5. Claim Requirements

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5. Claim Requirements

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Beers, RTDs, Whisky
Indonesia

This section provides information on the definition of different types of claims and any restrictions or allowance of claims as well as claim registration processes.

5.1 Overview of Claims

5.1.1 Types & Definitions

General Food

1. Nutrient/non-nutrient claims [1]

A claim that states, indicates, or implies that food has certain nutritional/non-nutritional characteristics including energy value and content of protein, fat, and carbohydrate content, as well as vitamin and mineral content.

Nutrient/non-nutrient claims are classified into:

a. Nutrient/non-nutrient content claim.

A claim that describes the level of a nutrient or non-nutrient contained in a food. It can be applied for energy, fat, protein, vitamins, minerals, and dietary fiber.

b. Nutrient/non-nutrient comparative claim

A claim that compares the nutrient or non-nutrient levels and/or energy value of two or more foods (examples: “reduced”; “less than”; “fewer”; “increased”; “more than”). It can be applied for energy, fat, protein, vitamins, minerals, and dietary fiber.

c. No sugar added claim

A claim that states the product does not contain added sugar or sucrose, glucose, honey, or high fructose corn syrup.

d. No salt added claim

A claim that states the product does not contain sodium chloride, sodium tripolyphosphate, sodium L-ascorbate, sodium selenate, sodium benzoate, monosodium L-glutamate, or other types of sodium salts.

e. Lactose claim

A claim that represents the content of lactose in the product (low lactose or lactose-free).

f. Gluten claim

A claim that represents the content of gluten in the product (low gluten or gluten-free).

2. Health claims [1]

Health claim means any representation that states, suggests, or implies that a relationship exists between a food or a constituent of that food and health.

Health claims are classified into :

a. Nutrient/non-nutrient function claim

A claim that describes the physiological role of the nutrient or non-nutrient in growth, development, and normal functions of the body. It can be applied for protein, fat, dietary fiber, vitamins, and minerals.

b. Reduced risk of disease claim

A claim that correlates the consumption of a food or food component in the total diet with a reduced risk of disease or health condition.

c. Glycemic claim

A claim that represents the value of glycemic load and glycemic index in the product (low, medium, or high glycemic).

3. Isotonic claims

A claim that represents the product is isotonic

4. Vegan claims

A claim that states the product does not contain animal-based foodstuffs and processed products, including honey.

5. Microorganism-related claims

A claim that states the product contains microorganism that has a specific function for consumers’ needs (probiotic or other health claims related to probiotics).

Category

Alcoholic drinks

Alcoholic beverages are prohibited to declare the nutrition content (including nutrition table and FOP) [5]. If linked to the eligibility criteria required for a product to include a claim [1], Alcoholic beverages are considered ineligible to declare any claims on the labels.

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.

5.1.2 List of Prohibited Claims

General Food

Nutrient/non-nutrient-free claims while it naturally contains the said substance
Any claims that exploit consumer worries
Any other misleading claims (examples: can fulfill all nutritional needs, can prevent/treat/cure disease)

Category

Alcoholic drinks

No claims can be used on Alcoholic beverages (See Section 5.1.1 (Category) 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.

5.2 Nutritional Claims

5.2.1 Permitted Claims

General Food

Nutrient/non-nutrient content claims
Nutrient/non-nutrient comparative claims
No sugar added
No salt added
Lactose claim
Gluten claim
Microorganisms (e.g. probiotics). Permitted claims will require a case-by-case evaluation.

The claims need to be in the local language.

Refer to Annex I of the legislation for a list of claims and their criteria [1].

Category

Alcoholic drinks

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.

