Indonesia Issues Revised Draft Regulation for Food Contact Materials

SafeGuardSHardgoodsOctober 28, 2025

SG 161/25

Indonesia completes public consultation on the nation’s revised draft legislation for food contact materials (FCMs) and articles.

In October 2025, Indonesia’s Food and Drug Authority (Badan Pengawas Obat dan Makanan (BPOM)) completed a 10-day consultation period on the nation’s revised draft regulation for FCMs and articles.

Key highlights of the revised draft law are summarized in Table 1:

Section to Draft Regulation	Highlight
Chapter II ‘Food packaging materials’	Defines scope of food packaging materials (FPMs): Ceramics Glass Metals and alloys Multilayer materials Paper and cardboard Plastics Rubber and elastomers The FPMs above must meet overall migration (OM) and/or specific migration (SM) requirements as detailed in Appendix I
Chapter III ‘Food contact substances’	Permits food contact substances (FCS) in Appendix III, with or without migration limit requirements, to be used in FPMs Prohibits 142 substances from being used as FCSs (Appendix IV)
Chapter IV ‘Reusable food packaging’	In addition to meeting migration limits, reusable plastic FPMs must respect the criteria for migration testing of these repeat use materials and articles in Appendix V
Chapter V ‘Food packaging from recycled materials’	Permits the use of recycled materials that comply with production methods in accordance with statutory regulations The provisions for FPMs and FCSs in articles 3 to 8 apply mutatis mutandis to recycled materials
Chapter VI ‘Assessment’	FPM and/or FCS other than those listed in Appendices I and IV may only be permitted to be used upon approval from the Head of the Agency based on safety assessment (see Appendix VI for ‘Example of Request Form for Assessment’
Chapter VII ‘Transitional provisions’	Food packaging in circulation must comply with the new law within five years from the day the legislation is enacted
Chapter VIII ‘Closing provisions’	Repeals Regulation No. 20 of 2019 on Food Packaging on the day the new law is enacted The new law enters into force on the date of promulgation
Appendix I ‘Migration limit requirements for FPMs’	Establishes a set of general requirements for plastics: ≤ 60 mg/kg or ≤ 10 mg/dm² for OM Not detected (ND) for SM of each of arsenic, total chromium and mercury (Limit of Detection (LOD) = 0.01 mg/kg)) ND for SM of cadmium (LOD = 0.002 mg/kg) ≤ 0.05 mg/kg for SM of lead Specifies 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 ≤ 0.01 mg/kg N-nitrosamines and ≤ 0.1 mg/kg N-nitrosatable substances for rubber and/or elastomers intended to infants/children Sets out OM and heavy metal content limits for uncoated paper and cardboard against SNI 8218:2015 ‘Paper and cardboard for food packaging’, or its latest version Sets forth 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 metal and alloy Defines requirements for multilayer materials
Appendix 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
Appendix III ‘Food contact substance permitted for use of food packaging’	Details a positive list of 115 substances with migration limits, including bisphenol A (BPA), bisphenol S (BPS) and several phthalates (Table A) Specifies a list of more than 1,300 substances without migration limits (Table B) Removes 44 substances identified as per- and polyfluoroalkyl substances (PFAS)
Appendix IV ‘Food contact substances prohibited from use as food packaging’	Bans more than 140 substances
Appendix V ‘Migration testing of plastic food contact packaging materials for reuse’	Details the criteria for testing OM and SM requirement based on stability requirements
Appendix VI ‘Example of request form for assessment’	Provides an example of an application form for the safety of food packaging’

Table 1

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