Indonesia Proposes HS Codes for Mandatory Halal Product Certification

JAKARTA — In a regulatory shift that could reshape trade flows and consumer markets across Southeast Asia’s largest economy, the Indonesian government has submitted to the World Trade Organization (WTO) a draft decree introducing a comprehensive system to classify which products must carry halal certification — using the internationally recognized Harmonized System (HS) of product codes.

Under the draft decree, notified on Nov. 6, 2025, via document G/TBT/N/IDN/160/Add.2, the government proposes to codify into HS codes all product types subject to mandatory halal certification. The scope includes not only food and beverages but also food additives, cosmetics, and natural medicine products.

The draft is currently open for public comment through Nov. 30, 2025. Once finalized, the HS‑coded list would serve as the legally binding reference for determining which goods — whether imported or domestically produced — are required to hold halal certification before being sold, distributed, or traded in Indonesia.

Clarity for Trade, Conformity for Regulators

For importers and exporters, the new HS‑code list promises a more transparent and predictable framework. Rather than navigating broad regulatory decrees or vague product descriptions, businesses will be able to consult a codified list: any product whose HS code appears on the list must secure certification under the auspices of the Halal Product Assurance Organizing Agency (BPJPH) — or, if applicable, register a foreign halal certificate issued by a recognized foreign certification body.

In parallel, the agency’s new legal instrument, BPJPH Decree No. 221/2025, sets out fresh procedures for the registration of foreign halal certificates (SHLN), replacing an earlier regulation. Under the decree — which will take effect on Dec. 15, 2025 — foreign-certified products that come from bodies with mutual‑recognition agreements (MRAs) with BPJPH need not seek recertification, but must register and display a BPJPH‑issued registration number on their labels.

Advocates of the reform say that codifying the rules into HS codes will reduce uncertainty, streamline customs and regulatory checks, and make compliance more manageable — especially for multinational companies operating across borders.

From Broad Halal Law to Detailed Compliance

The initiative builds on a regulatory foundation laid by the country’s Halal Product Assurance Law (Law No. 33 of 2014) and recent updates under Government Regulation 42/2024, which extended compliance deadlines for certain product categories and clarified enforcement mechanisms.

Under the law, most food and beverage products — along with cosmetics, pharmaceuticals, and other consumer goods — must obtain halal certification unless they are specifically exempted (for example, “positive list” items such as certain raw agricultural products).

But ambiguity has persisted, especially for products beyond traditional food and drink: Which cosmetics? What kinds of natural medicines? Until now, many importers have had to consult lists, guidelines, or seek legal interpretation. The new HS‑coded list aims to eliminate that ambiguity.

What It Means for International Traders and Domestic Markets

For exporters looking to access Indonesia’s vast consumer base — especially those in food, cosmetics, nutraceuticals, and natural health products — the reform may significantly raise the bar for compliance. Even a seemingly innocuous product may slip into the mandatory‑certification category if its HS code appears on the list.

That means foreign manufacturers must ensure their halal certificates come from BPJPH‑recognized foreign bodies, that certificates are registered correctly, and that packaging clearly displays the SHLN registration number when the reform takes effect. Failure to comply could result in shipment delays, rejections at customs, or denied access to the Indonesian market.

At the same time, domestic producers — including small and medium enterprises (SMEs) — could face increasing administrative burdens. While previous extensions under Government Regulation 42/2024 gave some relief, the HS list adds a layer of regulatory oversight. Compliance could require adjustments to production, labeling, supply chain documentation, and certification processes.

Regulators say the timing is deliberate: as Indonesia’s halal‑certified market expands, relying on broad class‑based legislation has become unwieldy. Codifying a list of specific HS codes allows for clearer enforcement, which helps prevent mislabeling, misuse of halal logos, and “gray‑market” imports that skirt halal requirements.

Moreover, the reform dovetails with broader efforts by BPJPH to strengthen transparency and consumer confidence. Earlier this year, the agency clarified requirements for halal‑mark labeling and public disclosure of certification information, reinforcing mandatory certification obligations across product categories.

Analysts say the move reflects Indonesia’s ambition not just to regulate more strictly, but to institutionalize halal compliance across its supply chains — domestic and international — in a way that aligns with global trade norms.

The public comment period remains open until Nov. 30, 2025. Stakeholders — including importers, exporters, industry associations, consumer advocacy groups, and foreign certification agencies — have a final window to weigh in. Once comments are considered and the decree is finalized, businesses will enter a transition phase toward full enforcement.

How quickly producers, especially smaller ones, can adapt remains uncertain. For many, the reform will demand re‑evaluations of supply chains, labeling, and compliance workflows — a task that could strain smaller operators and foreign exporters.

For consumers, however, the change could bring clearer assurance that goods labeled “halal” meet defined, enforceable standards.