An Indonesian importer who wants to sell Japanese noodles, snacks or sauces faces three separate gates, and each one is set by a different rule. Every product needs a BPOM registration number before it is sold, every shipment needs its own BPOM import approval, and from 18 October 2026 food and drink, imported products included, must be halal certified or clearly labelled as non-halal.
This guide sets out those gates in the order an importer meets them, what each one needs from the supplier in Japan, and where the rules are still being finalised. It is written for importers, distributors and wholesalers. Sunsho Trade buys the food in Japan and exports it; the registrant and importer in Indonesia is your company.
💬 Planning Japanese food for Indonesia? Sunsho Trade buys everyday Japanese food in Japan and exports it, and tells you early which documents each manufacturer can and cannot provide. Send us your product list.
Three gates, three rules
Imported processed food needs a BPOM marketing authorisation with an “ML” number, a BPOM import approval (SKI Post Border) for each shipment, and, from 18 October 2026, halal certification or a clear non-halal statement.
Checked against the published texts on 24 October 2026.
| Gate | Rule | Held by | When |
|---|---|---|---|
| Product registration (izin edar, “BPOM RI ML” number) | Law 18/2012 on Food, Government Regulation 86/2019 on Food Safety, BPOM Regulation 23/2023 on Processed Food Registration | The Indonesian importer appointed by the producer | Before the product is sold |
| Import approval per shipment (SKI Post Border) | BPOM Regulation 27/2022, as amended by BPOM Regulation 28/2023 | The registration holder, or an importer it authorises | Each import |
| Label in Indonesian | BPOM Regulation 31/2018 on Processed Food Labels, as amended | The importer | Before sale |
| Halal | Law 33/2014 on Halal Product Assurance, Government Regulation 42/2024 | The business placing the product on the market | From 18 October 2026 |
None of these is filed from Japan. What decides whether a Japanese product can pass them is mostly paperwork from the manufacturer, and that is the part to check before you choose the range.
Gate one: BPOM registration and the ML number
Every processed food imported for sale in retail packaging must hold a BPOM marketing authorisation, registered by an Indonesian importer that the overseas producer has formally appointed.
BPOM’s 2023 registration guideline puts the basis plainly: under Law 18/2012 and Government Regulation 86/2019, every processed food produced locally or imported for trade in retail packaging must hold a marketing authorisation before it is distributed. Registration is governed by BPOM Regulation 23/2023, which replaced BPOM Regulation 27/2017. An imported product is registered with the product status “ML”, and BPOM’s labelling guidance says the registration number of an imported product starts with “BPOM RI ML”.
The importer’s account. BPOM’s registration portal lists what an importer’s company account for imported (ML) products needs: tax number (NPWP), business identification number (NIB) under the risk-based licensing system, a processed food safety management system certificate (SMKPO), a letter of appointment from the producer, and a GMP, HACCP or ISO 22000 certificate or a local government audit certificate for the factory.
The letter of appointment is the step that decides the range. According to the guideline, the letter is an agreement from the company in the country of origin to the importer that registers. It must:
- name the overseas company or factory clearly, with an address that matches its GMP or HACCP certificate;
- name the importer exactly as on its NIB and registration account;
- say whether the appointment is exclusive (sole agent);
- state the start and end of the appointment;
- be legalised by a local notary, local chamber of commerce, local government or an authority it designates, an Indonesian mission abroad, or the origin country’s mission in Indonesia;
- carry the name, title and signature of the person in charge.
If the letter is issued by an exporter or another company that is not the factory, the guideline asks for a supporting statement showing that company’s relationship with the factory.
Product documents. The guideline’s technical table marks several items as applying to imported products: a photo of the original pack showing all label text clearly; a translation of any label text that is not in Indonesian or English, made by a sworn translator into Indonesian or English; a health certificate or a certificate of free sale; and the letter of appointment. Depending on the risk category, the table also lists the production process, shelf-life information, a label design, and analysis results for contaminants and additives.
What this means for a Japanese range: a manufacturer has to be willing to issue a legalised appointment letter and share its factory certificate. Not every manufacturer will do this for an overseas buyer it does not deal with directly. When you send us a list, we ask the manufacturers whether they will provide these documents before we quote; we cannot promise that any particular maker will. A product you can buy in Japan is not automatically a product you can register in Indonesia.
