Halal compliance, the big issue?
One of the areas that our International Regulatory Affairs team frequently get asked about is compliance with Halal requirements – and understandably so, as the situation is complicated! This white paper gives some background on the requirements of Halal, and associated legislation.
What is Halal?
To understand Halal, we advise referring to the Halal guidelines that are laid down in Codex Alimentarius CAC/GL 24-1997 on General Guidelines for use of the term Halal. This standard provides the background information needed to understand what it means to be Halal "permitted" and "non Halal" and therefore considered unlawful. This guideline includes a few examples of lawful "permitted" food, additives etc, and is a useful guide when looking at a product formulation to determine if Halal compliance is even a possibility.
A question we often get asked is whether Halal is a mandatory requirement on all food products or only on specific products? The answer is that Halal principally concerns meat products. However, there are certain additives where the origin must be stated as to whether it is from an animal or vegetable origin. There are also questions around enzymes, rennet and gelatine. In addition, alcohol is not permitted and therefore is considered to be not Halal, Finally, any pork and pork products are also not Halal. Therefore a product with pork gelatine is not permitted according to Halal requirements, and is therefore not Halal.
It is also stated in Codex that when a claim is made that a food is Halal, the word Halal or equivalent terms should appear on the label. However, it is important to consider in addition to the Codex guideline that it is necessary to be compliant with country specific Halal standards when applicable.
The International Challenge
Halal compliance is of particular relevance when it comes to exporting to the GCC, Indonesia, Malaysia, and Middle East, but it also has significance all over the world. The main challenge faced by manufacturers is that Halal standards differ between countries – some ingredients that may be Halal in some countries are either "questionable" or "not permitted" in others. Therefore, although there might be overlap between Halal requirements in various countries, the differences are such that products will need to be checked for compliance for each individual export market.
Gulf Cooperation Council (GCC) countries, which include the UAE, Saudi Arabia, Oman, Qatar, Bahrain, Kuwait and Yemen, have harmonised their Halal standards. But, be aware that these have recently been updated: Previously there were Standards such as GSO 1931/2009 on Halal food part 1- general requirement, also GSO 2055/2010 on Halal food part 2 - guidelines for Halal food certification bodies and the accreditation requirements. Also there was 993/1998 on Animal slaughtering requirements according to Islamic law.