On August 31, 2026, the Head of the Halal Product Assurance Organizing Agency (BPJPH) of Indonesia enacted the Decree of the Head of BPJPH No. 301 of 2026 on Products and Ingredients Exempted from the Halal Certification Obligation. The Decree is intended to implement Article 70 of Government Regulation No. 42 of 2024 (GR 42/2024), providing legal certainty regarding products and ingredients that are not required to be halal certified. The full text of the Decree, together with its Annex, comprises 201 pages, and it will enter into force six months from the date of enactment.
Nine Criteria for Exemption
- Derived from nature, either unprocessed or subjected only to minimal processing;
- Considered to pose no risk of containing and/or coming into contact with non-halal substances;
- Not derived from protected plants or animals;
- Not among products and ingredients that may disturb, harm, and/or endanger health, and free from narcotics, psychotropics, and/or nicotine;
- Not among products and ingredients whose use is prohibited under laws and regulations;
- Classified based on the characteristics, origin, properties, and safety of each product and ingredient, the prevalence of the process, and the risk of containing or being contaminated by non-halal substances;
- Containing only a single component, i.e., in the form of a single compound;
- Not causing any change to the origin of the material; and/or
- Without the addition of additives, auxiliary materials, and/or other substances, or using additives, auxiliary materials, and/or other substances that do not affect critical halal points or the risk of contamination by non-halal substances.
Exemption List Covering Seven Categories
The Annex to the Decree classifies the exempted products and ingredients into seven categories:
- Plant-derived products and ingredients
- Products and ingredients derived from non-slaughtered halal animals
- Algae-derived products and ingredients
- Natural water
- Chemicals and/or purified products of natural substances: aluminum, zinc, magnesium oxide, zinc oxide, sodium chloride, silver, etc.
- Synthetic inorganic chemicals and/or synthetic organic chemicals not derived from microbial fermentation: covering pharmaceuticals, dyes, etc.
- Others: pure cotton (absorbent cotton), cellulose and its derivatives, polyethylene, polyvinyl alcohol (PVA), etc.
Processing Methods Falling under “Minimal Processing”
The Decree also specifies that products and ingredients processed by means of washing, peeling, cooling, freezing, cutting, drying, salting, grinding, blanching, heating, homogenization, centrifugation, sieving, filtering, pressing, pre-treatment, size reduction, evaporation, sorting and classification, and/or fractional distillation still fall within the scope of minimal processing.
Exemption ≠ “Free from Management”
1. Products and ingredients on the list are not required to obtain a halal certificate; however, where necessary, businesses must submit supporting documents—such as the production process flow, product composition, the Certificate of Analysis (CoA) or equivalent documents—for the purposes of halal verification and/or testing;
2. Plant ingredients derived from genetic engineering processes must hold a food safety certificate or approval for genetically engineered products as required by applicable laws and regulations;
3. Dynamic supplement mechanism: for products and ingredients that meet the exemption criteria but are not yet listed in the Annex, stakeholders may submit an application, together with supporting documents, to the BPJPH Deputy for Partnership and Halal Standardization (through the Directorate of Halal Standardization).
Impact on and Recommendations for Cosmetics Companies
1. The exemption list is highly relevant to cosmetic ingredients: companies exporting cosmetics and their ingredients to Indonesia are advised to check their formula ingredients one by one against the Annex; ingredients included on the list no longer need to be covered by halal certification, which helps reduce certification costs;
2. Document retention is key: exemption does not mean exemption from verification. Businesses should systematically retain documents such as the production process flow, composition information, and CoAs for submission during verification and/or testing; for genetically engineered plant ingredients, ensure that the relevant certificates or approvals are complete;
3. Pay attention to the transition period and practical implementation interpretation: the period from October 18, 2026 to February 28, 2027 is set as the transition period. Enterprises may proactively communicate, as appropriate, with Indonesian halal certification bodies (LPH) and importers to confirm the effective timeline of the annex list. For products already falling within the scope of halal control, it is recommended to keep track of relevant developments and make preparations for halal certification and SHLN registration in due course;
4. Make use of the dynamic supplement mechanism: for proprietary ingredients that meet the exemption criteria but are not listed in the Annex, companies may apply to BPJPH for their addition, preparing supporting documents such as the production process flow, composition, and CoAs in advance.
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