28 Sep 2026 · TAMA Insight
New Guidance on Products and Materials Exempted from Halal Certification in Indonesia
Indonesia has introduced more specific guidance on products and materials that are exempted from the obligation to obtain halal certification. Through Decree of the Head of the Halal…
Indonesia has introduced more specific guidance on products and materials that are exempted from the obligation to obtain halal certification.
Through Decree of the Head of the Halal Product Assurance Agency (BPJPH) No. 301 of 2026 on Products and Materials Exempted from the Obligation to be Halal Certified (“BPJPH Decree No. 301/2026”), BPJPH sets out criteria and classifications for products and materials that may be excluded from the halal certification requirement.
The decree provides a more detailed framework for determining which products and materials fall within the exemption, including criteria concerning their origin, processing, composition, and potential exposure to non-halal materials.
The exemption should be understood within the broader halal product assurance framework in Indonesia. It does not constitute a general exemption for all products or materials that are considered low risk. Rather, the relevant product or material must meet the applicable criteria and fall within the classifications provided under the decree.
1. Specific Criteria for Products and Materials Exempted from Halal Certification
BPJPH Decree No. 301/2026 identifies criteria to determine whether a product or material may be exempted from the halal certification obligation.
In general, the criteria focus on products or materials that have a relatively straightforward origin, composition, and processing history and that do not present the types of halal risks contemplated by the regulation.
Among other considerations, the criteria address whether the product or material:
- originates from nature and is either unprocessed or subject only to limited processing;
- is considered not to pose a risk of containing or coming into contact with non-halal materials;
- does not originate from protected plants or animals;
- does not constitute a product or material that may endanger health and does not contain narcotics, psychotropics, and/or nicotine;
- is not prohibited under other applicable laws and regulations;
- can be classified based on its characteristics, origin, processing practices, and potential halal risks;
- consists of a single component or compound;
- does not involve a change in the origin of the material; and
- does not contain additives, processing aids, or other materials that create a relevant halal risk or increase the potential for contamination by non-halal materials.
These criteria are intended to be read together with the classifications and product lists provided under BPJPH Decree No. 301/2026.
Accordingly, satisfying one characteristic alone would not necessarily establish that a product or material falls within the exemption.
2. Seven Categories of Products and Materials
In addition to the criteria, BPJPH Decree No. 301/2026 identifies seven broad categories of products and materials that may fall within the exemption.
These include:
- Products and materials originating from plants
This category covers certain plant-based products and materials that meet the applicable criteria concerning origin, processing, composition, and halal risk. - Products and materials originating from halal animals that do not require slaughter
This includes certain products derived from animals for which halal status does not depend on a specific slaughtering process, subject to the applicable requirements. - Products and materials originating from algae
Certain algae and seaweed-derived products or materials may fall within this category where the relevant criteria are satisfied. - Products and materials originating from natural water
Natural water and certain minimally processed water products may fall within the category, subject to the applicable criteria. - Chemicals obtained through mining and/or purification of natural materials
Certain inorganic chemical materials obtained through mining or purification may be covered where the relevant requirements are met. - Inorganic and/or organic synthetic chemicals
Certain chemically synthesized materials may fall within the exemption where they satisfy the prescribed criteria. The relevant classification includes conditions concerning the production process, including the exclusion of certain materials derived from microbial fermentation. - Other products and materials
BPJPH Decree No. 301/2026 also provides a mechanism for products or materials that satisfy the relevant exemption criteria but are not yet included in the existing classification to be proposed for consideration.
The detailed scope of each category should therefore be assessed against the decree and its annex rather than based solely on the general description of the category.
3. Limited Processing Does Not Automatically Mean Exemption
One of the relevant considerations under the new framework is whether a product or material is obtained from nature without processing or only through limited processing.
The decree recognizes certain forms of limited processing, including processes such as washing, peeling, cooling, freezing, and fractional distillation, subject to the applicable provisions.
However, the existence of limited processing should not by itself be treated as sufficient to establish an exemption.
The product or material must also satisfy the other relevant criteria and fall within the applicable classification.
This distinction is particularly relevant for businesses dealing with agricultural products, natural materials, food ingredients, chemicals, and other raw materials that may undergo processing before being supplied or used in Indonesia.
4. Documentation and Supporting Evidence
The exemption from halal certification does not necessarily mean that businesses can disregard documentation concerning the origin and processing of their materials.
