Estimated reading time: 8 minutes

Ir. Emil Satria
Director of Industrial Food Seafood and Fishery Products (IMHLP) 
Directorate General of Agro Industry, Ministry of Industry 

Dr Jenny Elisabeth 
Director of Wilmar Polytechnic

The palm oil and downstream industry plays an important role from a qualitative aspect, among others, creating economic growth centres in Sumatra, Kalimantan and Eastern Indonesia, driving the production activities of oil palm plantation business activities mainly in the outermost, underdeveloped and remote areas, maintaining economic sovereignty, growing new palm-based industries. From the quantitative aspect, this industry absorbs a workforce of around 5.2 million people, increases upstream and downstream economic value and export value, contributes around 3.5% of GDP, tax revenue and export levies. The latest data, 2021, shows that the number of palm oil processing factories is 104 factories and 137 'repackers with a total production of palm cooking oil (MGS) of around 22.4 million kilo litres and exported 11.82 million tonnes equivalent to 13.13 million kilo litres equal to 12.25 billion US dollars. Currently, the national MGS demand is 5.8 million kilo litres (25.8% of domestic production) to meet MGS consumption of 11.5 litres per person per year.

Some of the benefits of downstreaming the palm oil industry include:

  • Driving productive economic activities through downstream industrialisation to achieve import substitution and investment promotion goals,
  • Improve the trade balance and strengthen the rupiah exchange rate through the export performance of high-value downstream palm oil products,
  • Become a driving force for the development of oil palm producing regions and the national economy, especially the 3T (outermost, underdeveloped, and deepest) regions, control greenhouse gas emissions through the use of renewable transportation fuels - environmentally friendly,renewable) – ramah lingkungan,
  • Achieving food sovereignty and energy sovereignty through the use of biofuels, and receiving support from environmentally friendly and sustainable upstream and downstream palm oil industry operations.

The Journey of Palm Oil Fortification in Indonesia

In 2012, the National Certification Agency (BSN) issued Indonesian National Standard (SNI) 7709:2012 on palm cooking oil. In the SNI, it is clearly stated that every cooking oil circulating in Indonesia must have a vitamin A content of 45 IU. On 13 August 2012, a letter was issued requesting the Minister of Health through letter Number GK/MenKes/280/VIII/2012 to the Minister of Industry so that vitamin A fortified MGS (SNI 7709:2012) can be made mandatory with the consideration that MGS is an appropriate food as an introduction of vitamin A to the community. The letter was based on the fact that the addition of vitamin A content to cooking oil is proven to increase vitamin A levels in vulnerable groups of pregnant women, infants 6-11 months, children under five 12-59 months, school children and adolescents and women of productive age. In 2013, the Ministry of Industry issued Minister of Industry Regulation No. 87/2013 on the mandatory implementation of SNI 7709:2012 starting 27 March 2015 but the implementation was postponed to 27 March 2016 and the second postponement to 31 December 2018. In 2019, SNI 7709-2019 was issued compulsorily with enforcement in accordance with Permenperin 46/2019 but with a transition period until December 2020, and in 2021 the SNI was effectively enforced.

The main difference between SNI 7709:2012 and SNI 7709:2019 is that Permenperin 87 of 2013 states 'with the addition of vitamin A' which can be interpreted as 'vitamin A fortification' while Permenperin 46 of 2019 states 'contains vitamin A and/or provitamin A' which can be interpreted as not only vitamin A fortification but also efforts to maintain provitamin A or beta carotene. In detail, SNI 7709:2012 defines palm cooking oil as food with the main composition of triglycerides derived from palm oil with or without chemical changes including hydrogenation, cooling and has gone through a refining process with the addition of vitamin A. While SNI 7709:2019, palm cooking oil is food with the main composition of triglycerides derived from palm oil that has gone through a fractionation process with or without the addition of other foods and food ingredients, containing vitamin A and/or provitamin A.

Minister of Industry Regulation No. 46/2019 regulates business actors related to producers, packers, company representatives and/or importers. The regulation explains that MGS 'producers' must have fractionation equipment, storage tanks, packaging machines, and quality test equipment. Meanwhile, 'packers' must have storage tanks, packaging machines, and quality test equipment. The regulation also regulates the certification system related to MGS quality testing, production/packaging process audits based on the implementation of ISO 9001:2015 or ISO 22000:2018 or other food-related management systems. Each producer and/or packager is required to submit production reports every 6 months through the national industrial information system (SIINAS).

The government relaxed the mandatory implementation of SNI MGS by issuing Minister of Industry Circular Letter No. 9 of 2022 concerning the relaxation of the policy of mandatory implementation of SNI palm cooking oil in the context of providing people's packaged cooking oil. The circular reads among others "in connection with the government's programme to provide MKGR, the mandatory implementation of palm cooking oil SNI in accordance with Minister of Industry Regulation No. 46 of 2019, is exempted until 31 January 2023. As of 1 February 2023, the mandatory implementation of palm cooking oil SNI will be effective in accordance with Minister of Industry Regulation No. 46 of 2019.

