Interpreting Indonesia's Halal Certification Standard: The HPAS Implementation Guide

This article introduces the Halal Product Assurance System (HPAS) standard and its implementation requirements, to help enterprises meet Indonesia's halal certification standard (HPAS). Below is an overview of the key content, structured as the standard's 12 criteria — each with its objective and the implementation evidence expected during an audit. 1. Halal Policy Objective: top management commits to consistently producing halal products. 1.1 Top management must establish a halal policy. 1.2 The halal policy must be in written form. 1.3 The halal policy must be disseminated to relevant stakeholders: the local team (training), the plant team (training) and suppliers (requesting supporting documents, or emailing suppliers with the halal policy attached). 2. Halal Management Team (HMT) Objective: a group of people responsible for implementing, evaluating and continuously improving the HPAS. 2.1 The organizational structure is made up of personnel from key activities (new-material selection and formulation (R&D), procurement, incoming materials (QC/QA), material storage, production, cleaning, finished-goods storage, transportation). 2.2 Top management has issued the HMT appointment letter. 2.3 The duties and responsibilities of each HMT member must be clearly defined. 3. Training and Education Objective: halal training must be scheduled once a year; personnel involved in manufacturing halal products must be trained, and the training must be evaluated to improve their competence. 3.1 The training SOP must be adjusted to add halal-training requirements. 3.2 The company must conduct halal training in advance of the audit. 3.3 Training materials must cover the 12 HPAS criteria. 3.4 Trainers must be competent; the initial training is conducted by the auditor, after which anyone who passes the training evaluation is qualified to be the next trainer. 3.5 Training must include an evaluation mechanism (e.g., oral or written exams) to measure competence. 4. Materials Materials comprise raw materials, additives, processing aids, primary packaging, cleaning agents and post-cleaning validation media (if any), and lubricating grease (if any). 4.1 A material/ingredient list (B.4). 4.2 The auditor will review the material list. 4.3 Positive-list materials require no supporting documents. 4.4 Non-positive-list / critical materials require halal supporting documents; some can be found in the LPPOM database. 4.5 Only when supporting documents are not in the LPPOM database will the auditor request further support (such as a halal certificate, flow chart, safety data sheet, analysis report or manufacturer's statement). 4.6 Cleaning agents are usually procured by the plant, while other materials may be procured by a global procurement department. The company must have a mechanism to ensure the validity of material supporting documents. 5. Production Facilities Scope: from material preparation at the facility producing certified products through to final product packaging. 5.1 Production facilities must be free of pork and its derivatives. 5.2 If facilities are shared with non-certified halal products, cleaning must be performed at every product changeover. 5.3 The facility scope runs from material preparation to final product packaging. 5.4 The company must arrange facility cleaning procedures. 5.5 Cleaning agents used must meet halal standards (halal certificate, or a chemical/no-animal-ingredient declaration). 5.6 Sampling methods and sampling tools must be free of contamination. 5.7 Cleaning-validation methods and their tools must be free of contamination. 6. Products 6.1 The product list must be clearly specified (B.4). 6.2 The master formula of certified products must be provided. 6.3 Product names and packaging must meet halal standards (no leaning toward haram products or any vulgar content). 6.4 The company must have new-product development ensuring products to be sold on the Indonesian market are halal-certified and bear the halal mark; non-halal products must be marked as non-halal. 6.5 Reformulation of halal-certified products must not change their halal status. 7. Written Procedures for Critical Activities Critical activities are those that, if uncontrolled, would change the halal compliance of materials, facilities and products. Their scope includes new-material selection, incoming inspection, material storage, production, formulation, cleaning, finished-goods storage and transportation. 7.1 A written procedure for new-material selection (new materials must be approved by the halal body; keep evidence). 7.2 A written procedure for incoming inspection (material name and code, manufacturer name and country of origin on packaging must match supporting documents; transport must use clean vehicles; keep evidence). 7.3 A written procedure for material storage (no cross-contamination; keep evidence). 7.4 A written procedure for production (using approved materials and facilities and the master formula for each product; keep evidence). 7.5 A written procedure for product formulation (reformulation must not change halal status; keep evidence). 7.6 A written procedure for cleaning production facilities (halal products produced in clean facilities using halal-compliant cleaning agents; keep evidence). 7.7 A written procedure for finished-goods storage (no cross-contamination; keep evidence). 7.8 A written procedure for finished-goods transportation (clean vehicles, no contamination). 8. Traceability 8.1 A written procedure for product traceability. 8.2 Halal-certified products made with approved materials and approved facilities must be traceable; keep evidence. 9. Handling of Non-conforming Products 9.1 A written procedure for non-conforming halal products, covering definition and handling. 9.2 Non-conforming halal products are halal-certified products that unintentionally used unapproved materials and/or facilities during production, or were contaminated during handling. 9.3 Non-conforming halal products may not be declared halal, may not be reworked or reprocessed, and may be sold to customers who do not require halal products. 10. Internal Audit 10.1 A written procedure for internal halal audit. 10.2 Internal halal audit is scheduled once a year. 10.3 The internal halal audit covers all HPAS criteria and is conducted by qualified personnel. 10.4 The company has a mechanism to ensure all findings are resolved and not repeated at the next audit. 10.5 The company commits to reporting the annual halal audit results to the halal body. 11. Management Review 11.1 A written procedure for management review of HPAS implementation. 11.2 Management review is scheduled once a year. 11.3 Management review is attended by top management. 12. Food Safety / Good Manufacturing Practice and Related Regulations The company must have implemented Good Manufacturing Practice (GMP), Hazard Analysis and Critical Control Points (HACCP), ISO 22000, FSSC 22000, BRC, AIB, PAS 220 or another system. Certificates for GMP, HACCP, ISO 22000, FSSC 22000, BRC, AIB, PAS 220 or another system are available. The company provides evidence of the most recent audit (internal or external) of GMP, HACCP, ISO 22000, FSSC 22000, BRC, AIB, PAS 220 or another system. In summary Enterprises meet the HPAS standard through training, documentation and system implementation, and ultimately obtain Indonesian halal certification. Halal certification proves that a product meets halal requirements and is essential for entering Indonesia and other halal markets, enhancing product competitiveness and consumer trust. Enterprises new to Indonesian halal certification often find the standard difficult to interpret — especially documentation, process management and implementation details — and need a full understanding of halal compliance requirements across raw-material procurement, production, storage and transportation. Professional consulting on HPAS interpretation and training, documentation guidance (HPAS manual, procedure documents, etc.), system implementation and internal-audit support, and registration, pre-audit and audit support can help enterprises pass certification smoothly.