What chemical and microbiological testing do processed foods need for Indonesia's BPOM ML registration?

Laboratory testing is a core requirement of BPOM ML registration for processed foods, covering two main areas: 1) chemical contaminant testing (under BPOM Regulation No. 16 of 2019) — including lead, cadmium, mercury, arsenic, tin, sulfur dioxide, aflatoxin, ochratoxin A and pesticide residues, with maximum permitted limits varying by food category, carried out at accredited testing bodies (such as KAN-accredited laboratories); 2) microbiological contamination testing — including total plate count (TPC), yeast and mold count, coliforms, E. coli, Salmonella, Staphylococcus aureus and Listeria monocytogenes, with parameters depending on the product's nature. Test reports are generally required to be issued within six to twelve months before the application date and to reference accredited methods such as ISO, AOAC or SNI. In addition, special categories such as GMO, irradiated and fortified foods have extra testing and labeling requirements.

Chemical and Microbiological Testing of Processed Foods: What Exporters Must Prepare

Laboratory testing is a core requirement of BPOM ML registration for processed foods, with the scope depending on the product category. This article covers the two main areas — chemical contaminant testing and microbiological contamination testing — plus additional requirements for special product categories.

Laboratory testing is a core requirement of BPOM ML registration for processed foods, with the scope of testing depending on the product category. There are two main areas of concern. 1. Chemical contaminant testing Under BPOM Regulation No. 16 of 2019, imported processed foods must undergo chemical contaminant testing. The chemical contaminants tested specifically include: lead (Pb), cadmium (Cd), mercury (Hg), arsenic (As), tin (Sn), sulfur dioxide, aflatoxin, ochratoxin A, and pesticide residues. The maximum permitted limits vary by food category. For example, canned fish products face stricter tin-limit standards than dried snack products. Laboratory testing must be carried out at an accredited testing body. Indonesia accepts test results from domestic laboratories accredited by the National Accreditation Committee (KAN), as well as from certain internationally accredited laboratories, subject to BPOM's current approved list. 2. Microbiological contamination testing The microbiological parameters typically required for BPOM ML registration include: total plate count (TPC), yeast and mold count, coliforms, E. coli, Salmonella, Staphylococcus aureus, Listeria monocytogenes, Bacillus cereus, Cronobacter sakazakii, and others. The specific parameters depend on the nature of the product — whether it is a ready-to-eat food, a dairy product, a beverage, or a heat-treated product. Test reports must be recent, generally required to be issued within six to twelve months before the application date, and must reference accredited testing methods, such as those of ISO, AOAC (the Association of Official Analytical Chemists) or the Indonesian National Standard (SNI). Preparing accurate and complete laboratory documentation in advance can prevent delays. Under the Codex Alimentarius framework, which BPOM uses as an international benchmark reference, food-safety testing standards provide a globally recognized baseline that aligns closely with Indonesia's domestic requirements. 3. Additional testing requirements for special product categories 1. Genetically modified foods (GMO) — if a product contains genetically modified ingredients exceeding 5%, a GMO test report must be provided, and the label must state “contains genetically engineered raw materials” (Mengandung Bahan Baku Rekayasa Genetika). 2. Irradiated foods — an irradiation-dose test report must be provided, and the label must state “has been irradiated” (Telah Diradiasi). 3. Allergen labeling — although BPOM does not currently mandate allergen testing, it is recommended to label the eight major allergens (peanuts, soy, milk, eggs, fish, shellfish, tree nuts, wheat); since 2024, BPOM has begun promoting the standardization of allergen labeling. 4. Fortified foods — if vitamins or minerals are added, a fortification-ingredient test report must be provided, and it must comply with the addition limits specified by SNI or Codex.

FAQ

What chemical and microbiological testing do processed foods need for Indonesia's BPOM ML registration?: Laboratory testing is a core requirement of BPOM ML registration for processed foods, covering two main areas: 1) chemical contaminant testing (under BPOM Regulation No. 16 of 2019) — including lead, cadmium, mercury, arsenic, tin, sulfur dioxide, aflatoxin, ochratoxin A and pesticide residues, with maximum permitted limits varying by food category, carried out at accredited testing bodies (such as KAN-accredited laboratories); 2) microbiological contamination testing — including total plate count (TPC), yeast and mold count, coliforms, E. coli, Salmonella, Staphylococcus aureus and Listeria monocytogenes, with parameters depending on the product's nature. Test reports are generally required to be issued within six to twelve months before the application date and to reference accredited methods such as ISO, AOAC or SNI. In addition, special categories such as GMO, irradiated and fortified foods have extra testing and labeling requirements.

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