Halal Product Assurance Organizing Agency Regulation Number 3 of 2026 Officially Enacted: Standardizing “Non-Halal” Labels for Products Circulating in Indonesia

Introduction

On 13 July 2026, the Halal Product Assurance Organizing Agency (Badan Penyelenggara Jaminan Produk Halal – BPJPH) enacted Halal Product Assurance Organizing Agency Regulation Number 3 of 2026 on the Form and Procedures for the Affixing of Non-Halal Information (“BPJPH Regulation 3/2026”), which took effect on 23 July 2026. BPJPH Regulation 3/2026 was issued to provide legal certainty and serve as a guideline for businesses and consumers regarding the communication of product halal status.

Specifically, BPJPH Regulation 3/2026 standardizes the form, size, placement, and procedures for affixing Non-Halal Information on products imported into, circulated, and traded within the territory of Indonesia.

BPJPH Regulation 3/2026 was issued to implement Article 110 paragraph (3) of Government Regulation Number 42 of 2024 on the Administration of the Halal Product Assurance Sector. The Regulation aims to ensure transparency of information and provide protection for consumers, particularly Muslim consumers, by providing clear information regarding products that are exempt from the halal certification requirement. Through BPJPH Regulation 3/2026, every product containing prohibited ingredients is required to clearly display Non-Halal Information in a manner that is easily recognizable, thereby enabling the public to obtain adequate information when making decisions regarding consumer products and goods.

Key Provisions

Obligation to Affix Non-Halal Information Independently

Pursuant to Article 3 and Article 4, products derived from prohibited ingredients are exempt from the obligation to obtain a halal certificate. Nevertheless, businesses are required to affix Non-Halal Information to such products.

The affixing of Non-Halal Information shall be carried out independently by businesses by referring to the criteria for ingredients and/or production processes that do not comply with the requirements of the Halal Product Assurance System (Sistem Jaminan Produk Halal – SJPH).

Criteria for Prohibited Ingredients and Contaminated Production Processes

Articles 5 through 20 stipulate the criteria for products that are subject to the obligation to affix Non-Halal Information, whether based on the origin of the ingredients or the production process. These criteria include:

·      the use of ingredients derived from prohibited animals, including pigs, dogs, predatory animals, amphibians, animals regarded as repulsive, as well as carrion or animals that are not slaughtered in accordance with Islamic law;

·      products containing alcohol or originating from the alcoholic beverage industry (khamr), including fermented and non-fermented beverages containing at least 0.5% (zero point five percent) alcohol;

·      the use of ingredients derived from microorganisms, genetically modified products, parts of the human body, and ingredients classified as najis (ritually impure) or mutanajis (contaminated by ritual impurity); and

·      production processes, locations, facilities, or equipment that have come into contact with or have been contaminated by materials derived from pigs, dogs, or other najis substances, without undergoing the purification process required under the SJPH.

Design Standards and Form of Non-Halal Information (Annex)

Pursuant to Article 21 and the Annex, BPJPH Regulation 3/2026 standardizes the form and procedures for affixing Non-Halal Information into the following two categories:

• Products containing pork and/or pork derivatives must display Non-Halal Information in the form of the words “CONTAINS PORK” in red, accompanied by an illustration of a pig, and placed within a red rectangular box with a white background.
• Products derived from prohibited ingredients other than pork or declared non-halal based on their production process must display the words “NON HALAL” using the Rodfat typeface in the red color code #fc0202. Where the product packaging has a red background, businesses may use another contrasting color to ensure that the Non-Halal Information remains clearly visible and easily legible to consumers.

Procedures and Placement of Non-Halal Information

Pursuant to Article 22 and Article 23, Non-Halal Information must be affixed to the outermost packaging received directly by consumers, to a specific part of the product, or to a designated location on the product according to its characteristics.

Such information must comply with the following requirements:

·      be placed in the most visible and easily readable location for consumers, with a proportionate size;

·      not use image backgrounds, colors, or designs that may reduce the clarity or legibility of the Non-Halal Information; and

·      be affixed in a permanent manner so that it cannot be easily erased, removed, or damaged while the product is being circulated.

Exceptions and Requirements for Bulk Products

Article 26 establishes specific provisions for bulk products that are not traded in retail packaging. For such products, businesses are required to affix Non-Halal Information to the container, dispenser, or storage facility used and to attach supporting documents from the ingredient manufacturer, such as a Certificate of Analysis (CoA) or a declaration letter stating that the ingredients and/or production process do not comply with halal requirements.

Furthermore, Article 27 provides an exception to the obligation to affix Non-Halal Information. Where a processed food or processed beverage product uses a trade name that expressly includes the word “pork”, the product shall be deemed to have fulfilled the obligation to provide information regarding its non-halal status as required under BPJPH Regulation 3/2026 and is therefore not required to display the standard Non-Halal Information label.

Transitional Provisions

Article 28 of BPJPH Regulation 3/2026 provides a transitional period for businesses to adjust the affixing of Non-Halal Information in accordance with the new requirements.

Products that had already been imported into, circulated, and traded within the territory of Indonesia before the promulgation of BPJPH Regulation 3/2026, namely before 23 July 2026, are granted an adjustment period of up to 12 (twelve) months from the date of promulgation, or until 23 July 2027.

Upon the expiry of the transitional period, all products falling within the scope of the Regulation must comply with the requirements concerning the form and procedures for affixing Non-Halal Information as stipulated in BPJPH Regulation 3/2026.

Closing

BPJPH Regulation 3/2026 governs the implementation of the Halal Product Assurance System (SJPH) by providing more detailed provisions regarding the form, procedures, and standards for affixing Non-Halal Information to products traded in Indonesia. Through this standardization, BPJPH seeks to ensure that product information is conveyed in a clearer, more uniform, and easily understandable manner for consumers, while also providing legal certainty for businesses in fulfilling their labeling obligations for products exempt from halal certification.

Following the entry into force of BPJPH Regulation 3/2026, businesses that manufacture or trade products derived from prohibited ingredients or processed in a manner that does not comply with the SJPH requirements should promptly adjust their packaging design, label placement, and procedures for affixing Non-Halal Information in accordance with the prescribed standards. Given that the transitional period is only valid until 23 July 2027, businesses should also ensure that all products circulating after that date fully comply with the new requirements in order to minimize the risk of non-compliance with the laws and regulations governing halal product assurance.