On July 23, 2026, the Indonesian Halal Product Assurance Agency (BPJPH) issued the Regulation of BPJPH No. 3 of 2026 on the Form and Procedures for Displaying Non-Halal Information, effective as from the date of promulgation. The Regulation puts in place a mandatory labeling regime for non-halal products: any product (including cosmetics) made from non-halal materials, or whose production process does not conform to the requirements of the Halal Product Assurance System (SJPH), while exempt from the halal certification obligation, must affix the standardized “non-halal” label as required.
Products already circulating in the Indonesian market enjoy a 12-month transition period, and existing products must complete compliance adjustments by July 23, 2027 at the latest. CIRS Group has summarized the main contents below for your reference.
Background
Under Indonesia’s Government Regulation No. 42 of 2024, from October 17, 2026, all cosmetics circulating in Indonesia must obtain halal certification, i.e., cosmetics are in principle brought within the scope of mandatory halal certification. However, products made from non-halal materials, or whose production process does not conform to SJPH requirements, while exempt from the halal certification obligation, must still bear a non-halal statement on the product.
Previously, Indonesia had no dedicated regulation uniformly prescribing the label form and affixation procedures for this statement, and companies’ practices varied. This Regulation was formulated to implement the above authorization and to unify label standards.
Criteria for Determining “Non-Halal”
Article 4 of the Regulation provides that the affixation of the non-halal statement is determined by companies themselves on the basis of the material criteria and/or the production process criteria (both criteria are anchored in non-conformity with the SJPH and may be applied separately or in combination):
Material Criteria
(1) Animal-derived materials (non-food use): materials derived from pigs, dogs and their derivatives; animal materials not slaughtered in accordance with the SJPH; animal leather that has not been tanned and purified; etc.;
(2) Plant-derived materials: materials that intoxicate or endanger health; materials to which non-halal additives or processing aids have been added during manufacturing (e.g., plant extracts obtained using non-halal solvents);
(3) Alcohol-containing materials: alcohol originating from the khamr (intoxicating beverage) industry; fermented or non-fermented beverage products with an alcohol content of ≥0.5%; materials with khamr added; and liquid by-products of the khamr industry;
(4) Microbial-origin materials: materials whose growth or manufacturing process is mixed with, contains, or is contaminated by non-halal substances; genetically engineered microorganisms using human or non-halal animal genes; culture media, additives and processing aids sourced from pigs or their derivatives; etc.;
(5) Products of chemical synthesis, biotechnology or genetic engineering: materials whose growth or manufacturing process is mixed with, contains, or is contaminated by non-halal substances;
(6) Human-derived materials: hair and any part of the human body used as materials for food, cosmetics, pharmaceuticals and daily-use articles;
(7) Najs (ritually impure substances) and contaminated materials: light, medium and heavy najs, as well as all materials contaminated by najs.
Production Process Criteria
A product shall be determined as non-halal if any of the following occurs at any stage of production, warehousing, packaging, distribution or sales:
- The slaughter premises, locations and tools are non-halal;
- During processing, storage, packaging, distribution, sale or display/serving, the product comes into contact with, and is contaminated by, non-halal materials, intermediate products or finished products;
- The production premises and tools of halal products are used on shared lines with non-halal products or cross-contaminated, and the purification treatment does not conform to SJPH requirements;
- Washing facilities are shared with, or used alternately with, equipment that has come into contact with pig-derived substances;
- Sampling instruments come into contact with pig-derived substances; etc.
Label Form and Labeling Requirements
1. Label Form
For cosmetics and other products outside the food and beverage category:
- regardless of whether the product is determined to be non-halal on the basis of materials or the production process, the “NON HALAL” mark must be used — red capital letters inside a red rectangular box on a white background;
- where the product packaging is red in color, other colors with sufficient contrast and easy recognizability may be used.
2. Labeling Location and Manner
- The non-halal statement may be affixed on the product packaging, on a specific part of the product, or at a specific location on the product;
- where it is affixed on the packaging, it shall be affixed on the outermost packaging received directly by the consumer. The label shall be proportionate in size and placed where it is most easily seen and read;
- background patterns, colors or other designs must not obscure the size, shape and color of the label, and the label must not be easily erased, peeled off or damaged.
3. Requirements for Products Sold in Bulk
For products not sold in retail packaging, companies shall affix the non-halal statement on the container, packaging or other easily identifiable marking, and must attach supporting documents issued by the material manufacturer, including the production process flow chart, the product composition list, the certificate of analysis (CoA) or similar documents, and questionnaires and/or declarations, to demonstrate that the product originates from non-halal materials or that its production process does not conform to the SJPH. Companies must ensure the qualification of the issuing institutions and the authenticity and consistency of the contents of the above documents.
CIRS Reminder
It is recommended that relevant cosmetics companies:
- Conduct self-check and determination: companies exporting cosmetics to Indonesia or selling cosmetics in Indonesia should screen their formulas one by one against the two categories of criteria — materials and production process;
- Update label designs in a timely manner: products determined to be non-halal must use the standardized “NON HALAL” mark specified in the annex to the Regulation; the label must be clear, prominent and not easily removable; products with red packaging may adopt other high-contrast color schemes;
- Prepare documents for bulk sales: for products sold in bulk, in addition to affixing the label on containers and the like, supporting documents such as the CoA, composition list, production flow chart and questionnaires/declarations should also be kept ready for regulatory inspection;
- Coordinate two key time points: one is the effective date of the mandatory halal certification obligation for cosmetics on October 17, 2026, and the other is the compliance deadline for non-halal labeling on July 23, 2027.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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