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To promote waste reduction and encourage sustainable consumption, refillable cosmetics are gaining popularity as an environmentally responsible choice among beauty consumers in Indonesia. By reducing reliance on single-use packaging, these products contribute to lowering plastic waste and support Indonesia’s national environmental sustainability objectives.

This article presents a comprehensive summary of Indonesia’s regulatory requirements for refillable cosmetics, covering key aspects such as product definitions, eligible cosmetic categories, sales and application provisions, labeling obligations, and the developing regulatory framework for refillable perfume products.

1. Definition

1.1 Refillable Cosmetics Refillable cosmetics refer to cosmetic products that are dispensed or repackaged into containers at a designated cosmetic refill facility upon a consumer’s request. Such refill facilities may be operated either by the product notifier itself or by another cosmetic business entity working in collaboration with the notifier.

1.2 Refillable Perfumes Refillable perfumes represent a distinct subset of refillable cosmetics. These products are formulated on-site at refill facilities by blending fragrance concentrates with solvents in accordance with individual consumer requests. To address this category, Indonesia has issued a draft regulation specifically governing refillable perfume products.

2. Permitted and Prohibited Product Categories

Only the following product classes may be manufactured and distributed as refillable cosmetics:

· Liquid bath soap

· Liquid antiseptic bath soap

· Liquid hand soap

· Shampoo

· Anti-dandruff shampoo

· Hair conditioner

Baby cosmetics are explicitly prohibited from being manufactured or distributed in refillable form.

3. Existing Regulatory Framework

Indonesia regulates refillable cosmetics through multiple instruments addressing production, distribution, licensing, labeling, and online sales. Key regulations include:

4. Compliance Requirements for Refillable Cosmetics

4.1 Sales Application Requirements Before any refillable cosmetic product may be sold, the notifier or refill facility operator must obtain approval from BPOM. BPOM will evaluate the submission for safety, efficacy, and quality.

The sales application must include:

· A proposal to sell cosmetics at the refill facility, in accordance with applicable regulations;

· The valid notification number(s) of the cosmetics to be refilled;

· Details of the refill facility to be used;

· A cooperation agreement, if the sales are conducted by a business entity other than the notifier.

· Eligibility Criteria

· To qualify for approval, the notifier or refill facility operator must ensure:

· Only cosmetics with valid notification numbers are refilled;

· A compliant cosmetic refill facility is available for use;

· A cooperation agreement is in place where applicable;

· Adequate sanitation and hygiene measures are implemented;

· Required technical documentation is maintained;

· Sufficient storage facilities are provided.

4.2 Labeling Requirements Refillable cosmetics must comply with the foundational labeling principles established by BPOM:

1. Completeness: All mandatory information must be provided;

2. Objectivity: Claims must accurately reflect product properties and efficacies and must not deviate from safety standards;

3. Non-misleading presentation: Labels should provide honest, accurate, and accountable information, avoiding exploitation of public health concerns;

4. No drug-like claims: Labels may not imply pharmacological effects or disease prevention;

5. Clarity and legibility: Information must be clear and easily legible;

6. Durability: Labels must remain intact, legible, and undamaged, avoiding easy separation and fade from the packaging.

7. Draft Regulatory Requirements for Refillable Perfumes On September 2, 2022, BPOM released a draft regulation specifically addressing refillable perfumes. Under the draft, manufacturers of refillable perfume products must ensure compliance with applicable Technical Requirements for Cosmetic Ingredients and the detailed requirements defined under the Guideline for Cosmetic Good Manufacturing Practice.

5.1 Manufacturing Requirements The draft regulation introduces requirements in six key areas:

1. Factory design and manufacturing facilities

2. Ingredients and packaging materials

3. Environmental sanitation

4. Storage conditions

5. Documentation

6. Labeling

5.2 Permitted Ingredients

5.3 Documentation Requirements Manufacturers must maintain at least the following:

· Procurement documents for ingredients and packaging materials

· Inventory records or stock cards for ingredients and packaging materials

· Manufacturing records (product name, manufacturing date, composition/formula, batch number)

· Sales records

5.4 Packaging Requirements Packaging materials must:

· Be inert and non-reactive with perfume ingredients;

· Be cleaned before use;

· Not be washed with methanol;

· Be supplied either by the manufacturer or provided by consumers.

Note: These requirements are contained in a draft regulation and are subject to change upon final issuance.

6. Other Regulatory Obligations

1. Refillable perfumes are exempt from product notification requirements;

2. Refillable cosmetics may not be sold online under BPOM's e-commerce control regulation;

3. Under the 2023 draft Regulation on Cosmetic Adverse Reaction Monitoring, notifiers must report adverse reactions associated with refillable cosmetics.

Indonesia’s regulatory regime for refillable cosmetics is continuing to evolve as authorities work to align environmental sustainability objectives with the protection of consumer health and safety. Businesses planning to manufacture or market refillable cosmetic or perfume products in Indonesia should carefully track ongoing regulatory updates—especially the anticipated finalization of refillable perfume rules while maintaining strict compliance with product approval, facility standards, labeling, and operational requirements.