Image of Toddler on Foreign Bottled Water Packaging Deemed to Violate Regulations, BPKN and KPAI Respond

A foreign bottled water (AMDK) packaging bundle featuring a photo of a toddler has recently become a topic of discussion. Several state agencies consider such practices non-compliant with prevailing regulations and potentially harmful to consumers. These concerns are not unfounded. BPOM Regulation No. 6 of 2021, Article 14 letter bb, explicitly prohibits advertisements for processed foods from featuring children under five years old, unless the product is specifically intended for toddlers. AMDK falls under the category of general food, not a baby-specific product. Displaying a toddler’s image on AMDK packaging is seen as potentially fostering inaccurate perceptions among consumers. BPKN Chairman Mufti Mubarok does not deny these concerns. According to him, an image of a baby on general food packaging can create the impression that the product is formulated for babies, whereas scientifically it is not. “If it creates the impression that it is intended for babies without special permission, it contravenes labelling provisions and violates the Consumer Protection Law,” Mufti said in a written statement received by Kompas.com on Friday (17/4/2026). He added that BPKN is ready to follow up on public reports regarding this matter and will recommend sanctions to BPOM if violations are found. KPAI Deputy Chairman Jasra Putra expressed a similar view. He reminded that children should not be used as instruments to influence purchasing decisions. “The best interests of the child must be the primary consideration, not exploited to disproportionately influence purchasing decisions,” Jasra stated. From a communication perspective, expert Burhanuddin Abe explained the reason why baby images are often chosen in marketing strategies. Such imagery has strong emotional appeal and easily builds positive associations in consumers’ minds. “Consumers might capture the implicit message that this product has special advantages for children. This is emotional manipulation,” Burhanuddin said. A similar precedent occurred with sweetened condensed milk (SKM) products. The use of visuals of healthy children in SKM advertisements for years eventually led to a BPOM ban after it was proven to cause misunderstandings in society regarding the product’s content and benefits. If similar violations are proven, regulators have the authority to impose sanctions, ranging from written warnings, withdrawal of promotional materials, to obligations for public corrections.