Regulation Watch · Business Licensing · Indonesia, including products and materials manufactured, imported, distributed, supplied or used by businesses operating in Bali.
BPJPH Exempts Listed Low-Risk Products and Materials From Halal Certification
BPJPH Head Decision 301/2026 creates a 201-page exemption list for specified low-risk plant, non-slaughter animal, algae, natural-water, chemical and polymer products and materials, effective 28 February 2027.
- Published
- Established on 31 August 2026. The official BPJPH JDIH record lists 31 August 2026 as both the establishment and publication date; the signed text was surfaced in this Regulation Watch review on 28 September 2026.
- Effective
- 28 February 2027, six months after the decision was established on 31 August 2026.
- Added to Watch
- 28 September 2026
Who is affected
PT PMA and PT PMDN manufacturers, importers, distributors, retailers and food-service operators; food, beverage, pharmaceutical, cosmetic, chemical, biological, agricultural, fisheries, packaging and consumer-goods businesses; foreign suppliers; directors; and procurement, product, quality, regulatory and halal-compliance teams.
Practical impact
A listed product or material that meets the decision's low-risk criteria will not need its own halal certificate from 28 February 2027. The annex spans minimally processed plant products, halal non-slaughter animal products, algae, natural water, mined or naturally purified chemicals, thousands of specified inorganic or non-microbial synthetic chemicals, and listed cellulose and polymer materials. The exemption is classification-specific rather than a blanket release for a finished product: processing, added ingredients, processing aids, fermentation, contamination risk, protected-species status or a product's absence from the annex can change the result. BPJPH may still request production-flow, composition, certificate-of-analysis and similar evidence. Plant materials produced through genetic engineering remain subject to the applicable food-safety certificate or approval.
Late discovery: BPJPH Head Decision 301/2026 was established on 31 August 2026, and the official JDIH record lists the same date for publication. The decision becomes effective six months later, on 28 February 2027, and supplies the product-and-material list contemplated by Article 70 of Government Regulation 42/2024.
The exemption is built around risk and traceability. Qualifying items originate from nature without processing or with only specified minimal processing, carry no material risk of prohibited content or contact, do not come from protected plants or animals, are not prohibited or harmful products, and are classified by source, characteristics, process and contamination risk. Relevant items may need to be single-component and must not acquire a different source identity or a halal-critical additive, processing aid or other material.
The annex is unusually broad and detailed. Its seven groups cover plant products and materials; products and materials from halal animals that do not require slaughter, including listed fish; algae; natural spring, groundwater and other natural water; chemicals obtained through mining or purification of natural material; specified inorganic and non-microbial synthetic chemicals; and a final group of listed cellulose and polymers such as polyethylene, polystyrene, polyurethane and PVC. The chemical section alone runs to 3,548 entries and often identifies the CAS number.
Minimal processing recognised by the decision includes washing, peeling, chilling, freezing, cutting, drying, salting, milling, blanching, heating, homogenisation, centrifugation, sieving, filtration, pressing, pretreatment, size reduction, evaporation, sorting and classification, and fractional distillation. A business should still match the actual process to the listed item and criteria rather than assuming every derivative of an exempt agricultural or chemical input is also exempt.
BPJPH can require supporting evidence even when a product or material is exempt. The decision expressly identifies the production flow, composition, certificate of analysis or equivalent and other supporting documents. Plant material produced through genetic engineering must also retain the certificate or approval for genetically engineered food safety required by other Indonesian rules.
The list can expand, but not by self-declaration. A stakeholder may propose an unlisted product or material to the Deputy for Halal Partnership and Standardization through the Directorate of Halal Standardization with the supporting process, composition and analytical records. BPJPH reviews the proposal with a technical team, and an approved addition becomes legally binding only when it is published on BPJPH's official website.
Required action
- Map each raw material and finished product against the exact annex entry, name, source and CAS number where provided; do not rely only on a supplier's generic description or the fact that a similar material appears on the list.
- Test the full product and process against the exemption criteria, including minimal processing, single-component status where relevant, absence of a halal-critical additive or processing aid, no prohibited or protected source, and no material contamination risk.
- Retain an auditable exemption file containing the production flow, full composition, certificate of analysis, supplier declaration, origin and processing evidence, and the annex entry relied on so it can be produced during inspection or halal-certification review.
- For genetically engineered plant material, obtain and maintain the food-safety certificate or approval required by Indonesian law; Decision 301/2026 does not waive that requirement.
- Where a product or material appears to meet the criteria but is not listed, submit a supported proposal to BPJPH's Directorate of Halal Standardization and continue to treat it as non-exempt until BPJPH approves and publishes the addition.
- Keep separate controls for BPOM registration, SNI or technical standards, import licensing, customs, non-halal disclosure and other sector approvals because the decision removes only the halal-certificate obligation for qualifying listed items.