An Act Regulating the Advertisement, Packaging, Labeling, Display, Sale, Preparation, and Serving of Halal Food in the Bangsamoro Autonomous Region

This regulates halal food without requiring anyone to be certified. It is a deception statute: the offence is misrepresentation, and the bill's substance is a long list of the ways it can be committed.

The general prohibition is in Section 4 — it is unlawful to make any oral or written statement that directly or indirectly tends to deceive or lead a reasonable individual to believe that non-halal food is halal. Then comes an evidentiary rule with real force: the presence of any non-halal food in a place of business that represents itself as selling, preparing or serving only halal food is presumptive evidence that the person in possession offers it for sale.

The enumerated prohibited acts cover the practical routes to fraud. Falsely representing an animal as grown in a halal way; falsely representing food as halal; removing or destroying the original halal identification affixed to a commodity, except where it is then sold as non-halal; possessing for resale as halal any commodity whose farm or slaughterhouse mark has been fraudulently attached; labelling unpackaged food as halal unless you manufactured it; and inscribing "halal" or any other word or symbol — expressly including characters in Arabic writing — on packaged food in a way that would deceive a reasonable individual.

And then the provision that makes mixed premises workable. An establishment may sell or serve both unpackaged non-halal food and food it represents as halal, but only if it posts a window sign at its entrance in block letters at least 4 inches high reading "Halal and Non-Halal Foods Sold Here" or "Halal and Non-Halal Foods Served Here".

Halal is defined by reference to the laws and customs of the Islamic religion, including as expressed by the Bangsamoro Darul-Ifta'. Penalties run to a fine not exceeding ₱5,000 or imprisonment not exceeding 1 year or both, extendable to a corporate entity's responsible officers where they knowingly consented. The Bangsamoro Halal Board writes the rules within 90 days.

The policy section frames this as consumer protection within the region's general welfare power — regulating activities that may be harmful to the health, safety and welfare of the Bangsamoro people, and specifically the advertisement, packaging, labelling, display, sale, preparation and serving of halal food.

The strategy follows from a judgement about where the harm lies. A Muslim consumer's injury is not that an establishment lacks a certificate; it is being served pork while believing otherwise. A statute aimed at the deception rather than at the paperwork catches the conduct that actually matters, including from establishments that never claimed to be certified.

The presumptive evidence rule is the engine of this bill. Proving that a restaurant served non-halal food as halal is close to impossible for a consumer or an inspector after the fact; proving that non-halal food was on the premises of an establishment advertising itself as halal-only is straightforward. Shifting the burden at that point is what makes the prohibition enforceable, and it is the single provision that distinguishes this approach from an exhortation.

Expressly naming Arabic characters in the labelling prohibition is the kind of detail that only comes from having seen the practice. A package carrying Arabic script and no claim in English conveys halal status to a shopper without stating it, and a prohibition drafted only against the word "halal" would miss it entirely. The clause covers "any other words or symbol, not limited to characters in Arabic writing", which closes the gap.

The 4-inch sign is the bill's most practical provision and the one a customer would actually use. Rather than forcing every establishment to choose between halal and non-halal, it permits mixed premises on condition of disclosure at the entrance, at a letter height specified so that compliance is not a matter of argument. That is a workable answer in a region with a substantial Christian and indigenous population who also need to eat.

Against all of that, the penalty is the weak point. A fine not exceeding ₱5,000 for deceiving Muslim consumers about pork is modest — Bill No. 164, dealing with the narrower question of pork labelling by fast food chains, escalates to ₱100,000 by the third offence. Where this bill goes further is in reaching the individuals: officers who knowingly consented can be penalised personally, which is worth more than the headline figure suggests.

Three bills in this registry regulate what the region eats, and they pick 3 different instruments for the same problem. Bill No. 10 licenses: every Muslim restaurant must hold an annual halal certificate. Bill No. 60 polices the lie: no certificate is required, but misrepresenting food as halal becomes an offence with a long schedule of prohibited acts. Bill No. 164 discloses: it does not regulate halal at all, instead requiring named fast food chains to label anything containing pork. All 3 are at Second Reading, Committee Stage, and none of the 3 has become law.