You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

August 10, 2026

Changes in Nutrition Labeling Requirements in Indonesia

On June 17, 2026, Indonesia’s National Agency of Drug and Food Control (BPOM) issued BPOM Regulation No. 10 of 2026 on Nutritional Information on Processed Food Labels.

The new regulation, which revokes three previous nutrition labeling regulations, introduces several notable changes affecting food and beverage manufacturers, importers, and distributors. These changes range from updated nutrient reference values and serving-size requirements to the introduction of the Nutri-Level front-of-pack labeling system for certain beverage products. Businesses operating in Indonesia should carefully review these developments and assess their products’ compliance with the new requirements during the transition period.

Implementation of the Nutri-Level Labeling System

To implement the recently issued decree on Nutri-Level labeling, BPOM Regulation No. 10 of 2026 stipulates the requirements to implement the Nutri-Level labeling system on the front-of-pack. Under the new framework, ready-to-drink beverages, powdered beverages, and liquid or solid concentrates are required to display Nutri-Level labeling on the front label of their packaging.

The Nutri-Level labeling system classifies products into color-coded levels A through D based on their sugar, sodium, and total fat content. The applicable Nutri-Level is determined based on the lowest level measured in the assessment of sugar, sodium, and total fat content.

For products classified as level C or D, the Nutri-Level label must be accompanied by information on the relevant sugar, sodium, and total fat content per 100 ml of the ready-to-consume product. Products classified as level A or B may either display only the Nutri-Level designation or display the Nutri-Level together with the relevant nutritional information per 100 ml.

Minimum Vitamin and Mineral Content Required for Declaration

BPOM Regulation No. 10 of 2026 introduces a stricter threshold for the declaration of vitamins and minerals in the nutritional value information section (ING).

Vitamins or minerals may only be declared if they are present at a level of at least 5% of the recommended dietary allowance (RDA) per serving, per 100 g, per 100 ml, or per package, in accordance with the inclusion of the ING table, except for processed foods that declare vitamins or minerals claims in accordance with certain laws and regulations. This represents a significant change from the previous regime under the now-revoked BPOM Regulation No. 26 of 2021, under which vitamins and minerals could be declared when present at a level of at least 2% of the RDA per serving.

Revised Serving Size Requirements

While serving size declarations were already required under BPOM Regulation No. 26 of 2021, BPOM Regulation No. 10 of 2026 introduces additional technical guidance on serving-size determination and presentation. The new regulation expressly requires serving sizes to be rounded to the nearest half-unit, providing a standardized approach to serving-size calculations across product categories. An exception applies to products classified under food category 11.6 (sweeteners, including table-top sweeteners and high-intensity sweeteners), which may require businesses to review and, where necessary, update their existing nutrition labeling.

In addition, an appendix to Regulation No. 10 of 2026 sets out updated serving-size references for a wide range of food categories. As a result, food business operators should review the revised category-specific serving-size references to determine whether their existing nutrition information tables, nutrient calculations, and serving-size declarations remain compliant under the new framework. Although serving-size requirements were already regulated under BPOM Regulation No. 26 of 2021, the 2026 regulation provides greater technical detail and updated references that may necessitate label revisions for certain products.

Updated Nutrient Reference Values

BPOM Regulation No. 10 of 2026 updates the nutrient reference values previously set forth in BPOM Regulation No. 9 of 2016 to correspond with the current development of scientific knowledge in health. Several reference values have been revised from those in BPOM Regulation No. 9 of 2016 (e.g., for total fat, vitamin B1, vitamin B2, vitamin B12, magnesium, potassium, and various other vitamins and minerals). As these values are used to calculate the percentage of RDA displayed in nutrition information tables, the revisions may affect the nutrient percentage calculations currently appearing on product labels.

The regulation also introduces updated nutrient reference methodologies and conversion factors. In particular, vitamin B3 may now be expressed in niacin equivalents (NE), folate may be expressed in dietary folate equivalents (DFE), and revised conversion factors have been adopted for vitamins A, D, and E. These changes are intended to align nutrition labeling requirements with current nutritional science and may require food business operators to reassess existing nutrient declarations and label calculations.

Updated Nutritional Value Information Table Formats

BPOM Regulation No. 10 of 2026 updates the standardized formats for the nutritional value information (ING) table. The regulation continues to allow both vertical and horizontal formats and now provides clearer templates for use on product labels.

For horizontal presentation, businesses may use either a three-column tabular format, which provides more space for displaying nutrient information and additional vitamins or minerals, or a two-column tabular format, which offers a simplified layout suitable for products with limited label space.

 

Three-column per-serving tabular format

 

Two-column per-serving tabular format

 

Three-column per-package tabular format

 

Two-column per-package tabular format

 

BPOM Regulation No. 10 of 2026 also introduces specific flexibility for micro-enterprises regarding the ING table. If analytical results are unavailable and the value of a processed food nutrient has not yet been established by the head of BPOM, the values in the ING table should be declared based on calculation results. The procedure for calculating the nutrient content for processed foods produced by micro-enterprises was established by the head of BPOM in 2026 and involves mostly traditional Indonesian food products.

