Complete BPOM Packaging Label Compliance Checklist
The definitive reference for cosmetic packaging label requirements per Indonesian BPOM regulations. Avoid registration rejection by ensuring all mandatory elements are correctly included.
This guide is based on BPOM Regulation No. 23 of 2019 on Technical Requirements for Cosmetic Materials, BPOM Regulation No. 12 of 2020, and Government Regulation No. 80 of 1999 on Product Labeling. Always check the latest regulations on the official BPOM website (pom.go.id) as regulations may be updated.
1. Mandatory Label Elements
Every cosmetic product distributed in Indonesia must include all of the following elements on its packaging label. Missing even one element can cause registration rejection.
Product Name
Clear product trade name that is not misleading. Must match the name registered with BPOM. Must not claim medicinal functions.
Brand Name
Registered trademark. If different from the product name, both must be included.
Net Weight / Volume
Net weight (grams) for solid products or volume (ml/mL) for liquid products. Use metric units. Format: "Net 30 mL" or "Netto 30 mL".
Ingredient List (Ingredients)
Complete list of ingredients using INCI (International Nomenclature of Cosmetic Ingredients) nomenclature, ordered by descending concentration. Preceded by the word "Ingredients:" (see detailed INCI section below).
Manufacture Date
Date or month and year of manufacture. Accepted formats: "MFG 01/2026", "Mfg. Date: Jan 2026", or "Dibuat: Januari 2026". Can be placed on primary or secondary packaging.
Expiry Date / PAO
For products with shelf life under 30 months: expiry date is mandatory (format "EXP MM/YYYY" or "Best before: ..."). For products with shelf life over 30 months: PAO symbol (open jar) with duration in months (e.g., 12M, 24M).
Batch Number / Production Code
Unique code identifying the production batch. Required for traceability in case of quality issues. Free format, typically a combination of letters and numbers that include production date information.
Manufacturer/Importer Name and Address
Full legal entity name and complete address including city and country. For local products: manufacturer name and address. For imported products: manufacturer AND Indonesian importer name and address. Address must be complete enough for location identification.
BPOM Notification Number
Registration number assigned by BPOM after successful product notification. Format: NA + 2-digit year + code + serial number (local products) or NI + 2-digit year + code + serial number (imported products). Example: NA18210100001.
Usage Instructions
Product usage instructions in Bahasa Indonesia. Must be clear and easy to understand. Example: "Apply adequate amount to cleansed face, morning and evening."
Warnings / Cautions
General warnings and specific warnings per product content (see Special Warnings section below). Minimum: "Avoid contact with eyes. Discontinue use if irritation occurs."
Product Purpose / Function
Brief description of product function. Must not claim medicinal functions or mention disease cure. Correct example: "Face moisturizer" not "Cures acne".
2. Label Placement Rules
Information placement on packaging has specific rules that must be observed to ensure regulatory compliance.
Front Panel (Display Panel)
- - Product name and brand name
- - Net weight / volume
- - Product purpose / function
- - BPOM notification number
Back / Side Panel
- - Ingredients list (INCI)
- - Usage instructions
- - Warnings and cautions
- - Manufacturer/importer name and address
Bottom / Crimp / Emboss
- - Batch number / production code
- - Manufacture date (MFG)
- - Expiry date (EXP)
Language Requirements
- - Bahasa Indonesia is MANDATORY for all information
- - Foreign languages may be added as supplement
- - INCI ingredients remain in INCI language (Latin/English)
Small Packaging: If primary packaging is too small to fit all information (e.g., lipstick, sample sachet), complete information MUST be included on secondary packaging (box). Primary packaging must at minimum contain: product name, batch number, and expiry date.
3. INCI Ingredient Listing Rules
The ingredients list is the label element most frequently causing BPOM rejection due to formatting errors. Follow these rules carefully:
Listing Order (Descending Concentration)
- Ingredients are listed from highest to lowest concentration
- Ingredients with concentration below 1% may be listed in any order after all ingredients above 1%
- Aqua (Water) is typically the first ingredient for water-based products
INCI Nomenclature
- Use official INCI names, not commercial or local names. Reference: CosIng database (EU) or PCPC International Cosmetic Ingredient Dictionary
- Botanical ingredients: use Latin genus/species name followed by plant part. Example: "Aloe Barbadensis Leaf Juice" not "Aloe Vera"
- Water: "Aqua" (international INCI standard)
Special Cases
Fragrance / Parfum
Fragrance mixtures may be listed as "Parfum" or "Fragrance" without detailing individual components. However, if containing mandatory declaration allergens (e.g., Linalool, Limonene, Citronellol), each must be listed separately.
Colorants
Colorants are listed using CI Number (Colour Index). Example: "CI 77891" (Titanium Dioxide), "CI 15850" (Red 6). Colorants may be listed in any order at the end of the ingredients list, marked with "+/-" if the product is available in multiple shades.
Nano Materials
Ingredients in nano form must be marked with "[nano]" after the INCI name. Example: "Titanium Dioxide [nano]".
Correct INCI Format Example:
Ingredients: Aqua, Glycerin, Butylene Glycol, Niacinamide, Cetearyl Alcohol, Cetyl Ethylhexanoate, Dimethicone, Sodium Hyaluronate, Tocopheryl Acetate, Aloe Barbadensis Leaf Juice, Parfum, Phenoxyethanol, Ethylhexylglycerin, Disodium EDTA, CI 19140.
