Indonesia BPOM Regulation No. 11/2026 Updates Food Packaging Rules: Key Changes for FCM Suppliers OG Title

Key Regulatory Facts at a Glance

The regulation applies most directly to producers of packaged food. It also creates new testing, formulation-review, and evidence priorities for packaging manufacturers, raw-material suppliers, exporters, importers, brand owners, and other companies that support downstream compliance in Indonesia.

What Changed under BPOM Regulation No. 11/2026?

1. Migration Controls Replace Reliance on Legacy Extractives Tests

Under the 2019 regulation, many plastic material specifications included extractives-based tests using solvents such as n-heptane, with some limits expressed in mg/cm². The 2026 regulation restructures testing around overall migration and specific migration requirements linked to material type and intended use.

For plastic food packaging, the general overall migration limit is 60 mg/kg or 10 mg/dm². The regulation also introduces the following general specific migration requirements for heavy metals in plastics:

These general limits sit alongside polymer-specific and substance-specific requirements in the annexes. Companies should therefore avoid treating the heavy-metal table as a complete test list for every plastic article.

2. Standardized Food Simulants and OM Test Conditions Are Introduced

The new testing annexes use a structured food-simulant system:

• Simulant A: 10% ethanol (v/v)

• Simulant B: 3% acetic acid (w/v)

• Simulant C: 20% ethanol (v/v)

• Simulant D1: 50% ethanol (v/v)

• Simulant D2: vegetable oil meeting the specified criteria

• Simulant E: poly(2,6-diphenyl-p-phenylene oxide)

For overall migration, the regulation establishes OM0 through OM7 conditions covering short contact, long-term storage, hot-fill and high-temperature uses. It also provides OM8 and OM9 substitute conditions when OM7 testing with Simulant D2 is not technically feasible.

This architecture is broadly familiar from the migration-testing approach used in EU Regulation No. 10/2011 for plastic food contact materials. However, EU test reports should not be assumed to demonstrate Indonesian compliance automatically. The applicable substance lists, restrictions, material scope, and regulatory basis must still be assessed against BPOM Regulation No. 11/2026.

3. Permitted Food Contact Substances Are Mapped across Material Categories

The regulation covers seven packaging material categories: plastics; rubber and elastomers; paper and paperboard; ceramics; glass; metals and metal alloys; and multilayer materials. For direct-contact materials, applicable migration requirements must be met.

Annex III organizes permitted food contact substances into two groups: substances with migration-limit requirements and substances without migration-limit requirements. The tables indicate whether listed substances may be used in key material categories and specify function and migration limits where relevant. Annex IV separately lists prohibited food contact substances.

This structure makes composition-level screening essential. Companies should compile substance names, CAS numbers where available, functions, material layers, supplier declarations, and intended-use conditions before deciding which tests are needed.

4. Unlisted Materials and Substances Need BPOM Safety Assessment

Food packaging materials or food contact substances outside the categories or lists specified in the regulation may only be used after written approval from the Head of BPOM based on a food packaging safety assessment. An application must include, at a minimum, applicant information, data on the material or food contact substance, and food packaging test results.

For suppliers introducing a new additive, coating component, polymer, or other unlisted substance, positive-list screening should take place early. Discovering an unlisted substance after commercial testing or shipment planning may create avoidable delays and duplicated work.

5. Melamine Migration Limits Are Significantly Lower

For melamine-formaldehyde plastics, the specific migration limit for melamine is reduced from 30 mg/kg under the 2019 framework to 2.5 mg/kg. For food packaging materials or articles intended for infants, the limit is 1 mg/kg, and microwave heating of those materials or articles is prohibited.

Manufacturers and importers of melamine tableware or related articles should review formulation, intended users, use instructions, and test evidence against the new limits.

6. Reusable Plastic Packaging Is Subject to Successive Migration Tests

Annex V introduces detailed testing rules for reusable plastic food packaging:

• Overall migration is generally tested three times on one sample using fresh portions of food simulant. The second result must be lower than the first, and the third must be lower than the second. Compliance is generally assessed using the third result.

• Specific migration is also generally tested three times. The second result must not exceed the first, and the third must not exceed the second. Compliance is based on the third result and on material stability across the three tests.

• If migration is detected and results increase from the first to the third test, material stability is considered inadequate. Compliance cannot be established even when the individual results remain below the specific migration limit.

• The annex allows limited alternatives or reduced testing where the prescribed same-sample method is technically impracticable or convincing scientific evidence demonstrates decreasing migration and compliance from the first test.

Transition Period and Key Deadline

Food packaging already circulating when the regulation entered into force must meet the new requirements no later than 12 months after promulgation — by June 30, 2027. This general transition provision does not automatically mean that every migration limit follows the same implementation date. Article 4 allows migration-limit requirements to be phased, and Article 13 provides an exception for limits implemented progressively based on risk assessment.

Companies should monitor future BPOM decisions and avoid assuming that the transition period postpones all compliance work until mid-2027.

What Should FCM Companies Do Next?

1. Confirm product scope and material classification. Identify every food-contact layer and determine whether the product is single-use, reusable, recycled, or multilayer.

2. Build a complete composition inventory. Collect raw-material specifications, substance names, CAS numbers, functions, supplier declarations, and existing compliance statements.

3. Screen substances against the new permitted and prohibited lists. Flag restrictions, migration limits, and unlisted substances before commissioning tests.

4. Review existing reports for regulatory usability. Check whether the simulant, contact time, temperature, analytical limit of detection, sample configuration, and repeated-use conditions match the new BPOM requirements.

5. Develop a risk-based testing plan. Select overall migration, specific migration, heavy-metal, monomer, and other tests according to the material, formulation, intended food, and worst foreseeable use.

6. Update Declarations of Compliance and technical files. Ensure that downstream customers, importers, procurement teams, and auditors receive evidence that reflects the 2026 regulation.

7. Plan early for BPOM assessment where needed. If a material or substance is not listed, assess the data package and local submission route before finalizing market-entry timing.

Why This Update Matters beyond Indonesia

Indonesia is one example of why ASEAN food contact materials compliance requires a market-by-market strategy. ASEAN does not operate a single, fully harmonized FCM approval system, and national rules differ in material scope, substance controls, testing methods, documentation expectations, and authority-facing procedures.

Companies exporting the same packaging material or article to Indonesia, Vietnam, Thailand, Malaysia, the Philippines, or Singapore should not rely on one universal compliance file. REACH24H's ASEAN food contact materials compliance services support country-specific regulatory assessment, positive-list screening, testing strategy, Declaration of Compliance preparation, technical file development, and registration or certification planning where applicable.

How REACH24H Can Help

REACH24H can help companies assess the Indonesian requirements and build a practical, country-specific pathway for Indonesia and other Southeast Asian markets.

• Regulatory assessment: Indonesia and ASEAN FCM regulatory applicability assessment.

• Substance screening: food contact substance and positive-list screening.

• Evidence gap analysis: review of existing EU, U.S., China, Japan, or other test reports.

• Testing strategy: customized migration, heavy-metal, monomer, and repeated-use testing strategies.

• Compliance documentation: Declaration of Compliance and technical file preparation.

• Authority-facing support: BPOM safety-assessment and application coordination for unlisted materials or substances, where applicable.

• Regional planning: multi-market ASEAN compliance planning and regulatory monitoring.

Recommended Reading

• ASEAN Food Contact Materials Compliance: Market Access Services for Food Packaging Exporters

• ASEAN Food Contact Material Regulations by Country: What Exporters Need to Know

• How to Navigate EU, US and ASEAN Food Contact Materials Regulations: Compliance Routes for Exporters

• Food Packaging Exports to Southeast Asia: Why Test Reports Are Not Enough for ASEAN FCM Compliance

Official Resources

• BPOM Legal Database — Regulation No. 11 of 2026 on Food Packaging

• BPOM Legal Database — Regulation No. 20 of 2019 on Food Packaging (revoked)

• EUR-Lex — Consolidated Regulation (EU) No. 10/2011