But a package’s safety on the shelf is only one part of the picture. What happens to that same cup, sachet, or pouch once the food inside it is discarded matters just as much. For a long time the two questions were regulated separately, under different laws with different aims.

Indonesia’s government has, in fact, been regulating that second question for some time. Law No. 18 of 2008 on Waste Management, Government Regulation No. 81 of 2012, and Ministry of Environment and Forestry Regulation No. P.75/2019 requires producers to reduce the waste their products and packaging create, and to use packaging that can be reused, recycled, or broken down naturally. That framework sets a target for producers to cut their waste by 30 percent by 2029. Then it schedules the removal of styrofoam, single-use plastic bags, straws, cutlery, and small sachets by January 2030.^[4] Indonesia’s national waste information system (SIPSN) records roughly 6.5 million tonnes of plastic waste a year, and about a quarter of it is food and beverage packaging, the takeaway box, the coffee cup, the sauce sachet, the refill pouch, so the framework’s reuse and recycling targets cover a large share of the plastic waste stream.^[1]

For years, BPOM’s food-safety rules touched on reused or recycled packaging only briefly. Meanwhile the environmental framework focused on a container’s volume and circularity rather than its food-contact safety. That left the public without a clear answer: if a business switched to recycled or reusable packaging to cut waste, was the container still safe to eat from?

BPOM’s newest regulation is where the two tracks start to connect. Indonesia’s food and drug authority, known as Badan Pengawas Obat dan Makanan (BPOM), promulgated Regulation No. 11 of 2026 on food packaging on 30 June 2026, replacing BPOM Regulation No. 20 of 2019.^[2] It implements the packaging safety requirement in Law No. 18 of 2012 on Food and Government Regulation No. 86 of 2019 on Food Safety. Government Regulation No. 1 of 2026 later amended the 2019 regulation.^[3] BPOM 11/2026 is the technical layer beneath that structure. It is also the first BPOM packaging rule with dedicated chapters on reusable packaging (Chapter IV) and packaging made from recycled materials (Chapter V).

That regulation sets out the obligation clearly: anyone who produces packaged food must use packaging material (Bahan Kemasan Pangan) that does not endanger human health. “Anyone” covers individuals and corporations, incorporated or not. The definition of packaging material is also broad. A restaurant packing takeaway, a cafe pouring coffee into a cup for sale, and a stall filling sauce into sachets all fall inside it, because the rule defines packaging material as any surface in direct contact with food, down to the sachet, the straw, the spoon, and the pot the food was cooked in.

Regulatory Shift

The regulation sorts packaging materials into seven categories: plastic, rubber and elastomer, paper and cardboard, ceramic, glass, metal and metal alloy, and multilayer. ^[2] The 2019 regulation organized packaging around nine materials, with multilayer treated as a subtype of plastic. It now stands on its own, which is relevant because multilayer laminates, such as coffee and snack pouches, are among the hardest packaging formats to recycle.

Every category carries its own migration limits, both total and specific. Migration is the transfer of substances from packaging into food. Total migration measures everything that transfers, regardless of whether it is hazardous. Specific migration checks named substances against individual thresholds. To pass, a material’s ingredients have to sit on BPOM’s list of permitted food-contact substances, stay off the prohibited list, and clear migration testing under the protocol set for that material type.

Why Reusable and Recycled Packing Matter

This is also where reusable and recycled packaging enter the picture, and where the 2026 revision does its heaviest lifting. Under Article 8, any reusable packaging has to meet the same migration limits as new packaging. Reusable plastic packaging faces an added test under Article 8(3): three rounds of migration sampling on the same piece, with each round showing leaching levels no higher than the previous one, a check that the material holds up rather than degrading with repeated use.  Recycled packaging does not get a lighter standard either. Articles 9 and 10 apply the same material, substance, and migration rules that govern new packaging to anything made from recycled content.

The Clock: One Year Transition

The regulation was promulgated on 30 June 2026, and Article 13 sets a twelve-month transition period, putting the deadline at around June 2027.^[2] Packaging already in circulation at that point is not affected until the transition ends; packaging placed on the market after that has to meet the new requirements, though Article 4(8) gives BPOM’s Head authority to phase in certain migration limits based on risk, so not every threshold necessarily lands on the same day. Article 12 attaches administrative sanctions to violations of the regulation’s core obligations, running against any person or corporation, incorporated or not.

Article 13 itself is short, just two paragraphs, and it does not carve out different rules by packaging type. It says packaging already on the market has to meet the new rule within twelve months, and that the phase-in exception is limited to the migration limits BPOM’s Head designates by risk. In practice, most businesses have until mid-2027 to update packaging specifications, and should not wait for BPOM’s follow-up guidance before starting.

Two Frameworks, One Compliance Obligation

Read together, this is a meaningful step toward the integration described earlier. A recyclable package that fails migration testing is still not compliant, and a package that clears every migration limit but ignores the 2030 phase-out schedule is not compliant either; for reused and recycled packaging specifically, producers now have one technical standard that answers both questions at once, rather than two standards that developed separately. It is not a full merger of food-safety and environmental regulation, but it is the clearest point of contact between the two so far, and a sign that policy is catching up with the packaging choices businesses were already being asked to make.

The two frameworks govern different dimensions of the same material. BPOM governs what may touch food. The environmental law governs the volume and circularity of the packaging itself. Neither substitutes for the other, and producers have to satisfy both at once.

What This Means for Companies

For companies managing packaging portfolios, a sensible starting point is reviewing the current portfolio against the seven material categories, with particular attention to anything reusable or recycled, since those are exactly the materials the 2026 revision singles out. From there, it is worth checking reusable and recycled packaging specifically against the requirements in Articles 8 through 10, since reusable plastics now need repeated testing and recycled packaging has its own production rules. Given the twelve-month transition, the earlier that review happens, the more room there is to act on what it finds. It is also a good moment to look at the same portfolio through an environmental lens: which formats are hard to recycle, which could move to reuse, and which sit on the 2030 phase-out list.

The Strategic Opportunity

BPOM 11/2026 also doubles as an opening. Indonesia’s circular input rate is still sitting at 9 percent against a 2029 target of 10 percent, and the national recycling rate at 13 percent against 20,^[5] so the country is short of both targets in ways the environmental law alone has not closed. A business that uses the new migration rules as the occasion to move packaging toward reusable or recycled formats is not just clearing a compliance requirement; it is moving the same three numbers Indonesia is trying to raise: more recycled input, longer-lasting packaging, and more material collected.

Read that way, getting packaging ready for BPOM’s new rules and the circularity work the environmental law has been asking for can run as one project. The spare capacity at recycling plants is also a reminder that the package is only half of it; collection and return systems decide how much material actually comes back.