On July 23, 2026, Indonesia submitted notification G/TBT/N/IDN/189 through the WTO/TBT Committee, soliciting public comments on the Draft Regulation on the Renewal of Halal Certificates prepared by Indonesia's Halal Product Assurance Organizing Agency (BPJPH), with comments due by September 21, 2026.
The draft applies to all goods and services subject to the phased implementation of mandatory halal certification (including cosmetics), and sets out the procedures and requirements for renewing a Halal Certificate after changes to product ingredients, the Halal Product Process (PPH), or product development. CIRS Group has compiled and summarized the main contents below for your reference.
Background
Indonesia operates a mandatory halal certification system, based on Law No. 33 of 2014 on Halal Product Assurance, with its implementation governed by Government Regulation No. 42 of 2024 (PP 42/2024), which phases in mandatory halal certification for food, beverages, pharmaceuticals, cosmetics, chemical products, biological products, genetically engineered products, and consumer goods.
The Halal Product Assurance Organizing Agency (BPJPH) is the government-established body that implements Halal Product Assurance (JPH) and issues Halal Certificates based on written halal fatwas of the Indonesian Ulema Council (MUI). This draft aims to implement Article 90 of PP 42/2024 and specifically regulates the “renewal” of Halal Certificates.
Key Contents
1. Scope of Application
The draft applies to domestic and foreign business actors that obtain halal certification directly from BPJPH; it does not apply to Halal Certificates issued by Foreign Halal Institutions (LHLN) recognized by BPJPH.
The products covered are all goods and services subject to phased mandatory halal certification in Indonesia, including food, beverages, pharmaceuticals, cosmetics, chemical products, biological products, genetically engineered products, consumer goods, and related services such as slaughtering, processing, storage, packaging, distribution, sales, and serving.
2. Definition and Trigger of “Renewal”
Article 1(17) of the draft defines “Halal Certificate renewal” as: changes made by a business actor, after obtaining a Halal Certificate, to the ingredient composition, the Halal Product Process (PPH), and/or product development.
Article 2 provides that a business actor who changes the ingredient composition and/or PPH after obtaining a Halal Certificate must renew the certificate; the change must be submitted through the integrated electronic system; and the renewal does not change the original certificate number.
3. Types and Procedures of Renewal
- Ingredient/PPH changes (Article 3): include addition/replacement of ingredients and addition/reduction/replacement of PPH; these may be processed via (1) reporting to BPJPH, (2) examination/testing by an LPH (Halal Examination Institution), or (3) PPH mentoring by a PPH mentoring institution.
- Product development (Article 4): includes adding/changing products, adding/changing PPH locations, and adding trademarks; these must be processed via LPH examination/testing or PPH mentoring.
- Quantity limits (Article 6): for renewals processed through the “business-actor self-declaration” mechanism, a maximum of 10 product names may be added each time; once a single product type reaches 30 product names, a new certificate must be applied for via the LPH examination/testing mechanism.
CIRS Reminder
- Distinguish “renewal” from “initial certification/expiry renewal”: this draft addresses certificate “renewal” triggered by ingredient, process, or product changes after a certificate has been obtained; companies should determine applicability based on their own change circumstances.
- Mind the scope boundary: the draft applies only to Halal Certificates obtained directly from BPJPH; certificates issued by BPJPH-recognized Foreign Halal Institutions (LHLN) are not covered
- Affected categories, including cosmetics: cosmetics fall within the mandatory halal certification scope of PP 42/2024; cosmetic companies holding a BPJPH Halal Certificate in Indonesia that adjust formulas/ingredients, production processes, or product lines must renew their certificate under this draft.
- Refer to the official text: the draft is still at the consultation stage; the final provisions, regulation number, and effective date are subject to the regulation officially issued by BPJPH.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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