A practical, BPJPH-first blueprint for surimi processors in Indonesia to pass halal certification on the first attempt. We cover SIHALAL steps, exact documents, ingredient risk screening (enzymes, phosphates, flavors), plant segregation, audit prep, common pitfalls, and 2025 timelines.
If you run a surimi line in Indonesia, you don’t have the luxury of guesswork anymore. Since October 17, 2024, halal is mandatory for food and beverage in Indonesia, and BPJPH’s expectations in 2025 are clear. In our experience supporting seafood processors, the teams that pass on the first try follow a simple, disciplined playbook. Here’s that playbook.
The 3 pillars of first-try BPJPH success
- Pillar 1. Documentation before production. Lock down SIHALAL data, supplier halal certificates, and your SJPH manual before you invite auditors. Backfill later and you’ll lose weeks.
- Pillar 2. Ingredient risk control. Most surimi failures come from additives. Treat enzymes, flavors, binders, and chemicals like CCPs with written specs and verified halal status.
- Pillar 3. Segregation you can prove. Auditors don’t want promises. They want a floor plan, color-coded tools, changeover SOPs, and cleaning validation that eliminate non-halal cross-contact.
Weeks 1–2: Gap analysis and SIHALAL setup
Here’s the thing. The SIHALAL portal won’t forgive vague answers. Build your data room first, then apply.
- Create an ingredient risk register. List every raw material and auxiliary: fish species, surimi-grade additives, processing aids, lubricants, cleaning chemicals, inks, adhesives, and glazing agents. Flag high-risk items: enzymes, flavors with ethanol, gelatin, caseinates, emulsifiers, phosphates, and release agents.
- Draft your SJPH manual. Keep it lean but complete. Include scope, organization chart with halal team, training plan, supplier halal verification SOP, production segregation rules, traceability, non-conformance and recall procedures, internal audit, and management review.
- SIHALAL account and product listing. In SIHALAL, set company profile and list products with precise names and SKUs. For surimi, separate each recipe variant if additives differ. Choose your LPH (auditing body) based on scheduling capacity, not only price.
Practical takeaway: Prepare a one-page flow diagram from fish receiving to finished surimi block. Auditors use it to anchor their questions, and it keeps your team aligned.
Weeks 3–6: Supplier verification, documents, and floor control
This is where most teams either accelerate or stall. We recommend a focused sprint.
- Supplier halal verification. Collect halal certificates for each additive and auxiliary from BPJPH-recognized bodies. Verify validity dates and scope. For flavors and enzymes, request a letter detailing carrier and fermentation media. Cross-check certificates via QR codes or authority websites. Don’t rely on “brand-level” certificates if the specific code isn’t listed.
- Exact documents auditors usually ask for in 2025:
- Legal: NIB, NKV, and applicable BPOM/permits for products. Company deed and address proof.
- Production: Process flow, floor plan with halal zones, equipment list, CCPs, changeover SOPs, cleaning validation records, and calibration.
- Materials: Full BOM with specification sheets, halal certificates or LoAs, COAs by lot, packaging specs and inks/adhesives MSDS.
- SJPH system: Manual, training records, internal audit report, corrective actions, supplier evaluation, traceability test results, mock recall.
- Records: Production logbooks by lot, sanitation logs, pest control reports, and waste handling SOPs.
- Plant segregation that stands up in audits. Use visual controls. Dedicated or color-coded tools. Sealed ingredient cages. Time separation with validated cleaning when shared lines are unavoidable. Keep non-halal items out of the building entirely if possible.
If you’re expanding SKUs alongside surimi, we can align raw materials to your halal bill of materials. For example, our white-fish inputs like Croaker Fillet (IQF) and portion lines such as Grouper Bites (Portion Cut) can be specified with halal-verified glazing and packaging auxiliaries. For fish ball programs, Yellowfin Ground Meat (IQF) helps standardize fat content within halal controls.
Need a quick read on whether your current ingredient set will pass? If you want a second set of eyes, Contact us on whatsapp.
Weeks 7–12: Mock audit, corrective actions, and submission
- Run a mock audit. Have your halal team walk the plant with a checklist that maps to SIHALAL fields. Check label claims, storage segregation, and batch reconciliation. Pull two traceability drills from finished goods back to additives and sanitation lot numbers.
