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    Bali Visa > Blog > Business Consulting > Is Permendag 23/2025 Hiding Import Restrictions from You?
Permendag 23/2025 import rules 2026 – hidden restrictions, zone nuances and reporting duties
December 12, 2025

Is Permendag 23/2025 Hiding Import Restrictions from You?

  • By KARINA
  • Business Consulting, Legal Services

Permendag 23/2025 looks like another import rule, but it quietly reshapes how consumer goods enter Indonesia. Many importers notice the headlines, yet miss the fine print.

At its core, Permendag 23/2025 tightens control over consumer goods. The text on Kementerian Perdagangan’s regulation database shows how it replaces older import rules.

Behind the scenes, Permendag 23/2025 links to risk based licensing and customs checks. Guidance from BPK’s official regulation portal helps decode the legal backbone.

But the real impact comes from seven less publicised restrictions. They decide who may import, which ports you can use, how reports are filed, and when sanctions hit, even with low volumes.

This guide turns Permendag 23/2025 into a checklist. For each hidden restriction, you will see how it works, where importers slip, and what documentation you must prepare before shipment.

Use these insights with updates from Kemenkeu’s restriction list so your Permendag 23/2025 strategy is aligned from HS code to warehouse door.

Table of Contents

  • Core Permendag 23/2025 Rules Every Importer Must Grasp
  • Permendag 23/2025’s Hidden Pre-Shipment Approval Demands
  • Zone and Bonded Warehouse Limits Under Permendag 23/2025
  • Real Story — When Permendag 23/2025 Killed a Shipment Plan
  • Import Realization Reports and Data Traps in Permendag 23/2025
  • Complementary and Market-Test Imports Under Permendag 23/2025
  • Using Exceptions Under Permendag 23/2025 Without Missteps
  • Sanctions and Audit Triggers Hidden in Permendag 23/2025
  • FAQ’s About Permendag 23/2025 Import Restrictions for 2026

Core Permendag 23/2025 Rules Every Importer Must Grasp

Permendag 23/2025 resets Indonesia’s consumer goods import regime. It replaces earlier trade rules and sets one frame for PI, LS, HS clusters, ports, zones and sanctions in one regulation.

For operational teams, Permendag 23/2025 means you cannot treat consumer goods as a generic category. Each cluster has its own path, conditions and documents that must appear in the customs entry.

The first restriction is mindset. If your SOP still cites prior rules, you risk using expired permits or outdated HS treatments. Permendag 23/2025 must become your main reference point.

Permendag 23/2025’s Hidden Pre-Shipment Approval Demands

Permendag 23/2025 restrictions 2026 – pre-shipment approvals, surveyor checks and stricter gateways

Permendag 23/2025 quietly tightens pre-shipment controls. For many consumer goods, shipment now needs Import Approval and a Surveyor Report before customs will even consider clearing cargo. 

Missing or mismatched PI or LS is not a small error. Under Permendag 23/2025, customs must reject clearance where required approvals are absent or do not align with HS code, quantity or origin data. 

The real trap is timing. If you apply late, goods may arrive before permits are issued. Under Permendag 23/2025 that delay converts straight into storage cost and the risk of regulatory scrutiny.

Zone and Bonded Warehouse Limits Under Permendag 23/2025

Permendag 23/2025 treats KEK, KPBPB and TPB as special spaces. Some import rules pause when goods first enter these zones, but they reactivate the moment goods move into the customs territory. 

For certain consumer goods, including food, cosmetics, bags, footwear and bicycles, zone entries may skip PI or LS at first. Yet Permendag 23/2025 reimposes those conditions when goods leave the zone. 

Alcohol is even tighter. Some duty-not-paid beverages can only circulate within specific bonded logistics and may never be released to the wider market, a limit many importers overlook.

Real Story — When Permendag 23/2025 Killed a Shipment Plan

Permendag 23/2025 looked simple to Rudi, an importer bringing branded footwear via a bonded logistics centre. His forwarder said PI and LS could follow while the goods sat in the warehouse.

