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Indonesia Consults on Amending Microbial Contaminant Limits for Processed Foods

Indonesia BPOM has released a draft regulation to amend the maximum microbial contaminant limits for several processed food categories, including tea, powdered drinks, and certain meat and noodle products.

In early October 2025, the Indonesian food and drug authority (BPOM) published a draft regulation proposing changes to the BPOM Regulation No. 13 of 2019 on the Maximum Limits of Microbial Contaminants in Processed Food. BPOM is inviting public feedback on the draft, with a submission deadline of October 16, 2025. The proposed changes include adding new food sub-categories and revising microbiological criteria for existing ones.

1. Introduction of New Food Categories and Criteria

The draft regulation introduces specific microbiological criteria for two new types of processed foods by adding them to existing categories. This change provides clear compliance standards for products that were not explicitly covered before.

  • Ready-to-consume Flour/Starch Preparations: This new sub-category is added under Food Category 06.4.3 (Pre-cooked Pasta and Noodles and Analogues). It sets limits for pathogens such as Salmonella (negative/25g) and Staphylococcus aureus (m=10 cfu/g, M=10³ cfu/g).

  • Pasteurized Sausages and Meatballs: Added to Food Category 08.3.2 (Heat-treated Processed Comminuted Meat, Poultry, and Game), this sub-category establishes strict limits for key pathogens. Notably, the criteria require Salmonella and Listeria monocytogenes to be absent (negative/25g).

2. Revision of Microbiological Criteria for Beverages and Tea

The amendment also revises the microbiological limits for several existing food products to enhance safety standards.

  • Flavored Powdered Drinks: For products in Category 14.1.4.3 (Concentrates for Water-Based Flavored Drinks) that contain milk, creamer, or chocolate, the limits for Aerobic Plate Count (APC) and Mold and Yeast have been updated.

  • Tea Products: The criteria for various tea products under Category 14.1.5 (Coffee, Coffee Substitutes, Tea, Herbal Infusions, etc.) are revised. This includes Dried Tea, Powdered Tea, and Tea Bags (including black, green, white, oolong, and scented varieties). The limits for APC and Mold and Yeast have been adjusted.

3. Key Changes to Microbial Limits

The following table summarizes some of the key additions and revisions proposed in the draft regulation.

Food Category

Product Type

Key Microbial Parameter

Proposed Limits (m, M)

06.4.3 Pasta and Pre-Cooked Noodles

Ready-to-consume Flour/Starch Preparations (New)

APC

m=10⁴ cfu/g, M=105 cfu/g

Bacillus cereus

m=102 cfu/g, M=103 cfu/g

Salmonella

negative/25g

Staphylococcus aureus

m=10 cfu/g, M=103 cfu/g

Escherichia coli

m=3 APM/g

08.3.2 Heat-treated Processed Comminuted Meat

Pasteurized Sausages and Meatballs (New)

APC

m=10⁴ cfu/g, M=105 cfu/g

Enterobacteriaceae

m=10 cfu/g, M=102 cfu/g

Staphylococcus aureus

m=102 cfu/g, M=2×102 cfu/g

Salmonella

negative/25g

Listeria monocytogenes

negative/25g

14.1.4.3 Concentrates for Drinks

Flavored Powdered Drinks (with milk/creamer/chocolate) (Revised)

APC

m=5×102 cfu/g, M=5×103 cfu/g

Mold and Yeast

m=5x10 cfu/g, M=5x10² cfu/g

Salmonella

negative/25g

14.1.5 Coffee, Tea, Herbal Infusions

Dried Tea and Powdered Tea (including black, green, white, oolong, and scented varieties) (Revised)

APC

m=104 cfu/g, M=106 cfu/g

Mold and Yeast

m=10³ cfu/g, M=10⁴ cfu/g

Tea Bags (including black, green, white, oolong, and scented varieties) (Revised)

APC

m=104 cfu/g, M=106 cfu/g

Mold and Yeast

m=5x10³ cfu/g, M=5x10⁴ cfu/g

Note: 'm' is the threshold value for the number of bacteria; the result is considered satisfactory if all values are ≤ m. 'M' is the maximum value; values are considered unacceptable if one or more are > M.

Compliance and Implementation

The draft regulation will affect all businesses producing, importing, or distributing the specified food products in Indonesia. Once finalized and promulgated, the new regulation will officially amend BPOM Regulation No. 13 of 2019. The draft states that the regulation will become effective on the date of its enactment, though a formal transition period may be announced in the final version. Businesses are advised to monitor the final publication of this regulation.

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