FAIRS Country Report Annual Jakarta Indonesia ID2024-0046
FAIRS Country Report Annual Jakarta Indonesia ID2024-0046
Post: Jakarta
Report Highlights:
This report provides updated technical information for requirements and regulations on food and
agricultural products as currently required by the Government of Indonesia (GOI). Sections that
have been updated for this year include Food Additive Regulations; Labeling Requirements;
Other Requirements, Regulations, and Registrations Measures; and Import Procedures. The
appendices have also been updated and a section on Trade Facilitation has been added.
THIS REPORT CONTAINS ASSESSMENTS OF COMMODITY AND TRADE ISSUES MADE BY USDA STAFF AND NOT
NECESSARILY STATEMENTS OF OFFICIAL U.S. GOVERNMENT POLICY
Disclaimer
This report was prepared by the Office of Agricultural Affairs of the USDA/Foreign Agricultural
Service in Jakarta, Indonesia for U.S. exporters of domestic food and agricultural products.
While every possible care has been taken in the preparation of this report, information provided
may not be completely accurate either because policies have changed since its preparation, or
because clear and consistent information about these policies was not available. It is highly
recommended that U.S. exporters verify the full set of import requirements with their foreign
customers, who are normally best equipped to research such matters with local authorities,
before any goods are shipped. FINAL IMPORT APPROVAL OF ANY PRODUCT IS
SUBJECT TO THE IMPORTING COUNTRY’S RULES AND REGULATIONS AS
INTERPRETED BY BORDER OFFICIALS AT THE TIME OF PRODUCT ENTRY.
Table of Contents
SECTION I: FOOD LAWS……………………………………………………………...………………………….5
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EXECUTIVE SUMMARY
Below is a summary of changes found within the FAIRS Country Report 2024:
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- Government Regulation No. 42/2024 mandates the transition of BPJPH to a stand-
alone entity that reports directly to the President and is no longer under the Ministry
of Religious Affairs (MORA). In addition, the regulation extends the deadline for
mandatory halal certification implementation for imported food and beverage
products by no later than October 17, 2026.
- MORA No. 944/2024 updates MORA Decree No. 748/2021 by revising the food and
beverage products category’s list of product types that are required to be halal certified.
In addition, MORA Decree No. 816/2024 lists the HS Code of the food and beverage
products that requires halal certification.
The food safety control system in Indonesia includes a broad range of pre-market and post-
market controls. Pre-market controls are conducted by evaluating the food safety of products to
ensure the compliance with safety and quality requirements prior to retail. If a product meets the
necessary requirements, the product is provided with a registration approval number and
becomes eligible for retail market. Post-market controls are conducted after food products have
been distributed in the market and/or retail outlets. The National Agency for Drug and Food
Control (BPOM) maintains that it is necessary for Indonesia to focus on pre-market controls due
to the wide area of coverage and Indonesia’s challenging geography.
Exporters report that one of the most difficult issues they face is the requirement that all
imported retail packaged food products must be registered through BPOM (registration
requirements also apply for food produced locally). In addition to registration numbers, some
imported products require additional approvals from other Government of Indonesia (GOI)
regulatory agencies. For example, for many agricultural products, an import recommendation
from the Ministry of Agriculture (MOA) is required in addition to an import license from the
Ministry of Trade (MOT). Imports of meat, poultry, dairy and horticultural products can be
subject to shifting regulations and requirements. Food additives require approval from BPOM,
and special labeling requirements may apply. Indonesia requires Indonesian language labels,
although currently supplementary labels (stickers) can be added. Mandatory labeling information
includes product name, ingredients list, weight or net volume, name and address of the
manufacturer or importer, date or production code, use by date, BPOM registration number, and
the source of certain food products. Halal certification labeling is already required for animal
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products not containing pork but will be mandatory for almost all food and beverage products by
no later than October 17, 2026.
On November 2, 2020 the GOI issued Law No. 11/2020 on Job Creation that amended several
previous laws including those on fisheries, agriculture, halal certification and the food sector.
The new law aims to simplify investment-related laws to generate a more competitive business
climate and to focus on simplification of business licenses requirements. Several implementing
regulations for this law have been issued this year, including:
On March 31, 2023, the Government of Indonesia issued Law No. 6/2023 on the Stipulation of
Government Regulation in Lieu of Law No. 2 of 2022 on Job Creation Intended to Become Law,
which revoked Law No. 11/2020 on Job Creation.
Food Law No. 18/2012 regulates all food and food products, defined as all food originating from
biological agricultural sources. Biological agricultural sources include agriculture, plantations,
forestry, fishery, livestock, aquaculture, and water. Products originating from biological
agricultural sources include processed and unprocessed products intended as food and/or
beverages for human consumption, food additives, raw materials, and other materials utilized in
the preparation, processing, and/or production of food and/or beverages.
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Law No. 18/2012 also states that the food supplies should always be sufficient, safe, high
quality, diverse, affordable, and may not conflict with religion, beliefs and culture, noting the
importance of food systems protecting producers as well as consumers of food. The GOI asserts
that its food system is designed to fulfil basic human necessities which provide fair, equal, and
sustainable benefits based on the concepts of food resilience, self-sufficiency, and food security.
According the GOI, the Food Law is intended to provide a legal basis to regulate the following
activities: (1) food planning; (2) food availability; (3) food affordability; (4) nutrition and
consumption; (5) food safety; (6) food labeling and advertising; (7) control; (8) food information
system; (9) food research and development; (10) food institution; (11) public participation; and
(12) enforcement. Currently, the existing implementing regulations are still valid until new
implementing regulations are issued in accordance with the Law.
One aspect of the Food Law is food importation. If local food sources are insufficient, food can
be fulfilled through imports (Article 14 point 2 and Article 36-40). The regulation instructs
policy makers to establish food import policies and regulations that increase production without
negatively impacting farming sustainability, farmer and fishermen’s welfare, and food
businesses. The GOI consistently prioritizes domestic food production over imports to meet
demand.
Other significant legislation concerning food and agricultural imports include (all links are to
original Indonesian copies):
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Law No. 9/2018 regarding Non-Tax Government Revenue
Law No. 21/2019 regarding Animal, Fish, & Plant Quarantine
Law No. 22/2019 regarding Cultivation of Plants, amended by Law No. 6/2023 regarding
Job Creation
Law No. 17/2023 regarding Health
Government Regulation (PP) No. 69/1999 regarding Food Label and Advertisement
Government Regulation (PP) No. 102/2000 regarding National Standardization
Government Regulation (PP) No. 28/2004 regarding Food Safety
Government Regulation (PP) No. 95/2012 regarding Veterinary Public Health and
Animal Welfare
Government Regulation (PP) No. 47/2014 regarding Control and Mitigation of Animal
Diseases
Government Regulation (PP) No. 17/2015 regarding Food Security and Nutrition
Government Regulation (PP) No. 57/2015 regarding Fishery Products Quality Assurance
and Safety System, and Added Value Improvement, amended by PP No. 27/2021
regarding the Administrations of Maritime and Fisheries
Government Regulation (PP) No. 4/2016 regarding the Import of Livestock and/or
Products of Animal Origin Particularly from a Country or Zone within a Country of
Import Origin, amended by Regulation No. 11/2022
Government Regulation (PP) No. 5/2021 regarding The Administration of Risk-Based
Business Licensing
BPOM Regulation No.10/2021 regarding the Business and Product Standards for Risk-
based Business Licensing Administration in the Drug and Food Sector
Minister of Agriculture Regulation No. 15/2021 regarding the Business Activities and
Products Standards of Risk-based Business Licensing Administration of the Agricultural
Sector
Government Regulation (PP) No. 26/2021 regarding the Administration of Agricultural
Sector
Government Regulation (PP) No. 29/2021 regarding the Administration of Trade Sector
Government Regulation No. 28/2023 regarding the Types and Tariff of the Non-Tax
Government Revenue within the Ministry of Agriculture
Government Regulation No. 29/2023 regarding Animal, Fish and Plant Quarantine
Government Regulation No. 28/2024 on Implementation of Law No. 17 Year 2023
regarding Health
Government Regulation (PP) No. 42/2024 regarding The Implementation of Halal
Product Assurance
In addition to the Laws and Government Regulations listed above, there are various Presidential
Instructions, Ministerial Regulations, and Ministerial/Agency/Institutional Decrees regulating
food production, imports, and distribution that can be accessed through this link:
https://peraturan.go.id/.
Many of Indonesia’s regulations related to the marketing of food and food products are unclear
and confusing, are in conflict with other regulations, are not enforced, or are enforced in a
haphazard manner. While a review of relevant regulations is important, the reality of what occurs
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in practice may be quite different. Therefore, it is essential that exporters confer with local
importers/agents to determine prevailing requirements on imports.
A. General Requirements
Food label information includes anything represented in the form of a picture and/or in writing.
Information in other forms accompanying the food, which is placed in, affixed to, or constitutes
part of the food packaging is also considered part of the food labeling. Any person producing or
importing food which is packed for retail (i.e., not packed for the food service or institutional
sectors) into the territory of Indonesia is obligated to place a label on, within and/or at the
packing of the food.
The supplementary label shall be done in such a way so as not to easily come off, fade or be
damaged, and shall be placed in a visible and readable position on packages. In Indonesia,
stickering is allowed. The supplementary label should be affixed prior to customs clearance
(before arriving at the Indonesian territory) and must be in accordance with the label approved
by BPOM during the product registration number application process. Statements or claims on
the benefit of the food product shall only be included if they are supported by scientific facts
which can be substantiated.
The label for retail food must include the following information:
a. The name of the product
b. Ingredients list
c. Net weight or net volume
d. The name and address of manufacturer or importer
e. Halal logo (currently mandatory for animal products, will be mandatory for most food
and beverage products by no later than October 17, 2026)
f. Date and/or production codes
g. The expiration date, month and best before date (except for wine, beverages with alcohol
content >10%, vinegar, sucrose, and bread/cake with a shelf life of < 24 hours).
h. BPOM Registration Number (ML number for imported food products; MD number for
domestically produced food products)
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The amendment Regulation No. 6/2024 includes the addition of two articles that regulate BPA labeling obligations and how to
store bottled drinking water.
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i. The source of certain food ingredients
If the product is intended for business sale for further processing, the label must contain at least
points a, c, d, f, and g.
In addition to the information above, the GOI may determine other information that may or may
not be mentioned on food labels. The information on the labels shall be written or printed in
Bahasa Indonesia, with Arabic numerals and Roman text. The use of foreign terms may be
permitted if there is no Bahasa Indonesia equivalent. The use of backgrounds, in the form of
pictures, colors, and other decorations, which can obscure the writing in the main part of label, is
prohibited.
