Food Compliance
Intelligence & Solutions
Indonesia Processed Food Labeling Regulation
Jan 11, 2021
Shea Wang
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CONTENTS

In Indonesia, processed food means food or beverage that is processed in a certain way or method with or without additives. Processed food label refers to any information regarding the processed food in the form of pictures, writing or a combination of both.

1. Competent Authority

In Indonesia, foods are supervised by the National Agency of Drug and Food Control, BPOM for short (Badan Pengawas Obat dan Makanan). BPOM examines food products before they enter the market of Indonesia and supervises the product quality after they enter the market, in order to ensure that the products are compliant and do not harm human health or local environment.[1]

2. Relevant Laws and Regulations

Law No.18/2012 on Food

Government Regulation No.69/1999 on Food Labels and Advertisement

BPOM Regulation No.31/2018 on Processed Food Label

BPOM Regulation No.22/2019 on Nutritional Value Information on Processed Food Labels

3. Label Requirements

Processed food labels can be placed in, affixed to, or constitute part of the food packaging. Anyone who produces processed food or imports processed food to Indonesia to be traded in retail packaging is required to include a label. The label must be easy to see and read, and shall not be easily separated from the food packaging, nor easy to fade or be damaged.

3.1 Format requirements

3.1.1 Language

The processed food label must be written or printed in Indonesian. For imported processed products, if the information has already been stated in Indonesian, foreign language can also be included. Technical or scientific terms with no equivalent in Indonesian can be stated in foreign terms.

3.1.2 Font

The writing on the label must be equal to or greater than the lowercase letter "o" in Arial font with a size of 1mm. Product name and warning terms on the label must be equal to or greater than the lowercase letter "o" in Arial font with a size of 2mm. When the label surface is smaller than or equal to 10 cm2, the writing must be stated in letter size of at least 0.75mm.

3.1.3 Background

Pictures, colors and other designs can be used as background as long as they do not obscure the writing.

3.2 Content requirements

The label for processed food must include the following information:

a. Product name;

b. List of ingredients used;

c. Net weight or net content;

d. Name and address of producer and importer;

e. Halal for those required;

f. Date and production code;

g. Expiry date, month and year;

h. Distribution license number for processed food; and

i. Origin of certain Food.

If the product is intended for business sale and to be processed as other food, the label must contain at least product name, net weight/net content, name and address of producer and importer, date and production code, and expiration information.

Processed food may include nutrition claim (nutritional content claim, comparative claim), health claim (nutritional function claim, other function claim, disease risk reduction claim) and other claims (isotonic claim, claim without added sugar, lactose claim and gluten claim) on the label.

3.2.1 Product name

The product name of processed food includes a food type name (compulsory) and a trade name (optional).

3.2.1.1 Type name

Food type must indicate specific characteristics of the processed food according to the Food Category. The Food Category can be found in BPOM Regulation No.34/2019 concerning Food Category. It includes 16 main categories such as dairy, fats and oil, fruits and vegetables, confectionery, etc.

Special conditions for food type on the label:

  • For products subject to SNI (Standard National Indonesia), food type on the label must be consistent with that of the SNI.

  • For alcoholic beverages that the type cannot be found in the Food Category, "MINUMAN BERALKOHOL GOLONGAN ...." (ALCOHOLIC BEVERAGES) must be labeled.

  • If the processed food type is not stipulated in the Food Category, the use of the type name should be approved in advance by the Head of BPOM.

3.2.1.2 Trade name

Trade name can be in the form of pictures, words, letters, numbers, color arrangements, or other forms that have distinctive power. It shall not use type name related to the processed food, words that directly or indirectly affect the interpretation of processed food, or words related to food safety, nutrition, or health aspects. The trade name should not be a public property or has a brand certificate of another person or business entity.

3.2.2 Ingredient list

The ingredient list must contain:

a. Raw material

b. Food additive

c. Auxiliary material

The ingredient list can be included following the terms "daftar bahan" (ingredient list), "bahan yang digunakan" (materials used), "bahan-bahan" (ingredients), or "komposisi" (composition).

3.2.2.1 Raw material

The complete name of raw materials should be labeled, abbreviation shall not be used. Raw materials should be arranged in the sequence that starts from the material of the highest content (excluding vitamins, minerals and food additives that are added into the processed foods).

Products with more than one ingredient should include the percentage of the main material, i.e. material with the highest amount or material that provides the identity of the product. Processed food products labeled with the terms "Dari...nama bahan" (From...name of material), "Dengan...nama bahan" (With...name of material), or the material image, should also state the percentage of the main material (excluding materials that also function as nutritional substances).

The added water must be included in the ingredient list, unless the water is part of an ingredient used. The added water which completely evaporates during processing is not compulsory to be included in the list.

3.2.2.2 Food additive

Food additives listed in the ingredient list include directly added food additives and carry-over additives.

The label should contain:

a. The food additive's group name (e.g. antioxidant, artificial sweetener, preservative, food color, enhancer, etc.);

b. The food additive's name;

c. The food additive registration number. [2] 

If the final product of processed food does not contain food additive, the claim of additive free can be stated on the label. Such claim is only permitted for artificial sweeteners, preservatives, synthetic dyes, antioxidants and flavor enhancer, and can be stated after the ingredient list.

