INDONESIA FISH CANNING
Setting Up Fish Canning Company in Indonesia: Ownership, KBLI, and Licences
A canning project reaches lawful production only when the shareholding, current activity code, industrial premises, retort process, processing-unit certificates, and product release all agree.
Fish canning under KBLI 2025 code 10217 is open to foreign investment under Indonesia's current investment-business list, so a 100% foreign-owned PT PMA is generally possible without a mandatory local shareholder. The exact shareholders, related activities, land arrangements, and sector conditions must still be checked before incorporation. A genuinely Indonesian-owned operation may use a local PT.
KBLI 10217 covers fish packed airtight or in cans with retort or pasteurization, including canned sardine, lemuru, mackerel, and tuna. The PT or PT PMA then needs more than an NIB: the applicable high-risk industrial licence, site and environmental approvals, building readiness, SKP, product-scope HACCP, BPOM production and product controls where applicable, halal compliance, and domestic or export market authorization must be completed before the relevant product is released.
Key takeaways
- KBLI 10217 is generally open to 100% foreign ownership, subject to checking the complete business model and current sector conditions.
- New projects should use the KBLI 2025 canning code rather than copying the former 2020 code 10221.
- A PT PMA needs at least IDR 2.5 billion paid-up capital and an investment plan above IDR 10 billion per code and project location under the general rule.
- Commercial sterility depends on a validated scheduled process, controlled retort operation, container integrity, traceability, and lot release—not the retort purchase alone.
- NIB, factory licensing, SKP/HACCP, BPOM, halal, and destination approvals are separate evidence layers.
Confirm canning is the actual process
The product definition should state fish species, raw-material condition, preparation, cooking, filling medium, additives, container material and size, closure, vacuum or headspace controls, retort or pasteurization method, intended shelf life, storage condition, brand owner, and destination. A metal can, glass jar, retort pouch, or other airtight package can involve related food-safety principles, but the exact KBLI and regulatory path follow the declared process and product.
Do not classify frozen fish, chilled fish, smoked fish, or ready meals as canning merely because the same company sells them. The current OSS hierarchy for fish processing separates salting or drying, smoking, freezing, fermentation, mincing, canning, further-processed products, and other methods. Each genuine additional manufacturing line may need another code, project entry, investment allocation, hazard analysis, and product scope.
Also decide whether the company will process its own products, provide contract canning, import ingredients or packaging, distribute finished goods, or export. A service fee, wholesale margin, or import activity can create a supporting revenue code and separate customs or trade work. Record who owns the fish and cans at every stage and who holds the finished-product authorization.
Determine foreign ownership and PT PMA structure
Under Presidential Regulation 10 of 2021 as amended by Presidential Regulation 49 of 2021, KBLI 10217 is not in a restricted or reserved investment category, so 100% foreign ownership is generally available. The official amended investment-business regulation should be checked together with every other code in the business plan. Ownership openness does not waive sector licences.
| Ownership facts | Entity route | Main consequence |
|---|---|---|
| One or more genuine foreign shareholders | PT PMA | PMA capital, investment, OSS, LKPM, and foreign-investment compliance |
| All shares beneficially and legally Indonesian-owned | Local PT | Domestic scale and capital rules, while sector controls still apply |
| Foreign party only tests or coordinates the market | Non-revenue presence may be assessed | Cannot manufacture, invoice canning revenue, or substitute for the licensed plant |
A PT normally has at least two shareholders, one director, and one commissioner. The incorporation deed, AHU approval, beneficial-owner filing, tax identity, registered address, bank mandate, shareholder funding, and authority to sign land, machinery, supply, brand, and distribution contracts should be internally consistent. Avoid nominee ownership that misstates the beneficial arrangement.
For a PT PMA, Minister of Investment and Downstreaming/BKPM Regulation 5 of 2025 generally requires paid-up capital of at least IDR 2.5 billion per PT and an investment plan exceeding IDR 10 billion for each five-digit KBLI at each project location. Land and buildings are generally excluded for manufacturing. Paid-up capital is subject to a 12-month restriction except permitted business uses. Capital is company funding, not a registration charge.
