When to use: steps 1–3 of the foreign certification workflow.
Related: document request template · China operating layer · typical findings
1. Intake — what you need on day one
Collect and record in the file:
- Applicant identity: legal name (Chinese + registered English name if any), 统一社会信用代码 (USCC), registered address, 法定代表人 (legal representative), contact and language (who speaks EN/ID).
- Product scope: product list with 配料表 (ingredient lists), target Indonesian customers/market, and whether the file is for (a) finished products exported to Indonesia or (b) materials (raw materials / additives / processing aids) feeding Indonesian certified products. These are different end-uses; the marketing story matters for scope.
- Production reality: actual factory address, whether production is owned or OEM/委托加工, and whether any repacking 分装 occurs (see §4).
- Existing certificates: ISO/HACCP/FSSC22000/BRC claims, and any halal/清真 certificates held (which body? which country?).
2. Eligibility screen (cheap, do before quoting)
Ask the killer questions early — they decide whether the file can ever close:
- Is the halal supervisor candidate Muslim, appointable, and ready to take the BPJPH-recognized competency exam? (Non-negotiable — see criterion 1.)
- Does any certified product contain meat or animal-derived material not covered by a BPJPH-recognized slaughterhouse/HCB chain? (See criterion 2 — no recognized chain → replacement or no file.)
- Are the main materials halal-certifiable (recognized HCB) or replaceable? A flavor/fermentation material without a cert is the classic hidden blocker.
- Is the facility pork-free or genuinely separable? A site with pork lines/processing is usually not certifiable for the same building.
- Will the company share process flowcharts and batch/sales records? Chinese reluctance here is manageable but must be planned for (NDA, staged requests).
If 1 or 2 fail with no fixable path, say so at intake — do not bill a doomed file.
3. Desk review (document phase)
Send the client document request in tiers: Tier 1 (legal and identity, items 1–8) at intake, Tiers 2–4 two to four weeks ahead. Attach the one-page Guide 06 — client checklist when the client only needs the list, and the client guide — the same requirements written for the company itself, with the fillable forms, the evidence hierarchy explained in plain terms and a printable 中文 checklist — when they need the reasons. Chinese suppliers release material documents slowly and usually only after an NDA (保密协议), so the supplier-dependent tiers are the ones that set your desk-review date.
Two habits make the return usable: keep the numbering identical to the request so the company’s folder mirrors it, and request stamped copies (盖章) with a stated record window (typically the last 6–12 months 🔎) instead of asking for “records” in general.
Review order (highest leverage first):
- Identity verification — GSXT lookup (official registry) vs the license copies provided: name, USCC, 经营范围 (scope), red flags (经营异常/行政处罚). See China operating layer.
- License vs production reality — SC 食品生产许可证 address and category annex (明细表) must match where goods are actually made and what is actually made there.
- SJPH manual & halal policy — signed? sealed (公章)? displayed? supervisor & team decrees current?
- Material list/matrix — complete six classes (see criterion 2)? Every critical material’s evidence identified (cert from recognized HCB, flowchart, animal-free statement, CoA/TDS/MSDS/RDS “free of animal origin” wording)?
- Flowchart — provided? materials annotated per step? any fermentation/solvent/animal step that contradicts the statements?
- Alcohol logic — for anything with ethanol: source declaration (khamr vs non-khamr) and finished-product ≤0.5% (max 0.49%) demonstration. See criterion 2 §4.
- Records preview — a sample of 出入库 (in/out), 投料/批记录 (batching) and sales ledgers to test whether a real cycle exists (see Guide 03 for the reconciliation technique).
4. Red flags seen at desk stage (China files)
- ⚠️ 清真 certificates presented as if BPJPH-recognized — not accepted; explain the LHLN rule.
- ⚠️ Brand owner’s license ≠ actual producer (OEM) — audit must happen at the real plant.
- ⚠️ Material certs from bodies not on the live LHLN list.
- ⚠️ Animal-free letters with no flowchart, or flowchart with a fermentation/extraction step hiding underneath.
- ⚠️ Packaging/cleaning/lubricant materials absent from the material list entirely.
- ⚠️ No ethanol-source declarations for flavors/vanilla-type ingredients.
- ⚠️ Supervisor appointed but exam never scheduled; training records empty.
5. Desk-phase deliverable
Produce a desk review memo mapping every gap to a criterion and an action owner:
| Finding | Criterion | Evidence needed | Owner | Target date |
|---|---|---|---|---|
| … | 1–5 | … | company / LPH | … |
This memo becomes the agenda for the on-site audit and the seed of the final report.
6. Communication & language plan
- Designate one company contact who can communicate in EN/ID or arrange an interpreter.
- Key documents (policy, manual, labels) need translation; record which documents were translated and by whom — the LPH report must state translation provenance.
- Keep a decision log: every material/process change decision dated and filed (links to post-cert duties, Guide 05).