National Standardization Agency Allows Institution-Drafted Conformity Assessment Schemes, Eases SNI Certification for UMK
On March 14, 2025, the National Standardization Agency (Badan Standardisasi Nasional or “BSN”) issued the Head of the BSN Circular Letter No. 1/SE/KA.BSN/3/2025 of 2025 on the Implementation of BSN Regulation No. 9 of 2023 on the Procedures for the Preparation of Conformity Assessment Schemes to Indonesian National Standards (the “Circular Letter”).
The Circular Letter was issued in support of the Government’s initiative to promote micro and small enterprises (Usaha Mikro dan Kecil or “UMK”) as a vital part of Indonesia’s economy. It provides greater autonomy to the Conformity Assessment Institutions (Lembaga Penilaian Kesesuaian or an “LPK”) in arranging conformity assessment schemes, especially for UMK that possesses a Business Identification Number (Nomor Induk Berusaha or the “NIB”).
We set out below the key highlights of the Circular Letter.
♦ Institution-drafted Conformity Assessment Schemes for Voluntary SNI Products
Article 42(1) of Government Regulation No. 34 of 2018 dated July 20, 2018 on the Standardization and National Conformity Assessment Systems (the “Government Regulation”) states that conformity assessment schemes are to be arranged by BSN. However, with the issuance of the Circular Letter, LPKs are now permitted to develop conformity assessment schemes for Voluntary SNI products that do not yet have schemes established by the BSN. This must be done in accordance with BSN Regulation No. 9 of 2023 dated September 19, 2023 on the Procedures for the Preparation of Conformity Assessment Scheme to Indonesian National Standards (the “BSN Regulation”).
♦ SNI Certification Convenience for UMKs
The Circular Letter provides convenience for UMKs by allowing the initial certification process to be conducted online. It further stipulates that surveillance and recertification must be carried out through online methods. However, the Circular Letter does not elaborate on the specific procedures or platforms to be used for these online processes.
♦ SNI Certification Relief for UMKs
The BSN Regulation provides relief for UMKs seeking to acquire the SNI Certification by requiring the LPKs to (i) reduce the number of personnel involved in the conformity assessment process, (ii) shorten the time required for conducting the conformity assessment, and (iii) reduce the number of sample goods to be tested (where applicable), all with the aim of lowering the overall cost of the conformity assessment. However, the BSN Regulation does not provide further details on how these cost reductions should be implemented, which may result in inconsistent application across different LPKs.
The Circular Letter aims at providing the clarity by specifying the exact number of personnel and time involved in conducting conformity assessments for UMKs. The provisions are as follows:
- for UMKs with a maximum of 20 (twenty) employees, the conformity assessment must be conducted by 1 (one) personnel within 1 (one) day;
- for UMKs with more than 20 (twenty) employees, the conformity assessment may be conducted under one of the following arrangements:
- 1 (one) personnel within 1 (one) day;
- 1 (one) personnel within 2 (two) days; or
- 2 (two) personnel within 1 (one day).
Regarding the reduction of sample goods to be tested, the LPKs must request initial test results that align with the relevant SNI Certification as part of the certification application process. These results must have been issued no more than 1 (one) year prior to the certification application.
For food and beverage products, test results previously used by UMKs to obtain a distribution permit from the Food and Drug Supervisory Agency may be accepted as evidence of compliance with SNI Certification requirements, provided the results cover the same parameters required under the applicable SNI standards.
If a UMK does not possess any of the aforementioned test results, then the LPK may collect an unspecified number of product samples for testing purposes. Additionally, sampling and testing are not required during surveillance or recertification processes, provided there have been no changes to the raw materials, production processes, or product specifications.
Please note that the benefits provided under the Circular Letter are limited to the UMKs that hold an NIB.
AKSET
Please contact Johannes C. Sahetapy-Engel (jsahetapyengel@aksetlaw.com), Thomas P. Wijaya (twijaya@aksetlaw.com), or Giorgio Alexander William Robot (grobot@aksetlaw.com) for further information.
Disclaimer:
The foregoing material is the property of AKSET and may not be used by any other party without prior written consent. The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. Specific legal advice should be sought by interested parties to address their particular circumstances.
Any links contained in this document are for informational purposes and are available and relevant at time this publication is made. We provide no liability whatsoever in respect of any information or content in such links.
