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Indonesia’s Ministry of Trade has issued Regulation No. 20 of 2025 on the import of chemicals, hazardous substances, and certain minerals, replacing Regulation No. 36 of 2023 (as amended). The rule was promulgated on 30 June 2025 and took effect on 29 August 2025.

Scope and Coverage

The regulation establishes import controls for the following categories:

• Non-pharmaceutical precursors, nitrocellulose (NC), industrial explosives, ozone-depleting substances (ODS/BPO), hazardous substances (B2), hydrofluorocarbons (HFCs), and certain designated chemicals (BKT) listed in the annexes. Examples in the annex materials and official briefings include commodity-grade inputs such as sodium tripolyphosphate (STPP), formic acid, and lysine and its salts, as well as numerous HFC refrigerant blends referencing components like HFC-134a and HFC-32.

Legal Basis and Key Dates

• Issued: 30 June 2025 (promulgated in the State Gazette).
• Effective: 29 August 2025 (60 days after promulgation).
• Replacing: Minister of Trade Reg. 36/2023 (as last amended by 8/2024) for the covered chemical streams.

Import Licensing and Verification

Importers must hold appropriate business permits and import approvals before goods enter Indonesia’s customs territory, using the regime defined in the regulation:

• IT (Importir Terdaftar / Registered Importer),
• IP (Importir Produsen / Producer Importer), and
• PI (Persetujuan Impor / Import Approval).

The regulation also formalizes verification/technical tracing by authorized surveyors and the issuance of Laporan Surveyor (LS) where required. Definitions for IT, IP, PI and LS are standardized in Article 1.

Electronic Realisation Reporting

Holders of PI or LS must submit electronic import realisation reports, covering both realised and unrealised volumes, in accordance with the trade licensing framework administered by the Ministry of Trade. Non-compliance triggers administrative sanctions.

Treatment in Special Regimes (FTZ/SEZ/Bonded)

The regulation distinguishes the treatment of goods entering Free Trade Zones (KPBPB), Special Economic Zones (KEK), and Bonded Warehouses (TPB):

• For BKT and certain bulk commodities (e.g., lube base stocks, cement/clinker, oil and gas), imports into TPB are not subject to import licensing/verification at entry; however, full import requirements apply when released into the domestic market.
• By contrast, ODS (BPO), HFCs, non-pharma precursors, nitrocellulose, industrial explosives, and hazardous substances (B2) are regulated upon entry into TPB, requiring import licensing and, where applicable, verification. Similar controls apply to KPBPB/KEK movements as specified in the rule.

Transitional Provisions

Existing IT/IP/PI documents remain valid until expiry and may be amended or extended under the new framework. However, previously issued PI for Certain Chemicals (BKT) under API-P/API-U are expressly revoked via the INATRADE system. Surveyor (LS) documents issued under prior rules remain valid through completion of the relevant importation.

Compliance Actions for Industry

• Map your HS codes against the annexes to determine whether your products fall under B2, ODS, HFCs, precursors, NC, explosives or BKT controls.
• Confirm permit status (IT/IP/PI) and whether LS verification applies to your line items.
• Set up reporting processes to file electronic import realisation reports for PI/LS-covered shipments.

Assess zone strategy: imports routed via TPB/KPBPB/KEK may obtain warehousing efficiencies, but domestic release will trigger full import controls; certain categories are regulated at all stages including entry.