Indonesia Aquatic Products Regulation

1. Definition

In Indonesia, as per Minister of Maritime Affairs and Fisheries Regulation No. 1 of 2021 on Recommendations for the Importation of Fishery Products and Live Fish Apart from Raw Materials and Industrial Auxiliary Materials, fishery products are fish that are handled, processed and/or made into final products in the form of fresh fish, frozen fish and other processed products.

2. Competent authority

Competent authority	Responsibility
Badan Pengawas Obat dan Makanan (BPOM)	BPOM is responsible for protecting public health through control and supervision of food products, traditional medicine, cosmetics, pharmaceuticals, biopharmaceuticals, and health supplements. It is tasked to issue import permits for food products and oversee the distribution of food products in Indonesia.
Kementerian Perdagangan (The Ministry of Trade, MOT)	MOT directs the formulation of policies related to the development of trade in Indonesia. It is responsible for classifying food imports, specifying food import procedures and issuing import approval letter.
Kementerian Kelautan dan Perikanan (Ministry of Marine Affairs and Fisheries, MOMAF)	MOMAF develops, establishes, and executes maritime affairs and fisheries policies. Under MOMAF, Fisheries Quarantine and Quality Control Agency (BKIPM) continues to be the competent authority for quality and safety of fish and fishery products as well as the enquiry point for sanitary matters in Indonesia's fishery sector.
Badan Karantina Indonesia (Indonesian Quarantine Agency, IQA)	IQA is responsible for enforcing government duties in the field of animal, fish and plant quarantine.

3. Market access approval

3.1 Import recommendation letter (SRP)

Importers for import of fishery products should apply an import recommendation letter from MOMAF. Minister of Maritime Affairs and Fisheries Regulation No. 1 of 2021 on Recommendations for the Importation of Fishery Products and Live Fish Apart from Raw Materials and Industrial Auxiliary Materials stipulates MOMAF's procedures for recommendations for importing fishery products and live fishes other than as raw materials. The import recommendation letter is valid for 1 year. Importers can apply through the OSS system. While for fishery products as raw materials, please refer to Ministry of Industry Regulation No. 19 of 2018 on Procedures for Giving Import Recommendations for Fishery Commodities as Raw Materials and Industrial Auxiliary Materials.

3.2 Import permit (PI)

The importer of fish and fishery products must obtain MOT's import permit (PI) before importing. Before applying for PI, SRP shall be obtained first. Importers can apply the PI through the online system.

3.3 Product positive list

Minister of Maritime Affairs and Fisheries Regulation No. 1 of 2021 on Recommendations for the Importation of Fishery Products and Live Fish Apart from Raw Materials and Industrial Auxiliary Materials states the types of fish and seafood products that are eligible for export to Indonesia.

Besides, Minister of Maritime Affairs and Fisheries Regulation Number 19/PERMEN-KP/2020 on Prohibition of Importation, Cultivation, Circulation and Export of Dangerous and/or Harmful Fish Types into and From the Fisheries Management Areas of the Republic of Indonesia lists the types of harmful fish that are prohibited to be imported into Indonesia.

In addition, BPOM Decree No. 456 of 2023 on List of Drugs and Food whose Import into Indonesian Territory is Restricted stipulates the list of foods (including processed aquatic products) which are restricted for imports into Indonesia.

3.4 Product registration (PB-UMKU)

In Indonesia, all processed food in retail packaging, including processed aquatic products, must be registered with BPOM to obtain Business Licensing to Support Business Activities (PB-UMKU). For imported products, the manufacturer should appoint a local importer to undertake the registration. BPOM may conduct on-site inspections of overseas manufacturers if necessary. In principle, the PB-UMKU shall be valid for five years, and can be prolonged via registration extension. Importers can apply for product registration through the online system.

3.5 Import certificate (SKI)

To import processed aquatic products into Indonesian territory, importers shall obtain the SKI Post Border as Import Certificate either before or within seven days after the goods are released from the customs area. The SKI Post Border shall be applied for by importers with valid PB-UMKU from BPOM through the online system. Each SKI Post Border is valid for one import only.

3.6 Inspection & quarantine

Aquatic products are required to be inspected and quarantined as per Law No. 21 of 2019 on Animal, Fish and Plant Quarantine and its Implementing Regulations. Exporters must submit a Prior Notice to IQA before shipping aquatic products into Indonesia. The Prior Notice can be submitted via the online portal.

4. Product compliance

4.1 Product requirements

Key compliance requirements for aquatic products are outlined as follows:

Items	Requirements
Food characteristics	BPOM Regulation on 13 of 2023 on Food Category Two mandatory Indonesian National Standards (SNIs) for aquatic products, namely, SNI 8222:2022 - Sardines and mackerel in canned packaging and SNI 8223:2022 - Tuna in canned packaging
Maximum limits of veterinary drug residues	MOA Regulation No. 14/Permentan/Pk.350/5/2017 on the Classification of Animal Drugs SNI 9223:2023 Maximum Limits for Veterinary Drug Residues in Food of Animal Origin (Voluntary)
Maximum limits of heavy metals	BPOM No. 9 of 2022 on Heavy Metal Contaminants in Processed Food
Maximum limits of chemical contamination	BPOM Regulation No. 8 of 2018 on Maximum Limit of Chemical Contamination in Processed Food
Maximum limits of microbial contamination	BPOM Regulation No. 13 of 2019 on Maximum Limit of Microbial Contamination in Processed Food SNI 01-6366-2000 – Maximum Limits for Microbial Contamination and Maximum Residue Limits in Food Products of Animal Origin (Voluntary)
Maximum limits of radioactive contamination	MOH Regulation No. 1031 of 2011 on Maximum Limit of Radioactive Contamination in Food
Maximum limits of melamine	MOH Regulation No. 34 of 2012 on Maximum Limit of Melamine in Food

4.5 Label

The labeling of processed aquatic products shall meet the food labeling requirements stated in Government Regulation 69/1999 Foods Labels and Advertisements and BPOM Regulation No. 31 of 2018 on Processed Food Label and its amendments. For the nutritional labeling and claims for processed aquatic products, please refer to BPOM Regulation No. 26 of 2021 Information on Nutritional Values on Processed Food Labels and BPOM Regulation No.1 of 2022 on Processed Food Claims and Advertisements.

In addition, the packaging of processed aquatic products shall comply with BPOM Regulation No. 20 of 2019 on Food Packaging.

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