Use KBLI 10217 and supporting codes
BPS Regulation 7 of 2025 introduced KBLI 2025. For a current new filing, OSS identifies KBLI 10217 as fish processing and preservation through airtight packing or canning accompanied by retort or pasteurization. The code includes factory vessels that can fish only in the sense that they process and can without conducting the fishing activity; actual capture operations fall under their own classification.
The former KBLI 2020 canning code for fish and aquatic biota other than shrimp was 10221. Do not carry that old number into a new 2025 project without checking the OSS transition path. Existing companies should compare their historical deed, NIB, project, licenses, and actual product scope before amending; a code migration decision is different from adding a new activity.
Add freezing, cold storage for third parties, wholesale, import, or export classifications only when those activities are real and separately classifiable. An in-line freezer, warehouse, or sales function that supports canning does not always create another revenue code. Conversely, invoicing customers for storage or importing finished goods is not covered merely because the company owns a cannery.
Select the industrial site and premises
Fish canning is manufacturing, so confirm industrial-estate applicability and any documented exception under Minister of Industry Regulation 37 of 2025, together with spatial conformity under Government Regulation 20 of 2024. The property file should cover land or lease rights, KKPR or the applicable spatial route, environmental approval, estate-manager consent, PBG and SLF, fire safety, and local utility or infrastructure conditions. A registered office address cannot replace the factory location.
The site must support raw-fish receiving, chilled or frozen holding, preparation, pre-cooking, filling, exhausting or vacuum control, closure, retorting or pasteurization, cooling, drying, coding, incubation or hold, finished-goods storage, laboratory work, and dispatch. Separate personnel, waste, chemicals, packaging, unprocessed product, retorted product, and released stock. Confirm steam, boiler, water, cooling water, electricity, drainage, wastewater, fish-waste handling, ventilation, compressed air, and backup needs.
Do not lease a shell around an untested process
Put the capacity, can sizes, retort type, boiler demand, water load, wastewater, floor loading, drainage, fire controls, and hygienic zones into the site test. Make the property commitment conditional on a verified route for the intended factory and alterations.
Complete OSS, industrial, and fisheries licences
Government Regulation 28 of 2025 is the current general risk-based licensing framework. A PT PMA is a large-scale project, and the current OSS risk output for its exact scope should be treated as controlling. The company obtains an NIB and then completes the high-risk industrial licence and its technical conditions before commercial production. An NIB allows the project to be identified and prepared; it is not the operating licence for the finished cannery.
- Form the company and align its deed, ownership, address, capital, tax, and beneficial-owner records.
- Create the OSS project using KBLI 10217, location, capacity, investment, machinery, energy, water, workforce, and raw-material data.
- Close spatial, environmental, estate, building, fire, boiler, utility, and other site conditions that apply.
- Complete the industrial licence with the required production flow, machinery, layout, quality-control equipment, and operating evidence.
- Obtain the Processing Feasibility Certificate, or SKP, and the relevant product-and-process HACCP scope through the fisheries-quality route.
SKP demonstrates that the unit applies good handling or manufacturing practices and sanitation standard operating procedures. HACCP builds on those prerequisites for the named product and process. KKP confirms that SKP and HACCP applications are integrated through OSS with document and/or field verification, and that SKP is a prerequisite in the relevant export HACCP pathway. The approved scope must match the actual line.
Each licence answers a different question. The fastest way to identify a gap is to require one final artifact for the entity, site, factory, processing unit, product, and destination before release.
Validate the retort, container, and food-safety system
Commercially sterile fish products require a scheduled process developed for the actual formula, product characteristics, fill, container dimensions and material, closure, retort type, loading pattern, heating medium, venting, come-up behavior, process temperature and time, cooling, and local conditions. A competent process authority or qualified specialist should establish and document the process. Operators need training and records that demonstrate every lot followed it.
Raw-material controls remain critical before thermal processing. Approve suppliers and document species, source legality, catch or landing information where required, lot identity, transport time and temperature, sensory acceptance, and relevant chemical or microbiological testing. For susceptible fish, the hazard analysis should address time-temperature exposure and histamine risk before the cans enter the retort. Cooking cannot be treated as a universal correction for compromised or untraceable raw fish.
