09 Feb 2016

The Minister of Trade has issued a regulation which restores the permission for holders of the Producer Importer Identification Number (“API-P”) to import what is referred to as “Manufactured Goods” (barang manufaktur), comprising the so-called (i) complementary goods. (ii) market test goods, and (iii) after sales services goods. Upon their importation, the Manufactured Goods may be traded or transferred to other parties.


The above mentioned regulation is Regulation of the Minister of Trade No. 118/M-DAG/PER/12/2015 concerning Provisions for the Importation of Complementary Goods and Goods for Market Test and for After Sales Services Purposes (“Reg. 118/2015”). It was issued on 23 December and became effective on 1 January 2016.


The (now restored) importation permission was previously provided under Regulation of Minister of Trade No. 27/M-DAG/PER/5/2012 regarding Provisions on Importer Identification Number as amended severally and lastly by Regulation No. 84/M-DAG/PER/12/2012 (“Reg. 27/2012”), which was revoked by Government Regulation No. 70/M-DAG/PER/9/2015 concerning Provisions on Importer Identification Number (“Reg. 70/2015”).

I. Requirements for Importation


Prior to the importation of the Manufactured Goods, the API-P holder is required to obtain the following:


  1. Recommendation letter from the technical Ministry
    This was required under Reg. 27/2012 of the Ministry of Industry (“MOI”), assuming that it is still valid. Specifically for the importation of after sales services goods, to the best of our knowledge the MOI has not issued regulations on the recommendation letter requirement, as this type of goods was just introduced by way of Reg. 118/2015.

  2. Import Approval from the Ministry of Trade

Under Reg. 118/2015, the license for the importation of complementary products, market test products and after sales services products is known as Import Approval (Persetujuan Impor). The application for the Import Approval is to be submitted online through . If the online application fails, the application may be submitted manually.


II. Quarterly Reports Requirement


Holders of API-P which have obtained an Import Approval are required to submit electronic quarterly reports to regarding the realization (or non-realization) of the approved importation at the latest on the 15th day of the next quarter. The reports are to be sent to the Directorate General of Foreign Trading of the Ministry of Trade.


III. Revocation of the Import Approval


The MOT may revoke the Import Approval of an API-P holder as sanction for the following:


  1. Two (2) times failure to submit the required quarterly reports;
  2. Inconsistency/violation of the stipulation in the Import Approval;
  3. Submission of incorrect data and/or information in the application for the Import Approval;
  4. Commitment of violation at customs based on the information from the Directorate General of Customs and Excise, and/or
  5. Being declared guilty for the criminal offence of misusing the Import Approval based on a final and binding court decision.


The Ministry of Trade will evaluate Reg. 118/2015 annually.


Under Reg. 118/2015, licenses for the importation of complementary goods and market test goods which were issued under Reg. 27/2012 with expiry dates before 30 June 2016 will remain valid until 30 June 2016. (by: Agus A. Deradjat, Herry N. Kurniawan, Sheila R. Alam & Wahyuni Hanindriyowati)