On June 30, 2026, Indonesia’s National Agency of Drug and Food Control (BPOM) issued BPOM Regulation No. 11 of 2026 on Food Packaging, which expands the list of approved food-contact substances and recognizes a broader range of permissible functions for those substances. The new regulation, which revokes BPOM Regulation No. 20 of 2019, reflects developments in packaging technology and materials science.
Although the new regulation provides more advantages to business actors by adding more food contact substances to the approved list for use in food packaging, there are more stringent rules and restrictions for testing. One of the most significant changes is a comprehensive migration-testing framework that sets out requirements for packaging materials, testing conditions, food simulants, and specific migration limits.
Overall and Specific Migration
Under BPOM Regulation No. 20 of 2019, migration requirements were primarily set out within the lists of approved food-contact substances and packaging materials. BPOM Regulation No. 11 of 2026 instead expressly requires packaging materials that come into direct contact with food to meet both overall and specific migration limits. These are defined as follows:
- Overall migration: The total quantity of all substances that migrate from the packaging, regardless of whether the substances are hazardous or nonhazardous to health.
- Specific migration: The quantity of a particular identified substance known to be hazardous to health that migrates from the packaging.
Stricter Limits on Heavy Metals
The overall migration limit for plastic packaging remains unchanged under both regulations at 60 mg/kg or 10 mg/dm². However, the new regulation introduces significant changes to the regulation of heavy metals. Under the 2019 regulation, four heavy metals—lead, cadmium, chromium VI, and mercury—were subject to a single combined limit of 1 mg/kg. The 2026 regulation, however, requires each heavy metal to meet its own individual specific migration limit, adds arsenic as a newly regulated substance, and broadens the scope of chromium testing from chromium VI (Cr(VI)) to total chromium (Cr). The specific migration limits under the 2026 Regulation are set out below:
- Arsenic (As): Not detected (LOD 0.01 mg/kg)
- Cadmium (Cd): Not detected (LOD 0.002 mg/kg)
- Total Chromium (Cr): Not detected (LOD 0.01 mg/kg)
- Lead (Pb): 0.05 mg/kg
- Mercury (Hg): Not detected (LOD 0.01 mg/kg)
Updated Rules on Food Simulants
A food simulant is a medium used to mimic the characteristics of a particular food to simulate the migration of components from the food packaging into the food. The 2026 regulation identifies five types of food simulants for use in overall migration testing, as follows:
- Simulant A: Ethanol 10% (v/v)
- Simulant B: Acetic acid 3% (w/v)
- Simulant C: Ethanol 20% (v/v)
- Simulant D1: Ethanol 50% (v/v)
- Simulant D2: Vegetable oil containing less than 1% unsaponifiable matter; if food simulant D2 cannot be used, 95% alcohol or isooctane may be used as an alternative food simulant
- Simulant E: Poly (2,6-diphenyl-p-phenylene oxide), particle size 60–80 mesh, pore size 200 nm
Under the 2019 regulation, simulant D2 was defined as vegetable oil, with no specific compositional requirements. The 2026 regulation narrows this definition and provides an alternative for situations where simulant D2 cannot be used.
New Requirements for Food Product Composition
The 2026 regulation introduces new disclosure requirements for the composition of food products that may come into contact with their packaging material. The name, percentage, and function of each component must be declared, and the sum of all declared percentages must equal 100%.
New Testing Requirements for Reusable Plastic Packaging
The 2026 regulation introduces additional requirements for reusable food packaging. Reusable plastic packaging must meet both the overall and specific migration limits through the testing protocol prescribed in Annex V.
For overall migration, compliance may be demonstrated in a single test. If the first result meets the applicable limit, no further testing is required. If it does not, up to two additional tests are permitted, provided that the results show a decreasing trend, with the second result lower than the first, and the third lower than the second.
Specific migration, by contrast, requires three tests in order to simulate the repeated contact that occurs over the packaging’s service life. Each result must meet the applicable specific migration limit, and the levels must not increase across the cycles; the second result may not exceed the first, and the third may not exceed the second. Compliance depends on these results, as well as on the stability of the packaging material throughout the three testing cycles. A material is considered unstable if detectable migration increases from the first test to the third, even when the migration values remain below the applicable regulatory limit.
Because contact under single-use conditions represents the worst-case scenario for migration, test data generated under those conditions is generally understood to support compliance for repeated-use applications as well.
Transition Period
BPOM Regulation No. 11 of 2026 provides a 12-month transition period from its promulgation date to allow food packaging products already circulating in the market to comply with the new requirements. Food packaging that was already in circulation before the regulation entered into force must be brought into compliance with the new regulation by June 30, 2027.
Business Impact
BPOM Regulation No. 11 of 2026 updates Indonesia’s food packing rules to better respond to developments in food packaging technology and materials science. Food packaging manufacturers, importers, and brand owners in Indonesia should review existing compliance practices and test reports to confirm that packaging intended for direct food contact meets the new overall and specific migration requirements.
