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

September 9, 2026

Indonesia’s Updated Regulation on Food Packaging

Subscribe to Updates

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.

Related Professionals

Industries

Life Sciences

Practices

Regulatory Affairs

Location

RELATED INSIGHTS​ 

March 2, 2021
The cannabis plant has fascinated many civilizations, societies, and individuals through the centuries with its unique properties, and many have learned how to benefit from these, finding a variety of therapeutic and industrial uses of the plant that, in turn, enhanced domestic economies worldwide. In Thailand, cannabis plants and their derivatives have been used since ancient times as treatment for many diseases, and the plant forms a key ingredient in many Thai traditional medicinal remedies. However, over the past few decades, cannabis usage was seen to change in a way that became incrementally more abusive, resulting in outright prohibition in almost all countries. Thailand was no exception, and in 1979 the Thai government officially enacted the Narcotics Act forbidding the use of cannabis and listing cannabis plants and their derivatives—most notably marijuana (cannabis with psychoactive properties) and hemp (cannabis with limited or no psychoactive properties)—as category 5 narcotics (i.e., prohibited substances). Despite these restrictions, many Thais continued to use cannabis illegally, and some urged the government to legalize personal and commercial use of cannabis plants and their derivatives. Eventually, some in the Thai government agreed that it was time to consider steps toward legalization, As a result, the government has been taking action to delist cannabis plants from the list of prohibited narcotics since 2018, when a regulation allowed the cultivation of hemp for industrial and non-commercial purposes, such as household cooking and research and development. The next significant step came in February 2019, when the Narcotics Act (No. 7) was amended, legalizing medical marijuana within certain limitations. In national elections the following month, the Bhumjaithai political party, whose election campaign included a pledge to decriminalize and legalize cannabis plants, won substantial support in parts of the country and chose to join the coalition government, with the Bhumjaithai party
Read More
February 23, 2021
As many are already aware, following the change of government in Myanmar on February 1, 2021, a draft Cyber Security Law was proposed which attracted widespread criticism. However, less attention has been paid to significant amendments to two existing laws, some of which have a similar effect to parts of the draft Cyber Security Law. In other words, while the draft Cyber Security Law has not progressed further and is under public scrutiny, significant elements of it have found their way into law in Myanmar by other routes. Because these amendments are already law, it is very important that individuals and businesses in Myanmar understand their implications. Amendments to the Law Protecting the Privacy and Security of Citizens The Law Protecting the Privacy and Security of Citizens (2017), or the “Privacy Law,” was amended on February 13, 2021, less than two weeks after the military government came into power. These amendments chiefly address the power of the government to conduct searches, seizures, and arrests; to extend detention without judicial oversight; and to carry out broad surveillance and investigation activities that could intrude on individual privacy. The amendments accomplish this by suspending various sections of the Privacy Law for as long as the State Administration Council (the military body now governing Myanmar) is in power. The suspended sections include the following: Section 5: Search, seizure, and arrest without civilian observation The relevant part of Section 5 of the Privacy Law states, “The responsible authorities shall … when acting in accordance with existing law, not enter into a person’s residence or a room used as a residence, or a building, compound or building in a compound, for the purpose of search, seizure, or arrest, unless accompanied by minimum of two witnesses who should comprise Ward or Village Tract Administrators…”. The suspension
Read More