When discussing Halal Product Guarantee in Indonesia, public attention usually goes straight to the halal certification obligation. Yet not all products are actually meant to be certified. There is a certain category of products made from non-halal (haram) ingredients that are in fact excluded from that obligation.
To regulate this, the Halal Product Guarantee Organizing Agency (BPJPH) issued BPJPH Regulation No. 3 of 2026 on the Form and Procedure for Including Non-Halal Information. This regulation serves as the official guideline for business operators in including non-halal information on products that enter, circulate, and are traded in Indonesia.
This rule isn't just about label formatting. The government wants to ensure consumers get clear information about a product's status, while business operators have a common standard for meeting their legal obligations. With uniform provisions, differing labeling practices that could confuse the public are expected to no longer occur. For operators in the food and beverage, cosmetics, pharmaceutical, biological product, and general-use goods sectors, understanding this regulation is an important part of maintaining compliance with Indonesia's Halal Product Guarantee framework.
Before BPJPH Regulation No. 3 of 2026 was issued, there was no rule specifically governing the form of Non-Halal Information that had to be used or how it should be included on products. As a result, each business operator could potentially use different methods of conveying this, so the information consumers received wasn't always consistent. Through this regulation, BPJPH established a nationally applicable standard. The goal isn't to restrict business activity, but to ensure that information about a product's status is conveyed clearly, is easy to understand, and doesn't mislead consumers.
At the same time, having a common standard also gives business operators legal certainty. They now have clear guidance on when a product must include Non-Halal Information, what label form must be used, and how it should be placed on packaging or the product itself. This regulation therefore not only protects consumer interests but also helps business operators carry out their obligations in accordance with applicable provisions.
No. Many people assume all products marketed in Indonesia must be halal-certified, but that's not how the Halal Product Guarantee system actually works. Products made from haram ingredients are in fact excluded from the halal certification obligation, business operators don't need to apply for halal certification for such products. However, that doesn't mean these products may be marketed without any information at all for consumers.
Instead, business operators are required to include Non-Halal Information in accordance with BPJPH provisions. This information is important so consumers know a product's status before deciding to buy or use it. This approach confirms that the regulation's main purpose isn't solely to mandate halal certification, but to ensure transparency of information for the public.
This obligation applies to products made from prohibited (haram) ingredients or products processed in a way that doesn't meet the requirements of the Halal Product Guarantee System (Sistem Jaminan Produk Halal, SJPH). In other words, the assessment isn't based solely on the raw materials used. How a product is manufactured is also a determining factor in whether it must carry Non-Halal Information.
For example, a product might not directly use ingredients classified as haram. However, if contamination with non-halal materials occurs during production, or if the production facility used doesn't meet SJPH requirements, the product's status can change. Because of this, business operators can't just check their ingredient list. The entire production chain from raw material sourcing, processing, storage, and packaging, to distribution also needs attention to ensure it complies with applicable provisions.
To make it easier for business operators to assess this, BPJPH Regulation No. 3 of 2026 divides the criteria into two main groups: criteria based on ingredients and criteria based on the production process. These two aspects form the basis for determining whether a product must include Non-Halal Information.
Also read: Indonesia's New Halal Compliance Sanctions: What Businesses Need to Know in 2026
The assessment under BPJPH Regulation No. 3 of 2026 is based on two main aspects: ingredients and the production process. A product can be classified as non-halal because of certain ingredients used, because its production method doesn't meet SJPH requirements, or because of both.
BPJPH Regulation No. 3 of 2026 divides the ingredients that form the basis for a non-halal status determination into seven groups. This grouping is meant to help business operators more easily identify whether the ingredients used in their products fall into a category requiring Non-Halal Information.
1. Animal-Derived Ingredients
Animal-based ingredients receive the most attention, though not all of them are automatically classified as non-halal.
