Regulation of the Food and Drug Authority of Indonesia Number 6 of 2026 Tightens the Process, Documentation, and Oversight of Processed Food Exports

Introduction

On April 29, 2026, the Food and Drug Authority of Indonesia (Badan Pengawas Obat dan Makanan, "BPOM") issued Regulation of the Food and Drug Authority of Indonesia Number 6 of 2026 on Procedures for the Issuance of Export Certificates for Processed Food ("BPOM Regulation 6/2026"). BPOM Regulation 6/2026 governs the issuance of Export Certificates (Surat Keterangan Ekspor, "SKE") by BPOM to support the export activities of processed food, food ingredients, food additives, and food packaging.

BPOM Regulation 6/2026 aims to enhance the competitiveness of Indonesian processed food through exports. The considerations state that businesses require a Processed Food SKE to ensure that exported products comply with the safety, quality, and nutritional requirements of the destination countries; thus, the issuance procedures are regulated to provide procedural certainty for exporters.

Key Provisions

Responsibility for Food Safety and Distribution

Under Article 2 and Article 3, businesses exporting processed food are responsible for the safety, quality, and nutrition of the products in accordance with the requirements of the export destination country, as well as for the distribution of such processed food in the destination country. Furthermore, Article 5 stipulates that exported processed food must comply with the provisions of laws and regulations.

Applicants, Types of Processed Food SKE, and Issuance Limitations

Under Article 1 and Article 6, Producers or Exporters may submit an application for the issuance of an SKE with the approval of the producer or business licensing holder. Article 4 stipulates that the Head of BPOM issues four types of Processed Food SKE, namely:

1. Certificate of Free Sale ("CFS");

2. Health Certificate/To Whom It May Concern;

3. Export Notification for Food Packaging; and

4. Irradiation Certificate.

Article 4 paragraph (7) restricts the issuance of CFS, which does not apply to processed food specifically for export and export products that have different compositions from products registered in Indonesia.

Account Management, Facility Declaration, and Data Updating

Applicants must register an account online by uploading a Business Identification Number (Nomor Induk Berusaha, "NIB"), the identity card of the person in charge, an application letter, and other supporting documents as set forth in Article 8 and Article 9, as well as list all addresses of processed food storage warehouses, including main, temporary, leased, and contracted warehouses. BPOM verifies account registrations and data changes within a maximum of 2 working days through a time-to-respond mechanism as stipulated in Article 10 and Article 11, with the time calculation paused and restarted if additional data is required. In the event an applicant cannot access the account, Article 12 stipulates that an application for access modification must be submitted by attaching a power of attorney and identity documents. All submitted data and documents must also be true, valid, and not falsified as set forth in Article 13 paragraph (2).

Evaluation Procedures, Item Limits, Approvals, and Fee Provisions

Applicants must pay the Non-Tax State Revenue (Penerimaan Negara Bukan Pajak, "PNBP") application fee no later than 3 working days from the receipt of the payment order. BPOM will then evaluate the application within a maximum of 1 working day after the payment is validated as stipulated in Article 14. One Submission Number (Nomor Aju) may only contain a maximum of 20 product items under Article 19 paragraph (2). If the application is approved, BPOM issues an approval in electronic or non-electronic form with a format referring to Annex II as set forth in Article 15. All submitted application fees are non-refundable if the application is rejected or declared void as stipulated in Article 23 paragraph (2).

Application Revision and Cancellation Mechanisms

Article 17 regulates the suspension of the service time calculation (clock-off) if application documents require revisions. Applicants may submit revisions or additional data a maximum of 3 times and must complete them within 30 calendar days from the issuance of the Submission Number. If this time limit is not met, the application is declared void. In the event an application is rejected or voided, the exporters must submit a new application under Article 18.

Laboratory Testing Requirements and Label Adjustment Provisions for PB-UMKU Products

Annex I Letter A stipulates that the submission of a CFS and Health Certificate for products with a Business License to Support Business Activities (Perizinan Berusaha untuk Menunjang Kegiatan Usaha, "PB-UMKU") number must attach a certificate of analysis from an accredited laboratory valid for a maximum of 1 year or a certificate of analysis from the Producer's laboratory. The certificate covers:

1. Genetically Modified Organism ("GMO") testing for products and processed results of soybeans, corn, tomatoes, and potatoes (unless there is a statement from the buyer proving that the destination country does not require it);

2. 3-MCPD testing for Hydrolyzed Vegetable Protein, Isolated Soy Protein, and Soy Sauce products (unless there is a statement from the buyer proving that the destination country does not require it); and

3. Residue testing for Ethylene Oxide and 2-Chloro Ethanol, as well as Ethylene Glycol and Di-ethylene Glycol for potentially contaminated products.

Exporters of cooking oil must also attach:

1. Export Approval (Persetujuan Ekspor, “PE”);

2. Export Declaration (Pemberitahuan Ekspor Barang, "PEB"); and

3. Harmonized System (HS) Code data.

Furthermore, Annex I stipulates that businesses must not include domestic licensing numbers (PB-UMKU) on export packaging if the design or label differs from the local product.

Specific Requirements for Home Industry Scale and Specific Export Products

Annex I Letter B stipulates that home industry scale businesses must attach a Home Industry Food Production Certificate (Sertifikat Produksi Pangan Industri Rumah Tangga, “SPP-IRT”) or Home Industry Food Permit (Izin Pangan Produksi Industri Rumah Tangga, “IPP-IRT”) along with proof of facility verification or correction completion (closed Corrective Action Preventive Action) from the Health Agency (Dinas Kesehatan) or BPOM. For the export of raw materials or specific export products, Annex I Letter C requires applicants to possess a Risk Management Program (Program Manajemen Risiko, "PMR") Implementation License and/or a Good Processed Food Production Practices (Cara Produksi Pangan Olahan yang Baik, "CPPOB") Implementation License. A CFS submission for specific export products must also be accompanied by proof of domestic sales in the form of a purchase order or invoice.

