Under Indonesia's Government Regulation 42 of 2024, processed food and the gelatin in it need a BPJPH halal certificate, and the producer must run a Halal Product Assurance System (SJPH). Domestic medium and large food producers had until 17 October 2024, and the regulation sets 17 October 2026 as the latest date for imported food, beverages and slaughter products.
This guide is for QA, R&D and halal managers in food, confectionery, capsule and gelatin plants that sell into Indonesia or supply ingredients to producers who do.
What does Indonesian law require of processed food and gelatin?
The framework is Law 33 of 2014 on Halal Product Assurance, implemented by Government Regulation 42 of 2024, which replaced Government Regulation 39 of 2021. Article 2 says products entering, circulating and traded in Indonesia must be halal certified. Products made from prohibited materials are exempt but must be labelled as not halal.
Three bodies are involved. A halal inspection body (LPH) examines and, where needed, tests the product. A fatwa body decides on its halal status: MUI at national, provincial or district level, the Aceh ulama council or the Halal Product Fatwa Committee. BPJPH then issues the certificate.
Article 74 makes SJPH compulsory, and Article 1 defines it as an integrated system that controls materials, production, products, resources and procedures so the halal process stays continuous. Under Article 88 a certificate stays valid as long as the material composition and the halal process do not change. Article 90 requires you to update it when they do, so every reformulation and supplier switch matters.
When does the obligation apply to your products?
The obligation is phased by product type and business size. The table shows the dates in Articles 159 to 161 of Government Regulation 42 of 2024 for the categories a food or gelatin business meets.
| Products and businesses | Date in GR 42/2024 | Article |
|---|---|---|
| Food, beverages, slaughter products and slaughtering services from domestic medium and large businesses | Phased from 17 October 2019 to 17 October 2024 | 160(1) |
| The same products from domestic micro and small businesses | Phased to 17 October 2026 | 160(2) |
| The same products from abroad | Set by the Minister of Religious Affairs no later than 17 October 2026, after considering mutual recognition agreements | 160(3) |
| Raw materials, food additives and processing aids for food and beverages, such as gelatin used as an ingredient | In the first phase, with food and beverages | 159(2) |
| Medicines | Later phases, the last ending 17 October 2034 | 161(1) |
The German-Indonesian Chamber of Commerce reports 17 October 2026 as the first major deadline for imported products. It also reports that BPJPH Regulation 4 of 2026 adds a per-shipment halal product assurance check for certain imports from 9 September 2026. Confirm your product category with BPJPH before you ship.
Why is gelatin treated as a critical material?
BPJPH's SJPH criteria call a material critical when it may come from, contain or mix with a prohibited material. Gelatin fits that definition because its source animal cannot be seen in the finished powder. The criteria, set by Head of BPJPH Decree 20 of 2023, include rules that apply directly to it.
- Every material must be halal certified, unless it is on the list of materials exempted by regulation.
- Nothing may come from pigs or their derivatives, blood or carrion.
- A material must not be made in a facility that also produces from pigs or other prohibited materials. A gelatin plant that also processes pig skin fails this rule, even for its bovine line.
- Land animals must be slaughtered according to Islamic law and animal welfare rules. Government Regulation 42 of 2024, Article 71, adds that a halal slaughterer must do this in an abattoir or other slaughter place.
- All aquatic animals are halal, which is why fish gelatin is a common route for capsules and confectionery.
You must hold a halal certificate for each material that needs one and check its validity, issuer, number and match to the material. For a material not yet covered by the mandatory or exempt lists, keep its process flow, composition and certificate of analysis instead.
A gelatin supplier outside Indonesia has two routes under Articles 145 to 148. If its certifier has a mutual recognition agreement with BPJPH, the importer registers the foreign certificate before the goods are sold. If not, the supplier applies to BPJPH for certification through an importer or official representative.
What are the five SJPH criteria, and who runs the system?
Decree 20 of 2023 builds SJPH on five criteria: commitment and responsibility, materials, the halal product process, products, and monitoring and evaluation. Commitment means a written halal policy and resources. The process criterion requires separate halal and non-halal holding, weighing, mixing, moulding and cooking, matching Articles 10 and 11 of the regulation.
The criteria list the written procedures you need. They cover new materials, purchasing, receiving, storage, facility cleaning and cleansing according to Islamic law, traceability, non-conforming product, recall and new product development. Equipment may not alternate between pork and non-pork products, even after cleansing.
Monitoring means an internal audit at least once a year and a management review. You report the audit results to BPJPH, and you report your material composition and halal process every six months.
A halal supervisor (Penyelia Halal) runs the system day to day. Article 60 requires a Muslim with a sound understanding of halal law. For medium, large and foreign businesses, Article 64 asks for both a training certificate and a competence certificate. Under Article 59 the supervisor applies SJPH, plans the halal process, proposes material changes, can propose stopping production and prepares samples for the halal auditor.
What do halal auditors look for in a processed food or gelatin plant?
The points below are AGS's practical reading of what an LPH auditor usually checks in this sector. They are not quotations from the regulation or the criteria.
- The material list matches the formulations on file, line by line, including flavours, emulsifiers, enzymes and carriers.
- Each gelatin or collagen lot has a valid halal certificate naming the species, the supplier and the plant that made it.
- Flavours and extracts that contain ethanol use industrial ethanol, not alcohol from alcoholic drinks (khamr), and the records show its source.
- Shared lines have documented cleaning, and other products made on them are declared in the application, as Article 73 requires.
- A new product or supplier change goes through halal change control before its first batch.
- A traceability exercise links one finished batch back to its gelatin and other critical lots.
- The last internal audit and the six-monthly report to BPJPH are on file.
Storage and dispatch are audited too. Our guide to halal warehousing and SJPH storage rules covers that part of the chain. If you also sell into the Gulf, compare these rules with the GSO 2055-1 requirements for processed food.
How AGS can help
The SJPH HAS - Processed Foods & Gelatin kit has 42 editable Word documents. It includes a halal quality manual and technical scheme and 13 procedures, among them gelatin raw material control for hides, skins and bones, alcohol and microbial materials, and sertu cleaning. There are 15 forms, including a material list (Daftar Bahan) and a gelatin consignment release record, plus registers, checklists with a BPJPH readiness checklist, guidance and training.
Frequently asked questions
Does fish gelatin avoid the slaughter requirement?
Yes. BPJPH's criteria treat all aquatic animals as halal, so the slaughter rule does not apply. Fish gelatin still needs a halal certificate and a plant that does not also process pork.
Does a halal certificate expire in Indonesia?
Under Article 88 a BPJPH certificate stays valid while the composition and halal process stay the same. A change in either means you must update it.
Can a product made from halal ingredients skip SJPH?
No. Article 74 requires SJPH to keep the halal process continuous, and certification looks at the system as well as the ingredients.
Does buying documentation mean the product will be certified?
No. Documents are a starting point. Certification depends on how the system runs, the LPH's findings and the fatwa.
AGS provides independent documentation toolkits. This guide and the referenced kit are prepared to support BPJPH requirements. They are not affiliated with, endorsed by or approved by BPJPH, MUI, any halal inspection body or any halal certification body, and they do not guarantee any certification outcome.
Reviewed October 2026. Facts checked against the sources current at publication.
