Enter Indonesia Safely with a Product License Holder Service

A local license holder is an eligible Indonesian entity that registers a regulated product and remains responsible for maintaining the approval throughout its validity period. Partnering with InCorp Indonesia ensures you access trusted local expertise, reducing compliance risks and streamlining registration processes. 

Therefore, choosing the right local license holder is an important step in maintaining regulatory control and facilitating smoother market entry. InCorp Indonesia can guide you through the registration timeline, from initial application to approval, helping you plan your market launch effectively.

Key Takeaways

• A local license holder is an eligible Indonesian entity that registers a regulated product and remains responsible for maintaining the approval throughout its validity period. 
• A license holder and a distributor serve different functions, though one company can sometimes perform both under the applicable rules. 
• Halal certification is now mandatory for many product categories — cosmetics and Class A medical devices must comply by October 17, 2026, with later phase-in dates for higher-risk device classes. 
• Recent BPOM regulations, including PerBPOM No. 25/2025 on cosmetic ingredients and PerBPOM No. 8/2026 on GMP certification, have tightened compliance obligations for notification holders. 
• Documentation must stay consistent across the manufacturer, product dossier, labels, importer, distributor, and registration holder. 

What is a Local License Holder in Indonesia? 

A local license holder is an eligible Indonesian entity authorized to register, hold, and maintain product approvals for a foreign brand. 

Depending on the product category, it may be referred to as a registrant, a notification holder, a marketing authorization holder, or an authorized representative. Its responsibilities commonly include: 

• Submitting registration applications; 
• Communicating with regulators; 
• Maintaining product dossiers; 
• Managing queries, variations, and renewals; 
• Supporting safety reporting and recalls; and 
• Keeping records ready for inspection. 

With BPOM closely regulating imported cosmetics, processed food, medicines, and supplements, an experienced local holder helps foreign brands manage registration and ongoing compliance more effectively.

READ MORE:

• Why You Need a Product License Holder to Import and Distribute to Indonesia 
• SNI License and Product Registration in Indonesia
• How to Register Imported Skincare Products in Indonesia 

License Holder or Distributor: Which One Should You Choose? 

Area	Local License Holder	Distributor
Primary role	Holds and maintains the product registration or marketing authorization	Sells and distributes the product in the Indonesian market
Regulatory responsibility	Communicates with the regulator and manages registration obligations	Manages commercial distribution and channel execution
Product registration ownership	Named as the registration holder, subject to the applicable framework (e.g., one holder per device under Permenkes 62/2017 Art. 13)	Does not automatically hold the registration unless formally appointed and eligible
Commercial activity	May be kept separate from sales and distribution	Usually involved directly in sales, warehousing, promotion, or delivery
Brand flexibility	Allows the brand to appoint or replace distributors without necessarily changing the holder	Registration can become commercially tied to the distributor when the distributor is also the holder
Market expansion	Can support a multi-distributor structure, where permitted	Usually manages an agreed territory, channel, or product range
Best suited for	Brands seeking independent regulatory control and commercial flexibility	Brands that have already committed to a long-term sales and distribution partner

Still unsure which structure fits your brand?  

InCorp Indonesia (an Ascentium Company) can assess your registration, import, and distribution needs and support either a local license holder or a distributor arrangement. Talk to our team -> 

Why Foreign Brands Need a Local License Holder 

Foreign brands generally cannot approach Indonesian product registration as a simple overseas filing. The application must usually be connected to a locally established and appropriately licensed business. 

A license holder in Indonesia may be needed for several reasons. 

Meet Local Eligibility Requirements 

The applicant must hold the correct business licenses, classifications, facilities, and sectoral approvals. Eligibility varies by product; therefore, a holder qualified for food registration may not qualify for cosmetics or medical devices. 

Maintain Regulatory Accountability 

The holder acts as the local contact for regulators and remains responsible for product dossiers, labels, claims, variations, renewals, and compliance throughout the approval period. 

Enter Indonesia Without Forming a Subsidiary 

Establishing a PT PMA is suitable for companies planning direct sales, employee operations, and broader commercial activities. Brands that first want to register products, test demand, or work through distribution partners can instead use a license holder as an interim or long-term route. 

Separate Registration from Distribution 

Using an independent holder can help brands change or appoint distributors without placing full control over product registration in the hands of a single commercial partner. 

