MOT Regulation 22/2025: New Import Rules for Certain Industrial Goods

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Authors

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The Ministry of Trade (“MOT”) has recently introduced a significant regulatory change through the issuance of MOT Regulation No. 22 of 2025 on the Policy and Regulation of Imports of Certain Industrial Goods, effective as of 30 August 2025 (“MOT Reg 22/2025”). This regulation reshapes the import control framework, requiring importers of designated goods to secure Import Approvals, comply with Verification or Technical Tracing by appointed surveyors, and regularly submit import realisation reports. It also strengthens supervisory measures and imposes administrative sanctions for non-compliance. By tightening oversight, MOT Reg 22/2025 signals the government’s intent to ensure greater control and accountability in the flow of industrial goods into the domestic market.

Scope of Products

MOT Regulation 22/2025 covers imports of a defined list of industrial goods (“Certain Products”), which include: ¹

1. iron/steel and their derivatives,
2. tyres,
3. semi-finished hand tools,
4. ceramics,
5. sheet glass and safety glass,
6. saccharin, cyclamate, alcohol-based fragrance preparations,
7. raw materials for alcoholic beverages,
8. downstream plastics,
9. valves.

The detailed Harmonized System ("HS") Codes for each product category are listed in the annex of the regulation.

Importer Obligations

For Certain Products, importers must comply with the following main obligations under MOT Reg 22/2025:

1. Import Approval ² – importers must obtain Import Approval for specific tariff lines before goods enter the Customs Territory.
2. Verification or Technical Tracing ³ – certain goods must undergo inspection by appointed surveyors, with the results set out in a Surveyor Report.
3. Designated Ports of Entry ⁴ – MOT may designate specific ports as entry points for Certain Products.
4. Import Realisation Report – importers holding an Import Approval/Import Certificate or conducting imports based on a Surveyor Report must submit an electronic import realisation report (including unrealised imports). ⁵

Special Areas

Import of Certain Products entering a Free Trade Zone and Free Port are, in principle, not yet subject to import requirements. However, once the goods are released from such area into other parts of the Indonesian Customs Territory, all import requirements apply. The same rule applies to goods entering through a Special Economic Zone and Bonded Logistics Centre. While these areas offer specific facilities for businesses, this regulation ensures that any goods circulating within Indonesia remain subject to prevailing import policies. ⁶

Supervision & Sanctions

Import Supervision is carried out jointly by the MOT and the Directorate General of Customs and Excise, both at the border and post-border. Inspections focus on compliance with licensing documents such as the Business Identification Number (Nomor Induk Berusaha – “NIB”), Importer Identification Number, Import Approval, Surveyor Report, and designated ports of entry. ⁷

Importers failing to comply, for instance by not submitting import realisation reports or breaching licensing requirements, may face administrative sanctions. These may include delays in goods release or revocation of import licences, which can directly affect business operations. ⁸

Transitional Provisions

Import documents issued prior to the effective date of MOT Reg 22/2025 remain valid until their expiry with the possibility of amendment or extension (except for certain types (e.g., saccharin, cyclamate, and alcohol-based perfumes), which are automatically revoked through INATRADE system). Other supporting documents, such as technical recommendations or Surveyor Report, remain valid insofar as they do not conflict with the new rules. Applications for Import Approval or Import Certificates submitted prior to the new regulation may still be processed, except for those categories already revoked. ⁹ A special provision also applies to imports of certain steel derivative products in the form of food trays used for the national nutritious meal programme. These are exempted from previous import requirements, provided that importers submit a statement of responsibility confirming their use for the programme. ¹⁰

Key Takeaway for Businesses

For companies importing Certain Products, the following steps are essential under MOT Reg 22/2025:

1. Check whether it is requiring a new Import Approval,
2. Confirm if the goods need surveyor verification,
3. Prepare to file import realisation reports regularly, and
4. Review whether the imports pass through the designated entry points.

Early compliance will help avoid delays at customs and prevent disruptions to the operations.

1. Article 2 of MOT Reg 22/2025 ↩
2. Article 3 of MOT Reg 22/2025 ↩
3. Article 4 of MOT Reg 22/2025 ↩
4. Article 5 of MOT Reg 22/2025 ↩
5. Article 15 of MOT Reg 22/2025 ↩
6. Article 6–10 of MOT Reg 22/2025 ↩
7. Article 17 of MOT Reg 22/2025 ↩
8. Article 16 of MOT Reg 22/2025 ↩
9. Article 18 of MOT Reg 22/2025 ↩
10. Article 18 of MOT Reg 22/2025 (duplicate reference) ↩

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Disclaimer:
This client update is the property of ARMA Law and intended for providing general information and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. ARMA Law has no intention to provide a specific legal advice with regard to this client update.

Go to

1. Scope of Products
2. Importer Obligations
3. Special Areas
4. Supervision & Sanctions
5. Transitional Provisions
6. Key Takeaway for Businesses

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