Pacific Shelf — Issue 010

EXDOC legacy certificate window closed 5.00pm AEST Friday 31 July 2026. NEXDOC is now the sole system for Australian meat export documentation.

The Department of Agriculture, Fisheries and Forestry moved meat and meat product export documentation from EXDOC to NEXDOC on Monday 6 July 2026. A tail period followed: Requests for Permit for destinations other than China that had already been lodged by 5.00pm AEST Sunday 5 July — at initial, final, inspected, or health-certificate-ready status — had until 5.00pm AEST Friday 31 July to be completed and their certificates printed. That deadline has now passed. RFPs for China closed earlier, on 5 July.

Exporter Declaration Numbers obtained through the EXDOC Single Electronic Window could not be carried across to NEXDOC.

For Australian exporters: if you hold consignments where the certificate was never printed before the Friday cut-off, the RFP is stranded and the request must be re-lodged in NEXDOC. Registration for NEXDOC is a prerequisite for lodging at all — unregistered exporters cannot export meat. Certificate appearance has changed: NEXDOC certificates print on plain white A4 with a QR code security feature, where EXDOC certificates printed on blue security paper. Both formats remain in circulation for consignments already in transit, so importers in all six markets should be told not to reject either.

Correction: Issue 001 reported the NEXDOC transition for edible meat as taking effect 15 June 2026, following the Singapore Food Agency circular of 26 May. That date was subsequently pushed to 6 July. Issue 003 built its lead on the 15 June date. We should have carried the change when it happened and did not. The operative date for edible meat and meat products is 6 July 2026.

Source: DAFF export system notices (primary). Corroborated by UK Official Veterinary Surgeon note, 26 June 2026, which records the move from 15 June to 6 July. Earlier: SFA circular, Food Trade Department, 26 May 2026 — agriculture.gov.au/biosecurity-trade/export/systems/notices

G/TBT/N/IDN/190 — BPJPH draft regulation on conformity assurance for foreign halal products entering Indonesia. Comment deadline 28 September 2026.

Indonesia has notified the WTO TBT Committee of a draft Halal Product Assurance Organizing Body regulation establishing the framework for verifying compliance of foreign halal products at the point of entry. The draft provides for administrative and physical checks on imported goods carrying foreign halal certification. It applies across goods and services within the halal assurance scope.

This is the latest instrument in a sustained BPJPH notification sequence: HS-code scoping (IDN/160/Add.2), foreign halal certificate registration under Head of BPJPH Decree No. 221/2025 (IDN/175/Add.2), storage, packaging and distribution service requirements (IDN/183), and the cosmetics assurance system guidelines (IDN/187). Enforcement infrastructure is already live — BPJPH Regulation No. 2 of 2026 on administrative sanctions came into force on 5 June 2026, ahead of the deadline it enforces.

For Australian exporters: the practical significance is timing, not content. The comment window on the border-verification mechanism closes 28 September. Mandatory certification for imported food and beverage begins 17 October. That is nineteen days between the technical rules for how foreign certificates will be checked being finalised and the date they start being checked. If your Indonesian importer is relying on a foreign halal certificate registered through SIHALAL rather than a BPJPH-issued certificate, the verification treatment of that certificate is still being written. Confirm with your importer now which route your SKUs are on. See deep dive.

Source: WTO TBT notification G/TBT/N/IDN/190 (per compiled ePing catalogue — full notification text not yet sighted; VERIFY notification date and scope directly on ePing before publication). Series context: G/TBT/N/IDN/160/Add.2, /175/Add.2, /183, /187. Primary: bpjph.halal.go.id

P.U. (A) 48/2026 Food (Amendment) Regulations 2026 came into operation 1 August 2026 — new standards for natural mineral water, packaged drinking water, and ceramic food-contact ware.

Gazetted 30 January 2026 with a six-month lead time, the amendment took effect on Saturday 1 August. It amends regulations 28, 360A and 394 of the Food Regulations 1985 and revises the Thirteenth and Twenty-Sixth Schedules.

Three areas change. For natural mineral water, a minimum total dissolved solids level of 50 mg/l is established, and label particulars are expanded: the product must be described as natural mineral water (or carbonated equivalent), and the label must carry the TDS figure in mg/l, mineral content, pH value, and the location and nature of the source. A fluoride warning is required where fluoride exceeds 1.0 mg/l. Chemical standards in the Twenty-Sixth Schedule are updated, including for arsenic, barium and fluoride. For packaged drinking water, certain processing water is exempted from chlorine residue limits. For ceramic ware, a definition of "cooking appliance" is introduced covering ceramic ware intended for conventional or microwave heating, and Table I of the Thirteenth Schedule is replaced with new maximum permitted lead and cadmium release proportions differentiated across large hollow-ware, small hollow-ware, cooking ware and flat ware.

