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Indonesia releases new compliance requirements for food contact materials and products

Time：

2026-07-23

Indonesia has released new compliance requirements for food contact materials and products, establishing comprehensive requirements for food packaging materials (FPMs) and food contact substances (FCSs), including migration limits, testing methods, positive and negative substance lists, requirements for recycled materials, and safety procedures for new substances and materials.

In June 2026, the Indonesian National Agency of Drug and Food Control (BPOM) officially issued Regulation No. 11 of 2026 on Food Packaging. The new regulation replaces the previous 2019 Regulation No. 20 on Food Packaging and establishes comprehensive requirements for food packaging materials (FPMs) and food contact substances (FCSs), including migration limits, testing methods, positive and negative substance lists, requirements for recycled materials, and safety procedures for new substances and materials.

Regulatory Requirements

Chapter 1 "General Provisions"

Several terms and their definitions have been introduced, including food packaging, FPMs, FCSs, and migration.

Chapter 2 "FPMs"

(1) The scope of FCMs is defined:

(2) The above-mentioned FPM must comply with overall migration (OM) and/or specific migration (SM) requirements.

Chapter 3 "FCS"

Authorized use of FCS listed in Annex III of the Regulations, provided that they comply with these specifications.

Chapter 4 "Reusable Food Packaging"

These materials must comply with applicable migration requirements.

Plastics shall meet the OM and SM requirements specified in Annex V of the regulation, including the application of stability factors.

Chapter Five "Food Packaging Made from Recycled Materials"

The use of recycled materials produced by legally compliant methods is permitted.

The provisions regarding FPMs and FCSs in Articles 3 to 8 shall apply mutatis mutandis to recycled materials.

Chapter Six "Evaluation"

The use of FPMs and/or FCSs not listed in Articles 4 and 6 is permitted, provided that such equipment has undergone a security assessment and been approved by the head of the institution (see the sample assessment application form in Annex VI).

Chapter Seven "Administrative Punishment"

Regulations will impose administrative penalties on individuals and enterprises in violation of the law in accordance with applicable laws.

Chapter VIII "Transitional Measures"

Food packaging in circulation must comply with the new law within 12 months from the date of promulgation of the law (see below).

Chapter Nine "Supplementary Provisions"

Abolish the Food Packaging Regulations No. 20 of 2019 as of June 30, 2026 (the date of promulgation).

The new law shall come into effect on June 30, 2026 (the date of promulgation).

Annex I "Relocation Restriction Requirements"

A general list of requirements for plastics was established (see Table 2).

SM requirements for 58 different types of plastics were specified.

Details of general requirements for rubber and elastic materials.

SM requirements for 23 types of rubber and elastic materials were described.

Rubber and elastomeric materials used in infant products must comply with the requirements for N-nitrosamines and N-nitrosatable substances.

Limits for organic substances and heavy metals in uncoated paper and cardboard were specified, using the methods described in Annex II C.

Migration requirements for lead and cadmium were established for three categories of ceramic products and five categories of glass products.

Details of general requirements for extractable lead and cadmium in metals and alloys.

SM requirements for specific types of metals and alloys were specified, including metals and alloys with coated materials.

Requirements for multilayer materials were defined.

Annex II "Migration Testing"

Describes the methods of migration testing, including the application of food simulants, time, and temperature.

Detailed test methods for N-nitrosamines and N-nitrosatable substances, as well as the SM for glass and ceramics.

Annex III "FCS permitted for use in food packaging"

It provides a detailed positive list of 117 substances with migration restrictions, including 2,2-bis(4-hydroxyphenyl)propane bis(2,3-epoxypropyl) ether (BADGE), bisphenol A (BPA), bisphenol S (BPS), and several phthalates (Table A).

A list of 1,308 substances without migration restrictions is specified (Table B).

Annex IV "FCSs Prohibited for Use in Food Packaging"

The use of 142 substances is prohibited.

Annex V "Migration Testing for Reusable Plastic Materials in Contact with Food"

Detailed explanation of the standards for testing OM and SM requirements based on stability requirements.

Annex VI "Application Form for Food Packaging Safety Assessment"

Provide examples of food packaging safety application forms.

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General Requirements for Plastic Materials

The new regulations establish strict migration limits for plastic materials, which are as follows:

Overall migration: ≤ 60 mg/kg or ≤ 10 mg/dm².

Lead (Pb): 0.05 mg/kg.

Cadmium (Cd): Not detectable (LOD=0.002 mg/kg).

Arsenic (As): Not detectable (LOD=0.01 mg/kg).

Total chromium (Cr): Not detectable (LOD=0.01 mg/kg).

Mercury (Hg): Not detectable (LOD=0.01 mg/kg).

Compliance Recommendations

The new regulations on food packaging in Indonesia will come into effect in June 2026 and will be applicable from June 30, 2027. It is recommended that export enterprises conduct a comprehensive review and inventory of existing packaging formulas and materials as soon as possible to avoid potential entry risks.

Jiayu Testing, as a professional third-party testing and certification service organization, has qualifications such as CMA, CNAS, CPSC, CCC, and has obtained laboratory accreditation from multiple authoritative certification institutions at home and abroad. It has a professional testing technology team, equipped with advanced instruments and equipment, proficient in various regulatory standards, and specializes in providing FCM food contact material testing services for various food contact materials (such as coatings, silicone rubber, plastics, metals, glass ceramic enamel, bamboo, wood, paper and cardboard) in China, the United States, the European Union and its member states (France, Italy, Germany, etc.), Japan, South Korea and other countries to ensure that your products meet the regulatory requirements of various countries. Welcome to contact us at 400-9269-886！