4. Special Warnings Required by BPOM
Certain product categories and ingredients require specific additional warnings. Failure to include these warnings is a common cause of rejection.
Products Containing AHA/BHA
Products with Alpha Hydroxy Acid (AHA) such as Glycolic Acid, Lactic Acid, or Beta Hydroxy Acid (BHA) such as Salicylic Acid must include:
Hair Dye Products
Hair dye products containing oxidative dye substances must include:
Products for Children
Cosmetic products intended for children (under 3 years) must include:
Aerosol Products
Products in aerosol/spray form must include safety warnings:
Products with Retinol / Retinoids
Products containing retinol, retinal, or other retinoid derivatives:
Products Containing Fluoride (Toothpaste)
Toothpaste and dental care products containing fluoride:
5. Common Label Mistakes That Cause BPOM Rejection
Based on our experience assisting hundreds of brands, here are the label mistakes that most frequently cause BPOM registration rejection:
Wrong INCI Format
Using commercial names (e.g., "Hyaluronic Acid") instead of correct INCI names ("Sodium Hyaluronate"). Using "Water" instead of "Aqua". Not following descending concentration order.
Missing or Incorrect PAO Symbol
Not including PAO symbol on products with shelf life >30 months. Using wrong format (e.g., "12 months" instead of open jar symbol with "12M"). Including PAO without expiry date on products with shelf life <30 months.
Incomplete Manufacturer Address
Listing only city without street address. Not including country of origin for imported products. Using marketing office address instead of production factory address.
Misleading Claims
Using claims such as "cures acne", "removes wrinkles", or "permanently whitens skin". Claims must be cosmetic in nature, not therapeutic. Use "helps diminish the appearance of" instead of "removes", or "brightens" instead of "whitens".
Missing Specific Warnings
AHA/BHA products without sunscreen warning, hair dye without patch test warning, or children's products without adult supervision warning. Each specific ingredient has mandatory warnings that must not be missed.
Wrong Batch Number Format
Batch number must be permanently printed (embossed, inkjet, or laser printed), not an easily replaceable sticker. Must be traceable to a specific production batch. Format must be consistent across all products.
6. Pre-Submission Label Review Checklist
Use the following checklist to verify every element on your label before submitting registration to BPOM. Check off each verified item.
BPOM Label Checklist
Basic Information
Ingredients & Safety
Manufacturer & Traceability
Format & Readability
Tip: Print the label proof at actual size and apply it to the physical packaging before final approval. This helps identify readability, placement, and sizing issues that are not visible on a computer screen.
Frequently Asked Questions
Answers to common questions about BPOM packaging label compliance
Is the Indonesian language mandatory on cosmetic packaging labels?
Yes, based on BPOM Regulation No. 23 of 2019 and Law No. 24 of 2009 on Flag, Language, and State Emblem, all information on cosmetic packaging labels distributed in Indonesia must be stated in Bahasa Indonesia. Labels may use foreign languages as additions, but Bahasa Indonesia must be present and must be more prominent or at minimum the same size.
What is the minimum font size for information on BPOM labels?
BPOM requires that all label information must be clearly readable. While there is no absolute minimum font size specified in regulations, best practice is to use at minimum 6pt for ingredient lists and 8pt for key information such as product name and warnings. For small packaging (under 30ml), you can refer to information on secondary packaging or include a leaflet.
What happens if my label does not meet BPOM requirements?
Your product registration will be rejected and you must correct the label then resubmit. This process can add 2-4 weeks to your timeline. In more serious cases, products already in circulation with non-compliant labels can be recalled from the market and the company can face administrative sanctions including written warnings, temporary activity suspension, or distribution permit revocation.
Do imported cosmetic products also need to follow the same BPOM label rules?
Yes, all cosmetic products distributed in Indonesia, both locally manufactured and imported, must meet the same BPOM label requirements. For imported products, the label must include the name and address of the importer in Indonesia in addition to the original manufacturer information. Additional sticker labels in Bahasa Indonesia can be applied over the original label, but must not cover the original batch number and expiry date.
How should the BPOM registration number be displayed on the label?
The BPOM registration (notification) number is displayed in the format determined by BPOM, for example: NA18XXXXXXXXX for local products or NI18XXXXXXXXX for imported products. This number must be clearly printed on primary or secondary packaging. Number format: NA/NI (local/import) + 2-digit year + category code + serial number. Ensure the number is permanently printed, not an easily removable sticker.
Do I need to include the PAO (Period After Opening) symbol on all cosmetic products?
The PAO symbol (open jar icon with month number, e.g., "12M") is mandatory on cosmetic products with a shelf life of more than 30 months. For products with shelf life less than 30 months, you must include a specific expiry date. Some products require both. PAO indicates how long the product is safe to use after the packaging is first opened.
What special warnings are required for products containing AHA/BHA?
Products containing AHA (Alpha Hydroxy Acid) or BHA (Beta Hydroxy Acid) must include a warning: "Contains AHA/BHA, may increase skin sensitivity to sunlight. Use sunscreen." or similar BPOM-approved wording. The warning must be in Bahasa Indonesia, clearly printed, and easily visible to consumers. AHA concentration above 10% or BHA above 2% requires additional warnings.
Need Help with BPOM Packaging Labels?
Dermapack's team has experience assisting hundreds of brands in meeting BPOM label requirements. We help from label design to registration-ready packaging.