Key Takeaways
Indonesia has extended the mandatory halal-certification deadlines for several product and service categories. Most affected categories will become subject to mandatory certification from 18 October 2028, while later deadlines apply to certain medicines and medical devices.
- The applicable deadline varies according to the product or service category, business scale, and origin of the product.
- The extended deadline does not remove the underlying certification obligation.
- The conformity-assurance provisions for foreign halal products have been revoked, withdrawing the pre-import verification framework.
- Other parts of the halal-compliance regime remain relevant, including the rules for non-halal declarations, administrative sanctions and ongoing compliance by businesses that already hold halal certificates.
Approximate reading time: 5 minutes
The government recently issued Government Regulation No. 40 of 2026 on Amendments to Government Regulation No. 42 of 2024 on the Administration of Halal Product Assurance (“Regulation“). The Regulation entered into force on 14 October 2026 upon its promulgation.
The Regulation gives businesses additional time to comply with mandatory halal certification requirements for several product and service categories that were due to take effect on 18 October 2026. It also revokes the provisions on conformity assurance for foreign halal products entering Indonesia. These provisions supported the pre-import verification framework under Halal Product Assurance Agency (Badan Penyelenggara Jaminan Produk Halal or “BPJPH“) Regulation No. 4 of 2026, which required verification of shipments before importation. That framework is now withdrawn.
While the extension grants affected businesses additional implementation time, it does not represent a loosening of Indonesia’s halal-compliance regime. Businesses that already hold halal certificates remain subject to the obligations attached to those certificates, including the requirement to implement the halal product assurance system (Sistem Jaminan Produk Halal or “SJPH“) consistently and to ensure that production, processing, storage, packaging, distribution, sales, and serving activities remain halal.
Which Products and Services Are Affected?
The Regulation does not introduce a single deadline for the affected products and services. The applicable deadline depends on the relevant product or service category, the scale of the business, and, in certain cases, whether the product is domestically produced or imported.
Imported products. Mandatory halal certification for imported food, beverages, slaughter products, and slaughter services will apply from 18 October 2028. The Regulation links this date to the completion of mutual-recognition arrangements, under which Indonesia recognises halal certificates issued by approved foreign halal certification bodies. This represents one of the most commercially significant changes introduced by the Regulation for multinational businesses exporting products into Indonesia.
Product categories subject to mandatory halal certification from 18 October 2028. The revised deadline also applies to:
- traditional medicines, quasi-drugs, health supplements, and cosmetics;
- chemical and genetically engineered products related to food, beverages, medicines or cosmetics; and
- specified consumer goods (including certain apparel, accessories, household products, office supplies) and Class A medical devices made from or containing animal-derived materials.
Related services. Services connected with the above product categories generally follow the deadline applicable to the relevant product category. Services related to food, beverages and slaughter products, other than slaughter services, will also become subject to mandatory halal certification from 18 October 2028. This represents a notable postponement for related services, as the underlying food, beverage, and slaughter-product categories have been subject to mandatory halal certification since 18 October 2024.
Micro and small enterprises. For micro and small enterprises, the mandatory halal certification for food, beverages, slaughter products, and slaughter services will apply from 18 October 2028.
Longer sector-specific timelines. Mandatory halal certification will apply to the following categories from the dates shown:
- over-the-counter medicines, limited over-the-counter medicines, and Class B medical devices: 18 October 2029; and
- prescription medicines other than psychotropics and Class C medical devices: from 18 October 2034.
Non-halal products. Products made from non-halal (haram) materials remain exempt from halal certification but must comply with the applicable non-halal declaration requirements.
Key Regulatory Implications
- Pre-import verification framework withdrawn
Prior to the amendment, BPJPH Regulation No. 4 of 2026 required administrative and physical checks of foreign halal products before they could be imported. The Regulation revokes the provisions on conformity assurance for foreign halal products, and declares them no longer effective.
The pre-import verification process should therefore no longer be treated as an import requirement. Businesses that had been preparing to implement it should update their import-compliance planning.
2. Non-halal declaration requirements continue to apply
The Regulation does not affect the requirements under BPJPH Regulation No. 3 of 2026 on the Form and Procedures for Non-Halal Declarations. Therefore, products made from non-halal (haram) materials remain exempt from halal certification but must carry the prescribed non-halal declaration where applicable.
Whether a product is treated as non-halal does not depend on its ingredients alone. Factors such as circumstances in the production process involving contact with, or contamination by, impure or non-halal materials or products may also affect the determination.
3. Administrative sanctions framework remains relevant
The Regulation does not affect the existing administrative sanctions framework.
For a detailed discussion on the sanctions framework, please refer to our previous client update here.
Recommended Next Steps
In light of the extension, businesses should focus on the following areas:
- Scope and timeline assessment. Reassess which products and related services require halal certification or non-halal declarations, identify the applicable implementation deadlines, and prioritise any outstanding compliance matters.
- Certification and labelling readiness. Continue addressing outstanding halal-certification applications, labelling requirements and non-halal declaration requirements that remain applicable notwithstanding the revised implementation timelines.
- Import-compliance planning. Review existing import procedures and implementation plans in light of the revocation of the pre-import verification framework. Businesses should also continue monitoring guidance from BPJPH concerning imported halal products and any implementing regulations issued under the Regulation.
- Ongoing compliance for certified products. Businesses that already hold halal certificates should continue implementing SJPH and reviewing their supply-chain, production and internal-control arrangements to ensure they remain halal. Certification should be supported by continued compliance and documented remediation.
If you have any queries on the above, please reach out to our Partner listed on this page.
For regional Competition matters, please see Rajah & Tann Asia’s Competition Practice for more information.
Contribution Note:
This Legal Update is contributed by the listed Contact Partner and Senior Associate Tsurayya Nurrahma, with the assistance of Associates Danil Pratama and Muhammad Rafiif Reynaldi.
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