Avoid Delays Under Indonesia’s New Food Packaging Rules

Indonesia has introduced new food packaging requirements that businesses should factor into product registration, packaging procurement, ongoing distribution, and market-entry planning. 

BPOM Regulation No. 11 of 2026 on Food Packaging took effect on June 30, 2026, and replaces BPOM Regulation No. 20 of 2019. The regulation updates requirements for packaging materials and food-contact substances, including migration limits, reusable packaging, recycled materials, and newer packaging technologies. 

For companies launching new products, assess packaging compliance early to build confidence and avoid last-minute issues before June 30, 2027. 

Key Takeaways

• BPOM Regulation No. 11/2026 introduces updated requirements for food packaging materials, food-contact substances, migration limits, reusable packaging, and recycled packaging. 
• Existing food packaging already in circulation should be reassessed now to ensure compliance by June 30, 2027, helping you stay in control of your operations. 
• Unlisted packaging materials or food-contact substances may require a food packaging safety assessment and written BPOM approval before use. 
• Foreign brands entering Indonesia should assess packaging compliance together with BPOM to identify gaps before they affect registration, production, or import planning. 

New Food Packaging Requirements at a Glance 

Area	What Businesses Need to Know	Recommended Action
Regulation	BPOM 11/2026 replaces BPOM 20/2019	Update compliance references and reassess current packaging
New products	Packaging compliance should be addressed during registration preparation	Review packaging before BPOM submission and commercial launch
Existing products	Packaging already in circulation generally has until June 30, 2027, to comply	Assess existing products and close gaps during the transition period
Packaging materials	Seven main material categories are covered	Identify all food-contact materials and packaging layers
Migration testing	Overall or specific migration testing may apply	Confirm testing based on material, food type, temperature, contact time, and use
Food-contact substances	Permitted and prohibited substances must be considered	Screen materials before laboratory testing
Supplier documents	Specifications and test evidence should match the actual packaging	Reconcile supplier declarations, composition data, and test reports
Reusable and recycled packaging	Additional safety and migration requirements may apply	Reassess packaging before changing materials or formats
Unlisted materials	Additional safety assessment and approval may be required	Identify unlisted substances or materials early
Regulatory support	Packaging issues can affect registration and continued distribution	Review packaging alongside product registration and compliance planning

BPOM 11/2026 affects both new products entering Indonesia and products already circulating in the market. The required action depends on whether a business is preparing for registration or bringing existing packaging into compliance. 

What Changed Under BPOM 11/2026? 

BPOM Regulation No. 11/2026 replaces BPOM 20/2019 and updates requirements for food packaging materials, food-contact substances, migration limits, reusable packaging, and recycled materials. 

Area	BPOM 20/2019	BPOM 11/2026	What It Means for Businesses
Plastic packaging	41 regulated types	Expanded to 58 types	Recheck applicable packaging requirements
Food-contact substances	Previous permitted list	88 additional substances permitted	Verify material composition and supplier data
Migration requirements	Existing limits	Updated limits and testing rules	Reassess existing test reports
Reusable packaging	Limited provisions	Clearer testing requirements	Confirm repeated-use compliance
Recycled packaging	Previously regulated	More explicit safety requirements	Verify recycled materials remain compliant
Unlisted materials	Less defined pathway	Safety assessment may be required	Check approval needs before use

For businesses, the priority is to confirm whether packaging specifications, supplier documents, and test reports support compliance for new registration or continued distribution. 

Who Must Comply with the New Food Packaging Requirements? 

BPOM 11/2026 requires businesses producing packaged food to use packaging materials that do not endanger human health. In practice, the requirements are relevant across the wider food and packaging supply chain, including: 

• Packaged food manufacturers in Indonesia 
• Foreign F&B brands entering or already selling in Indonesia 
• Importers and distributors of packaged food 
• Packaging manufacturers and suppliers 
• Raw-material and food-contact-material suppliers 
• Brand owners using third-party or overseas manufacturers 
• Businesses changing packaging materials, suppliers, coatings, or formats 

New products should address packaging compliance during registration preparation, while existing products may need their current specifications and supporting evidence reassessed. 

