Beware of Mislabeling! Nutri-Level Obligations under BPOM Regulation Number 10 of 2026

Introduction

On 9 June 2026, the Food and Drug Supervisory Agency (“BPOM”) issued Food and Drug Supervisory Agency Regulation Number 10 of 2026 on Nutrition Facts Information on Processed Food Labels (“BPOM Regulation 10/2026”), which took effect on 17 June 2026. This regulation provides more accurate information to the public so that consumers may select processed foods that meet their nutritional needs through the standardization of nutrition facts information displayed on packaging labels.

BPOM Regulation 10/2026 updates the previous provisions in line with developments in science and technology within the food sector. BPOM considers that supervisory instruments relating to nutrition labeling, nutritional labeling references, and obligations for Micro and Small Enterprises require refinement to ensure consumer protection and to create legal certainty that is more relevant and effective for processed food industry business.

Comparison

BPOM Regulation 10/2026 revokes and replaces Food and Drug Supervisory Agency Regulation Number 26 of 2021 on Nutrition Facts Information on Processed Food Labels (“BPOM Regulation 26/2021”), Food and Drug Supervisory Agency Regulation Number 16 of 2020 on the Inclusion of Nutrition Facts Information for Processed Foods Produced by Micro and Small Enterprises (“BPOM Regulation 16/2020”), and Head of the Food and Drug Supervisory Agency Regulation Number 9 of 2016 on Nutritional Labeling References (“BPOM Head Regulation 9/2016”). 

The following table compares BPOM Regulation 10/2026 and BPOM Regulation 26/2021:

Key Provisions

Obligation to Include Nutrition Facts Information (NFI)

Pursuant to Article 2, every business that produces and/or distributes Processed Food is required to include Nutrition Facts Information (“NFI”) on the packaging label. Such information must be presented in a standardized table format containing serving size, number of servings, details of the type and amount of nutrients and non-nutrient substances, the percentage of Recommended Dietary Allowance (“RDA”), and accompanying footnotes. Nevertheless, Article 3 specifies a list of exemptions for certain products that are not subject to this obligation, including bottled drinking water, ground coffee, dried tea, vinegar, spices, and yeast. On the other hand, Article 4 prohibits the inclusion of NFI on labels of any type of alcoholic beverage.

Nutri-Level Rating System

Article 27 requires the inclusion of a “Nutri-Level” label on the front of packaging for Processed Foods in the form of ready-to-drink beverages, powdered beverages, and concentrates (liquid/solid). Under Article 29, this indicator system reflects a food quality rating based on the cumulative content of sugar, salt (sodium), and total fat. The ratings consist of four categories:

1. Level A: the letter A combined with a dark green color.
2. Level B: the letter B combined with a light green color.
3. Level C: the letter C combined with a yellow color.
4. Level D: the letter D combined with a red color.

Laboratory Testing Obligations and Relaxation for Micro Enterprises

Under Article 6, the figures stated in the NFI table must be substantiated through testing results issued by a government laboratory or another accredited laboratory. To facilitate the distribution of imported Processed Foods, certificates of analysis may be issued by an authorized laboratory in the country of origin. To support ease of doing business, Article 7 provides a special provision for Micro Enterprises: where laboratory analysis results are not yet available and BPOM references have not yet been issued, Micro Enterprise business may include NFI based on theoretical calculations derived from the constituent food ingredients.

Serving Size and Label Format

Article 8 requires that the NFI table be measured and presented per one (1) Serving Size, the amount of which must be fulfilled by a single complete package. Based on the guidelines in Annex I, the method of presentation is regulated in detail, including the obligation to round energy, sodium, and cholesterol values to the nearest whole-unit increment (without decimals). These provisions facilitate the use of both vertical and horizontal (linear or tabular) label formats, which may be flexibly adjusted according to the total surface area of the relevant product packaging.

Transitional Provisions

Article 31 stipulates that all Processed Foods that obtained business licensing prior to 17 June 2026 are granted a transition period to make the necessary adjustments. Businesses must ensure that their product labels comply with BPOM Regulation 10/2026 no later than 17 June 2028. This transitional policy also fully applies to products that are still undergoing the licensing application process. Furthermore, the obligation to implement the “Nutri-Level” rating indicator for beverage products will only take effect after 17 June 2028.

Closing

BPOM Regulation 10/2026 strengthens the obligation of nutritional information transparency through the implementation of the visual “Nutri-Level” rating system. The regulation requires manufacturers of ready-to-drink beverages, powdered beverages, and concentrated beverages to clearly display information regarding sugar, salt, and fat content on the front of product packaging. Given the transition period until 17 June 2028, businesses may promptly undertake the necessary adjustments, including evaluating product compositions, conducting the required laboratory testing, and revising packaging designs and labeling information. Such measures are essential to ensure compliance with the applicable regulations, avoid administrative sanctions, and maintain the continued distribution of products in the market.