Indonesia Imposes Additional Food Labeling Restrictions

Indonesia’s National Agency of Drug and Food Control (BPOM) has recently enacted a significant update to the country’s food labeling regulations. This update, encapsulated in Regulation No. 20 of 2021, which amends Regulation No. 31 of 2018, introduces a range of new restrictions and clarifications affecting food labeling across various categories. The updated regulations took effect on August 2, 2021, with compliance deadlines set for December 31, 2021, for final food products and August 2, 2022, for food additives and products intended for further processing.

Key Changes in Food Labeling Regulations

Final Food Products

1. Non-Halal Foods: The revised regulation clarifies that products containing non-halal ingredients are not subject to halal certification requirements. This update affirms that non-halal food products can still be marketed and distributed within Indonesia.
2. Ingredient Percentages: Food labels must now include the percentage of each ingredient, especially for ingredients highlighted on the label or integral to the food’s name, either through text or imagery.
3. Polyol Warning: Labels containing polyols must feature a specific warning about this ingredient.
4. Allergen Information: The new regulation introduces a more flexible approach to allergen labeling. Instead of requiring allergens to be listed in bold within the ingredient list, the label can now simply state “contains allergens:” followed by the allergen names in bold. This change aims to simplify allergen information presentation.
5. Comparison Claims: Labels making comparative claims regarding quality or nutrient content, using terms such as “special,” “premium,” “gold,” “platinum,” “extra,” “+,” or similar terms, must include an asterisk (*) next to the claim. The explanatory note for the asterisk must detail the distinguishing features and, if applicable, comparable products of the same type. This information must be visible and easy to read.

Food Products for Further Processing

1. Label Disclaimers: Labels on food products intended for further processing must carry disclaimers such as “Not for Retail Sale,” “Not for Repackaging,” or “Only for Hotels, Restaurants, and Catering,” among others. This requirement does not apply if the product is sold directly from the manufacturer to a business operator responsible for further processing or if the distributor is directly appointed by the manufacturer or importer.

Food Additives

1. Maximum Allowable Amount: Labels for food additives sold at retail must state the maximum allowable quantity of the additive permissible in the final food product. Additionally, any processing aids used in food processing must be listed in the ingredient list.

Label Assessment

1. New Assessment Procedures: The updated regulation includes detailed guidelines for evaluating food labels that might contain additional unregulated information. A new application form and a comprehensive list of required details for label assessment have also been introduced to streamline the approval process with BPOM.

These amendments aim to enhance transparency and consumer protection by ensuring clearer, more precise food labeling standards across Indonesia.