On June 23, 2026, the Indonesian Food and Drug Authority (BPOM) adopted Regulation No. 11 of 2026 on Food Packaging, replacing the previous 2019 regulation (No. 20). The regulation entered into force on June 30, 2026, and establishes requirements for food contact materials (FCMs) and substances used in food packaging. Existing food packaging products must comply with the new regulation within 12 months of its entry into force, although some migration requirements may be implemented gradually following risk assessment.
The regulation applies to a broad range of food packaging materials, including:
- Plastics
- Rubber and elastomers
- Paper and board
- Ceramics
- Glass
- Metal and metal alloys
- Multilayer materials
The regulation also contains dedicated chapters on reusable food packaging and food packaging made from recycled materials.
Several elements of the regulation, including migration testing, the use of overall and specific migration limits, and positive lists of authorized substances, resemble approaches used in the EU’s FCM regulation (FPF reported).
Migration testing forms basis of the framework
Indonesia’s approach relies heavily on migration testing. Packaging materials in direct contact with food must comply with overall migration limits, which assess the total amount of substances transferred from packaging into food, and specific migration limits, which limit migration of individual substances known to pose health concerns. For example, for plastics, the regulation establishes an overall migration limit of 60 mg/kg food or 10 mg/dm² food-contact surface area.
The regulation further specifies migration limits for numerous monomers, additives, and residual substances associated with specific polymers. Examples include formaldehyde, melamine, styrene, vinyl chloride, acrylonitrile, and bisphenols.
List of authorized food contact chemicals
The regulation establishes a positive list of food contact chemicals authorized for use in food packaging, which includes more than 1,300 entries covering additives and other food contact chemicals that may be used in specific materials and functions. They include plasticizers, colorants, adhesives, printing ink components, stabilizers, antioxidants, solvents, antimicrobial agents, coating ingredients, and lubricants and modifiers.
Some substances, including chemicals of concern, are authorized subject to migration limits, while others may be authorized without specific migration limits. The regulation also includes product-specific restrictions for certain chemicals of concern. For example, bisphenol A (BPA) and bisphenol S (BPS) remain authorized in certain applications subject to a migration limit of 0.05 mg/kg food, while BPA is prohibited in polycarbonate food contact articles intended for babies and children under three years old. The problematic plasticizer, di(2-ethylhexyl) phthalate (DEHP; CAS 117-81-7), is also included within the authorized substances, subject to a migration limit of 1.5 mg/kg food.
List of prohibited food contact chemicals
The regulation further establishes a list of food contact chemicals that are explicitly prohibited from use in food packaging, including various chlorinated solvents, carcinogenic substances, asbestos, chromates, and certain fluorinated substances. Although the prohibited list includes some fluorinated food contact chemicals like ammonium bis(N-ethyl-2-perfluorohexanesulfonamido ethyl) phosphate and ammonium bis(N-ethyl-2-perfluorooctanesulfonamido ethyl) phosphate, the regulation does not appear to establish a broad restriction covering per- and polyfluoroalkyl substances (PFAS) as a chemical class.
Explicit provisions for reusable and recycled packaging
The regulation introduces dedicated requirements for reusable and recycled food packaging. Reusable packaging must continue to comply with migration requirements throughout its intended use, while reusable plastic packaging is subject to additional migration testing provisions. Recycled packaging is generally required to comply with the same requirements that apply to virgin food contact materials.
Process for authorization of new substances and materials
The regulation establishes a formal authorization pathway for food contact materials and substances that are not already covered by the regulation. Companies wishing to use new food contact substances or packaging materials must submit an application to BPOM including:
- Applicant information
- Information on the food contact substance or material
- Testing data and results
The substance may only be used following written approval from BPOM based on a food packaging safety assessment.
Reference
BPOM (2026). “Peraturan Badan Pengawas Obat dan Makanan Nomor 11 Tahun 2026 tentang Kemasan Pangan [Regulation No. 11 of 2026 on Food Packaging].” (pdf, Indonesian)
