A stable formulation is usually not the hardest part of the perfume business. The surprising part comes later, when the bottle is labeled and branded, then offered to others. At that point, your product changes its legal status. It is no longer a personal experiment, but a cosmetic that must have a distribution permit.
Product names follow concentration, not brand preference
The attachment to BPOM Regulation Number 21 of 2022 lists types of fragrance products along with the concentration limits for fragrance ingredients in each category:
- Body fragrance: lower concentration than eau de cologne
- Eau de cologne: 2 to 5 percent
- Eau de toilette: 4 to 10 percent
- Eau de parfum: 7 to 15 percent
- Perfume: 15 to 30 percent
There is also a category of fragrances for babies, which is a formulation for infants and children under three years old. Therefore, product naming is not a marketing decision. A bottle with an 8 percent concentration labeled as perfume falls outside the categories listed in the attachment, while labeling is one of the criteria that must be guaranteed by business actors according to Article 2.
The distribution permit is called notification
Article 4 paragraph (1) requires business actors to distribute cosmetics that have obtained a distribution permit in the form of a notification. Article 6 paragraph (2) limits who may submit it, namely the cosmetics industry in Indonesia, individual businesses or business entities that have production contracts with the cosmetics industry in Indonesia, or importers. All three must have a business identification number.
The consequences are quite strict for formulators working from home. Domestic cosmetic notifications are submitted by the cosmetics industry, and the accompanying documents include a CPKB certificate or a certificate of compliance with CPKB aspects with a remaining validity of at least three months, plus a stamped declaration from the industry leader. Brand owners without factories must take the production contract route to an already certified industry.
A Product Information Document must also be prepared in advance. Article 3 states that the DIP must be owned before making a notification, not compiled afterward. Its contents include data on safety, efficacy, and quality, with specific guidelines in BPOM Regulation Number 17 of 2023.
The deadlines that are easily overlooked
The general provisions of this regulation clarify that the term "day" within it means working days. The following three deadlines use this unit:
- Payment of notification fees must be made no later than 7 days after the Payment Order is issued. Beyond that, the application is considered void according to Article 29 paragraph (5).
- Notification of verification results must be provided no later than 14 days from the issuance of the product ID number.
- Specifically for fragrance product types, that notification must be provided no later than 3 days. Articles 30 paragraphs (3) and (4) indeed exempt fragrances from the general schedule.
The notification number is valid for 3 years and can be extended through renewal, according to Article 45 paragraph (1). Violations of the above provisions are subject to administrative sanctions detailed in Article 51 paragraph (2), ranging from written warnings, revocation of notifications, to closure of online access for notification applications for up to one year.
Changes on the factory side in 2026
BPOM established BPOM Regulation Number 8 of 2026 concerning CPKB Certification on April 21, 2026, replacing BPOM Regulation Number 33 of 2021. According to BPOM's press release, the new regulation eliminates the approval of cosmetic building layouts, standardizes certification service time calculations using clock on and clock off mechanisms, and adds criteria for cosmetic industries in groups A and B.
One of its emphases directly addresses brand owners seeking production partners: industries that obtain certificates of compliance with CPKB aspects are not allowed to accept production contracts. Therefore, when considering potential contract manufacturing partners, the type of certificate held by the partner needs to be reviewed, not just its existence. The renewal of the certificate itself can be submitted no earlier than 6 months before its validity expires.
For those just starting, the sequence that rarely leads to rework is usually the same: establish the concentration and category of the product first, prepare the DIP, then find a production partner whose certificate matches the form of the formulation to be notified. The creative side of formulating fragrances and the compliance side operate on different tracks, and the latter has its own calendar.
Sources
- BPOM Regulation Number 21 of 2022 on the Procedures for Submitting Cosmetic Notifications, Directorate of OTSKK Standardization BPOM
- BPOM Regulation No. 21 of 2022, Directorate of OTSKK Standardization BPOM, explanation of scope and transitional provisions
- BPOM Press Release Number HM.01.1.06.26.174, June 24, 2026: PerBPOM 8 of 2026, Simplifying Cosmetic Licensing for Business Actors
- BPOM Regulation Number 17 of 2023 on Guidelines for Cosmetic Product Information Documents, JDIH BPK
- Artisan Perfume: When Fragrance Becomes a Form of Self-Expression That Can't Be Bought at Any Counter
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- PKKPR: Why This One Permit Can Determine Whether Your Project is Legal or Violates Spatial Planning Laws