The skincare industry in Indonesia is growing rapidly, driven by the increasing public awareness of skin health. However, the circulation of skincare products that have not obtained distribution authorization from the Indonesian Food and Drug Authority (BPOM) still frequently occurs. Products without BPOM authorization may contain harmful substances that endanger consumer health. This issue raises the question of the extent to which legal protection can be afforded to consumers, particularly through civil law instruments.

Discussion
1. Relevant Civil Law Provisions
Several legal provisions that may serve as the basis for consumer protection against illegal skincare products include:
Article 1320 of the Indonesian Civil Code
Regulates the validity requirements of an agreement. When a consumer purchases a skincare product, a sales agreement is essentially formed. However, since the object of the agreement (the product) is unlawful—lacking distribution authorization and potentially violating the law—the agreement may be considered null and void by operation of law.
Article 1243 of the Indonesian Civil Code
Regulates compensation for breach of contract. If a business actor promises a product is safe but it turns out to be harmful, such conduct can be categorized as a breach of contract.
Article 1365 of the Indonesian Civil Code
Stipulates that any unlawful act that causes harm to another obliges the perpetrator to compensate for the loss. The production and distribution of skincare products without BPOM authorization can be classified as an unlawful act (onrechtmatige daad).
Law No. 8 of 1999 concerning Consumer Protection (UUPK)
Article 4: Consumers have the right to comfort, security, and safety in consuming goods and/or services.
Article 7: Business actors are obliged to guarantee the quality of goods and/or services produced.
Article 19: Business actors are responsible for providing compensation for losses suffered by consumers as a result of using goods traded.
Law No. 36 of 2009 concerning Health
Prohibits the circulation of medicines and cosmetics without distribution authorization.
2. Consumer Protection Analysis
Invalidity of the sales agreement: Since the product lacks BPOM authorization, the object of the agreement is considered unlawful.
Liability of business actors:
Business actors marketing illegal skincare products may be sued in civil court either under breach of contract or unlawful act claims.
Consumers’ right to sue: Consumers have the right to demand compensation, including refunds, reimbursement of medical expenses, or compensation for physical and psychological damages.
Dispute resolution: Consumers may file lawsuits in the District Court or through the Consumer Dispute Settlement Agency (BPSK).
3. Legal Implications
If found liable, business actors are obliged to pay compensation (Article 1365 of the Civil Code and Article 19 of the Consumer Protection Law).
Products without BPOM authorization may be confiscated and prohibited from circulation.
In addition to civil sanctions, business actors may also be subject to administrative and criminal sanctions (outside the scope of civil law review).

Conclusion:
The circulation of skincare products without BPOM authorization poses serious risks to consumers and may be categorized as an unlawful act under Article 1365 of the Civil Code. From a civil law perspective, consumers have the right to claim compensation for losses suffered through breach of contract or unlawful act mechanisms. Furthermore, the Consumer Protection Law provides additional safeguards by emphasizing the obligation of business actors to guarantee product safety. Therefore, legal protection for consumers can be enforced through civil lawsuits in the District Court or through dispute resolution at the Consumer Dispute Settlement Agency (BPSK).