Indonesia has issued Permendag 24/2025, replacing Permendag 8/2024 and taking effect in August 2025. The rule sets specific procedures for importing used goods and non-hazardous, non-toxic (non-B3) waste, including licensing, verification, zone treatment, reporting, and transition measures.
Key Takeaways
- Effective Aug 2025: Permendag 24/2025 replaces 8/2024 for used goods & non-B3 waste.
- Licensing & checks: PI/IP required depending on the item; LS and/or VPT apply in specified cases.
- Zones: KPBPB/KEK/TPB have tailored entry/exit rules; Sabang has unique treatment (policies off on entry, prohibitions still on).
- KITE: Still subject to import policies (Business Licensing, VPT, destination-port).
- Reporting & control: E-reports, sealed-container transport for industrial raw-material waste, and proper non-B3 waste management are mandatory; violations trigger Article 22 sanctions.
- Transition: Existing IP/PI remain valid; in-process files continue unless conflicting; prior docs/surveyors remain usable.
What changed under Permendag 24/2025—and when does it apply?
From August 2025, imports of used goods and non-B3 waste must follow new PI/IP + verification rules, with tailored provisions for special zones and clear reporting/sanction mechanisms.
What’s in scope—and what are the baseline import requirements?
New goods (when required), used goods under specific scenarios, non-functional secondary lithium batteries, and non-B3 waste—each with distinct approvals and checks.
- New goods: As required goods for importation.
- Used goods may be imported when:
- Not available domestically for industrial production (PI + Surveyor Verification/LS before entry);
- For disaster recovery/reconstruction;
- Non-functional secondary lithium batteries (intact): require an Import Permit (IP) from the Minister (based on technical coordination) before entry;
- Non-B3 waste (residuals/scrap/rejections): PI + LS before customs entry; specific entry ports may be designated;
- Other specified purposes per the regulation.
How are used capital goods (BMTB) handled?
BMTB can enter via Industrial Relocation/Factory Transfer or Dispensation routes, both tightly controlled and VPT-verified.
- Industrial Relocation / Factory Transfer:
- PI issued by the Director General for/under the Minister.
- BMTB may be inside/outside the Annexe (description, HS, age).
- Verification/Technical Tracing (VPT) is mandatory.
- Dispensation scheme:
- PI issued by the Director General.
- Machinery/mechanical equipment: max 20-year age, used directly by the importer, not in the Annexe, must undergo verification.
- Transport equipment (e.g., ships/boats): description/age may be outside the Annexe.
- Transfer of ownership limits:
- HS 8901/8903/8904/8905 (ships/vessels): transferable after 4 years of use.
- Other HS: transferable after 5 years.
- Force majeure: early transfer allowed; bankruptcy (final court ruling) required for special-circumstance exemptions.
How are KPBPB, KEK, and TPB treated (entries, exits, and authorities)?
Zone entries have bespoke licensing and verification flows; releases to the Customs Territory reactivate full import rules (with limited exceptions).
Free Trade Zones & Free Ports (KPBPB)
- Entry: BMTB & non-B3 waste subject to import policies (Business Licensing, VPT, and/or designated ports).
- IP & PI issued by the KPBPB Authority Head via SINSW/INATRADE after technical coordination; verification may occur inside KPBPB.
- Exit:
- BMTB entering KPBPB without import compliance must meet all rules when released to Indonesia.
- “Originally new” BMTB that entered KPBPB under exemptions becomes subject to rules upon release.
- Exceptions: transfers within Indonesia; BMTB fully made/obtained within KPBPB.
- PI for release to the Territory: Issued by the Director General; applicants can be KPBPB operators or holders/recipients in the Territory.
- Sabang KPBPB: Prohibitions still apply; import policies do not apply to entries from abroad, but only Sabang-licensed businesses may import. On release to the Territory, rules apply except destination-port provisions.
Special Economic Zones (KEK)
- Entry from abroad: Must follow import rules (Business Licensing, VPT, destination port).
- IP/PI: Issued by the KEK Administrator under KEK/Ministerial rules; IP follows a technical coordination meeting led by the National Council for KEK with relevant ministries (incl. handling of non-functional lithium batteries).
- Applicants: KEK operators or importers; issuance data reported to the Director General via SINSW/INATRADE.
- VPT may be conducted inside KEK.
Bonded Zones (TPB)
- Entry from abroad: Follow import policies (Business Licensing, VPT, destination port).
- IP/PI: Issued by the Director General; applicants may be TPB operators or importers.
- VPT may be conducted inside TPB.
KITE (Export-oriented facilities)
- Used goods and non-B3 waste imported for processing/assembly/installation for export under KITE remain subject to import rules (Business Licensing, VPT, and/or destination port).
What reporting and compliance are required—and what are the sanctions?
E-reporting is mandatory, certain movements must use sealed containers, unusable non-B3 waste must be managed properly, and Article 22 sanctions apply for breaches.
- E-reports: Import realisation/distribution (including nil realisation).
- Industrial raw-material waste: Must be transported sealed from the loading port to the designated destination (direct or in transit, no extra handling).
- Non-B3 waste not usable in production: Importer must manage it individually/jointly, or with a licensed waste processor.
- Supervision: Border/post-border; compliance with NIB, import licenses, VPT, and designated ports. A special task force for non-B3 waste may be formed by the Minister (coordinated by the Director General).
- Customs documentation: PI/LS (where applicable) must be included, or clearance is rejected.
What are the transitional provisions?
Existing IP/PI stay valid to expiry (amendable/extendable); in-process applications continue unless conflicting; prior documents/surveyors remain valid; arrived goods follow the new rule.
- IP/PI issued before enactment: valid until expiry; may be amended/extended per the new regulation.
- Applications in process: Continue if non-conflicting.
- Supporting docs/surveyors: Remain valid; verification can proceed for valid IP/PI/LS.
- Arrived goods (per manifest): Must comply with the new regulation.
- Existing technical guidelines: Continue where not in conflict.
How Permitindo Can Help
We turn Permendag 24/2025 into an execution plan—defining when you need PI vs IP, arranging VPT and LS (where required), setting up compliant KPBPB/KEK/TPB/KITE pathways, and building airtight post-border controls (e-reporting, sealed-container protocols, waste-handling chains) so your clearances aren’t rejected. Need local presence? We can set up your PT PMA/PT PMDN, align licensing, and support ongoing compliance. Start via the contact form below or email us at [email protected].
