Indonesia maintains a rigorous regulatory framework for health supplements under the Indonesian Food and Drug Authority (BPOM). All products must obtain Marketing Authorization (MA) through a product registration process, supported by safety, quality, and efficacy documentation. Imported supplements additionally require a Border Import Certificate (SKI Border) with strict shelf-life requirements.
All health supplements must meet stringent safety, quality, and efficacy standards before they can be marketed. BPOM has established a comprehensive regulatory framework, which not only specifies product ingredients and test requirements, but also enforces accurate labeling and validated health claims, thereby fostering consumer confidence and ensuring that only safe, high-quality products are available on the market.
1. Definition
As per BPOM Regulation No. 27 of 2022 on Control of the Importation of Drugs and Food into Indonesian Territory, health supplements are products intended to complement nutritional needs; maintain, enhance and/or improve health functions; have nutritional value and/or physiological effects; contain one or more ingredients in the form of vitamins, minerals, amino acids, and/or other non-plant ingredients that can be combined with plants.
2. Competent Authority
Competent authority | Responsibility |
Badan Pengawas Obat dan Makanan (BPOM) | BPOM is a vital institution in safeguarding public health through its regulation of health supplements. By approving products for market entry, monitoring their safety, educating the public, inspecting production facilities, and staying informed through research, BPOM ensures that health supplements available in Indonesia are safe, reliable, and beneficial for consumers. |
3. Main Regulations
Regulation | Major contents |
BPOM Regulation No. 16 of 2019 on Supervision of Health Supplements | It provides general supervision requirements for health supplements in Indonesia, involving general principles, production, packaging, labeling, advertising and surveillance. |
BPOM Regulation No. 32 of 2022 on Criteria and Administration of Health Supplement Registration | It sets forth the registration requirements for and procedures of health supplements. It also stipulates the health supplement registration standards include product safety, efficacy and quality, as well as labeling requirements. |
It stipulates the requirements for the importation of drugs and food products, including health supplements. It provides guidelines on the application of import license for health supplements.
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It changes the requirements for application of import license for health supplements, replacing SKI Post Border with SKI Border. | |
BPOM Regulation No. 24 of 2023 on Safety and Quality Requirements for Health Supplements | It details safety and quality requirements for health supplements in Indonesia. These requirements cover both product ingredients and finished products. |
It stipulates detailed rules for the labeling of health supplements in Indonesia, covering general requirements, mandatory and optional labeling items, etc. | |
Regulation No. 19 of 2022 on Guidelines for Claiming Health Supplements | It provides guidelines for the use of claims for health supplements by the establishment of classification and positive list of claims. |
4. Market Access Approval
To ensure health supplements to be marketed in Indonesia, stakeholders must first obtain Marketing Authorization for their products, then apply for Border Import Certificate for imported products.
4.1 Marketing Authorization
In order to ensure that health supplements marketed in Indonesia have met the Indonesian criteria, business operators are required to obtain a Marketing Authorization, which shall be obtained by submitting a product registration application. A Marketing Authorization is valid for a maximum of five years, and may be renewed through a renewal registration. For imported health supplements, the registration applications should be submitted by an importer in Indonesia through the ASROT System. The whole registration process includes two stages, namely, company registration and product registration.
4.1.1 Company Registration
Importers are required to finish the company registration in order to obtain an account for the actual product registration. The application process is outlined as below:
To obtain an account for product registration, documents required to be submitted from the registrants are as follows:
No. | Required documents |
1 | Single Business Number (NIB) |
2 | Individual Tax Number (NPWP) |
3 | Importer recommendations issued by Online Single Submission (OSS) for new importers |
4 | Certificate of Good Manufacturing Practice (GMP) of manufacturer from country of origin |
5 | Letter of authorization stating person in charge of company account |
4.1.2 Product Registration
After obtaining an account in 4.1.1, importers shall finish the product registration as per the application process as below:
To finish product registration, documents required to be submitted from the registrants are as follows:
No. | Required documents | Notes |
1 | Master formula | For pre-registration |
2 | Letter of authorization for person in charge of product registration | |
3 | Statement letter of company responsibility for document authenticity | |
4 | Certificate of Free Sale (CFS) or Certificate of Pharmaceutical Product (CPP) that has been legalized by the Indonesian Embassy / Consulate General or Apostille legalization by an authorized official in the country of origin | |
5 | LoA/ Letter of authorization for distribution from industry in the country of origin | |
6 | Good Manufacturing Practice certificate or other equivalent documents | |
7 | Product composition (per batch) | For registration |
8 | Detail of manufacturing process | |
9 | Certificate of analysis of raw material | |
10 | Certificate of analysis of finished product | |
11 | Specification and analytical method of finished product | |
12 | Specification of packaging material | |
13 | Batch numbering system | |
14 | Safety test result from an accredited laboratory in Indonesia | |
15 | Certificate of analysis of capsule shell or gelatine, Bovine Spongiform Encephalopathy (BSE) free certificate, halal certificate from authorized institution and statement letter of BSE free capsule (for hard capsule/ soft capsule/ gelatin material) | |
16 | Chloramphenicol test (for product containing honey and other honey-derived materials) | |
17 | Protocol and result of stability test | |
18 | Packaging design | |
19 | Supporting data regarding safety and efficacy | |
20 | Toxicity test result (if required) | |
21 | Origin and gaining process of certain material (if any) | |
22 | Halal certificate for raw material from non-marine origin (if any) | |
23 | Picture of original packaging from each angle |
Furthermore, it should be noted that health supplements which are manufactured, imported and/or marketed in Indonesia are prohibited from the following conditions:
being presented in injection, eye drop and topical dosage forms;
containing vitamins, minerals, amino acids and/or other substances exceeding the maximum limits;
containing substances which are harmful to health;
containing ethyl alcohol at a level greater than 1% and is in the form of an oral liquid dosage form;
containing drugs, medicinal chemicals, narcotics, or psychotropic substances;
containing protected animals or plants in accordance with the provisions of legislation;
containing materials which do not meet standards and/or requirements for safety, efficacy and quality.
