Introduction

On November 11, the Deputy for Fish Quarantine of the Indonesian Quarantine Agency issued Decree of the Deputy for Fish Quarantine of the Indonesian Quarantine Agency Number 8 of 2025 on Food Safety and Quality Requirements for Fish Products and Feed Safety and Quality Requirements for Fish Feed Entered into or Released from the Territory of the Unitary State of the Republic of Indonesia (“Decree 8/2025”), which took effect on its date of stipulation. The primary objective of this decree is to establish clear reference standards for testing and maximum allowable limits for fishery and fish feed commodities in export and import activities.

Background

The issuance of Decree 8/2025 is based on the urgency to guarantee the safety and quality of fishery commodities crossing national borders. According to its preamble, this decision stems from the need to ensure that every fish product and fish feed entering or leaving Indonesian territory complies with statutory regulations regarding food safety and quality standards. This is intended to prevent negative impacts on human health and environmental sustainability. Furthermore, Decree 8/2025 serves as an operational technical derivative supporting the implementation of Government Regulation Number 29 of 2023 on the Quarantine of Animals, Fish, and Plants, and Presidential Regulation Number 45 of 2023 on the Indonesian Quarantine Agency, to provide certainty regarding test parameters for Fish Quarantine Officers in the field.

Key Provisions

Third Dictum: Flexibility of Export Requirements

This section regulates strategic provisions for export business actors. The decree stipulates that the maximum limits for food safety and quality for fish products, as well as safety and quality for feed to be released (exported) from the Indonesian territory, may be aligned with the requirements of the destination country. This provision provides legal flexibility to ensure that Indonesian products are not restricted by domestic standards if the buying country has different standards, provided that the requirements of the destination country are met.

Annex A: Fresh Fish Product Standards

This section establishes test parameters for commodities such as Fresh Fish, Fresh Shrimp, and Fresh Tuna Loin. The focus of testing includes:

1. Sensory: Minimum score of 7.0 (scale 1-9) in accordance with the Indonesian National Standard (SNI).

2. Microbial Contamination: Establishment of limits for Total Plate Count (ALT), Escherichia coli, and Salmonella. Specifically for fresh shrimp, the parameters Vibrio cholerae and Vibrio parahaemolyticus are added.

3. Chemical & Heavy Metal Contamination: Regulation of maximum limits for Mercury (Hg), Lead (Pb), Cadmium (Cd), and Arsenic (As). Specifically for shrimp, there is a strict prohibition (none) on antibiotic residues of Chloramphenicol and Nitrofuran Metabolites, as well as a maximum limit for Tetracycline.

4. Histamine: For certain fish species (such as Tuna/Scombroid), histamine levels are limited to a maximum of 100 mg/kg.

Annex B: Frozen Fish Product Standards

Regulates parameters for Frozen Fish, Frozen Shrimp, Frozen Lobster, Frozen Cephalopods (Squid/Octopus), Frozen Scallop, and Frozen Tuna Loin. Key provisions include:

1. Physical: The product core temperature must reach a maximum of -18°C.

2. Parasites: The number of permitted parasites is limited to a maximum of 1 per kg for general frozen fish, however, Frozen Tuna Loin requires 0 parasites. Parasites are not required for frozen fish used as raw materials for the canning/boiling industry.

3. Chemical: The Total Volatile Base (TVB) limit for frozen fish is set at a maximum of 20 mgN/100g.

4. Frozen Shrimp Safety: Must be free from antibiotic residues of Chloramphenicol and Nitrofuran Metabolites (Not Detected), while Tetracycline is limited to a maximum of 100 micrograms/kg.

Annexes C & D: Processed Fish Products

This section details the thresholds for microbial and heavy metal contamination for various processed products, ranging from frozen fish, breaded fish (nuggets), to fermented and smoked products.

1. Microbiology: Establishes criteria "m" (acceptable limit) and "M" (maximum limit) for pathogenic bacteria such as Salmonella, Listeria monocytogenes, and Staphylococcus aureus in ready-to-eat products as well as those requiring cooking.

2. Heavy Metals: Referring to Regulation of the Indonesian Food and Drug Authority (BPOM) Number 9 of 2022, establishing safe limits for Arsenic, Lead, Mercury, Cadmium, and Tin (Sn) for processed products in cans and non-cans.

Annex E: Canned Fish Products

Specifically for canned Tuna, Sardines, and Mackerel, this regulation stipulates:

1. Drained Weight: Minimum 50% of net weight.

2. Physical: Must be free from filth (dirt/foreign matter) with 0 fragments.

3. Histamine: Maximum 100 mg/kg to prevent histamine poisoning common in scombroid fish types.

Annex F: Fish Feed and Fish Meal

This section plays an important role in maintaining the security of the aquaculture supply chain.

1. Fish & Shrimp Feed: Must be negative for Salmonella. Residue of antibiotics such as Nitrofuran, Chloramphenicol, and Oxytetracycline must be Not Detected (ND). The maximum Aflatoxin limit is 20 µg/kg and Melamine must be ND.

2. Fish Meal: Must be negative for Salmonella and negative for non-fish protein (to prevent adulteration or cross-contamination).

Closing

Decree 8/2025 represents a significant step in establishing quality standards for Indonesian fishery commodities under the Indonesian Quarantine Agency. Decree 8/2025 consolidates all technical standards, including physical, chemical, biological, and sensory, into one document, while simultaneously aligning with the standards of export destination countries to ensure exporters obtain legal certainty. For stakeholders, particularly Fish Processing Units (UPI) and feed producers, this decision requires the strengthening of internal quality controls, especially regarding antibiotic residues in shrimp and feed, as well as cold chain management to meet temperature standards and histamine levels.