On August 28, 2026, Indonesia notified the World Trade Organization (WTO) of TBT notification G/TBT/N/IDN/192, soliciting public comments on the draft Guidelines for the Implementation of the Halal Product Assurance System (SJPH) for Genetically Engineered Products. The deadline for submitting comments is October 27, 2026. The guidelines aim to establish a systematic halal compliance framework for enterprises utilizing genetic engineering technology in the production of goods, covering sectors including food, beverages, pharmaceuticals, and cosmetics.
Background
Under Article 155(2)(g) of Government Regulation No. 42 of 2024 on the Implementation of Halal Product Assurance, genetically engineered products are classified as products subject to mandatory halal certification.
However, genetic engineering techniques involve the manipulation of organisms and materials, necessitating more in-depth halal verification. To address this, BPJPH has developed these guidelines to provide specific reference for business actors, halal supervisors, halal auditors, and other stakeholders in implementing the SJPH for genetically engineered products.
Scope
The guidelines apply to raw materials and products related to food, beverages, pharmaceuticals, and cosmetics that are produced through genetic engineering techniques, encompassing the following four categories of genetically engineered products:
- genetically engineered plants
- genetically engineered animals
- genetically engineered plant cells or animal cells
- genetically engineered microorganisms
Key Considerations for Cosmetics Companies
For cosmetics companies, the content of the guidelines relevant to the cosmetics sector primarily concerns the application of genetically engineered microorganisms and their derivatives in cosmetic raw materials, specifically including the following key requirements:
1. Halal Determination Principles for Genetically Engineered Microorganisms
The guidelines establish clear criteria for determining the halal status of genetically engineered microorganisms: genetically engineered microorganisms are inherently halal, provided they are not harmful and are not contaminated with najis (impurities).
2. Strict Restrictions on Gene Sources
The guidelines stipulate that microbial materials produced through genetic engineering methods should not be inserted with genes derived from pigs or humans. Additionally, the storage medium for master seed preservation should use halal media. Furthermore, the antibiotics or marker genes used should not be derived from clinical antibiotics.
3. Halal Review of Critical Production Stages
The guidelines identify eight critical stages in the production of genetically engineered products that require halal review:
- determination of gene source;
- use of vectors and host organisms;
- growth media;
- fermentation process;
- harvesting;
- purification;
- use of supporting materials;
- final product.
Cosmetics companies whose raw material production involves genetic engineering technology should ensure that all the above stages comply with halal requirements.
SJPH Implementation Requirements
The guidelines require enterprises producing genetically engineered products to establish and maintain a comprehensive Halal Product Assurance System (SJPH), covering the following main areas:
1. Halal Policy and Organizational Framework
- Enterprises should develop a written halal policy committing to the use of halal genetically engineered raw materials, production in accordance with halal processes, and output of halal products.
- Enterprises should appoint a Halal Supervisor and/or a halal management team.
- Halal supervisors for micro, small, and medium enterprises should hold a halal supervisor training certificate and/or a competency certificate; medium-large and foreign enterprises should hold both a training certificate and a competency certificate.
2. Production Process Control
- Enterprises should physically separate the production premises, equipment, and tools used for halal and non-halal products, and such facilities should not be used interchangeably.
- Enterprises should establish and implement documented Halal Product Process (PPH) procedures covering the entire workflow of raw material management, production process control, and product management.
3. Traceability and Non-Conforming Product Handling
- Enterprises should establish a product traceability system to ensure full-chain traceability of raw material sourcing information.
- For products that do not meet halal criteria, enterprises should execute procedures including quarantine, investigation, risk assessment, disposition decisions, and product recalls when necessary.
4. Internal Audit and Periodic Reporting
- Enterprises should conduct internal audits at least once a year to monitor the implementation of the SJPH and report the audit results to BPJPH.
- In addition, enterprises should report their raw material composition lists and/or Halal Product Process (PPH) information to BPJPH every six months, and report promptly in the event of any changes.
CIRS Reminder
As Indonesia's October 2026 deadline for mandatory halal certification approaches, halal compliance requirements for various product categories are being rapidly refined. The release of these SJPH implementation guidelines for genetically engineered products signifies that Indonesia's halal regulatory framework has extended into the biotechnology sector.
For cosmetics companies, if product raw materials involve genetically engineered microorganisms, the following key points require particular attention:
- Review whether raw material supply chains involve genetic engineering technology, and confirm that gene sources do not contain porcine or human genes;
- Ensure that the growth media, antibiotics, and marker genes of genetically engineered microorganisms all meet halal requirements;
- Establish a comprehensive SJPH system covering genetically engineered raw materials, ensuring halal compliance traceability across all critical production stages;
- Monitor the final publication date of these guidelines and their effective date (the guidelines stipulate that they shall take effect upon the conclusion of the phased halal certification obligation for genetically engineered products).
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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