Indonesia’s 2026 compliance rules have changed what it means to source a flavor concentrate. Here’s what every liquid producer needs to understand about TDS and SDS documents.
Not long ago, a flavor was just a flavor. You smelled it, you liked it, you mixed it. Documentation was an afterthought.
That era is over.
Under Indonesia’s incoming regulatory framework (Government Regulation PP 28/2024 and BPOM’s administrative directive PerBPOM 18/2025) the technical documentation attached to every flavor concentrate you use has become the foundation of your product registration. Without it, you cannot submit. And without submission, you cannot sell.
Two documents sit at the centre of this: the Technical Datasheet (TDS) and the Safety Data Sheet (SDS). Most Indonesian liquid producers have never needed to read them carefully. Or read them at all. Now they need to read them like a lawyer.
The TDS: what your flavor is supposed to be
The Technical Datasheet is published by the flavor house. It describes what the product should look, measure, and behave like. Its the manufacturer’s promise to you, stated in numbers.
The numbers that matter for production
Two values on a TDS deserve particular attention for high-volume mixing.
Specific gravity tells you how dense the concentrate is relative to water. For a standard flavor the range sits between 1.010–1.050. It sounds minor, but if you’re producing a 1,000-litre batch and you’re dosing by volume without accounting for density, your declared nicotine concentration can drift. BPOM’s lab will catch that drift. Your registration won’t survive it.
Refractive index is less obvious but equally useful. It’s essentially a fingerprint of the concentrate. Single number that confirms the solvent is pure and the aroma chemicals are present in the right balance. A digital refractometer and thirty seconds of testing per delivery is all it takes to catch a bad batch before it contaminates your production run.
What the primary solvent declaration tells you
A well-structured TDS identifies the carrier solvent and its percentage. “Propylene Glycol (xx%), listed as E1520 under EU Reg. 1333/2008” tells you three things at once: the dominant solvent, its purity standard, and whether it’s food-grade. For your VG/PG ratio calculations (and for your Halal audit) this entry is essential.
The SDS: what your flavor can do to people and the environment
If the TDS is the product’s identity, the SDS is its character reference (including its bad qualities). Structured across 16 mandatory sections under the GHS framework, the SDS is the document BPOM cares most about for ingredient disclosure.
Section 2: hazard classification
This section carries pictograms. A Flammable Liquid Category 3 classification affects how you store the concentrate and what fire safety measures your facility needs. An Eye Damage Category 1 (GHS05) classification, which means irreversible tissue damage on contact, affects what PPE your mixing staff must wear. A BPOM or Ministry of Manpower auditor will check both.
Section 3: ingredient disclosure is the most important section for registration
SDS breaks down the concentrate by its constituent chemicals, each with a CAS number, a concentration range, and the hazard statements assigned to it.
Standard flavor concentrate might contain Propylene Glycol as the dominant carrier, alongside Ethyl Maltol, Furaneol, Ethyl Butyrate, and trace quantities of compounds like Allyl Heptanoate. That last ingredient, even at below 1%, carries an Acute Toxicity classification. The SDS must say so. And when you submit your BPOM registration dossier, you must show that its concentration in your finished liquid is within safe limits. That’s a mass-balance calculation that only works if you have the Section 3 data to start from.
The standards your supplier should already be meeting
When you evaluate a flavor concentrate for use in registered Indonesian products, these references on the TDS and SDS are meaningful signals.
FEMA GRAS / FDA GRAS Every aroma chemical has been toxicologically vetted. This is the baseline for inhalation-grade sourcing, not a bonus feature.
EU REACH compliance Every ingredient in the mixture has been registered with the European Chemicals Agency. Registration requires carcinogenicity, mutagenicity, and reproductive toxicity data. If it has a REACH number, it’s been scrutinised. This is the evidence base that backs up BPOM’s additive safety testing.
Regulation (EC) No 1334/2008 Confirms the flavor doesn’t contain restricted natural toxins like pulegone or safrole above safe thresholds. Critical for passing Indonesia’s prohibited additive testing.
UN1197 transport classification The current correct UN number for liquid flavor concentrates. If a supplier’s SDS still shows UN1169, the document hasn’t been updated since 2023. That’s a problem for air freight and for customs.
The deadlines you need on your wall right now
July 26, 2026 Ingredient disclosure submitted for all registered products. July 26, 2026 Additive safety testing completed via accredited laboratories. July 26, 2026 All SKU packaging transitioned to 10ml or 20ml formats. October 17, 2026 Halal certification required for all flavoring agents.
The Halal deadline deserves its own note. The certification process traces ingredients back to their source. For a concentrate with majority Propylene Glycol, the audit will ask where that PG was derived and whether the production facility maintains segregation from non-Halal processes.
How to spot issues
Not every SDS in circulation is legitimate. Some are outdated. Some are generic. Some are outright fabricated. Here’s what to look for.
Section 3 and Section 11 don’t match. If a chemical is listed as hazardous in the composition table but Section 11 (toxicological information) says “no data available” for that same substance, the document is non-compliant. BPOM will not accept it.
No UFI code. Since 2021, EU-compliant hazardous mixture documents require a 16-digit Unique Formula Identifier. Its absence on a product claiming EU compliance is a meaningful signal about the manufacturer’s standards.
Flash point and packing group conflict. If the TDS lists a 46°C flash point but the SDS assigns Packing Group II (which implies a flash point below 23°C), the document has a fundamental technical error. Any customs authority will flag this.
Generic ingredient descriptions. “Natural and artificial flavoring” in Section 3 is not a chemical disclosure. It is a placeholder. It will not satisfy BPOM’s ingredient disclosure requirement.
What this means for how you source
The practical outcome of all this is straightforward: the quality of your documentation is now tied directly to the quality of your supplier relationship.
A flavor house that provides a complete 16-section GHS-compliant SDS, a detailed TDS with batch-level analytical ranges, and REACH-registered ingredients gives you everything you need for BPOM registration, dual-laboratory verification, and export to the EU or UK. A supplier who sends you a two-page PDF with a generic ingredient list gives you a compliance problem.
Audit your current flavor inventory before the third quarter. For every concentrate you use, ask: do I have a TDS? Do I have a 16-section SDS? Is Section 3 fully populated with CAS numbers and concentration ranges? Is this supplier REACH compliant? Can they provide a Halal certificate before October?
Arkadia supplies REACH-compliant flavor concentrates from professional European flavor houses. With full TDS and SDS documentation included as standard. Talk to our team about your current inventory.
