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Five Steps to Identify a Product as Cosmetics

Cosmetics are products frequently utilized by society to enhance appearance, hygiene, and skin health. However, not all products related to skincare and appearance can be categorized as cosmetics. To ascertain whether a product falls under the cosmetic category, several aspects need to be considered. Here is a guide to identifying a product as cosmetics.

Outlined below are the five steps for identifying a product as cosmetics according to the BPOM Regulation of December 7, 2020:

  1. Cosmetic Composition: Cosmetics must not contain prohibited substances and/or exceed specified limits.
  2. Cosmetic Application Area: Cosmetics are intended solely for external use on human body parts such as the epidermis, hair, nails, lips, external genital organs, teeth, and oral mucosa membranes. Products used orally, by injection, or in contact with other parts of the human body, such as nasal mucosa membranes or internal genital organs, are not considered cosmetics.
  3. Primary Functions of Cosmetic Area: Cosmetics serve to cleanse, beautify, alter appearance, improve body odor, and/or protect or maintain the body in good condition.
  4. Product Presentation:  Cosmetics are not intended for treating or preventing diseases. Thus, the following aspects should be observed to ensure compliance as cosmetics:
    • Claims of product benefits/utility associated with the type of cosmetics;
    • Formulation and usage instructions;
    • Labeling;
    • Supporting materials; and
    • Targeted consumer groups. Populations with specific diseases or side effects from certain conditions are not allowed; for example, moisturizing skin for psoriasis patients.
  5. Physiological Effect of Products: Cosmetics have non-permanent physiological effects, and to maintain their effects, some cosmetics need to be used regularly.