U.S. labeling standards are not considered false or misleading by Indonesian standards, although
they are different. For example, Indonesia maintains its own Acceptable Daily Intake (ADI) or
Maximum Tolerable Daily Intake (MTDI) levels, set through BPOM Regulation No. 9/2016. The
standard U.S. nutritional fact panel format is acceptable.
In addition to the labeling criteria outlined above, processed food labels must state nutritional
facts as well as indicate if a food product has been irradiated, is organic, or contains genetically
modified organisms (GMOs). Labeling should also include preparation instructions (e.g., baby
formula, food for pregnant women, special diet foods), storage instructions (e.g., ice cream,
bottled water, processed meat), serving suggestions, intended use (e.g., infants, toddlers,
pregnant women, breast feeding mothers, athletes), and warnings as required.
2D Barcode
Based on BPOM Regulation No. 33/2018, replaced by Regulation No. 22/2022, processed food
products (except for special nutrition food) that obtained a registration number after December 7,
2018 are required to have a 2D Barcode Identification on the product label. This 2D Barcode
Identification is issued by BPOM and contains information on the registration number (M/L) and
expiration date of the product. Special nutrition food requires 2D Barcode Authentication that
can be issued either by BPOM or a business entity and has more detailed information, including:
a. Registration number
b. Batch number/production code
c. Expiration date
d. Serial number of the product
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BPOM Regulation No. 26/2021 requires all processed food to include nutritional value
information on the label, except for powdered tea and coffee, tea bags, bottled mineral water,
herbs, spices, seasonings, alcoholic beverages, and condiments.
Below is the nutrition facts label with linear format for products with a label surface area of ≤
100cm²:
Source: The National Agency for Drug and Food Control (BPOM)
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Food products that may originate from pork include gelatin, enzymes, fat, collagen,
colostrum, blood extracts, hydrolyzed hemoglobin, keratin hair extracts, placenta,
protein, thymus extracts, thymus hydrolysate, stomach extracts, ingredients (e.g. stearic
acid, palmitic acid, glycerol) oils, kidney extracts, shortening, thickeners, emulsifiers,
stabilizers, l-cysteine, monoglycerides, diglycerides, triglycerides, and nisin.
Food products that have come into contact with substances of pork origin during
production shall display a label stating: “Pada proses pembuatannya bersinggungan
dan/atau menggunakan fasilitas bersama dengan bahan bersumber babi” (in contact with
and/or using a common facility with substances of pork origin during production process)
as shown below:
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h. The words “KONSULTASIKAN DENGAN TENAGA KESEHATAN” (consult your
medical provider) should be written on the product for special dietary processed food
products.
i. Label for processed food products intended for medical needs should include:
- “HARUS DENGAN RESEP DOKTER” (By medical prescription only)
- “Produk bukan untuk Penggunaan Secara Parenteral” (Product not intended for
parenteral use)
- Osmolality value for products intended for internal use through nasal gastric tube.
e. Allergens
Materials that may cause allergies must be stated. These include cereals containing gluten
(wheat, rye, barley, oats, spelt), shellfish, eggs, fish, peanuts, soybeans, milk (including
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lactose), tree nuts, sulfites (>100 ppm), and all processed products containing these
ingredients, with the exception of highly refined food.
f. Processed Food Containing Food Additives
Food labels containing food additives must contain the following information: the food
additive group’s name (i.e., antioxidant, artificial sweetener, preservative, food coloring,
enhancer); the food additive’s name; and the food additive’s registration number. Carry-
over food additives must be written after the names of food additives.
Products containing food coloring should include the following label information:
BPOM regulations prohibit claims that a product is free from food additives on food
labels and in advertising. Food additives include antioxidants, anti-caking agents, acidity
regulators, artificial sweeteners, bleaches, emulsifiers, stabilizers, thickeners, firming
agents, preservatives, colors, flavors, and flavor enhancers, and sequestrants. Prohibited
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statements include the words “BEBAS” (free),” “TANPA” (without), “TIDAK ADA
KONTEN” (no content), or other similar words.
g. Halal
Law No. 6/2023, Article 48 amended Law No. 33/2014 on Halal Product Assurance.
Several changes in the new law includes a timeline for assistance in the approval process
of halal products, the creation of a halal product fatwa committee, guidelines on the
determination of a product’s halalness, and the establishment of a validity period for halal
certificates. Under this law, a new agency called the Halal Product Assurance Organizing
Agency (BPJPH), was given the authority to issue and revoke halal certificates and halal
labels on products.
The 2014 Halal Product Assurance Law, also known as the Halal Law, came into force
on October 17, 2019; however, a grace period for food and beverage products to come
into compliance was put into place until no later than October 17, 2024. Even before the
Halal Law was enacted, halal certification and labeling were already mandatory for
imports of meat and meat products, poultry and poultry products, and dairy products.
However, under the new Halal Law, all food and beverage products will require
mandatory halal certification and labeling (or non-halal labeling for non-halal products)
except for exempted products listed in MORA Decree No. 1360/2021, known commonly
as the Halal Positive List.
In October 2024, the issuance of the Government Regulation No. 42/2024 further
extended the deadline for mandatory halal certification implementation for imported food
and beverage products by no later than October 17, 2026 (see USDA GAIN Report
ID2024-0039 for more details). This regulation also stipulates that a halal certified
product is exempt from halal labeling requirements if:
- the product’s packaging is too small to include all required information;
- the product is sold and packaged directly in front of buyers in small quantities;
- the product is sold in bulk; or
- the product is sold in limited quantities.
In addition, this decree also requires the halal certificates of imported, halal-certified
products to be registered with the BPJPH. It also requires halal-certified products to
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display their halal certificate registration number under the BPJPH halal logo on the
packaging. The Head of BPJPH’s Decree No. 88/2023 provides the halal label formatting
requirements for halal products certified by HCBs, including the displaying of the
Indonesian halal logo with the product’s halal certificate registration number. The
following two formats are acceptable (“atau” means “or”):
The Head of BPJPH’s Decree No. 88/2022 determines the halal label usage on halal
certified products. This decree also states that the halal logo of the former halal authority,
MUI, can continue to be used until February 2, 2026.
Labeling is also required for non-halal products. Non-halal information can be a picture,
sign, and/or word that is attached to the product packaging, specific part of the product,
and/or specific place on the product. Examples of non-halal information can be seen in
the above section: Additional Information on Food Labeling for Certain Products, Part (a)
Food Containing Pork and Part (b) Food and Beverages Containing Alcohol. Labeling for
products from non-halal ingredients other than pork and alcohol must include non-halal
information in the form of words stating “Ingredient name” in a different color.
Final implementing regulations for the Halal Law are yet to be published, but more
information on those that have been published so far can be found in the following FAS
Jakarta GAIN reports:
ID1913: GOI Issues New Implementing Regulation on Halal Product Assurance
ID2021-0017: Indonesia Halal Overview
ID2021-0045: Update on Indonesia Halal Regulations
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Note: LHLN = Indonesian acronym for HCB
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ID2021-0031: Indonesia Notifies Draft Decree on Products Mandatory to be Halal
Certified
ID2021-0048: Indonesia Notified Draft Regulation on International Cooperation
on Halal Product Assurance
ID2022-0001: Clarifications on Decree 748 on Type of Product Required to be
Halal Certified
ID2022-0002: Indonesia Notifies Draft Decree on Materials that are Exempted
from Mandatory Halal Certification
ID2024-0002: BPJPH Mandates Registration of Foreign Halal Certificates for
Imports
ID2024-0005: Indonesia Accredits Five U.S. Halal Certifying Bodies
ID2024-0031: Indonesia Grants Two-Year Extension for Mandatory Halal
Certification for Food and Beverage Products with Caveats
ID2024-0039: Indonesia Confirms Extension for Mandatory Halal Certification
for Imported Food and Beverage Products and Annulment of Apostille
h. Food Irradiation
Irradiated packaged food must carry the word "IRADIASI" (irradiated) after the name of
the food type. The label must include the reason for irradiation and the logo shown
below:
The name and address of the radiation facility, the month and year of the irradiation, and
the country in which the process was carried out are also required. If the food cannot be
re-irradiated, then the label should include the wording: “TIDAK BOLEH DIRADIASI
ULANG” (not to be re-irradiated).
i. Biotechnology
BPOM Regulation No. 31/2018 requires “PRODUK REKAYASA GENETIK”
(genetically engineered product) wording to be stated on labels of food derived from
genetically engineered products. However, product derivatives that have undergone
further refining processes to the point where the GE material cannot be identified (to
include but not limited to oils, fats, sucrose, and starch) do not need this statement. In
addition, the GOI requires labeling only for food products containing more than 5 percent
content derived from genetically engineered processes.
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j. Organic Food
Processed foods that meet Indonesia’s organic processed foods requirements may use the
word “organic” and Indonesia’s organic logo on their labels as shown below. Domestic
and imported organic food must have an organic certificate issued by an Indonesian
Organic Certifier or a Foreign Organic Certifier domiciled in Indonesia and accredited by
the National Accredited Committee (KAN). Imported organic products are also allowed
to have an organic certificate issued by the certifier in the country of origin that is
recognized by KAN. Foreign organic logos can be placed next to the Indonesian logo.
l. Health Messages: Sugar, Salt and Fat Content Information in Processed Food and Fast
Food
Ministry of Health (MOH) Regulation No. 30/2013, amended by Ministry of Health
Regulation No. 63/2015, requires producers of processed foods for retail commerce to
provide sugar, salt, and fat content information and a health message on the label. As per
Ministry of Health Regulation No. 30/2013, health messages on labels should read,
“Consuming more than 50 grams of sugar, 2,000 milligrams of sodium, or 67 grams of
fat per person per day increases the risk of hypertension, stroke, diabetes, and heart
attack.” The regulation was implemented in 2019 and BPOM subsequently issued
regulation No. 22/2019, replaced by BPOM Regulation No. 26/2021, on Nutrition
Information Labeling for Processed Food which includes requirements for sugar, salt, and
fat content information for processed food products.
On November 4, 2024, Indonesia notified the World Trade Organization (WTO) of their plans to
control sugar, salt, and fat (SSF) consumption in processed foods, including fast food, under
notification number G/TBT/N/IDN/169. The provisions regarding the content of SSF are part of
Government Regulation No. 28/2024 on Implementation of Law No. 17 Year 2023 regarding
Health, which was signed and entered into force on July 26, 2024. According to Government
Regulation No. 28/2024, Article 194, every person who produces, imports, or distributes
processed food, including fast food, shall comply with the maximum content limits of sugar, salt,
and fat and include the relevant nutrition labels on processed food packaging or information
media for fast food. In response to this regulation, Indonesia’s National Agency of Drug and
Food Control (BPOM) has drafted a new regulation that would mandate the use of a “Nutri-
Level” front-of-pack labeling system for SSF content, which will replace BPOM Regulation No.
