Regulation Watch · Business Licensing · Indonesia, including products and food, beverage, hospitality, retail, distribution, import and service businesses operating in Bali.
Halal Breaches Can Trigger Product Withdrawal and Site Closure
BPJPH Regulation 2/2026 creates an enforceable sanctions process for halal-compliance breaches, including short correction windows, fines, certificate revocation, product withdrawal, public notices, and temporary closure of food-service premises.
- Published
- Established on 11 May and promulgated on 5 June 2026 in State Bulletin 2026 No. 365. The official BPJPH JDIH record and signed text were surfaced in this Regulation Watch review on 28 September 2026.
- Effective
- 5 June 2026, the date of promulgation.
- Added to Watch
- 28 September 2026
Who is affected
PT PMA and PT PMDN companies, directors and compliance teams; manufacturers, importers, distributors, retailers, hotels, restaurants, cafes, caterers and other food-service operators; pharmaceutical, cosmetic, chemical, biological and consumer-goods businesses; foreign producers whose halal certificates are registered in Indonesia; halal supervisors; LPH inspection bodies, halal auditors and PPH assistance institutions.
Practical impact
BPJPH now has a detailed enforcement route for breaches of mandatory halal certification, inaccurate application data, failure to separate halal and non-halal production or service flows, missing halal supervisors, unreported material or process changes, missing labels, failure to preserve certified status, missing non-halal statements, and foreign-certificate registration or renewal failures. Depending on the breach, BPJPH may issue a warning, impose an administrative fine, revoke a halal certificate or foreign-certificate registration, and order product withdrawal. A food or beverage service that fails to display the required non-halal statement can be required to close temporarily until it corrects the disclosure. BPJPH, relevant ministries and provincial or regency authorities may conduct the underlying supervision.
Late discovery: BPJPH Regulation 2/2026 was established on 11 May and promulgated on 5 June 2026 in State Bulletin 2026 No. 365. It took effect immediately. The regulation turns the general halal obligations into a detailed administrative-enforcement process for businesses, inspection bodies, auditors and PPH assistance institutions.
For businesses, the regulated breaches include selling covered products without mandatory halal certification after the applicable transition period, providing inaccurate information in a certificate application, failing to separate halal and non-halal production or service flows, lacking a halal supervisor, failing to report ingredient or process changes, omitting the halal label, failing to preserve certified halal status, failing to renew after a material change, failing to operate the halal-assurance system, omitting the required non-halal statement, and failing to register, display or renew a foreign halal certificate in Indonesia.
The sanction depends on the breach and can start above a warning. BPJPH may impose warnings, administrative fines, certificate revocation and product withdrawal. A certificate revocation is accompanied by withdrawal. Medium and large businesses that fail foreign-certificate registration, display or renewal duties can face a fine and/or withdrawal, while micro and small businesses follow a staged warning, fine and withdrawal sequence.
Correction windows are short and use working days. Failure to obtain mandatory certification after the relevant phase receives up to 30 working days after a warning; other listed business breaches generally receive 14 working days. Missing those windows can trigger a fine and/or withdrawal, and BPJPH may publish the non-compliance through electronic, social or print media or by placing a sticker. A withdrawal order must be completed within 60 working days.
Food-service businesses face a particularly visible consequence for missing non-halal disclosure. Until the required statement is displayed, withdrawal for directly processed food and beverage services or other services is implemented by temporarily closing the premises and posting a sticker, banner or other notice. BPJPH must announce the affected product to the public within two working days after the warning in this case.
Supervision may be carried out by BPJPH, relevant ministries or provincial and regency authorities. A business can object only to an administrative fine, halal-certificate revocation or withdrawal order, and must file with the BPJPH Head within five working days after the sanction is established. The filing needs the applicant's identity, grounds, challenged decision and supporting evidence. Businesses should therefore maintain inspection-ready records and authorize a response team before a notice arrives.
Required action
- Map every product and service against the applicable mandatory-halal phase, certificate or registered foreign-certificate status, and non-halal disclosure requirement; do not assume a pending application prevents enforcement after the relevant transition period.
- Reconcile certified product names, ingredients, suppliers, production codes, facilities and processes with current operations, and report any material or process change to BPJPH before relying on the existing certificate.
- Document separation of halal and non-halal locations, equipment, storage, packaging, distribution, sales and service, and formally appoint and maintain the required halal supervisor.
- Check that halal labels, foreign-certificate registration numbers and non-halal statements are displayed in the required form and location across packaging, menus, sales channels and premises.
- Create an inspection-response file containing the certificate, application evidence, supplier and ingredient records, process controls, labels, corrective-action owners and management contacts so a warning can be answered within the applicable 14- or 30-working-day period.
- If BPJPH imposes a fine, certificate revocation or product-withdrawal order, assess an objection immediately; the regulation allows only five working days from the sanction decision and requires the identity, grounds, challenged decision and supporting evidence.