BPJPH has designated certain animal types and parts that fall into this category: pigs and all their derivatives, dogs, fanged predatory animals, birds of prey with talons, and other animals that according to Islamic law may not be consumed. Besides the animal type itself, how the ingredient is obtained also matters. Meat from an animal that is inherently halal can still be classified as non-halal if the animal died without slaughter in accordance with SJPH requirements, or died from other causes such as strangulation, being struck, falling, being gored, or being mauled by a predator. This provision doesn't only apply to food and beverage products. For non-food products, the use of skin, bone, hair, fur, claws, or other body parts from haram animals also falls into the non-halal ingredient category.
2. Plant-Derived Ingredients
Unlike animal-based ingredients, plant-derived materials are essentially considered halal by default. However, that status can change if non-halal additives or processing aids are used during processing. For example, a plant extract processed using a haram solvent, or mixed with materials that don't meet SJPH requirements, can cause the product to fall into the non-halal category. This means business operators need to look not only at the ingredient's origin but also the entire processing chain the ingredient goes through before ending up in the final product.
3. Alcohol-Containing Ingredients
The topic of alcohol often confuses business operators. Many assume any alcohol content automatically makes a product non-halal, but BPJPH Regulation No. 3 of 2026 regulates this more specifically. The types of alcohol that form the basis for Non-Halal Information include alcohol from the khamr (intoxicating beverage) industry, fermented or non-fermented beverages with an alcohol content of at least 0.5%, ingredients to which khamr has been added, and liquid byproducts of the khamr industry that have been physically separated out. With this provision, business operators have a clearer reference for assessing raw materials, particularly in the food, beverage, cosmetics, and pharmaceutical industries.
4. Microbe-Derived Ingredients
Besides animal and plant ingredients, BPJPH also regulates materials derived from microorganisms. An ingredient can be classified as non-halal if the microorganism used was cultivated on a growth medium containing haram or unclean (najis) elements, or if its production process involves materials that don't meet SJPH requirements. This provision is highly relevant to the biotechnology, pharmaceutical, cosmetics, and food industries that use microbes in production.
5. Ingredients Resulting from Chemical, Biological, or Genetic Engineering Processes
Technological development means many products today are produced through chemical, biological, or genetic engineering processes. BPJPH Regulation No. 3 of 2026 stipulates that the results of such processes can also be classified as non-halal if they use materials from haram animals, human body parts, or other materials that don't meet SJPH requirements. Biotechnology companies and genetic-engineering-based industries therefore need to trace all material sources used throughout production.
6. Ingredients Derived from Human Body Parts
This regulation firmly states that human body parts cannot be used as ingredients in products within the scope of Halal Product Guarantee. This provision also applies to materials resulting from chemical, biological, or genetic engineering processes that use human body parts as a material source.
7. Unclean (Najis) or Contaminated (Mutanajis) Materials
The final category is najis or mutanajis materials. A material that was originally halal can change status if contaminated with unclean elements during production, storage, or distribution. Maintaining separation between halal and non-halal materials is therefore an important aspect of implementing the Halal Product Guarantee System.
Many business operators assume that as long as their raw materials are halal, their product is automatically halal. That assumption isn't always correct.
BPJPH Regulation No. 3 of 2026 confirms that the production process is also a determining factor in a product's status. In other words, a product using halal ingredients can still be required to carry Non-Halal Information if mixing or contamination with non-halal materials occurs during production. For example, this can happen if a production facility is used alternately for halal and non-halal products without proper cleaning procedures, if storage causes cross-contamination, or if distribution and serving are done without adequate separation.
Business operators therefore need to ensure that every stage of production processing, storage, packaging, distribution, and serving consistently applies the principles of the Halal Product Guarantee System. Ultimately, compliance with this regulation doesn't depend solely on the list of ingredients used, but also on how the entire business process is run. This is why BPJPH treats ingredients and the production process as two equally important aspects in determining the obligation to include Non-Halal Information.
After determining which products must include Non-Halal Information, the next step is to make sure the label form used complies with BPJPH requirements. BPJPH Regulation No. 3 of 2026 stipulates that business operators cannot create or modify labels at will. The goal is for information about a product's status to be conveyed consistently and be easily recognizable by the public.
