Decree of the Head of the Marine and Fishery Product Quality Control and Supervision Agency Number 20 of 2026 Strengthens Quality Testing Standards for Fishery Products

Introduction 

On 13 March 2026, the Head of the Marine and Fishery Product Quality Control and Supervision Agency (Badan Pengendalian dan Pengawasan Mutu Hasil Kelautan dan Perikanan, “BPPMHKP”) issued Decree of the Head of the Marine and Fishery Product Quality Control and Supervision Agency Number 20 of 2026 on the Designation of Reference Laboratories and Testing Laboratories to Support Official Control Testing of the Marine and Fishery Product Quality Assurance System (“BPPMHKP Decree 20/2026”). BPPMHKP Decree 20/2026 sets forth a list of government and private laboratories authorized to conduct fishery product quality testing in Indonesia to ensure procedural certainty in testing implementation, maintain the accuracy of test results through standardized laboratories, and enhance the national marine and fishery product quality and safety assurance system. 

BPPMHKP Decree 20/2026 was issued to implement Article 10 paragraph (1) of the Regulation of the Minister of Marine Affairs and Fisheries Number 8 of 2024 on the Implementation Control of the Marine and Fishery Product Quality and Safety Assurance System. Furthermore, the designation of reference laboratories and testing laboratories also supports laboratory quality management in controlling the quality and safety of marine and fishery products. Through this designation, the government ensures that testing under the Official Control scheme is conducted by accredited laboratories in accordance with the established testing parameters. 

Comparison 

BPPMHKP Decree 20/2026 repeals and replaces the Decree of the Head of the Marine and Fishery Product Quality Control and Supervision Agency Number 30 of 2025 on the Designation of Reference and Testing Laboratories to Support Official Control of the Marine and Fishery Product Quality Assurance System (“BPPMHKP Decree 30/2025”). The following is a comparison between BPPMHKP Decree 20/2026 and BPPMHKP Decree 30/2025: 

Key Provisions 

Mandatory Accreditation and Testing Legality 

The SECOND Dictum requires all Reference Laboratories and Testing Laboratories to possess SNI ISO/IEC 17025:2017 accreditation for each testing parameter conducted. Furthermore, the FIFTH Dictum stipulates that testing activities shall be conducted according to the testing parameters and testing method standards that have been accredited and agreed upon between the Competent Authority and the Testing Laboratory, including the methods set forth in the annexes to BPPMHKP Decree 20/2026. 

Duties of the National Reference Laboratory 

The THIRD Dictum designates the Reference Laboratory, namely the Standard Testing Center for Marine and Fishery Product Quality Control and Supervision (Balai Uji Standar Pengendalian dan Pengawasan Mutu Hasil Kelautan dan Perikanan), as the referral laboratory for marine and fishery product quality testing. In its implementation, the Reference Laboratory is tasked to: 

1. Develop testing methods through validation or verification; 

2. Provide quality assurance reference materials; 

3. Organize proficiency testing and interlaboratory comparisons for testing laboratories; 

4. Coordinate the resolution of testing result disputes; 

5. Maintain the competency of testing analysts; 

6. Implement product certification for the use of the Indonesian National Standard mark and marine and fishery product conformity marks; and 

7. Establish international cooperation for testing capacity development. 

Obligations of Testing Laboratories 

Testing Laboratories must fulfill several obligations in conducting marine and fishery product quality testing as set forth in the FOURTH Dictum, which include: 

1. Conducting verification of testing methods in their respective laboratories; 

2. Conducting testing according to the parameters set forth in the annexes; 

3. Submitting Test Result Reports (Laporan Hasil Uji, "LHU") of the tested samples; 

4. Implementing internal quality assurance through proficiency testing or internal quality control; 

5. Documenting testing reports to maintain data traceability; and 

6. Submitting annual performance reports to the Quality Management Center. 

Testing Laboratory Network Across Indonesia 

Annex II sets forth the list of Testing Laboratories within the Technical Implementation Units (Unit Pelaksana Teknis, “UPT”) of BPPMHKP distributed across various regions in Indonesia to support the implementation of marine and fishery product quality testing. The list includes: 

1. Sumatra: Medan, Padang, Palembang, Lampung, Jambi, Tanjung Pinang, Bengkulu, and Pangkal Pinang; 

2. Java: Jakarta, Serang, Bandung, Cirebon, Cilacap, Semarang, Yogyakarta, Surabaya, and Banyuwangi; 

3. Bali & Nusa Tenggara: Denpasar, Mataram, and Kupang; 

4. Kalimantan: Pontianak, Banjarmasin, Tarakan, and Balikpapan; 

5. Sulawesi: Manado, Gorontalo, Palu, Luwuk, Makassar, Mamuju, Kendari, and Bau-Bau; 

6. Maluku & Papua: Ambon, Ternate, Sorong, Manokwari, Biak, Jayapura, and Merauke. 

Ministry/Agency and Private Laboratories 

In addition to the Testing Laboratories within BPPMHKP UPTs, Annex II also sets forth laboratories from ministries/agencies, the private sector, and regional governments, which include: 

1. Ministries/Agencies: laboratories under the Food and Drug Supervisory Agency (BPOM) as well as other relevant ministries/agencies; 

2. Private Laboratories: Including PT Saraswanti Indo Genetech, PT Mutu Agung Lestari, and PT SGS Indonesia; 

3. Provincial Government Technical Implementation Units: including laboratories owned by regional governments such as DKI Jakarta and East Java. 

