Regulatory update (October 22, 2026): Indonesia has promulgated Government Regulation 40/2026 (signed and in force on October 14, 2026; State Gazette No. 156 of 2026) amending PP 42/2024. A group of Halal obligations that were due to take effect on October 18, 2026 (food and beverages of micro and small enterprises and from imports; traditional medicines and health supplements; cosmetics, chemical products and genetically engineered products; consumer goods, namely apparel, headwear and accessories, household health products, household equipment and appliances, worship supplies, stationery and office equipment; and Class A medical devices) will now take effect on October 18, 2028, and the regulation on pre-shipment verification of imported products has been revoked. We will check the official PDF article by article once it is posted in the national legal database. Please read the October 2026 dates in this article together with Indonesia Announces Extension of Phased Halal Certification Deadlines to 2028: What Is Delayed and What Stays the Same.
1. What the regulation says
This is a revision of the May 2026 version. The earlier wording — that fashion apparel, leather goods, footwear, bags and accessories, handicrafts and other mass consumer goods are "all mandatory" and "no certification, no market" — was too broad; this version prevails. Indonesia's mandatory Halal certification extends to consumer goods (barang gunaan) from October 18, 2026, and Article 161 of Government Regulation (PP) No. 42 of 2024 names apparel, headwear and accessories (phased deadline October 17, 2026). But the scope is not "all apparel and leather consumer goods": Article 158 of the same regulation limits the Halal obligation for consumer goods to goods derived from or containing animal-derived components. Leather, fur, wool, silk and down products, and products that use animal-derived auxiliaries or trims, are in scope and must be certified or carry non-Halal labeling to circulate in Indonesia. Ordinary cotton or polyester garments whose auxiliaries and trims contain nothing animal-derived are not listed in the regulation text; however, there is currently no official document further clarifying whether finished garments without animal-derived components need certification, so buyer requirements and the audit body's position govern.
| Provision | Content |
|---|---|
| PP 42/2024, Article 161(1)(e) | Apparel, headwear and accessories; phased period October 17, 2021 to October 17, 2026, enforced from October 18 |
| Same paragraph, item (f) | Household hygiene products, household goods, worship supplies, stationery and office supplies; same period |
| Article 158(1) | The Halal obligation for consumer goods is limited to goods derived from and/or containing animal-derived components |
| Article 158(2) | The specific types of goods that require certification are set by ministerial decision; BPJPH's draft guideline (notified to the WTO as G/TBT/N/IDN/195, comments until November 6, 2026) names leather, fur, hair, horn and bone, and synthetic-material products that use animal-derived substances as additives or processing aids |
So the test has two steps: is the product in a category named in Article 161, and does it contain animal-derived components? Only when both are true is there an obligation. Handicrafts and furniture are not listed in Article 161; whether bags, belts and watches count as "accessories" depends on the list of types published by ministerial decision — but either way, the animal-component test applies.
2. Why apparel and leather involve Halal at all
A Halal review covers a product's raw materials, auxiliaries, processing, storage and transport. For apparel and leather, the audit points are:
- the animal species behind leather, fur, wool, down and other animal-derived materials (pig and dog are excluded without exception), the slaughter or collection method, and the tanning and washing processes — certification bodies differ on hides from animals not slaughtered according to Islamic law once tanned, so the audit body's current standard prevails;
- whether auxiliaries such as sizing agents, softeners, dyes, fixing agents, coatings and adhesives contain animal-derived components (tallow-based ingredients, gelatin, animal enzymes);
- whether production lines, warehouses and transport are shared with non-Halal materials, and how cross-contamination is segregated and recorded;
- whether upstream suppliers can provide proof of origin, with traceability across the whole chain.
In short: the fiber decides the first step, auxiliaries and trims decide the second. A pure cotton T-shirt contains no animal-derived components and, under the text of Article 158, is not among the goods it covers — but there is currently no official document further clarifying whether the finished garment is therefore exempt from certification. If the softener is tallow-based or the label is genuine leather, the answer changes.
3. Which companies should act now
- Exporters of leather, fur, wool, silk and down products to Indonesia — the products themselves are animal-derived materials and in scope.
- Apparel makers using animal-derived auxiliaries or trims — a genuine-leather label, horn buttons, animal-glue fusible interlining or a tallow-based softener: a single trim can bring the whole product into scope.
