On February 2, 2021, Indonesia's government passed a new halal implementing regulation, Government Regulation 39 of 2021, which revokes Government Regulation 31 of 2019, an earlier implementing regulation. Government Regulation 39 of 2021 was published in the Official Gazette on February 21 and entered into force on the date of its enactment, though some of the provisions will not take effect until the law is fully implemented for foods on October 17, 2024. It should also be noted that additional implementing regulations are pending, so there may still be modifications to the requirements.

USDEC is sharing this draft with members because some of the provisions could be disruptive for many companies if they are implemented as drafted, particularly for companies that do not have 100% of production halal-certified now. Other provisions may still impact exporters that already have full halal certification.

USDEC is seeking member input so that we may better understand the potential impact and can advocate for modifications through subsequent guidance or updated regulations.

Action Requested

Member Feedback: The Indonesian government notified to the WTO for public comment on February 12 through G/TBT/N/IDN/131. This consultation period provides USDEC with an opportunity to share our concerns with the draft regulation to the U.S. government (USG) for their advocacy efforts. Click here for a summary of key points of the regulation and the questions on which USDEC is seeking feedback from members.

USDEC requests member comments on the summary provided below by Monday, March 29, in order to meet the USG deadline. Send feedback to Sandra Benson at sbenson@usdec.org.

Please note that the translation of Government Regulation 39 of 2021 is actually the translation of the draft regulation so the regulation number is not included. However, USDEC was informed that the regulation was finalized as drafted.

If your importer would also like to also provide feedback, point 2 in the WTO notification provides the parties to which comments may be submitted.

Please contact Sandra Benson at sbenson@usdec.org or Jonathan Gardner at jgardner@usdec.org with questions.