The Badan Pengawas Obat dan Makanan (BPOM) has released a draft amendment to its Regulation No. 13 of 2019 on Maximum Limits of Microbial Contamination in Processed Foods, reflecting evolving scientific standards and advancements in food safety risk assessment. The proposed regulation introduces new product categories, revises microbiological criteria, and establishes transitional compliance timelines for industry stakeholders.
Regulatory Background and Rationale
The amendment is grounded in Indonesias primary food safety framework, including Law No. 18/2012 on Food and Government Regulation No. 86/2019 on Food Safety, alongside existing BPOM organizational regulations. The authority notes that current microbial limits in certain food categories are no longer aligned with scientific and technological developments, necessitating a comprehensive update.
Key Amendments Introduced (Article I)
1. Addition of New Food Categories
The draft regulation expands the scope of microbiological criteria by introducing new processed food types:
1.Ready-to-eat flour/starch-based products under Category 06.4.3 (pre-cooked pasta and similar products)
2.Pasteurized sausages and meatballs under Category 08.3.2 (heat-treated processed meat products)
These additions reflect increased regulatory attention to convenience and ready-to-eat food segments, which carry higher microbiological risks due to minimal consumer preparation.
2. Revision of Microbiological Criteria
a. Flavoured Powdered Beverages Containing Dairy/Creamer/Chocolate
(Category 14.1.4.3 concentrates for water-based flavoured drinks)
Total Plate Count (ALT): m = 310 CFU/g; M = 510 CFU/g; n = 5; c = 2
Yeasts and moulds: m = 10 CFU/g; M = 510 CFU/g; n = 5; c = 1
Salmonella: Negative 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, scented teas):
Total Plate Count: m = 10? CFU/g; M = 10? CFU/g; n = 5; c = 3
Yeasts and moulds: Dry/powdered tea: m = 10 CFU/g; M = 10? CFU/g
Tea bags: m = 510 CFU/g; M = 510? CFU/g
3. Microbiological Limits for Newly Added Categories
Ready-to-Eat Flour/Starch Products:ALT: 10?10? CFU/g (n = 5; c = 2)
Bacillus cereus: 1010 CFU/g (n = 5; c = 1)
Staphylococcus aureus: 1010 CFU/g (n = 5; c = 2)
Escherichia coli: ?3 MPN/g (n = 5; c = 0)
Salmonella: Negative in 25 g
Pasteurized Sausages and Meatballs:
ALT: 10?10? CFU/g (n = 5; c = 3)
Enterobacteriaceae: 1010 CFU/g (n = 5; c = 2)
Staphylococcus aureus: 10210 CFU/g (n = 5; c = 1)
Salmonella: Negative in 25 g
Listeria monocytogenes: Negative in 25 g
These parameters are supported by internationally recognized analytical standards, including ISO and SNI methods, ensuring alignment with global food safety practices.
Transitional Provisions (Article II)
The regulation establishes a 12-month compliance period specifically for flavoured powdered beverages containing milk, dairy derivatives, creamers, or chocolate:
Products already holding business licenses must comply within 12 months from enactment
Products currently under approval will continue under existing rules but must also comply within the same 12-month timeframe
Business licenses are defined as legal authorization for distributing processed foods in Indonesia, including products from small-scale or home industries
This amendment represents a significant tightening of microbiological safety standards in Indonesia, particularly targeting:
Ready-to-eat and convenience foods
Dairy-containing powdered beverages
Tea and plant-based beverage categories
The inclusion of strict pathogen criteria, such as zero tolerance for Salmonella and Listeria monocytogenes, reflects a risk-based regulatory approach aligned with international food safety frameworks.
Food manufacturers, importers, and distributors will need to reassess their HACCP systems, microbiological testing protocols, and supplier quality controls to ensure compliance within the transition period.
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