Indonesia Unveils New Regulation on Processed Food Registration

On September 11, 2023, Indonesia Food and Drug Administration (BPOM) released BPOM Regulation No. 23 of 2023 on Processed Food Registration, which is constituted of 14 chapters and 7 appendixes, specifying the registration requirements for all processed food products for retail in Indonesia. The new regulation came into force immediately after its promulgation, repealing BPOM Regulation No. 27 of 2017 Processed Food Registration and its Amendment altogether.

General requirements 

• All locally-produced and imported processed foods for retail, including food additives, are required to register with BPOM to obtain the circulation permit (PB-UMKU) before circulating in the Indonesian market. Meanwhile, they must meet related food safety standards, GMPs and other requirements in Indonesia.

• Nine kinds of processed foods are exempted from registration, such as those with less than seven days of shelf life, and those used for further processing.

• The term of validity of PB-UMKU is five years, which can be prolonged via registration renewal. It is forbidden to produce or sell processed food with expired PB-UMKU.

Processed food registration  

• The registrations of processed food include three types, namely, new registration, registration alternation and registration renewal. All registrations shall be finished via the registration system on BPOM website, which requires registrants to apply for an account first. The required documents for account application are listed in Appendix 1.

• For locally-produced products, the registrants shall be local manufacturers. For imported products, the registrants shall be the importers designated by foreign manufacturers. Besides, the foreign manufacturers must meet Good Processed Food Production Methods (CPPOB) in Indonesia.

• For new registrations, the requirements depend on different risk grades of processed foods. In Indonesia, the risk of processed foods can be divided into three grades, low, medium and high. The grading basis consists of many factors, such as targeted consumers, processing technologies, claims, etc. The determination process of processed foods’ risk grades is stipulated in Appendix 3. Notably, for the same products produced by different factories under one enterprise in Indonesia, they shall obtain the same PB-UMKU number. For required documents for new registrations, please refer to Appendix 4.

• Registration alternations are required when minor changes are made to the account and/or to the processed food products. For required documents for registration alternations, please refer to Appendix 6.

• Registration renewals can be only done for the same products which have obtained registration approvals previously and are without any changes. The time point of the renewal should be 6 months at the earliest and 10 calendar days at the latest before the expiry of PB-UMKU. For required documents for registration renewals, please refer to Appendix 7.

Transitional provisions  

• For registration applications submitted before the promulgation of the new regulation, they will continue to be reviewed as per BPOM Regulation No. 27 of 2017 Processed Food Registration and its amendment.

• For PB-UMKUs issued prior to the new regulation, they will remain valid until their respective expiration dates. However, if registrants submit new registration applications in accordance with the new regulation, in which the same food data as the previously issued PB-UMKUs is provided, the foods with the latest approved data may circulate for a maximum of 24 months after the expiration of the existing PB-UMKUs.

• For food products that have obtained the latest approvals for registration alternations, they may circulate for a maximum of 12 months after the expiration of the existing PB-UMKUs, as long as it does not conflict with related laws and regulations on processed food.

• For food products still in the process of registration renewals and already obtained the approvals for renewals, they may circulate for a maximum of 12 months after the expiration of the existing PB-UMKUs, as long as it does not conflict with related laws and regulations on processed food.

For the English translation of this regulation, please feel free to contact us via [email protected].