On June 23, 2026, Indonesia's Food and Drug Authority (BPOM) issued Regulation No. 11 of 2026 on Food Packaging, effective from June 30, 2026, replacing the former Regulation No. 20 of 2019 on Food Packaging.
Under Article 4 of the Regulation, food packaging materials are classified into seven categories: plastics; rubber and elastomers; paper and board; ceramics; glass; metals; and multilayer materials. The Regulation systematically sets out the safety and hygiene requirements, permitted food contact substances, and prohibited substances for each material category.
The Regulation establishes a positive list (permitted food contact substances, with specific migration limits and overall migration limits) and a negative list (prohibited substances), requiring that food packaging does not migrate substances harmful to human health into food under intended use conditions. Relevant migration testing is conducted in accordance with standards such as SNI 8216.1:2015.
The Regulation provides that food packaging in circulation must comply with the new rules no later than 12 months after the Regulation's promulgation; this excludes migration limit requirements that are implemented in phases based on risk assessment. Compared with the replaced Regulation No. 20 of 2019, the new version reorganizes and updates the material categories and substance lists, further shifting toward a positive-list management model. Relevant food and packaging enterprises exporting to Indonesia should promptly verify product compliance against the new Regulation.
ChemRadar Insights
Centered on a positive list, covering seven material categories and setting out clear migration limits, the new Regulation has a significant impact on food contact material and packaging enterprises exporting to Indonesia. Relevant enterprises are advised to:
1. Verify material classification: Confirm the material category to which a product belongs (plastics; rubber and elastomers; paper and board; ceramics; glass; metals; and multilayer materials) and the applicable provisions.
2. Check substance compliance: Verify against the positive list whether the colorants, additives, monomers and other substances used fall within the permitted scope, and check whether products contain any prohibited substances on the negative list.
3. Conduct migration testing: Carry out specific migration and overall migration testing in accordance with the Regulation and SNI method standards to ensure compliance with the limits.
4. Note the transition period: Existing products must complete the compliance transition within the 12-month transition period. Enterprises should, in light of the transitional provisions of Article 13, assess the transition arrangements for products on sale and newly placed on the market.