Commodity Coverage and Fishery Product Matrices 

Annexes I and II set forth various matrices of marine and fishery products subject to testing, which include: 

1. Fresh/Raw Products: Fresh fish, live/fresh shrimp, mollusks (shellfish), jellyfish, and echinoderms; 

2. Processed Products: Frozen fish, canned products (sardines/mackerel), fermented products (shrimp paste), dried products, and breaded products; 

3. By-Products: Fish meal, fish oil, as well as fish feed and aquatic animal feed. 

Microbiological and Pathogen Testing Parameters 

Annex II sets forth microbiological testing parameters to support the safety supervision of marine and fishery products against biological contamination. The tested parameters include: 

1. Total Plate Count (TPC); 

2. Escherichia coli and Coliforms; 

3. Salmonella sp.; 

4. Vibrio parahaemolyticus and Vibrio cholerae; 

5. Staphylococcus aureus; 

6. Listeria monocytogenes; and 

7. Enterobacteriaceae and Clostridium perfringens. 

Chemical Residue, Heavy Metal, and Contaminant Testing Parameters 

Annexes I and II set forth chemical testing parameters for the safety supervision of marine and fishery products, which include: 

1. Heavy Metals: Mercury (Hg), Lead (Pb), Cadmium (Cd), Arsenic (As), and Tin (Sn); 

2. Antibiotic Residues: Chloramphenicol, Nitrofurans (AOZ, AMOZ, AHD, SEM), Tetracyclines, Quinolones, and Sulfonamides; and 

3. Other Contaminants: Histamine (specifically for scombroid fish), formalin, carbon monoxide (CO), and pesticide residues. 

Physical, Sensory, and Organoleptic Characteristics Testing 

Annex II also sets forth physical, sensory, and organoleptic characteristics testing to assess the quality and condition of marine and fishery products. The testing includes: 

1. Organoleptic/sensory assessment (odor, taste, texture, appearance); 

2. Measurement of acidity degree (pH); 

3. Product core temperature; 

4. Turbidity level and total dissolved solids (TDS). 

Testing Standards for Environmental Media and Production Facilities 

Annexes I and II also set forth testing on environmental media and production facilities to support the quality and safety control of marine and fishery products, which include: 

1. Process Water: Water quality testing used in fish processing units; 

2. Ice: Testing of ice used as a cooling medium for fishery products; and 

3. Wastewater: Testing of fishery industry wastewater parameters according to the applicable environmental standards. 

Harmonization of National and International Testing Methods 

Annexes I and II set forth reference methods for each testing parameter to support the conformity and validity of test results. These methods include: 

1. Indonesian National Standard (SNI); 

2. International standards, such as ISO, AOAC, BAM (Bacteriological Analytical Manual), and FDA; and 

3. Laboratory internal Work Instructions (IK) that have undergone a validation or verification process by the Competent Authority. 

Annual Performance Verification and Evaluation Mechanism 

The Quality Management Center conducts periodic verification of laboratory performance reports as stipulated in the SIXTH Dictum. The verification is conducted through direct on-site inspection (on-site verification) or remotely (remote verification). The verification results are then outlined in a performance evaluation report used as the basis for the operational assessment of the laboratory by the Head of the Agency in accordance with the SEVENTH Dictum. 

Transitional Provisions 

Laboratories that have not met the standard requirements based on the annual evaluation results must take corrective follow-up actions according to the evaluation recommendations as set forth in the EIGHTH Dictum. Furthermore, the Competent Authority may deactivate testing parameters in laboratories that fail to make corrections according to the evaluation results based on the NINTH Dictum. With the enactment of BPPMHKP Decree 20/2026, all testing activities under the Official Control scheme refer to the established list of laboratories and testing parameters. 

Closing 

BPPMHKP Decree 20/2026 designates the Reference Laboratories and Testing Laboratories authorized to conduct testing under the Official Control scheme for the Marine and Fishery Product Quality and Safety Assurance System. Through BPPMHKP Decree 20/2026, the government requires every Reference Laboratory and Testing Laboratory to possess SNI ISO/IEC 17025:2017 accreditation according to the testing parameters conducted, and to implement testing based on accredited testing methods agreed upon with the Competent Authority. In addition to governing the duties of Reference Laboratories and the obligations of Testing Laboratories, Annexes I and II also set forth the list of government, ministry/agency, regional government, and private laboratories distributed across various regions in Indonesia along with their commodity coverage, product matrices, microbiological parameters, chemical residues, heavy metals, contaminants, physical and organoleptic testing, as well as the national and international reference methods used in testing. BPPMHKP Decree 20/2026 also governs the periodic verification and evaluation of laboratory performance by the Quality Management Center, including the obligation for corrective follow-up actions for laboratories that have not met the evaluation requirements. Furthermore, the Competent Authority may deactivate testing parameters in laboratories that fail to make corrections according to the evaluation results. Therefore, businesses need to ensure that the laboratories utilized are accredited and possess the testing parameters according to the established list so that the testing results can be used in the certification process and marine and fishery product trading activities.