Halal Food Packaging Requirements: What Exporters Must Know

Why Packaging Is a Halal Compliance Issue

Many food exporters focus their halal compliance efforts on formulation and production — ensuring that ingredients are permissible and that facilities are free from cross-contamination. Packaging, however, is an equally important dimension of halal compliance that is frequently underestimated. The materials used to make packaging, the inks and adhesives applied to it, the claims and marks displayed on it, and the language in which information is presented are all subject to halal standards and local regulatory requirements that vary by destination market.

Errors in packaging compliance can result in shipments being held at customs, products being de-listed by retailers, certificates being suspended, and — in markets where halal labelling is legally regulated — administrative penalties. This guide covers the key packaging requirements that food exporters must understand before entering halal markets.

Packaging Materials and Halal Compliance

Primary Packaging Materials

The primary packaging that directly contacts food must be free from substances derived from prohibited sources. Potential compliance issues in common packaging materials include:

• Gelatin-coated films and casings: Gelatin used in edible films, sausage casings, and certain confectionery coatings must come from halal-certified and properly slaughtered animals (typically bovine or fish), not porcine sources. This must be documented with supplier declarations.
• Plasticisers in flexible packaging: Some plasticisers used in PVC films and other flexible plastics are derived from animal sources. Manufacturers should request material safety data sheets and declarations of conformity from their packaging suppliers.
• Carmine (E120) in packaging coatings: Carmine, a red pigment derived from cochineal insects, is prohibited under most halal standards. It sometimes appears in food contact coatings or printed decorations on packaging.

Printing Inks and Adhesives

This is one of the most commonly overlooked areas of halal packaging compliance. Some printing inks — particularly those used in flexographic and gravure printing — contain alcohol-based solvents or animal-derived additives (such as shellac, which is derived from the lac insect). Similarly, adhesives used in lamination and labelling sometimes contain animal-derived binding agents.

The practical implication for exporters is that they should request halal compliance declarations from their packaging converters and ink suppliers. Certifiers in stringent markets — particularly JAKIM in Malaysia — may request documentation on inks and adhesives as part of the audit process.

Secondary and Tertiary Packaging

Most halal standards focus their material requirements on primary (food-contact) packaging. Secondary packaging (outer cartons, corrugated boxes) and tertiary packaging (pallets, stretch wrap) are generally subject to less stringent material requirements, though some certifiers do require that secondary packaging not bear imagery or text that is offensive under Islamic principles.

Halal Logo and Mark Requirements

Only Use Certified Marks

A fundamental rule of halal labelling is that no halal claim, mark, or logo may appear on packaging unless the product has received valid certification from an accredited body authorising its use. Using a halal logo without certification — or using a logo from one certifier for a product certified by a different body — is fraudulent and can have serious legal consequences in markets where halal labelling is legally regulated.

Market-Specific Logo Rules

Malaysia: Products bearing the JAKIM halal logo must use the officially approved JAKIM logo artwork without modification. The logo dimensions, colours (green is standard), and placement are specified in JAKIM's guidelines. Products may not use any logo that resembles the JAKIM logo without holding valid JAKIM certification.

Indonesia: MUI's halal logo has specific artwork requirements. Under BPJPH's framework, a new standardised halal label design is being rolled out. Exporters to Indonesia should verify the current approved mark format with BPJPH or their LPH (inspection body).

UAE/GCC: The UAE uses specific halal mark designs accredited by ESMA. GCC countries may each have slightly different approved marks. Exporters should ensure the mark used corresponds to the specific certifier and market.

General principle: When in doubt, display the certifier's name in text alongside their approved logo rather than creating your own halal iconography. Text-based claims ("Certified Halal by [Certifier Name] — Certificate No. [XXXX]") are generally lower risk than graphical halal marks if there is any uncertainty about logo rights.

Labelling Laws by Market

Malaysia

Malaysia's Trade Descriptions Act and the Trade Descriptions (Definition of Halal) Order regulate halal claims. Making false halal claims is a criminal offence. Imported products bearing the JAKIM logo must hold valid JAKIM certification. Product labels must display the manufacturer's name and address, ingredient list, net weight, and country of origin in addition to any halal mark.

