July 26, 2026 is the date every liquid manufacturer in Indonesia needs to have on their calendar. That is when Government Regulation No. 28 of 2024 and BPOM Regulation No. 18 of 2025 take full effect, bringing the most significant regulatory changes to Indonesia’s e-cigarette industry in over a decade.
This article explains what is changing, what you need to prepare, and the steps to take now so your business is in a strong position when the deadline arrives.
What PP 28/2024 Changes
PP 28/2024 is the implementing regulation for Indonesia’s Omnibus Health Law No. 17 of 2023. It replaces Government Regulation No. 109 of 2012 and brings e-cigarettes under the same regulatory framework as conventional tobacco products for the first time in a structured, enforceable way.
Packaging size. After July 26, 2026, open system e-liquid may only be sold in 10ml and 20ml containers. Formats of 30ml, 60ml, and larger that currently dominate the Indonesian market will no longer be permitted. With less than six months remaining, producers who have not yet adjusted packaging, licensing, and distribution strategy are already behind.
Minimum purchase age. The minimum rises to 21, up from the previous threshold of 18. This has direct implications for where and how products can be marketed and sold.
Online sales. PP 28/2024 does not technically ban online sales outright, but it mandates strict age verification for any sale conducted through web services, commercial apps, or social media platforms. In practice, the major Indonesian e-commerce platforms — Tokopedia, Shopee, and others — have signaled they will de-list vape products rather than assume liability for meeting the new verification standards. A narrow legal path for compliant online sales exists in the regulation, but the market reality will be a de facto online ban for most producers.
Proximity restrictions. Sales are prohibited within 200 meters of children’s educational facilities or playgrounds.
Advertising. Social media advertising for vape products is now prohibited. Outdoor, print, and broadcast advertising requirements have also been considerably tightened.
Pictorial Health Warnings. The Pictorial Health Warning area on packaging has increased to 50% of the principal display panel, up from 40% under the previous regulation. Producers redesigning packaging for the new volume formats must account for this from the outset.
PerBPOM 18/2025: The More Technical Change
Issued in July 2025 with the same July 26, 2026 effective date, BPOM Regulation No. 18 of 2025 is where compliance becomes most technical and most consequential for liquid producers.
Ingredient disclosure. For the first time, manufacturers and distributors are required to disclose the full list of ingredients in their products to BPOM. This includes all chemical compounds and flavorings.
In practice, if your flavor supplier has never given you a technical datasheet showing the chemical composition of their formula, you now have a regulatory obligation you may not be able to meet — not because you are non-compliant by intent, but because the information you need to comply was never given to you.
Additive safety testing. Manufacturers are prohibited from using additives unless scientific evidence shows those additives are safe for health. E-liquids must be tested for banned additives before marketing and during circulation, with cross-verification by two different laboratories. This is not a formality. It requires laboratory-verified evidence that every additive in your formula is safe. Without knowing what compounds are in your flavor in the first place, you cannot begin to meet this requirement.
Labeling for REL (Refillable Electronic Liquid) products. Under PerBPOM 18/2025, e-cigarette liquid packaging must carry the statement “Contains Nicotine” and “No Safe Limit.” Unlike combustible cigarettes, e-liquid is not required to state tar levels, since these products are non-combusted. However, packaging that is large enough to accommodate it must still carry the “Contains 7,000 chemicals” health warning, in addition to the enlarged 50% PHW area.
The BNN Factor: A Risk Beyond BPOM
Compliance with BPOM is no longer the only enforcement risk liquid manufacturers face. As of early 2026, the National Narcotics Board (BNN) has become an active and increasingly aggressive participant in the regulatory space for vape liquids.
The trigger is the documented misuse of e-liquid as a delivery medium for synthetic substances. Most notably compounds such as Etomidate and other sedative. BNN has publicly advocated for significantly stricter controls on liquid products and, in some quarters, a total ban.
Producers should understand three specific implications.
Mandatory anti tamper seals. There is active regulatory and enforcement pressure for tamper evident packaging on all liquid products to prevent lacing after production. While not yet formally mandated in the July 2026 framework, producers who act on this requirement are in a stronger position.
All parties involved should wants this space closely, as the debate will continue and regulations will follow.
Correct Regulatory Standards for Flavor Compounds
The relevant frameworks for assessing whether a flavor compound is permitted in an e-liquid product are the following.
EU REACH. Registration, Evaluation, Authorisation and Restriction of Chemicals is the European regulation that classifies chemical substances and restricts their use in consumer products. The most important classification for producers to understand is CMR: Carcinogenic, Mutagenic, or Reprotoxic. Category 1 means the harm is confirmed in humans or strongly indicated by animal evidence. Category 2 means there is reasonable suspicion of harm. REACH restricts CMR Category 1 substances in consumer products above very low concentration thresholds.
