On October 12, 2026, the Halal Product Assurance Organizing Agency (BPJPH) of Indonesia issued Decree No. 376 of 2026 of the Head of BPJPH on the Guidelines for the Implementation of the Halal Product Assurance System for Sales Services, which took effect on October 12, 2026.
The Guidelines expressly bring retail stores selling cosmetics and personal care products, perfume shops, and other establishments within the scope of entities subject to halal certification for sales services, and provide that the Halal Product Assurance System (SJPH) obligations for cosmetics sales services took effect on October 18, 2026.
CIRS Group has compiled and summarized the main contents of the Guidelines and their impact on cosmetic companies as follows, for reference.
Six Key Requirements Established by the Guidelines
The main text of the Guidelines comprises six chapters (including annexes) and establishes requirements mainly in the following six aspects:
1. Defining the scope of application of sales services and the types of business operators, specifying that cosmetics retailers, perfume shops, and other entities are covered;
2. Providing two circumstances in which the Guidelines do not apply, namely operators selling only certified products of their own brands and operators selling only products exempt from mandatory certification;
3. Setting out the SJPH implementation requirements in respect of halal policy, halal supervisors, personnel training, consumable materials, premises, and equipment;
4. Providing graded requirements for the physical separation and purification of halal and non-halal products across the four stages of goods receipt, storage, display, and sale;
5. Providing requirements for products, packaging labels, traceability, and the disposal of non-conforming products;
6. Allocating the halal assurance responsibilities among the three parties involved in trading through electronic systems (PMSE): platform providers, sales partners, and delivery partners.
Scope of Application and Covered Entities: Cosmetics Retail Stores and Perfume Shops Are Covered
The Guidelines apply to business operators providing sales services directly to end consumers (retail/retail stores). The halal certification obligation applies to operators engaged in the sale of food, beverages, drugs, and/or cosmetics. The types of sales services of covered entities include:
- Self-service stores (convenience stores, supermarkets, hypermarkets);
- Pharmacies/drug stores;
- Perfume retailers/perfume shops; and
- Retail of cosmetics and personal care products (drugstores, health and beauty stores).
The Guidelines provide two circumstances in which they do not apply:
First, operators selling only products of their own brands (self-produced or imported by other enterprises within the same group), where the products have obtained a halal certificate or a foreign halal certificate registration number (RSHLN) and bear halal labels as required
Second, operators selling only products exempt from the mandatory halal certification obligation. Own-brand products must meet two conditions: they are sold in the original packaging, intact and sealed, with a tamper-evident design, and are not bulk or open products; and the operator does not unpack, repack, blend, or reprocess them, as evidenced by established provisions prohibiting such activities.
In addition, sales premises unrelated to food, beverages, drugs, or cosmetics (such as electrical appliance stores, bookstores, and household goods stores) that sell the above four categories of products incidentally in the course of their business are not subject to the halal certification obligation for sales services, but must have procedures for handling products that do not comply with halal standards.
When carrying out sales services, operators may integrate storage, packaging, delivery, processing, and/or serving activities, and need only apply for halal certification for the sales service as the principal activity, with the other activities provided as additional services.
Impact on Cosmetic Companies and Recommendations
The Guidelines bring retail stores selling cosmetics and personal care products, perfume shops, drugstores, and sellers offering cosmetics through e-commerce platforms within the purview of the halal assurance system. For cosmetic companies, the following matters require particular attention:
- Determine whether they fall within the scope of obligated entities: brand owners' own stores and counters in Indonesia may generally claim exemption from the sales service certification obligation where they sell only their own brands, the products hold halal certificates or foreign halal certificate registration numbers, they are sold in original, sealed, tamper-evident packaging, and no unpacking or repacking takes place. Once unpacking, dividing, repacking, or blending is involved, or other brands are also sold, the exemption is hard to apply. Supermarkets, hypermarkets, drugstores and similar comprehensive retail channels are expressly covered entities.
- Build the sales-side SJPH documentation system: issue and post a written halal policy, appoint and register a halal supervisor, establish segregation and labeling procedures covering goods receipt, storage, display and sale, together with procedures for facility purification, waste management and disposal of contaminated products, and communicate these to relevant parties while keeping records.
- Implement e-commerce channels in line with the responsibilities of the three parties: sellers offering certifiable products must hold certificates or provide non-halal statements; pure retail resellers must check halal labels item by item and warrant the truthfulness of the halal status disclosed to the platform; brand owners' own cross-border e-commerce teams should prepare accordingly.
- Track how the deadlines fit together: the Guidelines take effect on October 18, 2026, but on October 16, 2026, the Coordinating Ministry for Economic Affairs extended the transition period for mandatory certification of cosmetic products to October 17, 2028. Continue monitoring developments and, in the meantime, complete system preparations in accordance with the Guidelines.
What Can CIRS Do for You?
Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services, from regulatory compliance, laboratory testing, and R&D to data services across multiple industries.
The CIRS cosmetic team provides expert support to ensure that cosmetic products meet stringent global cosmetic regulations and safety standards. We offer comprehensive, lifecycle-based solutions for personal care products, from early-stage cosmetic ingredient development through to final product registration. Our services include:
- Cosmetic ingredient development and regulatory strategy,
- Physical/chemical and analytical tests,
- Toxicological tests (in vivo & in vitro),
- Efficacy and claim substantiation studies (in vivo & in vitro), and
- Ingredient and product registration across global markets.
With deep expertise in cosmetic regulatory compliance and safety evaluations, our team enables brands to bring products to market efficiently and with confidence.
Our Services
- Indonesian Companies License Holding Services
- BPOM Account Registration
- Formula and Packaging Review
- Cosmetic Product Notification
- PIF/DIP File Preparation and Compilation
- Product Testing Services
- Logistics and Customs Clearance
- HALAL Certification Services
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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