Indonesia

Indonesia's Halal Product Assurance Law mandates halal labelling (with the approved government halal mark) for all products covered by the regulation — a category that has been progressively expanded and includes most food and beverage products. Products without valid halal certification must explicitly state that they are "not halal" in specified categories. Labels must include a Bahasa Indonesia translation of key information for products sold domestically.

Saudi Arabia

All imported food products require Arabic-language labels. The halal certificate number must appear on the label for products where halal certification is required. SFDA publishes specific labelling requirements for different product categories. Shelf life, storage conditions, and country of origin are mandatory label elements.

United Arab Emirates

UAE Federal Law on Food Safety and associated cabinet decisions govern food labelling. Labels must be in Arabic (English is permitted in addition). Halal certification must be from an ESMA-accredited or UAE-recognised body. Products must declare all ingredients, allergens, and additives.

United Kingdom

Post-Brexit, the UK has its own food labelling regulations derived from retained EU law. There is no mandatory halal certification requirement under UK law — halal claims are voluntary but must be truthful and verifiable. Retailers may impose their own supplier requirements that include halal certification. The UK's Trading Standards authorities have the power to investigate misleading food claims.

Ingredient Disclosure Requirements

Halal compliance and food labelling law both require full disclosure of ingredients. Key considerations for exporters:

• E-numbers and additives: Many food additives have halal-status implications. Common examples include E120 (carmine — prohibited), E441 (gelatin — source-dependent), E471 (mono- and diglycerides — source-dependent). Ingredient lists must identify additives in a way that allows consumers to assess halal status, either by name or by E-number where local law permits.
• Compound ingredients: Ingredients that are themselves composed of multiple sub-ingredients (e.g., flavourings, seasoning mixes) must be declared in sufficient detail to allow halal assessment. Some markets require full sub-ingredient declaration for compound ingredients above a certain weight percentage.
• Allergen declarations: While not strictly a halal issue, allergen declarations are mandatory in most target markets and must be displayed prominently. Non-compliance is a common reason for shipment rejection.

Codex Alimentarius Halal Standards

The Codex Alimentarius Commission — a joint body of the World Health Organization and the Food and Agriculture Organization — has published two key documents relevant to halal food trade:

• CXG 24-1997: General Guidelines for Use of the Term "Halal": This document defines halal food from a Codex perspective, identifying prohibited ingredients and practices. It provides a baseline that many national regulatory authorities reference when developing domestic halal standards.
• CXS 1-1985 (General Standard for the Labelling of Prepackaged Foods): While not halal-specific, this standard provides the framework that most national food labelling regulations build upon, including requirements that are relevant to halal claim presentation.

Codex standards are not legally binding of themselves but carry significant weight in World Trade Organization disputes and are the reference point for determining whether national standards constitute technical barriers to trade. Exporters whose packaging complies with Codex halal guidelines are in a strong position if labelling compliance is questioned in a WTO context.

Practical Checklist for Halal Packaging Compliance

1. Obtain written declarations from packaging material suppliers confirming the halal status of all primary packaging components.
2. Request ink and adhesive formulation information from your packaging converter and verify against your certifier's requirements.
3. Use only the officially approved halal logo artwork from your certifying body — do not alter colours, proportions, or design.
4. Verify that your certification is current and valid before printing the halal mark on any packaging run.
5. Check the specific labelling language requirements for each destination market — Arabic, Bahasa, or local language requirements vary.
6. Ensure all ingredients, including additives and compound ingredients, are fully declared in accordance with local law.
7. Keep a packaging compliance file: retain supplier declarations, certifier artwork permissions, and label approval records.

Conclusion

Halal food packaging compliance is not simply a matter of adding a logo to an existing label. It encompasses material selection, ink and adhesive choices, logo rights management, market-specific labelling law compliance, and ingredient disclosure. Exporters who invest in understanding packaging requirements before entering a new market avoid the costly and reputationally damaging experience of shipments refused at the border or products pulled from retailer shelves.