Indonesia
Indonesia’s Law 33/2014 on Halal Product Assurance and its associated regulations (the Halal Law) is being phased in over a 15-year period. Compliance will become mandatory for the first tranche of products on 17 October 2024. This will affect Australian businesses exporting food and beverage products to Indonesia.
The Halal Law mandates new halal certification requirements for products seeking to enter the Indonesian market. It also greatly expands the range of products and export services for which it will be necessary to have halal certification. Australian exporters will need to meet these requirements to maintain or gain access to the Indonesian market.
The changes mean a much broader range of Australian businesses will need to prepare to meet mandatory halal requirements if they wish to export their products to Indonesia. Those exporters accustomed to complying with Indonesia’s previous halal certification regime will need to make changes to their current halal certification practices to ensure they remain compliant.
The Australian Government is working closely with Indonesia to ensure Australian exporters have the information they need to comply with the Halal Law. This page will be updated as more information becomes available.
Industry webinar
The Department of Foreign Affairs and Trade (DFAT), with the support of the Department of Agriculture, Fisheries and Forestry (DAFF), Austrade, and the Department of Industry, Science and Resources (DISR), has been hosting webinars to provide industry with briefing on Indonesia’s new import requirements for halal and non-halal products. The recording of the latest webinar, held Friday 6 September, is below. Recordings of past webinars can be found at the end of this webpage.
Key requirements under Indonesia’s Halal Law
The Halal Law establishes a new implementing authority for Indonesia’s halal certification regime, the Halal Product Assurance Organizing Agency (Badan Penanggulangan Jaminan Produk Halal or BPJPH). BPJPH takes over the halal certification functions previously managed by the Indonesian Ulema Council (MUI).
The Halal Law expands the scope of goods for which mandatory halal certification is required, including beyond goods that have traditionally been required to be halal certified. It also extends the requirement to include export services such as slaughtering, processing, storage, packaging, transport, marketing and presentation.
Under the Halal Law, exporters will need to:
- Arrange halal certification of products prior to export either directly through BPJPH or through an Australian Halal Certification Body (HCB) approved by BPJPH for the scope of products exported;
- Meet a requirement to completely segregate halal products from non-halal products during production, processing, storage and transportation (i.e. dedicated halal supply chains);
- Comply with new labelling requirements for halal and non-halal products;
- Ensure their Indonesian importers have registered their HCB-issued halal certificate on BPJPH’s online portal, SiHalal.
Scope of products and timeframes for implementation
Meeting the requirements of the Halal Law will become mandatory at different times for different products. Exporters are welcome to begin voluntarily adhering to the new halal certification requirements ahead of the mandatory implementation date although this is not strictly necessary. The phased implementation period for the Halal Law is summarised in the table below.
| Date for mandatory compliance | Products |
|---|---|
| 17 October 2024 | Food and beverage products, including raw ingredients, food additives and supplementary materials for food and beverage |
| 17 October 2026 |
|
| 17 October 2029 |
|
| 17 October 2034 |
|
| 17 October 2039 | Class D medical devices |
The Australian Government continues to seek further information from Indonesia on the scope and definitions for some of these product groups. Information currently available is outlined below. More information will be added as it becomes available.
Food and beverage products
Halal certification will be mandatory for all food and beverage products, including processed food and beverage products. There are limited exemptions. Exemptions include ‘haram’ (forbidden by Islamic law) products, such as pork and alcohol, and products that appear on the ‘Halal Positive List’. The ‘Halal Positive List’ comprises mostly raw materials which are considered inherently halal, including:
- Materials derived from nature without any further processing or additives, including materials from plants, non-slaughtered animals, materials derived from the microbial fermentation process, and natural water;
- Materials which are no risk of containing and/or being contaminated by non-halal substances;
- Non-dangerous chemicals that do not contain haram substances, including chemicals sourced from mining activities and/or purification processes of natural materials, as well as inorganic and organic synthesized chemicals.
Indonesian Minister of Religious Affairs Regulation 816/2024 provides a full list of food and beverage products (in Indonesian) that are required to undertake halal certification by HS code.
