Tuesday June 23 2026 · 3 items this week · Deep dive: Indonesia's Nutri-Level labelling

Indonesia fronts this week. The country is building a front-of-pack nutrition labelling scheme — "Nutri-Level," an A-to-D rating on sugar, salt and fat — and it advanced on two tracks in April: a BPOM draft revision for packaged retail food, and a Health Ministry decree for ready-to-eat product from large operators. The detail that matters for planning is the status: the scheme is not yet mandatory, and the deadline this digest carried in Issue 003 needs correcting (see deep dive). Vietnam's import picture gains a timeline — Decree 15/2018 still governs, but the amended Food Safety Law that ends the Decree 46 suspension is now slated for a September 2026 National Assembly session. Thailand tightens documentation for peanut-kernel imports — narrow, but on the radar for groundnut exporters.

Continuing trackers:

Indonesia's 17 October BPJPH halal deadline is roughly 116 days out and unchanged.

Vietnam's operative food-safety framework remains Decree 15/2018 — Decree 46 stays suspended pending the amended Food Safety Law, now slated for the National Assembly's September 2026 session.

Thailand's consolidated MRL regulation remains operative — verify the current schedule before each shipment.

Indonesia is rolling out a front-of-pack nutrition labelling scheme, "Nutri-Level" — an A-to-D rating on sugar, salt and fat (GGL), modelled on Singapore's Nutri-Grade. It advanced on two fronts in April. BPOM signed a draft revision of its processed-food nutrition labelling regulation on 6 April 2026, covering packaged retail products; this is the instrument behind WTO notification G/TBT/N/IDN/56/Add.2. The Health Ministry then issued decree KMK No. HK.01.07/MENKES/301/2026 on 14 April 2026, covering ready-to-eat food and beverages from large-scale operators.

The split is deliberate. BPOM governs packaged and manufactured retail food; the Health Ministry governs ready-to-eat product made and served by food businesses. For Australian packaged-goods exporters, the BPOM track is the one to watch — and it remains a draft.

For Australian exporters: every packaged line carrying a nutrition panel into Indonesia is in eventual scope — confectionery, dairy, snacks, cereals, non-alcoholic beverages. The cost is label redesign and, for high sugar/salt/fat products, reformulation pressure to hold a favourable rating. But this is a planning problem, not an immediate one: the deep dive below sets out why the mandatory clock has not yet started, and corrects the date this digest carried last issue.

The operative position is unchanged from Issue 003: Decree 46/2026 and Resolution 66.13/2026 are suspended by Resolution 15/2026/NQ-CP, effective 6 April 2026, and Decree 15/2018 remains the governing food-safety framework. What is new is a timeline. The amended Law on Food Safety — the trigger that ends the suspension — is slated for the National Assembly Standing Committee's September 2026 session, with the suspension expected to run into 2027. The Health Ministry is also proposing to amend Decree 46's imported-food state-inspection provisions, Articles 19 to 25, before it ever takes effect.

For Australian exporters: keep filing under Decree 15/2018's self-declaration regime — nothing changes at the border yet. The signal to watch is the September National Assembly sitting: when the amended law moves, the import-inspection regime moves with it, and likely in a form different from the January 2026 Decree 46 text. Health-supplement and functional-food exporters should note that product-declaration approvals remain stalled while Resolution 66.13 is suspended.

Thailand's National Bureau of Agricultural Commodity and Food Standards (ACFS) notified an addendum to its mandatory peanut-kernel aflatoxin standard, TAS 4702, covering the supporting documents required for import. Scope is narrow — peanut kernels, HS 1202 — and the Australia-to-Thailand peanut lane is thin.

For Australian exporters: relevant only to peanut and groundnut exporters shipping kernels to Thailand. If that is you, confirm the specific documentary change against the ACFS notification before your next consignment.

Indonesia is moving toward mandatory front-of-pack nutrition labelling, and it is doing so through two instruments that exporters keep conflating. Getting the split — and the status — right matters, because the obligation is more distant than early coverage, including ours, suggested.