InCorp Indonesia (an Ascentium Company) can help identify compliance gaps before registration or continued distribution. Talk to our team → 

READ MORE:

• How to Obtain BPOM Approval for Imported Skincare 
• Indonesia’s BPOM Issues New Food Labeling Regulations 
• Prepare Nutrition Labeling for Indonesia’s Nutri-Level Requirements 

Which Food Packaging Materials are Covered? 

The regulation covers seven main categories of food packaging materials: 

• Plastic 
• Rubber and elastomers 
• Paper and paperboard 
• Ceramics 
• Glass 
• Metals and metal alloys 
• Multilayer materials 

Businesses should identify materials that directly contact food and confirm whether they are single-use, reusable, recycled, or multilayer. This helps determine the applicable testing and documentation requirements for both new and existing products. 

What Must Businesses Verify Before Registration or Continued Distribution? 

Whether launching a new product or reviewing an existing one, businesses should verify several areas before moving forward. 

Confirm the Required Testing 

Check whether overall migration, specific migration, or other testing applies based on the packaging material and its intended use. Food type, contact time, temperature, and repeated use can affect the testing requirements. 

Check Food-Contact Substances 

Review packaging substances against the permitted and prohibited lists before testing. This is especially important for coatings, inks, adhesives, additives, polymers, and multilayer packaging. 

Review Reusable and Recycled Packaging 

Reusable packaging must still meet migration requirements, while recycled packaging must comply with applicable food-contact safety standards. Reusable plastics may also require repeated testing. 

Verify Supplier Documents 

Ensure material specifications, packaging composition, supplier declarations, test reports, and other supporting documents match the packaging in use to support compliance verification and avoid delays. 

Align Packaging Compliance with Product Registration 

For new imported F&B products, review packaging alongside BPOM product registration. Reassess existing products when packaging materials, suppliers, or specifications change. 

InCorp Indonesia (an Ascentium Company) can assist with regulatory assessment, document preparation, and product registration support for products entering or already operating in the Indonesian market. Talk to our team -> 

What Happens If a Packaging Material is Not Listed? 

If the applicable BPOM lists do not cover a packaging material or food-contact substance, it is not automatically acceptable because it is approved in another country. 

BPOM 11/2026 provides a mechanism for food packaging safety assessment. Businesses must obtain written approval from the Head of BPOM and provide supporting information such as: 

• Applicant information 
• Material or food-contact-substance data 
• Packaging test results 
• Supporting laboratory documentation where applicable 

Identify unlisted materials before using them for a new product or introducing them into an existing product. 

Use the Transition Period to Close Existing Food Packaging Gaps 

Food packaging already circulating when the regulation was introduced generally needs to comply with the new requirements by June 30, 2027. 

Businesses should use this period to identify gaps early rather than wait until the deadline by focusing on: 

• Reviewing current packaging materials and supplier documents 
• Checking whether existing test reports remain suitable 
• Identifying products that need additional testing or assessment 
• Prioritising products under registration, modification, or import planning 

Starting early gives you more time to close gaps without disrupting ongoing distribution. 

Compliance Gaps Can Become Operational Problems 

Under BPOM Regulation No. 11/2026, non-compliance with food packaging requirements may lead to administrative sanctions under applicable laws and regulations. 

Operationally, businesses may also face: 

• Additional testing or document requests 
• Product registration delays 
• Packaging changes or supplier rework 
• Disruption to import or launch timelines 

The main risk is identifying these gaps after you’ve already made registration, production, procurement, or distribution decisions. 

Ensure Your Products Meet the New Packaging Rules 

Whether launching a new food product or maintaining products already sold in Indonesia, address packaging compliance before it affects registration or distribution. 

InCorp Indonesia (an Ascentium Company) can support businesses with: 

• BPOM product registration for food and beverage products 
• Regulatory assessment to identify applicable packaging requirements 
• Document review and preparation for packaging and product registration 
• Compliance gap assessment for existing products and supporting records 
• Coordination with manufacturers and suppliers to obtain required technical information 

Prepare your food products for Indonesia before packaging gaps affect registration or market entry. Fill out the form below for a free initial consultation. 

Frequently Asked Questions