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INDONESIA REGISTRATION · Q&A

Registration Q&A

Frequently asked questions and key terms on registering medical devices (AKL) and cosmetics (BPOM) in Indonesia.

01Process & timeline

QCan a foreign manufacturer apply in Indonesia directly?
A

No. Medical devices (AKL) must be filed by a local entity holding an IDAK, and cosmetics (BPOM) by a locally registered notifier. The manufacturer issues a Letter of Authorization (LoA) to that entity; K-MBSS files through its local entity, PT Korea Medibiz Platform (PT KMP).

QWhat is the overall sequence?
A

Enquiry → document checklist → pre-review (feasibility and expected class) → quote & contract → full dossier → review & corrections → final check and filing by the local RA team → responses to authority queries → licence issued.

QHow long does it take?
A

Statutory review for imported devices is 15 working days for Class A, 30 for B and C, and 45 for D. Cosmetics take 2 working weeks for manufacturer registration and 2 for product notification. Authorities may extend these without notice. Document preparation — especially apostilles for the LoA and CFS — can add 4–8 weeks.

QWhy is there a pre-review?
A

Before contracting, we check feasibility, the expected class and any extra documents using your home-country approval, ISO/GMP certificates, product information and HS Code. For cosmetics we also screen for prohibited and restricted ingredients at this stage.

QWhat happens if the authority sends a query?
A

For devices, replies are due within 10 days (Class A–C) or 15 days (Class D) of the query. K-MBSS translates the query, tells you what is needed and resubmits through the local RA team. Missing the deadline can lead to rejection.

QHow will I know the status?
A

Your account manager emails you whenever the stage changes, and sends review results and correction requests itemised.

02Preparing documents

QWhat language should documents be in?
A

English. Korean documents (e.g. MFDS approvals) are submitted with an English translation. The device IFU and key label text must be translated into Indonesian; K-MBSS supports the translation review.

QWhere do I get an apostille?
A

In Korea, at the Ministry of Foreign Affairs consular service or online via e-Apostille. Private documents such as a company-issued LoA must be notarised first, then apostilled.

QDo I need to send originals?
A

Filing is done by uploading scans to the online system. Keep the apostilled LoA and CFS originals, as the authority may ask to verify them.

QHow do I submit documents?
A

Organise them as PDFs according to the checklist and email them to [email protected]. Including the document and product name in each file name speeds up the review.

QWhat must match across documents?
A

Product/model names, manufacturer name and address must be identical across all documents — including spacing and capitalisation. It is the most common reason for queries, so we cross-check item by item.

03Medical devices (AKL)

QWhich class is my product?
A

Indonesia classes devices A (low risk) to D (high risk). It is broadly similar to Korean classes but can differ by intended use and principle, so we confirm it in the pre-review.

QCan documents outside the class list be requested?
A

Yes. The class lists are the rule; additional data may be requested depending on principle, materials, sterilisation, software, body contact and claims. Class C products, for example, are sometimes asked for pre-clinical or clinical data.

QDo multiple models need separate registrations?
A

Models with the same principle, intended use and materials can sometimes be grouped in one application. Whether grouping is possible depends on the configuration and is checked in the pre-review.

QHow much validity must the ISO certificate have left?
A

The ISO 13485 certificate must have at least one year of validity remaining. A CE certificate is submitted with a letter confirming it is valid.

QWhat goes into the LoA?
A

Exact names and addresses of the manufacturer and the local registrant, the products (models) covered, the term (2–5 years), and the representative's signature and seal — written in English and apostilled. The licence validity follows the LoA term.

QHow should labels be written?
A

Show product name, licence number (KEMENKES RI AKL), names and addresses of the manufacturer and importer (PT KMP), lot/serial number and expiry date; intended use, directions, contraindications, precautions and warnings must be in Indonesian. Superlatives and definitive efficacy claims are not allowed.

QWhat are the most common queries?
A

Product name, manufacturer or address differing between documents; test reports showing another product name; self-made documents without manufacturer letterhead; DoCs missing the applied standards; approvals in Korean only; and missing Indonesian IFUs.

04Cosmetics (BPOM)

QIs my product a cosmetic?
A

It must be applied to external parts of the body (skin, hair, nails, lips, external genitalia, teeth, oral mucosa) for cleansing, fragrance, changing appearance, correcting body odour or protection. Oral, injectable or internal products, or products claiming to treat or prevent disease, are not cosmetics.

QIf an ingredient is allowed in Korea, is it fine?
A

Not necessarily. Indonesia follows the ASEAN Cosmetic Directive (ACD), with restricted ingredients in Annex I and prohibited ones in Annex V. A product sold in Korea cannot be registered if it contains a prohibited ingredient.

QWhich claims are not allowed?
A

Claims that could be mistaken for medicines — treating, regenerating, relieving inflammation — and unsupported superlatives. Any efficacy claim must be backed by evidence.

QWhose CFS — the manufacturer's or the brand owner's?
A

Either, submitted apostilled. Using the CFS of the same company named in the LoA reduces additional requests.

