Indonesia to restrict PFAS and Bisphenol in food packaging

Jakarta, October 2025 — Indonesia’s National Agency of Drug and Food Control (BPOM) has completed public consultation on a revised regulation that sets out new limits for chemicals permitted or prohibited in food packaging materials. Once adopted, the regulation will replace BPOM Regulation No. 20 of 2019, which has been in force since 2020.

The draft regulation consolidates and restructures existing positive, restrictive, and prohibited substance lists across a wide range of packaging materials, including ceramic, glass, metal, paper and paperboard, and plastics.

Under the new framework:

  • Appendix III introduces two sublists—List III.A, identifying substances with specific migration limits, and List III.B, substances permitted for use without migration limits.

  • Appendix IV contains substances prohibited for use in any food packaging or food-contact materials.

Among the substantive changes, BPOM proposes limits for Bisphenol A (BPA) and Bisphenol S (BPS) in polycarbonate and metal food packaging materials, capped at 0.05 mg/kg. For BPA, the restriction applies specifically to feeding bottles made of polycarbonate intended for children under three years old.

The draft also marks a significant step toward curbing the use of per- and polyfluoroalkyl substances (PFAS) in Indonesia. Forty-six previously permitted PFAS references in 2019 regulations have been removed. Two PFAS — ammonium bis(N-ethyl-2-perfluorooctanesulfonamidoethyl) phosphate and ammonium bis(2-(N-ethyl-2-perfluorohexanesulfonamide)ethyl) phosphate — have been explicitly added to the prohibited list. These compounds are typically used in paper and paperboard coatings for grease resistance.

The removal of permitted PFAS entries and the addition of these new prohibitions underscore BPOM’s tightening stance on PFAS use in food-contact materials. Any substance not appearing on the positive, restrictive, or prohibited lists will require prior BPOM approval before being used in food packaging.

Implications for industry

Companies are advised to continue to monitor the development of this regulation. Companies should also obtain information from their supply chains on whether their food packaging contains PFAS. Suppliers whose products (e.g. food packaging materials or food packaging) contain the two potentially prohibited chemicals or other PFAS should consider chemical alternatives and/or product redesign to prepare for the potential future ban.

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