New Regulated Lists of Goods Restricted from Import – Minister of Trade Regulation No. 47 of 2025 on Goods Subject to Import Limitation

The Minister of Trade (“MoT”) has recently issued MoT Regulation No. 47 of 2025 on Goods Subject to Import Limitation (“MoT Reg. 47/2025”), which took effect on 1 January 2026. This regulation is a new basis for Indonesia’s import restrictions, which revokes the previous regulation regarding importation restrictions under MoT Regulation No. 18 of 2021 on Export Prohibited Goods and Import Prohibited Goods (“MoT Reg. 18/2021”), and partially revokes MoT Regulation No. 21 of 2025 on Policy and Regulation on Import of Electronics and Telematics Goods.

The issuance of MoT Reg. 47/2025 reflects the government’s intention to strengthen import control mechanism, which ultimately designed to ensure stability of the national interest, public health, and environmental sustainability, directly or indirectly affected due to the mobilization and distribution of imported goods and commodities.

In light of the above, we highlight the specific new changes introduced by MoT Reg. 47/2025:

1. Changes on Restricted/Prohibited Goods

MoT Reg. 47/2025 introduces 2 additional categories of prohibited goods previously not banned, namely: (i) the cooling system-based goods other than fire extinguishers; and (ii) the cooling system-based electronic products.  This differs from MoT Reg. 18/2021, which prohibited imports of cooling system-based goods, but only those that use Chlorofluorocarbon (CFC) and Hydrochlorofluorocarbon-22 (HCFC-22), in their empty or filled condition.

For your ease of reference, please refer to the table below, which summarizes the categories of restricted goods and commodities under the currently prevailing regulation, MoT Reg. 47/2025, with those under the preceding MoT Reg. 18/2021.

(the current listed goods and commodities shall be referred to as “Limited Goods”).

Similar to MoT Reg. 18/2021, the appendix of MoT Reg. 47/2025 sets out more detailed specifications of goods banned for imports. For example, sugar quality is measured using the International Commission for Uniform Methods of Sugar Analysis (ICUMSA) rating, which indicates the level of purity of the sugar.

2. Restrictions Applicable to the Limited Goods

The importers are prohibited from carrying out the following activities involving the Limited Goods:

1. importation to Free Trade Zones and Free Ports (Kawasan Perdagangan Bebas dan Pelabuhan Bebas or KPBPB);
2. importation to Special Economic Zones (Kawasan Ekonomi Khusus or KEK);
3. importation to Bonded Storage Facilities (Tempat Penimbunan Berikat or TPB); and
4. importation of Limited Goods and/or materials to be processed, assembled, or installed for export purposes (i.e., import-for-export).

(Article 4 of MoT Reg. 47/2025)

This limitation does not apply to re-imports of exported Limited Goods (Article 5 of MoT Reg. 47/2025). Such re-imports may occur due to returns, transaction cancellations, maintenance, or other administrative issues, and may require the Limited Goods to be sent back to Indonesia in accordance with customs laws and regulations.

3. Exemption to the Restriction on the Limited Goods

Notwithstanding the foregoing restriction, MoT Reg. 47/2025 provides a clear exemption through a transitional provision where the importation of Limited Goods was carried out before MoT Reg. 47/2025 took effect. This exemption applies specifically to the:

1. cooling system-based goods other than fire extinguishers; and
2. electronics-based cooling systems,

which use Hydrochlorofluorocarbon 123 (HCFC-123) in empty or filled condition.

The exemption is strictly based-on the condition that such goods were shipped before 1 January 2026 and arrived in the designated ports before or on 31 January 2026, evidenced by the relevant documentation. However, as the timeline has lapsed, this exemption is no longer relevant.

4. Applicable Sanction to the Violation of MoT Reg. 47/2025

MoT Reg. 47/2025 stipulates that importers that fail to comply with these restrictions are subject to administrative sanctions. However, the regulation does not expressly detail the applicable sanctions, and instead, refer the sanctions to those under Government Regulation (“GR”) No. 29 of 2021 on Implementation of the Trade Sector, as amended by GR No. 3 of 2026 (“GR 29/2021”).

According to Article 166 (1) and (2) of GR 29/2021, the applicable sanctions are as follows:

1. written warning;
2. temporary suspension of business activity;
3. coercive measure;
4. administrative fee;
5. suspension of the business license and/or the business license to support business activities; and/or
6. revocation of the business license and/or the business license to support business activities.

Concluding Remarks

MoT Reg. 47/2025 reflects a clear tightening of Indonesia’s regulatory framework on imports, particularly with respect to the environmentally sensitive goods, hazardous materials, and certain strategic goods and commodities. Importers should assess their products fall within the scope of “Limited Goods” under MoT Reg. 47/2025, and evaluate how regulatory restrictions, including the prohibition on imports through designated zones and customs facilities, may affect existing supply chains and import agreement, particularly affecting those newly listed as Limited Goods.

As a risk-mitigation measure, importers should conduct an internal compliance review prior to shipment to ensure that the product classification and supporting customs documentation are accurate and complete. Where necessary, importers should seek clarification from the relevant authorities to reduce the risk of shipment rejection, administrative sanctions, or other operational disruptions under the current import regulation.

Disclaimer: The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. Specific legal advice should be sought by interested parties to address their circumstances.