Law No. 33 of 2014 regarding Halal Product Guarantees, as amended by Law No. 6 of 2023 on the stipulation of Government Regulation in Lieu of Law No. 2 of 2022 regarding Job Creation (“Halal Law”), requires a halal certificate to be obtained from the Halal Product Guarantee Organizing Agency (Badan Penyelenggara Jaminan Produk Halal or “BPJPH”) for all products entering, circulating, and being traded in Indonesia.
The implementation of this halal certification requirement will be rolled out gradually for different products, starting from five years from the promulgation of the Halal Law. The timeline for the implementation of the halal certificate requirement was stipulated in an implementing regulation for the Halal Law, namely Government Regulation No. 39 of 2021 regarding the Organization of Halal Product Guarantees (“GR 39/2021”).
This timeline was updated by Presidential Regulation No. 6 of 2023 regarding Halal Certification for Medicine, Biological Products, and Medical Devices (“PR 6/2023”), which added deadlines for the obtainment of halal certification for biological products and medical devices classified in risk category D.
The following are the deadlines to obtain halal certification for different product categories under GR 39/2021 and PR 6/2023:
| Products / Services | Start Date | Deadline to Comply |
| Food and beverage products, raw materials, food
additives, auxiliary materials for food and beverage products, and
slaughter results and slaughter services*
|
17 October 2019 | 17 October 2024 |
| Traditional medicine, quasi medicine, and health
supplements
|
17 October 2021 | 17 October 2026 |
| Cosmetics, chemical products, and genetically
engineered products
|
17 October 2021 | 17 October 2026 |
| Wearable items, e.g. clothing, headscarves, and
accessories
|
17 October 2021 | 17 October 2026 |
| Household and health supplies, household equipment,
worship equipment for Muslims, food and beverage packaging,
stationery, and office supplies
|
17 October 2021 | 17 October 2026 |
| Medical devices classified in Risk Category A
|
17 October 2021 | 17 October 2026 |
| Over-the-counter medicines and limited
over-the-counter medicines
|
17 October 2021 | 17 October 2029 |
| Medical devices classified in Risk Category B
|
17 October 2021 | 17 October 2029 |
| Medical devices classified in Risk Category C
|
17 October 2021 | 17 October 2034 |
| Prescription medicines except for psychotropics
|
17 October 2021 | 17 October 2034 |
| Biological products
|
19 January 2023 | 17 October 2039 |
| Medical devices classified in Risk Category D
|
19 January 2023 | 17 October 2039 |
* excluding products which (i) must be halal certified based on existing laws and regulations, (ii) were already halal certified before the enforcement of Law 33/2014, or (iii) have already been halal certified since the enforcement of Law 33/2014 up to the promulgation of GR 39/2021.
The process to obtain halal certification from the BPJPH may take up to 45 business days, pursuant to GR 39/2021. Considering the impending deadline for the first product category above, business actors may want to apply for halal certification for their products in advance to avoid any disruption to their distribution activities in Indonesia due to the absence of halal certification (or in the case of non-halal products, a label stating that the product is non-halal).
In particular for the food and beverage industry, which has a halal certification deadline of October 2024, it is important to arrange the certification now. Otherwise, products without halal certification will only be able to be distributed and sold in Indonesia if affixed with a label stating that the product is non-halal.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.