4. Labeling Requirements

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4. Labeling Requirements

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Beers, RTDs, Whisky
Indonesia

This section provides information on labeling requirements and the label approval process.

4.1 Mandatory Labeling Parameters

General Food

Packaged processed food

At a minimum, the following items have to be on the label [1,2,3,4]:

Name of product
Ingredient list
Net weight
Name and address of manufacturer and local importer/distributor
BPJPH Halal logo, if required
Date and code of production (batch)
Expiry date
Product Registration number
Source of certain ingredients (for animal origin, GMO, irradiated, related to halal)
Nutrition information [3]
Instruction of use (for products that need preparation before use)
Instruction for storage (for a product whose shelf life depends on storage and demands specific conditions)
Allergen ingredient. List of allergens: milk (with lactose), cereals with gluten, eggs, fish, crustacea, molluscs, peanuts, tree nuts, sulphites min 10mg/kg (as SO2). Allergen declaration. The name of any allergen present should be written in bold in the ingredient list. In addition, the label shall bear the information “Contains allergen, see the ingredients written in bold”.
GM food product statement, if any [4]. Details of it are noted below: GM food product statement should be declared in the ingredient list when a food product contains a minimum of 5% of genetically modified DNA in each GM raw material (except for oil, fat, sugar, starch, or other GM raw materials that had been refined, and no GM proteins were identified) [4].

Category

Alcoholic drinks

Same as General Food above except point e (BPJPH Halal logo) and g (Expiry date). [3] Point g (Expiry date) is exempted for alcoholic beverages containing at least 7% alcohol content.

Product

1) Beer

Same as "Category" (alcoholic beverages) above.

2) Alcoholic ready-to-drink beverages

“Alcoholic ready-to-drink beverages” should comply with the "Category" of alcoholic drinks above.

3) Whisky

“Whisky” should comply with the "Category" of alcoholic drinks above.

4.2 Languages

General Food

Bahasa Indonesia language. [1,2].

Origin or other languages can be used as long as all the mandatory information is written in Bahasa Indonesia.

Category

Alcoholic drinks

Same as General Food above.

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.

4.3 Mandatory Information on Stickers

General Food

Stickers can be a temporary solution for imported products. In practice, the use of stickers needs to be approved by the Authority on a discussion/agreement [1]. The sticker shall not be easy to remove.

Category

Alcoholic drinks

Same as General Food above.

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.

4.4 Product Legal Name

General Food

Product name can refer to food category regulation. [1]

Category

Alcoholic drinks

Same as General Food above.

Product

1) Beer

Bahasa Indonesia: bir [1]

2) Alcoholic ready-to-drink beverages

Depending on the type of product, i.e. flavored alcoholic drink (local language: minuman beralkohol berperisa) [1].

In the case of alcoholic beverages where the type is not listed in the food category regulation [1], the label should state “ALCOHOLIC BEVERAGES CLASS (A/B/C) ....” (Bahasa Indonesia: ‘’MINUMAN BERALKOHOL GOLONGAN ……”). [1]

3) Whisky

Bahasa Indonesia: whisky (similar to English) [1].

4.5 Product-specific Labeling Statements

Category

Alcoholic drinks

Alcoholic beverages should declare alcohol content in percentage ‘’contains alcohol ±...%’’ (Bahasa Indonesia: ‘’mengandung alkohol ±...%’’) and written on the visible side of the label. [1,2]. Note: the visible side of the label is usually the Front of Pack.

In addition, there should also be a warning statement that “drinking is prohibited for persons under 21 years of age or pregnant women” (Bahasa Indonesia: “di bawah umur 21 tahun atau wanita hamil dilarang minum”).

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.

4.6 Authority Approval

General Food

The product label needs to be approved by BPOM. It will be part of product registration or revision of label approval when the product was registered before [5].

Once approved by BPOM, the product will receive a BPOM registration number and 2D Barcode (BPOM QR code). Both must be placed on the main part of the label.

Category

Alcoholic drinks

Same as General Food above.

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.

4.7 Additional Notes on Labeling

Presentation of mandatory particulars

The main raw material that constitutes the product characteristic should be declared with the percentage of its quantity (QUID/quantitative ingredient declaration) in the ingredient list. [1,2].

GMO labeling

GM food product statement should be declared in the ingredient list when a food product contains a minimum of 5% of genetically modified DNA in each GM raw material (except for oil, fat, sugar, starch, or other GM raw materials that had been refined, and no GM proteins were identified) [4].

If applicable, there shall be written with "..... (GMO PRODUCT)" or in the local language: ".... (PANGAN PRODUK REKAYASA GENETIK)" on the ingredient list.

Labeling relating to recycling for plastic

It is mandatory to have the recycling code logo for plastic packaging (by stating the plastic code and can be recyclable) on the label. [6]

However, if the packaging material is other than plastic, no recycling logo is mandatory to be added.

Voluntary information

Other voluntary information such as EAN Code, additional promotion information (except for nutritional and health claims which are prohibited – see details in Section 5 of this guidebook), and environment-related logos (e.g. Tidy man “disposing into the bin responsibly”), are allowed on the label as long as it can be proven and does not mislead or is prohibited per Articles 61 and 67 of BPOM Decree on Food Labeling. The manufacturer is responsible for the accuracy of the information. [1,2]

Other labeling

Other labeling information that is currently not described in this section or not permitted for use requires prior case-by-case evaluation by BPOM. No tariff (free), the timeline is 85 working days. [1]

Forms to submit for labeling special permit: https://standarpangan.pom.go.id/dokumen/formpermohonan-pengkajian/Formulir-Permohonan-Kajian-Keamanan-Mutu-Gizi-dan-Manfaat-PanganUntuk-Label-dan-Kategori-Pangan.pdf.

The assessment result (approval) of new labeling information is publicly Flavored vegetable oil powdered milk available on the BPOM official website [7].