The Definition of Natural Flavourings Under BPOM Regulation
Under the applicable BPOM regulation on flavouring food additives, a natural flavouring is a flavouring obtained from plant or animal raw materials through physical, microbiological, or enzymatic processes, in their original state or after processing for human consumption. This definition is in substance aligned with the Codex Alimentarius CAC/GL 66-2008, the international reference framework adopted by many ASEAN food authorities.
The core of the definition is this: the raw material must come from nature, and the processing must stay within the physical, microbiological, or enzymatic categories. Once a process involves chemical synthesis or molecular modification through chemical reactions beyond the natural function of an enzyme, the natural status is lost. For the formulator, this line is the legal boundary between a "natural flavouring" label and a "nature-identical flavouring" label. Always refer to the latest version of the BPOM regulation before a final labelling decision, because the permitted dosage and types may change.
Raw Material Sources of Natural Flavourings
The raw materials of natural flavourings are grouped by their source and the method by which they are obtained:
- Botanical extracts. Vanilla from vanilla beans, coffee extract, tea extract, pandan extract, ginger extract. Obtained through food-grade solvent extraction (ethanol, propylene glycol, water, or vegetable oil).
- Essential oils. Citrus oil from citrus peel, peppermint oil from mint leaves, clove oil from clove buds, cinnamon oil from the bark. Obtained through steam distillation, cold press, or supercritical CO2 extraction.
- Oleoresins. Concentrated extracts from spices such as pepper, paprika, and turmeric. They contain both volatile and non-volatile compounds that give colour and taste.
- Fermentation products. Biological vanillin from microbial fermentation, certain cheese profiles, natural organic acids. They meet the natural criteria as long as the microorganisms used are approved for food.
- Enzymatic products. Protein hydrolysates, aroma compounds produced through the controlled action of food enzymes. They fall within the natural category under the Codex.
The carrier solvent used in natural flavourings must also be food-grade and declared on the CoA. Common solvents are propylene glycol, vegetable glycerine, ethanol (which requires halal consideration), medium-chain triglycerides (MCT), and water.
Labelling in Indonesia
On the ingredient list of food product packaging in Indonesia, the claim you use must reflect the regulatory category of the flavouring used:
- "Natural [name] flavouring" when the flavouring meets the BPOM definition of natural and reflects the character of its natural source (for example, "natural strawberry flavouring").
- "Nature-identical [name] flavouring" when its main aroma compound is synthesised but chemically identical to the one found in nature.
- "Synthetic [name] flavouring" or "artificial [name] flavouring" when it uses compounds not found in nature.
Certain food product categories have additional provisions on the use of the word "natural" in the trade name, the front-of-pack claim, or the fruit imagery on the label. If a product will include the word "natural" in the product name or a front-of-pack claim, verify directly with the supplier's regulatory team and refer to the relevant BPOM regulation before printing the design.
The Halal Status of Natural Flavourings
"Natural" does not automatically mean halal. Since October 2024, BPJPH halal certification has been mandatory for products on the Indonesian market, and every food additive must have a traceable halal status. Three critical points to check on natural flavourings:
- Ethanol solvent. Many botanical extracts use ethanol as a solvent. BPJPH and the MUI fatwa have specific criteria for ethanol residue in food additives. Confirm the residue reported on the CoA and the relevant fatwa reference.
- Animal raw materials. Some aroma profiles are produced from animal sources (for example, certain meat or seafood profiles). Make sure the animal source comes from halal animals slaughtered according to sharia.
- Shared production lines. If the supplier also produces non-halal flavourings in the same plant, the cleaning and line-separation procedures need validation. A valid BPJPH certificate already covers this audit.
Supplier Certification and Due Diligence
If you are going to use a natural flavouring in a product that will be on the Indonesian market, request the following documents as a standard package from the supplier:
- A BPOM registration number for the food additive, together with support for the ML or MD registration of your finished product.
- A BPJPH halal certificate with an active validity period, verifiable at halal.go.id.
- A Certificate of Analysis per batch, listing the composition, solvent residue, and main contaminants.
- An origin statement confirming the natural status in line with the BPOM and Codex definitions.
- An allergen declaration per the BPOM list (milk, egg, peanut, soy, gluten, fish, shellfish, and others).
- A Material Safety Data Sheet (MSDS) for handling, storage, and emergency response.
- A technical specification with recommended dosage and the appropriate process conditions.
If you are just beginning to map out flavouring suppliers, see also the food flavourings buying guide, which covers supplier evaluation criteria more broadly, and the basic explanation of food flavourings for technical context.
When to Contact VKA
VKA® has been a Southeast Asian food flavouring manufacturer since 1971, with a natural flavouring portfolio that spans tropical botanical extracts and signature Asian profiles. Its plant in Singapore is certified to FSSC 22000, GMP, HACCP, and MUIS halal. Official distribution in Indonesia is through PT Aroma Indonesia Internasional with complete BPOM and BPJPH documentation. Learn about VKA's formulation capabilities, or explore all of the flavour industry guides.