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26/2021 on Information on Nutritional Values on Processed Food Labels6. Please see ID2024-
0043 for additional information.
The Minister of Industry (MOI) issued a regulation on February 12, 2010, requiring all plastic
food packaging to include food grade logos and recycling codes.8
There are no industry regulations or practices applicable to package size. The metric system must
be used for weights and measures. The GOI issued Government Regulation No. 18/2012 which
manages domestic waste. Producers are required to use biodegradable packaging with as little
waste as possible and use raw material that can be recycled. Post is unaware of any additional
Packaging Sustainability Measures.
For information on the list of permitted packaging for irradiated food; please see the original
Indonesian copy of BPOM Regulation No. 3/2018 page 14.
Ministry of Health (MOH) Regulation No. 033/12 states that food additive production,
importation and circulation require a distribution license from the Head of the Indonesian
National Agency for Food and Drug Control. Under BPOM Regulation No. 11/2019, there are
26 groups of food additives, and each group has several types of food additives. The list of
permitted food additives, except for flavorings, and their maximum limits can be obtained in
attachment I & II9. To use a food additive that is not on the list, a permit must be obtained from
the Head of BPOM. BPOM Regulation No. 13/2020 on Flavored Food Additives explains the
ingredient type, groups, and the usage of flavoring additives, including flavoring adjuncts.
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A draft regulation on Nutritional Values on Processed Food Labels.
7 BPOM Regulation No. 20/2019 page 18
8 Ministry of Industry Regulation No. 24/2010
9 BPOM Regulation No. 11/2019 page 19 – 39 (List of permitted food additives), page 40 – 1143 (list of maximum limits)
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BPOM Regulation No. 23/2016 regulates the inclusion of the term “without food additives” on
labels and in food advertising.
BPOM Regulation No. 29/2021 sets specifications, including microbial and chemical
contamination limits, and labeling for food additive compounds. A food additive product from an
animal source must also have a certificate of conformity with Islamic purity, "halal." That
certificate is issued by the responsible authority in the country of origin.
On August 15, 2023, Indonesia updated the list of prohibited raw materials in processed food and
ingredients such as food additives in BPOM Regulation No.22/2023. This regulation replaces
BPOM Regulation No.7/2018 and provides two lists of prohibited bio-sourced ingredients (156
substances) and compounds (5 substances) in processed food, and 45 ingredients that are
prohibited from being used as food additives.
Pesticide Residue
Maximum Residue Limits (MRL) of pesticides and other contaminants in food and fresh
agricultural products are generally regulated by Law No. 18/2012 (“The Food Law”), amended
by Law No. 6/2023, under the chapter pertaining to food safety and quality. The implementing
regulation of the Food Law, with regards to toxicity, MRLs, prohibited materials for food
production processes, and appropriate materials and processes, uses the following regulations:
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o The MOH and MOA will monitor and enforce the joint decree according to their
tasks and functions.
The list appended to the joint decree includes 218 pesticides and a number of potentially
contaminated agricultural products for each pesticide. There is no provision for the use of
alternative standards; for example, Codex is not listed as a default for pesticides that lack a
corresponding Indonesian MRL.
The National Standard Agency (BSN) issued the SNI 01-6366-2000 regarding Maximum
Residue Levels for Microbe and Chemical content in animal-based food.
The BSN issued the SNI 7313:2008 regarding pesticide Maximum Residue Levels for
agricultural products. This SNI regulates MRLs for 196 types of pesticides.
BPOM issued Regulation No. 7/2018 regarding Raw Materials Prohibited in Processed
Foods. This regulation covers information on materials or single/mixture compounds of
plant or synthetic origin.
On August 25, 2024, the Indonesia’s National Food Agency (NFA) issued Regulation No.
10/2024 on the Maximum Contaminant Limits for Fresh Food in Circulation. This new
regulation requires importers to undergo regular laboratory testing for their fresh products
in order to verify that contaminant levels do not exceed the established thresholds. The
testing must be conducted in accredited laboratories, either in Indonesia or in the relevant
countries of origin if fresh foods are being imported. Fresh food of plant origin that has
been in circulation have 12 months from the date the regulation is issued, to comply with
the regulation.
Please visit the Legal Documentation and Information Network of the Indonesian Food and Drug
Supervisory Agency for BPOM’s database of regulations in Bahasa Indonesia.
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List of microbiological criteria can be found at BPOM Regulation No 13/2019 page 9 - 48
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SECTION VI: OTHER REQUIREMENTS, REGULATIONS AND REGISTRATION
MEASURES
Under BPOM No. 23/2023, e-registration is implemented based on the product’s risk level
(High, Medium-High and Medium-Low risk) and each category requires different certifications
and documentation.
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5. The use of food additives which have a determination in the average daily intake/or
maximum usage
6. The use of certain materials which have maximum usage
7. Product certification required for the use of the Indonesia National Standards (SNI) mark
8. The permit for implementing Risk-Based Preventive Food Safety Control (PMR) in
accordance with BPOM regulations.
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Additional Requirements
Trademark Certificate (for product with TM and or ® logo on the label)
Organic Certificate (for organic products that display an organic logo on the label)
GMO Information (for raw materials: potato, soybean, maize, sugar, and tomato)
Note: Product derivatives which have undergone multiple refining processes in high
temperature such as fat or oil (including lecithin) do not need a non-GMO statement
Information on Food Irradiation (for irradiated products)
Halal certificate for halal mandatory products
Other supporting documents: GMP/HACCP/ISO 22000 certificate issued by accredited
body in the country of origin
Separate registration processes are required for products that have identical compositions but do
not share similar packaging. A new registration is required for products with different sized retail
packages, different labeling designs, different names and production addresses, and different
names and/or addresses of importers and distributors.
The registration process should be undertaken by a local agent or importer. Typically, it takes
longer than the officially reported timeframe and costs more than the published rate. Detailed
information from the food manufacturer/supplier and product samples are needed for the
registration process, which can be sent to the local agent or importer.
There are three registration types: new registrations, variation registrations (changing of data),
and renewals (to be conducted between 6 months and 10 days prior to the expiration of the
current registration). Registration Numbers for facilities are valid for 5 years.
Source: The National Agency for Drug and Food Control (BPOM)
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Table 2. List of Non-Tax State Revenue (PNBP) Fee (in Indonesian rupiah)
New Data Re-
Food Category Registration Changes Registration
Food Claims 3,000,000 1,500,000 2,500,000
Alcoholic Beverage 3,000,000 1,500,000 2,500,000
GMO, irradiation, or organic product 2,000,000 1,000,000 1,500,000
Category 01.00 dairy product 750,000 400,000 600,000
Category 02.00 oils and fat 300,000 150,000 200,000
Category 03.00 edible ice e.g., sorbet 300,000 150,000 200,000
Category 04.00 fruits and vegetables e.g., mushrooms, 500,000 250,000 400,000
aloe Vera, peas etc.
Category 05.00 candy, chocolate 500,000 250,000 400,000
Category 06.00 cereal and its derivative 300,000 150,000 200,000
Category 07.00 bakery product 300,000 150,000 200,000
Category 08.00 meat product 500,000 250,000 400,000
Category 09.00 fishery product 500,000 250,000 400,000
Category 10.00 eggs product 500,000 250,000 400,000
Category 11.00 sweetener (including honey) 200,000 100,000 150,000
Category 12.00 spices, soup, sauces, salad, protein 200,000 100,000 150,000
Category 13.00 nutritional food 3,000,000 1,500,000 2,500,000
Category 14.00 beverage exclude milk and alcoholic 300,000 150,000 200,000
Category 15.00 snack 300,000 150,000 200,000
Category 16.00 food that is not included in the category 300,000 150,000 200,000
1 – 15
Food additives 200,000 100,000 150,000
Source: https://peraturan.go.id/id/pp-no-32-tahun-2017
Testing
Based on Government Regulation No. 28/2004, which was replaced by Regulation No. 86/2019,
laboratory testing shall be carried out in government laboratories, or any laboratories accredited
by the National Accreditation Committee, or any Accreditation Institutions acknowledged by the
National Accreditation Committee. BPOM is authorized to determine the types of processed
food that should be tested prior to distribution.
Certification
A list of required import documents can be found in the FAIRS Export Certificate Report.
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BPOM also provides priority service for the issuance of SKI with a maximum process approval
time of less than of six hours. Priority service is given to importers with good track records that
have obtained approval six times for new SKI registrations without any additional or incomplete
documents. The imported products must have at least two-thirds of shelf life remaining at the
time of import.
To obtain a permit, an importer must provide the following data and documents:
1. An application letter for the raw material, food additive, food product import, including
the following information:
Name and address of importer
Brand name and kind of products
Packaging type/weight/volume
Amount of imported product
Country of origin
Name and address of supplier
Number and date of invoice
Number and date of Bill of Lading (B/L) or Airway Bill (AWB)
Expiration date
Lot Number/Batch Number/Production Code
Flavor & Extracts Manufacturers Association (FEMA)/The Joint FAO/WHO
Expert Committee on Food Additives (JECFA)/Enzyme Commission (EC)
Number (for food additives/flavors)
Port of destination
2. Product specifications for the raw materials, food additives, food product imports:
Description/composition/ingredients
Physical characteristics
Chemical characteristics
Microbiological characteristics
Packaging
Utilization/applications
Storage, term of expiration date
3. IDR 6,000 stamped Declaration Letter for raw food material and food additives, declaring
that:
Product is not intended for retail sale
Applicant is willing to have the sample tested in an accredited laboratory at the
applicant’s expenses
4. Certificates (please see below)
5. Payment bank receipt for non-tax revenue (PNBP)
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Table 3. Indonesia: Required Documents for Obtaining an SKI
No. Certificate Food Raw Food
Product Material Additive
1 Health Certificate or Free Sale Certificate from - v v
government/authorized agency in the country of origin
(shown the original)
2. COA from producer (per batch) or from accredited v v v
laboratory and valid for 12 months (shown the original)
3. Radiation Free Certificate for dairy products from Europe v v -
4. Radiation Free Certificate for food products from Japan v v v
5. GMO Certificate for product from processed soybean, corn, v v v
tomato, and potato
6. Certificate of 3-Monochloro Propanediol (3-MCPD) analysis v v v
for hydrolyzed vegetable protein, isolated protein, soy sauce
7. Certificate of Origin for products derived from animal origin v v v
and the processed products (beef, gelatin, collagen, skin)
8. COA of Aflatoxin for nut products v v -
9. Halal Certificate for products labeled “halal” v v v
10. COA of Formalin for products suspected of containing v - -
formalin
11. COA of Melamine for food additives (Ammonium v v v
bicarbonates), raw food materials (dairy, flour, vegetable
protein, egg and egg products) for products suspected of
containing melamine
12. COA of Chloramphenicol for honey v v -
13. COA for Sudan Red for Oleoresin Capsicum v v -
14. Recommendation letter (SRP) from MOA for products of v v -
animal origin
15. Copy of registration approval letter with valid ML No., label v - -
and approved packaging
16. Letter of cooperation between importer and freight forwarder v - -
17. Document stating the production date or expiration date v v v
(original)
18. Document stating the batch number/lot number/production v v v
code
19. Supporting importation documents
a. B/L or AWB v v v
b. Invoice v v v
c. Packing List v v v
Source: The National Agency for Drug and Food Control (BPOM)
Dairy Products
Ministry of Agriculture Regulation No. 15/2021 regarding the Business and Product Standards
for Risk-based Business Licensing Administration of the Agricultural Sector requires the
approval of a foreign dairy establishment by the Minister of Agriculture before it can export to
Indonesia. The approval application must be submitted by the establishment through the Office
of Agricultural Affairs of the USDA/Foreign Agricultural Service in Jakarta. See GAIN Report
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ID2021-0038 regarding the changes to dairy import regulations and the dairy establishment
approval process, which includes a guide to obtaining dairy establishment approval.
