By:

– Dr. Ir. Muslich, M.Si 

Director of Audit Halal Service LPPOM MUI 

– Irma Rosiana Elisabeth, S.Si 

Product & Process Development Assistant Manager LPPOM MUI

In today’s digital era, the internet seems to be very easy to access in everyday life, including in getting information related to the halal status of a product through social media. Checking the truth of the information is a challenge in itself, including checking the validity of information related to the pork content in a product.

Lately a lot of discussion in social media related words which means pork on the labels of food products from South Korea. Several accounts on Instagram discuss the prohibition of a product because of the information on the label. However, is it appropriate to justify the halalness of a product based on this information? In this article, we will discuss the origin of the inclusion of pork on food product labels from South Korea. 

In Indonesia, processed food labels are regulated by the National Food and Drug Agency (BPOM) through BPOM regulation No. 31 of 2018. If there is a BPOM in Indonesia, the agency authorized to regulate labels in Korea is the Ministry of Food and Drug Safety (MFDS). The MFDS currently sets the standard for food labeling No. 2016-45, June 13, 2016. This standard is a reference for food producers in Korea.

MFDS requires food labels to contain information such as product name, product type, name and address of the party producing or importing it, date of production, expiration date, list of ingredients used and so on. In addition to this information, it is important to include allergens on food labels, because they can cause an immune reaction when consumed by consumers who are allergic to certain food ingredients. This immune reaction can have mild symptoms such as itching on the skin but can also have serious symptoms such as narrowing of the respiratory tract, even causing death.

Allergen regulations from one country to another can be different, if we compare Indonesia and Korea. Indonesia stipulates that ingredients that are included as allergens are cereals containing gluten (wheat, rye, barley, oats, spelled, or strains hybrid), eggs, fish, crustaceans (shrimp, lobster, crab, oysters), mollusks (shellfish, snails, or snails). seafood), peanuts, soy, milk (including lactose); tree nuts including walnuts, almonds, hazelnuts, walnuts,pecans, Brazil nuts, pistachios, macadamia nuts or Queensland nuts, cashews, and sulfite with a content of at least 10 mg / kg. However, in Korea apart from these ingredients, pork, chicken, beef, octopus, tomatoes and peaches are also categorized as allergens (MFDS 2016).

Since pork is one of the allergens, the author will discuss further how regulations in Korea regulate the declaration of pork on food product labels in Korea. In general, the basis for allergen labeling can be divided into two. 

Allergen Labeling If Food Contains Allergens 

Based on product labeling standards from MFDS No. 2016-45, 13 June 2016, if: 

a. Allergens are used as ingredients, 

b. Material is the result of extraction from regulated allergens, 

e. Using food additives containing allergens under the conditions described in points A and B. 

Therefore, a special area/box with a different background color must be made on the label, adjacent to the ingredient list containing information such as “contain eggs, pork, milk, shrimp, ….” for example in the following labels: 

If consumers find a label like Figure 1, that is, in the ingredient list there is a yellow line. Consumers should be careful because there are words (mean Contain or containing) (mean pork). Even if this kind of product such as entry into the Indonesian market then National Food and Drug Agency (BPOM) will require manufacturers to use the symbol, such as the following: 

Labeling Allergens as Precautionary Statement 

(Precautionary Allergen Labelling – PAL)

Korean products through product labeling standards by MFDs No. 2016-45, 13 June 2016, also uses the Precautionary Allergen Labeling (PAL) system in allergen declarations on food labels. The consideration of this PAL policy is as a precautionary measure since food can be contaminated with food waste containing allergens at many points along the food chain such as from workers, equipment, production lines, material storage, and so on. 

The form of the PAL statement on the label varies as shown in Figure 2. However, it generally uses 3 terms, namely: “may contain…” (produced on shared equipment…) and “made in the same factory asthe same factory as…” (manufactured in…) (Allen et al 2014). 

However, what needs to be criticized is that, in many cases, manufacturers do not carry out a comprehensive risk assessment to use PAL statements on food labels. For example, if a manufacturer does contain pork-derived ingredients, then to include a PAL statement on the label, a risk assessment should be carried out to measure the possibility of contamination of other products. 

The following are the results of interviews with several producers in Korea who use the statement “may contain/produced in the same factory as the product containing pork” on the packaging label. 

1. There are pig-derived ingredients that are used for other products produced in the same factory, although it can be ensured that they are produced in different lines of facilities and there is no cross-contamination, 

2. There is a dressing material with a savory taste, although these materials do not contain pork derivatives. 

According to (Allen et al 2014) most foods with PAL labels do not contain evidence of allergen contamination including pork. Instead of PAL being carried out to convey the risk of allergen cross-contamination, in practice the use of PAL creates uncertainty and ambiguity of information for consumers. 

This is an issue that is quite troubling for people with a Muslim majority population like Indonesia, when social media discusses a label that written without further explained that the inclusion of allergens (including pork) in Korean products not only when products using pork ingredients but there are also regulatory inform PAL uncertain whether overall food must contain pork or not. 

In the context of Korean processed food products that have been certified halal, the aspect of cross-contamination opportunities must have been observed by the auditors who audited the food producers. In MUI halal certification, producers are required to implement 11 criteria for the Halal Assurance System (SJH) which will be assessed by the auditor when the audit is carried out. 

One of the functions of implementing Halal Assurance System is to prevent cross-contamination opportunities between halal-certified and non-halal-certified products, if producers do not certify all products halal in one location.

This can be done in two ways: 1) ensuring that production lines and supporting equipment that are in direct contact with halal ingredients/products are separated from products containing pork derivatives, as well as the supporting equipment used; and 2) ensuring that employees who work are not a source of product contamination. 

In addition, consumers can also identify the halalness of a product themselves by paying attention to food labels that have been evaluated by BPOM and to the halal logo before consuming a product. (***) 

Sources:

– Allen KJ et al. 2014. Precautionary labelling of foods for allergen content: are we ready for a global framework. World Allergy Organization Journal. 7:10 http://www.waojournal.org/content/7/1/10 

– The Regulation of National Food and Drug Agency Number 31 of 2018 concerning Processed Food Label 

– Food Labelling Standard Public Announcement No. 2016-45 by the Ministry of Food and Drug Safety (MFDS)

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