This article is for quality assurance and regulatory affairs staff at food manufacturers selling into Indonesia, whether producing locally or importing, and for export managers at Indonesian producers supplying Codex-aligned markets. After reading it, you will understand what changed at Codex in July 2026, how precautionary allergen labelling Indonesia currently works under BPOM rules, and where the two frameworks diverge.
The Statement That Means Nothing Because It Is Used Everywhere
Walk a supermarket aisle in Jakarta and a large share of packaged foods carry a statement saying the product may contain peanuts, or tree nuts, or milk. Some of those products were made where the named allergen is handled on a different line, in a different room, on a different day. Others were made where the chance of cross-contact is real and material. The label does not tell a shopper which is which.
In the label reviews we run for food and beverage clients, the most common finding is that a precautionary statement was added once, at the packaging design stage, copied from a previous SKU or a competitor’s label, and never revisited even after the production line that supposedly justified it was decommissioned. That is not something you learn by reading the regulation. You learn it by opening enough label files.
The consequence for consumers is a documented paradox. Because “may contain” appears on so many products, a shopper managing a genuine allergy either avoids everything carrying it, narrowing her diet more than necessary, or learns the warning is usually meaningless and starts ignoring it. The second outcome is the dangerous one, and over-labelling causes it, not under-labelling.
The Short Answer: What Codex Changed and What It Means for Indonesia
Codex adopted guidelines on 7 July 2026 requiring manufacturers to justify a “may contain” statement with a risk assessment against a quantitative action level, rather than applying it at their own discretion. Indonesia’s current rule under Peraturan BPOM No. 31 Tahun 2018 works differently: it is triggered by the fact of shared production facilities, not by a measured allergen level. Codex texts are voluntary, so this does not change Indonesian law today, but it resets the international reference point manufacturers will eventually be measured against.
Allergen Declaration vs Precautionary Allergen Labelling: A Distinction the Wording Obscures
The two statements look similar on a pack but mean different things, and the difference drives everything else in this article.
| Allergen declaration | Precautionary allergen labelling (PAL) | |
| Typical wording | “Contains [allergen]” | “May contain [allergen]” |
| What it means | The allergen is a deliberate part of the recipe, added as an ingredient, food additive, or processing aid | The allergen is not in the formulation but may be present through unintended cross-contact |
| Basis | The recipe itself | The production environment and the residual risk it leaves behind |
| Status in most jurisdictions | Mandatory wherever the allergen is present | Historically discretionary; now subject to risk-based criteria under the new Codex guidelines |
Cross-contact, the mechanism PAL exists to communicate, arises from shared facilities or equipment, from storage and transport, from carry-over during handling, or from residues left after cleaning. It is a property of how a food is made, not of what is in it.
What Codex Adopted, and When
The Codex Alimentarius Commission adopted the new precautionary allergen labelling guidelines on 7 July 2026, during its 49th Session held in Geneva from 6 to 10 July 2026, as reported by the Food and Agriculture Organization of the United Nations. The text sits as an annex to the General Standard for the Labelling of Prepackaged Foods, CXS 1-1985, the instrument much of the world’s food labelling law is built on.
The guidance was finalised at the 49th Session of the Codex Committee on Food Labelling in Ottawa in May 2026, following FAO and WHO expert consultations on qualitative risk assessment and reference dose levels. It complements the existing Code of Practice on Food Allergen Management for Food Business Operators, CXC 80-2020, which governs the underlying management measures rather than the label statement itself, according to the FAO’s summary of standards adopted at CAC49.
The Three-Step Approach Codex Now Requires
The framework can be stated in three steps, and the order is the entire point of the reform.
- Control the allergen first. Manufacturers must prevent and control unintended allergen presence through segregation, scheduling, validated cleaning, and supply chain controls, before any labelling decision is made. PAL is not a substitute for these controls.
- Assess the residual risk. Where controls are in place and some possibility of cross-contact remains, that residual risk must be assessed rather than assumed.
- Apply PAL only where warranted. A precautionary statement is used only where, after mitigation, the unintended allergen level is demonstrated to be above the applicable action level. Below that level, PAL should not be used at all.
That last point is the one most manufacturers find counterintuitive. The guidelines do not simply allow omitting the statement when risk is low. They indicate it should be omitted, because an unwarranted “may contain” statement is treated as a labelling defect, not a harmless act of caution, given the dilution effect described above.
Reference Doses and Action Levels
A risk assessment needs a quantitative anchor or it becomes a matter of opinion. Codex supplies reference doses, which serve as the basis for action levels, the thresholds a measured allergen concentration is compared against. Above the action level, PAL may be used; at or below it, PAL should not appear on the label, per the FAO/WHO CAC49 outcomes summary.
