Prohibited Ingredients in Cosmetics Indonesia (BPOM Full List)

One of the most common reasons a cosmetic product fails BPOM notification in Indonesia is ingredient non-compliance. Whether the issue involves a prohibited substance, a restricted ingredient used outside permitted limits, or a colorant not approved for cosmetic use, formula problems can delay or block market entry entirely — even when every other part of the submission is in order.

Indonesia’s cosmetic ingredient framework is primarily governed by BPOM regulations, which incorporate and adapt international standards — including references from ASEAN Cosmetic Directive annexes — into the local regulatory context. Brands entering the Indonesian market, whether domestic or imported, need to verify their formula against these rules before submission, not after.

This article covers the key categories of prohibited and restricted ingredients under BPOM’s cosmetic framework, explains why ingredient review is a critical pre-submission step, and outlines what brands should do to reduce compliance risk. For the full registration process, refer to Cosmetic Registration Indonesia.

1. Introduction

BPOM, Indonesia’s National Agency of Drug and Food Control, sets the rules on which ingredients may and may not be used in cosmetic products sold in Indonesia. These rules are structured around several regulatory annexes that mirror the ASEAN Cosmetic Directive framework, adapted to Indonesia’s national requirements.

At the core of this framework is a distinction between three types of ingredient status: prohibited substances that may not be used at all, restricted substances that may only be used within specific conditions or concentration limits, and permitted substances such as colorants, preservatives, and UV filters that must appear on approved lists to be used in cosmetics.

2. What Are Prohibited Ingredients Under BPOM Rules?

Prohibited ingredients are substances that BPOM does not allow to be present in cosmetic products at any concentration for any intended use. These prohibitions are based on safety assessments and align, in most cases, with the ASEAN Cosmetic Directive Annex II, which lists substances that must not form part of the composition of cosmetic products.

The prohibited list is extensive and covers a wide range of chemical categories. Some substances are prohibited because of known carcinogenic, mutagenic, or reproductive toxicity concerns. Others are banned due to sensitization risks, endocrine disruption potential, or because they belong to drug categories that should not be present in cosmetics.

Examples of Substance Categories Commonly Found on the Prohibited List

• Certain heavy metals such as mercury compounds and lead acetate
• Halogenated salicylanilides and related antibacterial agents
• Steroids and hormonal substances not permitted in cosmetics
• Substances classified as CMR (carcinogenic, mutagenic, or reprotoxic) under applicable safety assessments
• Certain aromatic amines and nitrosamines
• Substances that function as pharmaceutical active ingredients and are not permitted in the cosmetic category

3. Key Categories of Prohibited Substances

While the full prohibited list runs to hundreds of entries, the substances that most commonly create problems for brands entering Indonesia can be grouped into several practical categories. Understanding these categories helps brands prioritize which parts of their formula to review first.

4. Restricted Ingredients: A Separate Consideration

Separate from the prohibited list, BPOM also maintains a list of restricted substances — ingredients that are permitted in cosmetics but only under specific conditions. These conditions typically include maximum concentration limits, restrictions on the product type or application area, mandatory warning statements on the label, or limitations on the target consumer group.

Restricted ingredients are often a more complex compliance challenge than outright prohibited substances, because the ingredient itself is not banned — the issue is whether it is being used within the permitted parameters. A brand may unknowingly exceed concentration limits, omit a required warning statement, or use an ingredient in a product type for which it is not approved.

Examples of Common Restricted Ingredient Conditions

• Maximum concentration limits for preservatives such as certain parabens or formaldehyde-releasing agents
• UV filter substances permitted only up to specified percentages in sunscreen formulations
• Alpha-hydroxy acids (AHAs) subject to concentration and pH restrictions
• Fluoride compounds permitted in oral care products within defined limits
• Certain hair dye intermediates restricted to professional use only, with mandatory label warnings

5. Why Formula Review Matters Before BPOM Notification

Formula compliance is not just a documentation requirement — it directly affects whether a product can legally be sold in Indonesia. BPOM reviews the ingredient composition as part of the cosmetic notification process, and products with formula issues may be rejected or require resubmission after correction.

For imported products, formula review becomes even more critical because reformulating after products have already been manufactured and shipped is both costly and logistically difficult. Identifying ingredient issues before production or importation allows brands to make adjustments at the right stage of the supply chain.

What a Pre-Submission Formula Review Should Cover

• Check all ingredients against the BPOM prohibited substance list
• Verify restricted ingredients against permitted concentration limits and conditions of use
• Confirm that any colorants, preservatives, and UV filters appear on the relevant BPOM positive lists
• Identify any mandatory warning statements required for restricted ingredients and reflect them on the label
• Review INCI nomenclature for consistency with what will be submitted in the notification dossier

6. Common Mistakes Brands Make With Ingredient Compliance

Many compliance issues involving prohibited or restricted ingredients are avoidable. They typically stem from assuming that approval in one market implies approval in another, failing to check ingredient status against the current BPOM-specific annex, or not identifying the full implications of restricted ingredient use — including label requirements.

Another frequent issue involves multi-functional ingredients — substances that might be used as both a cosmetic ingredient and a pharmaceutical active in different product types. In Indonesia, the classification of the product determines which rules apply, and brands should not assume that the cosmetic framing alone resolves any underlying ingredient concerns.

Most Common Ingredient Compliance Errors

• Assuming EU or US INCI compliance is sufficient for Indonesia
• Using a colorant that is approved in the home market but not listed in BPOM’s permitted colorant annex
• Including a preservative above its BPOM-permitted maximum concentration
• Omitting mandatory warning statements for restricted ingredients on the Indonesian label
• Not updating the formula compliance check after BPOM issues a new regulatory amendment
• Using outdated annex versions that do not reflect the most recent BPOM updates

7. How to Check Ingredient Status Before Submission

The primary reference for checking ingredient status in Indonesia is the regulatory annex published by BPOM, which is aligned with the ASEAN Cosmetic Directive. Brands and their regulatory consultants can use these annexes — covering prohibited substances, restricted substances, permitted colorants, permitted preservatives, and permitted UV filters — as the baseline for any formula compliance check.

For practical purposes, the most reliable approach is to conduct a line-by-line ingredient review against the applicable BPOM annexes before preparing the notification dossier. This review should cover not just the main actives, but also functional ingredients such as preservatives, emulsifiers, solvents, and colorants, which are sometimes overlooked but are equally subject to ingredient compliance rules.

Recommended Steps for Ingredient Compliance Review

• Obtain the full INCI ingredient list from the manufacturer
• Cross-reference each ingredient against the current BPOM prohibited and restricted substance annexes
• Check colorants, preservatives, and UV filters against the relevant BPOM positive lists
• Verify that any restricted ingredient concentrations fall within permitted limits for the specific product type
• Identify any required label warnings and incorporate them into the Indonesian label design
• Document the compliance review as part of the Product Information File

8. Conclusion

Ingredient compliance is one of the most foundational — and most frequently underestimated — parts of entering the Indonesian cosmetics market. A product that is compliant everywhere else in the world can still fail BPOM notification if it contains a prohibited substance, uses a restricted ingredient outside permitted conditions, or relies on a colorant or preservative not listed in BPOM’s approved annexes.

The safest approach is to treat formula compliance as a non-negotiable pre-submission step — not something to assess after the dossier is already being prepared. When ingredient issues are identified early, brands have the option to adjust formulas, update labeling, or reassess product positioning before committing to a full notification submission.

For the complete picture of how cosmetic notification works in Indonesia — including applicant structure, document requirements, and the step-by-step process — refer to Cosmetic Registration Indonesia.

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