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GOVERNMENT SUPPORT IN IMPLEMENTING PERMENKES NO.

30 / 2013

Agus Hari Wahono

Universitas Borobudur, Indonesia

Email : [email protected]om

Abstract

Food is a primary need for humans and is mandatory to fulfill it. Without food, humans cannot survive because

food is a source of energy for humans to carry out their daily activities. To maintain our health, we also need to

consume healthy foods and avoid foods that can cause various diseases. Regulation of the Minister of Health

Number 30 of 2013 concerning the Inclusion of Information on Sugar, Salt, and Fat Content and Health

Messages on Processed Foods and Ready-to-Eat Foods. This research is included in qualitative research and is

descriptive in nature. This study is an empirical study of laws and policies in Permenkes No. 30 of 2013. The

policy for including information on sugar, salt, and fat content as well as health messages for processed food

needs to be accompanied by changes to the Guidelines for Inclusion of Information on Nutritional Value on

Food Labels. The food industry in Indonesia can carry out a policy of including information on sugar, salt, and

fat content as well as health messages for processed food. But to implement it, the food industry offers a public-

private partnership model, namely the Public Health Responsibility Deal as has been done in the UK. and the

Millan Declaration in Switzerland.

Keywords

Government, Health, Regulation

INTRODUCTION

Food is a primary need for humans and it is mandatory to fulfill it. Without food humans

cannot survive, food is a source of energy for humans to carry out their daily activities. Food

is a source of energy for humans, so food must contain four healthy five perfect to help

sustain growth. To maintain our health, we also need to consume healthy foods and avoid

foods that can cause various diseases.

Living in the modern era like today, you can find many kinds of food products. Based on

Law Number 18 of 2012 concerning Food "Food is anything that originates from biological

products, whether processed or not that is used as a drink or food for human consumption,

including food raw materials, food additives or other ingredients that are used during the

process of preparation, manufacture and/or processing of the manufacture of drinks or

food.”(Ardani, 2020) From the way it is obtained, food can be divided into 3, namely fresh

food, processed food, and certain processed food (Davidou et al., 2020).

Processed food is food that has gone through a certain process. Based on Minister of

Health Regulation Number 63 of 2015 (Kusnali et al., 2019) concerning Amendments to

Minister of Health Regulation Number 30 of 2013 concerning the Inclusion of Information on

Sugar, Salt, and Fat Content and Health Messages on ProcessPed Foods and Ready to Eat

Food, article 1 paragraph 1 which reads: "Food Processed food is food and drink processed in

a certain way or method with or without additional ingredients, including certain processed

food, food additives, genetically engineered food products and irradiated food”[4]. Processed

food products can be found all around us, specially packaged processed food products. One

example of processed food is processed food from cassava or cassava chips. Cassava chips

are processed food products whose main ingredients are cassava, then by going through a

process such as frying or other processes by adding food additives to become cassava chips

Injuruty : Interdiciplinary Journal and Humanity

Volume 2, Number 2, February 2023

e-ISSN: 2963-4113 and p-ISSN: 2963-3397

GOVERNMENT SUPPORT IN IMPLEMENTING PERMENKES NO. 30 / 2013

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which can be consumed by various types of people. Indonesian people tend to consume

ready-to-eat or packaged food products that contain salt, sugar, calories, and high fat rather

than fresh food ingredients (Agrina et al., 2011). As humans, we need adequate nutrition from

the food we eat. However, if the nutrition we consume is unbalanced it can cause various

health problems such as obesity, diabetes, malnutrition, and the risk of heart disease.

According to Sinta in her research told that;

“The problem of obesity in Indonesia is increasing every year. In 2013 obesity in the male

population reached 19.7%, which was higher than data in 2010 which amounted to 7.8%. In

2013 the problem of obesity in the female population reached 32.9%, more than the 2010 data

which only amounted to 15.5%. Based on the 2018 Basic Health Research, the obesity rate

increased from 14.8% to 21.8% (Midah et al., 2021). The development of non-communicable

diseases is also a record because there has been an increase in cases of cancer, stroke, chronic

kidney disease, diabetes mellitus, and hypertension”.

