National Nutrition Agency Regulation Number 4 of 2026 Requires Sanitary Hygiene Eligibility Certificates for Nutrition Fulfillment Service Units and Imposes Operational Suspension Sanctions

Introduction

On April 8, 2026, the National Nutrition Agency (Badan Gizi Nasional, "BGN") issued National Nutrition Agency Regulation Number 4 of 2026 on Food Safety and Food Quality Assurance Systems within the National Nutrition Agency ("Regulation 4/2026"). Regulation 4/2026 establishes standards and mechanisms to ensure food safety, grade, and quality in implementing the Free Nutritious Meal (Makan Bergizi Gratis, "MBG") Program.

Regulation 4/2026 ensures food remains safe, hygienic, of high quality, and nutritious, while complying with religious, belief, and cultural norms of the community. The regulation also controls the risk of food poisoning and prevents biological, chemical, and physical contamination potentially endangering MBG beneficiaries' health.

Key Provisions

Raw Material Procurement and Inspection Procedures

Regulation 4/2026 stipulates mandatory raw material procurement and receiving procedures. Under Article 4 paragraphs (1) and (2), Nutrition Fulfillment Service Units (Satuan Pelayanan Pemenuhan Gizi, "SPPG") must conduct risk-based food safety inspections on received food raw materials, food additives, food processing aids, packaged processed food, and ready-to-eat processed food containers. This provision requires suppliers to ensure product quality and delivery processes meet standards. Article 4 paragraph (3) requires SPPGs to conduct inspections through the following stages:

1. Verifying documents and inspecting label information;

2. Conducting organoleptic and temperature inspections;

3. Performing rapid tests; and/or

4. Inspecting hygiene and the cold chain during transportation.

Obligation to Obtain Sanitary Hygiene Feasibility Certificates

Article 15 paragraph (2) and Article 16 paragraphs (1) and (3) require every SPPG to hold a Sanitary Hygiene Feasibility Certificate (Sertifikat Laik Higiene Sanitasi, "SLHS") by submitting a written application no later than 3 (three) business days after commencing operations. If the application has been submitted but the SLHS has not been issued, Article 16 paragraph (4) requires the SPPG to fulfill the following operational requirements:

1. Holding Food Safety training certificates for handlers of ready-to-eat food;

2. Conducting food sample inspections; and

3. Having undergone an Environmental Health Inspection (Inspeksi Kesehatan Lingkungan) by the regency/city health agency or community health center.

Fulfilling these requirements forms part of the food safety system implementation assessment under Article 2 paragraph (3).

SLHS Issuance and Assistance Mechanisms

Articles 17 and 18 stipulate that the regency/city health agency or the investment and one-stop integrated service agency issues the SLHS in accordance with the provisions of the ministry handling health affairs, while Article 16 paragraph (6) stipulates that the SLHS is issued no later than 3 (three) months after requirements are declared complete. Article 19 stipulates that BGN, the health agency, and the community health center provide technical guidance and assistance during the certification process, and Article 22 requires SPPGs that have obtained an SLHS to display the SLHS logo at their operational locations. Additionally, Article 16 paragraph (5) permits SPPGs to hold other food safety certificates in accordance with statutory provisions.

Food Handling and Storage Standards

Food handling and storage must apply the First In First Out ("FIFO") or First Expired First Out ("FEFO") principles as stipulated in Article 5 paragraph (2). Applying these principles is adjusted to the raw material types under Article 5 paragraph (3). SPPGs must also store ready-to-eat processed food samples in a refrigerator at temperatures below 5 (five) degrees Celsius for 2 x 24 (twenty-four) hours for inspection purposes in the event of food poisoning, as stipulated in Article 7 paragraphs (1) and (2).

Processing and Portioning Standards for Ready-to-Eat Processed Food

During the preparation and processing stages, SPPGs must maintain nutritional content and prevent bacterial growth by controlling raw materials, processing methods, time, processing room temperatures, and implementing sanitary hygiene as stipulated in Article 6 paragraphs (1) and (3). Portioning is conducted to meet the targeted nutritional adequacy rates in a single meal while maintaining food safety under Article 8 paragraph (1). This process must also observe the sanitary hygiene of food handlers as stipulated in Article 8 paragraph (2), using closed, food-grade containers complying with Indonesian National Standards that include allergy markers and safe consumption time limits, with a maximum serving limit of 4 (four) hours after the food is cooked, as stipulated in Article 8 paragraphs (3), (4), and (5).

Transportation Rules and Logistics Delivery Personnel Qualifications

Food transportation must meet safety, transport suitability, and timely delivery requirements as stipulated in Article 9 paragraph (1). Businesses must use transportation modes dedicated to transporting ready-to-eat processed food, and these modes must be cleaned daily, especially the interior surfaces that come into contact with food containers under Article 9 paragraphs (2) and (4). Additionally, every logistics driver must hold a Driving License and be in good health while on duty as stipulated in Article 9 paragraph (3).

Organoleptic Test Obligations by Receiving Officers

Beneficiaries receive food through receiving officers, accompanied by a handover receipt, while observing safety, officer hygiene, and environmental sanitation aspects as stipulated in Article 10 paragraphs (1) and (2). Receiving officers include educators, education personnel, and companion cadres under Article 10 paragraph (4). These officers must conduct organoleptic tests to ensure food conditions and quality, as well as inspect menu composition, cleanliness, packaging suitability, and portion adequacy before serving, as stipulated in Article 10 paragraphs (5) and (6).