💬 Want to know which products on your list come with a factory certificate and an appointment letter? Send us the list and we ask the manufacturers before quoting.
Gate two: the SKI Post Border for each shipment
Each shipment of processed food needs its own SKI Post Border, obtained within 7 calendar days of the customs release approval, and the goods must have at least two-thirds of their shelf life left when the SKI is applied for.
BPOM Regulation 28/2023 amends the 2022 regulation on the import of drugs and food. Under its Article 3, processed food entering Indonesia needs a SKI Post Border, the approval is valid for one import only, and the processed food must hold it no later than 7 days from the date of the goods release approval; the regulation defines a day as a calendar day. The application may be filed before the import declaration number is issued. The applicant is the registration holder, or an importer the registration holder has authorised, and the application must include a scan of the original SMKPO certificate for the distribution site.
The shelf-life rule is the one that shapes a Japanese order. Article 4 requires processed food, at the time of the SKI application, to have at least two-thirds of its shelf life remaining; processed food without an expiry date is exempt. Japanese snacks and some drinks have short shelf lives counted from manufacture, and time in a Japanese warehouse plus transit comes out of that two-thirds. We check best-before dates lot by lot before packing, and agree the minimum with you in advance so that the SKI test can be met. Short-dated snack ranges are discussed in Japanese snacks from a wholesale supplier.
A draft amendment to this regulation was open for public comment until 19 June 2026. We have not found a final text; check with BPOM or your broker whether it has been issued before relying on the 2023 wording.
Gate three: halal from 18 October 2026
From 18 October 2026, food and drink sold in Indonesia, imported products included, must be halal certified, while non-halal products may still be imported and sold if the label clearly states they are not halal.
The legal basis, as BPJPH (the Halal Product Assurance Organising Agency) states it, is Law 33/2014 on Halal Product Assurance and Government Regulation 42/2024. BPJPH told a WTO committee in June 2025 that the deadline for imported food, beverages and slaughtering services had been extended to 17 October 2026, and that the obligation applies from 18 October 2026. In a statement on 9 October 2026 its head said the obligation would be implemented from 18 October 2026 with no postponement.
Three points from BPJPH’s own statements matter for a Japanese range:
- A foreign halal certificate must be registered. Products certified by a foreign halal body must be registered with BPJPH through the SIHALAL system before entering the Indonesian market. BPJPH said in June 2025 that it had mutual recognition agreements with 87 foreign halal bodies in 32 countries. Check whether the body behind your product’s mark is one of them before relying on it.
- Non-halal products are not banned. BPJPH said non-halal products may still be imported and sold, provided the label carries a clear and visible non-halal statement. Japanese noodles with pork extract, or sauces containing mirin or other alcohol, fall into this group unless they are certified.
- Rules for imported products are still being written. In October 2026, BPJPH said special provisions were being prepared, in particular for micro and small businesses and for imported products. We have not seen them in final form. Confirm the current position with BPJPH or your broker before you commit to products without halal certification.
Halal certification and BPOM registration are separate processes; holding one does not satisfy the other. Instant noodles are the category where this bites hardest, as covered in Japanese instant noodles for bulk export.
Labels in Indonesian
The label must be in Indonesian and show, among other things, the importer’s name and address after “Diimpor oleh”, the BPOM RI ML number, the expiry information and halal status where required.
BPOM’s labelling guidance, citing BPOM Regulation 31/2018 and its 2021 amendment, says the label uses Indonesian; a foreign term may be used only where no Indonesian equivalent exists. Its minimum contents are the product name, the list of ingredients, net weight or volume, the name and address of the producer or importer, halal status where required, the production date and code, expiry information, the registration number, and the origin of certain ingredients. For an imported product, the importer appears as “Diimpor oleh” followed by its name and an address that includes at least the city, postal code and “Indonesia”.
We did not find, on the pages we checked, BPOM’s rule on how an added Indonesian label is applied to an imported pack, so confirm the method with BPOM or your broker. Note too that BPOM Regulation 31/2018 has a second amendment, BPOM Regulation 6/2024, which we have not reviewed in full. A Japanese pack never meets these rules unchanged, so every product needs an Indonesian label built from the manufacturer’s ingredient and allergen information.
