A product may have a simple trade name, but its import process involves a classification that determines how the goods are treated in the international trading system. One of the most important identifiers is the HS Code.
For imported halal products, HS Codes are now relevant beyond customs or logistics teams. BPJPH Regulation No. 4 of 2026 also includes HS Codes in Halal Product Assurance Verification for overseas products entering Indonesia.
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Importers need to provide a product list with HS Codes when applying for Halal Product Assurance Verification. Whether the HS Code matches the product type is also inspected.
Inconsistencies between product classification, halal documents, and customs documents may therefore create a need for verification or adjustments while the process is underway.
What Is an HS Code?
An HS Code, or Harmonized System Code, is an internationally used nomenclature system for classifying goods.
BPJPH Regulation No. 4 of 2026 describes the HS Code as a uniformly used goods classification nomenclature based on the International Convention on the Harmonized Commodity Description and Coding System.
HS Codes are used for various purposes, including tariffs, statistics, rules of origin, and supervision of export and import commodities.
In importation practice, this classification identifies goods more systematically than a trade name alone.
A Product Name Does Not Necessarily Determine Its HS Code
A product’s marketing name does not always provide enough information to determine its goods classification.
Two products that appear almost identical to consumers may have different materials, functions, or compositions.
Importers should therefore look beyond the commercial name in a supplier’s catalog when preparing HS Code data.
Technical product information needs to be consistent with the classification used in importation documents.
Why Do HS Codes Relate to Imported Halal Products?
BPJPH Regulation No. 4 of 2026 expressly includes HS Codes at several stages of Halal Product Assurance Verification.
Importers applying for Halal Product Assurance Verification must have a list of products to be imported into Indonesia with their HS Codes.
During Halal Product Assurance Verification, one inspection activity is identifying the HS Code according to the types of products subject to mandatory halal certification.
The HS Code therefore connects:
- product identity;
- halal requirements;
- importer documents;
- Halal Product Assurance Verification; and
- customs processing.
For companies importing many SKUs, this becomes increasingly important because every product needs to be mapped using consistent data.
HS Codes and Imported Halal Products
HS Code Conformity at Every Stage of Halal Product Assurance Verification (BPJPH No. 4 of 2026)
An HS Code is important information that importers must prepare. Its conformity is checked during Halal Product Assurance Verification and relates to customs processing.
| Stage | Main Activity | Role of the HS Code | Related Documents | What Is Checked | Important Notes |
|---|---|---|---|---|---|
| 1. Preparation Before Application | The importer prepares product data and documents before applying for Halal Product Assurance Verification. | The importer must have a list of products to be imported into Indonesia together with HS Codes. |
|
Completeness of the HS Code for each product submitted. | The HS Code must match the types of products subject to mandatory halal certification. |
| 2. Halal Product Assurance Verification Inspection | The Inspection Body inspects goods at the loading warehouse before shipment. | The HS Code is identified according to the product types subject to mandatory halal certification. |
|
|
The HS Code is one inspection point in Halal Product Assurance Verification. |
| 3. Verification Results | Inspection results are recorded in the Halal Product Assurance Verification Report (LPPH). | The HS Code recorded in the LPPH follows the data inspected. |
|
Consistency of all product data, including the HS Code, with the goods inspected. | The LPPH is valid for one shipment or one entry. |
| 4. Import Customs Declaration | The importer submits the import customs declaration and attaches the LPPH. | The HS Code is used in customs documents under the applicable provisions. |
|
Consistency between LPPH data and customs documents, including the HS Code. | Ensure HS Code data is consistent across all import documents. |
| 5. HS Code Differences | A difference exists between the HS Code in the LPPH and the customs authority’s determination. | The applicable HS Code is the one determined by the customs authority. |
|
Determination of the HS Code by the customs authority under statutory provisions. | Refers to Article 15 of BPJPH Regulation No. 4 of 2026. The customs authority’s HS Code determination applies. |
Remember: Product data, HS Codes, halal certificates/SHLN, labels, invoices, and other documents must be consistent from the outset. Good preparation helps the Halal Product Assurance Verification and customs processes proceed smoothly.
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HS Codes Must Be Included in the Submitted Product List
At the application stage for Halal Product Assurance Verification, importers must prepare a list of products entering Indonesia, complete with HS Codes.
This list forms part of the documents verified by the Inspection Body.
Product Documents Need to Be Consistent
The HS Code should not be viewed separately from other information.
During inspection, product data may be compared with information such as:
- product type or description;
- Halal Certificate or Registration Number;
- invoice;
- product order list;
- quantity or volume;
- production code;
- production date; and
- product units.
If names, descriptions, classifications, and supporting documents use inconsistent information, the importer may face requests for further clarification.
