UMK and Halal Certification: Ingredient Issues and Critical Points

The halal certification obligation applies to products included in the group required to be halal-certified according to KMA 748/2021 and its amendments. For micro and small enterprise (UMK) actors, this obligation is often perceived as a matter of paperwork. In practice, the typical UMK problem more often arises with ingredients and their critical points.

Why ingredients are the first issue

UMK generally buy ingredients from distributors without direct access to producers. When they have to explain the origin of ingredients, the information stops at the purchase invoice. In fact, the criteria of the halal product assurance system (SJPH) as regulated in Kepka BPJPH 57/2021 contain five criteria, one of which is ingredients. This criterion requires business actors to know and document the status of the ingredients used.

Some ingredients are classified as critical points because their status depends on their source or production process. Examples include:

• Cochineal (E120), a red colorant from the cochineal insect, whose status is viewed differently by scholars.
• Shellac (E904), a glossy coating from lac insect resin, whose process needs to be checked.
• Whey and caseinate, milk derivatives whose cheese-making process may use animal rennet.
• Microbial enzymes (amylase, protease, lipase) which may come from microbial, plant, or animal sources.

These ingredients are commonly used in colored beverages, candy, bakery products, formula powdered milk, and glucose syrup. UMK that use them need to trace source documents, not merely rely on common assumptions.

Limited documents from suppliers

The next issue is access to documents. To meet the ingredient criteria, UMK need information from suppliers regarding the source of ingredients. In practice, small suppliers may not necessarily provide such documents. If the ingredients come from large producers, information is usually available, but the communication line is long.

Therefore, a realistic first step for UMK is to map the ingredients used, separate those classified as critical points, and then request written information from suppliers for those ingredients. For ingredients with halal alternatives, such as plant-based colorants replacing cochineal or halal-certified microbial enzymes, considering switching suppliers can be an option.

Other criteria that require evidence

In addition to ingredients, Kepka 57/2021 contains criteria for commitment and responsibility, halal product process, product, and monitoring and evaluation. For UMK, the halal product process criteria often require separation of equipment or areas from ingredients whose status is unclear. This is not merely administrative work, but concerns daily production habits.

Law 6/2023 simplifies the certification process and introduces a halal statement scheme (self-declare) for UMK. This scheme lightens the pathway, but does not remove the obligation to know the status of ingredients. A halal statement must still be based on knowledge that can be accounted for.

The role of assistants and supervisors

Due to limited documents and personnel, assistance is important. Halal product process assistants help UMK trace ingredients and prepare evidence. On the other hand, halal supervisors run SJPH continuously, including monitoring and evaluation.

It should be noted that the determination of halalness is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee, and certificates are only issued by BPJPH. UMK do not determine the halal status of their own products; what they do is prepare evidence and systems so that the assessment process runs smoothly.

Practical steps that can be started

1. Make a list of all ingredients used, including additives.
2. Mark ingredients classified as critical points based on their source.
3. Request written information from suppliers for those marked ingredients.
4. Document the process flow and separation of equipment or areas.
5. Keep records as evidence for monitoring and evaluation.

That way, ingredient and critical point issues are no longer the main obstacle when UMK apply for halal certification. The remaining burden is more about diligence in tracing and maintaining documents.

To help map ingredients and critical points in a structured way, IndoHalal.id provides an SJPH platform that includes an ingredient registry, critical point marking, and BPJPH certification readiness.