To find out if your food and beverage products are covered by Indonesia’s halal requirements, check to see if they are included in this list [XLSX 30 KB]. The English translation of each HS code description in the Indonesian Custom Tariff Book (BTKI) can be accessed from the Indonesian Directorate General of Customs website.
Medical devices
Halal certification will only be required for medical devices originating from animals and/or containing animal elements.
Biological and chemical products
Biological products that must obtain a halal certification include enzymes, monoclonal antibodies, hormones, stem cells, gene therapy, vaccines, blood products, recombinant DNA products, and immunosera.
Non-halal products
Non-halal products are still allowed to enter Indonesia. They must include non-halal labels or descriptions which can be in the form of pictures, signs and/or words included on packaging or the product itself. These labels or descriptions must be easy to see and not easy to remove or damage. Non-halal ingredients must be printed in different colours to be easily identifiable.
Options for certification of products
Several Australian HCBs have been accredited by BPJPH. Meaning they are approved by BPJPH to issue halal certificates in relation to a specified scope of products and services. These certificates will be recognised by the Indonesian system for the products and services within scope of the HCB's accreditation.
A table of currently approved HCBs and the scope of their approval is below. The terms of HCBs’ approval do not limit their operation to within their own state or territory. Businesses can approach any approved Australian HCB regardless of location.
The Australian Government is currently working with Indonesia to encourage auditing of additional Australian HCBs who have already applied to BPJPH for recognition, including in other states and territories. This table will be updated as further information becomes available.
| Halal Certification Body (HCB) name | HCB location | Scope of commodities approved to issue certification for |
|---|---|---|
| Australian Halal Authority and Advisers Pty. Ltd. | Melbourne |
|
| Australian Halal Development and Accreditation (AHDAA) | Brisbane |
|
| Global Australian Halal Certification | Sydney |
|
| GLOBAL HALAL TRADE CENTRE PTY LTD (GHTC) | Brisbane |
|
| Islamic Co-ordinating Council of Victoria | Melbourne |
|
| National Halal Accreditation Services Australia Pty. Ltd. | Melbourne |
|
| National Halal Authority | Melbourne |
|
| SUPREME ISLAMIC COUNCIL OF HALAL MEAT IN AUSTRALIA INC | Sydney |
|
The information in the table above is based on information provided through the BPJPH website, as of 8 August 2024. The Australian Government is seeking further clarification on the scope of some of the terms used for commodities, which may not align with terms used elsewhere.
Exporters also have the option of approaching BPJPH directly to certify their products. The advantage of this approach, as we currently understand it, is that certification issued by BPJPH will not have an expiry date so will not require renewal as long as the product ingredients and production processes remain the same. However, exporters will need to cover the costs of Indonesian halal auditors’ travel to Australia to conduct a physical certification audit, including flights, on-ground transport, accommodation and per diems. The timing of the audit visit will also depend on the availability of Indonesian auditors, which may be limited.
Registering your product with BPJPH's online portal
To obtain a registration number and BPJPH halal certification label for their products, Australian exporters will need to ensure their Australian HCB halal certificate has been registered on BPJPH's online portal, SiHalal. This registration is done by Indonesian importers or an official representative in Indonesia, not Australian exporters.
BPJPH will issue one registration number for each halal certificate registered by an importer. This registration number may cover multiple consignments of goods, as long as they are of the same product type (e.g. "meat products and meat processed products" or "milk and its analogues") as set out by Indonesian Minister of Religious Affairs Decree 748/2021 and they share the same halal certificate. This registration number is unique to each importer, even if multiple importers register the same product using the same Australian HCB halal certificate from the same Australian exporter.
As of August 2024, the fee for registering foreign halal certificates on the SiHalal portal is IDR 800,000 (approximately AUD 80) per certificate.
Frequently Asked Questions
Is my product covered by these regulations?
A detailed list of products covered by Indonesia's halal law is set out in the Indonesian Minister of Religious Affairs Decree 748/2021 on the Types of Products that are Obliged to be Halal Certified. An unofficial English translation of this decree is available from the United States Department of Agriculture website [PDF].
Has Indonesia delayed the implementation of mandatory halal certification?
There has been no extension to the date of implementation of mandatory compliance for Australian exporters.