Transition Period

BPOM Regulation No. 10 of 2026 provides a 24-month transition period to facilitate compliance with the new requirements, so processed foods that had already obtained distribution permits before the regulation entered into force, as well as products that were undergoing registration at that time, must be brought into compliance with the new regulation by June 17, 2028. Similar transitional provisions apply to the implementation of Nutri-Level labeling requirements for affected beverage products. As a result, food business operators are afforded additional time to review product portfolios, update nutritional information, and revise product labels where necessary.

Business Impact

The new regulation will require many food and beverage businesses to review their existing nutrition labeling practices in order to comply with the new requirements. In particular, companies should assess the impact of the revised nutrient reference values, updated serving-size requirements, and Nutri-Level labeling requirements on their products.

The Nutri-Level requirements will be especially relevant for beverage manufacturers. Businesses should therefore begin evaluating their product portfolios and preparing any necessary label updates to ensure compliance before the expiry of the 24-month transition period.

RELATED INSIGHTS​ 

July 4, 2023
Practitioners from Tilleke & Gibbins’ Vietnam offices contributed content for the latest edition of the Practical Law Life Sciences Global Guide. The guide provides a comparative overview, in Q&A format, of laws and regulations on pharmaceuticals, medical devices, and other life sciences products in dozens of jurisdictions around the world. The Life Sciences Global Guide is divided into two sections: Commercialization (see more details here) and Regulation, which covers the following topics: Pharmaceuticals: Laws and regulatory authorities Clinical trials: Legal, regulatory, and procedural requirements Manufacturing and distribution Marketing: Authorization for marketing medicinal products, monitoring compliance and penalties, pharmacovigilance and other commitments, foreign marketing authorizations Data privacy Packaging, labeling, and tracking Biological medicines Medical devices: Legislation and regulatory authorities, definition and classification Healthcare IT Combination products and borderlines Natural health products Recent developments and reform proposals Practical Law, produced by Thomson Reuters, is the world’s leading legal know-how resource for business lawyers, publishing a huge range of guides covering hundreds of jurisdictions and practice areas. The full “Life Sciences Regulation in Vietnam” section can be found on the Practical Law website.
June 1, 2023
Life sciences specialists from Tilleke & Gibbins have supplied the Thailand and Vietnam contributions to the International Bar Association (IBA) Healthcare and Life Sciences Law Committee’s global telemedicine survey. The survey, spanning 54 jurisdictions worldwide, functions as a comparative legal guide on the provision of telemedicine and related products and services. It offers practitioners and industry users access to relevant rules and regulations, addressing key aspects such as regulation, data privacy, liability, and recent developments in telemedicine. Telemedicine has emerged as a transformative force in healthcare, revolutionizing the way medical services are accessed and delivered. As in many other jurisdictions, telemedicine has gained prevalence in Thailand and Vietnam, as it enables patients to remotely consult with healthcare professionals, access diagnostic services, and receive timely medical advice while minimizing physical contact. As the global healthcare landscape continues to evolve, understanding the legal and regulatory aspects of telemedicine becomes paramount, making initiatives like the IBA’s telemedicine survey vital for practitioners and industry stakeholders. The IBA is a globally recognized organization that brings together legal professionals and bar associations from around the world, and its Healthcare and Life Sciences Law Committee plays a crucial role in addressing legal issues and developments in the healthcare industry. The complete surveys for Thailand and Vietnam­—and the 52 other participating jurisdictions—are available on the IBA website.
May 23, 2023
Life sciences specialists at Tilleke & Gibbins’ office in Bangkok have contributed a new “Life Sciences Commercialization in Thailand” chapter to the Life Sciences Global Guide from Practical Law. The Q&A-style guide provides strategic information for companies active in the life sciences sector in Thailand. The chapter covers a number of key areas: Overview of the life sciences sector Pricing, government funding, and reimbursement: National health care system, price regulation and reimbursement Distribution and sale Cross-border trade and parallel imports Advertising and engagement with patient organizations Patents: Conditions for patentability, registration, length of protection, infringement, international treaties Trademarks: Requirements, registration Competition law issues: Authorities and legislation, commercial contracts and competition law, licensing approvals and formalities Product liability: Regulators, medicinal product liability law, liable partners, defenses, product liability claims, remedies Practical Law, produced by Thomson Reuters, is the world’s leading legal know-how resource for business lawyers, publishing a huge range of guides covering hundreds of jurisdictions and practice areas. The full “Life Sciences Commercialization in Thailand” section can be found on the Practical Law website.
May 23, 2023
The latest update to Practical Law’s Life Sciences Global Guide includes a new “Life Sciences Regulation in Thailand” chapter by attorneys in Tilleke & Gibbins’ Bangkok office. The chapter covers a range of regulatory issues related to development, manufacturing, and selling of pharmaceutical products and medical devices in Thailand. The chapter provides important information on the following topics: Pharmaceuticals: Laws and regulatory authorities Clinical trials: Legal, regulatory, and procedural requirements Manufacturing and distribution Marketing: Authorization for marketing medicinal products, monitoring compliance and penalties, pharmacovigilance and other commitments, foreign marketing authorizations Data privacy Packaging, labeling, and tracking Biological medicines Medical devices: Legislation and regulatory authorities, definition and classification Healthcare IT Combination products and borderlines Natural health products Developments, reforms, and proposals Practical Law, produced by Thomson Reuters, is the world’s leading legal know-how resource for business lawyers, publishing a huge range of guides covering hundreds of jurisdictions and practice areas. The full “Life Sciences Regulation in Thailand” chapter can be accessed on the Practical Law website.