In May 2024, the Indonesian government postponed the halal certification requirement for micro, small and medium enterprises (MSMEs) following a restricted cabinet meeting chaired by the incumbent president and relevant ministers.

The decision extended the deadline for MSMEs to obtain halal certification from October 1, 2024 to October 17, 2026, citing the lack of preparedness of MSMEs to comply with the regulations. This change was later formalized (along with other changes) by Government Regulation No. 42 of 2024 on the Implementation of Halal Product Assurance (GR 42/2024), which revoked the former Government Regulation No. 39 of 2021 (GR 39/2021).

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GR 42/2024 introduces several new provisions and modifies existing ones under GR 39/2021, including, but not limited to, the extension of the halal certification deadline for food and beverage products and ingredients, as well as as products from slaughter and slaughter services, adjustments to the validity period of halal certificates, recognition of foreign halal certifications and clarification of the various obligations imposed on companies and halal inspection agencies .

Halal certification deadline

Previously, in GR 39/2021, the Indonesian government set October 17, 2024 as a uniform deadline for halal certification of food and beverage products, ingredients and slaughter-related services, regardless of scale of the company. However, GR 42/2024 introduces a revised deadline structure as follows:

For non-food products and drinks subject to halal certification, the deadlines remain as set in GR 39/2021:

Halal certification: Period and renewal

The Indonesian government had previously stipulated that halal certificates issued by the Indonesian Halal Product Assurance Organizing Body (BPJPH) would be valid for 4 years under GR 39/2021, with renewal applications required at least 3 months before the expiration date.

However, under GR 42/2024, halal certificates issued by BPJPH now have permanent validityprovided that there is no change in the composition of the material or in the process of the Halal Product (PPH). Therefore, no renewal process is necessary unless there are product changes. If changes are made to the composition of the materials, the PPH or the product development, companies must update their halal certificate by sending a request to the BPJPH accompanied by supporting documents.

Halal certification of foreign products

GR 42/2024 introduces provisions that clarify the halal certification process for foreign products. Companies wishing to obtain halal certification for foreign products must apply through their importer or an authorized representative domiciled in Indonesia. The request is required under certain conditions, including the following:

1. The country of origin does not have a foreign halal institution;
2. The foreign halal institution has a mutual recognition agreement but does not have the necessary competence to certify the product concerned;
3. There is no cooperation or mutual recognition agreement between the foreign halal institution and the Indonesian Halal Authority (BPJPH); Or
4. The company voluntarily applies for certification.

If the foreign product has already been halal certified in its country of origin by a recognized foreign halal institution with a mutual recognition agreement with BPJPH, the company is not required to apply for halal certification in Indonesia. However, the foreign halal certificate must be registered before the product can be distributed in Indonesia. Registration follows the procedure described in GR 39/2021 and the validity of the certificate will align with the period of the foreign halal certificate.

Additionally, GR 42/2024 modifies the deadline for renewal of the foreign halal registration certificate from 90 days (as stipulated in GR 39/2021) to 60 days before its expiration.

New obligations for businesses

GR 42/2024 introduces additional obligations for companies that have obtained halal certification, complementing the requirements already stipulated in GR 39/2021. These new obligations include:

1. Affix a halal label to halal-certified products;
2. Maintain the halal integrity of products that have received halal certification;
3. Separate locations, facilities and tools used for slaughtering, processing, storage, packaging, distribution, sale and display between halal and non-halal products;
4. Renew the Halal Certificate in the event of a change in the composition of the ingredients and/or the PPH; And
5. Report any changes in the composition of the material and/or PPH to BPJPH.

Companies are required to maintain the halal integrity of their products by obtaining a Halal Product Consistency Certificate, issued following an assessment of their Halal Product Assurance Scheme (HPS). This assessment must be carried out every four years. For micro and small businesses, the assessment will be based on a risk analysis.

Failure to comply with these additional obligations and other provisions of GR 42/2024 may result in administrative sanctions, including written reprimands, administrative fines, revocation of the halal certificate or withdrawal of distributed products.

Key takeaways

GR 42/2024 mainly extends the compliance deadline for obtaining halal certification for food, beverages, ingredients and services related to slaughter, especially for micro and small businesses and foreign products. The deadline for medium and large businesses remains unchanged at October 17, 2024, meaning these businesses must comply with mandatory halal certification to avoid administrative sanctions.

Additionally, businesses should be aware of the additional requirements and obligations introduced under GR 42/2024 to ensure full compliance with the updated regulations.