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Indonesia BPOM Releases New Circular on Nitrous Oxide (N2O) as a Food Additive

The circular regulates the entire N2O supply chain for processed foods, including production, importation, registration, distribution, packaging, labeling, reporting, and facility requirements.

On February 27, 2026, Indonesia BPOM issued Circular Letter No. 2 of 2026 on Provisions for the Production, Importation, Registration, and Circulation of the Food Additive Dinitrogen Monoxide (N2O). This new regulation outlines a comprehensive framework for controlling the use of N2O as a food additive. The circular came into effect on the date of its issuance.

The directive was issued in response to surveillance findings that identified a growing trend of N2O misuse, wherein individuals inhale the substance directly to achieve euphoric effects. BPOM emphasized that utilizing N2contrary to its intended function as a food additive can result in severe health consequences, including death.

1. Scope of the Regulation

The circular specifically targets dinitrogen monoxide (N2O) when it is produced, imported, or circulated for its intended use as a food additive in processed food products. It aims to ensure the safety and quality of N2O throughout its lifecycle, from manufacturing to its application in the final food product.

2. Key Regulatory Areas Covered

As indicated by its title, the circular provides specific provisions for several key areas of the supply chain:

  • Mandatory Distribution Permits: Any N2O preparation produced domestically or imported into Indonesia is legally required to possess a valid distribution permit.

  • Strict Packaging Limits: The production and importation of N2O are restricted exclusively to primary packaging with a maximum net weight of 10 grams per individual unit.

  • Facility Certification Requirements: Manufacturers of N2O, which includes repackers, must secure an Implementation Permit for Good Processed Food Production Methods (IP-CPPOB).Importers distributing the substance are required to hold a Processed Food Safety Management System (SMKPO) certificate for their distribution facilities.

  • Comprehensive Labeling: Whether sold individually or in secondary packaging (multipacks), products must prominently display specific information, including: the product name and net weight or volume; the name and address of the manufacturing or importing entity; the production date, production code, and expiration date; the specific text "BTP", the food additive classification and type, and the maximum allowable usage limits in processed foods.

  • Mandatory Consumer Education: Business entities are obligated to actively inform and educate consumers that N2O is strictly designated for the processing and/or presentation of food.

  • Bi-Annual Compliance Reporting: All producers, distributors, and importers must submit comprehensive reports detailing their production, importation, and distribution activities every six months. These reports must be directed to the Head of BPOM, specifically to the Deputy for Processed Food Supervision.

3. Affected Parties and Compliance

The provisions outlined in this circular directly affect a range of business operators. This includes domestic producers of N2O, importers, distributors, and food manufacturers who use N2O as an additive in their processed food products. All involved parties are now required to comply with the stipulations set forth in this new legal instrument.

For expert assistance with food additive registration and regulatory compliance in Indonesia, please contact ChemLinked.

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