Indonesia's New Food Packaging Rules: BPOM Regulation 11/2026 and the June 2027 Deadline

BPOM Regulation 11/2026 reset Indonesia's food packaging rules with substance lists and migration limits. Packaging in circulation has until 30 June 2027.

If you are quoting food-grade woven packaging into Indonesia, the rules changed recently enough that a compliance file assembled a year ago may no longer describe what is required. Indonesia's food and drug authority, BPOM, promulgated Regulation No. 11 of 2026 on food packaging on 30 June 2026. It updates migration controls, test conditions, permitted-substance lists and requirements for reusable plastics, and it establishes a positive list of permitted food-contact substances with specific and overall migration limits alongside a negative list of prohibited substances. Food packaging already circulating in Indonesia generally has until 30 June 2027 to comply, which is a real deadline rather than a distant one.

Positive list, negative list, and what that structure demands of you

A positive-list regime is a different kind of obligation from a general safety requirement, and the difference matters for a woven bag. Under a general requirement you show that the finished article does not transfer harmful substances into food. Under a positive list you additionally have to show that the substances used are on the permitted list, within their stated limits. That pushes the burden of proof upstream, into the composition of the material rather than only into the behaviour of the finished bag, and it means an importer's questions will be about resin grades, additives, pigments and coating chemistry rather than only about a migration result.

For a laminated or lined woven bag, the substances that matter most are the ones in the layer that touches the food, plus anything that could migrate through it. That includes the coating or liner polymer, any slip or antiblock additives, and the pigments in a printed layer where print is on the contact side rather than the outer face. Print position is therefore a compliance variable and not only an appearance choice: a design printed on the outside of the fabric under a clear laminate sits in a very different position from ink on an inner surface. If a buyer asks where the ink is, that is a well-informed question rather than a pedantic one.

On the testing side, migration assessment relevant to Indonesian requirements is carried out in accordance with standards including SNI 8216.1:2015. The practical point is that a test report has to have been run under the conditions the regulation recognises, against the construction actually being supplied. A report produced for a different market's protocol may not be accepted, and a report produced for a different construction is not evidence about yours at all. Both are common reasons a file gets returned.

What a positive-list regime asks for, layer by layer
LayerWhat has to be characterisedWhy it matters
Contact liner or coatingPolymer grade, additives, thickness or coat weightThis is the surface the food actually touches
Adhesive or tie layerComposition, where one is presentA substance can migrate through a thin contact layer
Printed layerInk system, pigments, and which side it is onPrint position changes the exposure entirely
Outer woven fabricResin grade and additivesNot in food contact, but part of the article
Whole constructionOverall and specific migration under recognised conditionsThe finished-article evidence the file rests on
Production batchMeasured GSM, dimensions, strengthTies the evidence to what was actually shipped

The transition deadline is a commercial event, not just a legal one

A compliance transition with a fixed end date changes buying behaviour in a predictable way. Packaging already in circulation has until 30 June 2027, which means Indonesian food producers are in the middle of reviewing their packaging specifications now, and will be through to that date. For a supplier, that is the most useful window there will be for several years: a customer who has to revisit a specification anyway is far more open to changing supplier than one who is running a settled line. The way to be useful in that conversation is to arrive with composition documentation ready, not to arrive with a price list.

It also means asking a different first question. Rather than asking what bag they buy, ask what their current packaging file contains and where the gaps are against the new lists. Frequently the gap is not the polymer, which for a woven bag is generally straightforward, but the additive or pigment detail that their existing supplier has never been asked to disclose. A manufacturer who can produce that detail without a fight has a genuine advantage during a transition, and it costs nothing but organisation.

Indonesian end use, and the specification it implies

Rice, sugar, flour, animal feed and fertilizer dominate Indonesian woven packaging demand, and the climate is consistently humid, which pushes most of those applications firmly towards a moisture barrier. Hygroscopic products cake, feed degrades, and fertilizer sets solid, and all three failures get attributed to the bag. Against that, anything that carries field heat or continues to respire needs the opposite construction, one that lets heat and moisture out rather than sealing it in. As always the constructions are opposites rather than a spectrum, so the commodity has to be named.

Deadline
Packaging already in circulation generally has until 30 June 2027 to comply
Regime type
Positive list plus negative list, with specific and overall migration limits
Disclose
Resin grades, additives, pigments, coating and liner chemistry
Print position
Which side the ink is on is a compliance variable, not only cosmetic
Testing
Run under recognised conditions, including standards such as SNI 8216.1:2015
Do not reuse
A report for another construction or another market's protocol is not evidence

Feed deserves a separate note, because it sits at the awkward edge of the regime. An animal feed sack raises the same composition questions as a human-food bag, and Indonesian humidity makes the moisture barrier a performance requirement on top of them. Where the feed is pelleted and stored for weeks the barrier is the priority; where it arrives warm or contains material that is still respiring, airflow is. Settle that before commissioning any testing, since the evidence is written against a construction and a change of construction means starting again.

Frequently asked questions

What changed with BPOM Regulation 11 of 2026?

Promulgated on 30 June 2026, it updates Indonesia's food packaging framework: migration controls, test conditions, permitted-substance lists and requirements for reusable plastics. It sets out a positive list of permitted food-contact substances with specific and overall migration limits, and a negative list of prohibited substances. Packaging already circulating in Indonesia generally has until 30 June 2027 to come into compliance.

Why does a positive list make more work than a general safety rule?

Because it moves the burden of proof upstream. A general rule asks whether the finished article transfers harmful substances into food; a positive list also asks whether every substance used is permitted and within its limits. For a woven bag that means characterising the contact liner or coating, any adhesive, the additive package and the ink system, rather than relying on a single migration result for the finished bag.

Does it matter which side of the fabric is printed?

Yes, and it is one of the more commonly overlooked points. Ink on an outer face under a clear laminate is in a completely different exposure position from ink on a surface nearer the product. Because a positive-list regime looks at the substances present and their potential to migrate, print position becomes part of the compliance description of the construction and should be stated explicitly in the specification.

Can we use our existing European or US test reports?

Only as background. Migration assessment for Indonesian purposes needs to have been carried out under the conditions the regulation recognises, including standards such as SNI 8216.1:2015, and against the construction actually being supplied. A report run to another market's protocol, or for a similar but different construction, is the most common reason a compliance file is sent back for more work.

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