Halal Guide

Who Needs to Apply? The Roles of the OEM Factory and the Brand Owner

Divide responsibility for certificates, ingredients, labels, audits and complaints between the two companies.

Last reviewed 5 November 2026

ManaHalal note: Educational material for SME operators in Malaysia; not a verification, an application decision or advice that overrides JAKIM/JAIN/MAIN (Majlis/Jabatan Agama Islam Negeri, the state Islamic religious councils and departments). The scope of a certificate must be checked by holder, type of scheme, factory address, product and validity period. Amendments after 5 November 2026 must be checked before publication or application.

The customer pays the manufacturer to make the product, but who applies for the product certificate, who keeps the documents and who approves changes to the formula? All of this must be decided before the first production run.

The principle for the right applicant

The manufacturer is the party that applies for and maintains the SPHM (Sijil Pengesahan Halal Malaysia, the Malaysia Halal Certificate) for the contract manufacturing/OEM service. Product certification is a separate matter under the relevant product scheme. The identity of the applicant and the name of the product certificate holder must be matched to the business structure, the agreement, the ownership of the product and the authority's instructions; do not set one universal answer for every own-brand model.

Example responsibility matrix

Activity Brand owner OEM manufacturer Evidence needed
Product specification, brand and label Lead Checks feasibility Approved specification
SPHM for the OEM service Confirms validity Holder/applicant Certificate and scope
Product SPHM route Aligns with the factory/authority Supports according to the applicant's role Written application plan
Purchasing materials Approves the specification, or controls purchasing if agreed Records purchases and sources COA (certificate of analysis)/halal certificate/invoice
HACCP/KKM (Ministry of Health)/operations plan Checks the requirements Controls factory operations SOPs and records
Approval of logo artwork Checks claims and brand Confirms manufacturer information Proof of label version
Batch release Decides commercial accept/reject Issues QA/QC evidence Batch records and COA if needed
Complaints/recall Manages market communication Traces and isolates stock Complaint file and actions

This table is a division of roles in practice, not a substitute for an official decision on who the product certificate applicant is.

Early decisions to record

  1. The legal names of the brand owner and the manufacturer; the actual operating addresses.
  2. Who supplies each ingredient, packaging film, label and bottle.
  3. Who holds the controlled formula records and version changes.
  4. Who submits the product application and answers audit queries.
  5. Inspection rights, access to documents and the arrangements for moving production.
Roles of the OEM factory and the brand ownerThe brand owner provides the specification, artwork and order instructions, while the OEM factory provides the SPHM, licences, capacity and halal records. The two meet in the contract and role matrix, followed by confirmation of the product SPHM route, the ingredient register and controlled production, confirmation of the label, batch release and marketing, and then records, complaints, renewal and change control.Specification, artwork, orderinstructionsOEM SPHM, licences,capacity, halal records

Brand owner

Contract and role matrix

OEM factory

Confirm the product SPHM route

Ingredient register and controlled production

Confirm the label, batch release and marketing

Records, complaints, renewal and change control
Roles of the OEM factory and the brand owner

Frequently asked questions

I am only the brand owner and have no factory. Can I say the product is certified halal? Only when that product is genuinely covered by a valid product SPHM and the use of the logo/claims meets the conditions. Do not make claims based on the OEM certificate alone.

The manufacturer wants to use another customer's product certificate for my brand. Do not accept that assumption. Compare the product name, formula, label, holder and scope; consult the authority if it is unclear.

Actions this week

  • Sign the role matrix before opening the first PO (purchase order).
  • Record the applicant/holder and the reference number for each certificate.
  • Appoint one officer in each company for halal communication and changes.

Official references