Consumers may consider labels as the material of choice for purchasing a product. The

habit of reading labels carefully and thoroughly has been applied in developed countries,

especially labels regarding nutrition. Information about goods and/or services sold in the

market is important for consumers. The information included includes security, price, method

of use, product quality, guarantees, and other matters related to information on goods and/or

services.

The Consumer Protection Act (UUPK) has regulated consumer rights where in article 4

consumers have the right to know the guarantees and conditions of goods and/or services

clearly, correctly, and honestly. The obligation of business actors to provide clear, correct,

and honest information regarding the goods and/or services offered has been regulated in

UUPK in article 7.

Quoted from the journal Journal of Food Distribution Research: "food labels provide easy

access to nutritional information". It means food labels provide easy access to nutritional

information. As in processed food labels, it is necessary to include information on nutritional

value, especially information on sugar, salt, and total fat contained in processed food, as

stipulated in the Regulation of the Minister of Health. The inclusion of detailed information

on food packaging from processed foods or instant foods is important so that consumers can

measure their daily intake.

Regulation of the Minister of Health Number 63 of 2015, rules regarding the inclusion of

sugar, salt, and fat are also regulated in the POM Agency Regulation Number 22 of 2019

concerning Information on Nutritional Value. In the BPOM Regulation, only products with

MD distribution permits (large companies) are required to include information on nutritional

value, but in the transitional provision article, this obligation applies only to all products with

MD distribution permits for 30 months from the date the regulation comes into force. In this

BPOM regulation, micro and small businesses are not yet required. Meanwhile, the

Regulation of the Minister of Health explains that everyone who produces processed food

containing sugar, salt, and fat is required to include this information on the label so that the

regulation of the Minister of Health covers all levels of society that produce processed food

containing sugar, salt, and fat to include information on the processed food label.

Since the regulation of the Minister of Health No. 63 of 2015 was passed until now, in

fact, there are business actors in Semarang City who do not include information about sugar,

salt, and total fat contained in processed food on their packaging labels by Minister of Health

regulation No. 63 of 2015 junction Regulation of the Minister of Health Number 30 of 2013.

One of the chips business actors in Semarang City, the label does not include information on

sugar, salt, and total fat on the packaging label, by Regulation of the Minister of Health

Number 63 of 2015 in conjunction with Regulation of the Minister of Health Number 30

2013, namely in article 3 paragraph 1 which reads that: "Everyone who produces processed

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food containing sugar, salt and/or fat for trade is required to contain information on the

content of sugar, salt and fat, as well as health messages on processed food." In article 4

paragraph (1) reads: "Information on the content of Sugar, Salt, and Fat as referred to in

Article 3 paragraph 1 consists of the content of total sugar, total sodium, and total fat."

Regulation of the Minister of Health Number 63 of 2015 article 1 concerning changes to

Regulation of the Minister of Health Number 30 of 2013 in article 10 so that the sound is

amended as follows: within a period of 4 (four) years from the promulgation of this

Ministerial Regulation." Even though the Regulation was made with the intention that it can

be implemented effectively, and efficiently, and takes into account the readiness of the

community.

METHOD RESEARCH

This research is included in qualitative research and is descriptive in nature.

This study is an empirical study of laws and policies in Permenkes No. 30 of 2013.

The research was carried out in DKI Jakarta from September to November 2021 with

the primary data collection method through in-depth interviews and Round Table

Discussions with stakeholders at the Indonesian Ministry of Health, the Food and

Drug Supervisory Agency (BPOM), and the Food and Beverage Entrepreneurs

Association Indonesia (GAPMMI), while secondary data is in the form of laws and

regulations, results of previous research and other materials relevant to the purpose

of the study. The data was taken from the results of a study at the Center for

Research and Development of Humanities and Health Management with the title

"Study of Policy for Inclusion of Information on Sugar, Salt, and Fat Content". The

data were analyzed through a qualitative approach which interpreted the data from

the study and focused on social phenomena.

RESULT AND DISCUSSION

Table 1. Obligations that must be listed on food labels based on Perka BPOM No.