For Australian exporters: this bites hardest on Australian bottled and premium mineral water going into Malaysia. The label particulars are prescriptive and several — source location and nature, pH, TDS, mineral content — are details many Australian labels carry in marketing copy rather than in the regulated form. Product on the water is not grandfathered by the gazette date; the operative date is 1 August. If you export mineral water to Malaysia, get your Malaysian importer to confirm current stock label compliance this week. Exporters of ceramic tableware and cookware into the Malaysian food-contact channel should re-check migration test certificates against the replacement Table I.

Source: P.U. (A) 48/2026 Food (Amendment) Regulations 2026, gazetted 30 January 2026, in operation 1 August 2026 (via ChemLinked regulatory database summary; VERIFY full gazette text at Attorney General's Chambers before advising a client). Primary: Food Regulations 1985 [P.U. (A) 437/1985] — fsq.moh.gov.my

Catch-up: Notification 450 label transition expired 19 July 2026. Old-format prepackaged labels are now non-compliant on the Thai market regardless of production date.

Ministry of Public Health Notification No. 450 B.E. 2567, which took effect on 19 July 2024, replaced Notification No. 367 and its three amending notifications as Thailand's prepackaged food labelling rule. It gave the market a two-year sell-through window. That window closed on 19 July 2026.

The critical mechanic is what the two years were measured from. The clock ran from the notification's effective date, not from any individual product's manufacture date. From 19 July 2026, any prepackaged food manufactured in or imported into Thailand must carry a Notification-450-compliant label; stock still bearing a Notification-367-format label cannot lawfully be sold, however long ago it was produced.

Substantively, Notification 450 adds shellfish (molluscs) and squid to the mandatory declarable allergen list alongside crustacea, removes the requirement to specify colouring additives as natural or synthetic, drops the horizontal-continuity rule for food names, and realigns the "best before" definition with Codex.

For Australian exporters: two exposures. First, any Australian product sitting in a Thai importer's warehouse or on a Thai shelf with an old-format Thai label is now illegal stock and the Thai party carries the risk — expect requests to relabel or take return. Second, the molluscs and squid allergen addition catches Australian seafood, seafood-derived sauces and stocks, snack seasonings, and any product using shellfish-derived ingredients. Audit your Thai-market allergen statements against the Notification 450 list rather than against your Australian FSANZ label.

Source: MOPH Notification No. 450 B.E. 2567 (2024), effective 19 July 2024, transition expired 19 July 2026. Primary: Thai FDA — fda.moph.go.th

Two Thai FDA consultations: enzyme positive list closed 31 July; flavouring agents overhaul still open.

Thai FDA opened consultation on 1 July 2026 on a second revision to Annex 1 of Ministry of Public Health Notification No. 443 B.E. 2566 (2023), Thailand's positive list of enzymes permitted in food production. That consultation closed on 31 July 2026 — inside this issue's window, and now shut.

Separately, Thai FDA has a draft ministerial notification out for consultation comprehensively updating the framework for flavouring agents and food flavourings. Sources conflict on the closing date: one places it at 24 July 2026, another at 15 September 2026. Do not rely on either figure without checking the Thai FDA consultation page directly.

For Australian exporters: the enzyme list matters to Australian dairy, brewing, baking and fermentation-derived ingredient suppliers — if an enzyme you rely on is not on Annex 1 as revised, that is a market access problem, and the comment window has now closed. The flavourings draft is the one still worth a submission if you supply flavour systems or flavoured product into Thailand.

Source: Thai FDA public consultations, June–July 2026 (via secondary regulatory trackers; conflicting closing dates for the flavourings draft — VERIFY at fda.moph.go.th before publication). Primary: MOPH Notification No. 443 B.E. 2566 (2023), Annex 1

Nutri-Level tracker update — front-of-pack labelling is now live for ready-to-eat product under a Ministry of Health decree, ahead of the BPOM processed-food regulation this newsletter has been tracking.

Issue 001 tracked BPOM Nutri-Level A–D front-of-pack labelling as a December 2026 deadline for large-scale manufacturers. That framing needs updating, and the instrument needs disambiguating.

Two separate tracks are running. On 6 April 2026, the BPOM Head signed the revised BPOM regulation on nutritional value information for processed food labels, which incorporates Nutri-Level into front-of-pack nutrition labelling. Eight days later, on 14 April 2026, the Ministry of Health issued Decree No. HK.01.07/MENKES/301/2026 on the affixation of nutritional labels and health information to ready-to-eat processed food products, in force from that date, implementing the Health Law and Minister of Health Regulation No. 3 of 2026. The MoH decree targets ready-to-eat product from large-scale operators. The BPOM regulation governs packaged processed food.

The grading is unchanged from the 2024 draft — A (dark green) through D (red), scored on sugar, salt and fat. The threshold values in the issued instrument differ from the 2024 BPOM draft.

For Australian exporters: if you have been working to the 2024 draft thresholds, requantify. Note also that Level A carries a formulation restriction — reported as excluding natural and artificial sweetening additives, whether added directly or as a carrier — so a Level A claim is not achievable by sugar reduction via sweetener substitution alone.

