On June 3, 2026, Indonesia submitted a Technical Barriers to Trade (TBT) notification (Notification No. G/TBT/N/IDN/187) to the World Trade Organization (WTO), soliciting public comments on its newly drafted “Guidelines for the Implementation of the Halal Assurance System for Cosmetics”. The public consultation period closed on August 2, 2026.
Below is a detailed breakdown of the core requirements outlined in the draft decree to assist cosmetic exporters and industry stakeholders in navigating compliance.
I. Core Definitions and Conceptual Framework
The draft guidelines establish essential definitions governing halal cosmetic compliance:
- Cosmetics (Kosmetik): Any substance or preparation intended for contact with external parts of the human body (epidermis, hair, nails, lips, and external genital organs) or with teeth and oral cavity mucous membranes, primarily for cleaning, perfuming, modifying appearance, correcting body odors, protecting, or maintaining good condition.
- Cosmetic Raw Materials (Bahan Kosmetik): Natural or synthetic ingredients, as well as mixture compounds, utilized as constituents in cosmetics.
- Halal Assurance System (Sistem Jaminan Produk Halal – SJPH): An integrated operational framework established, implemented, and maintained to manage materials, manufacturing processes, finished products, human resources, and procedures to ensure the continuity of Halal Product Processes (PPH).
II. Halal Access Requirements for Cosmetic Raw Materials
Enterprises must possess valid Halal Certificates or equivalent supporting halal documentation recognized by the Halal Product Assurance Organizing Agency (BPJPH). Controlled substances encompass not only active and inactive ingredients but also auxiliary processing inputs:
1. Scope of Controlled Substances
The scope covers raw materials, additives, processing aids, substances on the production line with direct product contact risks (e.g., lubricants, cleaning agents, sanitizers), cleaning validation media, primary packaging, and applicators (if applicable).
2. Animal-Derived Ingredients: Red Lines and Classification
- Prohibited Sources: Ingredients derived from Islamic law-prohibited animals (e.g., swine, dogs) and their derivatives are strictly banned.
- Human-Derived Ingredients: Substances sourced from human body parts (e.g., placenta, blood, hair, urine) and their derivatives are classified as non-halal (Haram).
- Conditional Authorizations:
- Hair, Nails, and Horns: Sourced from non-prohibited animals while living or slaughtered in accordance with Sharia law are halal. If sourced from permissible animals not slaughtered according to Sharia, usage is restricted to cosmetics excluding lips, teeth, and oral mucosa.
- Animal Hides: Leather from permissible animal carcasses is clean following proper tanning and may be used in cosmetics excluding lip and oral applications.
- Animal Placenta: Must originate from living permissible animals. Placenta derived from carcasses not slaughtered via Sharia methods is banned.
- Insects and Snails: Beneficial and non-harmful insects/snails not raised in filthy environments (e.g., garbage) are permitted in cosmetics excluding lips, teeth, and oral mucosa.
- Silkworm Cocoons: Permitted (Mubah) for cosmetic use provided they present no harm.
3. Botanical, Microbial, and Advanced Technology Ingredients
- Botanical Sources: Naturally halal; however, if extraction solvents, stabilizers, or processing aids are introduced during manufacturing, these secondary inputs must hold verified halal status.
- Microbial Sources: Halal status depends on the organism, culture media, additive inputs, and post-fermentation processing aids. Genetically engineered microorganisms containing swine or human genes are strictly prohibited.
- Gold Nanoparticles (Nano Gold): The inclusion of gold particles in men’s cosmetics is permitted provided it complies with Sharia principles and is proven beneficial and non-harmful.
III. Manufacturing Process (PPH) and Facility Sanitation
- Physical Segregation: Production lines, facilities, and processing tools dedicated to halal cosmetics must be physically segregated from non-halal manufacturing lines.
- Contamination Prevention: Manufacturing equipment must never come into contact with severe impurities (Najis Berat), such as swine- or dog-derived components.
- Shared Production Lines: If a production line processes non-halal certified products (that do not contain severe impurities), the enterprise must submit detailed documentation specifying product names, full raw material declarations, processing workflows, and validated cleaning procedures for shared equipment.
- Sanitation Protocols for Severe Impurities: Facilities that come into contact with severe impurities must undergo a 7-stage water wash (including one wash with soil/dust or a validated equivalent cleaning agent). Machines vulnerable to water damage may undergo non-aqueous specialized cleaning until odor and color disappear. Such specialized deep sanitation must be audited by certified Halal Inspection Agency auditors.
IV. The Critical Control Points (Titik Kritis) for Cosmetics
Chapter III of the draft decree outlines critical control points across the cosmetic lifecycle:
- Raw Material Receipt: Verifying packaging, lubricants, cleaning agents, validation media, and applicators to prevent confusion between halal and non-halal items.
- Sampling Verification: Sampling equipment and tools must be strictly separated for halal and non-halal materials.
- Warehousing and Isolation: Storage and isolation areas must be partitioned into designated halal and non-halal zones to prevent cross-contamination.
- Packaging Operations: Packaging areas and packaging materials must be partitioned into halal zones. Containers must be tightly sealed to maintain product integrity.
- Labeling Compliance: Halal labels must be attached or printed in strict accordance with Indonesian statutory guidelines.
- Finished Product Storage, Logistics, and Distribution: End-to-end execution must follow relevant Indonesian legal codes to ensure zero contamination risks across the supply chain.
V. Enterprise Operational and Reporting Obligations
Certified cosmetic manufacturers must maintain ongoing compliance management:
- Halal Management Team: Companies must officially designate and register a Halal Supervisor (Penyelia Halal) with regulatory authorities and are encouraged to establish internal halal operational units spanning suppliers and logistics partners.
- Mandatory Training: Personnel participating in the Halal Assurance System must undergo internal or external halal training at least once per year, with documentation archived.
- Annual Internal Audits: Enterprises must conduct an internal audit and management review at least once per year and report findings directly to the BPJPH.
- Bi-Annual Ingredient Compliance Reporting: Enterprises must submit an updated raw material ingredient list and report any modifications to the Halal Product Process (PPH) to the BPJPH every 6 months.
VI. Halal Labeling Protocols
Once certified, products must adhere to placement rules for the official Indonesian Halal Logo:
- The logo must be placed in a prominent, clearly visible position on the product packaging that is durable and resistant to erasure or damage.
- Products Utilizing Mutual Recognition Arrangements (MRAs):
- Must display the official Label Halal Indonesia accompanied by the registration number of the foreign halal certificate; ou
- Display the Label Halal Indonesia, the foreign registration number, and the recognized foreign certifying body’s logo.
- Small Packaging Exemption: If a cosmetic package is too small to accommodate the printed logo, mandatory halal declarations must be included on the outer carton or enclosed product leaflet.
VII. Effective Date and Enforcement Context
Following formal enactment and official signing by the Head of BPJPH, the decree will enter into force 3 months after its official promulgation date.
With Indonesia’s overarching mandatory halal enforcement deadline for cosmetics taking effect on October 17, 2026, beauty brands targeting Southeast Asian markets should audit raw material origins, establish bi-annual reporting workflows, and verify facility segregation early to ensure seamless market access.
