Indonesia’s New Food Packaging Regulation: Key Compliance Changes

In June 2026, Indonesia updated its regulatory framework for food packaging through BPOM Regulation No. 11 of 2026 [1], replacing BPOM Regulation No. 20 of 2019 [2]. Key changes include updates to permitted food contact substances (“FCSs”), migration requirements, substance-specific limits, requirements for reusable and recycled packaging, and procedures for new FCS approvals.

Positive Lists and Material Categories

Regulation No. 11/2026 retains Indonesia’s positive-list system. Annex III lists FCSs permitted for use in food packaging and distinguishes between substances subject to migration limits and those without specified migration limits. It also identifies the applicable packaging materials, functions, and restrictions. FCSs prohibited for use in food packaging are listed in Annex IV.

Migration Requirements

Migration requirements are further expanded under Regulation No. 11/2026. While BPOM Regulation No. 20/2019 already established migration limits and testing conditions, the new regulation adopts a more structured, material-specific framework. It distinguishes overall and specific migration, assigns requirements to different material categories, and provides more detailed testing conditions based on intended food-contact use, including food simulants, contact time, and temperature. Reusable plastic food packaging is also subject to repeated migration testing under Annex V.

The overall migration limit for plastics remains unchanged at 60 mg/kg food or 10 mg/dm² of food-contact surface area. However, the regulation introduces stricter substance-specific migration limits. Under the 2019 regulation, plastics were subject to a combined 1 ppm limit for lead, cadmium, hexavalent chromium, and mercury. Regulation No. 11/2026 replaces this approach with separate migration limits for arsenic, cadmium, total chromium, lead, and mercury, including non-detection requirements for arsenic, cadmium, total chromium, and mercury and a lead migration limit of 0.05 mg/kg. In addition, the BPA migration limit for polycarbonate materials is reduced from 0.6 ppm to 0.05 mg/kg, with BPA prohibited in polycarbonate food-contact articles intended for children under three. The melamine migration limit is also reduced from 30 ppm to 2.5 mg/kg, and to 1 mg/kg for infant articles.

Applications for New Food Contact Substances

For an FCS that is not included in the positive list, the applicant must obtain written BPOM approval through the new FCS petition procedure. Compared with the forms in Regulation No. 20/2019, the new regulation requires substantially more information regarding the substance and its intended use. This includes details concerning the substance identity and composition, manufacturing process, intended food-contact conditions, food category, food composition, food production process, etc. It also requires a certificate of analysis from a government or accredited laboratory and a description of the literature from credible references that explains the safety of the FCS, including comparisons/relationships with regulations in other jurisdictions, migration test results, and safety data and references for each constituent monomer, if applicable.

Transition Period

The regulation provides a 12-month transition period from the date of promulgation on June 30, 2026. It is advisable for businesses to review affected formulations, positive-list status, migration limits, testing protocols, and supporting documentation as soon as possible, while monitoring any further migration requirements that BPOM may implement separately based on risk assessment.

We will continue updating you on developments in this area and keep you informed. In the meantime, if you have any questions or need any assistance, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Eric Gu (gue@khlaw.com), or your existing contact at Keller and Heckman LLP.

[1] https://jdih.pom.go.id/view/slide/1762/11/2026/c92a10324374fac681719d63979d00fe
[2] https://jdih.pom.go.id/view/slide/842/20/2019/07811dc6c422334ce36a09ff5cd6fe71