Indonesia Tightens Fish and Seafood Safety and Certification Rules

Indonesia has strengthened requirements for fish and seafood products through updated quality assurance and microbial contamination standards

Compliance Answer: Strengthened Quality Assurance and Microbial Contamination Standards for Fish and Seafood Products in Indonesia

Indonesia has recently enhanced its regulatory framework for fish and seafood products through updated quality assurance and microbial contamination standards. These changes are primarily governed by the Minister of Marine Affairs and Fisheries (MMAF) and the Food and Drug Agency (FDA RI), with enforcement authority vested in the Marine and Fisheries Quality Assurance Agency (MFQAA). The regulations establish comprehensive certification schemes, microbial contamination limits, and standardized health certificates to ensure compliance with both domestic and international food safety standards.

Regulation Analysis

1. Quality Assurance and Certification Requirements

Indonesia has introduced a nine-tier certification scheme covering the entire fishery supply chain, from upstream production to downstream distribution. These schemes are mandatory for all fish and seafood products intended for export and domestic distribution^{1, 2, 3}.

The nine certification schemes are:

1. Good Handling Practices (GHP) (including onboard fishing vessels)^{1, 2}
2. Good Hatchery Practices²
3. Good Aquaculture Practices²
4. Good Fish-Feed Production Practices²
5. Good Fish-Drugs Production Practices²
6. Good Fish-Drugs Distribution Practices²
7. Good Manufacturing Practices (GMP)²
8. Hazard Analysis Critical Control Point (HACCP) (including onboard fishing vessels)^{1, 2}
9. Good Fish/Fishery Product Distribution Practices^{1, 2}

2. Microbial Contamination Standards

Indonesia has set maximum limits for microbial contamination in processed fish and seafood products under FDA RI Regulation No. 13/2019, replacing the previous FDA RI Regulation No. 16/2019⁵. These standards apply to all processed food produced, imported, or distributed in Indonesia, except for commercially sterile food⁵.

Key Provisions of FDA RI Regulation No. 13/2019⁵:

• Microbiological criteria include:
  • Type of processed food
  • Type of microbes/microbial test parameters (e.g., Salmonella, E. coli, Listeria monocytogenes)
  • Microbial limits (specific thresholds for each microbe, detailed in the Annex)
  • Sampling plan
  • Analysis method
• Compliance is mandatory for all processed fish and seafood products⁵.
• Monitoring is required before and during distribution⁵.

Note: The Annex of FDA RI Regulation No. 13/2019 contains the specific microbial limits, which are not detailed in the provided sources. Stakeholders must refer to the full regulation for exact thresholds.

3. Health Certificates (HC) for Export

Under MMAF Regulation No. 33/2024, all fish and seafood products exported from Indonesia must be accompanied by a Health Certificate (HC) of Quality and Safety, issued by MFQAA¹. The certificate:

• Uses a standardized format to ensure recognition by importing countries’ authorities¹.
• Aims to prevent non-technical delays in trade, such as border rejections or product damage¹.
• Is aligned with international standards, including Codex Alimentarius Commission (CAC) guidelines⁴.

4. Authority and Enforcement

• MFQAA is the sole competent authority for:
  • Inspection and certification of fish and seafood products^{2, 4}.
  • Official control of quality and safety from upstream (production) to downstream (distribution)².
  • Issuance of Quality and Safety Assurance Certificates².
• FDA RI is responsible for enforcing microbial contamination limits in processed food, including fish and seafood products⁵.

Summary Answer

Indonesia has strengthened its regulatory framework for fish and seafood products through MMAF Regulation No. 33/2024 and MMAF Regulation No. 16/2024, which establish nine mandatory certification schemes (e.g., HACCP, GHP, GMP) and require Health Certificates (HC) of Quality and Safety for exports^{1, 2}. Microbial contamination limits are governed by FDA RI Regulation No. 13/2019, which sets maximum thresholds for pathogens in processed food⁵. The Marine and Fisheries Quality Assurance Agency (MFQAA) is the competent authority for enforcement, ensuring compliance with both domestic and international standards^{2, 4}. These measures align with Codex Alimentarius Commission (CAC) guidelines and aim to prevent trade disruptions while safeguarding public health^{1, 4}. Stakeholders must adhere to the certification schemes and microbial limits to avoid penalties or export rejections.

Sources

1. ↩ Regulations of The Minister of Marine Affairs and Fisheries Number 33 of 2024 Concerning The Release of Fishery Products From The Territory of The Republic of Indonesia _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN25/IDN178.DOCX
2. ↩ Regulation of the Minister of Marine Affairs and Fisheries (MMAF) of the Republic of Indonesia No. 16 Year 2024 concerning Authority of Guidance and to Control in the Framework of Issuing Quality and Safety Assurance Certificates of fishery products issue in Indonesia _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/SPS/NIDN153.DOCX
3. ↩ Regulation of FDA RI No. 8 Year 2018 on Maximum Limit of Microbial Contamination _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/SPS/NIDN137C1.DOCX
4. ↩ Government Regulation No. 38 Year 2023 concerning the organizational structure, nomenclature, duty and function of the Marine and Fisheries Quality Assurance Agency of the Ministry of Marine Affairs and Fisheries as the implementation of Law No. 39 Year 2008 concerning State Ministries of the Republic of Indonesia _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/SPS/NIDN147.DOCX
5. ↩ Regulation of FDA RI No. 13 Year 2019 on Maximum Limit of Microbial Contamination _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/SPS/NIDN138C1.DOCX