Dissecting Critical Points of Ingredients and How to Trace Them

In halal certification, critical points of ingredients are often simplified into a list of haram ingredients. In reality, the critical point lies in the origin and process. An ingredient that appears safe can become critical if its source is unclear. Conversely, an ingredient said to be derived from animals can be traced down to supplier documents.

Where critical points arise

The Decree of the Head of BPJPH (Halal Product Assurance Agency) Number 57 of 2021 on the Criteria for the Halal Product Assurance System (SJPH) places ingredients as one of the five SJPH criteria. This means business actors must be able to explain the origin of ingredients, not merely declare that the ingredient is halal. This document was amended by Kepka BPJPH 20/2023.

Critical points usually arise in ingredients that undergo fermentation, extraction, or coagulation processes. These processes use media or enzymes that may come from animals, plants, or microbes. At that point, the halal status of the ingredient is determined.

Four examples of ingredients and their critical points

1. Microbial enzymes

Amylase, protease, and lipase can be sourced from microbes, plants, or animals. Therefore, their status depends on the source. These enzymes are used in glucose and fructose syrup, meat tenderizers, juice and cheese production, and even dishwashing detergent whose contact with food is indirect. The alternative is microbial enzymes from halal-certified fermentation, accompanied by source documents from the supplier.

2. Whey and caseinate

These milk derivatives are halal in themselves. However, the cheese-making process from which they are sourced may use animal rennet. Whey and caseinate are widely used in formula powdered milk, protein drinks, bakery products, and processed cheese. Choose manufacturers that state the use of microbial rennet or halal-certified animal rennet.

3. Yeast

Yeast is generally halal because it is a fermentation microorganism. What needs to be checked is the growth medium. Yeast with a halal-certified plant-based growth medium is now the modern industry standard. Yeast is used in bread, non-alcoholic beer, fermented products, and packaged instant yeast.

4. Rennet

Rennet is a milk-coagulating enzyme. Animal rennet comes from the stomach of calves that must be slaughtered according to sharia. The alternative is microbial rennet from fungi or mold, or fermentation-produced chymosin (FPC) that is halal-certified. This ingredient is used in hard and semi-hard cheeses such as cheddar, mozzarella, parmesan, and gouda.

How to trace critical points

Tracing is not a one-time task. It runs together with the halal product assurance system. There are several steps that can be carried out.

1. Map the ingredients. Record all ingredients, including additives and processing aids. Group them by category: animal, microbial, plant, or synthetic.
2. Request source documents. For ingredients whose status depends on the source, request written information from the supplier about the origin of the ingredient and its manufacturing process.
3. Check the ingredient's halal certificate. If the ingredient is already halal-certified, match the product name, manufacturer, and validity period. Do not just keep a copy without checking its conformity.
4. Trace up to the original manufacturer. For risky ingredients, documents from the distributor alone are not enough. Trace up to the manufacturer that produces the ingredient.
5. Record in the ingredient registry. Keep the tracing results in an updated registry. This registry becomes evidence during internal audits and external inspections.
6. Review periodically. Suppliers may change, formulations may change. Tracing needs to be repeated according to a set cycle.

Keep in mind, the determination of halal status is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee. Halal certificates are only issued by BPJPH. Therefore, well-organized documents and tracing serve as examination materials, not as the determinant of halal status.

The role of other regulations

Law Number 33 of 2014 on Halal Product Assurance is the parent of the halal certification obligation, the establishment of BPJPH, the role of the Halal Inspection Agency (LPH), and MUI's authority in determining product halalness. Government Regulation Number 42 of 2024 on the Implementation of Halal Product Assurance regulates the procedures for establishment, accreditation, scope of activities, and revocation of LPH approval, as well as the appointment and dismissal of Halal Auditors. KMA Number 748 of 2021 on Types of Products Required to Have Halal Certification, as amended by KMA 944/2024, sets out the product groups required to have halal certification along with their phasing.

With that framework, critical points of ingredients are not merely a list of suspected ingredients. They are part of a system that must be proven through documents. The more organized the tracing, the more prepared business actors are to face inspections.

To manage the ingredient registry, critical points, and certification readiness in one place, IndoHalal.id provides an SJPH platform that helps business actors organize all SJPH criteria in a measurable way.