food packaging regulation in indonesia

Newest Regulation Update on Food Packaging in Indonesia

InCorp Editorial Team

Table of Content

On July 29, 2019, the National Agency of Drug and Food Control or Badan Pengawas Obat dan Makanan (BPOM) in Indonesia has made effective Regulation 20/2019 on Food Packaging.

The purpose of this new legal framework is to have more stringent supervision on food packaging. This regulation is compulsory for all types of food packaging and food packaging made from recycled materials. Food producers or manufacturers are given a 12-month time period to comply with the new regulation since the enforcement date on July 29, 2019.

The issuance of Regulation 20/2019 has also replaced the BPOM No. HK. of 2011 and BPOM No. 16 of 2014.

Regulation 20/2019 basically covers the below provisions:

  • Prohibited materials and substances
  • Permitted materials and substances
  • Recycled food packaging

Prohibited Materials and Substances in Food Packaging

food packaging in indonesia

In accordance with this new regulation, packaged food producers, or producers who manufacture food that is packaged and sold, are required to use food packaging that must not cause harm to human health.

In addition, the food packaging is not allowed to have the following prohibited food-contact substances:

1. Plastic Food Packaging

  • Colorings: alkanet, barium chromate, bismuth oxychloride
  • Oligomers: butyl-methylcarboxylbthyl,-phtalate, d-methl-cyclohexyl phthalate and its isomers, methyl-methylcarboxyethyl-phthalate
  • Adhesives: BFDGE, novolac glycidyl ethers, flectol H
  • Fillers: Asbestos
  • Curing agents: 2-choloanaline
  • Antioxidants: Hydrogenated 4,4’-isopropylidene-diphenolphosphite ester resins
  • Sanitizers: Hydrogenated 4,4’-isopropylidene-diphenolphosphite ester resins


2. Ink Printed Directly on Packaging

  • Colorings: emerald green, chrome vermillion, induline
  • Stabilizers: barium stearate, tributylin rosin salts, chlorinated naphthalenes
  • Solvents: o-Dicholorobenzene, ethylene dibromide, monochlorobenzene


3. Rubber-based Food Packaging: mercaptoimidazoline, 2-mercaptoimidazoline

4. Metal-based Food Packaging: lead solders

5. Glass-based Food Packaging: tin-coated lead foil

Permitted Materials and Substances in Food Packaging

food packaging indonesia

Allowed materials and substances of food packaging under Regulation 20/2019 are specified as follows:

1. Allowed substances with migration thresholds

  • Oligomers: phthalic acid, soybean oil, adipic acid
  • Antioxidants: thiodipropanoic acid
  • Antistatic agents: N,N-bis(2-hydroxyethyl)alkyl (C8-C18) amine, N,N-bis(2-hydroxyethyl)alkyl (C8-C18) amine hydrochlorides, alkyl (C8-C22) sulphonic acid
  • Stabilisers: Di-n-octyltin bis(n-alkyl(C10-C16) mercaptoacetate), mono-n-octyltin tris mercaptoacetate, dimethyltin bis(ethylhexyl mercaptoacetate)
  • Degradants: acetaldehyde
  • Catalysts: antimony trioxide
  • Adhesives: 2,2-bis propane bis ether, BADGE.H2O, BADGE.2H2O, BADGE.HCI, BADGE.2HCI, BADGE.H2O.HCI
  • Acetaldehyde scavengers: 2-aminobenzamide
  • Carriers for colorants: adipic acid, DEHA


2. Allowed substances without migration thresholds (in rubber-based, plastic-based, and elastomer-based food packaging)

  • Anti-foulants: benzoic acid, sodium salt, 2,4-dihydorxy polymer with formaldehyde
  • Anti-corrosion agents: polyethylene glycol (400) monooleate, zinc hydroxyl phosphite
  • Anti-microbial agents: benzethonium chloride USP, dimethyl dicarbonate, silver zinc glass
  • Preservatives: 1,2-Benzisothiazolin-3-one
  • Anti-static, Anti-fogging agents: aluminum borat, glycerol ester mixtures of ricinoleic acid
  • Anti-blocking agents: methylmethacrylate-trimethylolpropane trimethacrylate copolymers
  • Release agents: saturated fatty acid amides from fatty acids of marine, animal and vegetable fats and oils, sebacic acid, rice bran wax
  • Clarifying agents: dibenzylidene sorbitol, dimethyldibenzylidne sorbitol, polyvinil cyclohexane


3. Allowed materials

  • Multilayer plastic (migration thresholds based on usage conditions and food types)
  • Monolayer plastics depending on articles and resins
  • Paper and cartons
  • Rubber and elastomers
  • Covers, seals, gaskets
  • Ceramics
  • Upholstery (from resins, polymers)
  • Glass
  • Metals


All migration thresholds of allowed materials and substances must follow the migration thresholds for article forms.

For materials and substances that are not covered under the allowed substances and materials under Regulation 20/2019, they can still be used in food packaging in Indonesia as long as businesses have obtained Head of the BPOM’s approval. The approval can be applied with written application to the Head of the BPOM.

Food Packaging with Recycled Materials

Recycled food packaging must also strictly comply with several other regulations specifying the production methods, particularly article 10 and article 11 of the same regulation.

How Cekindo can Assist

Indonesia offers many opportunities for food producers, traders, and distributors looking to enter a large profitable market. However, the country’s food-related laws and processes can be difficult to maneuver for first-time foreign investors.

Cekindo can help you navigate the market that requires due diligence. By partnering with us, you can make all regulatory processes smoother and more effective. Seek advice from Cekindo now so that you can thrive in the food and beverage scene. Fill in the form below.

Verified by

Tjhia Edy Tarlesno

Legal & Compliance Manager at InCorp Indonesia

Edy Tarlesno holds various certifications and a respectable degree to be an expert on internal and external legal compliance in Indonesia. His experience starts from bankruptcy and insolvency, leading to a prominent social foundation consultancy in Indonesia.

Are you ready to make your
mark in Indonesia?

Get in touch with us

Lead Form

We use cookies to improve and customise your browsing experience. You are deemed to have consented to our cookie policy as you continue browsing our site.