- Suppliers of fabric, yarn and auxiliaries to Indonesian garment factories — apparel is in the mandatory scope, and its raw materials fall under certification too: pure cotton is on the exemption list in BPJPH Decision No. 301 of 2026 and can be exempted, while blended or viscose-containing yarns, dyes and auxiliaries carry a certification obligation; when the downstream finished product goes through BPJPH certification, the whole supply chain is reviewed and buyers will ask for composition and origin evidence or Halal certificates.
- Brand owners and traders — the obligation at the distribution stage falls on the importer, so certificate requirements move forward into purchasing terms.
Makers of ordinary garments with no animal-derived components and no animal-derived auxiliaries or trims: the regulation text does not list them, but there is currently no official document further clarifying the position of finished garments. We recommend preparing material evidence first and confirming requirements with buyers; voluntary certification is available when buyers require it.
4. How to prepare
- Inventory your products and draw the scope: apply the two-step test in Section 1 and sort products into three groups — in scope, depends on auxiliaries, and not listed in the regulation text; for finished garments in the last group there is currently no official document further clarifying their position, so prepare material evidence for them as well.
- Trace auxiliaries and trims: ask suppliers for composition statements and origin declarations; high-risk auxiliaries (leather, fur, down, sewing-thread lubricants, button base materials, interlining adhesives) need written proof of origin; send anything unclear for testing (PCR / LC-MS).
- Build the Halal Product Assurance System (SJPH) documents: Halal policy, procedures, a Halal supervisor, internal audit records, and a factory layout marking the production and storage areas of the products being registered.
- Before engaging a service provider, check that the LPH it works with is listed in BPJPH's official directory — certificates can only be issued by BPJPH and audits are carried out by an LPH, so be cautious of anyone who claims to issue certificates themselves.
- Timelines depend on how ready your materials are and on scheduling; the earlier you start collecting origin declarations for auxiliaries, the better. This article gives no fixed timeline or fee.
5. The position before and after October 18
On October 9 and 10, 2026, BPJPH's leadership stated publicly that the October 18 start date stands and will not be postponed; they also said that dedicated rules are being drafted for micro and small enterprises (UMK), imported raw and auxiliary materials, and consumer goods. As of this revision (October 12, 2026) that text had not been published; once it is, its text prevails. The two statements belong together: an unpublished rule is not a reason to wait. For in-scope products without a certificate, the route into Indonesian distribution is non-Halal labeling under the rules. The Halal obligation applies at the point of distribution in Indonesia — it is not an import license, so claims that uncertified goods are "banned from customs clearance" are inaccurate.
6. About SINOQUAL
SINOQUAL works with Halal inspection bodies (LPH) recognized by BPJPH, providing document preparation, application filing and audit-day communication support for BPJPH, HFC, Kosher and other certifications; in October 2026 SINOQUAL completed its own first apparel and textile BPJPH project. Send us three lists — fibers, auxiliaries and trims — and the free pre-assessment will first explain whether you are in scope and where the difficulties lie. We usually reply within one working day, longer over public holidays.
FAQ
- Which apparel and leather products does Indonesia's 2026 rule bring under mandatory Halal certification?
- Article 161 of PP 42/2024 names apparel, headwear and accessories (deadline October 17, 2026, enforced from October 18), and Article 158 limits the obligation to goods derived from or containing animal-derived components. Leather, fur, wool, silk and down products, and products using animal-derived auxiliaries or trims, are in scope. Ordinary cotton or polyester garments whose auxiliaries and trims contain nothing animal-derived are not listed in the regulation text, but there is currently no official document further clarifying whether such finished garments need certification.
- Clothes and bags are not eaten, so why does Halal apply?
- The audit covers the whole chain of raw materials, auxiliaries, processing and storage: the origin and processing of animal-derived materials, whether auxiliaries contain animal-derived components, and whether production lines are shared with non-Halal materials.
- Can uncertified products still enter Indonesia after October 18?
- Ordinary garments without animal-derived components are not listed in the regulation text, but there is currently no official document further clarifying whether they need certification; we recommend preparing material evidence and confirming requirements with buyers. In-scope products must be certified or carry non-Halal labeling under the rules; the Halal obligation applies at the point of distribution, not as an import license. Dedicated rules are being drafted and the text has not been published; once it is, its text prevails.
- How should a company prepare, step by step?
- Draw the scope with the two-step test, then trace auxiliaries and trims and test anything unclear, build the SJPH documents, check that the service provider's LPH is listed in BPJPH's directory, and start early rather than queueing after the rules take effect.
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