Food Claims on Product Packaging in Indonesia: Complete Guide Based on BPOM Regulation

Since 2016, Insightof has processed over 1,000 BPOM, Halal, and Medical Device certifications. Any product that complies with Indonesian regulations will be fully registered by our team.

10+ years experience / Certification Consulting / Based in Jakarta

Food labeling in Indonesia is not just about aesthetics — it is about compliance. Under the supervision of Badan Pengawas Obat dan Makanan (BPOM), every claim printed on packaging is strictly regulated under BPOM Regulation No. 1 of 2022 concerning Supervision of Claims on Processed Food Labels and Advertisements.

“We already included Nutrition Facts. Why is our front-of-pack claim still rejected by BPOM?”
“Can we write ‘safe for diabetics’ or ‘helps lower cholesterol’?”

Many of our clients feel frustrated when beautifully designed packaging must be revised entirely because of one non-compliant claim statement.

In Indonesia, a “claim” is not merely a marketing strategy — it is a regulated legal subject. Under BPOM Regulation No. 1 of 2022, claims must:

• Be truthful and not misleading
• Be supported by scientific evidence
• Not encourage improper consumption patterns
• Not imply disease prevention, treatment, or cure

A small wording mistake can result in serious regulatory consequences.

Understanding Food Claims Under Indonesian Regulation

What Is Considered a “Claim”?

According to BPOM Regulation No. 1 of 2022, a claim is any statement that suggests, describes, or implies specific characteristics of a food product, including:

• Nutritional content
• Functional properties
• Composition
• Health relationship

Claims may appear on:

• Product labels (packaging)
• Advertisements (digital, print, broadcast, etc.)

Main Categories of Claims Regulated by BPOM

Based on regulatory classification and our experience assisting hundreds of food companies, claims are generally divided into:

1. Nutrition Claims (Nutrient Content Claims)

Examples:

• Low Fat
• Sugar Free
• Source of Protein
• High Fiber

These claims must meet specific quantitative thresholds based on laboratory analysis.

2. Health Claims

Claims that describe the relationship between a food or nutrient and:

• Body functions
• Reduction of disease risk

Health claims require scientific substantiation and, in many cases, written approval from BPOM.

3. Other Specific Claims

Including:

• Isotonic claims
• Vegan claims
• Probiotic/microorganism-related claims
• Lactose-related claims
• “No Added Sugar” or “No Added Salt”

Basic Nutritional Threshold Requirement (Per Serving)

Before making any claim, your product must pass a fundamental nutritional “filter.”

In general, claims are only permitted if per serving does not exceed:

Certain claim types (such as fat-related or sodium-related claims) may have specific exceptions detailed in regulatory appendices.

If your product exceeds these thresholds, claims may not be allowed — even if laboratory values meet other claim criteria.

Specific Claim Requirements

A. Nutrient Content Claims

To use certain terms, products must meet quantitative standards based on accredited laboratory results.

Each nutrient claim must:

• Clearly state the nutrient name
• Declare the quantified amount per serving

Quantitative Thresholds for “Low” and “Free” Claims (BPOM Reference Standard)

Note: Besides the word “free” (bebas), equivalent terms such as “without” (tanpa) or “does not contain” (tidak mengandung) may be used. Specifically for energy, the word “free” can be expressed as “0 calories”.

Sources: Peraturan Badan Pengawas Obat dan Makanan Nomor 1 Tahun 2022 tentang Pengawasan Klaim pada Label dan Iklan Pangan Olahan

B. “No Added Sugar” Claims

This claim may only be used if:

1. No caloric sugars are added (e.g., sucrose, glucose, honey, HFCS).
2. No ingredients naturally high in sugar are added (e.g., jam, sweetened chocolate, candied fruit).
3. No fruit juice concentrate is used as a sugar substitute.
4. If the product naturally contains sugar, it must state:
   “Contains naturally occurring sugars.”

Permitted wording includes:

• “No Added Sugar”
• “Unsweetened” (if no sweeteners are used)

C. “No Added Salt” Claims

Requirements include:

• No added sodium salts (including MSG, sodium benzoate, etc.).
• Not derived from high-sodium ingredients (e.g., soy sauce, salted fish).
• Must meet “Low Sodium” criteria.

D. Lactose Claims

Applicable only to products that normally contain lactose (e.g., milk powder, yogurt).

• Low Lactose: ≤ 2 g per 100 g
• Lactose Free: ≤ 10 mg per 100 kcal

E. Vegan Claims

Vegan claims are permitted and may include a vegan logo, provided the product fully complies with ingredient restrictions.

Strict Prohibitions Under the Regulation

BPOM strictly prohibits claims that:

• State or imply disease prevention, treatment, or cure
• Claim to fulfill all nutritional requirements
• Exploit consumer fear
• Encourage excessive or improper consumption

For example, statements such as:

• “Safe for diabetics”
• “Prevents heart disease”
• “Cures cholesterol”

are prohibited for processed food products.

Food is not medicine.

Laboratory Testing Requirement

All claims must be supported by laboratory analysis from:

• Accredited laboratories, or
• Government laboratories

Imported products may use laboratory results from accredited institutions in the country of origin.

Q: Can we independently claim “Gluten Free”?
A: No. You must provide laboratory evidence (e.g., gluten testing in mg/kg). Claims cannot be self-declared without data.

Q: Our product contains probiotics. Can we immediately claim health benefits?
A: No. Health function claims involving microorganisms require formal evaluation and written approval.

INSIGHTOF Service Proposal

PT. ICI Insightof is ready to help you navigate complex claim regulations through:

• Pre-Assessment Label Review
  We review your packaging design before BPOM submission to minimize rejection risk.
• End-to-End Food Product Registration
  Full processed food registration until NIE issuance.

Correctly placing claims on your packaging can significantly increase product value in the Indonesian market. However, doing it without regulatory guidance carries high risk.

Feel free to contact us via WhatsApp, and we will respond during Indonesian business hours.

Official website: www.insightof.co.id
Email: marketing@insightof.co.id

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