Regulation of the Halal Product Assurance Organizing Body Number 2 of 2026 Tightens Sanctions for Halal Product Violations

Introduction

On June 5, 2026, the Halal Product Assurance Organizing Body (Badan Penyelenggara Jaminan Produk Halal, "BPJPH") issued Regulation of the Halal Product Assurance Organizing Body Number 2 of 2026 on the Imposition of Administrative Sanctions for Violations of Halal Product Assurance Implementation ("BPJPH Regulation 2/2026"). BPJPH Regulation 2/2026 governs the types of violations, forms of administrative sanctions, and mechanisms for imposing sanctions against businesses, Halal Examination Agencies (Lembaga Pemeriksa Halal), Halal Auditors, Halal Product Process Assistant Agencies (Lembaga Pendamping Proses Produk Halal), and Halal Product Process Assistants (Pendamping Proses Produk Halal) that fail to fulfill their obligations in the implementation of Halal Product Assurance.

The government issued BPJPH Regulation 2/2026 to support law enforcement through the imposition of administrative sanctions and to provide legal certainty, protection, and assurance regarding the halal status of products consumed and used by the public. In addition, BPJPH Regulation 2/2026 regulates the execution of administrative sanctions to support orderly government administration and accountability in the implementation of Halal Product Assurance (Jaminan Produk Halal, "JPH").

Key Provisions

Types of Halal Product Assurance Violations by Businesses

BPJPH Regulation 2/2026 regulates the types of halal product assurance implementation violations that businesses may commit. Article 17 stipulates that these violations include:

1. Failing to fulfill halal certification obligations for products entering, circulating, and traded that have passed the phasing period;

2. Providing dishonest information during registration;

3. Failing to separate production locations and equipment between halal and non-halal products;

4. Failing to have a halal supervisor;

5. Failing to report changes in ingredient composition;

6. Failing to display the halal label on certified products;

7. Failing to maintain product halalness;

8. Failing to renew the halal certificate;

9. Failing to implement the JPH system;

10. Failing to display non-halal information on products made from prohibited (haram) ingredients; and

11. Failing to register, failing to display the registration number adjacent to the halal label, and/or failing to extend the registration of foreign halal certificates.

Administrative Sanctions for Businesses

BPJPH Regulation 2/2026 regulates administrative sanctions for businesses that violate the implementation of Halal Product Assurance. Article 7 paragraph (1) and paragraph (2) stipulate that these administrative sanctions include:

1. Written warnings;

2. Administrative fines;

3. Revocation of Halal Certificates (including the revocation of foreign Halal Certificate registration numbers); and/or

4. Product recalls from circulation.

Article 18 regulates the types of sanctions imposed according to the violations committed. Businesses that fail to fulfill halal certification obligations for products that have passed the phasing period may face written warnings and/or product recalls from circulation. Meanwhile, businesses that provide incorrect information, fail to separate halal and non-halal production facilities, or fail to maintain product halalness may face administrative fines and/or Halal Certificate revocation. For violations relating to Halal Certificate renewal and failure to implement the JPH system, businesses face administrative fines and/or Halal Certificate revocation. Meanwhile, for violations concerning the reporting of ingredient composition changes and the display of halal labels, BPJPH Regulation 2/2026 imposes progressive sanctions comprising written warnings, administrative fines, Halal Certificate revocation, and product recalls from circulation.

Officials Authorized to Impose Administrative Sanctions

Article 2 paragraph (2) along with Article 3, Article 4, and Article 5 regulate the authority of BPJPH officials to impose administrative sanctions on businesses. Primary High Leadership Officials (Pejabat Pimpinan Tinggi Pratama) issue written warnings upon obtaining approval from Senior High Leadership Officials (Pejabat Pimpinan Tinggi Madya), while Senior High Leadership Officials impose administrative fines. Furthermore, the Head of BPJPH determines the revocation of Halal Certificates, the revocation of foreign Halal Certificate registration numbers, and product recalls from circulation.

Mandatory Information in Administrative Sanction Decisions

BPJPH Regulation 2/2026 regulates the mandatory information required in decisions to impose administrative sanctions on businesses. Article 8 paragraph (1) and paragraph (2) stipulate that written warning decisions must contain:

1. The identity and address of the violator;

2. The type and explanation of the violation;

3. The consequences of the violation;

4. The timeframe for completing follow-up actions; and

5. The date of issuance.

For Halal Certificate revocation sanctions, Article 9 paragraph (1) and paragraph (2) stipulate that the decision of the Head of BPJPH must contain the identity of the business, the address of the business, the Halal Certificate number, the product type, the product name, the type of violation, and the revocation date. Meanwhile, Article 10 paragraph (1) and paragraph (2) stipulate that product recall decisions must also include the timeframe for the recall. Article 9 paragraph (3) and Article 10 paragraph (3) require BPJPH to deliver these decisions to the business within a maximum of 5 working days from the date of issuance.