Shipment-Specific Certification Requirements

Annex I Letter D sets forth the application requirements for a Health Certificate in the form of a Shipment-Specific Certification. Businesses must attach:

1. Application letter;

2. Certificate of radioactive contamination analysis from a laboratory designated by the Certifying Entity;

3. Certificate of analysis from an accredited laboratory valid for a maximum of 1 year or a certificate of analysis from the Producer's laboratory if possessing a PB-UMKU number;

4. Exporter facility inspection results by BPOM food inspectors or joint inspections with relevant Ministries/Agencies;

5. Export Self-Assessment Checklist document;

6. Product scanning results;

7. Statement letter on the origin of raw materials;

8. Food safety management system certificate from an accredited institution, such as the British Retail Consortium ("BRC"), Food Safety System Certification ("FSSC") 22000, or ISO 22000; and

9. Transportation document in the form of a Bill of Lading or Airway Bill.

Additional Clause Provisions on Certificate of Free Sale

Annex I Letter E stipulates that applicants may request the addition of clauses to the CFS document according to the buyer's request. Exporters may include statements regarding product conditions, including:

1. The export product is identical to the product that has obtained a PB-UMKU, in terms of label, weight, and composition;

2. The export product has a different label design compared to the domestic label design;

3. The export product has a different trade name from the product that has obtained a PB-UMKU;

4. The export product has a different net weight or grammage; and

5. The product is sold on a Business to Business (B2B) basis.

Specific Requirements for Export of Food Packaging and Irradiation Certificates

Annex I Number 2 stipulates that an SKE application for food packaging must be accompanied by a specification description of the constituent materials, both food contact materials and substances, as well as a migration test result certificate from an accredited laboratory valid for a maximum of 2 years. Applicants must also include:

1. Food safety certificate, such as ISO 22000;

2. Material Safety Data Sheet (MSDS);

3. Certificate of Compliance; and

4. Certificate of Origin for re-export products.

Furthermore, Annex I Number 3 stipulates that an Irradiation Certificate application must attach an irradiation statement letter from an irradiation facility.

Automatic Approval Priority Service

Article 20 regulates a Priority Service for the issuance of Processed Food SKE processed automatically through a recommendation system. This service is valid for 1 year and granted to exporters meeting the following criteria:

1. Have a good track record under BPOM assessment technical guidelines;

2. Conduct export activities and apply for SKE routinely; and

3. Have no history of product rejection from export destination countries in the last 2 years.

SKE Validity Period, Reporting, and Consultation Services

Article 21 stipulates that a Processed Food SKE is valid for 1 export implementation. Article 22 provides an exception for businesses with good performance to obtain a longer SKE validity period usable more than once, with an obligation to submit an export realization report at the end of the usage period. Furthermore, Article 24 stipulates that BPOM provides an export consultation desk on its official website to deliver technical information regarding destination country requirements.

Transitional Provisions

Article 27 stipulates that Processed Food SKE issuance applications submitted before this regulation took effect continue to be processed under the previous provisions, and Processed Food SKE documents issued prior to April 29, 2026, remain valid and effective until their validity period expires. Businesses must also comply with administrative sanction provisions under Article 25, whereby if an applicant violates account data update reporting obligations, falsifies requirement data or documents, or fails to submit an export realization report, the Head of BPOM may impose administrative sanctions in the form of written warnings, closure of electronic system access for application submission for a maximum of 1 year, revocation of priority service, and/or suspension of priority service for 2 years, with the procedures for imposing such sanctions governed by Article 26.

Closing

BPOM Regulation 6/2026 regulates the issuance of Processed Food SKE by obligating businesses to ensure product safety, quality, and nutrition as well as distribution in the destination country, comply with legal requirements, and follow clear administrative processes. Applications may only be submitted by Producers or Exporters with the approval of relevant parties for SKE types covering Certificate of Free Sale, Health Certificate/To Whom It May Concern, Export Notification for Food Packaging, and Irradiation Certificate, with the restriction that a CFS does not apply to specific export products or products with compositions different from those registered in Indonesia. Businesses must register an account, submit accurate data, and list all warehouse facilities, subject to BPOM verification within a certain timeframe through a time-to-respond mechanism, while the evaluation process is conducted within 1 working day after PNBP payment validation, with a maximum limit of 20 items per Submission Number, and approvals issued according to the prescribed format. Businesses must also note that application fees are non-refundable, and they must complete document revisions a maximum of 3 times within 30 calendar days before the application is declared void, alongside fulfilling technical requirements in the form of an accredited laboratory analysis certificate valid for 1 year or a Producer's laboratory analysis certificate, parameter testing such as GMO, 3-MCPD, and chemical residues, as well as labeling provisions that prohibit the inclusion of a PB-UMKU number on certain export packaging. Furthermore, specific requirements apply to home industries, specific export products, shipment-specific certification, food packaging, and irradiation certificates, including obligations for additional documents and food safety system certification, as well as priority service arrangements with automatic approval for certain exporters and an SKE validity period that is in principle for 1 export with the possibility of multiple uses for well-performing businesses fulfilling reporting obligations. Applications submitted prior to the enactment of BPOM Regulation 6/2026 continue to be processed under previous provisions and issued SKE remain valid until their validity period expires. Meanwhile, violations of obligations, including data falsification, reporting non-compliance, or other violations, may be subject to administrative sanctions in the form of written warnings, closure of electronic system access for up to 1 year, revocation of priority service, and/or suspension of priority service for 2 years; Therefore, compliance with all requirements is essential to ensure the continuity of processed food export activities.