On September 24, 2026, Indonesia's Halal Product Assurance Organizing Agency (BPJPH) notified the WTO (G/TBT/N/IDN/197) of the Draft Decree of the Head of BPJPH on the Guidelines for the Implementation of the Halal Product Assurance System for Processing Services, with comments due by November 23, 2026. The proposed dates of adoption and entry into force are yet to be determined.
Under Indonesia's Government Regulation No. 42 of 2024, processing services are among the services subject to mandatory halal certification. The notified draft guidelines are intended to serve as an implementation reference for business actors in establishing the Halal Product Assurance System (SJPH) for processing services related to food, beverages, drugs, and cosmetics. CIRS Group has summarized the main contents below for reference.
Scope
1. Processing services are limited to services related to food, beverages, drugs, or cosmetics;
2. The scope of processing services listed in the guidelines includes, but is not limited to:
- Contract manufacturing services;
- Shared kitchen services;
- Water processing services;
- Milling services.
3. A processing service business actor refers to one that provides production facilities for use by other Business Actors to carry out part or all of the processes to produce products, while those using the production facilities of other Business Actors to produce foods, beverages, drugs, and/or cosmetics are users of processing services;
4. The guidelines apply to micro, small, medium, and large business actors, as well as foreign business actors.
Halal Commitment and Responsibility
1. Halal Policy: business actors should establish a written halal policy committing to provide human resources and infrastructure supporting the Halal Product Process (PPH), comply with halal regulations, use halal materials, and implement the PPH in accordance with regulations. The policy must be communicated to all personnel within the organization and to relevant stakeholders such as suppliers, partners, and distributors, and displayed in strategic locations such as offices, production areas, and warehouses.
2. Responsibilities: ensuring adequate resources for the establishment, implementation, and continuous improvement of the SJPH; appointing and reporting a Halal Supervisor (Penyelia Halal) to BPJPH as required by regulations; and, where appropriate, establishing a halal management team to ensure all personnel, including suppliers, partners, and distributors, maintain the integrity of halal assurance.
3. Training: arranging for Halal Supervisors to attend training organized by BPJPH, universities, and/or training institutions designated by BPJPH; providing internal and/or external training for personnel involved in SJPH implementation at least once a year; and retaining training records.
Materials
1. Materials cover raw materials, additives, processing aids, and packaging, as well as lubricants, greases, sanitizers in direct contact with materials or products, cleaning agents in direct contact with production facilities, and media for validating facility washing results;
2. Regardless of whether materials are supplied by the contracting client (the brand owner) or procured independently by the processing service provider (the contract manufacturer), the responsibility for verifying the halal status of materials rests with the processing service business actor;
3. All materials must meet halal requirements and applicable safety and quality regulations, be traceable with a clearly established halal status, and be free from non-halal or impure (najis) elements throughout sourcing, storage, handling, and use, supported by valid and verifiable documentation.
Halal Product Process (PPH)
1. The halal product process must be strictly, clearly, and consistently separated from non-halal processes, with physical and positional separation at minimum across locations, zoning, facilities, and equipment;
2. Sharing facility rules:
- Sharing facilities with non-halal products containing prohibited ingredients or heavy impurity (such as pork and its derivatives) is prohibited;
- Where facilities are shared with non-halal products containing only moderate impurity, purification in accordance with Islamic law must be completed before the facilities are reused for halal product processing, supported by a written purification procedure and documentation of each validated purification activity.
3. Handling contamination:
- Halal products contaminated with heavy impurity must be immediately withdrawn from circulation and destroyed; the affected area may be purified once, and if repeated contamination with heavy impurity occurs, the area may no longer be used for halal product processing;
- Halal products contaminated with moderate impurity must be immediately withdrawn and destroyed, and the affected area must be thoroughly purified again in accordance with Islamic law;
- Fully withdrawn contaminated products may be used for other purposes unrelated to the human halal food chain, provided the Halal Label is revoked first.
Products, Packaging, and Labelling
1. Halal certification cannot be conducted for the following products: products in the form of pigs or dogs; products whose packaging design, marks, symbols, names, or images are erotic, vulgar, or otherwise contrary to Islamic law; and products whose sensory characteristics (odor, taste, aroma) tend toward non-halal products or have been declared impure by fatwa;
2. Products must be physically separated from non-halal products or materials throughout preparation, processing, packaging, storage, and transport;
3. Packaging and labelling:
- Ensuring packaging materials do not contain non-halal substances;
- Ensuring packaging designs, marks, symbols, logos, names, and images are not misleading to consumers and do not violate Islamic principles;
- Affixing the halal label in accordance with BPJPH's provisions while observing the labeling regulations applicable to the relevant product category; the affixation of the halal label must be evidenced by a valid halal certificate.
4. Identification and traceability: identifying stored products (entry date, storage location, production date, etc.); establishing documented procedures to ensure that records of materials and production facility use remain traceable from raw material warehouses to finished product warehouses, so that the halal status of certified products can be traced to its source.
CIRS Reminder
According to Indonesia's Government Regulation No. 42 of 2024, the transition period for mandatory halal certification of major product categories, including foods, beverages, and cosmetics, will end on October 17, 2026, with enforcement starting October 18, 2026. These draft guidelines serve as the supporting implementation document for the processing service segment thereafter.
For businesses producing foods, beverages, drugs, and cosmetics through Indonesian contract manufacturers:
- Review the allocation of material halal verification responsibilities in contract manufacturing agreements — under the draft, such responsibility rests with the processing service Business Actor;
- Check in advance whether contract manufacturing facilities involve sharing facility arrangements between halal and non-halal products; where products involving moderate impurity are concerned, a written purification procedure with validated records must be established;
- For products also exported to markets outside Indonesia, pay attention to the interface between halal labelling and existing labeling compliance requirements;
- Monitor the final decree number, the entry-into-force date, and the alignment with the phased timeline of the halal certification obligation.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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