Indonesia’s food market is regulated by BPOM (the Indonesian FDA). Every imported food product needs a BPOM marketing permit (“Izin Edar”) before it can be sold. Foreign manufacturers must work through a local entity or agent to submit detailed applications. This is typically done via BPOM’s online portal, listing ingredients, manufacturing process, shelf life, labels, etc.
The BPOM will even audit distribution facilities for safety compliance. Importantly, the extent of BPOM’s review depends on the product’s risk category.
Since 2017, BPOM has used a risk-based registration system. Processed foods are classified into high, medium, low, or very-low risk classes based on factors like special ingredients (e.g. additives, preservatives), processing methods, and label claims. This classification drives the whole approval process.
Risk Categories and Registration Routes
Under BPOM rules, high- and medium-risk foods (e.g. products with special processing, additives, or bold health claims) go through a full evaluation process. In contrast, low- and very-low-risk foods (e.g. simple shelf-stable snacks without high-risk ingredients) go through a simpler notification process. In practice, this means different timelines and requirements:
- High/Medium Risk Foods: Registration requires a complete dossier including ingredient lists, manufacturing details, label design, shelf-life data, and comprehensive lab analyses (microbiological tests, heavy metal testing, nutrient analysis, and tests for any specific food additives or contaminants). These rigorous requirements ensure products with greater safety concerns meet all standards.
- Low/Very-Low Risk Foods: qualify for a simpler notification route. These products typically still need ingredient lists, process description, label layouts, and shelf-life info – plus nutritional analysis (unless the producer is a small local business). Critically, they do not require the extensive contaminant lab tests.
These differences mean that a typical packaged snack (e.g. chips, crackers, cookies with standard ingredients) often falls into the low-risk category. It can be registered quickly. Conversely, snacks with unconventional ingredients or processes (fermented items, items with health claims or novel additives) might be bumped into the higher-risk pathway. This triggers longer review and testing.


Key Differences: Low Risk vs. High Risk Registration
- Approval Timeline: Low-risk snacks follow a notification process that typically takes about 10 working days after submission. High-risk products require 30 working days of BPOM evaluation. This means low-risk products can reach market much faster. Often, they do so in a couple of weeks compared to months for high-risk items.
- Documentation & Testing: Low-risk registration needs basic documentation (composition, process, label, shelf life, and nutrition facts). High-risk registration requires additional testing and reports, including laboratory analyses for microbial contamination, heavy metals, nutrient content, and certain additives. In short, high-risk snacks need validated lab test results, whereas low-risk snacks usually do not.
- Review Process: Low-risk notifications are generally a rubber-stamp check of forms. In contrast, high-risk evaluations involve a substantive review of safety data. In practice, high-risk approval acts like a mini safety audit – BPOM may take a closer look at production methods, quality control, and test results.
- Risk of Rejection: Because high-risk applications are scrutinized more, any deficiencies (e.g. missing data, label errors, or test failures) can delay or reject the permit. Low-risk products have fewer hurdles, but still must avoid basic errors (labels in Indonesian, etc.) to pass the 10-day review smoothly.
Strategic Implications for Exporters

Understanding these categories is crucial for planning. For time management, if your snack formula puts it in a higher-risk class, start the registration process well ahead of your launch date. High-risk reviews can take 30 business days and may involve back-and-forth queries. For a low-risk item, you still need to prepare the dossier carefully, but you can expect final approval in about two weeks after submission.
On cost, anticipate that high-risk classification means extra expenses. You’ll need to pay for accredited laboratory tests (microbiology, heavy metals, etc.) and possibly local consultancy or a local testing partner. These tests not only cost money but also time (collecting samples, shipping to the lab, waiting for results). Low-risk products save on those analyses, reducing upfront costs. (Note: BPOM’s own registration portal has no fixed fee for food registration, but the preparation work and testing do incur real costs.)
For risk management, accurately classify your product from the start. Avoid underestimating the risk category. If BPOM determines a snack is high-risk (for example, if it contains certain preservatives or health claims you missed), your application could be delayed unexpectedly. To mitigate this, engage local experts or consultants familiar with BPOM rules. They can pre-screen your documentation and ingredients so that you submit under the correct category. Quality control is key: maintain thorough records and test results to support your claims.
Finally, consider product design as a strategy: if speed to market is crucial, could you reformulate or re-label to stay in the low-risk bracket? For instance, removing non-essential health claims or novel additives can keep your snack in the low-risk channel. This isn’t always possible, but it’s a strategic consideration for exporters balancing time and cost.
It’s important to note that these timelines depend on BPOM’s internal processing capacity and may be extended. This can happen if the agency requests clarifications, revisions, or additional data.
Even low-risk applications can face delays if documentation is incomplete or unclear. Exporters are advised to ensure that all submitted materials are accurate, compliant, and professionally prepared. This helps minimize unnecessary back-and-forth.
By aligning your product strategy with Indonesia’s classification scheme and being proactive in documentation, foreign exporters can manage time, cost, and compliance risks more effectively.
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