Indonesia has clarified regulations for selling so‑called “high-pH” or alkaline bottled water. Under a new Ministry of Industry decree (No. 62/2024) and BPOM (Food and Drug) rules, all packaged drinking water must meet mandatory SNI standards before registration. In particular, “Air Minum pH Tinggi” is now formally defined and regulated. High‑pH water is “AMDK [packaged drinking water] that contains certain minerals (with or without added minerals or oxygen) and has a high pH, and is safe to consume.”. The new policy requires an SNI certificate for this product and treats it as a “medium-high risk” processed food, with full documentation and testing.
Mandatory SNI Standards for Bottled Water
Under Permenperin 62/2024, all bottled water products are subject to SNI. The regulation lists five key SNI standards for different water types. In particular:
- SNI 8982:2021 – High‑pH Drinking Water. This standard defines the product (“Air Minum pH Tinggi”) and its quality requirements (mineral content, pH level, purity, etc.). It ensures that the water’s composition and contaminants comply with safety and health parameters.
- SNI 3553:2023 – Bottled Mineral Water (Air Mineral). Specifies parameters for mineral water (inherent mineral content, allowable additives, safety tests).
- SNI 6241:2023 – Demineralized Water. Covers water purified by processes like distillation or RO, ensuring it meets purity standards.
- SNI 6242:2023 – Natural Mineral Water. Applies to bottled water directly from natural springs, with controlled processing.
- SNI 7812:2021 – Dew Water. Covers water produced by condensing natural dew under controlled conditions.
Each SNI lays out the product definition, allowable composition (e.g. minimum oxygen or mineral content), and testing methods. For high‑pH water, SNI 8982:2021 in effect sets a minimum pH level and requires lab tests (e.g. for minerals, coliforms, bromate if ozone is used) to certify safety. (For example, BPOM notes that if ozone is used in production, the finished water must be tested for bromate to meet SNI requirements)
BPOM Registration: Medium‑High Risk and Required Documents
Because high‑pH water requires an SNI, BPOM classifies it as a medium-high risk processed food. According to BPOM Regulation No. 23/2023, products in this risk category must include comprehensive documentation when applying for market registration. In practice, companies registering high-pH bottled water should prepare the following:
- Product Formula & Ingredients: Provide a detailed composition or ingredient list, including the source of water and any additives.
- Production Details: Describe the manufacturing process, production flow, and in-line control points.
- Shelf Life and Production Codes: Include evidence from stability or shelf-life studies and outline your batch or lot coding system.
- Label Design: Submit a draft packaging label (in Bahasa Indonesia) showing all required claims and information. Once certified, this label must include the SNI mark.
- Authorized Agent Letter: For exports, issue a Letter of Appointment to the Indonesian distributor or local agent.
- Laboratory Analyses: Submit certificates of analysis for the final product, confirming compliance with food safety standards. This includes microbiological and chemical tests. If you list nutritional values, also include a nutrient content analysis.
- SNI Certification: Most importantly, attach a valid SNI Certificate (SPPT SNI) for SNI 8982:2021, along with supporting lab test results that prove the product meets SNI parameters.
- Import Documents (if applicable): For imported products, prepare clear product photos (showing foreign labels), sworn translations, a Free Sale or Health Certificate from the origin country, and a Letter of Appointment.
These requirements closely reflect the BPOM infographic summary: composition, process, shelf life, labeling, and SNI compliance data. In short, applicants should expect a rigorous submission process—similar to that for other medium-high risk foods.
Timelines and Deadlines
The Ministry of Industry’s SNI mandate (Permenperin 62/2024) is now in force. BPOM has confirmed that starting April 21, 2025, all new registrations for high-pH water must include an SNI certificate. Here’s how companies should respond:
- Now–End of 2024: Begin the SNI certification process immediately if you haven’t already. Apply to a designated certification body (LSPro), and submit your product for lab testing at accredited facilities. Since SNI certification (Type 5) includes factory audits and lab analysis, it may take several months. Early action is critical.
- Early 2025: Start preparing your BPOM registration documents. Assemble the required dossier, coordinate with your local representative, and ensure all foreign-language labels are translated and validated.
- By April 21, 2025: Ensure that any new registration includes SNI compliance. BPOM will reject applications lacking the SNI certificate. This deadline, emphasized in BPOM’s public notices, aligns with the Ministry’s SNI enforcement date.
Strategic Recommendations
To meet these regulations and capture market opportunities, companies should take the following steps:
- Engage Early with Certification Bodies
Reach out to a BSN-accredited certification agency (LSPro) as soon as possible. Confirm that your lab test provider is accredited to test all necessary parameters—pH, minerals, contaminants, and more. Remember, the certification follows a Type-5 product certification scheme. - Review Product Formulation
Re-examine your water’s composition to ensure it meets SNI 8982:2021 requirements. For instance, if you use ozone treatment, plan for bromate testing. Pre-testing your products can help avoid delays during certification. - Ensure Label & Document Compliance
Design labels in Bahasa Indonesia and verify that all health and nutrition claims are backed by supporting data. BPOM will closely scrutinize claims for medium-high risk products. Additionally, gather all necessary export documents—such as health certificates—and prepare certified translations. - Partner Locally
If you’re exporting, appoint a reliable Indonesian partner. A local representative can navigate BPOM’s SIINas registration system, manage regulatory communication, and assist with language or logistical issues. - Monitor Regulatory Updates
Stay informed about BPOM announcements and SNI revisions. For example, some regions like Bali have imposed bottle size restrictions. Always verify your compliance with both national and local rules. - Plan Time and Budget Accordingly
Factor in the costs and lead times for both SNI certification and BPOM registration. This includes testing and application fees. For example, the SNI 8982 registration fee is approximately Rp2.3 million. Build these into your planning timeline.
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