A print-ready, role-specific checklist for QA/Regulatory managers at Indonesian seafood processors to pass a 2026 BPJPH halal audit on the first attempt. What to prepare, the exact documents to upload in SiHalal, and the seafood-specific pitfalls to avoid.
If you manage QA or Regulatory at a seafood plant in Indonesia, you don’t need theory. You need a pass-first-time halal audit pack that actually works. We’ve run multiple BPJPH applications through SiHalal and hosted LPH auditors on frozen shrimp and finfish lines. Here’s the exact, seafood-focused checklist we use to clear audits with minimal NCs.
2026 reality: What BPJPH looks for at seafood plants
Auditors are practical. They check three pillars: your SJPH system design, your material controls, and your ability to prove traceability with clean records. In the last six months we’ve seen tighter scrutiny on sanitation chemicals, correct use of the national halal logo, and whether your SiHalal uploads match what’s on the shop floor. If there’s a gap between “what you say” and “what you do,” you’ll get findings.
The print-ready checklist QA managers use
Use this as your pre-audit internal checklist for BPJPH halal compliance. Map it to your HACCP plan so you’re not maintaining two parallel systems.
- Company and facility basics
- Legal docs: NIB, NPWP, deed of establishment, site licenses. Upload to SiHalal.
- Organization: org chart with named Penyelia Halal (Halal Supervisor) and deputies, with training certificates.
- Layout and flows: latest plant layout, people and product flows, cold chain map, pest control map.
- SJPH (Halal Assurance System) mapped to seafood operations
- SJPH Manual that mirrors your HACCP structure. Include policy, management responsibility, training, materials control, production facility, critical activities, traceability, handling nonconformity, internal audit, management review.
- Procedures and records: receiving, batching, glazing, IQF/IVP/IWP, rework handling, segregation, sanitation, chemical control, label control, recall/withdrawal mock drill.
- Internal halal audit plan and last internal audit report with CAPA and management review minutes.
- Materials and supplier documentation
- Full ingredient list per product code. Typical seafood criticals: STPP (E451), sodium metabisulfite (E223), CMC/sorbitol in glazes, antioxidants, color protectants, brines, packaging inks/adhesives on primary packs.
- For each material: halal certificate recognized by BPJPH or at minimum a halal declaration, full specification, COA per lot, and MSDS. Yes, STPP and sodium metabisulfite should have their own halal certificates or acceptable declarations. More on this below.
- Water and ice: microbiology and potability test results. If glaze is water-only, prove it with the SOP, batch sheet, and lab records.
- Sanitation, chemicals, and lubricants
- List every chemical used. Include degreasers, foaming cleaners, sanitizers, descalers, conveyor lubricants, mold-release, and hand soaps/sanitizers.
- Evidence: halal certificates for food-contact cleaners and any chemical with a possible residue. For non-food-contact chemicals, keep MSDS plus supplier declaration of no pork/khamr derivatives. Prefer food-grade H1 lubricants with halal certificates.
- Alcohol policy: written rule for procurement and controlled use. More on sanitizers below.
- Production controls and records
- Validated process flow for each line: receiving to dispatch. Include chill/freeze curves, IQF belt temps, core temperature checks, and glaze percentage checks.
- CCP/OPRP records aligned to HACCP and mirrored in SJPH. Calibration records for thermometers, scales, metal detectors.
- Rework policy. Labeling of WIP, rework, and hold lots.
- Traceability and mass balance
- One-up, one-down traceability with mass-balance capability. Show that harvest lots, additives, and packaging roll into a unique finished batch and can be traced back in 2 hours.
- Outsourcing: cold storage, transport, or co-packing agreements and audits. Include their halal status or segregation SOP.
- Label control and halal logo
- Draft and approved artworks. Ensure the Indonesian halal logo is the current BPJPH mark. Keep vector files and a label approval form. Show correct placement, scale, and certificate number text near the logo where applicable.
- Export labels: auditors expect proof you control versions for each market. If a product isn’t sold domestically, you may not print the BPJPH logo on export labels, but keep the SOP that governs this.
Need a quick pre-audit document check before you upload to SiHalal? We can walk you through line by line. Contact us on whatsapp.
Answers to the questions auditors actually ask
What documents do BPJPH and LPH auditors usually request at a seafood plant?
In our experience, the core pack includes:
- SJPH Manual and cross-reference to HACCP.
- Training records for all shifts, including temps and night crews.
- Material specs plus halal proofs for STPP, sodium metabisulfite, glazing agents, and cleaners. COAs matched to receiving logs.
- Water and ice quality tests. Free chlorine verification where applicable.
- Production records: glazing checks, yield logs, metal detection logs, cold chain temp charts, sanitation pre-op findings with closeout.
- Traceability demonstration: pick one SKU, run mass balance from harvest ticket to finished goods and back.
- Label approvals and the current halal logo usage proof.
Do STPP and sodium metabisulfite need individual halal certificates from suppliers?
