Indonesia enforces new restrictions on food labeling

The National Agency of Drug and Food Control (BPOM) of Indonesia has issued a regulation amending the country’s food labeling regulations by implementing various additional restrictions and providing extra clarity on food labeling requirements—not only for finished food products, but also for food additives and food products for further handling.

Regulation No. 20 of 2021 (an amendment to Regulation No. 31 of 2018) contains the changes, which went into effect on August 2, 2021. The time limit for final food products to comply with the new labeling requirements is December 31, 2021, and the deadline for food additives and food products for further processing is August 2, 2022.

The latest regulation has added some new requirements, which are outlined below.

Final Food Products

• Non-halal food: Food products containing non-halal ingredients are excluded from halal certification requirements, according to the new regulation. This clause is significant because it expressly states that non-halal food can still be sold and distributed in Indonesia.
• Ingredient percentages: Ingredient content percentages should be included in the ingredient list on a food label, as well as any ingredients that are highlighted on the label in words or pictures or are indicated as part of the food name.
• Polyol warning: Food products containing polyol must now carry a warning to this effect on their labels.
• Allergen information: The new rule allows for a different method of indicating allergen information on food labels. Allergens had to be listed in bold type in the ingredients list, and the label had to include the disclaimer “contains allergens, see list of ingredients printed in bold.” However, the new regulation allows allergen details to be declared on the label by using the phrase “contains allergens:” followed by the allergen name(s) printed in bold. It is no longer necessary to print allergen ingredients in bold in the ingredient list with this new option.
• Comparison claims: Food labels that use terms like “special,” “premium,” “gold,” “platinum,” “extra,” “plus (+)”, “advanced,” or similar words to compare the quality or nutrient content of one product to another must include an asterisk (*) after the comparison claim. The asterisk’s descriptive information must include information on specific attributes and, when appropriate, comparative food products of the same type, and it must be placed on a fully visible and easy-to-read part of the label.

Food Products for Further Processing

According to the new regulation, food products destined for further processing must be labeled with a disclaimer such as “Not for Retail Sale,” “Not for Repackaging,” “Only for Hotels, Restaurants, and Catering,” or something similar. This requirement does not apply if the food goods are sold directly from the manufacturer to the business operator who will further process the food product, or if the manufacturer or importer appoints the supplier of the food product.

Food Additives

According to the new regulation, food additive labels for retail sales must state the max amount of the additive that can be used in a food product. A processing aid for use in food processing must also be confirmed in the ingredient list if the food additive contains one.

Label Assessment

The new regulation also provides clear guidance for evaluating food labels that may contain unregulated information. In order to acquire approval from BPOM, there is also a new application form and a list of required information for food label assessment.