KMA 748/2021: Products That Must Be Halal-Certified

The halal certification obligation does not apply simultaneously to all products. The government sets its scope through regulation, and one of the main references is Minister of Religious Affairs Decree Number 748 of 2021 on Types of Products That Must Be Halal-Certified. This regulation was later amended by KMA 944/2024.

For businesses, the practical question is not merely "is my product required to have halal certification", but also "when does that obligation apply to my product group". This article explains the content of the regulation and its practical consequences in the field.

What Is Regulated

KMA 748/2021 sets out the product groups that must be halal-certified along with their phasing. This means the regulation not only names which types of products fall under the obligation, but also regulates the stages of its implementation.

This phasing is important to understand. Businesses whose products fall within the required groups need to know which stage applies to them. This regulation has also been amended through KMA 944/2024, so businesses should refer to the latest version when checking the scope of the obligation.

It should be noted that determining the halal status of a product is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee. Halal certificates are issued only by BPJPH. The regulation on types of products that must be certified does not in itself declare a product halal or haram.

Practical Consequences for Businesses

1. The obligation is phased, not simultaneous

Because there is phasing, businesses need to map the position of their products. Processed food and beverage products, for example, fall within the regulated groups. However, the stage of implementation needs to be checked according to the applicable provisions.

The practical consequence: do not delay preparation just because the obligation is not yet due. The certification process takes time, and system readiness cannot be built in a matter of days.

2. System readiness is a prerequisite, not a supplement

To obtain a halal certificate, businesses need to implement the Halal Product Assurance System (SJPH). The main reference is Head of BPJPH Decree Number 57 of 2021 on the Criteria for the Halal Product Assurance System, which contains five criteria: commitment and responsibility, materials, halal product process, product, and monitoring and evaluation. This regulation has been amended by Kepka 20/2023.

Consequently, businesses cannot rely solely on a verbal statement that the materials used are halal. Documents, procedures, and records are required to show that the system is running.

3. Critical points of materials must be traced, not assumed

In practice, many materials have a status that depends on their source. Some examples that often arise:

• L-Cysteine (E920): a dough softener historically extracted from human hair or poultry feathers. The alternative is certified L-Cysteine from microbial fermentation, or plant-based dough-softening enzymes.
• Whey and caseinate: milk derivatives that are themselves halal, but the cheese-making process from which they are sourced may use animal rennet. It must be ensured that the manufacturer states the use of microbial rennet or halal-certified animal rennet.
• Lecithin (E322): an emulsifier generally from soy, but partly from egg yolk or animal fat. Soy or sunflower lecithin that is clearly stated on the label is easier to trace.
• Vanilla extract: a natural vanilla flavor whose industry standard uses ethanol as an extraction solvent. The alternatives are vanilla powder, synthetic vanillin, or halal-certified vanilla extract with a water/glycerin solvent.

These materials are commonly used in mass-produced white bread, burger buns, commercial pizza dough, formula milk powder, protein drinks, bakery products, chocolate, margarine, baby food, cakes, pudding, ice cream, and premium coffee and chocolate drinks. Businesses in these sectors need to prepare supporting documents from suppliers.

4. Cost and time need to be taken into account

Head of BPJPH Decree Number 243 of 2025 on Service Standards at BPJPH sets out 27 types of services complete with requirements, timeframes, and tariffs. This regulation covers LPH accreditation, registration of LP3H and PPH Assistants, issuance of halal certificates, and facilitation codes, and revokes Kepka 120/2022.

For businesses, this means service tariffs and timeframes have a clear reference. Budget planning and certification schedules can be drawn up based on these provisions, not on estimates.

5. The choice of service pathway needs to be understood

Micro and small businesses have a halal declaration (self-declare) pathway for low-risk products. Meanwhile, larger businesses or those with higher-risk products follow the regular pathway. Understanding these pathways helps businesses choose the right step from the outset.

Steps That Can Be Prepared

1. Map your products and check whether they fall within the groups required to be halal-certified under KMA 748/2021 as amended by KMA 944/2024.
2. Inventory the materials, especially those whose status depends on the source, and collect supporting documents from suppliers.
3. Build the SJPH according to the five criteria in Kepka BPJPH 57/2021.
4. Estimate the cost and time based on the service standards in Kepka BPJPH 243/2025.
5. Determine the certification pathway that suits the scale of the business and the risk of the product.

The halal certification obligation is a matter of compliance, but also a matter of readiness. Businesses that prepare systems and documents earlier have more room to correct shortcomings before the process runs.

To manage all SJPH criteria in one place, IndoHalal.id provides an SJPH platform covering halal policy, material registry, critical points, internal audit, and BPJPH certification readiness.