Food Registration in Indonesia

Before you can sell or distribute food products and beverages in Indonesia, you first need to register them. In this article we will give you an overview of the process of food registration in Indonesia.

Which food products you need to register in Indonesia?

First of all, food registration in Indonesia is regulated by the National Agency of Food and Drug Control (FDA), widely known as Badan Pengawas Obat dan Makanan (BPOM).

Some food products are exempt from BPOM registration. This exemption includes products which are:

• imported for research, test and/or owned consumption’s purpose
• used as ingredients for end products
• not sold to end customers
• with a life cycle less than 7 days

For example, if a pizza restaurant wants to import olives and tomato paste for their pizzas. They don’t have to register those products since those are ingredients for making the final product – pizza. If olives and tomato paste were also sold separately they would, as a result, have to register the products.

Who can register products to BPOM?

In Indonesia, only limited liability companies that are established under Indonesian Law and have an import license can register products to BPOM. If you don’t have a company or you haven’t appointed any importer yet, you have 4 options to choose from:

#1 Setting up a foreign-owned company

The first option would be to set up a foreign-owned company, a PT PMA.

The minimum investment plan for setting up a PT PMA is 10 billion IDR (~760,000 USD), 2,5 billion of which must be paid up capital.

Maximum allowed foreign ownership can be:

• 100% for import and export companies
• 67% for distribution companies

Import-export companies cannot distribute products. Therefore, they need to assign one.

Limited foreign ownership for distribution companies means that you must have a local partner. In case you don’t have a local partner, Emerhub can help you out.

We also provide full company registration service and assist you with setting up your import company in Indonesia.

#2 Setting up a local or a nominee company

The second option for food and beverage registration in Indonesia is to set up a local or a nominee company (PT).

A PT can be established with a capital of 51 million IDR (~3,800 USD). However, note that if you plan to hire foreign employees, you should state at least 1 billion IDR (~75,000 USD) as paid-up capital through a capital statement letter.

Nominee companies don’t need to comply with foreign ownership restrictions since its shares are pledged to a local nominee such as Emerhub. If a local PT has even 1% of foreign shareholders, it will be a foreign company.

Thus, if you wish to have full control over your company and its finances, you can have Emerhub as your nominee.

	Local Company	Nominee Company
Legal entity type	PT	PT
Legal owner	Local owners	Emerhub based on an agreement with you
Maximum foreign ownership	No foreign ownership allowed	No limitation
Capital requirement	51 million IDR ~3,800 USD (if you don’t hire any foreign nationals)	Same as local company
Control over finances	Director of the company (local)	Director of the company (can be you)

Visit our page on setting up a nominee company in Indonesia to learn more.

#3 Emerhub as your nominee registrar/ product holder

If you do not wish to set up a company in Indonesia, the option would be to appoint us as your nominee registrar/product holder. We will provide you our company’s documents so you can register the products using our licenses.  

This is based on non-exclusivity which means that you can appoint multiple distributors and importers through this service. Payment is settled on a yearly basis.

#4 Appointed importer/distributor

The fourth option would be to look for an appointed importer or a distributor.

Appointing an importer or a distributor means that another company in Indonesia is assigned by you to be the importer or distributor of your products. You don’t even have to hold a legal presence in Indonesia.

However, signing an exclusive distributor agreement would mean that the appointed distributor will hold your products for 5 years.

Looking for distributors in a foreign market might not be the easiest task. Emerhub can do that for you and bring you together with reliable distributors in Indonesia.

Product registration process in Indonesia

After you have decided on the above, you can proceed to product registration.

The type of the products will be the base for beverage and processed food registration in Indonesia. If the products have a difference in packaging, composition, manufacturer, importer/distributor name, or labeling design, they are still considered as one registration.

The process of food and beverage registration in Indonesia is done in three stages.

Stage 1: Audit

The first stage of product registration is an audit on distribution facility. In other words, before you can start with product registration, you must have an appropriate place for storing your goods.

For example, if you are registering frozen foods, you need to have a cold storage for the products.

The audit will be conducted by the local BPOM of where your facility is located. The result of the audit applies to every beverage and food product that is to be registered.

Stage 2: Assessment

The second stage of food and beverage registration in Indonesia is the assessment of the products. Products are divided into 4 categories depending on the type of risk: with a high, medium, low, or very low risk factor.

Based on the results of the assessment the BPOM will issue an official invoice for the company to proceed to the evaluation stage.

Stage 3: Evaluation

Finally, the last stage of product registration is the evaluation. This stage can have three possible results:

1. Approval of your product registration application. The BPOM will issue ML codes for your products.
2. Rejection of your product registration application. Due to rejection you must start from the assessment stage again.
3. Additional data is required. In that case, you will be given 50 days to submit the requested data. If you fail to provide further data in time, the registration process will be canceled automatically.

The expected total time of the process of food registration in Indonesia is from 6 months to 1 year.

Validity

BPOM issues ML codes for 5 years after the approval. The extension of the ML codes is possible 6 months before the expiration at the earliest or 10 days before the expiration at the latest.

Requirements for food registration in Indonesia

Administrative requirements

• Registration form
• Legal documents of the importer
• Audit results on storage facilities
• GMP/ HACCP/ ISO 22000 certificate of the manufacturer
• Letter of appointment. It must clearly state that the appointed importer/distributor will proceed on the product registration. It should also set the type of appointment, whether it is exclusive or nonexclusive, and prove the validity of appointment
• Certificate of Free Sales
• Health Certificate

Technical Requirements

• Composition information on ingredients
• Manufacturing process
• Storage information
• Production code information
• Labeling design
• Certificate of Analysis of the finished product

Halal license

Because Indonesia has the largest Muslim population in the world (88%) most food and beverage products should have a halal license if they wish to sell products to mass market.

Manufacturer applies for the halal license, thus the importer or distributor does not separately have to apply for it.

Read our previous article about halal certification registration in Indonesia to find out more about the halal license.

Closing Thoughts

It’s relevant to to plan product importation well in advance. Since different products go through different processes get in touch with us to understand exactly what you need to do in Indonesia.

If you have any further questions regarding food registration in Indonesia or you would like to start with setting up your company in Indonesia, contact our consultants via [email protected] or by filling in the form below.