Proof of origin from Japan
Japanese goods can claim a preferential rate in Indonesia under the Japan–Indonesia EPA, the ASEAN–Japan agreement (AJCEP) or RCEP, with the certificate issued in Japan by the Japan Chamber of Commerce and Industry.
Japan’s Ministry of Agriculture, Forestry and Fisheries lists the Japan–Indonesia EPA, AJCEP and RCEP among the agreements using third-party certification by the Japan Chamber of Commerce and Industry. RCEP also accepts certificates made by exporters approved by Japan’s Minister of Economy, Trade and Industry; RCEP self-declaration is listed only for exports to Australia, New Zealand and Korea. Your broker should choose the agreement per HS code before we apply. The export side is covered in export from Japan: documents and flow.
What we supply from Japan, and what stays with you
We source, check and export the goods and gather the manufacturer documents your filings depend on; the BPOM registration, the SKI, the halal registration and the Indonesian label stay with the importer.
| Task | Sunsho Trade (Japan) | Importer (Indonesia) |
|---|---|---|
| Asking each manufacturer for an appointment letter and factory certificate | Yes, before quoting | Decides whether to proceed with each product |
| Pack photos, ingredient and allergen information | Supplies | Uses it for registration and the label |
| Sworn translation of Japanese label text | Supplies the source text | Arranges the translation |
| BPOM registration and ML number | No | Yes |
| Best-before dates checked against the two-thirds rule | Yes, lot by lot | Applies for the SKI |
| Health certificate or free sale certificate | Checks availability before ordering | Confirms which is needed |
| Halal status | Reports which products carry a mark and from which body | Registers foreign certificates or applies non-halal labelling |
| Export customs, shipping documents, EPA certificate of origin | Yes | Chooses the agreement with its broker |
Because registration is per product, a mixed shipment works best once each line already has its ML number. A first order is often smaller and built around the products whose documents came through. For a market where approval happens at the border instead, see importing Japanese food into Malaysia.
💬 Ready to plan Japanese food for Indonesia? Send the products, quantities and the shelf life you need on arrival, and we start with the document check. Request a quotation.
Frequently asked questions
1. Can Sunsho Trade register our products with BPOM?
No. BPOM registration for imported food is filed by an Indonesian importer that the producer has appointed. We help by asking manufacturers for the appointment letter, the factory certificate and product information, and by supplying pack photos and dates.
2. Can we import Japanese food that is not halal certified?
BPJPH has said non-halal products may still be imported and sold if the label carries a clear non-halal statement. Special provisions for imported products were still being prepared in October 2026, so confirm the current rule with BPJPH or your broker first.
3. How much shelf life must the goods have?
BPOM Regulation 28/2023 requires at least two-thirds of the shelf life to remain when the SKI Post Border is applied for, unless the food has no expiry date. A draft amendment was consulted on in 2026, so check the current text.
4. Is the Japanese label enough for registration?
No. BPOM asks for a photo of the original pack and a sworn translation of any text not in Indonesian or English. The label sold in Indonesia must be in Indonesian and show “Diimpor oleh” with the importer’s details and the BPOM RI ML number.
5. Which certificate of origin should we ask for?
An EPA certificate under the Japan–Indonesia EPA, AJCEP or RCEP, whichever your broker chooses for each HS code. The Japan Chamber of Commerce and Industry issues it in Japan.
Checked on 24 October 2026. Sources: BPOM (rumahsiripo.pom.go.id): Pedoman Registrasi Pangan Olahan 2023, registration requirements for imported-product accounts, processed food label rules; BPOM Regulation 28/2023 amending BPOM Regulation 27/2022, and the 2026 draft amendment, standar-otskk.pom.go.id; BPJPH statements of June 2025 (WTO TBT Committee), June 2026 and 9 October 2026, bpjph.halal.go.id; Ministry of Agriculture, Forestry and Fisheries of Japan, EPA certificate of origin systems, maff.go.jp; Japan Chamber of Commerce and Industry, tokuteishomei.jp.