When to use: step 5 of the foreign certification workflow — converting audit evidence into the LPH report that BPJPH and MUI will rely on.
Related: on-site audit · typical findings card · criteria pages
1. Anatomy of a good finding (NC)
Every NC must answer four questions so the company can act and the regulator can trust it:
- What is the requirement? (criterion + the specific SJPH element or rule text)
- What did we observe? (objective evidence: document name/number, batch, date, photo ref)
- Why does it matter? (the halal risk — contamination, unapproved material, unproven claim)
- What must change? (required corrective action, owner, deadline)
Write NCs that are verifiable: “material X (invoice no. …, dated …) has no halal certificate from a BPJPH-recognized body” — not “materials lack certificates” without specifics.
Classify findings per your LPH’s convention (e.g., major/minor/observation 🔎 — confirm with the LPH’s reporting rules), and separate NCs from observations and from surveillance items.
2. Report structure (suggested)
1. File & scope applicant, products, facility(ies), audit dates, criteria audited,
exclusions, participants
2. Company profile registry identity (USCC), licenses, production reality (OEM/分装?)
3. Desk-review summary what was reviewed, status at entry
4. Results by criterion 1–5: requirement → evidence verified → findings (see §3)
5. Non-conformities numbered NC list with the four-part anatomy
6. Sampling & lab samples taken, chain of custody, lab results (if any)
7. Conclusion & recommendation certificate recommendation or conditional / not ready
8. Annexes photos, stamped document copies, translation provenance
3. Results table per criterion
| Criterion | Evidence verified | Compliant | Findings |
|---|---|---|---|
| 1 Commitment & Responsibility | policy, decrees, competency, training records | ✅/❌ | NC-xx |
| 2 Materials | matrix, certificates, flowchart/statements, alcohol logic | ✅/❌ | NC-xx |
| 3 Process | flowchart vs floor, facility, records reconciliation | ✅/❌ | NC-xx |
| 4 Products | labels vs matrix, naming/design screen, product list | ✅/❌ | NC-xx |
| 5 Monitoring & Evaluation | internal audit, management review, CAPA | ✅/❌ | NC-xx |
Use the filled internal audit (32-item) and management review examples as the model for how compliant items read.
4. Evidence and annexes
- Every NC maps to a photo or a stamped document copy with a reference number in the annex.
- For China files, record translation provenance: which documents were translated, by whom, and whether they were official (公章-sealed) copies.
- Keep the reconciliation calculations in an annex (purchases ↔ batching ↔ sales windows) — they are your strongest objective evidence.
- Attach the material evidence decisions: which certificates were accepted (with LHLN verification date), which flowchart+animal-free statements were accepted, which materials were rejected and why.
5. Handling borderline cases
- Statement vs certificate: flowchart + animal-free statement is only valid for genuinely non-animal, mechanically/physically processed materials (see criterion 2 §2). If in doubt, escalate to cert-or-replace.
- Alcohol: khamr-source = haram at any level; non-khamr ethanol ≤0.5% (max 0.49%). If the source cannot be proven, treat as non-compliant (see criterion 2 §4).
- Recognized bodies: any certificate whose issuer is not on the live LHLN list at the audit date is not evidence.
- When evidence is genuinely ambiguous, mark the finding “insufficient evidence” instead of guessing — BPJPH/MUI need facts, not inferences.
6. Tone and language
- Report in the LPH’s official language; keep Chinese/Indonesian terms where precision demands (annex a glossary reference — see glossary).
- Findings must be respectful but unambiguous: this is a technical document, not a client-relations exercise.
- Draft within a week of the audit (memory and photo context degrade fast).
7. Checklist before submission
- Every NC: requirement + evidence + risk + required action, verifiable and specific
- Results table complete for all 5 criteria
- Sampling/logistics documented; lab results attached or status stated
- Translation provenance recorded for China documents
- Annex references resolve (photos, documents, calculations)
- Recommendation stated (recommend / conditional / not ready) with conditions listed