Approved dairy establishments are listed on the online import recommendation (SIMREK) lists.
A dairy establishment can begin exporting its products to Indonesia only after it has been
officially listed on both lists. As of November 6, 2024, there are 129 U.S. dairy establishments
approved to export to Indonesia.
Imports of dairy products to Indonesia require import licenses issued by the Ministry of
Trade.
Dairy import licenses require an import recommendation from the Ministry of
Agriculture.
A Halal certificate for halal-required products, issued by a halal certifying body
recognized by BPJPH, is one of the most important requirements to obtain an import
recommendation.
An import recommendation shall be valid for six months and should be used to obtain an
import permit from the Ministry of Trade within the six-month period.
The import recommendation number must be included on the health certificate
accompanying a shipment of dairy products.
An import license shall be valid for one fiscal year (based on Ministry of Trade
Regulation No. 36/2023 regarding Import Policy and Arrangement).
A list of dairy products eligible for export to Indonesia is included in the Annex of
Regulation No. 15/2021 (unofficial English translation).
Raw materials for dairy products intended for export to Indonesia must not be sourced
from countries and business units that have not been approved by the Ministry of
Agriculture.
The Ministry of Trade is responsible for issuing import licenses and specifying quantities
permitted for importation based on an MOT estimate of the importer’s cold storage capacity.
Ministry of Trade Regulation No. 36/2023 states cold storage capacity will continue to be used
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as a benchmark to determine the volume permitted for import. The proof of control (previously:
ownership) of refrigerated warehouse (cold storage) requirement applies to importers.
Recognition of the U.S. Food Safety Control System for Fresh Foods of Plant Origin
(FFPO/PSAT)
The GOI currently recognizes the United States’ Food Safety Control System for 79 Fresh
Food of Plant Origin (FFPO) products. Ministry of Agriculture Regulation No. 55/2016
requires products imported from FFPO-recognized countries to submit “prior notice”
notification on-line (See Prior Notice section below). Products from unrecognized countries
must also provide prior notice notification in addition to a certificate of analysis (CoA) from
a recognized laboratory. The Head of the Indonesian Agricultural Quarantine Agency
(IAQA) (now the Indonesian Quarantine Authority (IQA)) issued the initial recognition of
U.S. FFPO through an MOA decree following onsite verification in October 2009. The
recognition must be renewed every three years and was most recently renewed through IQA
Decree No. 447/2024 on January 16, 2024, for 78 products – 10 products had been removed
from the previous FFPO recognition, including apples.
However, on October 16, 2024, the Indonesian Quarantine Authority (IQA) issued Decree
No. 8014/2024 reinstating apples to the U.S. FFPO.. With the reinstatement of apples,
Indonesia now recognizes the food safety of 79 types of U.S. FFPO products. However, the
nine other products removed in IQA Decree No. 447/2024 were not reinstated to the U.S.
FFPO recognition list, namely carrots, rye, pecans, boysenberry, artichokes, dewberries,
pistachios, gherkins, and spinach.
The 79 plant products currently recognized by the GOI equivalence recognition (as per IQA
Decree No. 8014/2024 ) are as follows:
1. Grapes 20. Mandarin 38. Broccoli
2. Avocado 21. Melon 39. Cauliflower
3. Apple 22. Nectarine 40. Pepper Chili; Dried
4. Apricot 23. Peach Pepper Chili
5. Blackberries 24. Persimmon 41. Chicory
6. Blueberries 25. Pear 42. Leeks
7. Tin/Figs 26. Plum 43. Flower head
8. Cherries 27. Shaddock or Brassicas
9. Cranberry Pomelos 44. Sweet Corn
10. Citrus Fruit 28. Prunes 45. Mushrooms
11. Currant, Black, Red, 29. Raspberries Red, 46. Potatoes
White Black 47. Kale
12. Gooseberry 30. Squash 48. Kohlrabi
13. Grapefruit 31. Strawberry 49. Cabbage
14. Oranges 32. Asparagus 50. Brussels Sprouts
15. Longan 33. Onion 51. Lima Bean
16. Raisin 34. Shallot 52. Radish
17. Kiwifruit 35. Garlic 53. Turnips
18. Lemon 36. Beetroot 54. Cucumber
19. Limes 37. Sugar Beet 55. Okra
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56. Paprika 64. Wheat 73. Mung Bean
57. Parsley 65. Maize 74. Broad Bean
58. Celery 66. Oats 75. Cowpea
59. Tomato 67. Almond Nut 76. Peas
60. Eggplant 68. Hazelnuts 77. Coffee Beans
61. Sweet Potatoes 69. Macadamia Nuts 78. Pepper Black, White
62. Barley 70. Pistachios Nuts 79. Green Tea and
63. Rice; Rice Husked 71. Soybean Black Tea
and Rice Polished 72. Peanuts
Importation of fresh fruits and vegetables originating from pest-free producing areas must be
declared in the Additional Declaration section of the plant phytosanitary certificate that
accompanies the shipment. Importation from non-pest-free producing areas must be treated
with one of the following treatments: cold treatment with temperature appropriate for fresh
fruit and vegetables and for the prevention of the target pest; fumigation; Vapor Heat
Treatment (VHT); or irradiation. The treatment must be declared in the treatment column of
the phytosanitary certificate. Similar to the provision in MOA Regulation No. 42/2012,
imported fresh bulbs are regulated by MOA Regulation No. 43/2012 and its amendment,
MOA Regulation No. 20/2017and MOA Regulation No. 6/2022.
On June 22, 2015, the Head of IAQA (now IQA) released decree No.
756/KPTS/OT.140/L/06/2015 establishing California as a pest-free area for 9 pest fruit flies
in the United Sates: Ceratitis capitata; Anastrpha fraterculus; Anastrepha ludens;
Anastrepha obligua; Anastrepha serpentine; Anastrepha suspense; Rhagoletis cingulate;
Rhagoletis fausta; and Rhagoletis pamonella. As a result, major fresh fruit exports from
California do not need a pre-treatment. The decree replaces previous decree
348/Kpts/PD.540.220/12/06 on establishing California as a free area for Ceratitis capitata.
Prior Notice
IQA Regulation No. 9/2024 expands the scope of Indonesia’s Prior Notice requirement to
not only cover fresh fruit and vegetable imports but also all plant and plant products, animal
and animal products, as well as fish and fish products. Prior notice must indicate the date
and place of loading, date and place of arrival/destination, type of transportation, product
name, quantity imported, country of origin, packing unit, import purpose, degree of
quarantine risks, GMO attestation for GMO products, and container’s identification number.
The exporter must submit this Prior Notice form online before the arrival of the
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consignment. On August 5, 2024, IQA issued Regulation No. 1/2024 on the List of
Commodities Subject to Mandatory Animal, Fish and Plant Quarantine Inspection which
basically listed all the commodities now subject to the Prior Notice requirement (see this
GAIN Report ID2024-0036 for more information).
Approved foreign meat processing establishments are listed on the Directorate General of
Livestock and Animal Health Service (DGLAHS) website as well as on the online import
recommendation (SIMREK) lists. A meat processing establishment can begin exporting its
products to Indonesia only after it has been officially added to both lists. As of November 2024,
there are 21 U.S. beef processing establishments, 11 U.S. pork processing establishments, and
one U.S. lamb processing establishment approved to export to Indonesia.
Imports of meat products to Indonesia require import licenses issued by the Ministry of
Trade.
For non-beef products, import licenses require an import recommendation or verification
of the needs plan from the Ministry of Agriculture. Beef is under the commodity balance
policy and so no longer requires an import recommendation.
Halal certificates for halal-required products, issued by a halal certifying body recognized
by the Indonesian Halal Products Assurance Agency (BPJPH), is one of the most
important requirements to obtain an import recommendation or import license.
An import recommendation for non-beef products (pork, lamb, etc.) can be applied for at
any time and shall be valid for six months. It should be used to obtain an import license
from the Ministry of Trade within three months after its issuance.
The import recommendation number (or letter of consideration in the case of beef)must
be included in the Health Certificate (FSIS form 9060-5) accompanying the shipment of
meat products.
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An import license shall be valid for one fiscal year (based on Ministry of Trade
Regulation No. 36/2023 regarding Import Policy and Arrangement).
A list of meat products eligible for export to Indonesia is included in the Annex of
Regulation No. 15/2021 (unofficial English translation).
The importation of meat and meat products samples for exhibition purposes is allowed
(up to 200 kilograms).
Importers must indicate the products being imported and their market destination
(restaurant, hotel, catering, industry, retail, etc.) in their import recommendation
application to the DGLAHS.
For 2022 import licenses, Indonesia began implementing a new commodity balances policy for
beef and with import licenses valid for one year. The commodity balance policy is described in
more detail in Section IX: Import Procedures. Please note that under the commodity balance
policy, the previous import recommendation requirement for imported beef has been replaced by
a Letter of Consideration which is issued by the Ministry of Agriculture through the online
National Commodity Balance System (SINAS NK).
Pet Food
Ministry of Agriculture Regulation No. 15/2021 regarding the Business and Product Standards
for Risk-based Business Licensing Administration of the Agricultural Sector requires MOA
approval of foreign pet food processing establishments before they can export to Indonesia. U.S.
establishments should submit approval applications through the Office of Agricultural Affairs of
the USDA/Foreign Agricultural Service (FAS) in Jakarta.