Carryover food additive must be written after the name of ingredient that carries the food additive.

3.2.3 Net weight/net content

Solid processed food should state net weight using mg, g or kg. Liquid processed food should state net content using mL or L. Semi-solid or viscous food should state either net weight or net content.

3.2.4 Name and address of producer and importer

For domestic products, the producer's name, address (city, zip code, and Indonesia) should be labeled. The producer's address of imported processed food should include at least the city and country. Besides, for imported processed food, the importer's name and address (city, zip code, and Indonesia) should also be labeled, preceded by the words "Diimpor/didistribusikan oleh ..." (imported/distributed by...).

  • When the processed food is produced under commission, the name and address should be preceded by the words "Diproduksi oleh ... untuk ..." (produced by...for...), "Dikemas oleh ... untuk..." (packed by...for...).

  • When the processed food is produced under license, it should include the name and address preceded by the words "Diproduksi oleh ... dibawah lisensi: ..." (produced by...under license).

3.2.5 Halal information

Processed food which is packed in retail for trading in Indonesia are required to include halal information after obtaining a halal certificate. If there is mutual recognition on halal certifications between the country of origin and Indonesia, the halal of the origin country can be stated.

3.2.6 Production date and code

Production date and code are required on processed food label. The code can be stated in the form of batch number. The production date can be printed separately with the code, but must be accompanied by instructions on where to find the production code. The terms used can be:

"Kode Produksi, lihat bagian bawah kaleng" (Production code, see bottom of the can); or

"Kode produksi, lihat pada tutup botol" (Production code, see the bottle cap).

3.2.7 Expiration date

Expiration information shall be stated in date, month and year.

  • If the shelf life of the food is less than or equals to 3 months, the expiration information should include date, month and year.

  • When the shelf life of the food is longer than 3 months, date is optional, but month and year is mandatory.

The expiration information should be precede by the term "Baik digunakan sebelum" (Best before). It can be stated separately with the "best before" term, but instruction on where to find the expiration information should be included.

Drinks containing alcohol of at least 7%, breads and cakes with a shelf life of less than or equal to 24 hours, and vinegar can be exempted from the expiration information.

3.2.8 Distribution license number

The distribution license number should be stated on the label, with "BPOM RI MD" followed by the number for domestic products; and "BPOM RI ML" followed by the number for imported products.

3.2.9 Origin of certain food ingredients

Information about the origin of certain food ingredients includes:

A. Origin of animal-sourced or plant-sourced ingredients;

B. Food produced through a special process (including genetically engineered food and irradiated food).

Animal-sourced or plant-sourced ingredients should be labeled with the animal/plant type followed by the origin of the ingredient.  

Processed food containing ingredients derived from pork is obligatory to include a special sign with the words "MENGANDUNG BABI" (containing pork) and a picture of pig as follows.

containning pig.pngThe label of processed food products produced through shared facilities that intersect with pork-sourced ingredients must include specific words and a picture of pig as below. The meaning of the words is "in the manufacturing process, they touch or use facilities shared with pork-sourced ingredients".

.png

3.3 Other requirements

3.3.1 Nutritional Value Information

Information regarding nutritional or non-nutritional content must be stated on the label, in the form of Nutritional Value Information (Informasi Nilai Gizi, ING for short).

The ING should be in the form of a table, containing:

a. Serving measures;

b. Number of servings per package;

c. Type and amount of nutrient content; (Type of nutrient includes total energy, total fat, saturated fat, protein, total carbohydrates, sugar and salt (sodium)); 

d. Type and amount of non-nutritional substances;

e. AKG percentage (recommended nutritional adequacy rate); 

f. footnote.

Coffee powder, tea powder, tea bag, bottled drinking water, herbs, spices, seasonings and condiments are exempted from the ING. Besides, ING is prohibited on alcoholic drink labels.

An example of horizontal format nutritional value information table is as follows.

ING.png

3.3.2 Information about allergens

Information about allergens must be stated on labels of food containing allergens. Processed food using shared facilities which are used to produce food containing allergens is required to include information on allergens. Highly refined food can be exempted from the allergen information.

Allergens include cereals containing gluten, egg, aquatic products, peanut, soybean, milk (including lactose), nuts, and products with sulfite content of at least 10 mg/kg.

Allergen ingredients must be included in the ingredient list and printed in bold with a sentence "Mengandung alergen, lihat daftar bahan yang dicetak tebal" (contains allergens, see list of ingredients in bold print) on the label.

3.3.3 Alcohol drinks

Labels of alcoholic drinks must include warnings:

a. "MINUMAN BERALKOHOL"  (Alcoholic beverages)

b. "Mengandung Alkohol ± … % v/v"  (Contains alcohol ± … % v/v)

c. "DI BAWAH UMUR 21 TAHUN ATAU WANITA HAMIL DILARANG MINUM" (Under 21 years old or pregnant women are prohibited to drink).

3.3.4 Dairy 

Dairy products, including milk powder, UHT milk, pasteurized milk and sterile milk, should include the box with writings on the label as shown below. The words means “Pay attention! Cannot replace breast milk. Not suitable for infants up to 12 months old. ”

warning.pngExcept for the warning information above, on the label of condensed milk and its analogues, a sentence meaning “Cannot be used as the only source of nutrition” must be included, as in the picture below.

warnign.png