5.2.2 Nutritional Claim Registration

General Food

All nutritional claims that are permitted for use, will be reviewed during the product registration (label review). The product label must be approved by BPOM. Cost IDR 300,000 (~19.5 USD) – IDR 3,000,000/product (~195 USD), timeline 30 working days after documents are completed and correct (this is the timeline for registration as there is no separate process for label approval). Cost and timeline depend on the food category). Note that the actual registration process could take longer. [2,3]
If there is any revision (including addition) on the claims stated on the label, after the product is registered, it will need to be approved by BPOM. Cost IDR 1,500,000 (~100 USD), timeline 3 working days after documents are completed and correct. Note that the actual registration process could take longer. [2,3]
Nutritional claims that are currently not permitted for use, as well as microorganism-related claims, require prior case-by-case evaluation by BPOM (before the product registration). No tariff (free), timeline 85 working days. The required documents are listed in the legislation including the application form template, as follows: [1]
1. Other country's regulation
2. Manufacturing process
3. Amount of compound that is the object of the claim per day
4. History of use as food
5. Specification of product
6. Specification of product
7. Purpose of addition
8. Claim
9. Other methods and results of analysis of the nutrient,and other compounds in the end-product
10. Safety assessment
11. Ingredient list of product
12. Label
13. Scientific reference
14. Specific safety and characteristics of microorganisms when applied

Forms to submit claims: https://standarpangan.pom.go.id/dokumen/form-permohonan-pengkajian/formulir-permohonan-klaim-gizi-kesehatan-dan-klaim-lainnya.pdf.

Once the claim is permitted by BPOM, it can be registered together with the product to be declared on the product label. The cost and timeline refer to bullet no.1 above.

Category

Alcoholic drinks

Alcoholic beverages are prohibited to declare the nutrition content (including nutrition table and FOP) [5]. If linked to the eligibility criteria required for a product to include a claim [1], alcoholic beverages are considered ineligible to declare any claims on the labels.

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.

5.3 Health Claims

5.3.1 Permitted Claims

General Food

Types of health claims as mentioned above in Section 5.1.1:

Nutrient/non-nutrient function claims: permitted claims refer to Annex VII in BPOM Decree No 1 Year 2022 [1].
Reduced risk of disease claims: permitted claims will require case-by-case evaluation.
Glycemic claims.

The claims need to be in the local language.

Category

Alcoholic drinks

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.

5.3.2 Health Claim Registration

General Food

All health claims that are permitted for use, except the reduced risk of disease claims, will be reviewed at the product registration stage (label review). The product label must be approved by BPOM. Cost IDR 300,000 (~19.5 USD) – IDR 3,000,000/product (~195 USD), timeline 30 working days after documents are completed and correct (this is the timeline for registration as there is no separate label approval process, cost and timeline depend on the food category). Note the actual registration process could take longer. [2,3]
If any revision (including addition) on the claims after the product was registered, it will need to be approved by BPOM. Cost IDR 1,500,000 (~100 USD), timeline 3 working days after documents are completed and correct. Please note that the actual registration process could take longer. [2,3].
Health claims that are currently not permitted for use, as well as all reduced risk of disease claims, require prior case-by-case evaluation by BPOM (before the product registration). No tariff (free), timeline 85 working days after documents are completed and correct. The required documents are listed in the legislation including the application form template, as follows: [1]
1. Other country's regulation
2. Manufacturing process
3. Amount of compound that is the object of the claim per day
4. History of use as food
5. Specification of product
6. Name of compound
7. Purpose of addition
8. Claim
9. Other methods and results of analysis of the nutrient, and other compounds in the end-product
10. Safety assessment
11. Ingredient list of product
12. Label
13. Scientific reference
14. Specific safety and characteristics of microorganism when applied

Forms to submit claims: https://standarpangan.pom.go.id/dokumen/form-permohonan-pengkajian/formulir-permohonan-klaim-gizi-kesehatan-dan-klaim-lainnya.pdf.

Once the claim is permitted by BPOM, it can be registered together with the product to be declared on the product label. For the cost and timeline, please refer to bullet no.1 above.

Category

Alcoholic drinks

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.

5.4 Other Notes or Requirements for Claims

General Food

For all foods, the pre-requirement of a product to carry claims is per serving not more than: [1]
- total fat 18g
- saturated fat 6g
- cholesterol 60mg
- sodium 300mg
In addition, food that will include claims will be examined for eligibility during the registration process by BPOM. [1]
The assessment result (approval) of newly permitted claims is publicly available on the BPOM official website. [4]