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Jakarta — October 2025. Indonesia has issued BPJPH Decree No. 221/2025, setting out definitive procedures for registering overseas halal certificates (SHLN) so products certified abroad can be marketed domestically under the Halal Product Assurance Law framework. The decree replaces BPJPH Decree No. 90/2023 and takes effect 15 December 2025. A parallel WTO/TBT addendum confirms adoption, publication, and the entry-into-force timeline, and points to BPJPH’s public guidance.

What’s changing

Foreign halal certificates issued by a foreign halal certification body (LHLN) that has a mutual recognition arrangement (MRA) with BPJPH do not require re-certification in Indonesia. However, registration with BPJPH remains mandatory before products circulate on the Indonesian market. The decree converts prior practice into a single, binding procedure with clearer digital workflows, document standards, and change-management rules.

How registration works

Applications are lodged electronically via the SIHALAL system by an importer or an official representative in Indonesia, and they must be completed before products are placed on the market. Registrations are submitted per product category.

Documentation checklist

• Application letter
• Authorization letter from the foreign company appointing the applicant
• NIB (Indonesian Business Identification Number)
• Copy of the overseas halal certificate (SHLN)
• List of goods with HS codes
• Warehouse details (name, address, ownership)
• Signed statement of truth
  If documents are not in English, include an English translation.

Product name alignment

If the product name on the foreign certificate differs from the name used in Indonesia, submit either an updated SHLN or a declaration from the LHLN using BPJPH’s Annex III template to confirm the equivalence.

Renewals and changes

Registrations can be renewed from 60 days before the registration’s expiry until the expiry date. Temporary proof that renewal is in process may be used, subject to providing the updated SHLN within the required timeframe.

The decree distinguishes between:

• Changes that only require reporting (e.g., importer name/address with the same NIB, contact-person updates, HS-code corrections), and
• Changes that require a new registration (e.g., new NIB, change of LHLN, facility relocation).

A decision table in Annex II clarifies the correct path for each scenario.

Validity, labeling, and enforcement

The registration number remains valid for the same period as the foreign halal certificate. If the MRA or accreditation that underpins recognition expires, BPJPH may deactivate the registration number until recognition is restored.

After registration, importers or official representatives must apply the halal label together with the SHLN registration number in line with Indonesian labeling rules and promptly report any data changes to BPJPH.

Administrative sanctions for non-compliance may include written warnings, administrative fines, deregistration, and/or product withdrawal.

The Indonesian Food and Drug Authority (Badan Pengawas Obat dan Makanan, BPOM) has held a public consultation on the Draft Regulation on Certification of Good Manufacturing Practices for Cosmetics (CPKB), as part of ongoing efforts to modernize and strengthen regulatory oversight of the cosmetics sector. Stakeholders were invited to submit written comments until 26 September 2025.

The draft regulation seeks to replace BPOM Regulation No. 33/2021, introducing a risk-based supervision system, streamlining certification procedures, and codifying service-level timelines for verification, inspections, and decisions.

What the Draft Changes

Two certification tracks.

• CPKB Certificate - Required for manufacturers (including contract manufacturers), issued per dosage form, and valid for five years.
• Certificate of Compliance with CPKB Aspects - Intended for non-contract manufacturers, offered as Gradual Type A (covering 10 quality-system aspects) or Type B (covering baseline aspects). This certificate may cover multiple dosage forms and is also valid for five years.

Applications must be submitted online. BPOM will verify documentation within seven working days. Following payment, inspections are coordinated within 20 days, and decisions are issued within 35 days for cases that do not require inspection. The process follows a “clock on/off” principle, allowing up to three data-request cycles of 20 days each.

Administrative changes, such as name or address change without relocation, can be approved without inspection. Certain technical changes and renewals may trigger inspection depending on risk level and recent oversight history. Late renewals must re-apply as new.

Existing CPKB or Aspect certificates and joint-use approvals remain valid until their expiry date. Floor-plan pre-approvals submitted before the new rule takes effect will be processed under Regulation 33/2021, signalling the elimination of this requirement in the new framework. Upon entry into force, Regulation 33/2021 will be repealed.

Why It Matters for Industry

• Predictable timelines via codified milestones of seven-, twenty-, and thirty-five-days reduce uncertainty and idle time during processing.
• Scalable pathways for SMEs through Aspect-Compliance options (Type A/B) provide staged on-ramps toward full CPKB.
• Risk-based renewals/changes target inspections where they add value, limiting disruption for compliant sites.
• Integrated operations enabled by formalized joint-use approvals across cosmetics, Obat Kuasi, and PKRT.

What Companies Should Do Next

1. Map your certification path (full CPKB vs Aspect Compliance A/B) and confirm dosage forms requiring certification.
2. Align dossiers and QMS with the draft’s annexed checklists; prepare for electronic submissions and clock on/off interactions.
3. Plan for renewals and changes using risk triggers to avoid unnecessary inspections and downtime.
4. Evaluate joint-use feasibility (Obat Kuasi/PKRT) and assemble validation evidence if pursuing shared lines.

Context and Next Steps

Grounded in Government Regulation No. 28/2024 under the 2023 Health Law, the draft modernizes CPKB governance by emphasizing risk management, digital administration, and enforceable service levels. With consultation closed, stakeholders should monitor BPOM for the consolidated final text and effective date.