Importing goods into Bali has always been a high-stakes game, but the landscape shifted dramatically with the introduction of Permendag 23/2025.
Many business owners assume that deregulation means easier access, only to find their containers trapped at customs due to misunderstood technical requirements.
The reality is that while bureaucracy has eased in some areas, the government has tightened the screws on specific compliance checks for consumer products, causing significant operational disruption for unprepared investors.
The burden of dealing with unexpected red tape is heavy for foreign investors who rely on smooth supply chains. A single missing document can lead to rejection, fines, or even the revocation of your trading license under the new 2026 enforcement protocols.
Navigating these changes requires a precise understanding of the new “post-border” to “border” shifts that prioritize local market protection over unrestricted foreign entry.
Fortunately, the new system is navigable if you know exactly which boxes to tick before your shipment leaves its origin. By mastering the updated requirements for import licensing Indonesia, you can ensure your business remains compliant and profitable.
This guide breaks down the essential changes, helping you distinguish between genuine deregulation and the hidden restrictions that could catch you off guard. Visit the official Indonesia National Single Window to verify your initial status.
Table of Contents
- Overview of Permendag 23/2025 Regulations
- The Shift from Permendag 8/2024 to 2025 Rules
- Mandatory Pre-Entry Approvals and Verifications
- Impact on Consumer Goods and HS Codes
- Real Story: The Skincare Shipment Standoff
- The Role of Surveyor Reports (LS) in Customs
- Key Penalties for Non-Compliance in 2026
- Steps to Secure Your Import Rights Successfully
- FAQs about Permendag 23/2025 Regulations
Overview of Permendag 23/2025 Regulations
Permendag 23/2025 was issued by the Ministry of Trade to refine the flow of goods entering the archipelago. While it is marketed as part of a deregulation package aimed at making the investment climate more friendly, it simultaneously introduces rigorous technical barriers.
The regulation specifically targets “consumer goods” to prevent the local market from being flooded with substandard products that could harm domestic industries.
The core of this regulation is not an outright ban but a shift in when and how compliance is checked. Previously, many checks were done post-border, allowing goods to enter the market faster but with weaker oversight.
Now, the government demands that safety and technical standards (SNI) be verified before the goods even touch Indonesian soil. This “border” enforcement ensures that only compliant products enter the logistics chain.
For foreign investors in Bali, this means that the days of “bring it in and fix the paperwork later” are over.
The regulation aligns with the OSS-RBA (Online Single Submission Risk-Based Approach) system, categorizing imports based on potential risk. High-risk items now face scrutiny that mimics the strictness of import licensing Indonesia protocols seen in heavy industries, even for seemingly simple consumer items like apparel or electronics.
The Shift from Permendag 8/2024 to 2025 Rules
The transition from Permendag 8/2024 to the current 23/2025 framework marks a significant evolution in trade policy. The previous regulation was often criticized for its reliance on rigid quota systems that stifled business flexibility.
The new rules attempt to replace these arbitrary quotas with technical verifications, theoretically allowing for smoother trade if quality standards are met.
However, this shift has created a new bottleneck: the administrative burden of proof. Under Permendag 8/2024, an importer might have struggled to get a quota allocation. Under 23/2025, the struggle has moved to obtaining precise technical surveyor reports.
The definition of “finished goods” has also been expanded, capturing a wider net of products that previously flew under the radar as raw materials or intermediate goods.
Crucially, the 2026 enforcement strategy utilizes digital integration to flag discrepancies instantly. If your declared HS codes do not perfectly match the new Annex listings, the system rejects the entry application automatically. This binary “pass/fail” mechanism removes human discretion from the initial stages, making it vital to understand the exact requirements of import licensing Indonesia before initiating any shipment.
Mandatory Pre-Entry Approvals and Verifications
One of the most shocking aspects for new importers is the “Pre-Entry” requirement. The regulation mandates that the Import Approval (PI) and the Surveyor Report (LS) must be secured before the goods arrive at the customs zone. This is a departure from older practices where some documents could be processed while goods sat in bonded warehouses.
The Import Approval (PI) serves as your primary permission slip. It effectively tells the government what you intend to bring in and in what quantity.
This document is linked to your specific HS codes and requires proof that your products meet Indonesian National Standards (SNI). Without a valid PI, your cargo cannot even begin the customs clearance process.
Following the PI, the Surveyor Report (LS) is the final gatekeeper. This report is generated by an accredited surveyor in the country of origin, not in Indonesia. They physically inspect the cargo to ensure it matches the PI.
If the surveyor finds a discrepancy—say, 100 extra units of clothing not listed on the PI—the entire shipment can be flagged. This rigorous pre-entry process is now the backbone of the import licensing Indonesia system.
Impact on Consumer Goods and HS Codes
The brunt of Permendag 23/2025 falls on consumer goods, categorized broadly to include everything from children’s toys and beauty products to household appliances and ready-to-wear clothing.
The government has identified these sectors as vulnerable to low-quality imports, and thus, they require the highest level of scrutiny.
Importers must now audit their product lists against Annex I of the regulation. If your product falls into a regulated HS code, you cannot bypass the new checks. For example, a digital nomad importing a small batch of specialized coffee machines for a cafe in Canggu must now navigate the same compliance pathway as a large electronics retailer.