Among the outcomes at CAC49 is the first Codex-level reference dose for cereals containing gluten, reported at 4 mg and treated separately from wheat-allergy thresholds, reflecting that coeliac disease and wheat allergy are distinct conditions with different dose-response profiles. (SME to confirm this figure against the adopted guideline text before publication.)
The operational consequence is that a defensible PAL decision now requires data most manufacturers do not currently generate: how much allergen actually remains after controls, expressed as a measured concentration. That is an analytical and process-data question, and for many producers it will be the hardest part of any future transition.
Precautionary Allergen Labelling Indonesia: Where PerBPOM 31/2018 Stands Today
Allergen labelling for processed food in Indonesia is governed by Peraturan Badan Pengawas Obat dan Makanan Nomor 31 Tahun 2018 tentang Label Pangan Olahan, with the allergen provisions at Article 49, published on the BPOM JDIH regulatory database. An allergen is defined there as a food ingredient or compound that causes allergy or intolerance, and the regulation obliges producers to declare allergen-containing ingredients on the label.
The trigger that matters here is the one for cross-contact declarations. Under BPOM’s current labelling framework, a declaration of possible allergen presence is required where a product is made using the same production facility as a processed food containing an allergen, regardless of measured residual levels.
That is a facility-based trigger. It asks a factual question, is this product made in the same facility as an allergen-containing one, and requires the declaration if the answer is yes. It does not ask how much allergen remains after controls, and it makes no comparison against any threshold. Confirming how this applies to a specific SKU and production line is exactly the kind of question best worked through with a 食品饮料注册 specialist rather than inferred from the regulation text alone.
Codex has now adopted a framework that asks the second question, the quantitative one, that PerBPOM 31/2018 does not ask. The two approaches are not in conflict; a manufacturer following the Indonesian rule is doing exactly what Indonesian law requires. But the underlying logic is structurally different, and that difference is the substance of this development for anyone labelling food for the Indonesian market.
What Changes Now, and What Doesn’t
It is worth being precise here, since the temptation to overstate a Codex adoption is considerable.
Codex texts are voluntary. They are not Indonesian law. Nothing in the July 2026 adoption changes any requirement under Peraturan BPOM No. 31 Tahun 2018, and a manufacturer’s obligations remain exactly what they were before the adoption.
What Codex texts do instead is slower and structural. They function as internationally recognised benchmarks that support national legislation and facilitate trade under the WTO agreements on sanitary and phytosanitary measures and technical barriers to trade. Provisions of the General Standard for the Labelling of Prepackaged Foods have historically entered national law across various jurisdictions years after Codex adoption, and Indonesia participates in the Codex process as a member state.
The reasonable inference is not that Indonesian producers must act immediately. It is that a risk-based approach to PAL is now the international reference point, that export markets will move toward it on their own timelines, and that the analytical and process capability the framework requires takes longer to build than a label change takes to implement, particularly for exporters coordinating with an export/import compliance partner across multiple destination markets.
A Practical Checklist for QA and Regulatory Teams
Use this as a starting point for an internal review, not as a substitute for a documented risk assessment.
- Continue complying with Peraturan BPOM No. 31 Tahun 2018 for every product on the Indonesian market. Nothing here displaces that obligation.
- List every SKU currently carrying a precautionary allergen statement and record, per SKU, the basis it was originally added on.
- Note whether that basis (a specific shared line, a specific shared room) still reflects current production, or whether the line configuration has since changed.
- Establish whether in-house or contract lab capability exists to quantify residual allergen after cleaning and controls.
- For exported SKUs, check the PAL position separately in each destination market, since Codex adoption does not mean simultaneous national adoption.
- Treat any statement that could not be justified on a risk assessment as a commercial question worth reviewing, not only a compliance one.
Related reading on managing shared-facility allergen and cross-contamination risk for the Indonesian market: our processed meat import compliance guide covers a comparable facility-based compliance trigger from the import side.
Limitations of This Article
This article describes the Codex position as adopted on 7 July 2026 and the Indonesian position as at the date of publication. It does not reproduce the adopted guideline text, which should be consulted directly, and it states only the gluten reference dose figure reported by FAO, since other allergen-specific values should be taken from the source text rather than a secondary summary. The description of BPOM’s cross-contact trigger reflects Peraturan BPOM No. 31 Tahun 2018 and its current amendments; readers should confirm the operative position for their own product before relying on it. Nothing in this article constitutes a risk assessment for any specific product.
Get Your Label Reviewed Before It Becomes a Problem
Precautionary allergen labelling is one of the most commonly mislabelled elements on processed food packaging sold in Indonesia, because it is added once at the design stage and rarely reviewed again. Talk to our Food & Beverage Registration team about a label review to see how your current SKUs measure up against Peraturan BPOM No. 31 Tahun 2018.
