Why Your Customer Needs a Cosmetic Ingredient List for BPOM Registration
Learn why Indonesian beauty brands need a product-by-product INCI and formula package before BPOM notification—and how shade and fragrance names should align with labels and production.
An Indonesian beauty buyer recently sent us a straightforward request:
“To help us move forward with BPOM as soon as possible, could you provide the product's ingredient composition?”
Behind that short message is a common launch problem. The buyer does not need one generic ingredient list. The buyer needs a controlled data package for every final product and variant—connected to the exact formula, sample, shade or fragrance name, label and production version.
If those records are prepared only after the packaging artwork is finished, the project may need avoidable corrections. A shade name may not match the notification data. A fragrance version may be connected to the wrong formula. The ingredient list on the box may not match the product that will actually be produced.
The practical goal is therefore not simply to “send the ingredients quickly.” It is to make sure the sample, formula, variant name, notification information, label and bulk-production record all describe the same product.
Important: Indonesia uses a cosmetic notification process, although buyers often call it BPOM registration. This article is a project-preparation guide, not legal advice or a guarantee of BPOM acceptance. The Indonesian notification applicant or regulatory adviser should verify the latest requirements before submission.
The short answer: what should be prepared for each product?
For every final SKU or formula variant, prepare a record containing:
- Brand and working product name
- Product type and intended use
- Internal SKU or variant code
- Approved sample code
- Final formula version and date
- Full ingredient names using INCI nomenclature
- Quantitative concentration of each ingredient for the confidential notification formula
- Function of each ingredient
- Color Index (CI) number for applicable colorants
- Fragrance or flavour material code and relevant allergen information, where applicable
- Final shade or fragrance variant name
- Public label ingredient list
- Packaging format and net content
- Manufacturer-side supporting documents available for that specific product
This is more than an ingredient spreadsheet. It is a product identity record.
The label ingredient list and the notification formula are not the same document
One of the easiest mistakes is to ask a supplier for “the ingredient list” without saying which version is needed.
1. The confidential quantitative formula
BPOM's official cosmetics FAQ says the Notifkos formula template should include the ingredient name and concentration, the function of each ingredient, INCI nomenclature, CI numbers for applicable colorants and quantitative percentages adding up to 100%.
This is sensitive technical information. It should be transferred through an appropriate confidential process to the eligible Indonesian notification applicant or its regulatory adviser—not posted publicly on a product page.
2. The public ingredient list for the label
The public-facing composition normally does not show every percentage. BPOM's FAQ says the composition on the label must match the notified formula and use recognized ingredient naming. Ingredients are generally listed from higher to lower concentration, while ingredients below 1% have more ordering flexibility. Colorants may follow the other ingredients and use CI numbers where applicable.
The same FAQ allows aromatic materials to be identified with terms such as parfum, perfume, fragrance, aroma or flavour. Relevant fragrance-allergen components may also need to be handled in the formula and labelling records.
3. Supporting product documents
Depending on the selected product, formula, manufacturing partner and project, available documents may include an INCI list, MSDS, COA, GMPC-related material, product inspection information or other technical records. These documents must be confirmed product by product. A document available for one formula or factory should not automatically be promised for every SKU.
Why every shade or fragrance needs its own mapping
Suppose a brand plans one lip oil in four shades and three fragrance directions. From a marketing perspective, that may look like one product line. Operationally, it can create twelve shade-and-fragrance combinations.
That does not automatically mean twelve notifications in every situation. It does mean the brand should not assume that one formula file, one ingredient list or one artwork can represent every combination.
BPOM's FAQ uses a lipstick series as an example and treats each color variant as an item for fee purposes. More importantly, different shades can contain different CI colorants or different percentages. Different fragrance versions can also change the composition record.
