BPOM has officially replaced Regulation No. 22 of 2017 with the newly issued Regulation No. 22 of 2025, expanding the scope and detail of food product recall and destruction procedures in Indonesia.
This update reflects the growing need for stronger consumer protection and alignment with international food safety standards.
What’s New:
- Covers not only food products but also additives, raw materials, packaging, and labels
- Classification of withdrawals into three risk-based categories
- Detailed procedures for destruction and traceability
- Mandatory public disclosure for high-risk cases
- Enhanced sanctions and enforcement mechanisms
Key Differences and Updates:
| Area | 2017 Regulation | 2025 Regulation |
| Title & Focus | Focused on food withdrawal | Expanded to include withdrawal and destruction of processed food |
| Withdrawal Types | General withdrawal | Introduces mandatory vs. voluntary withdrawal |
| Classification | Not specified | Introduces 3 classes of withdrawal based on risk (Class I–III) |
| Destruction (Pemusnahan) | Mentioned briefly | Detailed procedures, documentation, and supervision requirements |
| Traceability | Required | Enhanced with international standards reference |
| Public Involvement | Limited | Encourages community participation and public disclosure for Class I withdrawals |
| Sanctions | Administrative | Expanded to include fines, license revocation, and service suspension |
| Publication | Not regulated | Mandatory public disclosure within 24 hours for Class I withdrawals |
Implications for Businesses:
- Operations:
Need to update SOPs, invest in traceability technology, and train staff on new recall and destruction procedures.
- Legal Compliance:
Increased monitoring of regulatory changes, more frequent internal audits, and closer coordination with legal counsel to avoid sanctions.
- Risk Management:
Enhanced focus on identifying, assessing, and mitigating food safety risks throughout the supply chain.
- Financial Planning:
Budgeting for potential recall costs, technology upgrades, staff training, and possible administrative fines.
This new regulation marks a significant shift in Indonesia’s food safety landscape. Businesses must act swiftly to align their internal procedures with the new requirements. Stay informed and ensure your business is ready for these important regulatory changes!
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