Several obstacles faced in the implementation of SNI for palm cooking oil:

  • The nature of vitamin A: unstable during storage, especially in packaging exposed to oxygen and sunlight which allows a decrease in vitamin A levels circulating in the market; some business actors must add vitamin A levels above 45 IU so that products entering the market still meet the specified quality requirements;
  • There is no domestic production of vitamin A and/or provitamin A so that business actors must import to fulfil their needs; vitamina A dan/atau provitamin A di dalam negeri sehingga pelaku usaha harus mengimpor untuk memenuhi kebutuhan;
  • There is an opinion that palm oil has a fairly high beta carotene content but is lost after the refining, bleaching, and deodorising process so there are efforts to produce red edible oil.

In 2022, BSN was tasked by the President through the Minister of Cooperatives and SMEs to develop SNI for red cooking oil as an effort to empower cooperatives/palm farmers and utilise the palm oil that has not been absorbed by cooking oil factories. SNI for red cooking oil was formulated by Komtek 67-04 Food on a fast track basis. The SNI for red cooking oil has been issued through the decision of the Head of BSN No. 350/KEP/BSN/9/2022 concerning the establishment of SNI 9098:2022 Red Cooking Oil. Red edible oil according to the SNI definition is oil obtained from refining without bleaching and deodorisation, and through the fractionation process of crude palm oil.

The Ministry's rationale for developing the red cooking oil industry is that about 41.44% of the oil palm land area is cultivated by independent farmers who produce about 35% of palm oil. The same thing is done in Malaysia by exporting red cooking oil to China, as well as the Republic of Cameroon to fulfil domestic needs.

Palm Cooking Oil

The government's policy to fortify vitamin A in palm cooking oil has not yet touched bulk cooking oil, which is still around 70% of the circulation in Indonesia. The government has actually issued a regulation banning the circulation of bulk cooking oil through a regulation of the Minister of Trade that regulates mandatory packaging of cooking oil. This regulation has been postponed many times for several reasons.

Starting in 2012, the government had targeted to stop the sale of bulk cooking oil by 2015. In 2016, Permendag number 9/M-DAG/ Per/2/2016, which regulates mandatory packaging of cooking oil, again failed to be implemented and finally Permendag number 36 of 2020, which was promulgated on 2 April 2020, states that bulk cooking oil should no longer be on the market from 1 January 2022 was also not realised. In order to achieve the goal of vitamin A fortification in palm cooking oil, the policy of banning the circulation of bulk cooking oil must be implemented immediately. And in order not to cause too much resistance and problems, the implementation is proposed in stages based on areas or monitoring in the cooking oil industry to reduce the sale of bulk cooking oil.

Vitamin A fortification in bulk oil is rather difficult to do (although it is possible to do so), considering the control process by the government which will be difficult to implement, as well as the very competitive selling price among producers. In addition, cooking oil (in the form of palm olein) sold in bulk is not only for household consumers, but mainly for food industry consumers such as instant noodles, snacks, biscuits, etc. Industrial cooking oil is not included in the category of products that need to be fortified, so in the field it will be difficult to prevent the use of industrial cooking oil sold as bulk cooking oil.

Red Palm Oil

The development of MSM, which is encouraged by the government for MSMEs, will contribute to the goal of the palm cooking oil fortification programme with beta carotene contained in MSM. The SNI for red cooking oil has already been issued. The SNI for palm cooking oil also provides an opportunity to add MSM as a source of beta carotene (pro-vitamin A). With the issuance of the SNI for palm cooking oil that has been revised in the vitamin A form, many parties who previously rejected vitamin A fortification in palm cooking oil have been able to accept it.

Considering that beta carotene is more unstable and more perishable than retinyl-palmitate which is used as a common vitamin A fortificant used in palm cooking oil, it is necessary to further evaluate the role and influence of MSM as a source of vitamin A in the community that consumes it, as well as product turnover in the market associated with MSM quality stability.

Quality of Fortified Palm Cooking Oil and its Monitoring

With the pattern of selling packaged cooking oil that also has secondary packaging in the form of carton boxes, efforts to protect the cooking oil from sun exposure should be maximised to keep vitamin A from spoiling. The placement of cooking oil products to be sold in open spaces is usually only for 1-3 days, due to the high turnover of products in the market. turnover produk di pasar yang cukup tinggi.

Vitamin A damage is triggered more by UV light than by high temperatures, so socialisation and education on the correct handling/storage of vitamin A fortified cooking oil needs to be done to traders and consumers. Avoiding exposure to sunlight or UV light on cooking oil will not only save the vitamin A content, but also maintain the quality of the cooking oil itself from oxidation damage. Oxidation damage to cooking oil can be monitored from the increase in peroxide number, which in many cases is found to increase far from the standards set in food regulations. The limit set by the Codex Alimentarius Commission is a maximum of 10 meq/kg for edible oil, while SNI sets the same value for products that are still in the factory, not consumed.

The SNI regulation has accommodated the concerns of entrepreneurs/industries about the risk of penalties, as a vitamin A content of 45 IU/g is required when palm cooking oil products are still in the factory and the content in the market is still tolerated at a level of 20% of the mandatory concentration.

Rapid test kits for the analysis of vitamin A and beta carotene content in palm cooking oil or MSM need to be developed and produced domestically, so that there is no dependence on imported instruments that are constrained by the import of reagents that are hazardous materials, and at a lower price. Research to find this rapid test kit technology needs to be carried out or offered top down to researchers in universities and research institutions.


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