Food safety incidents can emerge without warning, requiring businesses to act swiftly to protect consumers and comply with regulatory obligations. Across Southeast Asia, Thailand, Vietnam, and Indonesia have each developed comprehensive food recall frameworks designed to ensure rapid removal of unsafe products from the market while holding businesses accountable for compliance failures. While these three jurisdictions share common objectives—protecting public health and ensuring food safety—each has crafted distinct regulatory approaches reflecting their unique administrative structures, enforcement priorities, and legal traditions. Understanding these differences is essential for food businesses operating in the region, as recall procedures, timelines, reporting requirements, and penalties vary significantly across borders. This guide, available through the button below, examines the food recall regulations in Indonesia, Thailand, and Vietnam, providing practical guidance on legal requirements, procedural steps, and compliance obligations in each market.

The Indonesian Food and Drug Administration (BPOM) has introduced more stringent oversight of health supplements containing probiotics with new guidelines that require clinical trials for certain products and expanded documentation standards. BPOM Regulation No. 17 of 2025 replaces the previous 2021 regulation and establishes a comprehensive framework for evaluating probiotic strains used in health supplements. Assessment Requirements The new regulation expands the scope of assessment to include not only categorization and documentation but also technical procedures, strain classification, and clinical trial requirements. Unlike the previous regulation, which provided general guidance, the updated framework creates a comprehensive system for evaluating both registered probiotic strains and new or combined strains. Manufacturers must now submit supporting documentation covering strain identification and functional characterization, safety, efficacy, and product quality. The previous regulation required documentation only on safety, efficacy, and quality. Clinical Trials One of the most significant changes is the requirement for clinical trials conducted in Indonesia for applications that include benefit claims other than maintaining digestive health, or where there are modifications to benefit claims. The regulation specifies that phase 1 trials must demonstrate safety, while phase 2 trials must validate efficacy using statistically valid methods such as double-blind, randomized, placebo-controlled studies). In addition, phase 3 and phase 4 trials may be required, and postmarket surveillance data must be submitted. Technical Assessment Framework Annex 4, a newly introduced section, establishes technical procedures for assessing health supplements containing probiotics in Indonesia. This comprehensive framework outlines criteria for evaluating new probiotic strains, including strain identification, functional characterization, safety, efficacy, and product quality. The annex introduces a clear classification of claims for health supplement products containing probiotics: General claims(e.g., maintaining digestive health). Functional claims(e.g., normal biological function or activity in the body). Risk reduction claims(e.g., lowering disease risk). The regulation restricts use of the term

The Indonesian government has implemented mandatory halal certification to protect its predominantly Muslim population. To ensure halal standards, the government has issued several key regulations, including Law No. 33 of 2014 concerning Halal Product Assurance, Government Regulation No. 42 of 2024 concerning Implementation of Halal Product Assurance, and specifically for imported products, Decision of the Head of Halal Product Assurance Agency (BPJPH) No. 90 of 2023 concerning Procedures of Implementing Foreign Halal Certificate Registration. Compliance Deadlines The government has established statutory deadlines for products and services to obtain halal certification under Government Regulation No. 39 of 2021 concerning Implementation of Halal Product Assurance. The deadline for imported food, beverages, and slaughtering products and services to comply with halal certification was extended to October 17, 2026 (from October 17, 2024, originally) with the issuance of Government Regulation No. 42 of 2024. Other product categories have varying deadlines: October 17, 2026: Natural drugs, quasi-drugs, health supplements, cosmetics, chemical products, genetically engineered products, clothing and accessories, household supplies, prayer equipment, stationery, and class A medical devices October 17, 2029: Over-the-counter drugs and class B medical devices October 17, 2034: Prescription drugs (excluding psychotropics) and class C medical devices SHLN Registration for Imports To simplify the halal certification process for imported products, BPJPH offers a foreign halal certificate registration (Registrasi Sertifikat Halal Luar Negeri, or SHLN registration) pathway. This allows eligible imported products to obtain halal certification without filing the standard national halal certification procedure. Under the Halal Law, imported products are not required to apply for national halal certification if their halal certificate is issued by a foreign halal institution that has entered into a mutual recognition agreement (MRA) with BPJPH. Currently, 89 foreign halal institutions from countries (including the United States, South Korea, Thailand, and the United Kingdom) have entered into

Indonesia’s current regulations on franchises, as stipulated under Government Regulation No. 35/2024 on Franchising and its implementing regulation, Ministry of Trade (MOT) Regulation No. 71/2019 regarding Implementation of Franchising, highlight fundamental changes in franchise registration. These changes have introduced additional complexities and challenges in the franchise registration procedure, making it more difficult for franchise owners to navigate the process. New procedure Franchise applications are still submitted through the Online Single Submission (OSS) portal of the Capital Investment Coordinating Board (BKPM). However, the new procedure requires each applicant, including foreign franchisors, to have an OSS account and a business registration number (NIB) issued by BKPM. An application for franchise registration must be submitted under the applicant’s own account—submissions can no longer be made through the account of a consultant. Once a franchise application is submitted, the authority will distribute the submission to the MOT—the authorized ministry for franchise registration. Any notification or decision upon the registration made by the MOT will be available in the OSS system. Applicants should regularly monitor the status of the franchise application because no notifications will be sent to applicants to alert them of any deficiency. Here is the summary of the new procedure for franchisors: Notable Requirements The disclosure document, or prospectus, is the key focus for the MOT in examining a franchise registration for a franchisor. This document is subject to thorough scrutiny by the MOT to ensure that all mandatory information meets the requirements set in the franchise regulations. The current regulations specifically require that the mandatory clause “business system” in the prospectus cover operational standards and procedures, which should include human resource management, administration, operational management, standard operating methods, business location selection, business premises design, employee requirements, and marketing strategies. Other clauses that are equally important to pay attention to are: