From the perspective of foreign business operators, Indonesia represents one of the most attractive destinations for expansion in the Food and Beverage (F&B) sector. With a population exceeding 270 million, a growing middle class, and strong consumer demand, the Indonesian market offers significant opportunities for foreign enterprises seeking to introduce and distribute their products. 

However, the enthusiasm to penetrate this vast market is often accompanied by regulatory uncertainties, particularly in the field of product compliance. Foreign businesses are commonly faced with a fundamental question: which license should be secured first before entering the Indonesian market BPOM permit or Halal certification? Should both processes be undertaken in sequence, or can they be pursued concurrently to accelerate market entry?

This dilemma is both practical and strategic. On the one hand, the BPOM (National Agency of Drug and Food Control) serves as the gatekeeper for food safety and product legality, ensuring that imported products meet Indonesian health and safety standards before distribution. On the other hand, Halal certification mandated under Indonesian law reflects the religious and consumer protection framework that is equally essential in a majority Muslim country.

Foreign businesses, therefore, must carefully determine the regulatory pathway to ensure smooth entry into the Indonesian market. A clear roadmap is indispensable, not only to comply with the applicable laws but also to avoid duplication of efforts, delays in approvals, or potential legal risks that could arise from non-compliance.

This article will discuss these issues in detail, providing foreign business operators with a comprehensive perspective on the regulatory priorities whether to pursue BPOM permit first, Halal certification first, or both simultaneously—when seeking to expand their F&B products into the Indonesian market.

Read More: A Complete Guide to BPOM Registration

Product Registration – BPOM License (Izin Edar)

For imported food and beverage products, obtaining a BPOM license—commonly referred to as Izin Edar BPOM—is a mandatory prerequisite before the products can be lawfully distributed within the Indonesian market. Products categorized as ML (Makanan Luar / Imported Food) must undergo a structured two-stage process, ensuring both safety and regulatory compliance.

1. Preliminary Compliance: SMKPO (Sistem Manajemen Keamanan Pangan Olahan)
   SMKPO refers to the Processed Food Safety Management System, which serves as a preliminary compliance stage confirming that the product has been assessed under Indonesia’s food safety management requirements. This step forms the regulatory basis and is a prerequisite before the full BPOM Permit application can be filed.
2. BPOM License (Izin Edar BPOM – ML Number)
   The BPOM license constitutes the final approval authorizing the product’s lawful distribution in Indonesia. Registration requires submission of a comprehensive dossier to BPOM, including product composition, labeling, packaging, testing reports, and supporting documentation evidencing compliance with Indonesian food safety standards.

Key Principle: Without a valid BPOM License, F&B products cannot be legally imported or sold in Indonesia—even if Halal certification has already been obtained.

Halal Certification 

Under the Halal Product Assurance Law (Law No. 33 of 2014), Halal certification is mandatory for all food and beverage products marketed in Indonesia, except for those explicitly categorized as haram or exempted under the “positive list.” This legal obligation reflects not only a regulatory requirement but also the market expectation of Indonesia as the world’s largest Muslim-majority country.

The Indonesian Government, through the Halal Product Assurance Organizing Agency (BPJPH), has reinforced this obligation with the issuance of Government Regulation No. 42 of 2024 (PP 42/2024), which sets out the phasing schedule:

1. For domestic medium and large-scale businesses, mandatory Halal certification applies from 18 October 2024.
2. For imported food and beverage products. 
3. In the interim period, imported products may enter the Indonesian market provided that they secure a BPOM License (Izin Edar) and, where applicable, register foreign-issued Halal certificates through BPJPH’s SiHalal portal if covered by a Mutual Recognition Agreement (MRA).

Read More: What is SMKPO

Interrelation Between BPOM Permit and Halal Certification

In practice, foreign F&B companies must treat both BPOM Permit and Halal Certification as equally indispensable. However, the sequencing depends on the product’s purpose and timeline for market entry:

1. BPOM License First
   From a strictly legal standpoint, the BPOM License constitutes the gateway license for foreign food and beverage products entering Indonesia. Without this permit, no imported product may be lawfully distributed, even if it already carries a Halal certificate from abroad. The BPOM License process entails two critical stages:
   • SMKPO (Sistem Manajemen Keamanan Pangan Olahan) – a compliance mechanism that verifies whether the product meets Indonesia’s processed food safety management standards. It acts as the foundation for any subsequent BPOM application.
   • Izin Edar BPOM (ML Number) – the final regulatory approval issued by BPOM that legally authorizes the product for importation and sale in the Indonesian market.

