Food labeling plays a vital role in ensuring consumer safety, providing essential product information, and facilitating market transparency. In Indonesia, the growing food and beverage industry must be in line with strict labeling regulations set by the Indonesian Food and Drug Authority (BPOM). Non-compliance can result in penalties such as fines, product recalls, and/or suspension of business operations.
This article highlights the most common pitfalls in food labeling in Indonesia and answers frequently asked questions to help businesses navigate these regulations effectively. Understanding and complying with these requirements is crucial for companies aiming to maintain market access, and build trust with Indonesian consumers.
Common Pitfalls in Food Labeling
Here are the five most prevalent errors commonly observed on processed food labels:
1. Misinterpretation of Mandatory and Prohibited Information
This error arises when essential mandatory details are omitted, or prohibited information is erroneously included on the label.
2. Improper Placement of Labeling Items
This occurs when items required to be displayed on the principal display panel are mistakenly positioned elsewhere on the label, which is a non-compliance.
3. Inaccurate Ingredient Declaration
Ingredients are not listed in the correct descending order by quantity, are not compliant to QUID (Quantitative Ingredient Declaration) guidelines, or do not comply with regulations for labeling food additives.
4. Non-Compliant ING Table Formatting
The format of the ING table fails to meet established regulatory standards.
5. Omission of Required Warnings
This includes the absence of mandatory warnings, such as when a product contains artificial sweeteners without corresponding cautionary notice regarding their use.
FAQs of Food Labeling
Here are 10 frequently asked questions about food labeling:
Q1: Is it mandatory to include the importer's address on the label of food imported into Indonesia?
A1: Based on BPOM Regulation No. 31 of 2018 on Processed Food Labels, as amended by BPOM Regulation No. 20 of 2021, imported processed food must include both the name and address of the producer on the label, as well as the name and address of the importer or distributor.
Q2: What information should be included on secondary packaging containing individually packaged products?
A2: Secondary packaging labels must include all the required information in accordance with Article 5 of BPOM Regulation No. 31 of 2018 on Processed Food Labels.
Q3: What is the process for applying for a processed food label review?
A3: Applications for processed food label reviews can be submitted through https://e-standarpangan.pom.go.id/. Instructions for the e-Standard Food application can be downloaded at: https://e-standarpangan.pom.go.id/data/guide /Buku_Manual_Aplikasi_.pdf. Guidelines for completing the application form are available at https://standarpangan.pom.go.id/dokumen/pelayanan-publik/Pedoman_Pengisian_Formulir_Permohonan_Pengkajian.pdf.
Q4: What are the guidelines for including terms such as "recyclable," "reusable," or "biodegradable" on processed food labels?
A4: The inclusion of such terms, logos, or images related to environmental sustainability, including recycling claims, must comply with the regulations and approval from the Ministry of Environment and Forestry (KLHK).
Q5: Are imported products required to have a halal certificate in Indonesia?
A5: According to Government Regulation No. 39 of 2021 on Halal Product Assurance, products entering, circulating, or being traded in Indonesia must be halal-certified unless they are made from non-halal materials, in which case a non-halal declaration is required. The mandatory halal certification for food products, beverages, and slaughtering services will be in effect from October 17, 2024.
Q6: Are there specific size requirements for text on processed food labels?
A6: BPOM Regulation No. 31 of 2018 requires that all label information be clearly legible and proportional to the label's surface area. The minimum text size is the lowercase letter "o" in Arial font, 1 mm in height (Arial 6 pt). For product names and warnings, the minimum height is 2 mm.
Q7: Is it allowed to label a product as "plant-based"?
A7: The use of "plant-based" on labels is currently not permitted to avoid confusion between "plant-based" and "vegan." Businesses are advised to use "vegan" labeling if they meet the necessary requirements.
Q8: Can processed food labels include information in a foreign language?
A8: As per BPOM Regulation No. 31 of 2018, foreign or regional languages can be used on labels only if the same information is also provided in Indonesian Bahasa. If no equivalent Indonesian term exists, the corresponding foreign term may be used.
Q9: What nutrients must be listed in the ING table?
A9: According to Article 5, paragraph (3) of BPOM Regulation No. 26 of 2021 on Nutritional Value Information, the required nutrients include: total energy, total fat, saturated fat, protein, total carbohydrates, sugars, and salt (sodium). Additional nutrients such as trans fat, cholesterol, and dietary fiber must also be included if present in significant amounts.
Q10: Who is responsible for testing the nutrient values listed in the ING table?
A10: Testing of the nutrients listed in the Nutritional Value Information (ING) table is conducted by the manufacturer or business operator themselves.
Navigating the regulatory landscape of food labeling in Indonesia can be challenging. However, by being aware of common pitfalls and FAQs, businesses can take proactive steps to ensure their labels are compliant with Indonesian standards. As the food and beverage industry in Indonesia continues to grow, staying informed about labeling regulations and best practices will be essential for any company looking to succeed.
For comprehensive information of food labeling requirements in Indonesia, including regulatory framework, general labeling provisions, mandatory and optional labeling items, labeling exemptions, as well as special labeling for certain food products, ChemLinked highly recommends stakeholders to check our newly launched online course - Unlock Food Labeling Requirements in Japan, South Korea, and Southeast Asia. Click here or the banner below to get more details!