3. Compositional Aspects

Beers, RTDs, Whisky
Indonesia

This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives.

3.1 Composition Requirements

For permitted ingredients and ethanol content, please refer to definitions and basic characteristics in Section 2.2 of this guidebook.

3.2 Raw Material Requirements

General food

• Permitted raw materials are described in BPOM Decree No. 13 Year 2023 on Food Category. The raw materials mentioned in this regulation are considered as "general" food raw materials and permitted to be used at GMP (Good Manufacturing Practices) level unless otherwise stated [1]. 
• Prohibited raw materials are listed in BPOM Decree No. 22 Year 2023 on Prohibited Raw Materials for Food and Prohibited Substances for Additives [2].

Category

Alcoholic drinks

Ethanol (if added) should be food-grade and comply with the specification: [9] 

Product

1) Beer

Same as general food and alcoholic beverages above. 

2) Alcoholic ready-to-drink beverages

Same as general food and alcoholic beverages above. 

3) Whisky

Same as general food and alcoholic beverages above. 

3.3 Fortification

Category

Alcoholic drinks

Fortification is not permitted for all alcoholic beverages. In accordance with the safety and quality standards for alcoholic beverages. [1,9] 

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Alcoholic ready-to-drink beverages

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

3.4 Other Permitted Ingredients

Category

Alcoholic drinks

For Ethanol content, please refer to the basic characteristics in Section 2.2 of this guidebook.

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Alcoholic ready-to-drink beverages

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

3.5 Permitted Additives

Additives are any substance added to food, intentionally, to influence its characteristic and its form. [3] 

General food

Permitted food additives are regulated by the BPOM Decree No. 11 Year 2019 on Food Additives. When the food category is listed below the applicable food additives, it means they can be used within the maximum limits described in the regulations [3].

Category

Alcoholic drinks

Food additives that are allowed in food category 14.2 (Alcoholic Beverages, Including Similar Beverages with Low Alcohol Content). [3] 

Product

1) Beer

Same as the category (alcoholic drinks) above with the addition of food category 14.2.1 (beer) or 14.2.7 (flavored beer). 

2) Alcoholic ready-to-drink beverages

Same as the category (alcoholic drinks) above with the addition of food category 14.2.6 (spirits) or 14.2.7 (unstandardized alcoholic beverages).

3) Whisky

Same as the category (alcoholic drinks) above with the addition of food category 14.2.6 (spirits). 

The food additives added to the product are generally permitted to be used at GMP (Good Manufacturing Practices) level unless otherwise stated [3]. For example, potassium hydroxide and citric acid as food additives are permitted to be used at GMP level. 

3.6 Permitted Flavors and Colors 

Flavors are food additives in the form of preparations concentrate, with or without flavoring adjunct used to give flavor, with the exception of salty, sweet, and sour tastes. [4] 

Colors are food additives in the form of natural colors or synthetic colors that when added or applied to food can give or improve color. [3] 

Natural food color is a color made by extraction, isolation, or derivatization (partial synthesis) from plants, animals, minerals, or other natural sources, including natural identical colors. [3] Synthetic food color is a color obtained by chemical synthesis. [3]

General food

Permitted flavors for processed food are regulated by:

1. BPOM Decree No. 13 Year 2020 on Flavoring [4]; 
2. BPOM Decree No. 11 Year 2021 on Amendment of BPOM Decree No. 13 Year 2020 on Flavoring [5]; and 
3. Head of BPOM Decree No. HK.02.01.1.2.04.21.187 Year 2021 on Amendment of the Permitted Food Additives as Flavor Adjunct, Permitted Flavoring Substances, and Permitted Aromatic Compounds Source or Flavor Preparation [6].

Permitted colors for processed food are regulated by the BPOM Decree No. 11 Year 2019 on Food Additives [3]. When the food category is listed below the applicable colors, it means they can be used with the maximum limits described in the regulations [3].

Category

Alcoholic drinks 

• Permitted flavors: same as general food above.
• Permitted colors: same as general food and allowed in food category 14.2 (Alcoholic Beverages). 

Product

Same as above.  

• All flavoring substances, according to the regulations, of flavorings are permitted.  
• Colors are generally permitted to be used at GMP (Good Manufacturing Practices) level under the food category unless otherwise stated [3]. 

1) Beer

• Permitted flavors: same as "Category" (alcoholic drinks) above.
• Permitted colors: same as  "Category" (alcoholic drinks) above with the addition of food category 14.2.1 (beer) or 14.2.7 (flavored beer). 

2) Alcoholic ready-to-drink beverages

• Permitted flavors: same as "Category" (alcoholic drinks) above.
• Permitted colors: same as  "Category" (alcoholic drinks) above with the addition of food category 14.2.6 (spirits) or 14.2.7 (unstandardized alcoholic beverages). 

3) Whisky

• Permitted flavors: same as "Category" (alcoholic drinks) above.
• Permitted colors: same as  "Category" (alcoholic drinks) above with the addition of food category 14.2.6 (spirits).

All flavoring substances according to the regulations of flavorings are permitted. Colors are generally permitted to be used at GMP (Good Manufacturing Practices) level under the food category unless otherwise stated [3]. 

