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Updated: On April 22, 2022, BPOM unveiled the official version of Regulation on Requirements for Heavy Metal Contaminants in Processed Food with a 12-month transitional period. At the same time, BPOM No. 5 of 2018 regulation on the maximum level of heavy metal contaminants in processed food was repealed.
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As revealed by the WTO notification G/SPS/N/IDN/142 on February 3, 2022, Indonesia Food and Drug Administration (BPOM) announced to solicit comments from WTO members for Draft Regulation on Heavy Metals Contaminants Requirements in Processed Food until April 4, 2022. Once the amendment passes review, the current regulation (Indonesia Food and Drug Administration No. 5 regulation on the maximum level of heavy metal contaminants in processed food in 2018) will be replaced and repealed.
Major Content
The amendment refers to the Codex standard CODEX STAN 193-1995 General Standard for Contaminants and Toxins in Food and Feed, covering the maximum limit of 5 heavy metals(namely, arsenic, cadmium, mercury, lead and tin) in 50 food categories, such as dairy products, processed vegetable and fruit products, condiments, and infant formula.
Major Revision
Compared with the current provisions, the highlight of the amendment mainly lies in the further division of existing food categories regarding the maximum limit of contaminant, from 36 to 50 food categories. For example, for the limit with regard to chocolate, currently it is covered by the provisions for confectionary and chocolate, while the drafted amendment sets up five different limits for chocolate with different percentages of cocoa solids.
The Current Provision for Chocolate | ||||
Food category | Arsenic (mg/kg) | Cadmium (mg/kg) | Mercury (mg/kg) | Lead (mg/kg) |
Confectionary and chocolate | 1.0 | 1.0 | 0.05 (except cocoa powder, 0.03) | 0.50 (except cocoa powder, 0.85) |
The Drafted Provision for Chocolate | ||||
Food category | Arsenic (mg/kg) | Cadmium (mg/kg) | Mercury (mg/kg) | Lead (mg/kg) |
Chocolate products (total cocoa solids < 30%) (by dry weight) | 1.0 | 1.0 | 0.05 | 0.30 |
Chocolate products (30% ≤ total cocoa solids < 50%) (by dry weight) | 1.0 | 1.0 | 0.05 | 0.70 |
Chocolate products (50% ≤ total cocoa solids < 70%) (by dry weight) | 1.0 | 1.0 | 0.05 | 0.80 |
Chocolate products (total cocoa solids ≥ 70%) (by dry weight) | 1.0 | 1.0 | 0.05 | 0.90 |
Cocoa mass & cocoa powder (to be processed as chocolate products) | 1.0 | 1.0 | 0.03 | 1.0 |
In addition to adding more specific food categories, there are also some revisions to the current limit for certain food categories, such as processed fish products.
The Current Provision for Processed Fish Products | ||||
Food category | Arsenic (mg/kg) | Cadmium (mg/kg) | Mercury (mg/kg) | Lead (mg/kg) |
Fish and fishery products including molluscs, crustaceans, and echinoderms as well as amphibians and reptiles | 0.25 | 0.20 (except processed predatory fish such as shark, tuna and marlin, 0.40) | 0.50 (except processed predatory fish such as shark, tuna and marlin, 1.0) | 0.10 (except processed predatory fish such as shark, tuna and marlin, 0.30) |
The Drafted Provision for Processed Fish Products | ||||
Food category | Arsenic (mg/kg) | Cadmium (mg/kg) | Mercury (mg/kg) | Lead (mg/kg) |
Processed fish products | 2.0 | 0.30 (except processed fish belonging to cephalopods or shellfish,1.0) | 0.50 (except processed predatory fish such as shark, tuna and marlin, 1.0) | 0.30 (except processed fish which are included in cephalopods or shellfish, 1.0) |
Testing Report
It is required to provide test reports by accredited labs to demonstrate the compliance with the maximum limit of heavy metal contaminants in processed products. For imported food, the test report can be issued by local labs which have signed a mutual recognition agreement with authorized Indonesian organizations or labs.
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, the product shall comply with the new provisions within 12 months after the official promulgation of this regulation.
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