Mitigation against Food Contamination Indications

If organoleptic test results indicate hazardous physical or biological contamination, the receiving officer must halt food distribution as stipulated in Article 11 paragraph (1) letter a and Article 12. If physical contamination poses no potential harm and is visually identifiable, the officer conducts expanded random organoleptic testing under Article 11 paragraph (1) letter b and paragraph (2); if no contamination is found in other samples, distribution may continue by withdrawing the contaminated sample. If contamination is confirmed, the officer reports it to the Head of the SPPG under Article 13 paragraph (1), who then cross-checks at other distribution locations as stipulated in Article 13 paragraph (2). If contamination is found, the Head of the SPPG must recall all distributed ready-to-eat processed food, notify the community health center, and store samples for laboratory analysis under Article 13 paragraphs (3) and (5), subsequently reporting the incident to the Head of the Nutrition Fulfillment Service Office (Kantor Pelayanan Pemenuhan Gizi, "KPPG") as stipulated in Article 13 paragraphs (6) and (7) for further evaluation.

Integrated Handling and Funding of Food Poisoning Incidents

Upon suspected food poisoning, the Head of the SPPG and/or beneficiary representatives must immediately report to the nearest community health center, hospital, other healthcare facilities, or the Village Head/Lurah or other equivalent titles, and forward the report to the BGN through the Head of the KPPG as stipulated in Article 23 paragraphs (1) and (2). Handling is coordinated by the BGN with relevant agencies and implemented in accordance with statutory provisions on extraordinary events of food poisoning as stipulated in Article 23 paragraphs (3) and (4), involving relevant ministries, agencies, and regional governments, while handling funding is sourced from the State Revenue and Expenditure Budget (Anggaran Pendapatan dan Belanja Negara, “APBN”), the Regional Revenue and Expenditure Budget (Anggaran Pendapatan dan Belanja Daerah, “APBD”), or other legitimate sources as stipulated in Article 24, and if the incident is declared an Extraordinary Event by the regional government, all costs are charged to the APBD.

Operational Guidance and Supervision Mechanisms

The BGN, together with ministries/agencies and regional governments, conducts guidance and supervision within their respective authorities, where supervision activities are conducted at least twice a year or at any time as necessary, as stipulated in Article 25 paragraphs (1) and (4). Guidance involves assistance, technical guidance, and/or training, while supervision involves monitoring and evaluation, inspections, or other forms under Article 25 paragraphs (2) and (3); if supervision is cross-sectoral, its implementation is coordinated by the minister administering government affairs in the food sector as stipulated in Article 25 paragraph (5).

Special Evaluations of Findings and Complaints

If there are findings or complaints regarding non-compliance with hygiene and sanitation standards at an SPPG holding an SLHS, the regency/city health agency evaluates this through environmental health inspections, laboratory tests, or other measures under Article 20 paragraphs (1) and (2), with evaluation results potentially resulting in guidance or administrative sanctions as stipulated in Article 20 paragraph (3). If severe violations, repeated violations, or refusals to be evaluated are discovered, the health agency may freeze or revoke the SLHS under Article 21 paragraphs (1) and (2), and notify the BGN as stipulated in Article 21 paragraph (3); if the SLHS was issued by the investment and one-stop integrated service agency, the revocation is carried out by that agency based on a recommendation from the health agency under Article 21 paragraph (4).

Imposition of Administrative Sanctions and Cooperation Termination

SPPGs proven to have committed violations based on supervision results, caused food poisoning, and/or extraordinary events are subject to administrative sanctions under Article 26 paragraph (1). These sanctions include:

1. Temporary suspension of MBG Program production and distribution activities;

2. Recommendations for SLHS revocation; and/or

3. Permanent suspension through termination of cooperation agreements.

Further provisions on imposing sanctions and food safety systems are set forth in a Decree of the Head of the BGN as stipulated in Article 14 and Article 26 paragraph (2).

Transitional Provisions

Article 27 letter a stipulates that SPPGs operating before Regulation 4/2026 was promulgated must hold an SLHS no later than 3 (three) months from April 8, 2026, namely July 8, 2026. Article 27 letter b stipulates that SPPGs failing to fulfill this obligation are subject to temporary operational suspension of food provision activities until the SLHS is issued by the authorized agency.

Closing

Regulation 4/2026 mandates every Nutrition Fulfillment Service Unit and relevant businesses to meet food safety and quality standards in implementing the Free Nutritious Meal Program, with a primary focus on the urgent obligation to hold a Sanitary Hygiene Feasibility Certificate by July 8, 2026, to avoid temporary operational suspension sanctions. Meeting these standards requires consistent quality control implementation from the beginning of the process, including raw material inspections, applying First In First Out or First Expired First Out storage methods, limiting consumption time to a maximum of 4 (four) hours after food is cooked, and using cleanly maintained transportation modes. The supervision series also continues until the final distribution stage, where receiving officers must conduct organoleptic tests and hold full authority to halt food distribution upon finding contamination indications. Given that any form of violation, negative supervision findings, or food poisoning incidents can trigger severe administrative sanctions ranging from freezing or revoking certificates to terminating cooperation agreements, all business operators are required to immediately ensure operational compliance and comprehensive food safety system readiness to prevent the risk of business disruption.