Indonesia’s New Regulations on Imports

September 19, 2025

Imports are now governed in more detail in the Minister of Trade Regulation No. 16 of 2025 on Import Policies and Regulations (the “Regulation”). Effective as of August 29, 2025, the Regulation replaces Minister of Trade Regulation No. 36 of 2023 (“MOTR 36/2023”), including its subsequent amendments. The Regulation is the first in a series of new rules introduced as part of the Government’s reform of import policies.

The reform aims to strengthen both the national and regional economies in the face of an uncertainty climate by streamlining import procedures and supporting key sectors to encourage new investment. This commitment is further reflected in 8 (eight) additional regulations issued concurrently with the Regulation, all of which took effect on the same date, namely:

Minister of Trade Regulation 17 of 2025 on Policies and Regulations on Imports of Textiles and Textile Products;
Minister of Trade Regulation 18 of 2025 on Policies and Regulations on Imports of Agricultural and Livestock Goods;
Minister of Trade Regulation 19 of 2025 on Policy and Regulation of Salt and Fishery Commodity Imports;
Minister of Trade Regulation 20 of 2025 on Policy and Regulation of Imports of Chemicals, Hazardous Materials, and Mining Materials;
Minister of Trade Regulation 21 of 2025 on Policies and Regulations on Imports of Electronic and Telematics Goods;
Minister of Trade Regulation 22 of 2025 on Policies and Regulations on the Import of Certain Industrial Goods;
Minister of Trade Regulation 23 of 2025 on Policies and Regulations on Imports of Consumer Goods; and
Minister of Trade Regulation 24 of 2025 on Policy and Regulation of Imports of Goods in Non-New Condition and Non-Hazardous and Toxic Waste.

The Regulation introduces a more structured framework and greater ease of application for entrepreneurs, especially Importers, compared to the previous regulations. We set out below the notable changes introduced by the Regulation include:

♦ Ease of Conversion of API-U to API-P Status

Under MOTR 36/2023, an Importer was required to obtain a Business Identification Number/Nomor Induk Berusaha (an “NIB”), which also served as an Importer Identification Number/Angka Pengenal Impor (an “API”). An Importer could only select either: (i) a General Importer Identification Number /Angka Pengenal Impor Umum (an “API-U”), for goods intended for resale or transfer; or (ii) a Producer Importer Identification Number /Angka Pengenal Impor Produsen (an “API-P”), for goods intended for own use as capital goods, raw materials, auxiliary materials and/or production purposes.

Conversion from an API-U to an API-P was permitted only if 2 (two) conditions were met: (i) the Importer had completed all imports under its existing Import Permit/Persetujuan Impor and/or Surveyor Report/Laporan Survey; and (i) the NIB linked to the API-U had been valid for at least 1 (one) year.

The Regulation relaxes these requirements by allowing the conversion to be made if the Importer does not currently hold a valid Import Permit and/or Surveyor Report, or, if such a permit is held, no imports are being realized under it. This change enables Importers to immediately adjust their status without being subject to the 1 (one) year inactivity waiting period.

♦ Expanded Exemptions for API-P Holders

MOTR 36/2023 prohibited Importers holding an API-P from trading or transferring their imported goods. However, exceptions to such prohibitions were provided with respect to the following goods:

residual raw materials and/or auxiliary materials;
capital goods imported in new condition by an API-P holder and used for at least 2 (two) years;
manufactured goods serving as complementary goods, for market testing and/or after-sales service; and
goods traded or transferred by entities holding oil and gas processing and/or trading licenses issued by the Minister of Energy and Mineral Resources.

The Regulation expands this exemption by covering capital goods, raw materials, auxiliary materials, and/or materials supporting the production process, provided that such goods are subsequently re-exported in a quantity not exceeding the volume declared in the Import Customs Notification.

♦ Updated Structure of Administrative Sanction Framework

In contrast to the provisions under MOTR 36/2023, the Regulation establishes a clearer and more structured framework for administrative sanctions. It specifies 11 (eleven) types of administrative sanctions, which may be imposed either progressively or directly, in cases of violations such as inconsistencies in licensing documents, inaccurate in information provided in license applications, importing goods not in conformity with the relevant license, or importing goods without the required surveyor’s report. These sanctions consist of the following:

electronic warning;
written warning;
suspension of business licensing in the import sector;
revocation of business licensing in the import sector;
suspension of certificate;
revocation of certificate;
recommendation for revocation of surveyor report;
suspension of the process for issuance, amendment, or extension of business licensing in the import sector;
suspension of the process for issuance or amendment of certificate;
recommendation for suspension of Verification or Technical Tracing services; and/or
recommendation for revocation of NIB that serves as API-U or API-P.

AKSET

Please contact Johannes C. Sahetapy-Engel (jsahetapyengel@aksetlaw.com) or Unisya Izhari Rinsta Savira (usavira@aksetlaw.com) for further information.

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