Regulation of the Indonesian Food and Drug Authority Number 3 of 2026 Updates Maximum Limits for Microbial Contamination and Sets 12-Month Adjustment Period

Introduction

On February 18, 2026, the Indonesian Food and Drug Authority (Badan Pengawas Obat dan Makanan, “BPOM”) issued Regulation of the Indonesian Food and Drug Authority Number 3 of 2026 on the Amendment to Regulation of the Indonesian Food and Drug Authority Number 13 of 2019 on the Maximum Limits for Microbial Contamination in Processed Food (“BPOM Regulation 3/2026”), which took effect on its promulgation date, February 26, 2026. BPOM Regulation 3/2026 establishes and updates the maximum limits for microbial contamination across various processed food categories to support public health protection.

The considerations section of BPOM Regulation 3/2026 states that the previous provisions did not include maximum microbial contamination limits for ready-to-consume flour/starch products under food category 06.4.3, as well as pasteurized sausages and meatballs under food category 08.3.2. Furthermore, the microbial contamination limits applicable to flavored powder drinks containing milk, dairy products, creamer, or chocolate under category 14.1.4.3, as well as dried tea, tea powder, and tea bags under category 14.1.5, were deemed inconsistent with scientific and technological developments in the processed food sector and required revision.

Comparison

BPOM Regulation 3/2026 amends the provisions in the Annex of Regulation of the Indonesian Food and Drug Authority Number 13 of 2019 on the Maximum Limits for Microbial Contamination in Processed Food (“BPOM Regulation 13/2019”). The following table compares BPOM Regulation 3/2026 with BPOM Regulation 13/2019:

Key Provisions

Changes to Microbiology Criteria for Processed Food

Article I of BPOM Regulation 3/2026 amends the microbiology criteria for processed food as set out in the Annex and establishes a revised Annex as an integral part of BPOM Regulation 3/2026. This Annex contains microbial contamination parameters, sampling plans, microbial limits, and analysis methods for each processed food category. As a result of this amendment, businesses must adjust their quality control measures in accordance with the parameters applicable to their respective product categories. The Annex of BPOM Regulation 3/2026 covers, among others, the following categories:

1. Dairy products and analogs (including pasteurized milk, yogurt, cream, milk powder, and cheese);

2. Fats, oils, and oil emulsions (including butter, margarine, and fat emulsions);

3. Edible ice, fruits, and vegetables (including candied fruit products, frozen vegetables, mushrooms, tubers, seaweed, and nuts);

4. Confectionery/sweets and chocolate (including cocoa powder and chewing gum);

5. Cereals and derived cereal products (including flour, pasta, raw noodles, instant noodles, and processed rice);

6. Bakery products (including bread, crackers, biscuits, and frozen dough premixes);

7. Meat and meat products, including poultry and game (including cured, dried, or frozen products);

8. Fish and fishery products (including fish fillets, mollusks, crustaceans, echinoderms, amphibians, reptiles, and fish roe/caviar);

9. Eggs and egg products (including preserved eggs and egg-based desserts);

10. Salts, spices, soups, sauces, salads, and protein products (including ready-to-use seasonings, mayonnaise, oyster sauce, and soy sauce);

11. Food products for special nutritional purposes (including infant formula, complementary foods for breast milk, and diet foods);

12. Beverages, excluding dairy products (including mineral water, soda water, fruit juice, nectar, carbonated drinks, electrolyte drinks, coffee, and tea); and

13. Ready-to-eat snacks (including processed nuts, fish-based snacks, and potato or tuber-based snacks).

Additional Parameters for Specific Categories

The Annex of BPOM Regulation 3/2026 introduces microbiology parameters for categories that were not previously specifically regulated.

1. Ready-to-Consume Flour/Starch Products (Category 06.4.3): Businesses are required to conduct testing for TPC, Bacillus cereus, Salmonella, Staphylococcus aureus, and Escherichia coli prior to product distribution.

2. Pasteurized Sausages and Meatballs (Category 08.3.2): Businesses are required to conduct testing for TPC, Enterobacteriaceae, Staphylococcus aureus, Salmonella, and Listeria monocytogenes. For this category, Salmonella and Listeria monocytogenes must yield negative results in 25-gram samples in accordance with the Annex.

Obligation to Use Verified Analysis Methods

BPOM Regulation 3/2026 requires businesses to use the latest verified analysis methods in every microbiological test. These analysis methods must follow the standards established for each parameter, including relevant ISO or SNI ISO standards as listed in the Annex. Microbiological testing must be performed using compliant methods to ensure that test results satisfy the applicable maximum microbial contamination limits.

Transitional Provisions

Article II of BPOM Regulation 3/2026 regulates the adjustment of business licensing for flavored powder drinks containing milk, dairy products, creamer, or chocolate, with the following provisions:

1. Businesses that have obtained business licenses before the promulgation of BPOM Regulation 3/2026 must adjust their microbial contamination limits according to the Annex of BPOM Regulation 3/2026 within a maximum of 12 (twelve) months from the date of promulgation.

2. Products whose business licensing process was ongoing at the time of promulgation will continue to be processed under the previous provisions. However, these businesses remain obligated to adjust their microbial contamination limits according to the Annex of BPOM Regulation 3/2026 within a maximum of 12 (twelve) months from the date of promulgation.

Business Licensing to Support Business Activities (Perizinan Berusaha Untuk Menunjang Kegiatan Usaha, “PBUMKU”) during this adjustment period serves as valid authorization to distribute Processed Food within Indonesian territory, which also includes food produced by the food home industry (Industri Rumah Tangga Pangan, “IRTP”).

Closing

BPOM Regulation 3/2026 amends the Annex on microbiology criteria in processed food, including adding provisions for ready-to-consume flour or starch products and pasteurized sausages and meatballs, as well as adjusting parameters for several other categories. The amendments took effect on February 26, 2026. A 12 (twelve)-month adjustment period is granted only for flavored powder drinks containing milk, dairy products, creamer, or chocolate, whether licensed or still in the application process at the time of promulgation. Other food categories must comply with the new standards as of the effective date. Businesses must ensure that the microbial contamination parameters, sampling plans, microbial limits, and analysis methods they apply comply with the Annex to meet the applicable maximum microbial contamination limits.