As the largest economy in ASEAN and the fourth most populous country, Indonesia has a relatively well-established food safety regulatory system. On 9 May 2022, Indonesian Food and Drug Authority has published the requirements of heavy metal contaminants in processed food.

The Regulation requires organizations and individuals engaged in the production, storage, transport and or distribution of processed foods to comply with the requirements for heavy metal contamination in processed foods. The Regulation sets maximum limits for arsenic (As), lead (Pb), mercury (Hg) and cadmium (Cd) contaminants in 45 types of processed foods, and maximum limits for tin (Sn) in special foods, including powdered milk for infants and young children, foods for infants and young children and canned processed foods.

To enable exporters to understand the main amendments on the regulations and to avoid greater problems caused by a lack of understanding of the provisions, Foodmate explains the main changes to the new requirements for heavy metal limits for processed foods.

1. Modification of  the normative language

Modifications to normative language. The heavy metal limit requirement is defined as a processed food hygiene requirement, and in 2018, it was expressed as "heavy metal limit as a processed food safety requirement".

2. Laboratory for the testing of imported processed foods

The new Indonesian food regulations stipulate that for the Heavy metal Contamination Testing of imported Processed Food, laboratory test results can be issued by a laboratory of the country of origin which has a mutual recognition agreement with the authorized institution and/or accredited laboratory in Indonesia in accordance with the provisions of the legislation.

And in 2018, it is stipulated that Heavy metal Contamination Testing for imported Food can be carried out by foreign laboratories that have been accredited by the national accreditation committee or the accreditation body of the country of origin that have signed a Mutual Recognition Arrangement (MRA) agreement.

3. Removal of the CAC food classification system

In the 2018 food Regulations, the processed food categories refer to the CAC food classification system (e.g. 01.0 for dairy products and their analogues, 07.0 for bakery products). The new regulation removes the previous classification and adopts the product category directly as the classification (e.g. 1. dairy products, 2. fat processed products).

4. Newly add maximum resident limits (MRLs) for heavy metals for some product categories

The MRLs for heavy metal limits have been added for raw agar powder, agar powder, processed fruits, sauces, salads, protein products and yeast.

The special food subdivisions: powdered milk formula for infants and young children, special medical food, processed food for infants and children, special medical food for adults, processed food for weight control, processed food for athletes, and processed food for lactation and pregnant women, with heavy metal limit requirements for each subdivision. The MRLs for heavy metals required for some products are shown in Table 1.

5. Revision of the indicator requirements for some products

The lead content of processed fruit juice (Sari Buah Olahan) is more stringent, from 0.10mg/kg to 0.03mg/kg; the arsenic content of salt is more stringent, from 0.15mg/kg to 0.10mg/kg; However, the cadmium content requirements for flavored water-based beverages, electrolyte beverages and granular beverages have been relaxed, from 0.01mg/kg to 0.05mg/kg.

6. Summary

The revision of the maximum limits for heavy metals in processed foods is an adaptive change based on the development of the food industry. The new Indonesian food regulations refine the limit requirements for special foods and there are changes to the maximum limit requirements for several products. For more information on food compliance, please contact Global Foodmate.