JHY Legal can help companies conduct an initial review of imported halal product compliance document readiness and identify areas needing alignment before applying for Halal Product Assurance Verification.
HS Codes Are Also Checked Before Shipment
Halal Product Assurance Verification under BPJPH Regulation No. 4 of 2026 takes place in the country of loading and/or the product’s country of origin.
Inspection takes place directly at the loading warehouse before goods are shipped.
At this stage, the Inspection Body reviews more than the existence of a halal certificate.
Some Aspects Inspected
Inspection may cover at least:
- consistency of administrative data and documents;
- identification of product types based on the Halal Certificate or SHLN registration;
- validation of the Halal Certificate number or Registration Number;
- identification of the HS Code;
- goods quantity or volume;
- production code and production date;
- product units;
- Halal Label or Non-Halal Statement; and
- other supporting documents.
This means the HS Code data previously submitted needs to match the characteristics of the physical products to be shipped.
What If the LPPH HS Code Differs from Customs Classification?
BPJPH Regulation No. 4 of 2026 provides a specific rule for possible HS Code differences.
Article 15 provides that if the HS Code stated in the LPPH differs from the code determined by the competent customs authority, the applicable HS Code is the one determined by the customs authority in accordance with statutory provisions.
This provision matters because it shows that the customs authority retains a role in classifying goods for customs purposes.
What Does This Mean for Importers?
Importers should endeavor to confirm classifications from the outset so that data used in halal processing and customs documents do not diverge.
If differences arise, the company may need to coordinate and adjust the relevant documents or data.
The regulation does not state that every HS Code difference automatically results in goods being rejected. However, inconsistencies can add administrative work and require clarification in a process that should have been prepared before shipment.
Coordinate the Halal and Customs Teams
One challenge within companies is that product information is often held by several different functions.
The regulatory team may manage halal certificates. Procurement holds supplier documents. Customs handles HS Codes. Logistics arranges shipment schedules.
If each team uses different product data, the potential for inconsistency increases.
Create One Product Master Data Set
Companies importing many products can consider master data containing at least:
- product name;
- SKU;
- manufacturer;
- country of production;
- technical description;
- HS Code;
- Halal Certificate or SHLN status;
- Registration Number;
- label information; and
- supporting documents.
A single, consistent data source enables more efficient checks before shipment.
What About the List of Foreign Halal Products?
BPJPH Regulation No. 4 of 2026 also states that the list of Foreign Halal Products entering Indonesia is accompanied by HS Codes according to the product types subject to mandatory halal certification.
The product and HS Code list is determined by the Head of BPJPH.
This further shows that goods classification is an important component of imported halal product administration.
Importers need to ensure that the products they bring into Indonesia are mapped correctly to the relevant provisions.
Which Mistakes Should Be Avoided?
Several patterns can potentially cause problems in document preparation.
Using an Old HS Code Without Review
The company may reuse a classification from a previous shipment without checking whether the product, composition, or specifications have changed.
Product changes may require old data to be reviewed.
Following a Supplier’s HS Code Without Verification
An overseas supplier may provide the HS Code used in its country of origin.
This information can serve as a reference, but the importer needs to ensure its use complies with the rules applicable to Indonesian importation.
Inconsistent Product Names
Significant differences between names on invoices, product lists, halal certificates, and internal documents can make matching difficult.
Checking the HS Code Too Close to Shipment
If a potential difference is discovered only when goods are ready to depart, there is less room for correction.
Conduct a Review Before Finalizing the Shipping Schedule
Halal Product Assurance Verification takes place before shipment. HS Code review should therefore also form part of preparation before shipping.
Ideally, the company has checked classification and document consistency at the purchase order stage or when the supplier provides the final product specification.
This approach helps prevent problems first surfacing when goods are already at the loading warehouse.
JHY Legal can assist importers in reviewing imported halal product regulatory aspects, document readiness, and the relationship between product information, Halal Product Assurance Verification requirements, and documents used before products enter Indonesia.
Conclusion
An HS Code is more than a number used for customs processing. Under BPJPH Regulation No. 4 of 2026, it also forms part of the requirements and inspections in Halal Product Assurance Verification for overseas products.
Importers must include HS Codes in their submitted product lists and ensure conformity with product types.
If a difference later arises between the HS Code in the LPPH and the customs authority’s classification, the customs authority’s code applies.
Coordination among regulatory, customs, procurement, and logistics is therefore important. Early HS Code review can help reduce document inconsistencies and the need for corrections when shipment is approaching its scheduled departure.
This article provides general information and does not constitute legal advice. Read the JHY Legal disclaimer at https://jhylegal.com/disclaimer/.