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​ 

November 4, 2021
A new royal decree in Thailand (Royal Decree Re: Licensee to Pay the License Renewal Fee in Lieu of a Grace Period When Submitting a License Renewal Application B.E. 2564) does away with the current red tape associated with renewing certain marketing authorization and business licenses. Under the new royal decree, there is no longer any need to submit renewal applications for eligible licenses or to wait for approval from the relevant authority. Instead, the licenses will be automatically renewed upon payment of renewal fees. There are 31 eligible licenses listed in the royal decree, with a focus on licenses for hazardous substances and cosmetics. The royal decree on license renewal was published in the Government Gazette in May 2021 and will come into force on November 22, 2021. Although the new royal decree has not yet come into force, Thailand’s Food and Drug Administration (FDA) has already begun renewing licenses for hazardous substance licenses and cosmetics notification receipts via the new procedure. These licenses and notification receipts are detailed below: (Note: Hazardous substances for household use and public health are classified into four types according to their risk. Products containing type 2 and 3 substances are a higher risk than type 1 and must be registered with the FDA. Type 4 substances are prohibited.) Procedural Guidance The licenses for hazardous substances in the table above should be renewed in the two months preceding their expiry date, while the notification receipts for cosmetics should be renewed in the six months before their expiry date. Renewed licenses are valid for another six or three years (i.e., matching the original validity period). Under the new royal decree on license renewal, eligible licenses for hazardous substances and cosmetics can be renewed by notifying the FDA via its e-submission system. The license holder
October 26, 2021
Parallel imports—branded goods imported into a domestic market and sold there without the consent of the intellectual property (IP) owner—pose a unique challenge for IP owners. In contrast to counterfeit goods, parallel imported goods are manufactured by or under the license of the IP owner and formulated or packaged for a particular jurisdiction and then imported into a different jurisdiction without the authorization of the IP owner. Intellectual property laws and perspectives on parallel import vary throughout Southeast Asia. The distinct legal landscape in each nation should be carefully navigated in consultation with legal experts to ensure brand protection to the fullest degree. This guide provides insight into the legal frameworks relating to parallel imports in Cambodia, Indonesia, Laos, Myanmar, Thailand, and Vietnam. Each section examines the relevant laws and regulations that pertain to parallel imports and explores the remedies available to IP owners in each country. Finally, the guide presents some strategies to combat parallel importation and maximize IP protection in Southeast Asia. The full guide can be downloaded through the button below.   This guide was prepared with the assistance of Tilleke & Gibbins interns Christian Pederson and Keoni Williams.
October 25, 2021
Michael Ramirez, a counsel in Tilleke & Gibbins’ dispute resolution group in Bangkok, has updated the firm’s contribution to the Global Attorney-Client Privilege Guide, published by Lex Mundi. The newly expanded guide provides information on what constitutes attorney-client privilege in over 70 countries around the world. The Thailand section of the guide contains in-depth information on the function and applications of attorney-client privilege in Thailand (or, as explained in the guide, an equivalent concept enshrined in Thai law), including coverage of the following topics: Privilege in corporations Common interest doctrine Litigation funding Crime-fraud exception Work product doctrine/litigation privilege Other privileges including mediation, accountant-client and settlement negotiation The interactive guide features expert contributions by Lex Mundi member firms from jurisdictions worldwide. Readers can browse the contributions, generate country-specific reports, and compare attorney-client privilege in multiple jurisdictions. For more information, please visit the Lex Mundi website.
October 14, 2021
As part of its membership in Lex Mundi, Tilleke & Gibbins has published an updated edition of its Guide to Doing Business in Thailand for 2021. This guide outlines all of the key factors for starting and operating a business in the Thai market. Issues covered include: Investment incentives Financial facilities Exchange controls Import and export regulations Structures for doing business Requirements for the Establishment of a Business Operation of the Business Cessation or Termination of the Business Labor legislation, relations, and supply Tax Immigration requirements This publication is part of Lex Mundi’s Guides to Doing Business series prepared by member firms in more than 100 jurisdictions worldwide. The guides serve as a useful resource when planning an international business strategy or researching a new market.