Indonesia’s Non-Halal Product Labeling: New Regulation On Design And Labeling Guidelines For Non-Halal Labels.
The Halal Product Assurance Organizing Agency (Badan Penyelenggaran Jaminan Produk Halal or “BPJPH”), the Indonesian government agency that oversees the country’s Halal Product Assurance system, including halal certification, has issued a regulation on design and labelling guidelines for non-halal labels.
BPJPH Regulation No. 3 of 2026, dated July 23, 2026, regarding Design and Labeling Guidelines for Non-Halal Labels (“BPJPH Regulation No. 3/2026”) is an implementing regulation for Law No. 33 of 2014 regarding Halal Product Assurance, as amended by Law No. 6 of 2023 regarding the Stipulation of Government Regulation in Lieu of Law No. 2 of 2022 regarding Job Creation to Become Law (the “Halal Assurance Law”), and Government Regulation No. 42 of 2024 regarding the Implementation of Halal Product Assurance.
Among other requirements, the Halal Assurance Law requires products that have obtained halal certification to bear a halal label and requires non-halal products be bear a non-halal label before being circulated in Indonesia.
BPJPH Regulation No. 3/2026 provides further guidance on the (i) criteria for non-halal labeling; (ii) the design of the non-halal label; and (iii) guidelines for non-halal labeling.
Criteria for Non-Halal Labeling
Under BPJPH Regulation No. 3/2026, whether a product is required to bear a non-halal label is determined based on two criteria: (i) the materials used and (ii) the production process.
The material criteria consider the materials used in a product, taking into account animal origin, plant origin, alcohol content, microorganisms, production through chemical, biological processes, or genetic engineering processes, parts of the human body, and/or najs or mutanajis materials.
The production process criteria consider how a product is processed, including the locations, facilities, production equipment, and washing facilities used in the processing, storage, packaging, distribution, sale, and/or serving of the product.
Design of the Non-Halal Label
Under BPJPH Regulation No. 3/2026, there are two non-halal label designs, namely (i) a non-halal label for products originating from pigs and their derivatives; and (ii) a non-halal label for products originating from materials other than pigs and their derivates, or products produced through a non-halal production process.
Non-halal label for products originating from pigs and their derivatives:
Non-halal label for products originating from materials other than pigs and their derivates, or products produced through a non-halal production process:
Guidelines for Affixing the Non-Halal Label
BPJPH Regulation No. 3/2026 provides that the non-halal label may be affixed to the packaging and/or other appropriate parts or locations of the product, provided that the label is:
- placed proportionally on the product;
- positioned in a location that is easily visible and readable;
- placed against a background that does not obscure the size, shape, or color of the non-halal label; and
- not easily erased, removed, or damaged.
For products that are not sold in retail or individually packaged form, including products sold in bulk, the non-halal label may instead be affixed to containers, dispensers, packaging, or other marking surfaces that are easily visible and readable.
In addition to affixing the non-halal label, business actors selling products in bulk are required to attach supporting documentation relating to the products. Such documentation may include the production process flow, product composition, certificate of analysis or similar documents, questionnaires, and/or statements. The documentation must state that the products originate from prohibited (haram) materials and/or involve a non-halal production process.
Application to Pharmaceutical, Biological and Medical Products
The non-halal labeling requirements under BPJPH Regulation No. 3/2026 also apply to pharmaceutical products, biological products, and medical devices.
However, business actors should note that the affixation of the non-halal label must also take into account the labeling requirements issued by the Indonesian Food and Drug Authority (Badan Pengawas Obat dan Makanan or “BPOM”) and the Ministry of Health, as applicable.
Transition Period for Compliance
BPJPH Regulation No. 3/2026 provides a transition period for business actors to comply with the new non-halal labeling requirements.
Products that had entered, been circulated, or been traded in Indonesia prior to the enactment of this regulation are given a maximum of 12 months to comply with the new non-halal labeling requirements.
Business actors should therefore review their existing products, packaging and labeling arrangements to determine whether any changes are required during the transition period. (27 August 2026)
