On 24 August 2026, Indonesia's food and drug authority BPOM announced in a press release that it had issued BPOM Regulation No. 11 of 2026 on Food Packaging, replacing Regulation No. 20 of 2019. detikHealth followed on 12 October 2026 with a summary titled "BPOM Terbitkan Aturan Baru Kemasan Pangan, Perketat Standar Keamanan", which reported that businesses must now meet total and specific migration limits for packaging materials.
If you run quality for a food or beverage company that sells into Indonesia, whether from a plant in Indonesia, a regional hub or a co-packer elsewhere in Asia-Pacific, this is a supplier-control problem more than a paperwork one. The packaging you buy is a hazard source you only partly control. This article looks at the regulation from that angle and shows how ISO 22000 supplier and hazard controls turn the new rules into routine work.
📌 Regulatory Case: BPOM Regulation No. 11 of 2026 on Food Packaging
Per BPOM's press release No. HM.01.2.08.26.237 (24 August 2026), the rule aims to reduce health risks from chemicals migrating from packaging into food. It covers plastics, rubber and elastomers, paper and paperboard, ceramics, glass, metals and alloys, and multilayer packaging. Only food contact substances that BPOM has assessed as safe may be used, and new materials need written approval from the Head of BPOM based on scientific evidence.
"Food packaging is not merely a wrapper, but a part that greatly determines the safety of a food product." — BPOM Head Taruna Ikrar, BPOM press release, 24 August 2026 (translated)
To see what this means on a production line, it helps to separate the requirements by the question each one forces you to answer.
| Requirement | What was reported | What you need to prove |
|---|---|---|
| Total migration | Limits on all substances moving from packaging into food | Supplier test results for the packaging article, not only the raw resin or board |
| Specific migration | Limits on particular harmful substances | Declarations of the food contact substances used |
| Permitted substances | Only BPOM-assessed substances; banned and permitted lists updated | Material list checked against the official lists |
| Reusable and recycled packaging | Allowed if all safety requirements are met; reusable plastics have specific rules including migration testing | Test evidence and good manufacturing practice records |
| New materials | Written approval of the Head of BPOM; uncovered substances need a risk assessment application | An approval trail before launch |
| Transition | Packaging in circulation must comply within 12 months of promulgation | A dated plan with owners |
| Enforcement | Administrative sanctions for violations | Records retrievable on request |
The press release names packaged-food businesses, packaging producers, the food industry and testing laboratories as parties in implementation, and it frames compliance as an investment in consumer trust and the competitiveness of Indonesian industry. For a regional quality manager the hard part is data. Packaging often passes through a converter, a film supplier and a resin producer, and each layer holds part of the information you now need. That chain is exactly what ISO 22000:2018 asks you to control.
The links are specific. Clause 4.2 requires you to understand relevant requirements, including legal ones. Clause 7.1.6 requires control over externally provided processes, products and services, which includes packaging suppliers. Clause 8.5.1 requires preliminary information for hazard analysis, including the characteristics of product-contact materials. Clause 8.2 governs prerequisite programs, and clauses 9.2 and 10.2 close the loop through internal audit and corrective action. Packaging converters can add ISO/TS 22002-4, the prerequisite program specification for food packaging manufacturing.
Know the limit: ISO 22000 supports compliance but does not replace legal obligations. Certification does not exempt a product from BPOM requirements, and the regulation may demand things the standard does not. Treat the standard as the operating system and the regulation as the content it carries.
Because the 12-month window is already running, five steps can start now without waiting for further technical guidance, and each one strengthens a system the standard already requires.
Inventory Every Food-Contact Material
List each primary pack and contact material by product, with supplier, material type and the date of the last conformity data. Everything else depends on this list.
Request Migration and Substance Data from Suppliers
Ask for total and specific migration results on the finished packaging article, plus a declaration of food contact substances. Write these into purchase specifications and supplier approval criteria.
Run a Gap Analysis Against the Official Text
Compare each material with the permitted and banned lists in the official regulation at jdih.pom.go.id. Rank gaps by risk and by the volume of product in the market.
Update the Hazard Analysis and Prerequisite Programs
Add chemical migration to the hazard analysis and set controls at receiving, storage and, where relevant, reuse. Treat recycled content as a separate risk line.
Verify with Internal Audit and Management Review
Test whether practice matches the updated procedures, then take the results to management review so leadership resources the work and tracks progress against the deadline.
The difference between the two ways of working becomes obvious on the day a customer or inspector asks for evidence.
| Dimension | Reactive | ISO 22000-based |
|---|---|---|
| Regulatory monitoring | Waits for supplier or media updates | Legal requirements reviewed on a schedule |
| Packaging data | Collected when asked | Held per supplier and per product |
| Hazard analysis | Focused on ingredients | Includes contact materials and migration |
| Ownership | Left to the QC team | Top management accountable (Clause 5) |
| Improvement | After complaints or findings | Audit, review and corrective action cycle |
Business benefit: Documented packaging compliance is increasingly requested in retailer audits and export negotiations. Building it once inside an ISO 22000 system serves both regulators and customers.
Common mistakes follow a pattern. Companies assume packaging safety is entirely the supplier's job even though the brand owner that markets the food carries obligations. Supplier declarations are collected once and never refreshed. Reusable and recycled packs sit outside the hazard analysis. And teams wait until the deadline is close, although inventory and supplier data requests take months to complete.
If you want to align your food safety system with an international framework, Arafar Nusa offers ISO 22000 consulting to build a food safety system from gap analysis through the certification audit, and can combine it with ISO 9001 in one integrated system, so legal compliance and certification are built together.
Frequently Asked Questions
Is ISO 22000 required to comply with BPOM Regulation No. 11/2026?
No. The regulation is a legal obligation, while ISO 22000 is a voluntary standard. ISO 22000 helps by giving you a structure for controlling packaging hazards, managing suppliers and proving compliance through records. A certificate does not replace the legal requirements.
What is the deadline for packaging already on the market?
BPOM's Processed Food Safety Standardization team lead told detikHealth that packaging already in circulation must comply no later than 12 months after the regulation is promulgated. Confirm the promulgation date on the official copy at jdih.pom.go.id.
Are recycled and reusable packaging still allowed?
According to BPOM's press release, reusable and recycled packaging is allowed if it meets all safety requirements, including migration limits and good manufacturing practice. detikHealth also reported specific rules for reusable plastics, including migration testing.
Does this affect companies that import or co-pack for the Indonesian market?
The press release says businesses producing packaged food must use safe packaging and confirm its safety before distribution. If you supply or co-pack for Indonesia, check the official text and confirm with your Indonesian regulatory contact how it applies to your product.
Where should a quality manager start?
Start with an inventory of every food-contact material, request migration and substance data from each supplier, compare it against the official lists, and close gaps through your hazard analysis and prerequisite programs.
Need to Align Your Packaging Controls with BPOM Rules?
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