Recently, Indonesia submitted notification G/SPS/N/IDN/138/Add.1, indicating that the Indonesian Food
and Drug Authority (BPOM) has issued a draft revision of its 2019 Regulation No. 13 on maximum microbiological
limits in processed foods (G/SPS/N/IDN/138). The proposed draft introduces new product categories, updates microbiological standards,
and establishes a transitional compliance timeline for industry stakeholders.
This revision is based on Indonesia’s main food safety framework, including Law No. 18/2012 on Food,
Government Regulation No. 86/2019 on Food Safety, and current BPOM organizational regulations.
BPOM noted that microbiological limits for some food categories are no longer consistent with scientific and
technological developments, making comprehensive updates necessary.
1. New Food Categories
The draft expands microbiological standards to cover additional processed food types:
Category 06.4.3: Instant pasta and similar products, including ready-to-eat flour/starch-based items.
Category 08.3.2: Pasteurized sausages and meatballs under heat-treated meat products.
Category 14.1.4.3: Flavored powdered beverages (liquid or solid) containing milk, dairy derivatives, creamer, or chocolate.
Category 14.1.5: Coffee, coffee substitutes, tea, herbal infusions, and hot cereal beverages (excluding cocoa), including dry tea,
tea powder, and tea bags (black, green, white, oolong, and flavored teas).
These additions reflect BPOM’s growing focus on convenience and ready-to-eat foods,
which carry higher microbiological risks due to minimal consumer handling.
2. Revised Microbiological Standards
a. Flavored powdered milk/chocolate beverages (Category 14.1.4.3)
Total plate count: m = 3×10³ CFU/g; M = 5×10³ CFU/g; n = 5; c = 2
Yeast and mold: m = 10² CFU/g; M = 5×10² CFU/g; n = 5; c = 1
Salmonella: not detected in 25 g (n = 5; c = 0)
b. Tea products (Category 14.1.5)
Applicable to dry tea, powdered tea, and tea bags (black, green, white, oolong, and floral teas):
Total plate count: m = 10⁴ CFU/g; M = 10⁶ CFU/g; n = 5; c = 3
Yeast and mold:
Dry/powdered tea: m = 10³ CFU/g; M = 10⁴ CFU/g
Tea bags: m = 5×10³ CFU/g; M = 5×10⁴ CFU/g
3. Microbiological Limits for Newly Added Categories
Category 06.4.3 Instant pasta/flour-starch products
Total plate count (ALT): 10⁴ CFU/g (n = 5; c = 2)
Bacillus cereus: 10² CFU/g (n = 5; c = 1)
Staphylococcus aureus: 10¹⁰ CFU/g (n = 5; c = 2)
E. coli: ≤3 MPN/g (n = 5; c = 0)
Salmonella: not detected in 25 g
Category 08.3.2 Pasteurized sausages and meatballs
Total plate count (ALT): 10⁴ CFU/g (n = 5; c = 3)
Enterobacteriaceae: 10¹⁰ CFU/g (n = 5; c = 2)
Staphylococcus aureus: 10² CFU/g (n = 5; c = 1)
Salmonella: not detected in 25 g
Listeria monocytogenes: not detected in 25 g
All limits follow internationally recognized analytical methods, including ISO and SNI,
ensuring alignment with global food safety practices.
4. Transitional Compliance Period
The regulation grants a 12-month compliance period for flavored powdered beverages containing milk,
dairy derivatives, creamer, or chocolate:
Products with valid business licenses must comply within 12 months after the regulation takes effect.
Products still under approval must comply with current rules but must also meet the new standards within the 12-month period.
Here, “business license” refers to legal authorization to distribute processed foods in Indonesia, including small-scale or home-based production.
5. Regulatory Implications
This revision represents a significant tightening of Indonesia’s microbiological safety standards, targeting ready-to-eat foods,
powdered milk beverages, tea, and plant-based beverages. Zero-tolerance policies for Salmonella and
Listeria monocytogenes demonstrate a risk-based approach consistent with international food safety frameworks.
Recommendations for Businesses:
Manufacturers, importers, and distributors should reassess their HACCP systems,
microbiological testing plans, and supplier quality controls during the transition period.
Using a reputable Indonesian freight forwarder or Indonesia double clearance logistics
provider can help ensure imported products meet BPOM compliance requirements.
Regular updates on BPOM notifications and microbiological standards
are critical for maintaining market access and reducing clearance risks.
