On July 12, 2024, the Indonesian Food and Drug Authority (BPOM) officially introduced the updated Notifkos cosmetic notification system. The Notifkos 3.0 system was fully opened to enterprises on January 2, 2025, and is now officially in operation. The new 3.0 system features multiple updates and newly added functionalities.
Notifkos 3.0 Feature Updates
- Simplified A-Window (Enterprise Verification) and B-Window (Enterprise Data Update) Processes: Enterprises no longer need to queue for a number or send emails for appointments. They can update their data independently. After submitting the completed template, reviewers will conduct the verification directly within the system;
- Full Integration with OSS: The new system expands cosmetic notification services, covering all new applications, updates, and modification notifications;
- Simplified Enterprise/Factory Modification Process: Enterprises no longer need to queue in person. Fees are calculated solely based on the enterprise/factory modification application. Additionally, the system will automatically apply the modification to all related products;
- Direct Submission of Product Deregistration Requests: Enterprises can now submit product deregistration requests directly within the system;
- New Feature for Packaging Updates and Modifications for Export-Only Products; and
- New Notification and Supplementary Information Function for Packaging Information Changes
ASEAN Cosmetic Regulations and Indonesia’s Cosmetic Notification System
(I) ASEAN Cosmetic Directive (ACD)
The Association of Southeast Asian Nations (ASEAN) consists of ten member countries: Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand, and Vietnam. On September 3, 2003, ASEAN member states signed the Agreement on the ASEAN Harmonised Cosmetic Regulatory Scheme (AHCRS), which includes the ASEAN Cosmetic Directive (ACD). The directive aims to ensure the safety, quality, and efficacy of cosmetics sold within ASEAN while eliminating trade barriers among member states. Since January 1, 2008, ASEAN member countries have fully implemented the ACD. The directive establishes lists of prohibited, restricted, and permitted ingredients and sets out specific requirements for cosmetic classification, labeling, claims, product notification, and the Product Information File (PIF).
ASEAN has not achieved unified cosmetic product regulation. Before being marketed in each ASEAN member state, cosmetic products must undergo separate notification processes in each country. Regulatory oversight is conducted by the respective national cosmetic regulatory authorities, primarily focusing on post-market surveillance.
(II) Product Notification
In ASEAN countries, product notification is submitted through an online system, and an administrative fee is required. While the required documentation varies by country, it generally includes information on the manufacturer/brand owner, local applicant, and product details. After submission, the respective regulatory authority conducts a basic review and provides feedback, which may include approval, requests for additional information or modifications, or rejection. The notification approval issued by the regulatory authority must be presented to local customs authorities during product importation.
Product notification must be carried out by a locally registered company, which serves as the notification holder. In some countries, the notification holder is also responsible for ensuring the quality and safety of the product. Additionally, product notifications have a validity period, and if the product is to remain on the market after expiration, the notification must be renewed in advance. Similarly, if there are changes to the manufacturer or product details, the notification information must be updated through the online system.
(III) Indonesia Cosmetic Notification
1. Cosmetic Notification Process
(1) Company Account Registration (Notifkos System)
Administration Requirement | ||
Local Company | Importer | Contract Manufacturer |
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(2) Cosmetic Notification
- Application Fees:
Products manufactured in non-ASEAN countries: 1,500,000 IDR;
Products manufactured in ASEAN member countries: 500,000 IDR.
- Validity Period:
The notification number is valid for 3 years. Upon expiration, the applicant must renew the notification; otherwise, the product can no longer be legally sold.
- Processing Time:
The entire notification process takes approximately 3–4 months.
2. Responsibilities of the Product Notification Holder
According to Indonesian cosmetic regulations, the product notification holder has the following responsibilities:
- Ensure the manufacturer produces safe products, establishing a robust system to guarantee product safety and compliance with ASEAN Good Manufacturing Practice (GMP) requirements.
- Collect post-market usage information and promptly communicate relevant data to the manufacturer.
- Appoint qualified personnel to handle product complaints and recalls.
- Maintain the Product Information File (PIF).
- Report any Serious Adverse Events (SAEs) to the relevant regulatory authorities.
(IV) Draft Regulation on Indonesian Cosmetic Notification
On December 10, 2024, the Indonesian Food and Drug Authority (BPOM) released a draft regulation on cosmetic notification. The key contents of the draft regulation include:
- Addition of new definitions for "Licensed Cosmetic Manufacturing" and "Bulk Products."
- Scope of applicants for cosmetic notification: Domestic cosmetic manufacturers in Indonesia, Distributors of domestic cosmetics and Importers of foreign cosmetics.
- Required documents for cosmetic notification: For imported cosmetics from non-ASEAN countries, a Certificate of Free Sale (CFS) and a GMP certificate issued by an authorized official or recognized institution in the country of origin must be provided.
- Notification procedures, templates for filling out notification information, official online review process and on-site inspection requirements, etc.
About CIRS
CIRS can provide a professional one-stop service covering the whole life-cycle of a personal care product, which includes cosmetic ingredient development, physical/chemical tests, toxicological tests (in vivo & in-vitro), efficacy studies (in vivo & in-vitro), ingredient registration, and product registration.
The services items cover:
Regulatory Compliance Services
- China: Compliance Consulting for Cosmetics and Ingredients;
- Globally: Compliance Consulting for Cosmetics (EU, UK, US, Japan, South Korea, Australia & New Zealand, ASEAN, Middle East, Mexico, Brazil, and Africa); and
- Compliance Consulting for Disinfectants and Household Products.
Data Services
- China: Cosmetics and Ingredients Data Services (China CosIng); and
- Globally: Cosmetics and Ingredients Data Services covering China, EU, UK, North America, ASEAN, Japan, and South Korea (Global CosIng).
Product Testing Services
- Cosmetic Safety and Human Efficacy Testing;
- Toxicological Safety Assessment for Cosmetic Ingredients; and
- In Vitro Efficacy Testing for Cosmetics and Ingredients
If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.
Further Information
https://registrasi.pom.go.id/announcement/detail/319/highlight-fitur-sistem-aplikasi-notifkos-baru
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