Indonesia Regulates Claims on Processed Food Labels and Advertisements

On January 4, 2022, Indonesia Food and Drug Administration (BPOM) enacted Regulation of the Food and Drug Supervisory Agency Number 1 of 2022 concerning Supervision of Claims on Processed Food Labels and Advertisements. This regulation came into effect immediately after BPOM's announcement with a 30-month grace period.

General Principle 

In Indonesia, processed food can only bear claims once it complies with the basic features of its corresponding food category. Besides, processed food needs to meet the following daily consumption requirements to bear claims:

• No more than 18g of total fat;

• No more than 6g of saturated fat;

• No more than 60mg of cholesterol;

• No more than 300mg of sodium.

However, the above preconditions are not applicable to vegetarian claim, claims for processed food that needs to be further processed and added with other food ingredients, as well as claims regarding the fat, saturated fat, cholesterol, sodium and/or dietary fiber.

Permitted Claims 

The following claims are permitted for qualified products based on the considerations of the type, quantity and function of nutrients and non-nutrients, reasonable daily consumption of food, balanced nutrition consumption, public health status, suitability of food as a carrier of nutrients and non-nutrients, as well as the suitability of claims:

• Nutrition/non-nutrition claims

  a) Nutrient/non-nutrient claim

  b) Nutrient/non-nutrient comparative claim

  c) No sugar added claim

  d) No salt added claim

  e) Lactose claim

  f) Gluten claim

• Health claims

  a) Nutrient/non-nutrient functional claim

  b) Reduction of disease risk claim

  c) Blood glucose claim

• Isotonic claims

• Vegetarian claims

• Microorganism-related claims 

All the information on the above claims must be consistent with that on the labels when obtaining the distribution permit. The detailed definition, specification and testing method for each type of claim are provided in the annex of this regulation. Take sugar for example, to claim “low sugar”, the sugar content of the product must be no more than 5g per 100g of solid product or 2.5ml per 100ml of liquid product. While to claim “sugar-free”, the sugar content must be no more than 0.5g (ml) per 100g (ml) of product.

To use claims unspecified in this regulation or some permitted claims including claim of reducing of disease risk, blood glucose claim or microorganism-related claims, applicants need to apply on BPOM official website to obtain the written approval from the food standardization organization. 

Lab Test 

All permitted claims' authenticity and efficacy need to be proved via analysis result report issued by government labs or government-approved labs. For imported food, the report can be issued by either local labs that are approved by local government, or other local labs which have signed a mutual recognition agreement with authorized Indonesian organizations or labs.

Prohibited Claims 

As revealed by the regulation, the following claims are prohibited:

• Processed food's claims for infants

• Processed food's claims of reducing disease risk for children aged 1-3

• Claims that no nutrients/non-nutrients contained in the processed food that doesn't contain nutrients/non-nutrients naturally

• Claims that consumption of some processed food can satisfy the needs for all nutrients

• Claims that take advantage of consumer concerns

• Claims that mislead consumers to wrongly consume some processed food

• Processed food's claims that can prevent, cure or heal diseases

Grace Period 

For processed food which have already obtained a distribution permit before the implementation of this regulation, or processed food which is in the process of applying for a distribution permit, they shall comply with the new provisions within 30 months after the promulgation of this regulation.