Pet food processing establishments must be approved by the Ministry of Agriculture through an
animal health and veterinary public health risk analysis assessment process, which consists of a
document desk review, onsite audit, and evaluation. Each approval step is subject to an approval
fee in accordance with Government Regulation No. 28/2023. U.S. pet food processing
establishments wishing to export to Indonesia are encouraged to contact the Office of
Agricultural Affairs of the USDA/FAS in Jakarta at [email protected] for guidance. As of
November 2024, there are 57 U.S. pet food establishments approved by the Ministry of
Agriculture.
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Imports of pet food to Indonesia require import licenses issued by the Ministry of Trade.
Import licenses require an import recommendation from the Ministry of Agriculture.
An import recommendation must be used to obtain an import license from the Ministry of
Trade within three months of its issuance.
The import recommendation number must be included on the health certificate
accompanying a shipment of petfood.
An import license shall be valid for one fiscal year (based on Ministry of Trade
Regulation No. 36/2023 regarding Import Policy and Arrangement).
Raw materials for pet foods intended for export to Indonesia must not be sourced from
countries and business units that have not been approved by the Ministry of Agriculture.
Rendered Products
Ministry of Agriculture Regulation No. 15/2021 regarding the Business and Product Standards
for Risk-based Business Licensing Administration of the Agricultural Sector requires MOA
approval of a foreign rendering establishment before it can export to Indonesia. U.S.
establishments should submit approval applications through the Office of Agricultural Affairs of
the USDA/Foreign Agricultural Service (FAS) in Jakarta.
Rendering establishments must be approved by the Ministry of Agriculture through animal
health and VPH risk analysis assessment process, which consists of a document desk review,
onsite audit, and evaluation. Each approval step is subject to an approval fee in accordance with
Government Regulation No. 28/2023. Rendering establishments wishing to export to Indonesia
are encouraged to contact the Office of Agricultural Affairs of the USDA/FAS in Jakarta at
[email protected] for guidance. As of November 2024, there are 33 U.S. rendering
establishments approved by the Ministry of Agriculture.
Only rendered products of ruminant and poultry origin may be imported into Indonesia.
(DGLAHS will perform a product purity test.)
Raw materials of rendered products intended for export to Indonesia must not originate
from porcine sources, dead animals, wildlife, or animals originating from other countries.
Import licenses for rendered products are issued by the MOA, can be applied for at any
time, and are valid for 4 months.
Approved rendering establishments are subject to bi-annual, physical onsite audits.
Rice
MOT Regulation No. 36/2023, amended by MOT No. 8/2024 covers the approval process for
imported rice through the commodity balance system. The import period may be determined
during the inter-ministerial coordination meeting held prior to any import decision. The
regulation defines rice specifications that are allowed for import as follows:
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Table 5. Ministry of Trade Regulation on Rice Imports
No. HS Code Description Allowed for Imports Imported by
A Medium Quality Rice
1006.30 Semi-milled or Indonesia’s state-
wholly milled rice, owned logistics board
whether or not and food procurement
polished or glazed agency (BULOG)
1. 1006.30.50 -- Basmati rice With maximum of 25
2. 1006.30.60 -- Malys rice percent broken grains
3. 1006.30.70 -- other fragrant rice
4 1006.30.99 -- other (japonica
rice)
B. Import Rice for Further Food Processing
1006.40 Broken rice Rice or glutinous rice Private importers
5 1006.40.90 -Other with maximum of 15 (Producer Importer
percent broken grains Recognition/API-P)
11.02 Cereal flours other
than of wheat or
meslin
1102.90 -Other
6 1102.90.10 -- rice flour Rice flour, glutinous rice
flour and other rice flour
C Specialty Rice
1006.30 Semi-milled or
wholly milled rice,
whether or not
polished or glazed
7 1006.30.30 -- Glutinous rice Glutinous rice with Indonesia’s state-
maximum of 10 percent owned companies and
broken grains food procurement
8 1006.30.40 -- Hom Mali rice Hom Mali rice with agency.
maximum of 5 percent
broken grains Note: private
9 1006.30.50 -- Basmati rice Basmati rice with companies only
maximum of 5 percent allowed to import
broken grains specialty rice through
10 1006.30.60 -- Malys rice Malys rice with Indonesia’s state-
maximum of 5 percent owned companies
broken grains
11 1006.30.70 -- Other fragrant rice Jasmine rice and other
fragrant rice with
maximum of 5 percent
broken grains
12 1006.30.91 --- Parboiled rice Parboiled rice
13 1006.30.99 --- Other Japonica and other rice
33
with maximum of 5
percent broken grains
Source: Ministry of Trade Regulation No. 8/2024
Imports of rice are permitted when government and industry stocks are low. This is only
permitted when the rice cannot be produced domestically. Imported rice can only be used as raw
material for food manufacturing and cannot be sold to other parties. Rice is one of the five
commodities made subject to the Commodity Balance policy in 2022 per Presidential Regulation
No. 32/2022, replaced by Presidential Regulation No. 61/2024. This import license based on the
commodity balance is described in more detail in the Section IX: Import Procedures. Import
licenses are valid for one year.
Additionally, imported rice must be packaged and labeled in Bahasa Indonesia prior to arrival in
Indonesia. Packaging that comes into direct contact with food must be made of food grade
material in accordance with Indonesian regulations. Packaging made of plastic is required to
include a Food Grade logo and Recycling Code in accordance with Indonesian regulations.
Compliance with packaging requirements must be proven by:
a. Certificate of test results issued by a competent testing laboratory and recognized by the
local government; or
b. Letter of statement from importer stating that the packaging used is in accordance with
provisions of Indonesian regulations by including Food Grade Logo and Recycling Code
on the packaging.
For Thai Hom Mali, Basmati, Japonica, and Steam Rice, packaging size is required to be at
maximum 10 kg per bag.
On February 12, 2019, the Ministry of Trade issued regulation No. 8/2019 on Rice Labeling
which states that any rice packers or importers selling rice in less than 50 kg bags must include a
label in Bahasa Indonesia on each bag that contains the following information:
a. Rice brand
b. Quality type of the rice (e.g., medium rice, premium rice, or specialty rice)
c. Net weight in kilograms or grams
d. Packaging date
e. Name and address of the rice packers or importers
In addition to the abovementioned MOT Regulation No.8/2019, on February 16, 2023, the
Indonesian National Food Agency issued Regulation No. 176/2023 on Rice Quality and Labeling
Requirements which differentiates rice into two qualities: regular rice and specialty rice.
Specialty rice includes:
a. Glutinous rice
b. Red rice
c. Black rice
d. Local variety rice
e. Fortified rice
f. Organic rice
g. Geographical indication rice
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h. Rice with health claims
i. Certain rice which cannot be domestically produced
Based on the criteria of safety, nutritional content, organoleptic properties, physics, and
composition, rice is classified into four quality classes:
1. Premium rice
2. Medium rice
3. Sub-medium rice
4. Broken rice
Any rice producers or importers distributing rice must meet the following minimal requirements:
a. Pest free, based on results of visual tests
b. Free of musty odors, sour odors and other foreign odors, based on results of organoleptic
tests
c. Safety requirements as stated by Indonesian Food Law: maximum residue limit, use of
food additives, maximum contamination limit, good implementation practices.
Any rice producers or importers selling rice in Indonesia must include inside or attach label on
the packaging in Bahasa Indonesia prior to arrival in Indonesia. Label must include information
on:
a. Product name in the form of classification, type name (can be stated as variety name) and
trade name
b. List of ingredients used
c. Nett weight in kilograms or grams
d. Name and address of the producers or importers
e. Quality class
f. Production date and code, and/or expiration date
g. Rice origin
h. Registration number, for those required
i. Halal, for those required
j. Maximum Retail Price, for those required
Seeds
In July 2019, the Ministry of Agriculture issued Regulation No. 38/2019, amended by Regulation
No. 23/2023 regarding the procedures for seed testing, assessment, variety release, and
withdrawals. Based on this regulation, to import a new hybrid seed variety, either genetically
engineered (GE) or conventional, the importer must provide a guarantee-letter stating that the F1
hybrid seed will be produced in Indonesia within two years after the date of release. In the case
of F1 hybrid paddy seed, they must guarantee that the seed will be produced in Indonesia within
three years after the release. Meanwhile, the F1 estate crops hybrid seed will be produced in
Indonesia within three years for seasonal crops and six years for annual crops after the release.
However, Ministry of Agriculture Regulation No. 15/2021 regarding the Standard of Business
Activity and Standard of Product in the Implementation of Risk-based Business Licensing in the
Agricultural Sector, has removed the point on importing F1 hybrid food crop seeds, which means
seeds for F1 food crops must be produced locally.
35
Indonesian import procedures for horticulture seeds are mainly regulated based on Ministry of
Agriculture Regulation No. 15/2017 as amended by Ministry of Agriculture Regulation No.
17/2018 and No. 26/2018. This regulation covers import and export licenses, and states that seed
imports can be conducted by business units, government institutions, plant observers, or
individuals. MOA approval is required for all seed imports. For information on requirements for
seed introduction/importation into Indonesia, please see attachment pages 19 & 20/Form IF-01.
For technical information on exporting commodities to Indonesia, please see page 9/Form - IF
02.
b. Procuring quality seeds for 1. The variety has been registered for circulation (not more than 2 years
commercial purposes since its registration).
2. Must meet the quality standards or minimum technical requirements.
3. Local supply is not sufficient.
4. The variety is not locally produced.
5. The requested seed volume and type is limited according to the need of
procuring implementation of quality seeds.
6. Seeds must be produced overseas.
7. “Seeds” must be stated clearly on the packaging in Bahasa Indonesia.
c. Procuring parent stocks for 1. These parent stocks are not available in Indonesia.
the multiplication of seeds 2. Seed description must be signed by the seed breeder.
from registered varieties 3. The volume of the requested seed is in accordance with the seed
production plan.
36
Importation of Seed for
Technical Requirements:
Purpose of:
f. Implementing benchmarking 1. The requested seed volume and type is based on testing needs.
tests between laboratories, 2. Valid participation letter for the benchmarking test between labs or
proficiency test, or validation proficiency test or statement letter of proficiency test from International
method in the framework of Seed Testing Association (ISTA).
accrediting seed quality 3. Statement letter on organizing proficiency test, benchmarking test
laboratories between labs, or validation methods.
4. After the test is completed, the remaining seeds, including seeds and
sprouts resulting from seeds of the proficiency test as well as growing
media which is used in the test must be destroyed.
g. Implementing new, unique, The requested seed volume and type is in accordance with testing needs
uniform, and stable test and supported by a testing plan proposal.
