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Halal certification for contract manufacturing

The scheme certifies the manufacturer, not the product. Each product still applies on its own, and each kind of contract work needs a separate application.

What the scheme is, and is not

A company that makes products for other companies under a written agreement must hold a certificate under the contract manufacturing (OEM) scheme before it can offer that service. It is a certificate for the manufacturer's operation. It is not halal certification of what is made.

This is the point brand owners most often miss. Every product that wants to use the halal logo has to apply under the scheme that fits it: food and beverage, cosmetics, pharmaceuticals, consumer goods or medical devices. A brand owner who engages a certified contract manufacturer has certified the factory and nothing else.

Contract manufacturing (OEM) scheme: what the manual requires
RuleWhat the manual says
Certificate firstA company doing contract manufacturing must hold a certificate under this scheme before it can offer contract manufacturing to other companies
Not a product certificateThe scheme cannot be used as halal certification of the manufactured product. Every product that wants to use the halal logo must apply under its own scheme
What can be manufacturedHalal products only, under the food and beverage, cosmetics, pharmaceuticals, consumer goods, slaughterhouse or medical device schemes
Written contractA written contract, agreement or mutual consent to manufacture between the manufacturer and the customer or brand owner
SubcontractorsThe company must make sure any party it appoints to manufacture by contract already holds a certificate
Separate applicationsA separate application is required for each contract manufacturing service. Food and pharmaceutical contract manufacturing, for example, are applied for separately
Merging certificatesMerging certificates is not allowed under the contract manufacturing and logistics schemes

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, pages 50 to 63 · edition of 2020

One application per kind of work

The manual requires a separate application for each contract manufacturing service. A factory that makes both food and pharmaceutical products for clients applies twice. It cannot combine certificates either, because merging is not allowed under this scheme. And if you subcontract part of the work, the company you appoint must already hold a certificate.

For the prerequisites that sit behind each product type (food premises registration, veterinary approval, an NPRA manufacturer's licence, an MDA establishment licence), the manual applies the one that is relevant to what the factory makes. The sector pages cover them: food, cosmetics, pharmaceuticals.

Staffing and system

The staffing bands are the same as for other product schemes. Large and medium contract manufacturers need two permanent Malaysian Muslim employees in the processing area, a Halal Executive, a committee and a HAS. Small ones need one employee, a Halal Supervisor and an IHCS, and micro ones one employee and an IHCS. Note that for a contract manufacturer the requirement is about your floor, not your client's.

Muslim staffing and halal management requirements, by company size
Company sizeMuslim employeesAppointmentCommitteeSystem
Large and medium industryMinimum two permanent Malaysian Muslim employees on duty in the processing area throughout every operating period or shiftHalal Executive at every branch premisesInternal Halal Committee for the premises and for each branch under separate operational managementHAS developed and implemented per the MHMS 2020 manual
Small industryMinimum one permanent Malaysian Muslim employee on duty in the processing area throughout every operating period or shiftHalal Supervisor at the premisesNot separately requiredIHCS developed and implemented per the MHMS 2020 manual
Micro industryMinimum one permanent Malaysian Muslim employee on duty in the processing area throughout every operating period or shiftNot separately requiredNot separately requiredIHCS developed and implemented per the MHMS 2020 manual

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, Prosedur 19, page 31 · edition of 2020

Companies registered abroad

The fee structure differs for a company registered outside Malaysia that manufactures in Malaysia. The processing fee is RM200 instead of RM20, and the statutory fee for contract manufacturing is charged per application and depends on where the applicant is registered.

Application processing fee
ApplicantFee per application
Registered in MalaysiaRM20
Registered abroad, manufacturing in MalaysiaRM200

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, Bahagian III, page 13 · edition of 2020

Contract manufacturing, foreign-registered applicant: statutory fee per application
Applicant categoryCriteriaFee (per application)
ASEAN countriesApplicant registered in an ASEAN member stateRM2,500
Other countriesApplicant registered elsewhereRM10,000

Source: JAKIM, Manual Prosedur Pensijilan Halal Malaysia (Domestik) 2020, Bahagian III, page 14 · edition of 2020

The certificate is valid for two years for a company registered abroad that carries on manufacturing in Malaysia, and three years under the contract manufacturing scheme itself. A reprint for a foreign-registered applicant is charged at RM1,000 per certificate. All of these are on the cost page, and the renewal rules are in validity and renewal.

If you export to Malaysia instead of manufacturing there, a different route applies, through a certification body that JAKIM recognises. See the recognised bodies by country.

Note: We are independent consultants, not JAKIM. We prepare the manufacturer and the brand owner for their separate applications. We cannot certify a product or issue a certificate.

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