The EU Tobacco Products Directive (TPD) goes further specifically for e-liquid. It prohibits any substance with CMR properties from being used in e-cigarettes or refill containers, regardless of concentration. There is no permitted level for a CMR substance in e-liquid under the TPD. The prohibition is absolute.
It is worth noting that flavor safety frameworks designed for food, such as the FEMA GRAS program in the United States or EFSA assessments in Europe , explicitly do not cover inhalation. FEMA has stated clearly that its GRAS assessments apply only to flavor ingredients added to food and are not applicable to vaping products. A flavor being food grade does not mean it is safe to inhale, and it does not satisfy the standards required for e-liquid in regulated markets.
For Indonesian producers, the practical reference points are EU REACH for chemical classification and the EU TPD for what is and is not permitted in e-liquid. These are the standards your buyers in export markets are using, and they are the standards increasingly referenced by BPOM as Indonesia’s own framework develops.
What Has Been Found in Indonesian Market Flavors
GC-MS testing of flavor samples from the Indonesian market has found several compounds with problematic classifications appearing repeatedly. The table below summarizes the most commonly detected restricted substances and why they pose a compliance risk.
| Compound | Common Flavor Note | Classification | Why BPOM Will Flag It |
|---|---|---|---|
| Estragole | Sweet / Anise | Carcinogen 1B | Prohibited in EU TPD; fails additive safety scrutiny at any concentration. |
| Benzaldehyde | Cherry / Almond | Reprotoxic Cat. 2 | REACH restriction; frequently over-concentrated in Indonesian liquid formulas. |
| Acetaldehyde | Fruity / Citrus | Carcinogen 1B | Tracked in emissions assessments; also forms as a byproduct of high-temperature vaping. |
| Diphenyl Oxide | Floral / Rose | Reprotoxic Cat. 2 | Detected at 0.2–0.6% in concentrate samples; not permitted in regulated market e-liquid. |
| Rose Oxide | Rose / Floral | Reprotoxic Cat. 2 | Found at low but measurable concentrations; same prohibition applies. |
The presence of these compounds does not automatically mean the finished product is dangerous at the final consumer dilution level. What it does mean is that the formula contains substances that are prohibited in regulated export markets, and that will fail the additive safety scrutiny now required by PerBPOM 18/2025 domestically. In the current enforcement environment, it also means potential exposure to BNN scrutiny if any unidentified compound is present alongside them.
What to Do
Know what is in your formula
Before you can verify additive safety, you need the complete chemical composition of every flavor you are using. This is the foundation of everything else.
A supplier with properly documented, compliant formulas will have this document ready. If they cannot provide it, that tells you something important about the compliance risk they are transferring to you.
If documentation is not available from your supplier, GC-MS analysis of your current flavor samples is the alternative. It is expensive and should only be used in last resort.
Assess each identified compound against applicable standards
Knowing what is in your formula is half the answer. Knowing whether each compound is permitted under EU REACH and the EU TPD, and whether it will pass BPOM’s additive safety testing, is the other half. Any CMR Category 1 substance must be removed from the formula. Any CMR Category 2 substance must be assessed against permitted concentration limits and against the requirements of your target markets.
Adjust packaging and re-register affected SKUs
The transition to 10ml and 20ml formats requires label redesign, re-filing of product registrations, and managing existing larger-format stock. The new 50% PHW area must be incorporated into any label redesign. Any change to formula, packaging, or manufacturer requires a new pre-market notification to BPOM. Handling both formula and packaging changes in a single notification cycle is more efficient than two separate cycles.
Build your disclosure documentation
PerBPOM 18/2025 requires full ingredient disclosure to BPOM backed by laboratory test evidence and cross-verification from two laboratories. Under the notification framework, new products must be submitted months before they can legally be placed on shelves.
This is the constraint producers consistently underestimate. If you wait until July 2026 to begin testing, you will enter a blackout period of four to six months during which you cannot legally sell any new or reformulated stock. Producers who begin the documentation and notification process now will be ready. Those who begin in June will not.
Why This Is Also an Opportunity
Stricter regulation consistently produces market consolidation. Producers who cannot meet the new requirements exit the market. Those who do meet them gain a larger share of the remaining demand and access to customers they could not reach before.
Producers with complete compliance documentation can supply large domestic retailers who are increasingly requiring regulatory documentation as a condition of working together. They can respond to export inquiries from Singapore, Australia, and other ASEAN markets that already have compliance requirements higher than current Indonesian standards. They can demonstrate to international buyers that their formulas are clean, tested, and documented.
All of this starts from knowing what is in your formula and having the paperwork to prove it. If you are in Indonesia and need help getting there, we are based in Bandung and work with a certified R&D laboratory that provides GC-MS analysis and full compound-level documentation for each flavor. The deadline is close. We are happy to help you understand where you stand before it arrives.

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