There is also a strict “Zone to Mainland” rule. Goods entering Free Trade Zones (like Batam) might face lighter initial checks, but moving those goods into the “customs territory” (like Jakarta or Bali) triggers the full weight of the regulation. Attempting to move goods internally without the proper import licensing Indonesia documents is considered a violation and is heavily penalized.
Real Story: The Skincare Shipment Standoff
Elena, a 34-year-old entrepreneur from Spain, thought her supply chain was bulletproof. For years, she had imported raw organic ingredients to her boutique in Uluwatu without a hitch. But in 2026, she decided to scale up by importing a line of finished serums from Barcelona.
That single decision triggered a regulatory avalanche. When her container hit the port in Surabaya, it was immediately red-flagged. Why? Because under Permendag 23/2025, finished goods are “consumer products” requiring a Surveyor Report (LS) from the origin country.
Elena had shipped first and checked the rules later—a mistake that left her goods frozen and her daily storage fees skyrocketing. She assumed the process would be similar to her raw material shipments, unaware that the new 2026 regulations treat consumer-ready goods with extreme scrutiny.
Without a pre-shipment Surveyor Report (LS), her cargo was blocked at the border, turning a routine restocking into a weeks-long standoff.
Desperate to save her investment, Elena used Bali Legals to intervene. They identified that her HS codes were misclassified and helped her petition for a re-examination while rushing a surveyor in Spain to verify the next batch.
Although she had to pay a steep lesson in demurrage fees for the first shipment, the corrective guidance saved her business license from revocation, allowing her to eventually clear the goods and keep her shop open.
The Role of Surveyor Reports (LS) in Customs
The Surveyor Report (LS) has evolved from a supplementary document to a critical “Golden Ticket” for entry. Under the 2026 guidelines, the LS is the only document that proves your goods existed in a compliant state before they left the origin country. It details the quantity, technical specifications, and condition of the goods.
This report must be uploaded to the customs portal (PEB) alongside your Import Approval. If the LS is missing, the system will issue a rejection notice immediately.
It is important to note that the LS cannot be issued retroactively once the ship has sailed. The inspection must happen pre-shipment.
The cost of obtaining an LS varies depending on the surveyor and the volume of goods, typically ranging from IDR 5 million to 20 million per shipment. While this adds to the upfront cost, it eliminates the risk of goods being rejected upon arrival.
For any business serious about import licensing Indonesia, budgeting for the LS is now as important as budgeting for shipping costs.
Key Penalties for Non-Compliance in 2026
The Indonesian government is not lenient with violators of Permendag 23/2025. Article 20 of the regulation outlines a sliding scale of sanctions that can cripple a business. The most common immediate penalty is the blocking of customs clearance, leaving your goods to rack up storage fees at the port.
Financial penalties have also increased. Fines for administrative errors or non-compliance can range from IDR 10 million to 100 million.
However, the greater risk is the suspension of your NIB (Business Identification Number) and API (Importer Identification Number). If you are flagged as a repeat offender, your ability to import can be revoked entirely.
Furthermore, there are criminal implications for fraud. Using a “nominee” to bypass restrictions or falsifying HS codes to avoid the “consumer goods” label is considered a serious offense.
2026 has seen a crackdown on these practices, with several high-profile PT PMA companies losing their licenses. Compliance with import licensing Indonesia is the only safe harbor.
Steps to Secure Your Import Rights Successfully
Securing your import rights in this new era requires a disciplined, step-by-step approach. The first step is to register as an Importer (IT) via the Indonesia National Single Window (INSW). This process takes 1-3 days and links your NIB to the customs database.
Next, you must apply for your Import Approval (PI). This is done online and requires you to submit all product documentation, including proof of SNI compliance if applicable.
This approval process typically takes 3-7 days. Once you have the PI, you must contact an accredited surveyor in the origin country to conduct the physical inspection and issue the LS.
Finally, ensure that all documents—the PI, LS, and commercial invoice—are uploaded to the customs system before the vessel arrives. Monitor your “realization reports” monthly; failing to report what you actually imported versus what you were approved for is a common trap.
By following this rigid structure, navigating import licensing Indonesia becomes a manageable, repeatable process.
FAQs about Permendag 23/2025 Regulations
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Does Permendag 23/2025 ban all consumer goods imports?
No, it does not ban them. It replaces quotas with stricter technical checks and requires import licensing Indonesia documents like the Import Approval (PI) and Surveyor Report (LS) to be in place before shipment.
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Can I process the Surveyor Report (LS) after the goods arrive in Bali?
No. The LS must be conducted and issued in the country of origin before the goods are loaded onto the vessel. If goods arrive without it, they will likely be rejected or re-exported.
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Who is exempt from these new import restrictions?
Exemptions apply to goods entering Special Economic Zones (KEK) until they are sold domestically, raw materials for export-oriented industries (KITE), and non-commercial personal shipments with a Certificate of Exemption.
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How long does it take to get an Import Approval (PI)?
The official timeline is 3-7 business days, provided all your documents, including SNI certificates and product details, are perfectly aligned with the regulations.
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What is the penalty for importing goods without the proper license?
Penalties range from the immediate rejection of the shipment and demurrage costs to fines up to IDR 100 million and the potential revocation of your company’s import identification number (API).