Delays hit. The PI under Permendag 23/2025 was issued for a nearby HS code and smaller quota than the shipment. Customs refused release, citing mismatched approval and restricted goods settings. 

Rudi had to re-route part of the shipment and absorb extra costs. The lesson was clear: plan PI, LS and zone strategy together, using Permendag 23/2025 as the blueprint, not a post-arrival fix.

Import Realization Reports and Data Traps in Permendag 23/2025

Permendag 23/2025 adds a reporting restriction many miss. Importers must file Import Realization Reports, including certain non-executed imports, within set deadlines by electronic channels. 

Late or missing reports trigger administrative sanctions, even if your physical cargo flow is clean. Under Permendag 23/2025, paperwork alone can undermine your ability to keep using approvals. 

The real risk is data mis-alignment. If reports understate use of PI or LS, the system may flag discrepancies. Internal tracking must match precisely what Permendag 23/2025 expects to see.

Complementary and Market-Test Imports Under Permendag 23/2025

Permendag 23/2025 rules 2026 – complementary goods, market test imports and quiet quota limits

Permendag 23/2025 allows complementary and market-test imports, but these are not loopholes. They sit on tight PI conditions, LS duties and specific HS lists that cap what can enter. 

Volumes are limited and tied to clear business logic, like testing demand or supplying lines that support domestic production. Using them to bypass normal quotas misreads Permendag 23/2025. 

Treat these channels as strategic options, not back doors. Each approval under Permendag 23/2025 should map to product, timeline and exit plan, with evidence ready if auditors review choices.

Using Exceptions Under Permendag 23/2025 Without Missteps

Permendag 23/2025 recognises that some imports are non-commercial or special. For them, the regulation opens tightly framed exceptions, often backed by a formal certificate from the Director General. 

The hidden restriction is eligibility. Many importers assume they qualify, but exceptions are narrow. They depend on purpose, importer type and legal basis, not convenience or short-term stock gaps. 

Mis-using an exception can backfire. If reviews show routine commercial flows labelled as “special”, authorities can withdraw approvals and question earlier shipments under Permendag 23/2025.

Sanctions and Audit Triggers Hidden in Permendag 23/2025

Permendag 23/2025 builds a structured sanctions ladder. It ranges from warnings to suspension or revocation of approvals or business rights for repeat or serious breaches of import conditions. 

The quiet restriction is targeted monitoring. The rule calls out NIB, API, HS codes, PI and LS as audit points. If patterns look odd, your company may be pulled into focused trade supervision. 

Over time, a poor record under Permendag 23/2025 can affect credibility with banks, partners and other ministries. Clean files become a strategic asset, not just a compliance cost.

FAQ’s About Permendag 23/2025 Import Restrictions for 2026

  • What does Permendag 23/2025 actually regulate?

    It governs consumer goods imports into Indonesia, setting who may import, what approvals are needed, which zones are used and how reports and sanctions work.

  • Is Permendag 23/2025 only about new approvals?

    No. It also shapes HS groupings, port choices, treatment of bonded zones, complementary imports, reporting duties and the way sanctions escalate over time.

  • How soon before shipment should I apply for PI and LS?

    As early as possible. Permendag 23/2025 assumes approvals and surveyor reports are in place before goods move, not while cargo is already waiting at the port.

  • Do KEK or TPB remove my compliance burden?

    They mainly shift the timing. Permendag 23/2025 may relax some entry rules into zones, but conditions reappear when goods leave for the domestic market.

  • What happens if I skip Import Realization Reports?

    Repeated failures can trigger administrative sanctions. Over time that may threaten approvals or your ability to import under Permendag 23/2025 at all.

  • Can small importers rely on exceptions instead of PI and LS?

    Only if they truly fit the narrow exception criteria. It is safer to assume Permendag 23/2025 applies fully unless a clear written basis says otherwise.

Questions on Permendag 23/2025? WhatsApp our import compliance team today for clear guidance.

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KARINA

A Journalistic Communication graduate from the University of Indonesia, she loves turning complex tax topics into clear, engaging stories for readers. Love cats and dogs.

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