Short answer: yes, that’s what most LPH teams now expect. These additives are chemically mineral or synthetic, but auditors want formal halal assurance to close risk on carriers, anti-caking agents, processing aids, and shared equipment. If a halal certificate isn’t available, compile this fallback pack: detailed composition with no animal-derived carriers, a process flow with no khamr sources, a signed no-pork/no-khamr declaration, and recent COAs. But our pass-first-time recommendation is to source STPP and SMBS with recognized halal certificates.
How do we demonstrate halal traceability for shrimp from farm to finished product?
We set it up like this:
- Inbound: harvest ticket or supplier DO, pond ID, harvest date, species, size grade. Assign a unique raw lot code at intake. Verify supplier approval and halal status of any treatment used post-harvest.
- Additives and packaging: link additive lot IDs and packaging roll IDs to the raw lot in the batching record.
- Processing: each WIP step carries forward the parent lot code. IQF line records should show belt speed, freezer temp, metal detect checks, and glaze percentage per batch.
- Finished goods: one finished batch code that ties back to all inputs. Run a mock recall. Target: trace back to pond in under 2 hours.
Are alcohol-based hand sanitizers allowed in a halal-certified seafood facility?
Here’s the thing. Policies vary by LPH, but 2026 practice we see most often is risk-based acceptance if: ethanol isn’t from khamr, the sanitizer is used before gloving or fully evaporates, and there’s no pathway to product contamination. The cleanest audit path is to switch to halal-certified sanitizers or non-alcohol hand rubs in production zones. Keep supplier declarations on ethanol origin, MSDS, and a written policy controlling procurement and point-of-use. If you must use alcohol for critical disinfection, document why and how you prevent carryover.
Which sanitation chemicals must have halal proof for BPJPH audits?
Prioritize halal certificates for anything that can remain on food-contact surfaces or migrate: foam cleaners, CIP detergents, quats, peracetic acid blends, conveyor lubes on open product lines, hand soaps used by trimmers. For non-food-contact uses, MSDS plus supplier no-pork/no-khamr declarations are usually acceptable. We maintain a chemicals register showing the halal proof type and the expiry date so we’re never scrambling during audits.
What label proofs and halal logo files are auditors expecting for seafood exports?
- Use the current national halal logo. Keep vector artwork and your internal logo usage guideline. Don’t stretch, recolor randomly, or overlay patterns.
- Show a label approval workflow, version control, and a live example on a printed shipper or retail bag. Include the halal certificate number text per your SOP where required.
- For export-only SKUs without the Indonesian halal logo, keep a policy that defines market-by-market rules and examples of compliant artworks, plus buyer approvals if they require extra marks.
The top reasons seafood plants fail their first BPJPH audit
We’ve seen the same patterns:
- Missing halal proofs for additives and cleaning chemicals. Fix by building a materials register with status and expiry tracking.
- SiHalal uploads don’t match the floor. Outdated layout, old label version, or retired SOP still posted.
- Unregistered outsourcing. Third-party cold storage or filleting room isn’t covered by your scope or there’s no segregation SOP.
- Weak document control. No version numbers, uncontrolled prints, or training records missing for night shift. Solve with a master list and stamped “controlled copy” prints.
- Evidence for “no alcohol” is verbal only. Keep purchase blocks in ERP, supplier declarations, and a chemicals gatekeeping SOP.
- Using the old logo. Replace legacy MUI marks with the current BPJPH logo in all artworks and marketing.
Timeline, fees, and what to upload in SiHalal
- Typical timeline we see: 2–4 weeks for document prep, 1–3 weeks for desk review, 1–2 days onsite, then 2–4 weeks to decision. Total 6–12 weeks if your docs are tight.
- Fees vary by product count, site size, and chosen LPH. Budget starts in the tens of millions IDR and scales with complexity.
- SiHalal upload tips:
- Use a consistent file naming convention: Category_DocName_Plant_Version_Date.pdf. Auditors love this.
- Expiries: tag certificates and tests with reminders 60 days before expiry.
- Map files to SJPH chapters and cross-link to HACCP elements so reviewers can navigate quickly.
Where our team can help (and what “good” looks like on the floor)
On our frozen finfish lines like Grouper Fillet (IQF) and portioned SKUs such as Mahi Mahi Portion (IQF), we keep additive-free glaze or, when customers request functional treatments, we hold current halal certificates for STPP and any glazing agents. For shrimp programs, we run end-to-end traceability packs that tie pond ID to finished batch in under two hours. That level of discipline is what LPH teams expect now.
If you want a sanity check on your SJPH-to-HACCP mapping or materials register, we’re happy to share templates and examples we use on export programs. Questions about your specific product list or labels? Call us. If you’re still building your SKU range, you can also View our products for halal-ready formats suited to retail and foodservice exports.
Practical takeaway: lock down your materials proofs, get your label versions right, and make SiHalal reflect your real plant. Do that, and the rest of the audit becomes a confirmation exercise, not a surprise hunt.