Unpacking Critical Points of Ingredients and How to Trace Them

The halal status of a product is not determined by a single ingredient alone. However, some ingredients have a status that depends on their source and process. Such ingredients are called critical points. This article unpacks four common examples of ingredient critical points and how to trace them.

What Makes an Ingredient a Critical Point

An ingredient is called a critical point when its halal status cannot be determined from its name or form alone. Chemicals with the same name can come from different sources. Glycerin, for example, can come from palm oil or pork fat. Without information on its origin, its status cannot be established.

Therefore, a critical point is always related to two things: the source of the ingredient and the processing method. The source shows where the ingredient comes from. The process shows how the ingredient is treated, including processing aids and the facilities used. Both need to be traced, not just one.

Within the framework of the Halal Product Assurance System (SJPH), ingredient criteria are regulated in the Head of BPJPH Decree Number 57 of 2021 on SJPH Criteria. This decree contains five criteria, one of which is ingredients. Thus, ingredient tracing is not merely administrative, but part of the implementation of SJPH itself.

Four Examples of Ingredient Critical Points

The following are four ingredients that often appear in discussions of critical points. Their status cannot be generalized; each needs to be examined specifically.

Glycerin / Glycerol (E422)

Glycerin is a versatile humectant. This ingredient can come from halal palm oil or from haram pork fat. Glycerin is used in toothpaste, syrup medicines, cosmetics, candy, moist cakes, and food preservatives. The alternative is halal-certified vegetable glycerin, generally from palm or coconut oil. To trace it, check supplier documents that state the origin of the ingredient and the halal certificate if available.

Fragrance / Fragrant Ingredients

Fragrant ingredients in cosmetics generally have a high alcohol solvent and may contain animal musk. Their status depends on the source. The alternative is non-alcohol fragrance or halal-certified synthetic musk. These ingredients are used in perfumes, spray deodorants, and scented body care products. Tracing needs to touch on the composition of the fragrance and its solvent, not just the product name.

Shellac (E904)

Shellac is a glossy coating from the resin of the lac insect. Materially, shellac is generally tolerated, but its process needs to be checked. This ingredient is used as a glossy coating for candy, medicinal pills or supplements, and fresh fruit coating. The alternative is halal-certified shellac with verified solvents, or vegetable coatings such as pure carnauba wax. The critical point is not the insect itself, but the solvent and the process that accompany it.

Gelatin

Gelatin is a thickening protein from animal collagen. Its status is halal only if the source and slaughtering are clear. Gelatin is used in marshmallows, jelly candy, medicinal or supplement capsules, ice cream, yogurt, and certain bakery products. The alternatives are fish gelatin, halal-certified beef gelatin, or agar and carrageenan as vegetable substitutes. Tracing gelatin requires clarity on the animal species, tissue origin, and slaughtering method.

How to Trace Ingredient Critical Points

Tracing critical points is not a one-time job. There is a sequence that can be followed so that the results can be accounted for.

1. Map the ingredients. List all ingredients used, including processing aids that do not appear on the label. Group them by category and initial status.
2. Ask about origin. For each ingredient whose status depends on the source, request written information from the supplier about the ingredient's origin. Do not stop at the trade name.
3. Request supporting documents. Documents may be ingredient halal certificates, product specifications, or supplier statements. Check the validity period and their conformity with the ingredients purchased.
4. Check the process. Trace processing aids, facilities, and potential cross-contamination. Critical points can appear here even if the main ingredient is already clear.
5. Record and review. Keep the tracing results in an ingredient registry. Review periodically, especially if there are changes in suppliers or formulas.

These steps are in line with the ingredient criteria in SJPH, which require a mechanism for inspection and monitoring. Head of BPJPH Decree 57/2021 also contains monitoring and evaluation criteria, so tracing is not a one-off activity.

The Role of Regulation and Institutions

On the side of business actors, Kepka BPJPH 57/2021 is the main reference for implementing SJPH. This regulation has been amended by Kepka 20/2023. The obligation for halal certificates for certain product groups is regulated in Minister of Religious Affairs Decree Number 748 of 2021, which was amended by KMA 944/2024. As for the procedures for organizing halal product assurance, including accreditation of Halal Inspection Bodies (LPH) and appointment of Halal Auditors, these are regulated in Government Regulation Number 42 of 2024.

Accredited Halal Inspection Bodies refer to SNI ISO/IEC 17065:2012, which regulates impartiality, confidentiality, personnel competence, and complaint and appeal management. This standard is the reference in LPH accreditation.

It should be noted that the determination of halal status is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee. Halal certificates are only issued by BPJPH. Therefore, the results of ingredient tracing by business actors are preparatory and documentary in nature, not a definitive determination of halal status.

Conclusion

Ingredient critical points require careful attention to source and process, not just the ingredient name. By mapping ingredients, asking about origin, requesting documents, checking the process, and recording and reviewing, business actors can build stronger traceability. To manage all SJPH criteria, including the ingredient registry and critical points, the SJPH platform from IndoHalal.id can help organize documents and internal audits in one place.