Halal Industry and Exports: Commonly Overlooked Critical Ingredient Points

Halal certification is not merely a formality for industries targeting export markets. Destination countries with large Muslim populations demand traceable evidence, not just claims. On the other hand, businesses face long and complex supply chains. Some ingredients that appear safe actually harbor critical points that are often missed.

The Decisive Regulatory Framework

In Indonesia, the halal certification obligation is regulated through Minister of Religious Affairs Decree Number 748 of 2021 on Types of Products Requiring Halal Certification, which was later amended by KMA 944/2024. This regulation sets out product groups along with their phasing. For industry, understanding this scope and phasing is the basis for certification planning, including for product lines intended for export markets.

At the operational level, the main reference for implementing the Halal Product Assurance System (SJPH) is BPJPH (Halal Product Assurance Agency) Head Decree Number 57 of 2021 on Criteria for the Halal Product Assurance System, which has been amended by Kepka 20/2023. The five criteria within it cover commitment and responsibility, ingredients, halal product processes, products, and monitoring and evaluation. The ingredient criteria form the foundation that determines the extent to which the system can be held accountable.

Commonly Overlooked Critical Ingredient Points

Some ingredients have a status that depends on their source. This means their halal status cannot be determined from the ingredient name alone; it must be traced to its origin and processing method.

• Vanilla extract. The industry standard for this natural vanilla flavoring uses ethanol as an extraction solvent. Its status depends on the source of the solvent. Alternatives include vanilla powder, synthetic vanillin, or water/glycerin-solvent vanilla extract that is halal-certified. This ingredient is commonly found in cakes, puddings, ice cream, and premium coffee or chocolate drinks.
• Gelatin capsule shells. Capsule shells for medicines and supplements made from gelatin are the critical point most often overlooked by consumers, and frequently by businesses as well. Alternatives include vegetable capsules (HPMC — hydroxypropyl methylcellulose) or halal-certified beef gelatin capsules. Their use is widespread in prescription and over-the-counter medicines, vitamin supplements, and fish oil in softgel form.
• Collagen. This structural protein from animal skin or bone has a source that determines its halal status, just like gelatin. Alternatives include fish collagen (marine collagen) or halal-certified beef collagen. This ingredient is common in beauty supplements, collagen drinks, and skincare products.
• Albumin (egg white). This protein from egg white is generally halal, but still needs verification that it is free from non-halal admixture. It generally does not require a substitute; ensure the label explicitly states "egg albumin/albumen." This ingredient is used in bakery products such as meringue and macaron, processed meat products, and certain pharmaceutical products.

Implications for Documents and Supply Chains

For industry, critical ingredient points are not a single issue. Every ingredient with "source-dependent" status requires supporting documents explaining its origin and process. In the export context, these documents form part of the evidence that the halal product assurance system runs consistently, not only during audits but throughout the production cycle.

The monitoring and evaluation criteria in Kepka 57/2021 affirm that the system must be maintained. Changes in suppliers, formulation changes, or ingredient substitutions need to be recorded and their impact on the product's halal status assessed. Without proper record-keeping, critical points that were initially controlled can turn into gaps.

The Role of the Halal Inspection Agency

Field inspections are carried out by accredited Halal Inspection Agencies (LPH). The LPH accreditation guidelines are set out in BPJPH Head Decree Number 78 of 2025, which refers to SNI ISO/IEC 17065:2012. This standard governs impartiality, confidentiality, personnel competence, complaint and appeal management, and accountability. For industry, understanding this framework helps prepare relevant evidence and reduces the risk of findings during assessment.

It should be emphasized that the determination of halal status is the authority of the MUI (Indonesian Ulema Council) Fatwa Commission or the Halal Product Fatwa Committee, while certificates are only issued by BPJPH. This article does not determine the halal status of any product; rather, it maps ingredients that require further tracing.

Practical Steps for Industry Players

1. Map all ingredients, including additives and flavorings, then flag those with "source-dependent" status.
2. Collect supplier documents explaining ingredient origin and processing methods.
3. Record every supplier or formulation change, and assess its impact on the SJPH.
4. Ensure personnel running the SJPH have appropriate competence.
5. Conduct regular internal audits before external assessment.

Consistency at critical ingredient points is part of export readiness. Products with well-organized documents are easier to account for in any market.

To map critical points and prepare ingredient documents systematically, IndoHalal.id provides an SJPH platform that helps manage your business's SJPH criteria in a single application, from halal policy to BPJPH certification readiness.