Indonesia's ambition to become a major global halal player rests on the readiness of downstream industries. A halal certificate is a requirement, but not the only one. The real problems often arise long before documents are submitted: in raw materials and critical points that are invisible on the label.
Why critical material points determine export competitiveness
Products to be exported to markets with strict halal requirements must be able to prove the origin of every ingredient. This proof is not merely a statement, but documentation that can be traced. If one ingredient is unclear, the entire product line risks being held up. This is where the industry needs to map critical points from the outset, not just before applying for certification.
Regulation places the halal product assurance system as the reference on the business actor side. Decree of the Head of BPJPH (Halal Product Assurance Agency) Number 57 of 2021 on the Criteria for the Halal Product Assurance System contains five criteria: commitment and responsibility, materials, halal product processes, products, and monitoring and evaluation. The materials criterion is the foundation that determines whether a halal claim can be accounted for.
Critical points often missed in production lines
Some materials have a status that depends on their source and processing. Business actors need to trace them one by one.
- Gelatin. This thickening protein from animal collagen is halal only if its source and slaughtering are clear. Its use is widespread: marshmallows, jelly candies, medicine and supplement capsules, ice cream, yogurt, and certain bakery products. Alternatives include fish gelatin, halal-certified beef gelatin, or agar and carrageenan as plant-based substitutes.
- Gelatin capsule shells. A critical point that is often overlooked. Many supplements and medicines use these shells. Alternatives are plant-based capsules made from HPMC or halal-certified beef gelatin capsules.
- Mechanically separated meat (MSM). Meat remnants extracted from bones by machine risk being mixed from various types of animals. Economically priced processed meat products such as sausages, nuggets, and meatballs need assurance of a dedicated halal production line and certificates from certified slaughterhouses.
- Alcohol or ethanol. Its status depends on the source, level, and purpose of use. This material appears as a solvent for flavorings and colorings, vanilla extract, fermented products such as soy sauce, tapai, and tempoyak, as well as liquid medicines. Alternatives are non-alcohol plant-based solvents or ethanol with source and level documents verified by LPH (Halal Inspection Agency).
This list is incomplete without document tracing. For each material, the industry needs to know the supplier's origin, the production process, and whether there is cross-contamination in the distribution chain.
The role of regulation in simplifying, not removing obligations
Law Number 6 of 2023 amends Law 33/2014 and simplifies the certification process. A halal self-declaration scheme was introduced for micro and small businesses, and a path for the Halal Product Fatwa Committee was opened. This simplification eases administration, but does not remove the obligation to trace materials. For medium and large industries, the regular route still demands strong documentary evidence.
The obligation to be halal-certified is itself regulated in Minister of Religious Affairs Decree Number 748 of 2021 on Types of Products Required to Be Halal-Certified, which was later amended by KMA 944/2024. The phasing of this obligation signals that the domestic market also demands the same readiness as the export market.
Practical steps to prepare the supply chain
- Map all materials, including additives and processing aids, then mark which ones have syubhat (doubtful) status or depend on their source.
- Request source documents and halal certificates from each supplier. Keep them as part of the materials registry.
- Identify cross-contamination points in the production line, especially if one facility processes halal and non-halal products.
- Conduct periodic internal audits to ensure the system is still running, not just on paper.
- Prepare alternative materials for critical points so as not to depend on a single supplier.
The determination of the halal status of a product is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee. Certificates are only issued by BPJPH. Therefore, the industry should view certification as the result of a well-organized system, not the end goal. Sustainable halal exports rest on the ability to trace materials and prove it consistently.
To map critical points and prepare a materials registry in a measurable way, the SJPH (Halal Product Assurance System) platform from IndoHalal.id helps manage all SJPH criteria in one application, from halal policy to BPJPH certification readiness.