Indonesia Revises Draft Amendment to Microbiological Limits for Processed Foods Image

Indonesia Revises Draft Amendment to Microbiological Limits for Processed Foods

Date
31 Mar 2026

Reference source : World Trade Organization

Contaminants in Food Food Industry Food Safety Indonesia

Jakarta, March 2026. Indonesia has circulated an addendum to its draft amendment to National Agency of Drug and Food Control Regulation No. 13 of 2019 on the maximum limits of microbial contamination in processed foods. The revised draft updates the content and scope of the previously notified measure and focuses on four specific food categories, reflecting the authorities’ effort to address newer processed food types, implementation issues under the current framework, and developments in science and technology.

Relevant background and regulatory context

The draft amendment is positioned as a revision to BPOM Regulation No. 13 of 2019, which remains the core Indonesian rule establishing maximum microbial contamination limits for processed foods. According to the draft text, the existing 2019 regulation is considered no longer fully aligned with scientific and technological developments in the processed food sector, prompting BPOM to update selected microbiological criteria rather than replace the framework entirely.

This means the current proposal should be understood as a targeted amendment to the existing microbial contamination regime, not a wholly new regulation. The main structure of the 2019 rule remains in place, while specific product entries and microbiological criteria are being expanded or revised.

What the revised draft does

The amended draft is limited to four food categories.

First, it adds a new processed food type under Category 06.4.3 for pre-cooked pasta, noodles, and similar products, namely ready-to-eat flour- or starch-based processed foods.

Second, it adds a new processed food type under Category 08.3.2 for comminuted and heat-treated meat products, namely sausages and meatballs subjected to pasteurization.

Third, it revises the microbiological criteria for flavoured powdered beverages under Category 14.1.4.3 where the product contains milk, milk products, creamer, or chocolate.

Fourth, it revises the microbiological criteria for tea products under Category 14.1.5, specifically dry tea, powdered tea, and tea bags, including black tea, green tea, white tea, oolong tea, and scented tea.

Newly added food categories and products

A notable feature of the draft is that it expressly introduces microbiological criteria for food types that were not previously covered in a sufficiently specific way.

For ready-to-eat flour- or starch-based products under the pre-cooked pasta and noodle category, the draft sets microbiological parameters for total plate count, Bacillus cereus, Salmonella, Staphylococcus aureus, and Escherichia coli.

For pasteurized sausages and meatballs under the heat-treated comminuted meat category, the draft establishes parameters for total plate count, Enterobacteriaceae, Staphylococcus aureus, Salmonella, and Listeria monocytogenes.

These additions indicate BPOM’s intention to assign more product-specific microbiological controls to processed foods that may present different contamination risks depending on composition and processing method.

Changes for flavoured powdered beverages

The draft also updates the microbiological criteria for flavoured powdered beverages that contain milk, dairy products, creamer, or chocolate. For this product group, the revised annex sets limits for total plate count, yeasts and moulds, and Salmonella.

This is one of the more commercially relevant parts of the amendment because the draft includes an express transition provision for this category. Products in this group that have already received business licensing to support commercial activities before the new regulation takes effect would be required to align with the new requirements within 12 months from promulgation. The same 12-month adjustment period would also apply to products already under application when the regulation is issued.

Changes for tea products

Another important update concerns tea products under Category 14.1.5. The draft revises the criteria for dry tea, powdered tea, and tea bags, including black, green, white, oolong, and scented tea.

For dry tea and powdered tea, the amended annex sets revised limits for total plate count and yeasts and moulds. Tea bags are also covered separately, with distinct microbiological thresholds. This suggests BPOM is refining the current framework to better reflect differences in product format and handling conditions across tea products.

Transitional arrangements

The draft contains a specific transition clause for flavoured powdered beverages containing milk, dairy products, creamer, or chocolate. Existing authorized products and products already in the licensing pipeline would still need to comply with the new rules within 12 months from the date the amended regulation is promulgated.

The draft also clarifies that the relevant business licensing serves as the legal basis for circulating processed food in Indonesia, including home industry processed food products. This gives the transition clause practical significance for both established market players and pending applicants.

Why the amendment was introduced

Indonesia states that the amendment has been developed for three main reasons. First, scientific and technological developments in processed food have made parts of the 2019 regulation outdated. Second, new processed food types have emerged for which microbiological criteria have not yet been established. Third, the authorities have identified implementation challenges under the existing regulation, including issues in applying microbiological criteria to certain commodities.

Taken together, these reasons show that the amendment is both technical and practical in purpose. It is not only updating the science behind the limits, but also trying to make the framework easier to apply to real product categories in the market.

Business implications

For food manufacturers, importers, and brand owners placing processed foods on the Indonesian market, the draft signals more tailored microbiological compliance expectations for selected products. Companies active in instant or ready-to-eat starch products, pasteurized meat products, powdered beverage mixes, and tea products should review whether their specifications, testing protocols, and technical dossiers align with the revised criteria.

The transition period for certain powdered beverages is particularly important, as businesses with existing authorizations may need to reassess formulations, microbial control measures, and product testing within the 12-month adjustment window once the amendment is finalized.

Next steps

The WTO addendum states that the updated draft is open for comments for 60 days from circulation of the addendum, with a deadline of 24 May 2026. Adoption and entry into force have not yet been confirmed in the addendum. If adopted, the measure would update selected microbiological criteria under Indonesia’s 2019 processed food contamination framework while leaving the broader regulation in place.


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