This regulation stipulates the requirements for perfume refill, including factory design, manufacturing facility, ingredients, packaging materials, environmental sanitation, storage conditions, document, labeling, supervision and inspection, as well as non-compliance penalties.

Term:

Perfume refill: It is a perfume preparation made directly at the manufacturing facility by mixing fragrance concentrates with solvents in certain compositions according to consumer’s demand.

Perfume refills are widely sold in Indonesia, but products that fail to meet safety and quality requirements pose health risks to consumers. To ensure the public's safety when using perfume refills, on Sep. 2, 2022, Indonesia BPOM released the draft Regulation Concerning the Control of Perfume Refill for public consultation. ¹

According to the regulation, perfume refill manufacturers are required to guarantee and ensure the manufactured products meet quality and safety standards, that is, Technical Requirements for Cosmetics Ingredients, and the detailed requirements for the following six aspects in Guideline for Cosmetic Good Manufacturing Practice.

1) Factory design and manufacturing facilities;

2) Ingredients and packaging materials;

3) Environmental sanitation;

4) Storage conditions;

5) Documentation;

6) Labeling.

The key points are as follows:

Ingredients

When manufacturing perfume refills, permitted ingredients include:

Required Documents

Manufacturers of perfume refills are required to obtain at least the following documentations:

1) Procurement documents for ingredients and packaging materials;

2) Inventory records or stock cards for ingredients and packaging materials;

3) Manufacturing records (including product name, manufacturing date, composition/formula and batch number);

4) Sales records.

Labeling Information

For perfume refill, the following information must be indicated on the label:

1) Product name including the word “perfume,” and product code as the product variant;

2) Manufacturing date;

3) Net content;

4) Batch number;

5) Name and location (city) of the manufacturing facility.

Packaging Materials

For packaging materials, there are four requirements as follows:

1) The packaging material must be inert and do not react with the ingredients of perfume refill;

2) The packaging material should be made clean before use;

3) Methanol should not be used to wash primary packaging materials;

4) Packaging materials can be obtained from consumers directly or provided by manufacturers.

If you are interested in all compliance requirements for perfume refill, welcome to contact ChemLinked to request the English translation.

Further Reading

• Indonesia Implements the Amended Cosmetic Ingredient Use Requirements: 17 Newly Permitted Ingredients and 231 Newly Prohibited Ingredients
• WTO Circulates Indonesian Decree on Materials Exempted from Mandatory Halal Certification
• Indonesia Implements New Technical Requirements for Cosmetics Claims

Reference Links

[1] Indonesia BPOM released the draft Regulation Concerning the Control of Perfume Refill

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