In May 2024, the Indonesian government announced a two-year extension for mandatory food and beverage certification until October 2026 for Indonesian micro and small enterprises. Indonesia has yet to issue the implementing regulation for this delay but has indicated the delay will apply to Indonesian companies only. For all other companies, including all foreign producers/exporters, there has been no extension to the date of implementation for mandatory certification.
My importer is asking me to provide them with a "legalised" version of my halal certificate so it can be registered on BPJPH's SiHalal portal. What is this requirement?
Currently, BPJPH requires all importers to upload a copy of their halal certificate that has been "legalised" either by via an Apostille from DFAT or a formal legalisation by an official from an Indonesian Embassy or Consulate. The Australian Government continues raise with Indonesian authorities our concerns about this requirement and is seeking further clarification on how Australian businesses can practically comply.
An Apostille is a way that DFAT certifies that an official Australian public document is genuine for use by a foreign government. Because Australian HCBs are private institutions, not government agencies, halal certificates issued by these bodies are not classified as official public documents. This means that DFAT is unable to issue an Apostille on these documents directly. An Apostille can be applied only to a halal certificate that has been first notarised by an Australian Notary Public. The Government is seeking clarification from BPJPH as to whether halal certificates that have been legalised in this way would be acceptable under Indonesia's regulations.
Further information on how to obtain an Apostille is available on the Smartraveller website.
When will further Australian Halal Certifying Bodies be accredited by BPJPH?
As of August 2024, eight Australian HCBs have been approved by BPJPH. Two further HCBs have completed their onsite audit by BPJPH inspectors and are awaiting final approval by BPJPH. A further eight HCBs are awaiting their BPJPH audit to be scheduled.
DFAT will continue to update this website as BPJPH approves further HCBs.
What are Indonesia's labelling requirements for halal-certified products?
We understand that the Indonesian halal label should be prominently displayed and should include BPJPH's official halal logo and the registration number of the foreign halal certificate obtained from BPJPH. Goods may also display the logo of the HCB that provided halal certification alongside the BPJPH logo and certificate number. Inclusion of the HCB logo on the label is optional. Examples are shown below:
A digital copy of the BPJPH label (including an associated halal certificate number for each importer) can be downloaded on BPJPH's SiHalal portal, using the Indonesian importer's account.
BPJPH has announced that there will be a transition period for mandatory labelling for certain products until 2 February 2026, including those products already in market by 17 October 2024. DFAT is seeking further clarification from BPJPH on which products this transition will apply to, and how Indonesia's labelling requirements will be applied in practice.
We are also seeking confirmation from BPJPH whether using a sticker to display the relevant logos and certificate numbers will satisfy Indonesia's labelling requirements, as well as whether labels need to be applied as a port-of-entry/customs requirement or point-of-sale requirement.
We will continue to update this website as further information becomes available.
Does Indonesia require Australian exporters to employ a "Halal Supervisor" who is of the Muslim faith?
Under Indonesian Government Regulation 39/2021 on the Implementation of the Halal Law, companies seeking to have their products halal certified in Indonesia are required to have a "Halal Supervisor" who observes and coordinates halal processes within their business. Currently, this regulation requires the Halal Supervisor to be of the Muslim faith.
DFAT continues to raise concerns with Indonesia about this requirement, particularly for businesses that do not engage in animal slaughter. We will continue to update this web page as we receive further information on this requirement from the Indonesian government.
What are the requirements for separating halal and non-halal products in the production process and supply chain?
Halal and non-halal products must be kept separate at all point of the supply chain, from production to storage, freight and distribution. This includes any tools or machinery used in the production process.
Resources and contact details
For general questions relating to implementation of the Halal Law please contact ntb@dfat.gov.au.
For specific questions relating to the export of food and agricultural products to Indonesia in line with the Halal Law, please contact the Department of Agriculture, Fisheries and Forestry via exportstandards@aff.gov.au.
Previous industry webinars
Webinar with Indonesia’s Halal Product Assurance Organizing Agency (BPJPH) on 25 July 2024.
Transcript: BPJPH Industry Webinar [DOCX 55 KB]
Australian Government Industry Webinar on 20 March 2024.