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December 10, 2021

Indonesia Imposes Additional Food Labeling Restrictions

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Indonesia’s National Agency of Drug and Food Control (BPOM) has issued a regulation to amend the country’s food labeling regulations by instituting various additional restrictions and providing additional clarity on food labeling requirements—not only for final food products but also for food additives and food products for further processing.

The additions are contained in Regulation No. 20 of 2021 (an amendment to Regulation No. 31 of 2018), which took effect on August 2, 2021. The deadline to comply with the new labeling requirements for final food products is December 31, 2021, and the deadline for requirements related to food additives and food products for further processing is August 2, 2022.

The new requirements introduced by the latest regulation are outlined below.

Final Food Products

  • Non-halal foods. The new regulation clarifies that food products containing non-halal ingredients are exempt from halal certification requirements. This provision is important as it explicitly confirms that non-halal food products can still be sold and distributed in Indonesia.
  • Ingredient percentages. Percentages of ingredient content must be included in the list of ingredients on a food label, and on any ingredients that are emphasized on the label in words or pictures, or stated as part of the food name.
  • Polyol warning. Labels for food products containing polyol must now include a warning to this effect.
  • Allergen information. The new regulation provides an alternative for indicating allergen information on the food label. Under the 2018 regulation, allergens had to be indicated in the ingredients list in bold type, and the label had to have the disclaimer “contains allergens, see list of ingredients printed in bold.” The new regulation, however, allows allergen information to be declared on the label with the phrase “contains allergens:” followed by the allergen name(s) printed in bold. With this new alternative, it is no longer required to print allergen ingredients in bold in the list of ingredients.
  • Comparison claims. Food labels that compare the quality or nutrient content with another product, using terms such as “special,” “premium,” “gold,” “platinum,” “extra,” “plus (+)”, “advanced,” or similar words, must display an asterisk (*) after the comparison claim. The explanatory information for the asterisk must include information on distinguishing features and, when appropriate, comparative food products of the same type, and must be placed on a part of the label that is clearly visible and easy to read.

Food Products for Further Processing

The new regulation stipulates that the labels of food products for further processing must include an appropriate disclaimer such as “Not for Retail Sale,” “Not for Repackaging,” “Only for Hotels, Restaurants, and Catering,” or similar. This requirement does not apply if the food product is sold directly from the manufacturer to the business operator that will further process the food product, or if the distributor of the food product is directly appointed by the manufacturer or importer.

Food Additives

The new regulation requires labels for food additives for retail sale to state the maximum allowable amount of the additive that can be used in a food product. Also, if the food additive contains a processing aid for use in food processing, it must be declared in the list of ingredients.

Label Assessment

The new regulation also provides clear information for assessment of food labels that may include additional unregulated information. There is also a new application form and list of required information for food label assessment in order to obtain approval from BPOM.

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