The two instruments

The Health Ministry's decree, KMK No. HK.01.07/MENKES/301/2026, came into force on 14 April 2026 and covers ready-to-eat food and beverages — initially large-scale operators and ready-to-drink sweetened beverages such as boba, teh tarik, palm-sugar coffee and packaged juices. BPOM's draft revision of its processed-food nutrition labelling regulation, signed 6 April 2026, covers packaged and manufactured retail food — the products most Australian exporters ship. Both carry the same Nutri-Level scheme; they sit with different authorities and move on different clocks. For a packaged-goods exporter, BPOM is the authority that matters, and its instrument is still a draft.

What Nutri-Level is

A four-band front-of-pack rating on sugar, salt and fat: Level A (dark green), B (light green), C (yellow), D (red), with A the lowest GGL content and D the highest. Grading runs on self-declaration, but the declaration must be backed by results from a government or accredited laboratory — so lab testing is part of the compliance workflow, not optional. Where it applies, the label must appear across packaging, printed and digital menus, promotional material and delivery-platform listings, not the pack alone.

Mandatory or not — and the correction

This is the part to get right. Under the Health Ministry decree, Nutri-Level is currently voluntary; the decree frames it as something that "may be" applied. It becomes mandatory two years after Indonesia issues the maximum sugar, salt and fat thresholds — and those thresholds have not yet been issued. The two-year clock has not started. The BPOM packaged-food instrument, separately, is still a draft.

Issue 003's tracker carried a "31 December 2026" mandatory date for Nutri-Level. That date does not hold, and we correct it here: there is no fixed mandatory date yet. The trigger is the two-year period that follows the still-unissued SSF thresholds. We will carry the corrected position until those thresholds are set.

Where the cost sits

For products likely to land at the high-GGL end — sugary beverages, confectionery, some dairy and snacks — the live exposure is reformulation pressure and the marketing reset that comes with a C or D band on the front of pack. Label redesign and lab testing are the baseline costs for everyone in scope. None of it is urgent. All of it is foreseeable, and the direction of travel is unambiguous.

What to do now

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Pacific Shelf will track the SSF threshold issuance and the BPOM finalisation, and will reset the mandatory date the moment either lands. Questions about your specific product category — reply directly to this email.

7 Aug 2026 · MALAYSIA · G/TBT/N/MYS/135 — comment period closes on proposed function/health-claim amendments to the Food Regulations 1985. · MEDIUM

17 Oct 2026 · INDONESIA · BPJPH halal certification mandatory for all imported food and beverage. No certificate = no customs clearance. (~116 days out.) · HIGH

17 Oct 2026 · INDONESIA · Transition from the old MUI halal logo to the new national BPJPH logo — mandatory by this date. · MEDIUM

Watch · INDONESIA · Nutri-Level front-of-pack labelling — currently voluntary; becomes mandatory two years after the maximum SSF thresholds are issued (not yet issued). Corrects the 31 Dec 2026 date carried in Issue 003. · MEDIUM

Confirm status · AUSTRALIA → INDONESIA / MALAYSIA · Edible-meat and halal certificate changeover to NEXDOC (reported 15 Jun 2026 per SFA circular + G/SPS/N/AUS/630/Add.2). Confirm go-live directly with DAFF. · HIGH

Ongoing · THAILAND · Consolidated MRL regulation operative since 22 July 2025. Verify MRL compliance against the current schedule before each shipment. · MEDIUM

Watch · VIETNAM · Decree 15/2018 operative; Decree 46 suspended pending the amended Food Safety Law, now slated for the National Assembly's September 2026 session. MOH proposing to amend Decree 46 Articles 19–25 before it lands. · MEDIUM

Verify · THAILAND · Peanut-kernel aflatoxin import-documentation update (G/SPS/N/THA/216/Add.6) — confirm the documentary change and effective date. · LOW

— Jasper Blackwell-Doran

Melbourne, Australia