Regulation Watch · Tourism and Health · Indonesia. The regulation applies nationally to every person or corporation producing food in packaging, including PT PMA and PT PMDN food and beverage manufacturers, importers responsible for Indonesian-market products, hotels, restaurants, caterers, tourism and hospitality operators that manufacture packaged food, and businesses using direct-contact packaging. Its supply-chain effect also reaches packaging manufacturers, converters, material suppliers, testing laboratories and contract manufacturers.
BPOM Replaces Indonesia's Food-Packaging Safety Rules
PerBPOM 11/2026 replaces Indonesia's 2019 food-packaging rule with migration testing, approved food-contact-substance, reusable and recycled packaging controls, plus a 30 June 2027 general transition deadline.
- Published
- Established in Jakarta on 23 June 2026 and promulgated on 30 June 2026 in State Bulletin 2026 No. 433. It was first recorded by Regulation Watch on 10 October 2026 as a late-discovered instrument.
- Effective
- 30 June 2026, the date of promulgation specified by Article 15. PerBPOM 20/2019 was revoked on the same date.
- Added to Watch
- 10 October 2026
Who is affected
PT PMA and PT PMDN packaged-food and beverage manufacturers; Indonesian importers and local representatives of foreign food brands; packaging producers, converters and material suppliers; hotels, restaurants, caterers and tourism operators producing packaged products; retailers and private-label businesses; reusable-packaging and recycled-material operators; shareholders and directors; and product-development, procurement, quality, laboratory, regulatory, sustainability and legal teams.
Practical impact
Direct-contact packaging must use safe food-packaging materials and permitted food-contact substances, meet total and/or specific migration limits and be supported by the prescribed migration tests. The rule covers plastic, rubber and elastomer, paper and cardboard, ceramic, glass, metal and alloys, and multilayer packaging. Reusable plastic requires the dedicated reusable-packaging migration test, while recycled packaging must also comply with the applicable good-manufacturing requirements. A material or food-contact substance outside the listed framework cannot be used until the Head of BPOM grants written approval after a safety assessment. Packaging already circulating must generally comply by 30 June 2027, subject to separately phased migration limits; BPOM has officially stated that the BPA limit for polycarbonate packaging will be stepped down to 0.05 mg/kg in the fifth year.
PerBPOM 11/2026 was established on 23 June 2026, promulgated on 30 June in State Bulletin 2026 No. 433 and took effect on promulgation. It revokes PerBPOM 20/2019 and replaces the former food-packaging framework with updated migration, food-contact-substance, reusable-packaging, recycled-material and safety-assessment controls.
The primary legal duty falls on every person or corporation producing food in packaging. Direct-contact packaging must be safe and must meet the applicable total and/or specific migration limit. Compliance is demonstrated through the migration tests in Annex II, not merely through a generic supplier statement or a foreign food-grade certificate.
The material framework covers plastic, rubber and elastomer, paper and cardboard, ceramic, glass, metal and alloys, and multilayer packaging. Annex I contains migration limits, Annex II the test framework, Annex III permitted food-contact substances, and Annex IV prohibited substances. Product, packaging, use condition and test evidence therefore need to be assessed together.
Reusable packaging is expressly regulated. A food producer using reusable packaging must ensure the applicable migration limits continue to be met, and reusable plastic must undergo the dedicated Annex V test. Recycled packaging must meet the applicable good-manufacturing requirements and is subject, with necessary adaptations, to the same safe-material, substance, migration and reuse provisions.
A packaging material or food-contact substance outside the listed framework may be used only after written approval from the Head of BPOM based on a packaging-safety assessment. The application must include at least applicant information, technical data for the material or substance and packaging test results. Commercial use should therefore wait for the written approval rather than treating a pending assessment as authorization.
Packaging already circulating receives a 12-month general transition, ending on 30 June 2027. The regulation separately allows the Head of BPOM to phase particular migration limits after a risk assessment. In September, BPOM officially stated that the BPA limit for polycarbonate packaging would be reduced in stages to 0.05 mg/kg in the fifth year; affected businesses should keep the general transition and the substance-specific stage in separate compliance registers.
Article 12 applies administrative sanctions through the wider legislation to violations of the core safety duties. Because the regulation does not provide one universal fine or fixed sanction sequence, businesses should not infer that non-compliance carries only a warning. Registration, inspection, import, distribution, withdrawal and general food-safety consequences may also be engaged.
Foreign investors, directors and procurement teams should treat packaging as part of the regulated product rather than a commodity purchase. Before the transition ends, the Indonesian product owner should reconcile the bill of materials, supplier evidence, migration tests, reuse or recycled-content controls and BPOM filings for each stock-keeping unit, then contractually control future changes.
Late discovery: the instrument took effect in June 2026 but was not previously recorded in the Regulation Watch ledger. The current BPOM JDIH metadata, official text and later BPOM implementation statements now provide the primary-source basis for publication without changing the instrument's true legal dates.
Required action
- Create an inventory of every direct-contact packaging configuration used for Indonesian products, including closures, liners, coatings, inks, adhesives and each layer of a multilayer structure; link it to the food type, contact time, temperature, reuse cycle and Indonesian product-registration file.
- Classify each packaging material under the seven regulated groups and obtain supplier specifications, formulation or compliance declarations, certificates of analysis and traceability evidence for the food-contact substances used.
- Compare each material and food-contact substance against Annexes I, III and IV, then commission the applicable total and/or specific migration testing under Annex II using the correct food simulant and conditions of use.
- For reusable plastic packaging, validate the repeated-use migration test in Annex V and document cleaning, inspection, rejection and maximum-use controls; do not treat a single-use migration result as sufficient for reuse.
- For recycled-content packaging, verify the applicable good-manufacturing requirements, input-material controls and traceability, and apply the same material, substance, migration and reusable-packaging rules where relevant.
- Apply to BPOM for a written safety-assessment approval before commercially using any packaging material or food-contact substance that falls outside the listed materials or permitted substances; include applicant data, material or substance data and packaging test results.
- Replace, reformulate or requalify non-compliant packaging already circulating before 30 June 2027, while separately tracking any BPOM decision that phases a specific migration limit, including the announced five-year BPA pathway for polycarbonate packaging.
- Update supply, co-manufacturing, import and private-label contracts so composition changes require prior notice, Indonesian migration evidence is available for inspection, and responsibility for corrective action, withdrawal and replacement is allocated.