification Cosmetic Products Regulatory Updates Test methods BPOM Indonesia Cosmetic Regulations

GPC - Global Product Compliance

New 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) has introduced a new draft aimed at strengthening the safety and quality oversight of imported cosmetic products. This important update outlines mandatory test parameters that must be included in Certificates of Analysis (CoA) submitted during the import certification process.

Key Update:

The new guidelines are 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 spanning from 2017 to 2025.

Key Requirements for Importers:

  1. Border Import Certificate (SKI):

All cosmetic imports must obtain an SKI prior to entry.

  1. Certificate of Analysis (CoA):

The CoA must be issued by either:

  • The product manufacturer, or
  • An accredited laboratory.
  1. Mandatory Test Parameters in CoA:

The CoA must include testing results for:

  • Heavy metals (including Lead (Pb), Mercury (Hg), Arsenic (As), and other specified metals)
  • Microbial contamination
  1. 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
  1. 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

 

  1. Certificate Validity:

Each Certificate of Analysis is valid for one year from the date of issuance.

  1. 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 effectively supervise cosmetic imports.

Effective Date: The decision comes into force from the date of enactment.