The widespread circulation of hazardous skincare products in Indonesia, including
those containing mercury, hydroquinone, and corticosteroids, even those with
distribution permits from BPOM, raises serious concerns about the effectiveness of
BPOM's regulatory oversight. This study analyzes the potential criminal liability of
BPOM for negligence in supervising such products. Using a normative juridical
approach, it examines relevant regulations and the legal concept of criminal
negligence, including the functioneel daderschap doctrine. The findings indicate
that BPOM's failure to adequately monitor product safety may constitute criminal
negligence, underscoring the need for stronger accountability mechanisms to safeguard public health