Before naming or designing the packaging, create a variant matrix:
| SKU | Sample code | Formula version | Shade | Shade code | Fragrance | Fragrance code | Label version |
|---|---|---|---|---|---|---|---|
| LO-01 | SAMPLE-01 | LO-V3 | Petal Pink | 01 | Strawberry Cream | STR-01 | ART-01 |
| LO-02 | SAMPLE-02 | LO-V4 | Rosewood | 02 | White Peach | PCH-01 | ART-02 |
The entries above are only a workflow example. They are not confirmed ZONO formulas, ingredients or fragrances.
How to name cosmetic shades without losing control of the formula
A good shade name helps customers remember the product. A good shade system also helps the factory, brand, designer and notification team identify the same variant.
Use this structure:
Brand + product type + commercial variant name + fixed variant code
For example:
- Lip Oil —
Clear 00,Petal Pink 01,Rosewood 02,Berry Wine 03 - Lip Gloss —
Glass Nude 01,Peach Veil 02,Cocoa Shine 03 - Liquid Lipstick —
Soft Nude 01,Brick Rose 02,Berry Wine 03 - Blush Powder —
Apricot Flush 01,Rose Petal 02 - Liquid Highlighter —
Moon Pearl 01,Champagne Beam 02,Bronze Glow 03 - Mascara —
Black 01,Brown 02 - Eyeliner —
Black 01,Cocoa Brown 02
These are naming concepts, not confirmation that a color, formula or product is available. The final commercial name must be connected to the approved physical sample and its actual formula.
Four naming rules that prevent confusion
- Never reuse one code for two different colors. A creative name can change during branding, but the internal variant code should remain controlled.
- Do not name a shade from a photo alone. Confirm the physical sample under agreed viewing conditions before locking the name.
- Do not use an ingredient as a naming claim unless the formula supports it. BPOM's FAQ says ingredient names used in cosmetic product names should be supported by the notified formula.
- Keep the name consistent across the notification data, label, invoice and production records. Small wording differences can create unnecessary questions during import or document review.
How to name fragrance or flavour variants
For lip products, commercial fragrance directions may include concepts such as:
Strawberry CreamWhite PeachCoffee CandySweet ToffeeUnscented
Again, these are naming concepts—not confirmed fragrance materials or product claims.
The commercial name and the formula information serve different purposes:
White Peachmay be the consumer-facing variant name.PCH-01may be the internal fragrance-material code.Parfumor another permitted term may appear in the public ingredient list.- Specific components or allergens may need to be recorded separately where applicable.
Do not invent a fruit extract, natural origin or functional claim simply because the fragrance smells like a fruit. A “peach” aroma does not automatically mean the formula contains peach extract.
If a product does not need fragrance—for example, a mascara or eyeliner—do not add a fragrance name merely to complete a marketing table. The variant system should reflect the actual product.
The safer workflow before BPOM submission
Step 1: Confirm the Indonesian market at the beginning
Tell the supplier that Indonesia is the target market before formula and packaging decisions are finalized. Include document and notification needs in the initial product brief.
Step 2: Freeze the physical sample and formula version
The brand should approve a clearly coded sample. Avoid approving only from a photo or an informal message. The sample code should connect to the exact formula version.
Step 3: Build one data row for every final variant
List each shade, fragrance, packaging size and product name. Where formulas differ, record them separately. Do not rely on descriptions such as “same as the pink one but a little darker.”
Step 4: Prepare the confidential formula and label list
The manufacturing side should prepare the available ingredient information for the selected formula. The Indonesian notification applicant or regulatory adviser should check the formula against the current BPOM ingredient requirements, including restricted ingredients and the positive lists for colorants, preservatives and UV filters.
As of this article's regulatory review, BPOM's technical ingredient requirements are contained in PerBPOM No. 25 of 2025, which replaced the previous 2019 regulation and its 2022 amendment.
Step 5: Lock shade and fragrance names before final artwork
Map every commercial variant name to its sample code, formula version and artwork number. If the name changes, update the controlled matrix before printing.
Step 6: Cross-check four records
Before submission and again before production, compare:
- notification formula;
- label ingredient list and product name;
- approved sample/formula record;
- bulk-production instruction.
