Unpacking Critical Points of Ingredients and How to Trace Them

In halal certification, critical points of ingredients are the part that most often demands attention. This is because the halal status of an ingredient cannot always be judged from its name. Tracing is needed down to the source and the production process.

What Is Meant by Critical Points

Critical points are conditions or ingredients that potentially contain elements that are not halal or whose origin is unclear. This potential arises because ingredients can come from animal, microbial, or certain chemical processes. Some ingredients can also come from different sources, so their status depends on the supplier.

Halal product assurance regulations in Indonesia place ingredient inspection as an important part. Law Number 33 of 2014 on Halal Product Assurance regulates the obligation of halal certification and the role of the Halal Inspection Agency (LPH). Meanwhile, Government Regulation Number 42 of 2024 regulates the procedures for establishing and the scope of LPH activities, as well as the appointment of Halal Auditors. The determination of product halalness itself is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee, and certificates are only issued by BPJPH.

Examples of Ingredients with Status Depending on Source

Some ingredients have a status that is not automatically halal or haram. Their status depends on the origin of the ingredient. Here are several examples that are often encountered.

1. Gelatin Capsule Shells

Gelatin for the shells of medicine and supplement capsules is a critical point that is often overlooked by consumers. This ingredient can come from animals. The alternative is vegetable capsules (vegetable capsule/HPMC — hydroxypropyl methylcellulose) or halal-certified bovine gelatin capsules. Their use covers prescription and over-the-counter medicines, vitamin supplements, and fish oil in softgel form.

2. Microbial Enzymes for Food Processing

Enzyme categories such as amylase, protease, and lipase can come from microbial, plant, or animal sources. Therefore, their status depends on the source. The alternative is halal-certified microbial enzymes from fermentation, with source documents from the supplier. Enzymes are used in glucose/fructose syrup, meat tenderizers, juice and cheese production, and even dishwashing detergent for indirect contact.

3. Glycerin or Glycerol (E422)

Glycerin is a versatile humectant that can come from palm oil (halal) or pork fat (haram). The alternative is halal-certified vegetable glycerin, generally from palm or coconut oil. This ingredient is widely used in toothpaste, syrup medicine, cosmetics, candy, moist cakes, and food preservatives.

4. Albumin (Egg White)

Albumin comes from egg white. It is generally halal, but still needs to be verified as free from non-halal mixtures. No alternative is needed; ensure the label explicitly states "egg albumin/albumen." Albumin is used in bakery products such as meringue and macaron, processed meat products, and certain pharmaceutical products.

How to Trace Critical Points of Ingredients

Tracing critical points is not merely reading the ingredient names on the label. A systematic approach down to supplier documents is needed. Here are the steps that can be carried out.

1. Identify potentially critical ingredients. Focus on ingredients whose status depends on the source, such as gelatin, enzymes, and glycerin. Ingredients that are generally halal such as albumin are still checked to ensure there is no mixture.
2. Trace the origin of the ingredient. Know whether the ingredient comes from animal, plant, or microbial sources. For animal ingredients, ensure the type of animal and the method of slaughter comply with the requirements.
3. Request supporting documents from the supplier. Halal certificates for ingredients, product specifications, and production process flows serve as initial evidence. These documents show that the supplier has a halal assurance system.
4. Verify consistency. Ensure the ingredients received match the documents provided. Changes in supplier or formulation must be accompanied by updated documents.
5. Record in the ingredient registry. Every critical ingredient along with its documents should be recorded neatly. This registry facilitates internal audits and inspections by LPH.

Good tracing does not stop at a single purchase. It becomes part of a halal product assurance system that runs continuously. That way, if there is a change in the source of ingredients, business actors can immediately adjust their documents and processes.

The Role of Regulations and Institutions

The obligation of halal certification is regulated in Law 33/2014 and further elaborated in PP 42/2024. The groups of products that must be halal-certified are stipulated through Minister of Religious Affairs Decree Number 748 of 2021, which was later amended by KMA 944/2024. Meanwhile, the Head of BPJPH Decree Number 243 of 2025 sets the BPJPH service standards, including requirements, timeframes, and service tariffs.

In practice, business actors need to understand that the determination of halalness is not done by themselves. The determination of halalness is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee. Halal certificates are only issued by BPJPH. Therefore, tracing critical points of ingredients is an effort to prepare evidence and systems, not to unilaterally determine halal status.

By tracing critical points with discipline, business actors can reduce the risk of non-compliant ingredients. This step also facilitates the certification process and maintains product consistency in the market.