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On November 17, 2025, Indonesia's Halal Product Assurance Organizing Agency (BPJPH) notified the World Trade Organization (WTO) of a draft Decree Concerning Guidelines for Implementing the Halal Product Assurance System in Storage, Packaging, and Distribution Services. 1
The draft specifies that logistics services—including storage, packaging, and distribution—related to cosmetics, food, beverages, pharmaceuticals, and other regulated products are subject to halal certification. It aims to provide a reference for business operators, halal auditors, and supervisors in applying for and maintaining halal certification for these service activities. The public consultation period remains open until November 30, 2025.
Applicable Scope
The decree applies to business operators providing logistics services for products that are required to obtain halal certification. The scope is categorized into three main service areas:
Storage Services: Includes businesses offering warehousing (owned or leased), container and Unit Load Device (ULD) rentals, and regulated agents with temporary storage facilities. Manufacturers managing storage as part of production, retailers storing goods for operational purposes, and warehouse owners who only lease buildings are exempt.
Packaging Services: Covers businesses involved in sorting, packing, repacking, and labeling. This includes third-party logistics (3PL) providers, exporters and importers, pharmaceutical wholesalers, packing houses, distributors, and retailers performing these functions.
Distribution Services: Applies to businesses handling the transportation and delivery of halal products, ensuring that halal integrity is preserved throughout transit.
Halal Assurance System Requirements
Business operators within the scope must establish, implement, and maintain a halal product assurance system. Key criteria include (but are not limited to):
1. Management Commitment and Responsibility
Halal Policy: Businesses must establish a written halal policy, committing to consistently produce halal services and prevent contamination from non-halal and najis (ritually impure) materials.
Halal Supervisor: A competent halal supervisor must be appointed to oversee the implementation of the halal product assurance system, conduct internal audits, and manage corrective actions.
Human Resources: Companies must provide regular training to all personnel involved in the Halal Product Process to ensure they understand and can effectively implement the halal product assurance system.
2. Halal Product Process Control
Facilities and Equipment:
Locations, facilities, and equipment must be designed and maintained to prevent cross-contamination between halal and non-halal products.
Dedicated Facilities: Certain high-risk operations require dedicated facilities. For example, cold storage (freezers, chillers) used for meat and its processed products must be used exclusively for halal items.
Shared Facilities: Facilities may be shared between halal products and non-halal products, provided the non-halal items do not contain najis berat (severe impurities, e.g., from pigs). Strict, documented cleaning and ritual purification procedures are mandatory between uses.
Auxiliary Materials: All auxiliary materials used in the logistics process, such as cleaning agents, packaging materials in direct contact with the product, and processing aids, must be halal-certified or fall under a category officially exempted from certification.
Cleaning and Purification: Businesses must establish and document procedures for cleaning and, where necessary, ritually purifying facilities and equipment that have come into contact with najis. The effectiveness of cleaning is measured by the removal of color and smell of the impurity.
3. Product Handling and Traceability
Segregation: Strict procedures must be in place to physically separate halal and non-halal goods during all stages, including receiving, storage, packing, and dispatch.
Traceability: A robust traceability system is required to track the movement of goods and ensure their halal status can be verified throughout the logistics chain. This includes proper identification, coding, and record-keeping.
4. Monitoring and Evaluation
Internal Audit: Businesses must conduct internal audits of their HALAL PRODUCT ASSURANCE SYSTEM implementation at least once a year to identify and correct any non-conformities.
Management Review: A management review must be conducted at least annually to evaluate the overall effectiveness of the HALAL PRODUCT ASSURANCE SYSTEM and drive continuous improvement.
ChemLinked Comments
This draft decree marks a further extension of Indonesia's mandatory halal framework to encompass the full supply chain. Logistics providers in the cosmetics, food, beverage, and pharmaceutical sectors will be required to implement a formal halal assurance system and obtain halal certification for their service operations.
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