Overview
Indonesia, through its Ministry of Trade (“MOT”), has taken a significant step in reforming import regulations as part of the government’s broader agenda to simplify regulations and promote ease of doing business.
MOT Regulation No. 16 of 2025 on Import Policies and Provisions, as later amended by Regulation No. 37 of 2025 (collectively, “MOT Regulation 16/2025”), has recently taken effect. It revokes previous import regulations and establishes a comprehensive and integrated legal framework governing import activities. The enactment of this regulation was followed by a series of specific import-commodity regulations, grouped into eight clusters as follows:
- Textiles and Textile Products, under MOT Regulation No. 17 of 2025;
- Agricultural and Livestock Goods, under MOT Regulation No. 18 of 2025;
- Salt and Fishery Commodities, under MOT Regulation No.19 of 2025 (as amended by MOT Regulation No. 38 of 2025);
- Chemicals, Hazardous Materials, and Mining Materials, under MOT Regulation No. 20 of 2025;
- Electronic and Telematics Goods, under MOT Regulation No. 21 of 2025;
- Certain Industrial Goods, under MOT Regulation No. 22 of 2025;
- Consumer Goods, under MOT Regulation No. 23 of 2025; and
- Non-New Goods and Non-Hazardous/Non-Toxic Waste, under MOT Regulation No. 24 of 2025.
Key Provisions
- New Definitions: MOT Regulation 16/2025 introduces more detailed import-related definitions to provide greater certainty in the implementation of import policies. These include, among others: Import-Restricted Goods (Barang Dibatasi Impor), Import-Prohibited Goods (Barang Dilarang Impor), Import-Free Goods (Barang Bebas Impor), Goods for Market Testing Purposes (Barang untuk Keperluan Tes Pasar), and Goods for After-Sales Services (Barang untuk Pelayanan Purna Jual).
- Exemption from Import Licensing Requirements: Import licensing requirements including Business Identification Number (Nomor Induk Berusaha or “NIB”) that serves as the Importer Identification Number (Angka Pengenal Importir or “API”), import licenses, and technical verification, do not apply to certain goods imported for export purposes.
- Additional Exemption from Transfer Prohibition: Certain imported production inputs (including capital goods, raw materials, auxiliary materials, and other production inputs) may now be traded or transferred to third parties, provided that the goods are later re-exported and the quantity re-exported does not exceed the quantity originally imported.
- Conversion of API-U to API-P: An NIB serving as a General API (“API-U”) may be converted into a Producer API (“API-P”) if the importer has no import approvals or surveyor reports, or has them but is not in the process of realizing those imports.
- Revocation of API Status: An NIB serving as an API may be revoked if: (i) the importer does not hold any import licensing, certificates, and/or surveyor reports; or (ii) the importer holds any valid import licensing, certificates, and/or surveyor reports, and is not actively realizing any import transactions.
- Administrative Examination Timeline: In addition to the existing service level agreement of five working days for issuing import licenses, the administrative examination process is now subject to a maximum timeline of 15 working days.
- Temporary Suspension of Import License Processing: The processing of import licenses may be temporarily suspended if: (i) a technical calculation and/or verification is required; (ii) a post-border inspection is required due to an alleged import violation; or (iii) there is a disruption to the application system.
- Import of Goods for Non-Business Activities: Importers who import certain Import-Free Goods and/or Import-Restricted Goods for non-business purposes (i.e., not for resale or commercial use) may be exempt from specific import licensing requirements.
- Reporting Obligations for Import Activity: In addition to the general requirement to submit a monthly import activity report by the 15th of the following month, importers who utilize a surveyor report must submit a report within 30 days after the surveyor report is used for customs clearance or post-border inspection.
- Import Supervision: Import supervision now encompasses compliance with NIB (serving as an API), import business licensing, technical verification, and port-of-destination regulations. Inspections are conducted both at the border and after customs clearance (post-border).
- Administrative Sanctions: MOT Regulation 16/2025 specifies 11 types of administrative sanctions that may be imposed on importers, either sequentially or independently. These sanctions range from electronic or written warnings to the suspension or revocation of import licenses, certificates, and NIB, as well as recommendations to suspend or revoke a surveyor’s report or technical verification services.
Closing
MOT Regulation 16/2025 consolidates and replaces the previous import rules while introducing clearer procedures, broader oversight, and a more structured sanctions framework. Its cluster-based approach provides importers with a more practical way to determine which requirements apply to their specific commodities. These changes reflect the government’s ongoing effort to streamline and simplify import regulations.
Importers should view this as an opportunity to improve their internal processes in line with the new, clearer rules, ensuring full compliance while gaining a competitive advantage through more efficient operations within the updated framework.
For more information or inquiries, please contact:
Andika Mendrofa at andika.mendrofa@nusaadvocates.com
Anisa Wibowo at anisa.wibowo@nusaadvocates.com