(BUSS) for the need of plant
variety protection
j. Implementing quality test 1. The requested seed volume and type is in accordance with testing needs
necessary for issuing orange and supported by a testing plan proposal.
and blue certificates based on 2. Letter of application for issuing orange and blue certificates.
the regulations of the 3. Application for seed sampling for testing purposes.
International Seed Testing 4. All remaining seed samples must be destroyed within one /of testing.
Association (ISTA)
Source: Ministry of Agriculture
The Decree of the Head of the Agricultural Quarantine Agency No. 152/Kpts/PD.540/L/8/2003
states that seed imports must:
be accompanied by a phytosanitary certificate from the country of origin and transit country,
pass through the designated entrance point,
be reported and delivered to Plant Quarantine Officials at the entrance point for
quarantine treatments,
37
be accompanied by an Import License from the Ministry of Agriculture or appointed
officials,
N.B: Quarantine officials will ask for the original copies of the phytosanitary certificate,
import license, copies of invoices, packing list, and airway bill or bill of lading.
Although no Indonesian quarantine laboratory has been accredited by the International Seed
Testing Association (ISTA), the Ministry of Agriculture refers to the International Standard for
Phytosanitary Measures from the United Nations Food and Agriculture Organization (UN FAO)
for quarantine inspections and actions.
Sugar
MOT Regulation No. 36/2023, amended by MOT No. 8/2024 covers the approval process for
imported sugar. The regulation defines sugar specifications that are allowed for import as
follows:
Imported raw sugar must only be used as raw material for refineries to produce white sugar for
consumption, while refined sugar may only be imported as raw material for the food and
beverages industry. Only importers who hold general importer-producer identification numbers
(Angka Pengenal Importir-Produser, API-P) can import raw or refined sugar. Sugar is one of the
38
five commodities subject to the Commodity Balance policy initially implemented in 2022 per
Presidential Regulation No.32/2022, replaced by Presidential Regulation No. 61/2024. This
import license based on the commodity balance is described in more detail in Section IX: Import
Procedures.
White sugar can only be imported to build up national stocks and stabilize prices. Only state-
owned companies and API-P importers can import white sugar upon authorization from the
government. In addition to receiving an import recommendation from the Ministry of Industry,
white sugar importers must obtain an import recommendation from the Ministry of State-Owned
Companies and the Ministry of Agriculture to obtain an import license from the Ministry of
Trade. Import licenses for white sugar are valid for one year from the issuance date.
The intention of Ministry of Trade Regulation No. 36/2023 was to simplify sugar import
procedures and to improve the competitiveness of Indonesia’s sugar industry. As mandated by
Law No. 7/2021 on the Harmonization of Tax Regulations, the GOI increased the value added
tax on sugar imports to 11 percent. The new tax came into effect on April 1, 2022, setting sugar
import duties and taxes as follows:
Table 8. Indonesia: Sugar Import Duty (ID) and Value Added Tax (VAT), 2022
No. Commodity ID VAT
(Rp./Kg) (US$/ton) (%)
1. Raw cane sugar 550 38 11
2. White sugar 790 55 11
3. Refined sugar 790 55 11
Source: Indonesian National Single Window.
Seafood
On February 2, 2021, the Government of Indonesia issued Regulation No. 27/2021 on Business
Process in the Maritime and Fisheries Sector, which is one of the implementing regulations of
Law No. 11/2020 on Job Creation. It states that the issuance of import licenses for fish and
seafood will be based on commodity balance policy. The new policy of import license is
described in more detail in Section IX: Import Procedures. To implement this new policy, on
May 28, 2021, the Ministry of Marine Affairs and Fisheries (MMAF) also issued Regulation No.
24/2021, replaced by MMAF No.6/2023 on the Establishment of Fishery Commodity Balance
and Import Allocation Distribution of Fishery Commodities.
The Minister of Maritime and Fishery issued Decree No. 80/2022, which was amended by
Decree No. 195/2023, listing fish products limited for export to Indonesia and requiring an
import license (MOT No. 36/2023) and Regulation No. 19/2020 lists live aquatic species banned
from import.
The Commodity Balance policy requires importers to submit a “needs plan” every September for
the following year’s imports in order to receive import licenses. The Ministry of Industry (for
imports for industrial purposes) or Ministry of Marine Affairs and Fisheries (for imports for
retail/ foodservice consumption) verifies and determines the final, aggregate import needs plan.
The impact of the commodity balance policy on import licenses is described in more detail in the
39
Section IX: Import Procedures. The importation of fish or seafood can be carried out by Importer
Producers for processing, as well as by General Importers for the following uses:
o Modern markets
o Hotel, restaurant, and catering industries
o Bait
o Raw material for processed fishery products: filets, sausages, meatballs etc. (This
only applies to micro-small enterprises without industry licenses.)
o Raw material for traditional production of boiled-salted fish
Food Categorization
BPOM Regulation No. 13/2023 (replacing BPOM Regulation No. 34/2019) covers food
categories. The food categorization regulation sets guidelines for setting standards, assessments,
inspections, and certifications for food safety controls. Thus, industry is able to decide quality
and food safety requirements (e.g., microbes and heavy metal maximum limits), characteristics
of products, product registration, and food additives that can be used and approved on products.
Domestic and imported food products sold in retail packaging must comply with the provisions
on food categories outlined in BPOM Regulation No. 13/2023. There are 16 food categories
stated in attachments I to XVI. If a type of food does not fall under one of the foods categories
listed, written approval is required from the head of BPOM. BPOM Regulation No. 13/2023 also
provides detailed information on the list of approved ingredients derived from plants and
animals. The approved ingredients list is divided into two categories:
1. Raw materials without limitation of use (323 ingredients)
2. Raw materials with limited use (9 ingredients, including ginseng)
40
Alcoholic Beverages (Beer, Wine, Spirits)
The distribution and sale of alcoholic beverages are controlled by the GOI. There are three
categories of alcoholic beverages: “Category A” contains zero to five percent alcohol; “Category
B” contains greater than 5 percent and less than 20 percent alcohol; and “Category C” contains
21 to 55 percent alcohol.
An importer of alcoholic beverages must hold an imported alcoholic beverage permit (IT-MB)
from the MOT. The main requirement for the IT-MB application is an appointment letter
authorized in the country of origin by a Public Notary and an Indonesian Commercial Attaché
(for the United States, at the Indonesian Embassy in Washington D.C. or one of the consulates.)
The application must indicate 20 foreign brands/manufacturers from at least 5 countries and have
six distributors in at least six provinces per MOT Regulation No. 36/2023, amended by MOT
Regulation No.8/2024. The IT-MB will be valid for as long as the importing company is still
conducting alcoholic beverage import activities.
The type and amount of the imported alcoholic beverage products allocated to fulfill national
demand is determined by the MOT and issued in April annually. The ports of entry for imported
duty-paid alcoholic beverages including the seaports of Belawan, Medan; Tanjung Priok,
Jakarta; Tanjung Emas, Semarang; Tanjung Perak, Surabaya; Bitung, Manado; and Soekarno
Hatta, Makassar, as well as via all Indonesian international airports.
The distribution and sale of alcoholic beverages under category B and C fall under the GOI’s
control. Direct sales are only allowed for duty-paid alcoholic beverages (including categories A,
B, and C) for on-site consumption at hotels, restaurants, bars, pubs, and night clubs. Duty-free
shops can sell duty-free alcoholic beverages, including categories A, B, and C in certain
locations. MOT Regulation No. 6/2015, amended by MOT Regulation No. 120/2018 prohibits
sales of category A alcoholic beverages in minimarkets and other retail shops. Supermarket and
hypermarket retail sales of alcohol are still allowed. Direct selling and/or retail of alcoholic
beverages and alcoholic beverage products to people under the age of 21 years is prohibited in
Indonesia.
BPOM Regulation No. 05/2021 states that alcoholic beverages distributed in Indonesia must
comply with food safety and quality standards on methanol content, metal and chemical
contamination, and food additives. Maximum methanol content is less than 0.01% b/v
(calculated based on product volume). Alcoholic beverages are not allowed to be advertised in
the media. Prior to distribution, imported alcoholic beverages must be registered at BPOM with
the required documents as follows:
41
On December 27, 2023, the Ministry of Finance (MOF) issued Regulation No. 160/2023 to
replace Regulation No. 158/2018, imposing a new excise tax on ethyl alcohol, beverages, and
concentrates containing ethyl alcohol. The regulation was implemented on January 1, 2024. The
new tax is described in Table 9.
Table 9. Indonesia: Excise Tax for Ethyl Alcohol and Products Containing Ethyl Alcohol
Type Ethyl Alcohol content Excise Tax (IDR per
liter)
Domestic Import
Product
Ethyl alcohol or ethanol
All kinds of ethyl alcohol, level content, and type 20,000 20,000
Beverages containing ethyl alcohol
A 5% or less 16,500 16,500
B More than 5% up to 20% 42,500 53,000
C More than 20% 101,000 152,000
Concentrate containing ethyl alcohol
All concentrates, content level and type, as a raw material or
processing aid in beverages contain ethyl alcohol production:
Fluid
Solid 228,000 228,000
1,000 1,000
Source: MOF Regulation No. 160/2023
On April 1, 2022 the MOF issued Regulation No. 26/2022 , amended by MOF Regulation No.
10/2024 on the Stipulation of Goods Classification System and Imposition of Import Duty
Tariffs on Imported Goods, which includes information on the import duty at the ad valorem
tariff rate of 90 percent for wine, cider, perry, and mead, and 150 percent for spirits and liqueurs.
Biotechnology
The Government Regulation No. 28/2004, replaced by Regulation No. 86/2019 states that
Genetically Engineered (GE) food must be tested prior to distribution. BPOM Regulation No.
6/2018 concerning Food Surveillance on Genetically Engineered Food replaced BPOM
Regulations No. 19/2016 and No. HK.03.1.23.03.12.1563/2012 on the Guidelines for Food
Safety Assessments of Genetically Engineered products. An assessment for imported GE
products is required before distribution in Indonesia, which includes:
a. genetic information, including general description, host description, etc.;
b. donor organism;
c. genetic modification description;
d. genetic modification characteristics; and
e. food safety information, including substantial equivalence, changes in nutritional value,
allergenicity, and toxicity.
BPOM Regulation No. 6/2018 was put in place to address the following:
42
1. Imported GE products must obtain approval from BPOM in the form of GE Food Safety
Certificate after the assessment is done.
2. After obtaining a food safety certificate, the importers must convey:
- a sample of the GE product and its conventional counterpart
- a document indicating primary sequence information, a validated detection method,
and a location where Certified Reference Materials can be obtained.
3. GE processing aids not containing GE DNA or GE proteins are exempt from food safety
assessment by the Biosafety Commission for Genetically Engineered Products (BCGEP).
