Decree of the Head of BPJPH Number 307 of 2025 and Circular Letter of the Head of BPJPH Number 2 of 2026 Strengthen Regulatory Control over Halal Imports through HS Code Classification and SHLN Registration

Introduction

The Halal Product Assurance Organizing Agency (Badan Penyelenggara Jaminan Produk Halal, “BPJPH”) issued two instruments concerning imported products, namely the Decree of the Head of the Halal Product Assurance Organizing Agency Number 307 of 2025 on Harmonized System Codes for Types of Products Required to be Halal Certified in Food and Beverage, Food Additives, Cosmetics, and Natural Medicines ("Decree 307/2025") which was issued on November 20, 2025 , and the Circular Letter of the Head of the Halal Product Assurance Organizing Agency Number 2 of 2026 on the Mechanism for Determining Product Categories in the Registration of Foreign Halal Certificates for Products Not Yet Listed in the Provisions of Types of Products Required to be Halal Certified and Materials Exempted from the Halal Certification Obligation ("SE 2/2026") which was issued on February 20, 2026.

Decree 307/2025 stipulates the list of Harmonized System Codes (“HS Code”) for types of products required to be halal certified, while SE 2/2026 governs the mechanism for determining product categories in the registration of Foreign Halal Certificates (Sertifikat Halal Luar Negeri, “SHLN”) specifically for products not yet listed in the provisions for types of products required to be halal certified and materials exempted from the halal certification obligation. Both instruments serve as regulatory references for importers in fulfilling administrative obligations for products entering, circulating, and traded within Indonesia. These provisions are based on Law Number 33 of 2014 on Halal Product Assurance as last amended by Law Number 6 of 2023 and Government Regulation Number 42 of 2024 on the Implementation of the Halal Product Assurance Field. The diversity of product types, including those not yet listed as mandatory halal products or exempted materials, necessitates clear classification guidelines and a mechanism for determining product categories in the SHLN registration process.

Key Provisions

Determination of HS Code Classification

The FIRST Dictum of Decree 307/2025 stipulates the list of HS Codes for types of products required to be halal certified. The list covers four product groups, namely food and beverages, food additives, cosmetics, and natural medicines, as set forth in the annex of the decree.

The Function of the HS Code List for Importers

The HS Code list in Decree 307/2025 serves as a guideline for importers and/or official representatives of businesses in Indonesia as stipulated in the THIRD Dictum. The list is utilized for:

1. The execution of Foreign Halal Certificate registration applications;

2. The understanding of types of products required to be halal certified for food and beverages, food additives, cosmetics, and natural medicines entering, circulating, and being traded in the Indonesian territory; and

3. Halal certification applications to the Halal Product Assurance Organizing Agency or Foreign Halal Institutions.

Amendment and Addition of the HS Code List

Decree 307/2025 provides that unlisted or revised HS Codes may be added or amended by the Deputy for Halal Partnership and Standardization as stipulated in the SECOND Dictum. Such amendments or additions are conducted after coordinating with the Deputy for Halal Registration and Certification, relevant ministries/agencies, and experts, without the need to issue a new Decree of the Head of the Agency. In addition, the FIFTH Dictum stipulates that the Harmonized System Code list as referred to in the SECOND Dictum constitutes a valid and legally binding document.

Obligation to Publish HS Code List Amendments

Decree 307/2025 provides that any amendments or additions to the HS Code list must be published on media accessible to the public. This provision is set forth in the FOURTH Dictum, which requires the Deputy for Halal Partnership and Standardization to publish the Harmonized System Code list as referred to in the FIRST Dictum and SECOND Dictum on media that is easily and widely accessible.

Principle of Conformity in SHLN Registration Applications

Foreign Halal Certificate registration applications must conform to the details of types of products required to be halal certified as well as materials exempted from the halal certification obligation. This provision is stipulated in Point 5 letters a and b of SE 2/2026, which requires applications to be submitted based on the established product type classification.

Additional Requirements for Unlisted Products

If an imported product is not yet listed in the details of types of mandatory halal certified products or exempted materials, the applicant must submit supporting documents to BPJPH as stipulated in Point 5 letter c of SE 2/2026. This provision applies to importers and/or official representatives in Indonesia applying for SHLN registration. Point 5 letter d of SE 2/2026 provides that such supporting documents shall take the form of a statement letter from the manufacturer, importer, and/or official representative of the businesses in Indonesia detailing the product category, as well as the constituent ingredient composition and/or production process of the submitted product. Furthermore, the statement letter must also attach:

1. Material Safety Data Sheet (MSDS);

2. Certificate of Analysis (COA); and/or

3. Supporting documents for ingredient composition.
   

Closing

Decree 307/2025 and SE 2/2026 clarify the management of halal certification obligations for imported products by establishing the HS Code list as a reference for determining the types of products required to be halal certified and governing the mechanism for determining product categories in the registration of Foreign Halal Certificates. The HS Code list may be added to or amended according to the established mechanism, and every update is published to ensure accessibility for businesses. During the SHLN registration process, applicants must ensure that product classifications conform to the established product type details and submit supporting documents if the product is not yet listed. Such supporting documents are in the form of a statement letter explaining the product category, ingredient composition, and/or production process, and must attach a Material Safety Data Sheet (MSDS), Certificate of Analysis (COA), and/or supporting documents for ingredient composition. Accordingly, importers and/or official representatives in Indonesia must carefully align product classifications and prepare the necessary technical documentation to fulfill administrative requirements for products entering, circulating, and traded within Indonesia.