Follow-Up Deadlines for Written Warnings

Businesses must follow up on violations after receiving a written warning sanction. Article 19 paragraph (1) stipulates that businesses failing to fulfill halal certification obligations for products that have passed the phasing period are granted a maximum of 30 working days to meet this obligation. For other violations, businesses are given a maximum of 14 working days to perform follow-up actions. If a business fails to follow up within this timeframe, Article 20 empowers BPJPH to disseminate information regarding the violation through print media, electronic media, social media, and/or the placement of warning stickers. Additionally, pursuant to Article 19 paragraph (2) and paragraph (3), businesses may face further administrative sanctions in the form of product recalls from circulation or administrative fines, depending on the type of violation committed.

Sanction Variations for Foreign Halal Certificate Administrative Violations Based on Business Scale

BPJPH Regulation 2/2026 regulates varying administrative sanctions for violations related to foreign Halal Certificate registration based on the business scale. Article 18 paragraph (6) stipulates that medium and large-scale businesses that fail to register, fail to display the registration number near the halal label, or fail to extend foreign Halal Certificate registrations face sanctions in the form of administrative fines and/or product recalls from circulation. Meanwhile, Article 18 paragraph (7) stipulates that micro and small businesses committing the same violation face progressive sanctions consisting of written warnings, administrative fines, and/or product recalls from circulation. Furthermore, Article 18 paragraph (8) authorizes BPJPH to first issue a written warning sanction prior to imposing administrative fines and/or product recalls from circulation.

Product Recalls from Circulation

BPJPH Regulation 2/2026 regulates the obligation to recall products from circulation as a follow-up to specific administrative sanctions. Article 23 paragraph (1) stipulates that businesses must recall products from circulation within a maximum of 60 working days from the date the product recall decision is issued. If a business fails to conduct the product recall within the specified timeframe, Article 23 paragraph (2) stipulates that BPJPH will coordinate with relevant ministries and/or agencies to execute the product recall from circulation. Additionally, pursuant to Article 21, the revocation of a Halal Certificate may be accompanied by a product recall from circulation, depending on the type of violation committed.

Product Recalls and Public Announcements for Products Containing Prohibited Ingredients

Article 22 regulates the follow-up actions for violations involving the failure to display non-halal information on products derived from prohibited ingredients. Article 22 paragraph (1) stipulates that businesses receiving written warnings for this violation must recall products from circulation until the non-halal information is displayed on the product. Article 22 paragraph (2) stipulates that product recalls from circulation for food and beverage service businesses and other related service businesses are carried out through the temporary closure of the business premises and the dissemination of information regarding the violation through stickers, banners, and/or other media. Furthermore, Article 22 paragraph (3) stipulates that BPJPH must announce information regarding the product to the public within a maximum of 2 working days from the issuance of the written warning through electronic media, social media, and/or print media.

Filing Objections to Administrative Sanctions

BPJPH Regulation 2/2026 grants businesses the right to file objections against specific administrative sanctions. Article 38 paragraph (1) and Article 39 paragraph (1) stipulate that businesses may file objections with the Head of BPJPH against sanctions consisting of administrative fines, Halal Certificate revocation, the revocation of foreign Halal Certificate registration numbers, and/or product recalls from circulation. Article 40 stipulates that objections must be submitted within a maximum of 5 working days from the date the administrative sanction decision is issued. Furthermore, Article 41 regulates that the Head of BPJPH appoints an Appeals Team (Tim Banding) to review the submitted objection within a maximum of 2 working days. Based on the review results, the Head of BPJPH issues a decision to accept or reject the objection within a maximum of 1 working day and delivers a notification or an amended decision to the business.

Requirements for Filing Objections

Article 39 paragraph (3) stipulates that objection applications submitted to the Head of BPJPH must contain:

1. The identity of the applicant;

2. The grounds for the objection;

3. The contested decision; and

4. Other evidence supporting the grounds for the objection.

Additionally, Article 39 paragraph (4) stipulates that supporting evidence may include follow-up monitoring documents of JPH inspection results.

Sanctions for Businesses via the Halal Self-Declaration Mechanism

Article 24 regulates the imposition of administrative sanctions for micro and small businesses that obtain Halal Certificates through the halal self-declaration mechanism. Article 24 paragraph (1) stipulates that businesses failing to fulfill halal certification obligations for products that have passed the phasing period face written warnings. Meanwhile, Article 24 paragraph (2) stipulates that businesses committing violations as referred to in Article 17 letters b through i (such as providing incorrect information, failing to separate production facilities, failing to have a halal supervisor, up to failing to implement the JPH system) face progressive sanctions consisting of written warnings, administrative fines, and Halal Certificate revocation.

