Indonesia Issues New Legislation for Food Contact Materials

SafeGuardSHardgoods14 Jul 2026

SG 098/26

Indonesia publishes new legislation to set compliance requirements for several types of food contact materials (FCMs) and articles.

In June 2026, Indonesia’s Food and Drug Authority (Badan Pengawas Obat dan Makanan, BPOM) issued Regulation No. 11 of 2026 concerning food packaging (the Regulation). This new law establishes comprehensive requirements for food packaging materials (FPMs) and food contact substances (FCSs), including migration limits, testing methodologies, positive and negative substance lists, requirements for recycled materials and procedures for the safety of new substances and materials.

What does this regulation require?

Key provisions in the new law are summarized in Table 1.

Section to the Regulation	Highlight
Chapter I ‘General provisions’	Introduces several terms and their definitions, including a) food packaging, b) FPMs, c) FCSs and d) migration
Chapter II ‘FPMs’	Defines the scope of FCMs: Ceramics Glass Metals and alloys Multilayer materials Paper and paperboard Plastics Rubber and elastomers Specifies that the FPMs above must meet overall migration (OM) and/or specific migration (SM) requirements
Chapter III ‘FCS’	Authorizes the use of FCS listed in Annex III of the Regulation, provided they meet those specifications
Chapter IV ‘Reusable food packaging’	Stipulates that these materials must comply with applicable migration requirements Requires plastics to meet the OM and SM requirements specified in Annex V of the Regulation, including the application of stability factors
Chapter V ‘Food packaging from recycled materials’	Permits the use of recycled materials that comply with production methods in accordance with statutory regulations Specifies that the provisions for FPMs and FCSs in articles set out in Articles 3 to 8 apply mutatis mutandis to recycled materials
Chapter VI ‘Assessment’	Allows the use of FPMs and/or FCSs not listed in Articles 4 and 6, provided they have been approved by the Head of the Agency following a safety assessment (see Annex VI for the sample assessment request form)
Chapter VII ‘Administrative sanctions’	Specifies that administrative penalties will be imposed on individuals and businesses for violations in accordance with applicable laws
Chapter VIII ‘Transitional measures’	Stipulates that food packaging in circulation must comply with the new law no later than 12 months from the day the new law was promulgated (see below)
Chapter IX ‘Closing provisions’	Repeals Regulation No. 20 of 2019 on Food Packaging on June 30, 2026 (the day of promulgation) The new law entered into force on June 30, 2026 (the day it was enacted)
Annex I ‘Migration limit requirements’	Establishes a list of general requirements for plastics (see Table 2) Specifies the requirements for SM of 58 different types of plastic Details general requirements for rubber and elastomeric materials Describes SM requirements for 23 types of rubber and elastomer materials Stipulates that rubber and elastomer materials used in infant and children’s products must meet requirements for N-nitrosamines and N-nitrosatable substances Sets forth OM and heavy metal content limits for uncoated paper and cardboard by using the methods described in Annex II C Sets out migration of lead and cadmium requirements for three categories of ceramic and five categories of glass articles Details general requirements for extractable lead and cadmium in metals and alloys Specifies SM requirements for specific types of metals and alloys, including those with a coating material Defines requirements for multilayer materials
Annex II ‘Migration testing’	Describes methods for migration testing, including the use of food simulants, time and temperatures Details methods for testing N-nitrosamines and N-nitrosatable substances, as well as SM for glass and ceramics
Annex III ‘FCSs permitted for use in food packaging’	Details a positive list of 117 substances with migration limits, including 2,2-bis (4-hydroxyphenyl) propane bis (2,3-epoxypropyl) ether (BADGE), bisphenol A (BPA), bisphenol S (BPS) and several phthalates (Table A) Specifies a list of 1308 substances without migration limits (Table B)
Annex IV ‘FCSs prohibited for use in food packaging’	Bans 142 substances
Annex V ‘Migration testing of reusable food contact plastics’	Details the criteria for testing OM and SM requirements based on stability requirements
Annex VI ‘Food packaging safety assessment application form’	Provides an example of an application form for the safety of food packaging

Table 1

Entry	Test item	Requirement
1	Overall migration	≤ 60 mg/kg or ≤ 10 mg/dm²
2	SM of arsenic, total chromium and mercury	Not detected (ND) for each substance (Limit of detection (LOD) = 0.01 mg/kg)
3	SM of cadmium	ND (LOD = 0.002 mg/kg)
4	SM of lead	≤ 0.05 mg/kg

Table 2. General requirements for plastic materials

Who is impacted?

The Regulation affects stakeholders across the FCMs and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in the Indonesian market.

When does it apply?

The new law entered into force in June 2026 and will apply from June 30, 2027.

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