On August 28, 2026, Indonesia submitted the WTO TBT notification G/TBT/N/IDN/193, soliciting public comments on the draft BPJPH Regulation on Halal Supervisors, with comments due by October 27, 2026. The draft regulation, comprising ten chapters and 28 articles, systematically establishes the qualification requirements, duties and authorities, registration procedures, and oversight mechanisms for Halal Supervisors, covering multiple product sectors including food, beverages, pharmaceuticals, and cosmetics.
Background
Under Article 65 of Government Regulation No. 42 of 2024, implemented pursuant to Law No. 33 of 2014, business actors applying for a Halal Certificate are required to have a Halal Supervisor. Previously, requirements for Halal Supervisors were dispersed across various regulatory instruments.
With the October 2026 deadline for mandatory halal certification approaching, BPJPH has developed this dedicated regulation to establish a unified and clear management framework for Halal Supervisors across all categories of business actors, including foreign enterprises.
General Qualification Requirements for Halal Supervisors
Under Article 17 of the draft regulation, all categories of Halal Supervisors must meet the following basic requirements:
- Muslim;
- Possess broad knowledge and in-depth understanding of halal-related sharia (Islamic law), evidenced by a training certificate and/or a competency certificate; and
- At least 18 years of age.
Duties and Authorities of Halal Supervisors
The main duties of a Halal Supervisor include:
- Supervising the Halal Product Process (PPH) within the enterprise;
- Determining corrective and preventive actions; and
- Coordinating PPH-related activities and accompanying halal auditors during inspections.
In terms of authorities, Halal Supervisors are entitled to access all information and documents related to SJPH implementation throughout the entire production chain, conduct internal audits and management reviews, determine corrective and preventive actions, propose temporary operational suspension when non-conformities that may affect product halal status are identified, control material approval, request explanations from all relevant parties, and coordinate laboratory testing.
Registration and Management Mechanism
Under the draft regulation, halal supervisors must register with BPJPH through the SIHALAL electronic system, submitting materials including identity documents, curriculum vitae, training and competency certificates, employment agreements, proof of residence, and recent ID photographs. BPJPH must complete the document review within five working days. The registration fee must be paid within five working days after the invoice is issued (extendable up to twice). The registration number will be issued within two working days after payment confirmation.
Where a halal supervisor is found to have violated the provisions on halal product assurance (JPH) management, or has not been designated by any enterprise as a halal supervisor for four consecutive years, BPJPH will revoke his/her registration number, and re-registration will not be permitted thereafter. Enterprises may replace halal supervisors under specified circumstances, including failure to meet qualification requirements, violation of JPH regulations, disclosure of business secrets, resignation, expiration of contract, management decisions, or the death of the supervisor.
Transitional Arrangements
Article 27 of the draft regulation provides that Halal Supervisors already designated prior to the entry into force of this regulation shall remain recognized, but must complete compliance adjustments within two years from the effective date.
What Can CIRS Do for You?
Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services, from regulatory compliance, laboratory testing, and R&D to data services across multiple industries.
The CIRS cosmetic team provides expert support to ensure that cosmetic products meet stringent global cosmetic regulations and safety standards. We offer comprehensive, lifecycle-based solutions for personal care products, from early-stage cosmetic ingredient development through to final product registration. Our services include:
- Cosmetic ingredient development and regulatory strategy,
- Physical/chemical and analytical tests,
- Toxicological tests (in vivo & in vitro),
- Efficacy and claim substantiation studies (in vivo & in vitro), and
- Ingredient and product registration across global markets.
With deep expertise in cosmetic regulatory compliance and safety evaluations, our team enables brands to bring products to market efficiently and with confidence.
Our Services
- Indonesian Companies License Holding Services
- BPOM Account Registration
- Formula and Packaging Review
- Cosmetic Product Notification
- PIF/DIP File Preparation and Compilation
- Product Testing Services
- Logistics and Customs Clearance
- HALAL Certification Services
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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