BPOM has publicly reported revoking 21 cosmetic distribution authorizations after finding composition differences between products, notification data and packaging information. The differences included ingredient type, concentration, or both. This is why the final cross-check is a compliance control—not administrative tidying.
Who is responsible for what?
| Party | Main responsibility |
|---|---|
| Brand owner | Select final products and variants; approve names, samples, claims and artwork |
| Indonesian notification applicant/holder | Confirm eligibility, submit the notification and maintain local regulatory responsibility |
| Regulatory adviser | Interpret current Indonesian requirements and review the submission package |
| Supplier/manufacturing side | Provide available formula and product information for the selected version; maintain traceable sample and production records |
| ZONO Beauty | Coordinate the product, formula, packaging and manufacturing-side information available for the specific project |
ZONO does not replace the Indonesian notification applicant and cannot guarantee BPOM acceptance or a fixed approval time. Document availability and regulatory support must be confirmed for each product and manufacturing route.
A copyable request to send to your cosmetics supplier
Subject: Product formula and variant data needed for Indonesia BPOM notification
Please prepare one complete record for every final product and variant. For each SKU, include the product name, product type, sample code, final formula version, full quantitative composition using INCI names, ingredient percentage, ingredient function, CI numbers for colorants, fragrance code and relevant allergen details where applicable, proposed shade or fragrance name, public label ingredient list, packaging format, net content and available manufacturer-side documents. Please also confirm the issue date and the person responsible for the data. Do not combine variants if their composition is different.
This request is more precise than “please send the ingredient list” and reduces follow-up questions.
Frequently asked questions
Can we use one ingredient list for every shade?
Do not assume so. If shades use different colorants or concentrations, they need their own controlled composition records. BPOM's FAQ treats each lipstick color variant as an item in its fee example. Ask the Indonesian notification applicant to confirm the filing structure for the specific product line.
Does the public label need to show every ingredient percentage?
The public label ingredient list and the confidential notification formula serve different purposes. BPOM's Notifkos guidance calls for quantitative percentages totaling 100% in the formula template. The consumer label uses the applicable ingredient-listing order and naming rules.
Can the label simply say “fragrance”?
BPOM's FAQ permits terms including parfum, perfume, fragrance, aroma and flavour. Specific components or allergens may still need to be considered depending on the formula and applicable requirements.
When should we choose the shade or fragrance names?
After the physical sample and variant direction are clear, but before notification data and final artwork are locked. Every name should map to one sample code and formula version.
What happens if the formula changes after submission?
Do not silently use the old ingredient list. Stop and ask the Indonesian notification applicant or regulatory adviser to determine the correct regulatory action before production or import. BPOM's FAQ warns that an incorrect formula submitted after the draft stage may require a new notification.
Can an overseas supplier guarantee BPOM approval?
No supplier should promise a guaranteed result. The supplier can prepare accurate manufacturing-side information. The eligible Indonesian applicant submits the notification and carries the local responsibility, with regulatory review where needed.
Prepare the product identity before preparing the box
The fastest-looking option is often to design the packaging first and request ingredients later. In practice, the more controlled sequence is:
approve sample → freeze formula → map variants → review notification data → finalize label → release production
If you are preparing a private-label makeup project for Indonesia, send ZONO your product list, target market, selected sample or formula code, planned shades or fragrance variants and packaging direction. We can help coordinate the product and manufacturing-side information available for the project before the brand completes its local regulatory review.
Explore ZONO's private-label development process.
Send Your Product and Variant List
Official references
- PerBPOM No. 21 of 2022 — Cosmetic Notification Procedure
- BPOM Cosmetics FAQ — Formula, INCI, CI, names and labelling
- PerBPOM No. 25 of 2025 — Technical Requirements for Cosmetic Ingredients
- BPOM notice on cosmetic composition mismatches
- ASEAN Cosmetic Labelling Requirements
Regulatory information reviewed on 10 August 2026. Requirements can change; confirm the current position before submission.