     By prioritizing BPOM, foreign businesses establish the regulatory legitimacy of their products, ensuring that they are legally recognized and can enter Indonesian distribution channels. This step is non-negotiable, as BPOM operates as the country’s chief food safety authority.

2. Halal Certification Thereafter
   While BPOM addresses safety and legality, Halal Certification addresses religious compliance and consumer protection. Under Law No. 33 of 2014 and Government Regulation No. 42 of 2024. In the interim, imported products may still circulate with a valid BPOM Permit, but businesses are strongly advised to initiate Halal certification as early as possible, for several reasons:
   • Documentation Overlap: The same product data required by BPOM (ingredients, labeling, production process) is also necessary for Halal certification, allowing businesses to streamline compliance efforts.
   • Market Advantage: Even before the deadline, Halal certification significantly enhances consumer trust and retail acceptance, given that over 85% of Indonesia’s consumers are Muslim.
   • Regulatory Preparedness: Early certification avoids last-minute bottlenecks and ensures uninterrupted market access once Halal enforcement becomes absolute.
3. Current Approach
   In practice, the concurrent approach—pursuing both the BPOM License and Halal Certification at the same time—is increasingly recognized as the most strategic pathway for foreign enterprises. The advantages are manifold:
   • Regulatory Synergy: Since BPOM and Halal both require similar product documentation, simultaneous preparation minimizes duplication of effort and reduces inconsistencies.
   • Time Efficiency: Running both processes in parallel shortens overall lead time, thereby accelerating market entry and avoiding sequential delays.
   • Market Readiness: By securing both approvals, companies achieve dual compliance—ensuring products are not only legally marketable (via BPOM) but also religiously acceptable (via Halal).
   • Future-Proofing: With the Halal obligation for imported products, concurrent certification guarantees that foreign businesses are fully prepared and compliant well in advance.

Strategic Insight: While BPOM remains the legal prerequisite for entry, Halal certification represents a market necessity. The concurrent approach, therefore, balances regulatory compliance with consumer expectations, offering foreign enterprises both legal certainty and competitive advantage.

Read More: Halal Certification Procedure and Timeline in Indonesia

Conclusion

For foreign enterprises seeking to expand into Indonesia’s dynamic Food and Beverage sector, securing both the BPOM License and Halal Certification is not merely a regulatory formality but a dual necessity. Each requirement serves a distinct yet complementary purpose: the BPOM License guarantees the product’s safety and legality of distribution, while Halal Certification ensures religious compliance, consumer confidence, and market acceptance in a predominantly Muslim country.

It must be emphasized that the BPOM License operates as the absolute legal prerequisite: without it, no product may be imported or sold in Indonesia, irrespective of its Halal status. At the same time, Halal Certification—mandated under Indonesian law—functions as an indispensable consumer protection mechanism and a decisive factor in purchasing behavior. In view of this regulatory landscape, the most prudent and strategic approach is to pursue both processes concurrently. By aligning documentation and synchronizing submissions, foreign businesses may:

1. Avoid duplication of effort and administrative inefficiency;
2. Reduce the risk of delays arising from sequential applications;
3. Secure a faster and smoother entry into the Indonesian market; and
4. Establish a robust compliance framework that safeguards long-term operations.

A concurrent strategy not only ensures legal certainty under Indonesian law but also provides a clear competitive advantage, as consumers and distributors increasingly favor products that demonstrate both regulatory compliance and Halal assurance.

ET Consultant stands ready to provide comprehensive assistance throughout this process—from preliminary advisory, preparation of documentation, and coordination with BPOM and BPJPH, to the final issuance of permits and certificates. With our expertise in regulatory compliance and market-entry strategies, we are committed to guiding foreign businesses toward seamless integration into the Indonesian F&B market with full compliance, accuracy, and efficiency.

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ET Consultant is a Business Consultant and Legal Consultant Expert that provides support for local and multinational clients to start and manage their business operations in Indonesia. ET Consultant specializes in Business Incorporation, Licensing & Legal, Accounting & Taxes, Immigration, and Advisory Services.

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