4.2 Border Import Certificate
After obtaining Marketing Authorization, health supplements require a Border Import Certificate (also known as SKI Border) to be imported into Indonesia. It should be noted that health supplements that are intended to be imported must have at least 2/3 of the shelf life.
SKI Border is an approval letter of importation of goods into Indonesia which shall be obtained before the goods are released from the customs area. Applications for SKI Border shall be submitted via e-bpom portal or SINSW, by a company of Marketing Authorization holder, or a government institution and an importer authorized by the Marketing Authorization holder. Notably, a Border Import Certificate is only valid for one-time importation.
To apply for the SKI Border, the applicant shall register with BPOM with the following documents to obtain a username and password.
No. | Required documents |
1 | Original NIB |
2 | Original application letter signed by the director or the proxy of board of directors |
3 | Duly stamped, original statement of the person in charge |
4 | Original Import Power of Attorney |
5 | HS Code list of commodities to be imported |
6 | Front view and back view photos of the warehouse and office |
7 | Warehouse address where the product is stored |
With the username and password, the applicant can apply for SKI Border online. The documents required to be uploaded are as follows:
No. | Required documents | Notes |
1 | Marketing Authorization approval | / |
2 | Certificate of analysis | It must be provided by the manufacturer or an accredited laboratory. It must include the following information: - name and address of the manufacturer; - name of products; - testing parameter based on the provisions; - test results; - analysis method; - batch number/lot number/production code; - production date; - expiration date. |
3 | Invoice | Product name, packaging, and packaging size listed on the invoice must match the product name, packaging, and packaging size listed on the Marketing Authorization. Otherwise, the application must be supported with the reference letter from the manufacturer. |
4 | Other supporting documents | / |
Within a maximum period of 6 hours after the documents are received in full according to the requirements and after the payment of non-tax state revenue, the application documents are evaluated to issue an approval or rejection. The application approval of SKI Border is issued electronically, and does not require stamp and signature.
5. Product Compliance
5.1 Product Requirements
In principle, all manufactured or imported health supplements to be marketed in Indonesia must meet the criteria of safety, efficacy and quality. Specifically, the criteria include:
Use of raw materials in accordance with the provisions of the Indonesian pharmacopoeia, Indonesian herbal pharmacopoeia, pharmacopoeia of other countries or recognized scientific references;
Safety and efficacy substantiation through empirical and/or scientific evidence; and
Good Manufacturing Practice is implemented.
The overall product requirements are outlined as follows:
Item | Requirements |
Dosage forms |
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Active ingredients |
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Auxiliary ingredients |
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Contaminants |
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Test parameters for finished products | Click here for more details. |
5.2 Label
In general, both local and imported health supplements must be correctly labeled before distribution in Indonesia. The labeling information must be objective, complete and non-misleading. It must be displayed on both primary and secondary packaging, as well as on product brochures/leaflets, and directly printed or securely attached to the container and/or packaging.