3.7 Permitted Processing Aids 

Processing aids means a substance or material, not including apparatus or utensils, and not consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods, or its ingredients, to fulfill a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product, which no risk to health and no technological function. [7] 

General food

Processing aids for processed food are regulated by: 

1. BPOM Decree No. 28 Year 2019 on Processing Aids in Food Production [7]; and 
2. BPOM Decree No. 20 Year 2020 on Amendment of BPOM Decree No. 28 Year 2019 on Processing Aids in Food Production [8]. 

Processing aids are allowed (mostly at GMP level) for designated food categories. Details are listed in the table below:

If not listed, it would require prior evaluation by BPOM before being used.

Category

Alcoholic drinks

Same as general food above.

Product

1) Beer

Same as general food above.

2) Alcoholic ready-to-drink beverages

Same as general food above.

3) Whisky

Same as general food above.

3.8 Additional Notes

Methanol content in the finished alcoholic beverages product: not more than 0.01% w/v (calculated from weight percentage of methanol to total volume of product). [9] 

3.9 References

1. BPOM Decree No. 13 Year 2023 on Food Category 

https://jdih.pom.go.id/download/rule/1492/13/2023/Peraturan%20Badan%20Pengawas%20Obat%20 dan%20Makanan%20Nomor%2013%20Tahun%202023%20tentang%20Kategori%20Pangan

2. BPOM Decree No. 22 Year 2023 on Prohibited Raw Materials for Food and Prohibited Substances for Additives

https://jdih.pom.go.id/download/rule/1513/22/2023/Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%2022%20Tahun%202023%20tentang%20Bahan%20Baku%20yang%20Dilarang%20dalam%20Pangan%20Olahan%20dan%20Bahan%20yang%20Dilarang%20Digunakan%20sebagai%20Bahan%20Tambahan%20Pangan

https://jdih.pom.go.id/download/rule/1610/22/2023/Regulation%20Of%20The%20Indonesia%20Food%20and%20Drug%20Authority%20Number%2022%20of%202023%20on%20Prohibited%20Raw%20Materials%20in%20Processed%20Food%20and%20Prohibited%20Materials%20as%20Food%20Additives

3. BPOM Decree No. 11 Year 2019 on Food Additives

https://jdih.pom.go.id/download/rule/848/11/2019/Bahan%20Tambahan%20Pangan

4. BPOM Decree No. 13 Year 2020 on Flavorings

https://jdih.pom.go.id/download/rule/1119/13/2020/Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%2013%20Tahun%202020%20tentang%20Bahan%20Tambahan%20Pangan%20Perisa

5. BPOM Decree No. 11 Year 2021 on Amendment of BPOM Decree No. 13 Year 2020 on Flavorings 

https://jdih.pom.go.id/download/rule/1251/11/2021/Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%2011%20Tahun%202021%20Tentang%20Perubahan%20Atas%20Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%2013%20Tahun%202020%20tentang%20Bahan%20Tambahan%20Pangan%20Perisa

6. BPOM Decree No. HK.02.01.1.2.04.21.187 Year 2021 on Amendment of the Permitted Food Additives as Flavor Adjunct, Permitted Flavoring Substances and Permitted Aromatic Compounds Source or Flavor Preparation

https://jdih.pom.go.id/download/rule/1259/HK.02.01.1.2.04.21.187/2021/KEPUTUSAN%20KEPALA%20BADAN%20PENGAWAS%20OBAT%20DAN%20MAKANAN%20REPUBLIK%20INDONESIA%20NOMOR%20HK.02.01.1.2.04.21.187%20TAHUN%202021%20TENTANG%20%20PERUBAHAN%20BAHAN%20TAMBAHAN%20PANGAN%20YANG%20DIIZINKAN%20SEBAGAI%20AJUDAN%20PERISA,%20PERUBAHAN%20SENYAWA%20PERISA%20YANG%20DIIZINKAN%20DIGUNAKAN%20DALAM%20BAHAN%20TAMBAHAN%20PANGAN%20PERISA,%20DAN%20PERUBAHAN%20SUMBER%20BAHAN%20BAKU%20AROMATIK%20ALAMI%20DAN/ATAU%20SUMBER%20PREPARAT%20PERISA

7. BPOM Decree No. 28 Year 2019 on Processing Aids in Food Production

https://jdih.pom.go.id/download/rule/832/28/2019/Bahan%20Penolong%20Dalam%20Pengolahan%20Pangan 

8. BPOM Decree No. 20 Year 2020 on Amendment of BPOM Decree No. 28 Year 2019 on Processing Aids in Food Production 

https://jdih.pom.go.id/download/rule/1126/20/2020/Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%2020%20Tahun%202020%20tentang%20Perubahan%20atas%20Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%2028%20Tahun%202019%20Tentang%20Bahan%20Penolong%20Dalam%20Pengolahan%20Pangan 

9. BPOM Decree No. 5 Year 2021 on Safety and Quality Standard of Alcoholic Beverages 

https://jdih.pom.go.id/download/rule/1233/5/2021/Peraturan%20Badan%20Pengawas%20Obat%20dan%20Makanan%20Nomor%205%20Tahun%202021%20Tentang%20Standar%20Keamanan%20dan%20Mutu%20Minuman%20Beralkohol