- Close gaps. Replace any additive without a valid halal certificate. Standardize hand rubs and surface sanitizers. Reprint labels if claims don’t match the approved product names.
- File in SIHALAL and schedule the LPH audit. Expect a desk review followed by on-site assessment. Respond to corrective action requests within 5 working days to keep momentum.
Practical takeaway: Photograph evidence. Auditors love clear photos of segregated storage, tool color zones, and ingredient labels with halal logos that match certificates.
Your top questions, answered from the factory floor
What ingredients in surimi commonly cause halal audit failures in Indonesia?
From what we’ve seen, three frequent culprits: 1) microbial transglutaminase with unclear fermentation media or brand scope, 2) seafood flavors with ethanol carriers from khamr sources or without halal certificates, and 3) caseinates/gelatin-based binders with animal-origin ambiguity. Runners up: emulsifiers, anti-foams, and release agents with stearates of unknown origin.
Is microbial transglutaminase allowed in halal-certified surimi?
Yes, if it’s microbial-derived and the fermentation media and processing aids are halal. Use brands with current halal certification recognized by BPJPH. Obtain a composition letter stating source organism and that no porcine or non-halal bovine derivatives are used. Auditors often request the exact product code on the certificate.
Can ethanol-based seafood flavors be used if the alcohol evaporates?
Don’t bank on evaporation. In 2025, auditors look at source and presence at any stage. Choose halal-certified flavors with non-khamr ethanol or, safer, with carriers like propylene glycol or triacetin. If ethanol is used, document the source, halal certificate, and your validated cook-off parameters. Many teams still opt to reformulate to avoid debate.
Are STPP and other polyphosphates considered halal under BPJPH?
Sodium tripolyphosphate and most polyphosphates are synthetic and generally acceptable. Provide specs and, when available, a halal certificate or manufacturer declaration. Watch for mixed blends with carriers or anti-caking agents. Verify each component.
Do alcohol-based hand sanitizers jeopardize halal certification in a surimi plant?
Auditors typically accept them when they’re not product-contact, used per SOP, and dried before handling. Prefer non-khamr ethanol or isopropanol-based products and document that hands are dry before touching food-contact surfaces. For equipment, use alcohol-based agents only with a rinse or validated no-residue protocol.
What documents do I need to submit in SIHALAL to certify a surimi factory?
Plan on: company legal docs (NIB, NKV), product list and formulations, process flow and layout, SJPH manual, supplier halal certificates and specs, sanitation and calibration records, training logs, internal audit and management review notes, traceability and recall tests, and label artworks. Upload clear scans and keep file names readable.
How long does halal certification for a surimi processor take in 2025?
With complete documents, we see 45–75 days end-to-end. Desk review and scheduling can take 2–4 weeks, the audit 1–2 days, corrective actions 1–2 weeks, fatwa session timing varies, and BPJPH issuance 1–2 weeks. In busy periods, plan for 90 days. Certificates are typically valid for 4 years, with surveillance per your SJPH.
The 5 mistakes that kill halal audits for surimi plants
- Assuming “brand is halal” covers all SKUs. It doesn’t. Certificates must list the exact product code.
- Relying on post-audit reformulation. If a flavor fails, you’ll restart the clock. Vet before the audit.
- Weak changeover validation. If you share lines, show measurable cleaning verification, not just a cleaning form.
- Overlooking “invisible” inputs. Printing inks, adhesives, defoamers, gear lubricants, glazing additives. You need specs and LoAs.
- Uncontrolled rework. If you recycle trim or off-spec surimi, treat it like an ingredient with traceability and halal status preserved.
Resources and next steps
If you take nothing else from this guide, start an ingredient risk register and request updated halal certificates this week. Most delays start there. Then write a two-page SJPH summary and walk your floor with a camera for visual evidence. That sets you up to move fast in SIHALAL.
If you’re mapping a surimi or value-added line and want a sanity check on additives or segregation, Call us. We’re happy to share templates and real examples from Indonesian seafood plants that cleared on the first attempt.
One last thought. The industry is busier post-mandatory deadline, and LPH calendars fill quickly. The processors who win in 2025 aren’t the ones with perfect plants. They’re the ones who make it effortless for auditors to say yes.