HK.00.06.51.0475 concerning Guidelines for the Inclusion of Information on Nutritional

Values

Information that must be included

Nutrients that Must Be

Listed

Nutritional Substances that

Must Be Listed with Certain

Requirements

1. Serving sizes: BPOM has the

authority to approve serving sizes

for food safety assessments or

registration, which are stated in

metric units such as mg, g, and

ml.

2. Number of Servings per Package:

the number of servings contained

in one food package

3. Saturated Fat: must be stated if it

is present in a significant amount,

namely more than 0.5g per

serving, and/or include a

statement (claim) regarding fat,

fatty acids, or cholesterol and/or

include the energy value of

saturated fat. However, it does not

need to be stated for food

1. Total Energy: comes

from fat, protein, and

carbohydrates in units of

kcal per serving

2. Total Fat: the content of

all fatty acids in food

expressed in

triglycerides in units of

grams per serving and

the percentage of RDA

of fat

3. Protein: the content of

all amino acids in food

products is stated in

grams per serving, and

the percentage of RDA

4. Total Carbohydrates:

includes sugar, starch,

1. Energy from Fat: Energy

from fat must be included if

it is present in a significant

amount, namely more than

0.5 grams of fat, but it does

not need to be stated for food

intended for children aged 6

to 24 months

2. Saturated Fat: must be stated

if it is present in a significant

amount, namely more than

0.5g per serving, and/or

include a statement (claim)

regarding fat, fatty acids, or

cholesterol and/or include

the energy value of saturated

fat. However, it does not

need to be stated for food

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intended for children aged 6 to 24

months

dietary fiber, and other

carbohydrate

components listed in

grams per serving and

percentage RDA

1. 5. Sodium: expressed in

milligrams per serving

and AKG percentage

intended for children aged 6

to 24 months

3. Trans Fat: must be stated if it

is present in a significant

amount, namely more than

0.5 gram per serving, and/or

include a statement (claim)

regarding fat, fatty acid, or

cholesterol

4. Cholesterol: must be stated if

it is present in significant

quantities, namely more than

2 mg per serving, and/or

include statements (claims)

regarding fat, fatty acids, or

cholesterol

5. Dietary fiber: must be stated

if it is present in a significant

amount, which is more than

0.5 gram per serving

6. Sugar: must be stated if it is

present in significant

quantities, namely more than

1 gram per serving, and/or

include a statement (claim)

regarding the content of

sugar, sugar alcohol, or

sweetener

7. Vitamins A, C, Iron, and

Calcium: must be stated if

they are present in significant

quantities, namely more than

2% of the RDA per serving

and/or statements (claims)

regarding Vitamins A, C,

Iron and Calcium

From the table above it can be seen that the inclusion of nutritional labels has not been

fully attached to food products in other words, it is still voluntary (Kemenkes RI, 2008). So to

implement Permenkes No. 30 of 2013 it is necessary to amend Perka BPOM No.

HK.00.06.51.047.

A. National Policy regarding the Obligation to Include Information on Sugar, Salt, and

Fat Content for Processed Foods

Inclusion of information on the content of sugar, salt, and fat in Food Labels based on

Permenkes No. 30 of 2013 is an obligation for every individual or corporation, both legal

entities and non-legal entities that produce processed food containing sugar, salt, and/or fat

for trade (Saputro, 2018). This is by the mandate of Law no. 36 of 2009 where the

standardization of food and beverages consumed by the public, having a distribution permit,

and the use of labels for packaged food an obligation that must be carried out by everyone

producing processed food. The impact of non-fulfilment of these obligations is a ban on

circulation, withdrawal from circulation, and distribution permits revoked and confiscated

which are then destroyed. The provisions for standardization in the food and beverage sector

have created an obligation to supervise the Food and Drug Supervisory Agency (BPOM)

from the process of production, processing, and distribution of food and beverages, while

supervision in the context of prevention, control, and handling of non-communicable diseases

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is carried out by the Ministry of Health with the Regional Government. and can involve the

active role of the community.

