The global snack industry continues to expand rapidly, driven by increasing consumer demand and the ease of cross-border trade. Various snack products are now manufactured and distributed internationally, creating significant opportunities for companies seeking to enter new markets. Indonesia, with its large population and growing consumer market, presents an attractive destination for snack importers. In particular, packaged and dry snack products are increasingly imported due to their longer shelf life and convenient distribution. However, before imported snack products can be marketed in Indonesia, importers must comply with several regulatory requirements governing product registration, import supervision, and halal certification.
The importation of snack products into Indonesia is primarily governed by Ministry of Trade Regulation No. 23 of 2025 concerning Import Policies and Regulations for Consumer Goods, which regulates the importation of consumer goods into the Indonesian market. In addition, food products entering Indonesia are subject to supervision by the Indonesian National Agency of Drug and Food Control (Badan Pengawas Obat dan Makanan or “BPOM”) under BPOM Regulation No. 28 of 2023 on the Amendment to the Regulation of the National Agency of Drug and Food Control No. 27 of 2022 concerning the Supervision of the Importation of Drugs and Food into the Territory of Indonesia. Under this regulatory framework, imported food products intended for commercial distribution must obtain several approvals before they can be legally marketed in Indonesia.
One of the key requirements is obtaining a Marketing Authorization (Izin Edar) issued by BPOM. This authorization confirms that the food product has been reviewed and approved for distribution in Indonesia. The Marketing Authorization also identifies the licensed importer responsible for the product, and the product may only be imported by the importer whose name is listed in the authorization. In addition, importers must obtain a Post-Border Import Certificate issued by BPOM, as stipulated under Article 3 paragraph (2) point (b) of BPOM Regulation No. 28 of 2023. This certificate forms part of the post-border supervision mechanism applied to food products entering Indonesia.
Another important regulatory requirement that importers must consider is Indonesia’s mandatory halal certification regime. Under Law No. 33 of 2014 concerning Halal Product Assurance, all products that enter, circulate, and are traded in Indonesia must be halal-certified, unless the products are clearly identified as non-halal. This regulation aims to provide certainty and protection regarding the halal status of products consumed or used by the public. The requirement applies to both domestically produced and imported products, including imported snack products.
Indonesian regulations allow the recognition of halal certificates issued by foreign halal certification bodies under certain conditions. Pursuant to Article 147 of Government Regulation No. 42 of 2024 concerning the Implementation of the Halal Product Assurance Sector, if a product has already obtained halal certification from a foreign halal certification body that has cooperation with the Indonesian Halal Product Assurance Agency (Badan Penyelenggara Jaminan Produk Halal or “BPJPH”), and the relevant product category falls within the scope of such cooperation, the importer may register the foreign halal certificate with BPJPH. Upon successful registration, the product will obtain a Foreign Halal Certificate Registration Number (Nomor Registrasi Sertifikat Halal Luar Negeri), which must be obtained before the product may be labelled as halal in Indonesia.
In certain circumstances, importers cannot rely on the recognition of foreign halal certificates and must instead apply for full halal certification in Indonesia. This may occur where the product has obtained halal certification from a foreign halal certification body that does not have cooperation with BPJPH, where the product category falls outside the scope of cooperation between the foreign certification body and BPJPH, or where the product has not obtained halal certification from any certification body. In these cases, the importer or the official representative of the manufacturer in Indonesia must apply for halal certification through BPJPH’s electronic system and comply with the applicable certification procedures.
Considering the various regulatory requirements applicable to imported snack products, businesses planning to enter the Indonesian market should carefully assess their compliance obligations. These include obtaining BPOM Marketing Authorization, securing the required import certificates, and ensuring compliance with Indonesia’s halal certification requirements. Failure to comply with these regulatory obligations may result in delays in import clearance, restrictions on product distribution, or potential regulatory sanctions.
Navigating Indonesia’s regulatory framework for food importation and halal certification can be complex, particularly for foreign businesses entering the Indonesian market. Schinder Law Firm has extensive experience assisting domestic and international clients in regulatory compliance matters, including food product registration with BPOM, halal certification and foreign halal certificate registration, as well as import licensing and regulatory structuring for consumer goods. For further information or consultation regarding the importation of food products into Indonesia, please feel free to contact us at info@schinderlawfirm.com.
Author:
Dewi Susanti