30 Sep 2026 · TAMA Insight
Overview of the Indonesian Regulatory Framework for Food Additives
Indonesia already has a regulatory framework governing food additives (bahan tambahan pangan or “BTP”), covering their permitted use, safety assessment, product registration, importation, labeling, and enforcement. Any new…
Indonesia already has a regulatory framework governing food additives (bahan tambahan pangan or “BTP”), covering their permitted use, safety assessment, product registration, importation, labeling, and enforcement. Any new regulation concerning food additive businesses would therefore need to be considered within this existing framework rather than as a standalone regime.
1. Scope of Food Additives
Under Government Regulation No. 86 of 2019 on Food Safety (“Government Regulation 86/2019”), food additives are substances intentionally added to food for a technological purpose during production, processing, preparation, treatment, packaging, storage, or transportation. They are not ingredients and are not intended to be consumed as food themselves.
Substances added solely to maintain or improve nutritional value are excluded from the definition of food additives and are subject to a separate regulatory framework. This distinction is relevant, for example, to the addition of vitamins, minerals, amino acids, and other nutritional substances to processed food.
2. Approval and Permitted Use
The types of permitted food additives and their use conditions are established under the applicable food safety regulations. Government Regulation 86/2019 provides that changes to the types of permitted food additives must be determined through a regulation of the Head of the Food and Drug Supervisory Agency (BPOM).
The determination of permitted additives and their maximum use levels must take into account valid scientific evidence and exposure assessment. The applicable assessment may consider toxicological benchmarks such as the Acceptable Daily Intake (ADI), as well as relevant food consumption data.
For processed food, maximum use limits are determined by BPOM, while the National Food Agency (Badan Pangan Nasional) has authority in relation to maximum limits for fresh food, in accordance with the respective regulatory mandates.
Food additives must also comply with the applicable Indonesian Food Codex standards. Where an applicable national standard is unavailable, the regulations provide for the use of relevant international standards in accordance with the applicable requirements.
3. Product Registration and Business Requirements
Food additives produced, imported, and distributed in Indonesia are subject to marketing authorization (izin edar) from BPOM. The requirements include compliance with applicable standards and possession of the relevant business or industrial licensing.
The Minister of Health’s Regulation No. 33 of 2012 on Food Additives (“MOH Regulation 33/2012”) further provides that food additive producers must have the required industrial licence and be registered with BPOM. Importation of food additives is also subject to approval from BPOM.
Accordingly, a business dealing with food additives may face requirements at both the business-activity level and the product level, depending on the nature of its activities.
4. Safety, Testing, and Use Restrictions
Food additives may only be used within the maximum levels established for the relevant food category. The use of prohibited substances as food additives is also not permitted.
The applicable framework is based on food safety and risk assessment considerations. In addition to the assessment used in establishing permitted additives and maximum levels, the regulations contain requirements concerning the specifications of food additives, including matters relating to purity and identification.
Food businesses using additives must therefore ensure that the substances used and their levels of use comply with the applicable requirements for the relevant food category.
5. Labeling and Related Materials
Foods containing food additives or additive preparations are subject to the applicable food labeling requirements. The labeling framework operates alongside the substantive restrictions on the use of additives and provides a mechanism for identifying the additives used in processed food.
Food-contact packaging and processing aids are regulated separately from food additives, although they form part of the broader food safety framework. Packaging materials, for example, are subject to specific BPOM requirements concerning permitted materials and, in certain circumstances, prior approval for importation.
Processing aids (bahan penolong) are likewise subject to separate requirements under Government Regulation 86/2019, including requirements concerning permitted substances and, where applicable, maximum limits based on food safety risk assessment.
6. Enforcement and Sanctions
The existing framework provides several forms of enforcement for violations involving food additives.
Under MOH Regulation 33/2012, BPOM may impose administrative measures including written warnings, temporary restrictions on distribution, product recalls, destruction of products that do not meet applicable safety or quality requirements, and revocation of marketing authorization.
Broader food safety legislation may also provide for additional administrative, civil, or criminal consequences depending on the nature of the violation. In particular, the use of additives above the permitted limits or the use of prohibited substances may give rise to criminal liability where the relevant statutory elements are satisfied.
Businesses may also face consumer claims where unsafe products cause loss or harm, subject to the applicable consumer protection provisions.
7. Related Regulatory Frameworks
Food additives should be distinguished from substances added to improve or maintain nutritional value. The latter are subject to a separate BPOM framework, including BPOM Regulation No. 30 of 2021 on Requirements for the Addition of Nutrients and Non-Nutrients to Processed Food.
A similar distinction applies to processing aids and food-contact packaging materials, which are regulated under separate provisions even though they may arise within the same production process.
Conclusion
Indonesia’s existing food additive framework already regulates the principal stages of the food additive business, including the determination of permitted substances, safety and exposure assessment, maximum use levels, product registration, production and importation requirements, labeling, and sanctions.
Accordingly, any new regulation concerning food additive businesses would need to be coordinated with the existing framework, particularly Government Regulation 86/2019, MOH Regulation 33/2012, the applicable BPOM regulations, and the broader food safety and consumer protection legislation. The key issue would be how any new requirements are integrated with, or further specify, the requirements that already apply to food additives in Indonesia.
This alert is part of a series examining regulatory developments affecting food, food additives, and related businesses in Indonesia. Please feel free to contact us should you wish to discuss these developments further.
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