Why October 2026 Is a Hard Deadline for Foreign Brands Under the New BPOM Cosmetic Regulation

If your brand is currently selling cosmetics in Indonesia, there is a regulatory clock counting down in the background. 

The BPOM cosmetic regulation landscape shifted significantly in early 2025, and the ripple effects are reaching foreign brands, local distributors, and importers across Southeast Asia. 

With October 2026 set as the compliance deadline, the window to assess, adjust, and re-notify is narrowing faster than many companies realize.

This guide breaks down exactly what Peraturan BPOM No. 25 Tahun 2025 (PerBPOM 25/2025) requires, which ingredients are under scrutiny, and what practical steps foreign brands can take to stay compliant without disrupting their market presence in Indonesia.

What PerBPOM No. 25/2025 Actually Changes in BPOM Cosmetic Regulation

PerBPOM No. 25/2025 is not a minor update. It represents a comprehensive overhaul of Indonesia’s cosmetic ingredient framework, officially replacing two previous regulations: PerBPOM No. 23/2019 and PerBPOM No. 17/2022. 

Both of those regulations governed which ingredients were permitted, restricted, or prohibited in cosmetic products. The new regulation consolidates and updates the entire annex list, bringing it into closer alignment with the ASEAN Cosmetic Directive (ACD), which serves as the regional benchmark for ingredient safety standards across member states.

This alignment with the ASEAN Cosmetic Directive is significant. It signals that Indonesia is not operating in regulatory isolation. Brands that are already compliant with ACD guidelines may find the transition smoother, but the specific Indonesian thresholds and prohibited lists still require careful review, as they are not always identical to regional standards.

The new regulation covers:

• A revised list of prohibited ingredients (Annex I)
• Updated restricted ingredients with new concentration limits (Annex II)
• Permitted colorants, preservatives, and UV filters (Annexes III, IV, V)

Any product currently notified under the old annexes must be reviewed against the updated lists before the October 2026 deadline.

Ingredients Now Banned or Restricted: What Brands Must Know

This is where many foreign brands will feel the sharpest impact. PerBPOM 25/2025 introduces changes across two categories: outright bans and tightened restrictions.

Newly Prohibited Ingredients (Banned Cosmetic Ingredients Indonesia 2026)

The following ingredients are now fully prohibited under the updated BPOM kosmetik framework:

• Lilial (Butylphenyl Methylpropional): Banned due to reproductive toxicity concerns, mirroring the EU’s earlier action.
• D4 (Octamethylcyclotetrasiloxane): Restricted in EU rinse-off products since 2018; now prohibited in Indonesian cosmetics.
• Styrene: A known carcinogen, no longer permissible in any cosmetic formulation.
• Quaternium-15: A formaldehyde-releasing preservative, now fully banned.

If any of these appear in a product’s ingredient list (INCI), the product is not eligible for renewal under the current notification number. 

Full reformulation is required before the product can re-enter the BPOM e-notifikasi system.

Restricted Ingredients With Updated Limits

Some ingredients remain permitted but with tightened concentration limits. The table below provides a quick reference for brands assessing their formulations:

Ingredient	Old Limit	New Limit	Status
Salicylic acid (leave-on)	2.0%	0.5% (face) / 2.0% (body)	Restricted
Salicylic acid (rinse-off)	3.0%	2.0%	Restricted
BHT (Butylated Hydroxytoluene)	0.8%	0.001% (lip) / 0.8% (others)	Restricted
Benzophenone-3 (BP-3)	10%	6%	Restricted
Resorcinol	0.5%	0.1% (hair dye only)	Restricted
Formaldehyde (nail hardeners)	5.0%	2.5%	Restricted

The salicylic acid BPOM new limit is particularly relevant for brands with acne care, exfoliating toners, and anti-dandruff haircare products, as those categories commonly use salicylic acid at concentrations that may now exceed the permitted levels.

こちらもご覧ください: BPOM Nutri-Level: What Indonesia’s New Food Labeling Regulation Means for Every Food and Beverage Business

How This Affects Your Product Registration

Under Indonesia’s notification system, cosmetics are not “approved” in the traditional sense. They are notified through BPOM’s online platform, which issues a notification number that must appear on the product label. 

This is what consumers and retailers see when they cek BPOM kosmetik (check product status) using the BPOM app or website.

Here is what the regulation change means in practical terms:

• Products with prohibited ingredients cannot be renewed. If the notification expires, the product cannot legally be sold or imported until it is reformulated and re-notified.
• Products with newly restricted ingredients above the new limits must be reformulated and re-notified before the October 2026 deadline.
• Products already compliant with the new ingredient limits can proceed with standard notification renewal, but the safety file and formula declaration must still be updated to reference PerBPOM 25/2025.
• New product notifications submitted after the regulation’s effective date must already comply with the new annexes.

その BPOM e-notifikasi portal is the system through which all notifications, renewals, and amendments are processed. 

Foreign brands typically work through a licensed local responsible person (penanggung jawab) or regulatory affairs consultant to manage this process, as the system requires an Indonesian entity.

