Regulatory Update – Key Amendments to Indonesia’s Import Framework

Indonesia’s Ministry of Trade has introduced further refinements to the national import framework through Regulation No. 37 of 2025*, which amends Regulation No. 16 of 2025**. Effective as of 5 November 2025, this amendment aims to strengthen oversight of import activities while enhancing legal certainty and streamlining procedures for business actors whose Business Identification Number (Nomor Induk Berusaha or “NIB”) also serves as an Importer Identification Number (Angka Pengenal Impor or “API”).

The new regulation introduces provisions that were previously unregulated and revises several key aspects of import arrangements for investment purposes. One notable update concerns the conversion of general API (API Umum or “API-U”) to producer API (API Produsen or “API-P”), which maintains the same substantive process as before but expands the documentary requirements. Importers must now provide an additional supporting letter (surat keterangan) alongside existing import approvals and surveyor reports.

Regulation No. 37/2025 also closes a regulatory gap by introducing clear procedures for API revocation. An NIB functioning as an API may now be revoked electronically through the INATRADE system, integrated with the OSS platform, and only under specific circumstances such as, where an importer does not hold valid import licences, supporting letters, or surveyor reports, or where such permits exist but import activities are no longer being conducted. Following revocation, importers must submit an OSS declaration confirming the grounds for revocation, the absence of ongoing import activities, and that API-P goods will not be traded where the revocation concerns a NIB serving as an API-P.

The regulation further amends import arrangements for investment purposes by removing the broad exemptions previously provided under Annex I letter B number 3 of Regulation No. 16/2025. A limited transitional exemption remains available for certain restricted goods in new condition, provided that the goods were shipped before 5 November 2025 (as evidenced by a bill of lading or airway bill) and arrive at their destination no later than 3 February 2026, supported by the relevant BC.1.1 customs documentation.

Through these amendments, the Ministry of Trade underscores its commitment to building a more orderly, transparent, and technology-integrated import regime. The updated framework is expected to enhance regulatory certainty, improve data traceability, and support Indonesia’s broader goal of strengthening domestic production while gradually reducing reliance on imported goods.

*Regulation of the Minister of Trade of the Republic of Indonesia Number 37 of 2025 on the Amendment to Regulation of the Minister of Trade Number 16 of 2025 on Import Policies and Provisions (“Regulation No. 37/2025”)

**Regulation of the Minister of Trade of the Republic of Indonesia Number 16 of 2025 on Import Policies and Provisions (“Regulation No. 16/2025”)

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