Since 2016, ICI has supported more than 1,000 BPOM, Halal, and Medical Device registrations in Indonesia. Our experience shows one consistent truth:
Products that comply with Indonesian regulations will be fully registered — but only if the system behind them is solid.
10 Years Experience / Certification Consulting Expert / Based in Jakarta
Many of our clients ask: ‘Our baby products are dermatologically tested and hypoallergenic. Why do we still need Halal certification?’ or ‘We already have BPOM notification, isn’t that enough?’
In the Indonesian market, safety (BPOM) and religious compliance (Halal) are two different pillars. For products targeting infants or those with sensitive skin, the scrutiny is even higher because the ‘thay-yib’ (purity/goodness) aspect of the product is closely linked to parental trust. With the fast-approaching 2026 deadline, being ‘safe’ is no longer sufficient to remain on the shelves.
Mandatory Halal Enforcement Roadmap for Cosmetics
According to [Government Regulation No. 42 of 2024], cosmetics are categorized under the second phase of mandatory implementation. This includes everything from baby lotions and diaper creams to specialized skincare for sensitive skin.
| Category | Deadline for Mandatory Halal |
| Food & Beverages | October 17, 2024 (Phase 1) |
| Cosmetics & Skincare | October 17, 2026 (Phase 2) |
| Medicines & Medical Devices | 2026 – 2034 (Phased) |
Critical Checkpoints for Baby & Sensitive Skin Products
When we consult on sensitive skin cosmetics, the biggest challenge isn’t just the ‘active’ ingredients. It is the complex additives and the production environment.
- Animal-Derived Stabilizers: Many gentle creams use glycerin or fatty acids. If these are derived from animal fat without a clear Halal chain, the application will be rejected immediately.
- Alcohol Content: While [MUI Fatwa No. 11 of 2018] allows certain types of synthetic alcohol in cosmetics, baby products often claim to be ‘alcohol-free.’ Any discrepancy between your Halal material list and your BPOM label will cause significant delays.
- Cross-Contamination: Even if your ingredients are clean, if the same production line is used for products containing pig-derived collagen (common in some anti-aging lines), you must prove a strict [Syar’i cleaning process] (Disertu).
The Halal Assurance System (SJPH) Requirement
Obtaining a Halal Certificate is not a one-time event. Business actors are required to implement the Halal Product Assurance System (Sistem Jaminan Produk Halal – SJPH) as a continuous compliance framework.
Under current regulations issued by BPJPH, SJPH consists of five mandatory criteria:
1️⃣ Commitment and Responsibility
Top management must establish and sign a written Halal Policy and appoint a Halal Management Team responsible for implementing and maintaining SJPH.
2️⃣ Materials
All materials used in production must be halal-compliant and documented in a verified Halal Material List. Supporting documents such as halal certificates or material specifications must be maintained.
3️⃣ Halal Product Process (PPH)
The entire production process — including purchasing, receiving, storage, formulation, production, cleaning, and distribution — must ensure no contamination with non-halal substances.
4️⃣ Product
The product name, form, and characteristics must not contradict halal principles, and labeling must comply with Indonesian halal regulations.
5️⃣ Monitoring and Evaluation
Companies must conduct internal audits and periodic evaluations to ensure ongoing compliance, including corrective actions when necessary.
FAQ
Q: If my baby lotion uses high-purity synthetic ingredients, is the audit easier?
No, it is not necessarily easier. Even if a material is synthetic, the BPJPH requires proof of its origin and production process to ensure it was not contaminated by najis (impurities) during manufacturing. For baby products, auditors often request more detailed technical specifications for preservatives and fragrances.
Q: Can I put the Halal logo on my packaging as soon as the audit is finished?
No, you must wait. You are only permitted to print the Halal Indonesia logo after the Sertifikat Halal is officially issued by BPJPH. Applying it prematurely based on a successful audit report is a violation that can lead to administrative sanctions
Q: Does ‘Fragrance-Free’ mean it is easier to get Halal?
No, it does not. While it removes one complex ingredient (fragrance), the base emollients and preservatives still require full documentation. In practice, the ‘purity’ requirements for baby products often make the audit more rigorous.
Q: What if our packaging is too small for the full Halal Indonesia label and registration number?
For very small packaging where space is technically limited, specific labeling adjustments may be allowed in accordance with BPJPH regulations. However, the product must still hold a valid Halal Certificate, and labeling requirements must follow the official technical guidelines.
How INSIGHTOF Supports Your Entry
Entering the Indonesian market requires more than just translating documents. We provide:
- Pre-Assessment: We review your full ingredient list (Ingredients/Composition) before you spend a penny on official fees.
- SJPH Setup: We help you draft the Manual SJPH and train your internal team.
- Agency Services: We act as your bridge to BPJPH and the LPH (Halal Inspection Body), handling everything from account registration on SIHALAL to the final audit.
The transition period for cosmetics ends in 2026. For high-trust categories like baby and sensitive skin products, early certification is your strongest marketing tool. Handling this independently often leads to ‘re-submissions’ that waste months of time. Let the experts handle the bureaucracy while you focus on your product.
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