MOT Regulation 32/2025: New Import Rules for Chemicals, Hazardous Materials, and Mining Materials

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Authors

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The Ministry of Trade (“MOT”) has recently introduced a regulatory change through the issuance of MOT Regulation No. 32 of 2025 on the Amendment to the MOT Regulation No. 20 of 2025 on Import and the Regulation of Imports of Chemicals, Hazardous Materials, and Mining Materials, promulgated on 22 September 2025 and effective as of 6 October 2025 (“MOT Reg 32/2025”). The earlier regulation established a new sector-based regime, including for chemicals, hazardous materials, and mining materials, with the objective of simplifying procedures and providing clearer guidance for import-related business activities.

In this ARMA Update, we highlight the key changes under MOT Reg 32/2025, including the expansion of regulated goods, import policy treatments in specific zones, and transitional provisions for ongoing shipments.

1. Expansion of Regulated Goods

   The previous regulation covered eleven categories of goods subject to import restrictions. MOT Reg 32/2025 expands this scope to include “other fuels” within the petroleum and natural gas category. Accordingly, the categories of regulated goods now comprise:

   1. lubricant raw materials;
   2. clinker and cement
   3. rough diamonds;
   4. non-pharmaceutical precursors;
   5. petroleum, natural gas, and other fuels;
   6. nitrocellulose (NC);
   7. explosives for commercial industries;
   8. ozone-depleting substances (ODS);
   9. hazardous materials (B2)
   10. hydrofluorocarbons (HFCs); and
   11. certain chemicals (Bahan Kimia Tertentu - BKT),
   (collectively referred to as “Chemicals, Hazardous Materials, and Mining Materials”).

   The detailed Harmonized System (“HS”) Codes for each category are listed in the annex to the regulation.

2. General Importer Obligations

   For Chemicals, Hazardous Materials, and Mining Materials, importers must comply with the following main obligations:

   1. Import Approval – importers must obtain Import Approval for specific tariff lines before goods enter the customs territory.
   2. Verification or Technical Tracing – certain goods must undergo inspection by appointed surveyors, with the results set out in a surveyor report.
   3. Designated Ports of Entry – MOT may designate specific ports as entry points for Chemicals, Hazardous Materials, and Mining Materials.
   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).

3. Import Policies in Free Trade Zones and Free Port

   Lubricant raw materials, clinker and cement, petroleum, natural gas and other fuels, and BKT imported into Free Trade Zones and Free Ports (Kawasan Perdagangan Bebas dan Pelabuhan Bebas – “KPBPB”) from outside the customs area are exempted from import policies. These policies apply only when the goods are transferred from KPBPB to other areas within the customs territory, covering import licensing, verification or technical inspection, and port of destination requirements.

4. Import Policies in Special Economic Zones

   Lubricant raw materials, clinker and cement, petroleum, natural gas and other fuels, and BKT imported into Special Economic Zones (Kawasan Ekonomi Khusus – “KEK”) from outside the customs area are not subject to import policies. These policies only apply when such goods are subsequently transferred from KEK to other areas within the customs territory, encompassing requirements on import licensing, verification or technical inspection, and designated ports of destination.

5. Import Policies in Bonded Storage Areas

   Lubricant raw materials, clinker and cement, petroleum, natural gas and other fuels, and BKT imported into Bonded Storage Area (Tempat Penimbunan Berikat – “TPB”) from outside the customs area are not subject to import policies. These policies only apply when such goods are subsequently transferred from TPB to other areas within the customs territory to be imported for use, encompassing requirements on import licensing, verification or technical inspection, and designated ports of destination.

6. Transitional Provisions

   Pursuant to MOT Reg 32/2025, the provisions of this regulation do not apply to the import of other fuels shipped prior to its effective date, as evidenced by the Bill of Lading (“B/L”) or Air Waybill (“AWB”), and arriving at the destination port no later than 31 October 2025, as evidenced by customs documents in the form of a manifest.

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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. Expansion of Regulated Goods
2. General Importer Obligations
3. Import Policies in Free Trade Zones and Free Port
4. Import Policies in Special Economic Zones
5. Import Policies in Bonded Storage Areas
6. Transitional Provisions

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