The Food and Drug Supervisory Agency of the Republic of Indonesia (Badan Pengawas Obat dan Makanan Republik Indonesia/BPOM RI) has readjusted the list of raw materials and ingredients prohibited as food additives (prohibited ingredients) for processed food through the issuance of BPOM Regulation No. 22 of 2023 (Regulation 22/2023), in force since 15 August 2023. The recently issued regulation revokes and replaces the previous legal framework i.e., BPOM Regulation No. 7 of 2018 (Regulation 7/2018).
To provide a summary of the new regulation, this week’s Legal Updates covers the discussion of Regulation 22/2023 and the updates. First of all, we should understand that all manufacturing or import activities of processed foods are prohibited from using certain raw materials and ingredients as food additives, either in a single form or in mixtures that originate from biological and/or synthetic sources. The prohibited raw materials and ingredients include materials that may disturb, harm and/or endanger health; and/or materials that contain narcotics, psychotropics, nicotine, drug materials, protected plants and/or protected animals.
Even though the list of raw materials and ingredients prohibited for processed food has recently been readjusted through Regulation 23/2023, it should be noted that the list may be readjusted again in the future in line with scientific developments.
There are differences in the total number of prohibited materials and ingredients stipulated in Regulation 22/2023 and Regulation 7/2018. The total number of prohibited raw materials derived from biological resources is reduced from 165 to 156; the total number of chemical compounds prohibited for use in processed foods is reduced from 35 to 5; and the total number of prohibited ingredients as food additives is 45, which was not previously regulated in Regulation 7/2018.
The table below summarizes the readjusted list of prohibited raw materials and ingredients:
| Summary of Materials | |
| Prohibited Raw Materials | Prohibited Ingredients |
| Biological resources: Regulation 22/2023 no longer includes several materials e.g., Cinnamomum iners Reinw: Blume, Lonicera japonica Thunb, Melaleuca alternifolia (Meiden & Betche) Chell, Melissa officinalis L, Morus spp, Mucuna pruriens, Verbena officinalis L. | Include the following, among others: Boric acid and related substances, Dulcamara, Chloramphenicol, Brominated vegetable oil, Nitrobenzene, Alkanet, Food Brown 2, C.I. Acid Green No.3, Orchid and Orcein, Violet 6 B, etc. |
| Chemical compounds: Regulation 22/2023 only leaves five out of 35 compounds on the list e.g., Lipoic acid, Acetyl L-Carnitine, Benzylpiperazine and/or its derivatives, Methylsulfonylmethane, Phaseolamin. | |
Regulation 22/2023 also states that the supervision on Prohibited Raw Materials and Ingredients as food additives is to be implemented based on relevant laws and regulations, which includes Regulation of the Government No. 86 of 2019 on Food Safety.
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