Brand owners with products on the Indonesian market should be aware of an important regulatory development that may affect commercialisation plans, distribution arrangements and product compliance requirements.
Indonesia is one of the world's largest consumer markets and the world's largest Muslim-majority country. As a result, halal certification is increasingly becoming an important regulatory and commercial consideration for businesses operating in the region.
Indonesia's Halal Product Assurance Law (Law No. 33 of 2014) introduced a phased programme of mandatory halal certification for products sold in Indonesia. Food and beverage products have already been subject to mandatory certification requirements since October 2024. A further phase is scheduled to take effect on 17 October 2026, extending requirements to additional product sectors including cosmetics, supplements, pharmaceuticals and a broader range of consumer goods.
The Indonesian authorities have indicated that products falling within relevant categories may require halal certification before they can be lawfully marketed in Indonesia. Products that are not halal must generally be identified and labelled accordingly. Non-compliance may lead to administrative sanctions, including warnings, fines, withdrawal of products from the market and possible licensing consequences.
From a trade mark perspective, certification is granted in relation to products rather than trade marks themselves. Nevertheless, the new regime may have practical implications for brand owners because a registered trade mark may have limited commercial value if products cannot be lawfully sold or distributed in Indonesia. Businesses planning new product launches, distribution arrangements or expansion into Indonesia may therefore wish to consider halal compliance as part of their wider market-entry strategy.
The classes most likely to be affected include, among others:
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Class 3 (cosmetics and personal care products)
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Class 5 (pharmaceuticals, supplements and health products)
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Class 18 (leather goods)
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Classes 29, 30 and 32 (food and beverage products)
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Class 43 (restaurant, catering and food service brands)
Certain chemical, household, textile and consumer goods categories may also fall within scope.
Many overseas brand owners do not commercialise products directly in Indonesia and instead rely on local distributors, importers, franchisees, licensees or commercial agents. In those circumstances, responsibility for product certification and compliance may sit partly or wholly with the local intermediary, depending upon the terms of the arrangement that is in place. Businesses may therefore wish to check with their Indonesian distributor or commercial partner to understand what steps have already been taken and whether any further action is required.
How can we help?
If you have products marketed or distributed in Indonesia and would like to understand whether the mandatory halal certification requirements may affect your business, please let us know. We would be happy to obtain more detailed guidance from local Indonesian counsel, or arrange an introduction directly.
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