Food Testing Laboratory in Indonesia: What BPOM Checks Before Registration

Every processed food product sold in Indonesia has to clear BPOM’s laboratory testing requirements before it can get a distribution permit, and for most manufacturers and importers, the hard part isn’t running the tests themselves. It’s picking a food testing laboratory whose accreditation actually covers what BPOM wants to see. This article is written for food and beverage manufacturers, importers, and regulatory teams working through a BPOM registration dossier, and it walks through how BPOM and the Ministry of Health define an acceptable laboratory, what actually gets tested, and where lab selection most often slows a submission down.

That laboratory step sits inside the wider BPOM Certification process every processed food product has to pass through, and it’s usually the step teams underestimate.

In our experience preparing food registration dossiers for both local and imported products, BPOM reviewers rarely reject a Certificate of Analysis because the test values themselves are wrong. They reject it because the issuing food testing laboratory’s published KAN accreditation scope does not name the exact product matrix being tested (a lab accredited for dairy testing, for example, but not for plant-based dairy alternatives). This mismatch is invisible on the CoA itself; it only shows up when someone cross-checks the laboratory’s scope of accreditation document against the product category before submission, not after. That single gap between “the lab is accredited” and “the lab is accredited for this specific matrix” accounts for a disproportionate share of the registration delays we see in practice.

Food Testing Laboratory: What “Government-Approved” Means Under BPOM Rules

A government-approved food testing laboratory, in the context of Indonesian food registration, is one of two things: a laboratory operated directly by a government body, such as a Balai Besar POM or Balai POM testing unit under 业务流程对象模型, or a private laboratory holding SNI ISO/IEC 17025 accreditation from the Komite Akreditasi Nasional (KAN) that specifically covers the test parameters and product matrix being submitted.

在下面 Peraturan BPOM No. 1 Tahun 2022 tentang Pengawasan Klaim pada Label dan Iklan Pangan Olahan, Pasal 27 ayat (1), any nutrition or health claim on a food label must be supported by analysis from an accredited laboratory or a government laboratory. For imported products, this analysis does not have to come from an Indonesian laboratory: Pasal 27 ayat (2) allows results issued either by a laboratory in the country of origin that is accredited by the competent authority there, or by a laboratory in the country of origin operating under a mutual recognition arrangement with an accredited laboratory or authority in Indonesia. BPOM applies the same underlying standard across its broader food registration review, which sits on the food safety framework set out in Undang-Undang No. 18 Tahun 2012 tentang Pangan 和 Peraturan Pemerintah No. 86 Tahun 2019 tentang Keamanan Pangan. A Certificate of Analysis from a laboratory that falls outside these accepted routes, even if that laboratory holds accreditation for other test types, is treated by BPOM the same way as no Certificate of Analysis at all.

The Five Parameter Groups a Food Testing Laboratory Must Cover

BPOM’s review of a food registration dossier tests five parameter groups. Which of these apply, and at what threshold, depends on the food category assigned under Peraturan BPOM No. 34 Tahun 2019 tentang Kategori Pangan.

1. Microbial Contamination

Tested against Peraturan BPOM No. 13 Tahun 2019 tentang Batas Maksimal Cemaran Mikroba dalam Pangan Olahan, which sets maximum limits for parameters such as total plate count, coliform, Escherichia coli, Salmonella, and Staphylococcus aureus. Limits differ by food category and by whether the product is ready-to-eat.

2. Heavy Metal Contamination

Tested against Peraturan BPOM No. 9 Tahun 2022 tentang Persyaratan Cemaran Logam Berat dalam Pangan Olahan, which replaced the earlier Peraturan BPOM No. 5 Tahun 2018 on the same subject. Parameters typically include lead (Pb), cadmium (Cd), mercury (Hg), arsenic (As), and tin (Sn), with maximum limits set per food category.

3. Chemical Contamination

Tested against Peraturan BPOM No. 8 Tahun 2018 tentang Batas Maksimum Cemaran Kimia dalam Pangan Olahan, which covers contaminants such as mycotoxins and pesticide residues that can occur during cultivation, processing, or storage rather than being intentionally added.

4. Food Additives

Tested against Peraturan BPOM No. 11 Tahun 2019 tentang Bahan Tambahan Pangan, which sets which additive categories (preservatives, sweeteners, colorants, antioxidants, and others) are permitted, and at what maximum concentration, for each food category.

5. Nutrition Value Information (Informasi Nilai Gizi)

Tested against Peraturan BPOM No. 22 Tahun 2019 tentang Informasi Nilai Gizi pada Label Pangan Olahan, which requires analysis of energy, total fat, saturated fat, protein, carbohydrate, sugar, and sodium, presented on the label in the Guideline Daily Amount (GDA) format.

Which Parameter Groups Apply to Your Product?

Not every product is tested against all five groups at the same intensity. Food category and risk tier, both determined under Peraturan BPOM No. 34 Tahun 2019 and the risk-based framework applied during registration, shape which tests a laboratory runs and how the dossier is reviewed.

1. Identify the product’s food category under Peraturan BPOM No. 34 Tahun 2019 tentang Kategori Pangan. Category determines which contamination and additive limits apply.
2. Confirm whether the product carries a nutrition or health claim. If it does, Peraturan BPOM No. 1 Tahun 2022 Pasal 27 requires the claim to be backed by accredited or government laboratory analysis specifically.
3. Match the product matrix (dairy, plant-based, beverage, confectionery, and so on) against the laboratory’s published KAN accreditation scope before samples are sent, not after results come back.
4. Route the resulting Certificate of Analysis, along with the product’s full technical file, for SME review before it is attached to the registration submission.

How Laboratory Testing Fits Into the BPOM Registration Process

Laboratory testing is one input into the broader registration process governed by Peraturan BPOM No. 23 Tahun 2023 tentang Registrasi Pangan Olahan, which sets out how product data, risk classification, and supporting documents, including the Certificate of Analysis, are submitted and reviewed. Because the registration system evaluates risk classification and supporting evidence together, a Certificate of Analysis from a laboratory outside the accepted scope can affect how the whole submission is classified, not only the specific parameter in question.

For a full walkthrough of the registration stages this testing feeds into, see our related guide on food and beverage registration rules and processes in Indonesia. 

Because laboratory scope questions are easy to miss until a dossier is already queried, this is one of the areas where working with a specialist regulatory partner protects a submission timeline rather than only speeding up paperwork; our Food and Beverages Registration Services in Indonesia includes matching product matrices against laboratory accreditation scope before sampling, not after.

For imported products, where the laboratory work is often paired with local representation requirements, our License Holder Service in Indonesia coordinates the local point of accountability BPOM requires alongside the laboratory dossier.

Talk to Our Food & Beverage Registration Team Before You Book Lab Testing

Matching a food testing laboratory’s accreditation scope to your product before samples are sent is the step that most often saves weeks on a BPOM submission. Book a consultation with our Food & Beverage Registration service team to review your product category and laboratory options before you schedule testing.