4. BPOM requires applicants to submit samples of GE products and their conventional
counterparts or their parent seed no later than six months after receiving distribution
approval. GE products that have been distributed prior to the enactment of this regulation
must comply no later than May 2019.
5. If the importer submits an application of assessment for an imported GE product, the data
submitted should be in the form of testing results that must be carried out by an
accredited laboratory, or an overseas laboratory that implements the Good/GLP
Laboratory Method, or a laboratory that has a Mutual Recognition Arrangement (MRA)
agreement.
For additional information, please see the Agricultural Biotechnology Annual Report 2024.
Special Nutrition
BPOM issued Regulation No. 1/2018, amended by BPOM No. 24/2019 and BPOM No. 24/2020,
regarding the Surveillance of Processed Foods for Special Nutrition Needs (PKGK). This
regulation oversees processed foods for special dietary and medical needs, including foods and
beverages providing tailored nutrition for adults, infants, children, pregnant mothers, and
athletes12. This regulation also defines PGKG and provides requirements on the standard and
quality of each food category (including requirements for materials, nutritional content, food
additives, and labeling). Imports of PKGK products must be accompanied by a certificate
proving the product complies with good manufacturing practices for processed foods (CPPOB).
The certificate must be issued by the competent authority in the country of origin that has a
Mutual Recognition Agreement with GOI.
Halal Certificate
According to Law No. 33/2014 on Halal Product Assurance, a new agency called the Halal
Product Assurance Organizing Agency (BPJPH) is charged with overseeing the collection of
fees and issuance of halal certificates for specific products. Law No. 33/2014 came into force on
October 17, 2019, beginning a five-year grace period for all food and beverage products to come
into compliance by the October 17, 2024, deadline. (Mandatory halal certification for all other
products began on October 17, 2021, with grace periods extending between 5 to 15 years,
depending on product category.) However, Government Regulation No. 42/2024, made BPJPH a
stand-alone entity that reports directly to the President and extended the deadline for mandatory
halal certification implementation for imported food and beverage products by no later than
October 17, 2026.
12
Under this amendment regulation, BPOM added snack for children into category of processed food of special dietary
43
Under this law, the Indonesian Council of Ulama (MUI) retains responsibility for determining
whether something is halal or not and for issuing halal fatwas accordingly. Under Law 33/2014,
halal certification is mandatory for all food and beverages (including products derived through
genetically engineering process), pharmaceuticals, cosmetics, biological products, and chemical
products sold in Indonesia, unless the products are on the halal positive list (see below) or are
non-halal (e.g., contains pork or alcohol). All business processes, including production, storage,
packaging, distribution, and marketing will be required to comply with this law, which also
requires non-halal information to be placed on packaging for all non-halal products. Ministry of
Religious Affairs Decree No. 748/2021, updated by Ministry of Religious Affairs Decree No.
944/2024, list the product types that are required to be halal certified. In addition, Ministry of
Religious Affairs Decree No. 816/2024 lists the HS Codes of the food and beverage products
that require halal certification. Meanwhile, Ministry of Religious Affairs Decree No.
1360/2021 lists the materials exempted from mandatory halal certification, known commonly as
the halal positive list.
To date, BPJPH has accredited five U.S. HCBs, namely (in alphabetical order):
American Halal Foundation
Halal Transaction of Omaha
Islamic Food and Nutrition Council of America (IFANCA)
Islamic Services of America
ISWA Halal Certification Department
For further information regarding these HCBs and their approved scopes, please see GAIN
Report ID2024-0005.
The halal certificates of imported products, which are issued by BPJPH-accredited HCBs, must
be registered with BPJPH through the SIHALAL system before the products can be sold in
Indonesia.
Irradiation Certificates
All imported irradiated food should be accompanied by a certificate issued by authorized officers
in the country of origin that is valid for the batch. It is also required to fulfil the requirements of
safety, quality, nutrition, and label and food advertisement.
The following are the types of foods that can be irradiated and their respective doses.
44
Table 10. Indonesia: Type of Food Allowed to Be Radiated
No Type of Food Irradiation Purpose Maximum Dose Absorbed
(kGy)
1. Bulb and root tuber Prevent sprouting during storage 0.15
2. Fresh vegetables and a. Delay ripeness 1.0
fruits (excluding No. 1) b. Kill insects 1.0
c. Extend shelf life 2.5
d. Quarantine treatment 1.0 (for fruit fly 0.15)
3. Processed vegetables Extend shelf life 7.0
and fruits
4. Mango Extend shelf life 0.75 combine with hot water
(55°C) for 5 minutes
5. Mangosteen a. Kill insects 1.0
b. Quarantine treatment 1.0
6. Cereal and millet a. Kill insects 1.0
products, beans, oil b. Reduce microbe amount 5.0
seed, peas, dried fruits
7. Fish, fresh and frozen a. Reduce certain pathogenic 5.0
seafood microorganisms
b. Extend shelf life 3.0
c. Control infection by certain 2.0
parasites
8. Processed fish and a. Reduce certain pathogenic 8.0
seafood microorganisms
b. Extend shelf life 10.0
9. Meat and poultry and a. Reduce certain pathogenic 7.0
their processed microorganisms
products (fresh and b. Extend shelf life 3.0
frozen) c. Control infection by certain 2.0
parasites 7.0
d. Kill salmonella bacteria
10. Dried vegetables, a. Reduce certain pathogenic 10.0
seasonings, dried microorganisms
herbs, and herbal teas b. Kill insects 1.0
45
Radiation Free Certificates
On July 2022, MOA issued Regulation Number 12 Year 2022 regarding the Food Safety
Supervision of Fresh Food of Animal Origin and Fresh Food of Plant Origin Imported into the
Territory of the Republic of Indonesia Against Radioactive Contamination. The regulation applies
to fresh food of plant origin and fresh food of animal origin products, including fresh fruits and
vegetables, grains including maize and barley, meat and meat products, milk and dairy products
and other foods categorized as fresh foods originating from countries with nuclear and/or
radiology emergency status.
Based on Ministry of Agriculture Regulation No. 15/2021, imported organic food must be
accompanied by:
Transaction certificate issued by the Organic Certification Institute (LSO) that has been
certified by the National Accreditation Committee (KAN) whether it is a domestic LSO
or foreign LSO domiciled in Indonesia. The LSO must perform certification of the
business unit in the country of origin.
A health certificate or certificate of sale issued by an authorized institution in the country
of origin.
The 2008 BPOM regulation (replaced by BPOM Regulation No. 1/2017) stated that organic
fresh foods must contain at least 95% organic fresh food from the total volume or weight,
excluding water and salt content. Water and salt content are water and salt added at the time of
processing. Food additives and other materials permitted in organic processed foods are attached
to the regulation. Raw materials, food additives, other materials, and organic processed foods
cannot be treated with irradiation and cannot be derived from genetically engineered products.
The regulation also states that if the PC cannot be issued by the competent authority of the
country of origin, then quarantine action will be carried out on the carrier media, which is in the
form of a plant that has undergone minimal processing (semi-processed plant products). The
MOA will only consider PCs issued within 90 days. The MOA can also consider allowing
importation without a PC if the country of origin can provide them with a strong justification.
46
Table 12. Indonesia: List of Carrier Media
3. Frozen fruits and vegetables put in cold storage with temperatures between 0710; 0811
-18°C to -12°C
5. Vegetables and fruits that are provisionally preserved (for example, in 0711; 0812
sulfur dioxide gas, in brine, in sulfur water or in other preservative
solutions), but unsuitable in that state for immediate consumption
6. Dried vegetables, whole, cut, sliced, broken or in the form of powder, but 0712
not for further preparation
7. Tubers with high starch or inulin content, chilled, frozen, sliced, or in the 0714
form of pellets
8. Coffee, coffee husks and skins, coffee substitutes, roasted, whether 0901
decaffeinated or not
10. Cereal grains that are hulled, rolled, flaked, pearled, sliced, kibbled, or 1104
ground
11. Parts of plants that are used in preparation of perfumes, pharmaceuticals, 3005; 3301
insecticides, fungicides, or for other purposes, dried whether sliced crushed
or ground
12. Vegetable materials of a kind used for plaiting, cleaned, bleached, or dyed 1401
Source: Ministry of Agriculture
47
Table 14. List of SNI Mandatory Products
No. of SNI Product/HS Code Regulation
SNI 8223:2016 Canned tuna Ministry of Fisheries and Marine Affairs
HS Code: 1604.14.10.00 Regulation No. 58/2016
SNI 8222:2016 Canned sardine and Ministry of Fisheries and Marine Affairs
mackerel Regulation No. 58/2016
HS Code: 1604.12.10.00;
1604.13.10.00;
1604.15.10.00
SNI 7709:2019 Palm cooking oil Ministry of Industry Regulation No. 46/2019
HS Code: 1511.90.36;
1511.90.37; 1511.90.39
SNI 6242:2015 Bottled water Ministry of Industry Regulation No. 26/2019
HS Code: 2201.10.10
SNI 3747:2009 Chocolate powder Ministry of Industry Regulation No. 60/2010
HS Code: 1805.00.00
SNI Sugar Ministry of Agriculture Regulation No.
3140.3:2010/Amd1:2011 HS Code: 1701.99.10 13/2020
SNI 2983:2014 Instant coffee Ministry of Industry Regulation No. 3/2016
HS Code: 2101.11.10
SNI 2973:2022 Biscuit Ministry of Industry Circular Note No.
HS Code: 1905.31.10.00; 500/MIND/7/2016
1905.31.20.00; (The Ministry of Industry (MOI) issued a
1905.32.00.00; circular letter dated July 25, 2016,
1905.90.20.00; postponing the implementation date for the
1905.90.90.00 biscuit SNI. There is no information stating
when the biscuit SNI will be enforced)
SNI 01-3556-2000 Salt for consumption Ministry of Industry Regulation No. 29/1995
SNI 3751: 2009 Wheat flour for foodstuff Ministry of Industry Regulation No.59/2015
Source: http://sispk.bsn.go.id/RegulasiTeknis/SniWajib
In order to obtain an SNI for imported products, an importer must fulfil several requirements,
including obtaining product quality conformity test results from an assigned domestic or foreign
accredited laboratory.
48
BPOM regulations No. 25/2020 and BPOM Regulation No. 13/2023 state that this guidance will
include:
OTHERS
Milk products have special regulations
Baby food has special regulations
Animal quarantine regulations for live animals and semen vary and should be consulted before
exporting live animals to Indonesia. Requirements on exporting live animals (including pet
animals) can be found in USDA APHIS International Regulations for Animals page.