Source: Ministry of Health Decree No. HK.01.07/MENKES/301/2026, in force 14 April 2026 (via Tilleke & Gibbins and Indonesian trade press). BPOM revised labelling regulation signed 6 April 2026 — regulation number not confirmed; one secondary tracker cites BPOM Regulation No. 10/2026 finalised 9 June 2026. VERIFY the BPOM instrument number and its compliance dates before publication. Primary: pom.go.id / kemkes.go.id

Standing tracker, expanded: MRL consolidation under Ministerial Notification 460 (2025) — the October 2025 implementing circular is the operative guidance.

Covered in Issue 001 as operative since 22 July 2025. Adding detail readers have asked about. Notification No. 460 (2025) consolidated four earlier pesticide MRL notifications into a single instrument. It introduces ASEAN MRLs as a fallback reference where neither Thailand nor Codex has set a limit for a given pesticide-commodity pair, aligns commodity classification to TAS 9045-1-2568, and applies zero tolerance to chlorpyrifos and paraquat. A Thai FDA circular of 7 October 2025 supplies worked examples for selecting the applicable limit, handling processed foods, and grouping commodities — including how the ASEAN fallback and processing-factor calculations operate.

For Australian exporters: the October 2025 circular, not the notification alone, is what your compliance team should be working from. The chlorpyrifos and paraquat zero tolerance is the practical trap for Australian horticulture.

Source: Thailand FDA Ministerial Notification No. 460 (2025), effective 22 July 2025; TFDA circular, 7 October 2025. Primary: fda.moph.go.th

Analysis, not regulation. Sourced from USDA FAS GAIN reports released 30 July 2026 and written from a US export perspective — read for market signal, not compliance obligation.

G/TBT/N/IDN/190 closes for comment on 28 September. Mandatory certification starts 17 October.

Pacific Shelf has carried the Indonesian halal countdown in every issue since Issue 001. The arithmetic then was eighteen weeks. It is now eleven.

What has changed since is not the deadline — BPJPH has been consistent that 17 October 2026 will not move again — but the density of the instruments arriving underneath it. In the past twelve months BPJPH has notified the WTO of an HS-code list defining what is in scope, a revised procedure for registering foreign halal certificates, guidelines for storage, packaging and distribution service providers, a cosmetics assurance system, and now a conformity assurance framework for foreign halal products at the border. It has separately brought a sanctions regulation into force.

That last point deserves attention. BPJPH Regulation No. 2 of 2026 on administrative sanctions for halal assurance violations took effect on 5 June 2026 — more than four months before the obligation it enforces. The reported sanctions ladder escalates through written warning, fine, certificate revocation, product recall, premises closure, and public disclosure, and reaches auditors and certification bodies as well as business operators. Indonesia built the enforcement machinery first.

The two routes, and why route matters more than ever

An Australian product can reach Indonesian shelves halal-compliant by one of two paths, and they are not equivalent.

Route one — BPJPH certification. Your Indonesian importer applies through the SIHALAL portal at ptsp.halal.go.id. A valid BPOM ML registration number is a prerequisite; without it the halal application cannot proceed. BPJPH routes the file to an accredited Halal Inspection Agency (LPH), which for meat, dairy and complex processed products conducts a physical facility audit — for overseas facilities, by a BPJPH-approved overseas auditor. The Indonesian Ulema Council then issues the fatwa, and BPJPH issues the certificate, valid four years against a specific formulation and process.

Route two — foreign certificate registration. Where your product carries certification from a foreign halal body inside BPJPH's mutual recognition network, that certificate is registered with BPJPH through SIHALAL and issued a registration number. The governing procedure is Head of BPJPH Decree No. 221 of 2025, effective 15 December 2025, which replaced Decree No. 90 of 2023.

Route two is faster and is where most Australian exporters with existing halal certification will land. It is also the route G/TBT/N/IDN/190 is about. The draft sets out how foreign-certified goods will be checked administratively and physically on arrival. Until that instrument is settled, the border treatment of a registered foreign certificate is not fully specified — and the comment window on it closes nineteen days before enforcement begins.

Recognition of the certifying body, it is worth noting, is not the same as the product satisfying every Indonesian-specific requirement. Additional documentation or testing can still be required, and the Indonesian importer of record carries the legal responsibility.

What to do now

Pacific Shelf will carry the BPJPH tracker in every issue until 17 October. Questions about your specific product category or supply chain — reply directly to this email.

— Jasper Blackwell-Doran Melbourne, Australia

Pacific Shelf publishes every Tuesday. Reply directly to this email with questions, corrections, or feedback. If a colleague needs this, forward it.

This digest is for informational purposes only and does not constitute legal, regulatory, trade, or compliance advice. Regulatory information should be verified against current primary sources before any action is taken.

[email protected] · pacificshelf.net

© 2026 Jasper Blackwell-Doran / Pacific ShelfREGULATORY ITEMS