The obligation to label processed food is also regulated in Law no. 18 of 2012

concerning Food whereby everyone who produces domestic food to be traded and everyone

who imports food to be traded after entering Indonesian territory is required to include labels

in and/or on food packages written or printed in Indonesian which contains at least

information regarding a) product name; b) list of materials used; c) net weight or net content;

d) the name and address of the party producing or importing; e) lawful for those required; f)

production date and code, date, month and year of expiry; g) distribution permit number for

processed food; and f) the origin of certain foodstuffs. Information on the content of sugar,

salt, and fat in food and beverages is not a minimum requirement in Law no. 18 of 2012.

Based on PP No. 69 of 1999 concerning Food Labels and Advertisements states:

“Whereas information about materials used in food production activities or processes is

listed on labels as ingredients sequentially starting from the most abundant part, except for

vitamins, minerals, and other nutritional enhancing substances. Based on Perka BPOM No.

HK.00.06.51.0475 concerning Guidelines for the Inclusion of Nutritional Value Information

on Food Labels, what is meant by other nutrients in the form of carbohydrates, proteins, fats,

and their components and their derivatives including energy. It means that sugar, salt, and fat

are other types of nutritional content in food. In addition, the nature of mandatory nutrition

labels is only for products that include claims, and are required by laws and regulations. The

mandatory nature of the inclusion of information on the content of sugar, salt, and fat in

Permenkes No. 30 of 2013 is not in sync with Perka BPOM No. HK.00.06.51.047512.” [11]

Information on labelling regulations that apply in several countries, namely the Food

Labelling Guide (FDA) that applies in the United States, Labelling of Packaged Food that

applies in Australia, and Euro Council 2000/13/EC that applies in the European Union and is

a revision of Euro Council 79 /112/EC. In addition, there are also labelling regulations issued

by the Codex Alimentarius Commission (Codex Stan 1-1985) (Hikmatiar, 2013; Gunanta,

2007)13. Regulations in the United States and Australia require nutritional information to be

included on food labels. If you look at the minimum provisions for nutritional information in

PP no. 69/1999, the inclusion of information on the content of sugar, salt and fat is not an

obligation, but "in a limited way" the obligation is for the inclusion of nutrients on food labels

as regulated in BPOM Head Regulation No. HK.00.06.5112. This means that not all

processed food is required to implement the policy in Permenkes No. 30 of 2013. The BPOM

regulation states that not all food labels are required to include information on nutritional

value, except for food labels accompanied by a statement that food contains vitamins,

minerals, and/or other substances which are added or required based on the provisions of the

laws and regulations applicable in the field of quality. and food nutrition, it is obligatory to

include vitamins, minerals, and or other nutritional substances. What is meant by other

nutrients are carbohydrates, proteins, fats, and their components and their derivatives,

including energy (Kusnandar, 2019)..

B. Government Support in Implementation of Permenkes No. 30 of 2013

The eat more campaign is currently rolling out in television commercials. The results of

discussions with several public health and nutrition practitioners stated that advertisements on

television convey more that their processed food products are healthy, but the public has

limited knowledge of the extent to which advertised food is healthy, nutritious, or non-

nutritious, so it needs to be strengthened through more specific regulations. Under these

conditions, the Government must further strengthen regulations not only aiming at educating

good nutrition to the public but also trying to promote good eating habits, including reading

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processed food labels, as well as regulating food distribution to consumers. Four factors

influence public education, namely experience, environment, food availability, and related

policies/regulations from procurement to distribution.

The industry agrees that the inclusion of nutritional values on labels is a form of

education to the public, but providing understanding to the public through food labels will

take quite a long time (Nomor, 18 C.E.). This shows that information through advertisements

on television is more effective than through food labels. Furthermore, it was stated that the

first step that must be taken by the Government is to carry out public health promotion in

schools or posyandu and posbindu because that will be clearer and on target (Nuriyanto,

2020).

In connection with the implementation of Permenkes No. 30 of 2013 in tackling non-

communicable diseases by reducing the level of consumption of sugar, salt, and fat in the

food industry argues that it is necessary to study in advance which types of food can be

applied first because so far, the government has only limited it through regulations, but there

is no explanation of how to implement it and the standard because it can have an impact on

industrial management. In addition, the industry provides input that it is necessary to

synchronize the policies of the Ministry of Health and the Ministry of Agriculture regarding

food availability in the community because if the Government advises consuming lots of

fruit, but the agricultural sector does not have enough fruit available or the price of fruit is not

affordable for the community (Kagira et al., 2012). Then it will be unacceptable effective.

