Reference source : World Trade Organization
Indonesia’s Halal Product Assurance Organizing Agency (BPJPH) has notified three draft regulations covering halal-certificate updates, ongoing compliance with the Halal Product Assurance System (SJPH), and conformity checks for foreign halal products entering Indonesia. The drafts were notified to the World Trade Organization under references G/TBT/N/IDN/188, G/TBT/N/IDN/189 and G/TBT/N/IDN/190.
The proposed measures form part of the implementation of Government Regulation No. 42 of 2024 on Halal Product Assurance. They would affect domestic and foreign manufacturers, exporters, importers, brand owners and ingredient suppliers whose products fall within Indonesia’s phased mandatory halal-certification framework. This framework covers food, beverages, pharmaceuticals, cosmetics, chemical products, biological products, genetically engineered products and certain consumer goods.
Draft Regulation G/TBT/N/IDN/189 would establish procedures for updating a halal certificate when a business changes its ingredients, production processes, manufacturing facilities, products or trademarks. Relevant changes may include adding, replacing or removing an ingredient, modifying halal production activities, changing a production location or introducing another product within an existing product category. The updated certificate would retain its original certificate number.
The applicable procedure would depend on the nature of the change and the certification route originally used. Limited changes may be handled through a report to BPJPH, while changes involving unregistered foreign ingredients, ingredients without recognised halal documentation or significant production-process modifications may require examination or testing by a Halal Inspection Agency.
Applications would be submitted through BPJPH’s integrated electronic system. Businesses may need to provide details of the affected products and ingredients, evidence of the ingredients’ halal status, ingredient-use matrices, production-facility documents and information about the revised production process. Failure to submit requested documents or complete payment within the prescribed period could result in cancellation of the application.
The draft would apply to domestic and foreign businesses holding halal certificates issued directly by BPJPH. It would not govern certificates issued by foreign halal institutions recognised by BPJPH.
Draft Regulation G/TBT/N/IDN/188 would establish an ongoing compliance cycle for holders of BPJPH-issued halal certificates. Businesses would be required to undergo an assessment of their SJPH implementation once every four years and obtain a certificate confirming the continued consistency of their halal-compliance system.
Certificate holders would also need to report annually on their ingredients and halal production processes, submit internal-audit results and document management reviews. If BPJPH identifies an ingredient or production change that has not been reported, it may direct the business to update its halal certificate or correct the certificate information.
The assessment method would depend on factors such as business size, product risk and previous reporting compliance. Assessments could be conducted on-site, remotely or, for eligible lower-risk micro and small businesses, through self-assessment. The risk assessment may consider the type and number of products, production facilities, marketing area and consistency of regulatory reporting.
A halal-consistency certificate would remain valid for four years. Businesses would need to apply for the next assessment during the three months before the certificate expires. Existing certificate holders would have up to one year following adoption of the regulation to align their reporting and assessment procedures with the new requirements.
Draft Regulation G/TBT/N/IDN/190 would introduce a shipment-specific conformity-assurance procedure for foreign halal products entering Indonesia. Inspections would be conducted at the loading warehouse in the country of origin or shipment before the goods are dispatched to Indonesia.
An inspection body appointed by BPJPH would compare the products with the relevant halal certificate or registered foreign halal certificate. The review would cover product identity, certificate and registration numbers, HS classification, quantity, production codes, production dates and labelling. It would also examine potential contamination risks during storage and transport, the country of production and the recognition status of the foreign halal institution.
Supporting documents could include purchase records, certificates of analysis, certificates of origin and safety data sheets where relevant. Importers would apply electronically for a Halal Product Assurance Report, known as an LPPH, and provide business, importer, tax, product, certificate and HS-code information.
The inspection would normally be completed within 15 calendar days after the required scheduling information is received, although an additional 15 days may be allowed. Each LPPH would cover only one shipment or entry and would need to be available when the customs import declaration is submitted. The proposed system would exchange information through Indonesia’s National Single Window.
Failure to obtain the required LPPH or pay an outstanding assessment fee could result in administrative measures. Depending on the circumstances, these may include written warnings, cancellation of a halal certificate or registration number, withdrawal of the products from circulation or destruction of the goods.
| WTO reference | Draft measure | Notification date | Comment deadline |
|---|---|---|---|
| G/TBT/N/IDN/188 | SJPH implementation assessment | 23 July 2026 | 21 September 2026 |
| G/TBT/N/IDN/189 | Halal-certificate updates | 23 July 2026 | 21 September 2026 |
| G/TBT/N/IDN/190 | Conformity assurance for foreign halal products | 30 July 2026 | 28 September 2026 |
The adoption and general entry-into-force dates for the draft package have not yet been determined. The imported-product regulation is expected to apply 30 days after promulgation, although this timing remains subject to the final adopted text.
Companies holding BPJPH-issued halal certificates may need to strengthen their procedures for identifying and reporting changes to formulations, ingredients, manufacturing locations and production processes. The proposed annual reporting and four-year assessment cycle would make halal certification an ongoing compliance responsibility rather than a one-time approval.
For foreign products, the proposed shipment-level LPPH could introduce an additional pre-shipment inspection and customs-documentation step. Importers and exporters may therefore need to coordinate halal certificates, labels, product descriptions, HS codes and shipment records before goods leave the country of origin.
The final scope will depend partly on a separate BPJPH decision identifying the products and HS codes subject to the imported-product conformity procedure. Companies should therefore follow the consultation process and review the final adopted texts before changing their compliance procedures.