Mandatory Halal Certification Extended to 2028: Additional Time for Imported Products, Cosmetics, and Herbal Medicines

Government Regulation Number 40 of 2026, which amends Government Regulation Number 42 of 2024 on the Implementation of Halal Product Assurance, was promulgated on 14 October 2026 and published in the State Gazette of 2026 Number 156. Effective as of the date of its promulgation, the Regulation introduces amendments to Articles 160 and 161 of Government Regulation Number 42 of 2024.

ABOUT THE REGULATION

Government Regulation Number 40 of 2026 introduces a targeted adjustment to the implementation timeline for mandatory halal certification under Government Regulation Number 42 of 2024. Rather than changing the underlying certification obligation, the amendment primarily provides additional time for certain product categories to comply with the mandatory halal certification requirements.

The adjustment responds to practical challenges that remain in the implementation of the halal certification framework, including the readiness of businesses, the capacity of Halal Inspection Bodies, Halal Auditors and halal process facilitators, as well as supporting infrastructure and supply chains. For products originating from abroad, the Government also takes into account the progress of mutual recognition arrangements with partner countries.

Against this background, several product categories whose certification phasing period was previously scheduled to end on 17 October 2026 have now been granted an extended timeline until 17 October 2028. Importantly, the Elucidation makes clear that the extension is intended to provide additional time for implementation and does not remove or waive the obligation to obtain halal certification. Accordingly, affected businesses should view the extended period as additional time to prepare for compliance rather than an exemption from the mandatory halal certification regime.

COMPARISON

The most significant change introduced by Government Regulation Number 40 of 2026 is the extension of the halal certification timeline for several product categories that were previously approaching the 17 October 2026 deadline. For most affected categories, the deadline has been extended by two years to 17 October 2028, while a different commencement date applies to certain products originating from abroad.

The revised deadlines are summarized below:

As shown above, the extension primarily affects micro and small businesses in the food and beverage sector, certain products originating from abroad, herbal medicines and health supplements, cosmetics and chemical products, consumer goods, and Class A risk medical devices. Meanwhile, the existing timelines for over-the-counter and limited OTC drugs, as well as prescription drugs, remain unchanged.

A notable distinction applies to food, beverages, slaughtered products, and slaughtering services originating from abroad. Rather than simply extending the previous deadline, the amended framework provides that the mandatory halal certification requirement for these products will apply from 18 October 2028. This should therefore be distinguished from product categories whose phasing period ends on 17 October 2028.

KEY POINTS TO NOTE

■ Medium and large businesses. The extension does not affect the halal certification timeline for medium and large businesses in relation to food, beverages, slaughtered products, and slaughtering services. For these businesses, the phasing period already ended on 17 October 2024, meaning that the halal certification obligation is already applicable (Article 160(1)).

■ Services related to food and beverages. Services connected with food, beverages, and slaughtered products, other than slaughtering services, are subject to a separate timeline. The mandatory halal certification requirement for these services will apply from 18 October 2028 (Article 160(1a)).

■ Products originating from abroad. For food, beverages, slaughtered products, and slaughtering services originating from abroad, the halal certification obligation will apply from 18 October 2028. Its implementation will also take into account the completion of mutual recognition arrangements for Halal Certificates between Indonesia and the relevant partner countries (Article 160(3)).

■ Medical devices. Different timelines continue to apply depending on the risk classification of medical devices. The phasing period for Class B risk medical devices ends on 17 October 2029, while the phasing period for Class C risk medical devices ends on 17 October 2034 (Article 161(1) letters h and i).

■ Early certification remains available. Businesses are not required to wait until the end of the applicable phasing period to begin the certification process. A Halal Certificate may still be applied for earlier, allowing businesses to prepare for compliance ahead of the relevant mandatory deadline (Article 161(3)).

LEGAL CONSEQUENCES

Government Regulation Number 40 of 2026 does not introduce a new sanctions regime. Administrative sanctions for non-compliance with the mandatory halal certification requirements continue to be governed by Law Number 33 of 2014 on Halal Product Assurance, as amended, together with Government Regulation Number 42 of 2024.

Importantly, the extended phasing period should not be interpreted as a waiver or removal of the halal certification obligation. It merely provides additional time for the affected product categories to comply. Once the relevant phasing period has ended, products that are required to be halal-certified but continue to circulate without a Halal Certificate may be subject to administrative sanctions under the applicable regulatory framework.

EFFECTIVE DATE

Government Regulation Number 40 of 2026 was stipulated and promulgated in Jakarta on 14 October 2026 and became effective on the same date (Article II point 2). Its entry into force is also accompanied by several consequential adjustments to the existing regulatory framework.

In particular, all implementing regulations under Government Regulation Number 42 of 2024 must be adjusted to conform with the amendments introduced by Government Regulation Number 40 of 2026 (Article II point 1 letter a). In addition, the existing provisions concerning the conformity assurance of foreign halal products entering Indonesia are revoked and declared no longer valid (Article II point 1 letter b).

OTHER MATTERS

Several additional changes should also be noted. Article 160(4) of Government Regulation Number 42 of 2024 has been deleted as part of the amendment.

For products originating from abroad, the Elucidation of Article 160(3) further clarifies that their importation into Indonesia remains subject to the applicable customs and trade regulations. Accordingly, the revised halal certification timeline does not displace other regulatory requirements applicable to the importation of goods into Indonesia.

A separate approach also applies to drugs, biological products, and medical devices where the relevant raw materials are not yet sourced from halal materials and/or the manufacturing process is not yet halal. For these products, the applicable phasing period will follow the relevant laws and regulations, as provided under Article 161(1) letter j.

RECOMMENDATION

The additional period leading up to 2028 should be treated as a compliance preparation window rather than a postponement of the underlying obligation. Exporters and importers should use this period to identify and map products that fall within the mandatory halal certification regime, assess the applicable certification timeline for each product category, and prepare the necessary compliance measures ahead of the relevant deadline.

Businesses dealing with products originating from abroad should also closely monitor the development of mutual recognition arrangements between halal bodies in their home countries and the Halal Product Assurance Organizing Agency (BPJPH). At the same time, businesses should remain attentive to further implementing regulations and regulatory adjustments following Government Regulation Number 40 of 2026, particularly where these may affect the certification process or requirements applicable to imported products.