Geographical Indicators
The legal protection for Geographical Indicators (GIs) in Indonesia is under Law No. 20/2016 on
Trademarks and Geographical Indications, which was updated through Law No. 6/2023, and the
Ministry of Law and Human Rights Regulation No. 12/2019, amended by Regulation No.
10/2022 on GI which provides the technical guidance on the procedure and registration for GI in
Indonesia. Under Regulation No.10/2019, registration for international brand with GIs in
Indonesia must be submitted in writing to the Directorate General of Intellectual Property
(DGIP) through a designated representative (a power of attorney or the diplomatic
representative) after the GI product has already obtained recognition from the government of the
country of origin. As of November 2024, Indonesia has registered 167 GIs, including cheeses
(e.g., Gorgonzola, Parmigiano Reggiano, and Grana Padano, ) and alcoholic beverages (e.g.,
Tequila, Scotch Whisky, and Champagne).
50
announced that for Phase II (2023), it would expand the commodity balance policy to apply to 19
more commodities, including agricultural products such as corn and garlic. Until the commodity
balance is set for a particular commodity, the administration of import licenses will continue
under existing licensing regimes (for example, the two-step licensing process remains in place
for 2023 dairy and horticultural imports, Figure 3).
Per Presidential Regulation No. 143/2024, CMEA no longer oversees the commodity balance
process for food commodities but retains its lead on the commodity balance process for non-food
commodities such as fuel, textiles, iron, steel, tires, plastic, cement, and footwear. On November
5, 2024, the President issued Regulation No. 147/2024 assigning Coordinating Ministry for Food
Affairs (CMFA) to replace CMEA in overseeing and coordinating the implementation of the
food commodity balance process.
Figure 3. Indonesia: Food Commodity Balance (CB) and Import Licensing Process through
the SINSW System
Importer submits the need Relevant Ministry that oversees the commodity sector shall
plan by September verify, and determine the needs and supply plan by October
Business Process to Submit Need and
SINSW
Letter of Consideration/ Import
Recommendation
Supply Plan
Inter-ministerial
SSm Licensing meeting to
Officialized CB
(no later than the determine CB, led
CB and requirements validation
Business Process Licensing
Figure 3 illustrates the import licensing process for products subject to the Commodity Balance
policy. First, importers must submit their “Needs Plans” for the following year by September via
the online National Commodity Balance System (SINAS NK), a sub-system of the Indonesia
51
National Single Window System (INSW)13. The relevant ministry with oversight of the
commodity will review and verify the data to generate an aggregate Needs Plan, which takes into
account the Supply Plan consisting of production and stock data for the current year. Once the
aggregate Needs Plan is finalized, the commodity’s ministry will submit the data to the CMFA
via the SINAS NK system through the INSW by October.
Then, INSW will compile the data submitted by the commodity’s ministry. At this stage, the
INSW automated system determines the preliminary commodity balance, and the official
commodity balance must be finalized no later than the seventh working day in December
(Presidential Regulation No. 61/2024) through a technical coordination meeting and then the
inter-ministerial meeting led by CMFA to officialize the commodity balance.
Finally, after the commodity balance has been determined, the importer will receive notification
from INSW (via SMS or email) to process the import application. Within five working days, the
Ministry of Trade (MOT) will then issue the import license based on the commodity balance
through Single Submission (SSm) Licensing system.
Figure 4. Indonesia: Import Licensing Process for Non- Commodity Balance Products
through the SINSW System
Pre-shipment Inspection
MOT Regulation No. 36/2023, amended by MOT Regulation No.8/2024, requires a pre-
shipment inspection for certain products (see Table 15 below) in the country of origin.
13
Information on INSW can be found in the SECTION X: TRADE FACILIATION
52
Inspections can be carried out by surveyors that have been appointed by MOT and accredited by
the National Accreditation Committee (KAN) as regulated by Ministry of Trade Regulation No.
16/2021 on Verification and Technical investigation in the Foreign Trade Sector. In order to
carry out verification in the country of origin, the surveyor must have overseas branches or
representatives or affiliating with overseas Surveyors.
53
SECTION X: TRADE FACILITATION
Advance Rulings
On February 3, 2022 the Ministry of Finance issued Regulation No. 7/2022 regarding the
Procedure for Submitting Advance Ruling on Origin Application, which enables importers to
seek a decision from Customs on the origin of imported foods prior to submission of the import
declaration14. This new regulation aims to expedite the movement, release and clearance of
goods and to meet the WTO-TFA Agreement. The Ministry of Finance issues a decision for
advance ruling within 30 working days for Authorized Economic Operators applicants and 40
working days for other applicants15.
Single Window
In 2018, the President of Indonesia issued Regulation No. 44/2018 on the Indonesia National
Single Window system (INSW) to integrate all customs, quarantine, licensing, port/airport
documents related to exports and imports, and can be electronically submitted to the relevant
ministries and institutions/agencies. This system is managed by Lembaga National Single
Window (LNSW) under the Ministry of Finance. In 2021, the GOI introduced the upgraded
version of the INSW system, the Indonesia National Single Window System (SINSW), which
aims to operate as a single channel for all business licensing in the import sector. Under MOT
Regulation No. 36/2023, amended by MOT Regulation No.8/2024 and Presidential Regulation
No. 61/2024 requires application of import license to be submitted through INSW, including
submission of (import need) volume in the commodity balance system.
E-Certificates
The Indonesian Quarantine Agency has developed an Implementing Arrangement for the
exchange of electronic certification (e-Cert) with several trading partner countries such as
Australia, New Zealand, and the Netherlands. On February 2, 2023, Indonesia notified the World
Trade Organization (WTO) under notification number G/SPS/N/IDN/145 that the Indonesia
Quarantine Agency has provided paperless services to users of quarantine services by issuing
electronic certificates (Phytosanitary and Health Certificate) and requests reciprocity from
trading partners. Indonesia has developed a technique for validating the certificate through the
IQA portal on: https://ppkonline.karantina.pertanian.go.id/checkcert.
14
WTO - Indonesia Advance Rulings
15
Authorized Economic Operators is company that have been recognized by the Directorate General of Customs
and Excise, Ministry of Finance and receive certain customs treatment, Ministry of Finance Regulation No.
137/2023
16
Based on data from Indonesia Port Corporation (Pelindo II)
54
5. Terminal Mustika Alam Lestari, (tariff calculation)
Most of the common issues in Indonesia’s custom clearance process occur with imported
products that are regulated by more than one ministry and require a two or three – step license,
e.g. agriculture and livestock products are regulated by the Ministry of Trade, the Ministry of
Agriculture and the Quarantine Agency; seafood and fishery products are regulated by the
Ministry of Fisheries and Marine Affairs, the Ministry of Trade or the Ministry of Industry, and
the Agency of Quarantine; processed foods and beverages are regulated by the Ministry of
Trade, and the National Agency of Drug and Food Control. The involvement of multiple
ministries and agencies needs improved coordination and integration in implementing import
regulations so as not to disrupt trade.
Exporters are cautioned to avoid issues with stuck shipments. Re-selling or re-exporting cargo
that has arrived at Indonesian ports can be extremely challenging and requires the full
cooperation and approval of the original consignee. Therefore, exporters are encouraged to
always conduct due diligence on importers before conducting any business. For information on
the re-selling of cargo after arrival in Indonesia; please see report on Guide to Re-selling
Containerized Cargo After Arrival.
17
https://apps3.insw.go.id/dashboard_dtinsw.php
55
APPENDIX I: GOVERNMENT REGULATORY AGENCY CONTACT
56
Halal Product Assurance Organizing
Agency (BPJPH)
Jl. Raya Pd. Gede No.13, Pinang Ranti, Kec KSO Sucofindo - Surveyor Indonesia (KSO
Makasar, Jakarta Timur, Jakarta 13560 SCISI)
Tel: +6221-8087-7955 On Import Verification Program/Pre-
Homepage: https://bpjph.halal.go.id Shipment Inspection
http://www.mui.or.od/Products regulated: halal- Menara Bidakara 2, 5th Floor Jl. Jend. Gatot
certified food Subroto Kav 71-73 Pancoran Jakarta Selatan
12870
National Food Agency Tel: +6221-8379-3222/Fax: +6221-8370-
Jl. Harsono RM No.3, Ragunan, Jakarta 0445/8379-3226
12550, IndonesiaTel: +6221-7807377 Homepage: www.scisi.co.id
Homepage: https://badanpangan.go.id/
57
APPENDIX II: OTHER IMPORT SPECIALIST CONTACTS
Association of Indonesian Fresh Fruit and USA Poultry & Egg Export Council
Vegetable Exporters- Importers (USAPEEC)
(ASEIBSSINDO) #15-04 Liat Towers 541 Orchard Road
Gd. Graha Antero Lt 5 Singapore 238881
Jl. Tomang Raya No. 27 Kebayoran 11440 Ph: +65- 6733-4255/6
Tel: +6221-5695-8893/Fax: +6221-5695-8892 Fax: +65- 6732-1977
E-mail: [email protected]; Email: [email protected]
[email protected]
U.S. Meat Export Federation (USMEF)
Indonesian Consumer Organization 627A Aljuned Road, 04-04 Biztech Centre,
(YLKI) Singapore 389842
Jalan Pancoran Barat VII No. 1 Duren Tiga, Ph: +65- 6733-4255/6
Pasar Minggu Fax: +65-6732-1977
Jakarta 12760 Email: [email protected] &
Tel: +6221-798-1858/Fax: +6221-798-1038 [email protected]
Email: [email protected]
American Soybean Association (ASA)
Association of Flourmills (APTINDO) #11-03 Liat Towers, 541 Orchard Rd.
Daniprisma Building, 3rd Floor, Jl. Sultan Singapore 238881
Hasanuddin No. 47-48 Jakarta 12160 Ph: +65-6737-6233/Fax: +65-6737-5849
Ph: +6221-7279-7843 E-mail: [email protected]
Fax: +6221-720-6008
Email: [email protected] U.S. Soybean Export Council (USSEC)
Mr. Ibnu Edy Wiyono - Indonesia in Country
Association of Meat Importers (ASPIDI) Representative USSEC
Delta Building Phone: +628121005056
Jl. Suryopranoto No.15, Jakarta Pusat 10160, Email: [email protected]
Indonesia
Tel: +62 21 3454509
Email: [email protected]
58
U.S. Wheat Associates (USWA) Ambassador’s Court, 4th Floor, No. 416,
#15-02 Liat Towers 541 Orchard Road 76/1 Soi Lang Suan, Ploenchit Road,
Singapore 238881 Bangkok, Thailand 10330
Ph: +65-6737-4311 Ph: +66-2- 251-8655/6
Fax: +65-6733-9359 Fax: (66-2) 251-0390
Email: [email protected] E-mail: [email protected]
Attachments:
No Attachments
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