Container integrity is a second control system. For metal cans, specifications, incoming inspection, seam setup, routine seam measurements, teardown, coding, handling damage, corrosion, leakage, and cooling-water hygiene must be controlled. Other airtight formats require their own seal and package-integrity evidence. A satisfactory retort chart cannot rescue a leaking closure, and a sound seam cannot rescue an inadequate thermal process.
BPOM Regulation 10 of 2023 governs application of a food-safety risk management program at processed-food production facilities and includes commercially sterile food within its implementation. The official BPOM PMR implementation explanation should be assessed alongside CPPOB requirements and the OSS supporting permits shown for KBLI 10217. Applicability and the exact permit route depend on the facility and product scope.
Lot-release minimum evidence
Link raw-fish lot, recipe and fill record, container and closure checks, retort identification, scheduled-process parameters, deviations and disposition, cooling, product code, hold or incubation, laboratory results where required, and quality authorization. Deviations need documented expert evaluation rather than automatic release.
Authorize each canned-fish product and market
A licensed factory does not automatically authorize every retail product. For Indonesian distribution, determine the responsible manufacturer and authorization holder, BPOM distribution authorization, recipe and food-additive compliance, packaging, shelf-life evidence, Indonesian label, nutrition and claims, and halal certification. A change in fish species, filling medium, net weight, can dimension, thermal schedule, brand arrangement, or label can trigger technical and regulatory review.
For exports, identify the destination before the line is validated. The importing country or buyer may require establishment listing, a specific HACCP scope, process filing or technical review, health certificates, laboratory tests, catch or origin records, labeling, container standards, and importer approval. Indonesian customs and export documentation form another layer. Buyer standards should be labeled as contractual when they exceed Indonesian law.
Build change control into the product file. A substitute can supplier, altered seam specification, new retort basket, faster line speed, different fill weight, changed thickener, larger fish pieces, modified cooling water, or relocated temperature sensor can affect the validated system. Quality, engineering, regulatory, and production owners should assess the change before use, identify required revalidation or product variation filings, and retain the approval with the affected lot records.
Use a SKU matrix with product name, species, recipe, fill, container, closure, scheduled process, plant line, SKP/HACCP scope, BPOM status, halal status, label owner, destination, tests, certificates, importer, and release signatory. Commercial production begins only for combinations that pass the matrix; a pending variation should remain on hold.
Release the canned-fish line only on evidence
Proceed when ownership and director authority are documented, KBLI 10217 accurately describes the line, the PT PMA capital and investment plan are funded, the industrial premises can lawfully host the designed process, and the company holds effective industrial, SKP, HACCP, BPOM, halal, and market evidence applicable to the first SKU. Commission the utility, seamer, retort, controls, laboratory, traceability, and hold-and-release process before commercial inventory enters the line.
Stop if the scheduled process is generic, the can size or formula is outside validation, the building approval does not cover the installation, a licence remains in preparation status, or the product and destination owner are unclear. Resolve the named gap and repeat only the affected verification. The decision target is not “company registered”; it is one identifiable canned-fish lot that the licensed company can manufacture, evaluate, release, and sell to a named market. After launch, track licence conditions, surveillance, calibration, process deviations, product changes, environmental monitoring, tax, employment, and LKPM reporting in one accountable compliance calendar. Assign every obligation to a named role and retained completion artifact.
Frequently asked questions
Does a foreign investor need an Indonesian shareholder for KBLI 10217?
Generally no. The current investment list treats KBLI 10217 as open, so 100% foreign ownership is ordinarily possible through a PT PMA. Check every additional activity and current sector condition before finalizing the shares.
Is KBLI 10221 still the code for a new fish cannery?
No for a current new KBLI 2025 filing. Fish canning is now KBLI 10217. An existing company's historical code and transition status should be reviewed before any amendment.
Is HACCP enough to sell canned fish in Indonesia?
No. HACCP controls the defined product and process. The company still needs the applicable corporate, OSS, industrial, site, SKP, BPOM production and product, labeling, halal, and distribution approvals for the intended sale.