QCan I register with ISO 22716 instead of GMP?
A

Yes. Submit a valid ISO 22716 certificate from an accredited body, apostilled.

QWhat if the trademark owner differs from the manufacturer?
A

Either may apply, but a trademark licence agreement between the two must be submitted. The OEM agreement must state the brand, product names and expiry date, and the manufacturer name must match the GMP certificate exactly.

QCan I sell in Korean packaging as is?
A

An English sticker must be added, showing product name, ingredients, manufacturer and Indonesian importer/distributor (PT KMP), directions and a space for the BPOM number.

QDoes the product need testing before registration?
A

Product testing is not generally required at notification, but post-market sampling can occur, so keep finished-product CoA and microbial/heavy metal test data ready.

05After registration

QHow long is the licence valid and how is it renewed?
A

Devices: up to 5 years following the LoA term; OEM-manufactured products up to 3 years. Renewal can be filed from 9 months before expiry. Cosmetics: 3 years, renewed before expiry.

QBy when must imports start?
A

Cosmetics must be imported and distributed within 6 months of notification. Device renewals also check distribution records, so renewal may be difficult without sales.

QWhat if product information changes after registration?
A

Changes to the product name, manufacturer address, labelling/packaging or (for cosmetics) ingredients require a variation. Some changes require a new registration, so please consult us before changing anything.

QCan other importers sell our product?
A

The licence is issued in the name of the filing entity. Other companies can sell under a distribution agreement with the licence holder. Changing the licence holder itself normally means re-registering under a new LoA.

QWhat does the annual maintenance fee cover?
A

Work to keep the licence active — liaison with the authority, periodic reports and licence status management. Paid once a year after registration.

06Fees & contract

QHow much does it cost?
A

Three items per product: government fee (PNBP), registration fee and annual maintenance. Fees depend on class or type, number of products and document readiness — send us your product details for a tailored quote.

QWhen are fees paid?
A

Within 7 days of contract: PNBP 100% and 60% of the registration fee. Within 7 days of licence issue: the 40% balance and 100% of the annual maintenance fee. Same for devices and cosmetics.

QIs there a discount for several cosmetics?
A

Registration fees are negotiable when two or more products are registered together.

QHow is the contract signed?
A

After the quote, we sign our standard contract. Download, sign and seal it, then send us the scan.

QWhat if registration is refused?
A

If a licence cannot be obtained due to errors or omissions in submitted documents, or uncontrollable causes such as Indonesian policy changes, fees already paid are not refunded (Standard Contract, Article 5). That is why we put so much into the pre-review and dossier review.

07Glossary

AKLDeviceAlat Kesehatan Luar negeri

Import medical device licence issued by Kemenkes; numbers begin with KEMENKES RI AKL.

IDAKDeviceIzin Distribusi Alat Kesehatan

Medical device distribution licence. Only local entities holding it can apply for AKL.

RegalkesDeviceRegistrasi Alat Kesehatan

The Ministry of Health's online device registration system; documents are uploaded as scans.

DoCDeviceDeclaration of Conformity

Manufacturer's declaration that applied standards are met; must list the standards.

IFUDeviceInstructions for Use

Intended use, directions, contraindications and warnings must be translated into Indonesian.

ISO 13485DeviceMedical device QMS

Quality certification for device manufacturers; needs at least one year of validity left.

BPOMCosmeticBadan Pengawas Obat dan Makanan

Indonesia's FDA, responsible for registration and post-market control of cosmetics, drugs and food.

NACosmeticNotifikasi

Cosmetic notification number, beginning with NA once approved.

DIPCosmeticDokumen Informasi Produk

Product information file in 4 parts (administrative, raw materials, quality, safety), shown at BPOM inspections.

ACDCosmeticASEAN Cosmetic Directive

ASEAN cosmetics rules with restricted (Annex I) and prohibited (Annex V) ingredient lists.

ISO 22716CosmeticCosmetics GMP

Cosmetic manufacturing quality standard; accepted instead of CGMP.

MoSCosmeticMargin of Safety

Safety margin calculated from exposure per ingredient, used in the safety assessment.

LoACommonLetter of Authorization

Manufacturer's authorisation of the local registrant; written in English and apostilled.

CFSCommonCertificate of Free Sale

Proves the product is legally sold in the country of origin.

ApostilleCommonApostille

International authentication of documents; needed for the LoA, CFS and cosmetic GMP/ISO 22716 certificates.

PNBPCommonPenerimaan Negara Bukan Pajak

Government (non-tax) fee.

HS CodeCommonHarmonized System Code

International product classification code used for customs and import rules such as SNI.

OEMCommonOriginal Equipment Manufacturing

Manufacturing under the buyer's brand; an agreement is required when brand owner and manufacturer differ.

Didn't find your answer?

Send us the product name, registration type, home-country class and HS Code, and our team will reply.

[email protected] · +82 2-2224-0977 · Mon–Fri 09:00–17:00 KST