Indonesia has enacted Minister of Trade Regulation No. 20 of 2025 (Permendag 20/2025), which revokes Permendag 8/2024 and takes effect in August 2025. The rule tightens procedures for importing chemicals, hazardous substances, and mineral resources through mandatory licenses, Import Approval (PI), and Surveyor Reports (LS), with tailored treatment for special zones and export schemes.
Key Takeaways
- In force August 2025: Permendag 20/2025 replaces 8/2024 and standardizes import controls for specified chemicals, hazardous substances, and minerals.
- Core trio: IT/IP importer status, PI before entry, and LS from an appointed surveyor underpin clearance.
- Zones differ: Some goods are exempt when imported into KPBPB/KEK/TPB; others (e.g., precursors, NC, explosives, ODS, B2, HFCs) face full requirements even in zones.
- Exemptions exist: Granted for non-business or specified business purposes per annexes; can cover zone transfers and KITE scenarios (via Letter of Exemption).
- Strict reporting: Electronic realisation reports and LS uploads are mandatory; PI/LS must appear on customs declarations, or entries are rejected.
- Transition-friendly: Existing PIs remain valid to expiry; pending PIs continue if not conflicting with the new rule.
What changed under Permendag 20/2025—and when does it apply?
As of August 2025, Permendag 20/2025 replaces 8/2024 and standardises import controls for specified chemicals, hazardous substances, and minerals via PI and LS requirements.
Which commodities fall within the scope?
Strategic chemicals, hazardous substances, and mineral resources listed below are covered by the new regime.
- Lubricant base oils
- Cement clinker and cement
- Rough diamonds
- Non-pharmaceutical precursors
- Crude oil and natural gas
- Nitrocellulose (NC)
- Commercial explosives (handak)
- Ozone-depleting substances (ODS)
- Hazardous substances (B2)
- Hydrofluorocarbons (HFCs)
- Certain regulated chemicals
What import licenses and documents are now mandatory?
Importers must hold the right importer status (IT/IP), obtain Import Approval (PI) before entry, and secure a Surveyor Report (LS) after technical verification.
- Importer status: Registered Importer (IT) or Producer Importer (IP) issued by the Ministry of Trade.
- Import Approval (PI): Required before goods enter Indonesia’s Customs Territory; expressly applies to ODS and HFCs (Art. 4(1)).
- Surveyor Report (LS): Based on technical verification/inspection by an independent surveyor appointed by the Minister.
- Entries into FTZ/KEK/TPB from abroad: Customs declaration must state PI number, issuance/expiry dates, HS code, quantity/unit, destination port, and foreign port of loading.
How do surveyor verification and customs inspection work?
An appointed independent surveyor verifies shipments and issues an LS, which customs uses as the basis for inspection at the arrival port.
- Technical verification: Conducted pre-clearance by an appointed surveyor.
- Customs inspection: Relies on the LS at the designated port of entry.
How are Free Trade Zones (KPBPB), Special Economic Zones (KEK), and Bonded Zones (TPB) treated?
Some goods are exempt from PI/LS/destination-port rules when imported into KPBPB/KEK/TPB; others still require full compliance even in zones, with special notes for Sabang KPBPB.
- Exempt from PI, LS, destination-port designation when imported into KPBPB/KEK/TPB:
- Lubricant base oils; Cement clinker and cement; Crude oil and natural gas; Certain regulated chemicals (BKT).
- Caveat: Exemption does not apply if goods arrive directly at a destination port inside the Customs Territory; once moved into the Territory, all requirements apply.
- Who may request PI for release from KPBPB to Customs Territory: the FTZ business operator or the holder of the goods in the Customs Territory.
- Subject to full requirements (PI, LS, destination-port designation) even when imported into KPBPB/KEK/TPB:
- Rough diamonds; Non-pharmaceutical precursors; Nitrocellulose (NC); Commercial explosives (handak); ODS; Hazardous substances (B2); HFCs.
- PI issuance is via the electronic licensing system.
- Sabang KPBPB: Standard import policies/regulations do not apply to imports from outside the Customs Territory into KPBPB Sabang; only business entities licensed by the Sabang FTZ Authority may import.
What exemptions exist, and who qualifies?
The Minister may grant exemptions for non-business and certain business purposes per annexe criteria; eligibility depends on NIB/API status and annexe listings, and can extend to zone-to-territory transfers and KITE schemes.
What types of exemptions can be granted?
Two broad cases—non-business uses and business uses meeting specific criteria.
- Non-business: Personal use or non-commercial institutional purposes.
- Business: Certain sectors/criteria as listed in the regulation’s annexes.
Who is eligible for exemptions?
Both non-API and API-eligible importers may qualify, subject to annex exclusions and activity lists.
- Importers not eligible to hold NIB as API: may obtain exemptions unless listed in Annexe II.
- Importers eligible to hold NIB as API may obtain exemptions except those in Annexe III.
- Qualifying business activities: specified in Annexe IV.
Do exemptions apply to zone transfers and export-oriented facilities?
Yes, certain zone-to-territory movements and KITE imports can be exempted with an official letter.
- Transfers from KPBPB/KEK/TPB into the Customs Territory for: Lubricant base oils; Cement clinker and cement; Crude oil and natural gas; Certain regulated chemicals (BKT).
- KITE imports into KPBPB/KEK/TPB for non-pharmaceutical precursors and B2 (hazardous substances).
- Letter of Exemption (Surat Keterangan Pengecualian): May be issued by the Minister of Trade as a legal basis.
Can explosives be imported as complementary goods?
Yes, explosives (bahan peledak) may be imported as Complementary Goods with a Complementary PI (PI Komplementer / API-P).
- Valid for imports into KPBPB, KEK, TPB, and under KITE with duty exemption.
What reporting is required, and what are the sanctions?
Importers must e-report realisations/distribution and upload the LS; missing reports or documents trigger administrative sanctions, and customs will reject entries lacking PI and LS.
- Reporting: Electronic submission of import realisation/distribution (including nil realisation) and LS upload.
- Sanctions: Administrative actions under Article 21 for non-compliance.
- Customs declaration: Must include PI and LS; otherwise, customs processing is rejected.
How are existing approvals handled during the transition?
Valid PIs issued under the previous rule remain usable until expiry, and pre-effective-date PI applications continue if they don’t conflict with Permendag 20/2025.
How Permitindo Can Help
We help you map your HS lines to the new controls, secure IT/IP status, obtain PI through the e-system, manage surveyor coordination (LS), and set up compliant flows for FTZ/KEK/TPB/KITE scenarios.
Permitindo’s trade compliance team can:
- Assess whether your goods fall under the scope
- structure, special-zone use vs. direct-to-territory entry,
- Prepare PI packages and surveyor instructions
- Implement post-border reporting and documentation controls to avoid sanctions or customs rejection. To get started, reach us at contact@permitindo.com or use the form below.
