Typical Challenges for UMK (Micro and Small Enterprises) in Fulfilling Halal Certification Obligations

The halal certification obligation is regulated in Law Number 33 of 2014 on Halal Product Assurance. This law also establishes BPJPH (Halal Product Assurance Agency), regulates the role of LPH (Halal Inspection Agency), and affirms MUI's (Indonesian Ulema Council) authority in determining product halalness. For large business actors, this framework can generally be absorbed into existing quality systems. For UMK, the problem is different.

Certification Demands a System, Not Just Conviction

The main reference for implementation on the business actor side is the Decree of the Head of BPJPH Number 57 of 2021 on the Criteria for the Halal Product Assurance System, which was later amended by Kepka 20/2023. This document contains five criteria: commitment and responsibility, materials, halal product processes, products, and monitoring and evaluation.

These five criteria demand a written trail. Halal policy must be declared. Materials must be registered. Critical points must be identified. Internal audits must be carried out. For micro-enterprises whose production is run by a few people, this work adds a burden beyond production, sales, and daily bookkeeping.

The product groups required to be halal-certified along with their phasing are stipulated through the Decree of the Minister of Religious Affairs Number 748 of 2021, which was amended by KMA 944/2024. The phasing means the obligation does not arrive all at once, but it does not remove the obligation itself.

Four Problems That Often Arise

1. The origin of materials is not always known

UMK often buy semi-finished materials without knowing their source. The following four materials often become critical points.

• Yeast. Generally halal, but its growth medium needs to be checked. The alternative is yeast with a halal-certified plant-based growth medium, which has generally become the standard in modern industry.
• Carmine or cochineal (E120). A natural red dye from the cochineal insect. Its status is syubhat (doubtful) because scholars differ in opinion. Substitutes can be plant-based red dyes such as beet, anthocyanin, or lycopene.
• Mechanically separated meat (MSM). Meat residue from bones extracted by machine, at risk of being a mixture from various types of animals. The guarantee is a dedicated halal production line and certificates from certified slaughterhouses.
• Mono- and diglycerides of fatty acids (E471). The most common emulsifier in the food industry, can come from palm oil or animal fat. What is needed is halal-certified E471 with plant-based fatty acid sources listed in the material certificate from the supplier.

These four examples show the same pattern: the status of a material cannot be concluded from its generic name. What determines it is the document from the supplier.

2. Supplier documents are difficult to request

UMK are usually in a weak position relative to suppliers. Requests for material certificates for small-quantity purchases often get no response. Yet without those documents, the material criteria are difficult to fulfill.

3. The role of the halal supervisor

The commitment and responsibility criteria assume there is personnel running the system. At UMK, this function is often held concurrently by the owner or one employee who also handles production.

4. Maintaining the system after the certificate is issued

The monitoring and evaluation criteria require the system to keep running. Changes in suppliers or formulas must be recorded. This is recurring work, not a one-time task.

Where UMK Should Move Next

There are two things that can be done first. First, compiling a simple material registry: material name, supplier name, and halal document status. Second, separating materials that are already clear from those that still need to be traced, such as the four examples above.

For certification bodies, accreditation refers to SNI ISO/IEC 17065:2012 which regulates impartiality, confidentiality, personnel competence, complaint and appeal management, and liability. This means that inspection indeed rests on verifiable evidence.

It should be emphasized that the determination of halalness is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee. Certificates are only issued by BPJPH. Therefore, the task of UMK is not to judge whether their product is halal or haram, but to prepare evidence that their materials and processes can be accounted for.

The typical problem of UMK is not in intention, but in administrative capacity. Tidying up the material registry and critical points from the start makes the certification process no longer feel like an additional burden. If you want to tidy up those steps, the SJPH service — the Halal Product Assurance System Platform from IndoHalal.id helps manage SJPH criteria in one application, from halal policy, material registry, critical points, to BPJPH certification readiness.