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Typical Issues Faced by UMK in Fulfilling Halal Certification Obligations

The halal certification obligation demands evidence of ingredients, processes, and systems. For UMK, the heaviest burden lies precisely in documents and the supply chain.

R
Redaksi IndoHalal
September 12, 2026 · 4 min read
143
Colorful display of fresh vegetables at an outdoor farmers market stall.

The halal certification obligation applies gradually to products within the scope of halal product assurance. For micro and small businesses, the obligation is the same, but their capacity differs. The issues faced by UMK are rarely about intention. The problems lie in documentation, ingredients, and the supply chain.

Disproportionate administrative burden

The halal product assurance framework is regulated in Law 33/2014, with the latest amendment through Law 6/2023. Law 6/2023 simplifies the process and introduces a halal declaration scheme for UMK.

However, the system on the business operator's side still refers to the SJPH criteria, namely the Head of BPJPH Decree 57/2021, which was later amended by Decree 20/2023. The criteria cover commitment and responsibility, ingredients, halal product processes, products, and monitoring and evaluation.

For a factory with a quality team, these five criteria are routine. For a UMK managed by one to three people, all five mean additional work: writing policies, organizing purchase evidence, recording production flows, and documenting evaluations.

Ingredient issues and their origins

The most frequent problems arise not in the main recipe, but in auxiliary ingredients. Several critical points need to be examined:

  • Microbial enzymes for glucose syrup, meat tenderizers, or juice and cheese production. Their sources can be microbial, plant-based, or animal-based, so their status depends on origin.
  • Glycerin (E422) in toothpaste, syrup medicine, candy, and moist cakes. It can come from palm oil or pork fat.
  • Cochineal (E120) in red drinks, candy, and fruit yogurt. This colorant is derived from insects and its status is viewed differently by scholars.
  • Gelatin capsules in medicines and supplements, including fish oil softgels. Alternatives include plant-based capsules or halal-certified bovine gelatin.

What makes it difficult for UMK is proving the origin of these ingredients. Auxiliary ingredients are often purchased from baking supply stores, small distributors, or markets, without source documents. Yet the ingredient criteria demand clarity.

Undocumented supply chain

UMK usually do not buy directly from producers. Purchases are made through intermediaries, in small quantities, and often switch suppliers following prices. As a result, when asked to submit a list of ingredients along with supporting documents, UMK struggle to trace who the actual producer is.

This problem grows when one product uses many ingredients. Each ingredient needs to be verified, and each supplier needs to be asked for documents. For a business operating daily, chasing documents from many suppliers feels like work that competes with production itself.

Limited role of halal supervisors

The SJPH criteria require monitoring and evaluation. This function should ideally be carried out by personnel who understand the system. In UMK, this role is often held concurrently by the owner, who also handles sales, finance, and production.

As a result, monitoring runs irregularly. Records are made only before inspections, not as a habit. The system is also difficult to maintain after the certificate is issued.

Differences in readiness among UMK

Not all UMK face the same burden. A business selling a single product with few ingredients is far lighter than a business making many variants with diverse auxiliary ingredients. Businesses already accustomed to recording purchases and production are also better prepared.

Therefore, a reasonable first step is to map out the main points yourself: what ingredients are used, where they come from, and what documents already exist. From that map, UMK can assess whether the halal declaration scheme is sufficient or whether the regular pathway is needed.

It should be noted that the determination of halal status of a product is the authority of the MUI Fatwa Commission or the Halal Product Fatwa Committee, while the halal certificate is only issued by BPJPH. Business operators prepare the system and its evidence, not determine the halal status of their own products.

What can be done first

The issues faced by UMK will not disappear by waiting. Several things can be started without large costs:

  1. Record all ingredients, including auxiliary ingredients, for each product variant.
  2. Keep labels, packaging, or purchase invoices as initial evidence of ingredient origin.
  3. Ask suppliers directly who the producer of the ingredient is.
  4. Separate ingredients with clear origins from those still needing tracing.
  5. Get used to daily recording, not just before inspections.

That way, when the certification process is carried out, UMK do not start from zero.

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Jawaban konsultan bersifat panduan teknis. Penetapan kehalalan produk adalah kewenangan Komisi Fatwa MUI atau Komite Fatwa Produk Halal, dan sertifikat halal hanya diterbitkan oleh BPJPH.