On October 12, 2026, the Halal Product Assurance Organizing Agency (BPJPH) of Indonesia issued Decree No. 372 of 2026 of the Head of BPJPH on the Guidelines for the Implementation of the Halal Product Assurance System for Genetically Engineered Products, which took effect on October 18, 2026. The Guidelines expressly bring cosmetic materials produced through genetic engineering within the scope of products subject to halal certification.
CIRS Group has compiled and summarized the main contents of the Guidelines and their impact on cosmetic companies as follows, for reference.
Six Key Requirements Established by the Guidelines
The main text of the Guidelines comprises five chapters (including annexes) and establishes requirements mainly in the following six aspects:
1. Defining the scope of application of genetically engineered materials, limiting them to the four categories of food, beverages, drugs, and cosmetics;
2. Classifying genetically engineered materials by source into four categories — plants, animals, plant or animal cells, and microorganisms — and specifying the halal certification obligations applicable to each;
3. Setting out the rules for determining the halal status of genetically engineered materials of microbial origin, including the requirements on culture media, gene sources, and purification;
4. Listing the eight critical control points at the production stages that are subject to halal review;
5. Providing the requirements for implementing SJPH in respect of production premises and equipment, written procedures, purification, products, packaging and labeling, traceability, and other aspects;
6. Establishing ongoing compliance obligations covering internal audits, management reviews, and periodic reporting to BPJPH.
Scope of Application: Genetically Engineered Materials Cover Only Food, Beverages, Drugs, and Cosmetics
The Guidelines specify that the materials used in the Halal Product Process (PPH) comprise raw materials, processed materials, additives, and processing aids, of which those produced through genetic engineering processes cover only the four categories of food, beverages, drugs, and cosmetics. The forms of genetic engineering processes include recombinant DNA processes and hybridoma technology (cell fusion).
The production stages subject to halal review cover eight steps, namely the determination of gene sources, the use of vectors and host organisms, growth media, the fermentation process, harvesting, purification, the use of auxiliary materials, and the finished product. For cosmetic companies, the three steps of fermentation, purification, and culture media are usually where the halal risks are most concentrated.
Four Source Categories and Their Halal Certification Obligations
The Guidelines classify genetically engineered materials into four categories by source and specify the certification obligations applicable to each:
- Genetically engineered products of plant origin: seeds and their harvested products are exempted from the obligation of mandatory halal certification where this can be evidenced by a food safety certificate or an approval document for genetically engineered products; processed food raw materials, food additives, processing aids, and other derived products are handled in accordance with the mandatory certification provisions applicable to the food and beverage category.
- Genetically engineered products of animal origin: they must originate from live halal animals slaughtered in accordance with SJPH provisions, and their products must obtain halal certification.
- Genetically engineered products of plant or animal cell origin: animal cells must originate from live halal animals slaughtered in accordance with SJPH provisions, and their products must in principle obtain halal certification; however, this mandatory certification obligation will apply following an assessment based on developments in science and technology, which means that it is not yet applicable in practice at the present stage.
- Genetically engineered products of microbial origin: products produced through fermentation or other biotechnological processes using bacteria, yeasts, molds, or other microorganisms as host organisms, which may include food, beverages, drugs, cosmetics, ingredients, processing aids, enzymes, food additives, and other products; such products fall within those required to obtain halal certification, and the halal critical points in the production process must be taken into account during certification.
Impact on Cosmetic Companies and Recommendations
The Guidelines took effect on October 18, 2026, and are the first dedicated implementation guidelines for the halal certification of genetically engineered products in Indonesia, whereas the start date of the mandatory halal certification obligation for categories such as cosmetics has been postponed to October 17, 2028.
The two should be viewed separately: the Guidelines themselves have already taken effect and may serve as the technical basis for companies to establish their systems and apply for certification; the mandatory obligation has not yet started to run, but the certification requirement itself has not been removed.Companies concerned are advised to carry out the following work:
1. Identify materials of genetic engineering origin: focus on checking functional ingredients produced by fermentation and ingredients obtained through recombinant technology, and confirm whether they fall within the scope of application of the Guidelines.
2. Request halal documentation relating to genetic engineering from suppliers in advance: for raw materials that appear neither on the mandatory certification list nor on the exemption list, it is necessary to obtain the production process flow, the composition, and the certificate of analysis, supplemented by a statement of freedom from heavy najis, a halal questionnaire, a material safety data sheet (MSDS), and laboratory test results.
3. Verify the culture media and gene sources: confirm that the culture media of the host microorganisms do not contain components of porcine origin, that no genes of human or porcine origin have been used, and that no genes encoding antibiotic resistance are contained, among others;
4. Build the SJPH documentation system in accordance with the Guidelines: complete the records of separate premises and equipment for the processing, storage, and packaging stages, the application materials for shared facilities, the graded purification procedures and the training and dissemination records, and ensure that the written procedures covering the three aspects of materials, processes, and products are traceable.
5. Establish a regular reporting mechanism after obtaining certification: arrange for the submission of reports on raw material composition and the production process once every six months, and report to BPJPH in a timely manner whenever the formulation or the process changes; at the same time, complete internal audits and management reviews on an annual basis and submit the results.
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