MSMEs and Halal Certification: The Supplier Document Problem

In handling halal certification, MSMEs often reach the same point: ingredients have been recorded, critical points have been identified, but the process stops when they have to attach evidence from suppliers. This issue rarely comes up in public discussions, even though in practice it is what most often slows down completion.

Why supplier documents become an obstacle

The criteria for the halal product assurance system on the business actor side are set out in the Decree of the Head of BPJPH (Halal Product Assurance Agency) Number 57 of 2021 on the Criteria for the Halal Product Assurance System. This decree contains five criteria: commitment and responsibility, ingredients, halal product process, product, and monitoring and evaluation. The decree has been amended by Kepka 20/2023.

The ingredient criteria require business actors to know the origin and status of the ingredients used. For large industries, that information is usually already available in the form of ingredient certificates from suppliers. For MSMEs, the same information is often not documented. Purchases are made from intermediary traders, packaging does not list the original manufacturer, and there is no certificate that can be archived.

As a result, MSMEs can name the ingredient correctly but cannot show the basis for their assessment. This is what distinguishes the supplier document problem from the ingredient critical point problem. With critical points, the question is which ingredients need to be checked. With supplier documents, the question is who can prove the status of that ingredient.

Ingredients that most often cause difficulty

Some ingredients have a status that depends on their source. This means their status cannot be determined from the ingredient name alone. The following ingredients are among those often encountered by food and supplement MSMEs:

Lecithin (E322). An emulsifier generally derived from soy, but some comes from egg yolk or animal fat. The alternative is soy lecithin or sunflower lecithin that is clearly stated on the label.
Mono- and diglycerides of fatty acids (E471). The most common emulsifier in the food industry, it can come from palm oil or animal fat. The alternative is halal-certified E471 with a plant-based fatty acid source stated in the ingredient certificate from the supplier.
Taurine. An amino acid in energy drinks; it is now generally synthetic, but historically came from cattle bile. The alternative is synthetic taurine that has been halal certified.
L-Arginine and other amino acids. They can be the result of microbial fermentation or extraction from animal sources. The alternative is amino acids from microbial fermentation that are halal certified with traceability documents from the supplier.

All the ingredients above have one thing in common: the ingredient name is not enough. What determines it is the source and the documents that accompany it.

Recurring problem patterns

Several patterns often appear among MSMEs. First, suppliers do not issue ingredient certificates because the purchase scale is small. Second, an ingredient certificate exists but has expired or does not list the trade name used. Third, the document is only a purchase receipt without manufacturer information. Fourth, ingredients change suppliers without being re-recorded.

These patterns are not a matter of indifference. MSMEs usually buy ingredients according to daily production needs, so recording suppliers is seen as an extra burden. Yet without that record, the ingredient criteria are difficult to meet consistently.

Steps that can be started now

The supplier document problem does not have to be solved all at once. There is a more sensible sequence for MSMEs:

List all ingredients used, including additives and processing aids.
Mark ingredients whose status depends on the source, such as lecithin, E471, taurine, and amino acids.
For each marked ingredient, find out the original manufacturer, not just the trader where it was bought.
Request an ingredient certificate or a certificate of explanation from the manufacturer or authorized distributor.
Keep the documents along with their validity dates, then update them when ingredients change suppliers.

These steps look simple, but they require orderly administrative habits. For MSMEs, the benefit is not only for certification. The same documents are useful when there are questions from buyers, when taking part in procurement programs, or when planning to add product lines.

The role of assistants and the limits of authority

Halal product process assistants are tasked with helping business actors prepare documents and understand the criteria. However, assistants do not determine the halal status of ingredients. 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, the task of MSMEs is to provide complete and traceable evidence. The more orderly the supplier documents, the smaller the chance that the process stops midway because of unanswered questions.

To help with regular recording of ingredients and critical points, IndoHalal.id provides an SJPH (Halal Product Assurance System) platform that accommodates an ingredient registry, critical point marking, and certification readiness in one place.