In general, the results of discussions with the food industry are ready to implement a

policy of including information on the content of sugar, salt, and fat in their processed food.

Some of the inputs from the food industry include that the food industry needs

encouragement so that it can play an active role in producing healthier food. The food

industry offers several strategies as have been implemented in several developed countries

such as increasing the image of the food industry organization (organizational and corporate

image) through a framework of cooperation through Public-Private Partnerships (public-

private partnership) to reduce sugar, salt, and fat in the food industry. processed food

products that are carried out in stages. It is hoped that this partnership can trigger more and

more other food industries to get involved, for example in the Public Health Responsibility

Deal that has been carried out in England and the Millan Declaration in Switzerland (Wyness

et al., 2012)

As for support from the government in efforts to implement Permenkes no 30 of 2013:

1. Sugar reduction through Community-Based Intervention Strategy and Imposition of

Import Tax

The intervention strategy of reducing sugar has been carried out by WHO using a

community-based intervention approach, namely the imposition of a tax on food

containing sugar. However, the results of data confirmation at the P2PTM Directorate, the

approach to imposing a tax on sugar is predicted to have problems at this time because the

current Ministry of Finance policy only provides restrictions in the form of a limited tax

on alcohol and tobacco products. So that a policy change is needed if you are going to add

sugar as a substance that is subject to tax, and you must have strong and scientific reasons

that consuming sugar is considered harmful to the environment (McLean-Meyinsse et al.,

2011). He further explained that basically the imposition of a sugar tax can be carried out

on food containing more than 10% sugar because currently the danger of sugar to health

can be seen from beverage products that contain high sugar which is consumed by many

children.

2. Salt reduction through food reformulation approach

Efforts that can be made by the Government in reducing the prevalence of non-

communicable diseases caused by salt consumption is through the reformulation of salt in

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food products. For example, instant noodles in Indonesia currently contain a high level of

salt, so it is necessary to reformulate the salt content. The reformulation approach is

carried out by considering the benefits of both parties (win-win solution) between the

interests of the food industry and the Government because in the end if many consumers

are sick, producers will lose the market because sick consumers cannot consume the

products they produce.

3. Deregulation of Trans-Fat Bans

Trans fat is a type of unsaturated fatty acid and can be classified as natural or

industrially produced using industrial processing techniques. The prohibition on the use

of trans fats in Indonesia can be seen in Perka BPOM No. 21 of 2016 concerning Food

Categories (Kristiyanti, 2016). Foods with the category of vegetable fats and oils such as

cooking oil (frying oil) must have basic characteristics with a trans fatty acid content of

0% of total fatty acids, the same is true for solid cooking oil (frying fat). Indonesia's steps

in limiting the use of trans fat must consider several policy options including legislative

limits on trans fat content, voluntary reduction by food industry players and the use of

trans fat, and mandatory labelling of trans fat. Setting legal limits on the use of trans fats

in all food products is probably the most effective option to reduce the number of people

who consume artificial trans fats and thus potentially reduce the risk of disease. It is

possible that mandatory labelling and voluntary reformulation will face obstacles,

especially in unpackaged food products and food produced by small and medium

enterprises may continue to contain trans fats.

CONCLUSION

The policy for including information on the content of sugar, salt, and fat as well as

health messages for processed food needs to be accompanied by changes to the Guidelines

for Inclusion of Information on Nutritional Value on Food Labels. Basically, the food

industry in Indonesia can carry out a policy of including information on sugar, salt, and fat

content as well as health messages for processed food. But to implement this policy, the food

industry offers a public-private partnership model, namely the Public Health Responsibility

Deal as has been done in the UK. and the Millan Declaration in Switzerland. The aim is to

improve the image of the organization where the food industry can play an active role in

efforts to reduce the intake of sugar, salt, and fat in food products which are done in stages.

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Istiana Sari, Darwati

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