The cosmetic industry in Indonesia continues to experience strong growth, driven by increasing demand for skincare, personal care, and beauty-lifestyle products. Within this dynamic business landscape, cosmetic toll manufacturing (contract manufacturing) has emerged as a strategic solution that enables companies to accelerate innovation, reduce capital expenditure, and expand product portfolios without building their own production facilities.

As a pharmaceutical and cosmetic manufacturer operating since 1965, PT Galenium Pharmasia Laboratories provides contract manufacturing services that fully comply with BPOM regulations, CPKB standards, and the evolving needs of modern brand owners.

1. Regulatory Framework for Cosmetics and Contract Manufacturing in Indonesia

1.1 CPKB — Good Manufacturing Practices for Cosmetics

• Cosmetic manufacturing facilities that produce on a contract basis must hold a valid CPKB (Cara Pembuatan Kosmetika yang Baik) certificate.
• CPKB certification is a mandatory requirement for any factory to legally manufacture cosmetic products in Indonesia.

1.2 Cosmetic Notification (NIE / NA-BPOM)

• All cosmetic products distributed in Indonesia must undergo the Notification process with BPOM prior to market release.
• The Notification scheme is regulated under BPOM Regulation No. 12 of 2020 on Procedures for Filing Cosmetic Notifications.
• Once approved, the brand owner receives a Notification Number (Nomor Notifikasi), which serves as the legal authorization for product distribution.

1.3 Updated Regulations: Labeling & Cosmetic Safety

• Recent regulations, such as BPOM Regulation No. 18 of 2024 on Cosmetic Labeling, Promotion, and Advertising, establish requirements for claims, labels, and mandatory information on cosmetic packaging.
• All cosmetic products must comply with safety standards, quality requirements, and the allowed/restricted/prohibited ingredients listed in BPOM’s cosmetic ingredient regulations.

Regulatory Summary

To legally manufacture and distribute cosmetic products in Indonesia — including through a toll manufacturing arrangement — two key requirements must be met:

1. The manufacturing facility must be certified under CPKB
2. The product must be registered through BPOM’s Notification system and comply with all labeling, ingredient, and claim regulations

2. Requirements for Cosmetic Contract Manufacturing: Brand Owners & Manufacturers

Companies or brand owners seeking to engage in cosmetic contract manufacturing must meet the following regulatory requirements:

• Possess a legal business entity with an official NIB (Business Identification Number) issued through the OSS system, and the relevant KBLI codes related to cosmetic trading or activities.
• If engaging in contract manufacturing, the company must establish a Manufacturing Agreement with a CPKB-certified factory, which forms part of the supporting documents for the Notification process.
• As the Notification applicant, the brand owner must submit product data including:
  • formula and full INCI ingredient list
  • product claims
  • packaging and labels
  • supporting safety data
• The manufacturing facility must meet technical requirements, hygiene standards, proper documentation, and quality management systems as defined by CPKB.

3. Entities Allowed to Conduct Cosmetic Contract Manufacturing

Under BPOM’s Notification guidelines and CPKB regulations, the following entities are legally permitted to engage in cosmetic contract manufacturing:

1. Cosmetic Manufacturers

CPKB-certified factories authorized to produce cosmetic products. They may act as:

• Producers for their own brands, or
• Contract manufacturers for other brand owners

2. Registered Business Entities (PT, CV, UD, Trading Companies)

Brand owners or distributors with a valid NIB and relevant KBLI codes may collaborate with CPKB factories for contract manufacturing.

3. Cosmetic Importers

For imported cosmetics, importers must comply with Notification and ingredient regulations and may engage foreign manufacturers as long as the regulatory requirements are met.

4. Contract Manufacturing by Non-Manufacturing Business Entities

Businesses without production facilities may legally engage in contract manufacturing with a certified CPKB factory, provided that all legal documentation and agreements meet BPOM requirements.

Important Note

Individuals (non-corporate entities) cannot act as Notification applicants or formal brand owners, as BPOM requires a registered business entity with a valid NIB.

4. Why Brand Owners Choose Cosmetic Contract Manufacturing — Key Strategic Advantages

Partnering with a CPKB-certified manufacturer such as Galenium offers the following benefits:

• Capital efficiency (CapEx reduction) — Brand owners avoid the high cost of building and maintaining their own production facilities, equipment, and QC operations.
• Resource optimization & business focus — Companies can concentrate on formulation R&D, branding, marketing, distribution, and regulatory activities, while manufacturing is handled by a compliant factory.
• Production scalability & flexibility — Ideal for new brands, product launches, diverse SKUs, and both small-batch and large-scale production.
• Regulatory compliance & product quality assurance — CPKB-certified manufacturers ensure that processes align with BPOM standards, simplifying audits and documentation.
• Faster time-to-market — Contract manufacturing enables brands to launch products more quickly and stay responsive to market trends compared to building in-house production capabilities.

5. Risks & Responsibilities — Why Strict Regulations Are Necessary

• Non-compliance with CPKB, Notification requirements, ingredient regulations, or labeling standards may result in product recalls or enforcement actions by BPOM, including revocation of distribution permits.
• Both the brand owner and the manufacturer hold responsibility for product safety, quality, and claims. Regulatory breaches may result in legal, administrative, and reputational consequences.

6. Conclusion

Cosmetic contract manufacturing is a legal, efficient, and strategic pathway for brand owners seeking to enter or expand within Indonesia’s fast-growing cosmetic market — provided that all regulatory requirements are fully met:

• The manufacturing facility must hold CPKB certification
• The brand owner must have valid NIB and KBLI codes
• The product must undergo BPOM Notification with complete documentation and compliant labeling

PT Galenium Pharmasia Laboratories is committed to supporting brand owners through comprehensive cosmetic contract manufacturing services — from formulation development to production and regulatory documentation. By adhering to Indonesia’s regulatory framework, brands can focus on building market presence and expanding product reach without regulatory obstacles.