Indonesia Processed Food Registration (Low-Medium Risk)

Criteria for Low-Medium Risk Processed Food:

• Not classified as Special Purpose Processed Food (PKGK).
• Not a processed food with claims.
• Not an organic product or made using genetically modified ingredients.
• Does not undergo the following processing methods:
  • Pasteurization
  • Sterilization / UHT / LACF
  • Irradiation
  • Other New Technologies
  • Freezing / Frozen storage without further cooking process
• Not categorized as specific processed food such as those requiring SNI certification or alcoholic beverages.
• Does not contain restricted raw materials.
• Does not use flavorings or food additives (BTP) with an Acceptable Daily Intake (ADI) or a numerical maximum limit.

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Registration Document Processing Flow:

1. Log in to the e-registration website at ereg-rba.pom.go.id.
2. Fill in the required data and upload documents according to the requirements.
3. Generate and retrieve an ID permit from OSS.go.id, then continue the submission process on Ereg RBA.
4. Payment Order Letter (SPB) is issued.
5. Issuance of PB-UMKU (Certificate of Compliance for Processed Food Commitments).
6. Submission of compliance fulfillment by the business operator.
7. Evaluation of compliance fulfillment by officers:
   • If the commitment is canceled, the PB-UMKU number becomes invalid.
   • If the commitment is approved:
     • With notes → The PB-UMKU number remains valid but requires improvements according to the notes.
     • Without notes → The PB-UMKU number remains valid.

Note:

• The data entered and uploaded documents must be accurate and in compliance with regulations.
• Once the Certificate of Compliance for Processed Food Commitments is issued, the business operator must submit a compliance evaluation within a maximum of 12 months.

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Self-Evaluation of Compliance Fulfillment

a. Ensure product data is correct:

• Product Type Name, Brand Name
• Weight / Net Content
• Serving size (for ING)
• Processing Method
• Food Category
• Type of Packaging
• For imported products: Compliance with the Health Certificate / Free Sale Certificate and Letter of Appointment (LOA)

b. Ensure that the inputted composition matches the uploaded documents:

• Use of Food Additives (BTP) within the maximum limit.
• Use of Raw Materials that do not have a maximum limit or are prohibited according to regulations.

c. Ensure the label design complies with regulations:

• Label design must comply with regulations.
• Must not include:
  • Claims of being not for special dietary use
  • Organic, GMO, or Irradiation logos
  • Specific processing methods (e.g., sterilization, pasteurization)
  • Food Additives with maximum limits, flavor additives, certain raw materials, or prohibited substances as per regulations.

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Evaluation Results of Compliance Fulfillment

The compliance evaluation results may be:

• Approved: The input data and uploaded documents are correct and meet the requirements.
• Approved with Notes: There are minor errors or missing information that do not cause cancellation.
• Canceled: The commitment is not fulfilled.

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Top 5 Reasons for Certification Cancellation

Based on previous compliance evaluations, the top five reasons for the cancellation of the Certificate of Compliance for Processed Food Commitments are:

1. Incorrect selection of packaging type.
2. Incorrect selection of food category.
3. Contains food additives (BTP) exceeding the maximum limit.
4. Contains raw materials exceeding the maximum limit.
5. Failure to upload the Health Certificate / Free Sale Certificate.

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INSIGHTOF offers comprehensive regulatory services to facilitate market entry in Indonesia, specializing in BPOM and Kemenkes product registration with expert guidance every step of the way.

For any inquiries, please feel free to contact us at marketing@insightof.co.id.