Mandatory and optional labeling items for health supplements are listed as below:
Item | Details |
General requirements |
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Mandatory labeling items | a) Product name and dosage form; b) Name and address of business operators; c) Name and address of the contract giver and/or the contract recipient; d) Name and address of the licensor and/or licensee; e) Net content, net weight, and/or quantity; f) Composition; g) Additional ingredients; h) Claims of efficacy/benefits; i) Use instructions; j) Contraindications, side effects, interactions, and warnings; k) Distribution Permit Number; l) Production code; m) Expiry date; n) Storage conditions; o) 2D Barcodes; p) Logo or text of health supplements; q) Other information (e.g., halal label, alcohol content, information on the origin of certain material). Notes: 1. Except for item (f) (g) (h) (i), all other items must be placed in positions that are easy to see and read on product labels. 2. Items (a) to (e) must be indicated on the primary packaging. If the primary packaging has a labeling area of less than 10 cm2, item (b) can be indicated on the secondary packaging. 3. For products with restricted sizes and packaging shapes, labeling items can be indicated in other forms, such as hanging labels, brochures, display panels, shrink wrap, etc. |
Optional labeling items | a) Nutrient content; b) Quality assurance document; c) Consumer service information; d) Image, logo, and/or text information; e) Gluten free, alcohol free, and no additives; f) Low lactose and lactose free; g) Clinical tested; h) Description of achievements in marketing or awards. |
In addition, Indonesia explicitly prohibits several information to be indicated on the labels of health supplements:
Statements that the product is free from certain ingredients when it actually contains them, either accidentally or as a carry-over ingredient/compound
Images or information related to health workers, religious figures, and public officials, and acting as such information, texts, or images that offend certain ethnicities, religions, races, and/or groups
Information about raffles, competitions, or prizes
Information, texts, or images that are contrary to or prohibited by statutory provisions
Information that creates an image/perception contrary to the norms of decency, ethics, or public order
Visualization or other information that is excessive or unrelated to health supplements
Information that creates misleading perceptions regarding product safety/efficacy/benefits and quality
5.3 Claim
In Indonesia, all claims for health supplements fall into three types, namely, general claims, functional claims, and disease risk reduction claims. The three types requires different supporting documents for their uses.
Types of claims | Scope | Claim example | Supporting documents |
General claims |
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| At least one of the following scientific data research supports the claim determination: a. A valid reference from a book, journal, dissertations, or other research; b. Literature on the utilization of active substances historically throughout time (e.g research and published documents).
There must be a reasoning explanation for the combination. |
Function claims | Function claims relate to specific beneficial effects of health supplements on normal biological functions or activities in the body. These claims relate to positive effects in maintaining/supporting healthy organ/body system functions. |
| The relevant sources of data must be included at least one in the final product to support the determination of the claims: a. Scientific proof from the conclusions of human studies. In circumstances where the endpoint of human testing is not achievable, a surrogate endpoint may also be adopted. b. Authoritative reference text, monograph, or pharmacopeia.
Additional verification of at least one from the secondary data obtained is necessary to support the claims: a. Data from scientific experiments performed on animals. b. A collection of historical and empirical use (e.g classic texts and published documents). c. Proof from scientific reviews that have been published.
If there is no evidence in the final product for new combinations, there must be justification for the reason for the dose of each component as well as proof of no harmful interactions. |
Disease risk reduction claims |
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| Claims must be validated by primary evidence, which requires the following: a. Scientific data from human intervention studies (clinical trials) of the completed item or products that share the same composition. b. At least one of the following data has additional evidence supporting: - Authoritative reference work, such as a monograph or pharmacopeia. - Scientific advice from authorities in other nations. - Published scientific reviews (scientific reviews or meta-analyses) |
Additionally, the guidelines list the examples of permitted claims for health supplements.
No. | Nutrient | Scientific, nutritional, and functional claims that have been recognized and/or registered |
1 | Vitamin A (≤5000 IU) |
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2 | Beta-carotene (≤ 20,000 IU) |
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3 | Vitamin B1 (≤ 100 mg) |
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4 | Vitamin B2 (≤ 50 mg) |
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5 | Vitamin B3 (≤ 100 mg) |
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6 | Pantothenic acid (≤ 100 mg) |
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7 | Vitamin B6 (≤ 100 mg) |
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8 | Vitamin B12 (≤ 200 mg) |
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9 | Folic Acid (≤ 800 mg) |
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10 | Folic Acid (≤ 1000 mg: special products for pregnant women) |
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11 | Biotin (≤ 500 mg) |
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12 | Vitamin C (≤ 500 mg) |
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13 | Vitamin C (500 – 1000 mg) |
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14 | Vitamin D (≤ 400 IU) |
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15 | Vitamin E (≤ 100 IU) |
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16 | Vitamin E (≥100 IU) |
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17 | Calcium (≤ 1200 mg) |
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18 | Magnesium (≤ 600 mg) |
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19 | Iron (≤ 30 mg) |
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20 | Selenium (≤ 200 mcg) |
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21 | Fluor ≤0.7 mg (Toddler) ≤1.5 mg (Teenager) ≤3 mg (Adult) | As a supplement to support meeting fluoride demands. |
22 | Chromium (≤ 200 mcg) |
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