What Foreign Brands Must Do Now

The good news: there is still time to act, provided brands begin the compliance process now rather than in 2026. Here is a practical breakdown of the steps involved in achieving cosmetic compliance Indonesia foreign brand obligations under PerBPOM 25/2025.

Step 1: Conduct a Formulation Audit

Pull the full ingredient list for every product currently notified in Indonesia. Cross-reference each ingredient against the new Annex I (prohibited), Annex II (restricted), and relevant Annexes III-V (permitted substances). Flag any ingredient that appears on the prohibited list or exceeds the new concentration limits.

This step requires access to the complete formulation, not just the INCI list on the consumer label. Brands should coordinate with their manufacturing partners to obtain full formula declarations.

Step 2: Update the Safety File

Even for products that pass the formulation audit without issue, the Cosmetic Product Safety Report (CPSR) and safety data file must be updated to confirm compliance with PerBPOM 25/2025. BPOM expects safety documentation to reference the current applicable regulation. Outdated safety files can delay or invalidate the notification process.

Step 3: Re-Notify Through BPOM e-Notifikasi

Products that require reformulation or updated documentation must go through the BPOM e-notifikasi system again. This includes submitting the revised formula, updated safety assessment, and new labeling if concentration declarations or claim statements have changed. 

Processing times for cosmetic notifications in Indonesia typically range from 3 to 14 business days for straightforward submissions, but complex cases or those requiring back-and-forth with BPOM can take longer.

Building in a buffer of at least 6 months before the October 2026 deadline is strongly advisable.

Does This Apply to Your Product Category?

The impact of PerBPOM 25/2025 varies by category. Here is a broad mapping of which product types face the highest risk of non-compliance:

Product Category	Risk Level	Key Ingredients to Review
Skincare (leave-on)	高い	Salicylic acid, BP-3, Lilial, BHT
Suncare	高い	Benzophenone-3, UV filters
Anti-dandruff / scalp care	高い	Salicylic acid, Quaternium-15
Hair color / dye	Medium-High	Resorcinol, formaldehyde
Rinse-off cleansers	Medium	D4, Quaternium-15
Color cosmetics	Medium	Colorants, BHT (lip products)
Nail products	Medium	Formaldehyde (hardeners)
Fragrance	Low-Medium	Lilial, styrene
Baby / sensitive skin	高い	All prohibited ingredients

Brands with products in the high-risk categories should prioritize their audit immediately. Products already near the end of their notification validity period face a compound urgency: the notification renewal deadline and the regulatory compliance deadline could collide.

3-Step Self-Assessment Checklist for Cosmetic Brands

Before engaging a regulatory consultant, brands can run a quick internal check using this three-step framework:

Checklist: Is Your Product at Risk Under PerBPOM 25/2025?

• Step 1 – Ingredient Screen: Does any product contain Lilial, D4, Styrene, or Quaternium-15? If yes, reformulation is mandatory.
• Step 2 – Concentration Check: Does any product contain Salicylic Acid above 0.5% (leave-on face), BHT above 0.001% (lip), or Benzophenone-3 above 6%? If yes, a limit adjustment or reformulation is required.
• Step 3 – Notification Status Check: Do any current BPOM notification numbers expire before or shortly after October 2026? If yes, renewal must be initiated with the updated formulation and documentation.

If the answer to any of these questions is “yes” or “unsure,” a full compliance review is the recommended next step.

How Business Hub Asia Can Help Foreign Brands Navigate This BPOM Cosmetic Regulation Change

For foreign brands, the combination of formulation review, safety documentation, and BPOM e-notifikasi submission can be a significant operational challenge, particularly when managed across time zones and language barriers. This is where having the right partner makes a tangible difference.

Business Hub Asia offers end-to-end support for cosmetic compliance Indonesia foreign brand requirements, including:

• Formulation screening against PerBPOM 25/2025 annexes
• Safety file review and update to align with current BPOM expectations
• Re-notification coordination through the BPOM e-notifikasi platform
• Label compliance review to ensure labeling reflects updated formulations and meets Indonesian labeling requirements
• Ongoing regulatory monitoring so brands are notified of future changes before they become urgent

Whether a brand is managing a single SKU or an extensive product portfolio, the team at Business Hub Asia works directly with local responsible persons and regulatory specialists to streamline the process from audit to approved notification.

The October 2026 deadline is firm. Indonesia’s BPOM has not signaled any intention to extend the grace period, and non-compliant products found in distribution after the deadline could face withdrawal from sale, rejection at customs, or administrative action against the local responsible person.

The window is open. The question is whether brands use it wisely.

Take Action Before the Clock Runs Out

The Indonesian cosmetics market is one of the most dynamic and rapidly growing in Southeast Asia. For foreign brands that have already invested in building a presence here, PerBPOM 25/2025 is not a reason to step back. It is a reason to act decisively.

The brands that will come out ahead are those that treat this regulation not as a compliance burden, but as an opportunity to strengthen their product safety profile and deepen their credibility with Indonesian consumers and regulators alike.

Business Hub Asia is ready to support brands at every stage of the compliance journey, from initial formulation screening to final notification approval. Reach out today for a compliance consultation and ensure your products are ready long before October 2026 becomes a problem.

Contact us to schedule your cosmetic compliance review.