Manage Post-Market Obligations 

Ongoing holder responsibilities typically include complaint handling, safety reporting, inspections, label and claim monitoring, submission variations, renewal management, and recall coordination.

Which Products Usually Need a Local License Holder? 

A local entity is commonly required for products that must be registered, notified, approved, or certified before importation and sale. 

Product Category	Regulator	Registration Route	Key 2026 Requirement
Processed food and beverages	BPOM	Registration under PerBPOM No. 23/2023 through the BPOM food-registration platform	The holder must align registration with the appointed importer and distribution structure.
Cosmetics	BPOM	Notification through Notifkos; the NA number is valid for three years	Halal certification takes effect on October 17, 2026. Updated ingredients, GMP, and fee rules also apply under PerBPOM No. 25/2025, PerBPOM No. 8/2026, and PP No. 15/2026.
Food supplements and traditional medicines	BPOM	Category-specific evaluation covering ingredients, dosage, claims, safety, and manufacturing standards	Separate technical dossiers and supporting evidence are required for each product category.
Medical devices and IVDs	Ministry of Health	Registration under Permenkes No. 11/2025 through an IDAK holder; approvals are issued as AKL or AKD	One holder is generally permitted per device. Halal deadlines are phased by class, starting with Class A on October 17, 2026.
Household health products (PKRT)	Ministry of Health	Separate registration route based on product classification	Composition, intended use, and claims can change the applicable registration pathway.
Other regulated imports	BPOM, BPJPH, or sector regulators	May require SNI, halal registration, import approval, or sector-specific licenses	Early classification helps identify the correct authority, documents, and approval route.

What Documents Are Usually Needed for Product Registration? 

Requirements vary by product category and regulator, but foreign brands generally need to prepare four groups of documents. 

• Manufacturer and company documents; 
• Manufacturing, GMP, or quality certificates; 
• Product composition and specifications; 
• Test reports and safety data; 
• Packaging artwork and Indonesian labels; 
• Product claims and usage instructions; 
• Letter of Authorization; and 
• The local holder’s business and sectoral licenses. 

The final checklist should be confirmed after product classification, as incomplete or inconsistent documents can delay approval. 

Local License Holder Service: Process and Timeline 

A structured license-holder service typically covers the following stages. 

Stage	Process	Estimated Timeline
Product classification	Confirm the regulator, registration route, and applicant requirements.	1–2 weeks
Holder eligibility	Verify the local entity’s licenses, personnel, and facilities.	1–2 weeks
Appointment	Complete the Letter of Authorization and service agreement.	1–3 weeks
Document review	Identify dossier, label, claim, or testing gaps before filing.	2–4 weeks
Registration	Submit the application and manage regulator queries.	Varies by product and risk class
Approval maintenance	Manage renewals, variations, labels, and reporting.	Ongoing
Import coordination	Align registration with the importer, customs, warehouse, and distributor.	2–6 weeks

What to Review Before Appointing a License Holder 

The right license holder can affect registration speed, compliance, and future expansion. Foreign brands should review: 

• Regulatory Experience: Proven expertise with BPOM, Kemenkes, and the relevant product category. 
• Independence: A neutral structure that keeps registration separate from distributor interests. 
• Responsiveness: Clear processes and timely handling of regulator questions. 
• Scalable Support: Capacity to manage registrations, renewals, variations, and growing product portfolios. 
• Post-Market Support: Assistance with label changes, recalls, and regulatory updates. 
• Halal Expertise: Knowledge of the requirements affecting food, cosmetics, and medical devices in 2026. 

A Case Study on a Successful License Holder Experience 

InCorp Indonesia (an Ascentium Company) served as an independent license holder for an international F&B company that imports products from Thailand. Through this structure, 37 products were successfully registered, and the company’s planned portfolio expanded from 19 to 49 products without tying registrations to a single distributor. 

See how we supported product registration and expansion in Indonesia. Read the full case study here.

Enter Indonesia with the Right License Holder 

InCorp Indonesia (an Ascentium Company) supports foreign brands that require an eligible local entity to manage product registration and maintain regulatory representation in Indonesia. 

Our support can include: 

• Product classification and registration 
• Local license-holder arrangements 
• Import and distribution compliance 
• Ongoing renewals and regulatory updates 

The right structure depends on the product and market-entry plan. 

InCorp Indonesia’s team can review your proposed product, determine the registration route, and recommend a structure covering registration, license holding, importation, and distribution. Talk to us by filling out the form below.

Frequently Asked Questions