Officially, there are two forms of Non-Halal Information that can be used:
The designs for both labels have been set out in the appendix to BPJPH Regulation No. 3 of 2026. Business operators therefore need to use the form that matches applicable provisions and must not alter the key elements that have been established. Generally, the "MENGANDUNG BABI" (CONTAINS PORK) label is used for products that actually contain pork or its derivatives, while the "NON HALAL" label is used for other products that don't meet halal criteria due to certain ingredients used or their production process.
In addition to regulating the label's form, BPJPH also provides guidance on where it must be placed. The purpose is simple: so consumers can easily identify a product's status before deciding to buy or use it.
In principle, Non-Halal Information can be placed on:
If a product is marketed in packaging, the label must be placed on the packaging received directly by the consumer. This way, information about the product's status is visible without needing to open the packaging first. Placement of the label must also account for several factors: it must be easy to see, easy to read, proportionally sized, not obscured by the packaging design, and not easily removed or erased. This provision shows that including Non-Halal Information isn't just a formality the information genuinely needs to be clearly visible so consumers can make an informed decision.
Not all products are marketed in retail packaging. Some products, particularly certain raw materials or food ingredients, are sold in bulk. For such conditions, BPJPH Regulation No. 3 of 2026 still requires Non-Halal Information. Since there's no retail packaging, this information can be placed on the container, dispenser, storage vessel, or other medium that's easily visible to consumers.
Besides displaying the label, business operators are also required to have supporting documentation showing that the product does in fact originate from haram materials or was produced using a process that doesn't comply with the Halal Product Guarantee System. Such documents may include the production process flow, product composition, a Certificate of Analysis (CoA), producer questionnaires, or a statement letter explaining the product's status.
This obligation ensures that information given to consumers isn't based on the label alone but can also be substantiated if BPJPH or a related agency conducts an inspection.
BPJPH is providing a 12-month adjustment period for business operators to give them time to meet the new requirements regarding the form and procedure for including Non-Halal Information. BPJPH Regulation No. 3 of 2026 officially took effect on July 23, 2026. For products that had already entered, circulated, or were being traded before that date, business operators are still given the opportunity to adjust their labeling in line with the new provisions until July 23, 2027.
This adjustment period can be used to review products currently on the market, update packaging designs, ensure the correct form of Non-Halal Information is used, and prepare supporting documentation as needed. By making adjustments early, business operators can reduce the risk of non-compliance once the grace period ends, while ensuring their products can continue to be marketed in accordance with applicable provisions.
Also read: Halal Certification in Indonesia: A Detailed Overview
BPJPH Regulation No. 3 of 2026 provides clearer guidance on the form and procedure for including Non-Halal Information for products made from haram materials or produced using a process that doesn't comply with the Halal Product Guarantee System (SJPH). Through this regulation, the government aims to ensure consumers receive clear information about the status of the products they buy. At the same time, business operators gain certainty regarding what label form must be used, where it should be placed, and the correct procedure for including it.
Equally important, this regulation is a reminder that a product's status isn't determined by its raw materials alone. How a product is manufactured, stored, packaged, and distributed is also part of the assessment. Business operators therefore need to view compliance holistically, not just from the standpoint of product composition. For companies that produce, import, or distribute products in Indonesia, understanding these provisions is an important step to ensure business activities continue to run in accordance with regulations while maintaining consumer trust.
Understanding Halal Product Guarantee regulations isn't always easy, especially when a business has to adapt to various new requirements. From determining product status and managing halal certification to fulfilling labeling obligations, each stage requires a proper understanding of applicable provisions. CPT Corporate is ready to help business operators meet various regulatory requirements in Indonesia, including consultation on halal certification, product compliance, business licensing, and other legal and corporate compliance services. Contact our team to get a solution tailored to your business needs.
Ketika membahas Jaminan Produk Halal di Indonesia, perhatian publik biasanya langsung tertuju pada kewajiban sertifikasi halal. Padahal, tidak semua produk memang ditujukan untuk disertifikasi. Ada kategori produk tertentu yang berasal dari bahan haram sehingga justru dikecualikan dari kewajiban tersebut.
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