Grounds for Filing Objections Against Administrative Sanctions

Article 6 paragraph (3) regulates the grounds that businesses may use to file objections against the imposition of administrative sanctions, namely:

1. The enforcement of Halal Product Assurance inspection was not conducted in accordance with procedures;

2. Inspectors failed to provide valid statements and evidence supporting the alleged violations;

3. The administrative sanctions were determined by unauthorized officials;

4. The discovery of new evidence that may aggravate or mitigate the imposition of administrative sanctions; and

5. The business is unable to execute corrective follow-up actions due to force majeure.

Supervision of Halal Product Assurance Implementation

Article 34 paragraph (2) and Article 35 stipulate that the supervision of Halal Product Assurance implementation is conducted by Halal Product Assurance Inspectors from BPJPH, relevant ministries/agencies, and/or local governments in accordance with their respective authorities. Article 36 and Article 37 stipulate that inspection result reports serve as the basis for the Head of BPJPH or authorized officials to determine the imposition of administrative sanctions in accordance with the conducted inspection results.

Monitoring of Follow-Up Actions on Administrative Sanctions

Article 42 stipulates that follow-up actions on the imposition of administrative sanctions are documented in the follow-up monitoring documents of Halal Product Assurance inspection results. Furthermore, Article 43 regulates that BPJPH monitors the follow-up actions of Halal Product Assurance inspection results after the imposition of administrative sanctions.

Prohibitions for Halal Examination Agencies, Halal Auditors, and Halal Product Process Assistants

BPJPH Regulation 2/2026 also regulates prohibitions for parties involved in the implementation of Halal Product Assurance. Article 25 letter j and Article 27 letter l stipulate that Halal Examination Agencies and Halal Auditors are prohibited from conducting activities outside the execution of examinations and/or testing that could generate additional costs or conflicts of interest with businesses. Additionally, Article 31 paragraph (3) details violations for Halal Product Process Assistants, such as forging documents or engaging in actions that result in illegal levies and/or gratifications during the Halal Certificate application process. For these types of violations, Article 32 paragraph (3) stipulates that Halal Product Process Assistants face administrative sanctions in the form of registration number revocation.

Transitional Provisions

Article 44 stipulates that businesses may reapply for a Halal Certificate for products that have been subjected to Halal Certificate revocation sanctions. Furthermore, Article 45 regulates that laws and regulations governing administrative sanctions in the implementation of Halal Product Assurance must align with BPJPH Regulation 2/2026.

Closing

BPJPH Regulation 2/2026 regulates the types of violations, forms of administrative sanctions, officials authorized to impose sanctions, supervision mechanisms, and procedures for filing objections in the implementation of Halal Product Assurance. For businesses, BPJPH Regulation 2/2026 governs various violations subject to administrative sanctions, including failing to fulfill halal certification obligations, providing incorrect information, failing to separate halal and non-halal production facilities, failing to have a halal supervisor, failing to report changes in ingredient composition, failing to display halal labels or non-halal information, failing to maintain product halalness, failing to renew Halal Certificates, failing to implement the Halal Product Assurance system, and failing to meet foreign Halal Certificate registration obligations. For these violations, BPJPH may impose sanctions comprising written warnings, administrative fines, the revocation of Halal Certificates or foreign Halal Certificate registration numbers, and/or product recalls from circulation based on the specific violation committed. BPJPH Regulation 2/2026 also designates the officials authorized to impose each sanction, details the mandatory information required in administrative sanction decisions, and establishes the obligation to deliver decisions to businesses within a maximum of 5 working days from issuance. Businesses receiving written warnings must execute follow-up actions within a maximum of 30 working days for halal certification obligation violations after the phasing period and a maximum of 14 working days for other violations, with the potential dissemination of violation information and further administrative sanctions if follow-up actions are not performed. Furthermore, BPJPH Regulation 2/2026 regulates product recall obligations from circulation, including the mandatory temporary closure of specific business locations, the display of violation information, and public announcements regarding products containing prohibited ingredients that fail to display non-halal information. BPJPH Regulation 2/2026 also establishes varying sanctions for foreign Halal Certificate administrative violations based on business scale and outlines sanctions for micro and small businesses that obtain Halal Certificates via the halal self-declaration mechanism. In practice, the imposition of administrative sanctions is based on inspection results conducted by Halal Product Assurance Inspectors, documented in the follow-up monitoring documents of Halal Product Assurance inspection results, and followed by post-sanction monitoring. BPJPH Regulation 2/2026 also grants businesses the right to file objections against specific administrative sanctions by meeting the requirements and grounds set forth in the regulation, with a submission deadline of a maximum of 5 working days from the date of issuance. In addition to governing business obligations, BPJPH Regulation 2/2026 establishes prohibitions for Halal Examination Agencies, Halal Auditors, and Halal Product Process Assistants, alongside sanctions for violations committed during the performance of their duties. Finally, businesses whose Halal Certificates have been revoked remain eligible to reapply for a Halal Certificate in accordance with laws and regulations, and existing regulations governing administrative sanctions in the implementation of Halal Product Assurance must align with BPJPH Regulation 2/2026.