Where necessary for halal-related examination or verification, businesses may be required to provide supporting information demonstrating that the relevant product or material satisfies the applicable criteria.
Depending on the circumstances, supporting documentation may include information concerning the production process or a Certificate of Analysis (CoA).
For businesses, maintaining appropriate documentation may therefore be important even where the relevant material is not subject to halal certification.
In practice, businesses should be able to substantiate, where required, the material’s origin, composition, processing method, and other characteristics relevant to the exemption criteria.
5. Genetically Modified Plant Materials
BPJPH Decree No. 301/2026 also addresses products or materials originating from genetically modified plants.
The fact that a material originates from a plant does not, on its own, determine whether it qualifies for the exemption. Specific requirements concerning food safety certification or approval for genetically modified products may continue to apply.
Businesses using genetically modified plant-derived materials should therefore assess halal requirements separately from applicable food safety and genetically modified product requirements.
Compliance with one regulatory requirement does not necessarily replace compliance with another.
6. Products or Materials Not Yet Listed
A product or material may satisfy the relevant exemption criteria but not yet appear in the list provided under BPJPH Decree No. 301/2026.
The decree provides a mechanism through which stakeholders may propose additional products or materials for consideration.
The proposal may be supported by relevant technical documentation, including information concerning the production process and analytical documentation. BPJPH may then assess the proposal, including by considering developments in science and technology and through consultation with relevant stakeholders.
This mechanism is relevant for businesses using specialized raw materials or technical substances that are not expressly identified in the current list.
Until a product or material is formally included within the applicable framework, businesses should avoid assuming that it is automatically exempt merely because it appears to satisfy the general characteristics of an exempt product or material.
7. Relationship with Products That Are Non-Halal
The exemption framework should also be distinguished from the regulatory treatment of products that are themselves non-halal.
A product that is non-halal does not become eligible for the exemption merely because it is not required to obtain a halal certificate.
The applicable halal product assurance framework separately addresses products that are not halal, including requirements concerning the provision of information indicating their non-halal status.
Accordingly, businesses should distinguish between:
- products or materials that qualify for an exemption from halal certification; and
- products that are non-halal and are subject to applicable non-halal labelling or information requirements.
These are different regulatory categories and should not be treated interchangeably.
8. Practical Implications for Businesses
The new guidance may be particularly relevant for manufacturers, importers, distributors, and businesses using raw materials or technical substances in their production processes.
Before treating a material as exempt from halal certification, businesses should consider at least the following:
First, determine whether the product or material falls within one of the categories identified under BPJPH Decree No. 301/2026.
Second, assess the product against the relevant exemption criteria, including its origin, processing, composition, and potential exposure to non-halal materials.
Third, review the applicable annex and product classification rather than relying solely on a general description of the material.
Fourth, maintain appropriate technical documentation that can support the material’s status if requested during verification or examination.
Finally, consider other regulatory requirements that may apply independently, including food safety, genetically modified product, import, labelling, or sector-specific requirements.
This assessment may be particularly important for businesses that use large numbers of raw materials or technical ingredients, as the regulatory status of each material may depend on its specific source and manufacturing process.
Conclusion
BPJPH Decree No. 301/2026 provides more specific guidance on products and materials that may be exempted from the obligation to obtain halal certification in Indonesia.
The framework is based on specified criteria and product/material classifications, with particular attention to the origin, processing, composition, and potential halal risks of the relevant material.
The exemption should not be understood as a blanket exemption for natural, minimally processed, or low-risk materials. Businesses should assess the specific material against the criteria and classifications established under the decree and, where relevant, maintain supporting documentation demonstrating compliance.
For businesses operating in Indonesia, particularly manufacturers and importers using multiple raw materials or technical substances, the new framework may provide greater clarity in determining which materials fall within the halal certification regime and which may be exempt, while other regulatory obligations may continue to apply independently.
This alert is part of a series examining recent developments in Indonesia’s halal product assurance framework. As the regulatory framework continues to develop, businesses should continue to monitor relevant developments and assess the requirements applicable to their products, materials, and production processes, particularly where the halal certification status of specific materials may affect their operations in Indonesia.
If you would like to discuss how these developments may affect your business or have any questions regarding specific products or materials, please feel free to contact us.
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