Adjustment of Mandatory SNI Requirements for Solid NPK Fertilizer under Minister of Industry Regulation 25/2026

Introduction

On 3 September 2026, the Ministry of Industry (“MOI”) issued Regulation of the Minister of Industry of the Republic of Indonesia Number 25 of 2026 on Amendments to Regulation of the Minister of Industry Number 11 of 2025 on the Mandatory Application of the Indonesian National Standard for Solid Nitrogen, Phosphorus, and Potassium Fertilizer (“Minister of Industry Regulation 25/2026”). This regulation amends a number of technical and administrative provisions under Minister of Industry Regulation 11/2025 concerning the mandatory application of the Indonesian National Standard (“SNI”) to Solid Nitrogen, Phosphorus, and Potassium (“NPK”) Fertilizer, including provisions concerning the Indonesian Standard Industrial Classification (“KBLI”), requirements for Authorized Representatives of Overseas Manufacturers, the appointment of Importers, and the legalization of documents for Overseas Manufacturers.

Minister of Industry Regulation 25/2026 was issued to improve the effectiveness of the mandatory application of SNI to Solid NPK Fertilizer, as reflected in the considerations section. One of the principal adjustments concerns the KBLI code for Solid NPK Fertilizer industrial activities, which has been changed from the previous 20123 and/or 20124 to 20122 as a follow-up to the changes in business classification under Regulation of the Statistics Indonesia Number 7 of 2025 concerning the Indonesian Standard Industrial Classification. In addition, this regulation adjusts the warehouse location requirements for Authorized Representatives, the mechanism for appointing Importers, and the procedures for legalizing documents for Overseas Manufacturers, including by introducing a legalization mechanism through apostille.

Comparison

Minister of Industry Regulation 25/2026 constitutes an amendment to Minister of Industry Regulation 11/2025, such that certain provisions of the previous regulation have been substantively amended, certain new provisions have been inserted, and the Annex concerning the certification scheme has also been comprehensively revised. The principal comparison between the new provisions and the previous provisions in several key aspects is set out in the following table.

Key Provisions

• Adjustment of Requirements for Solid NPK Fertilizer Industrial Companies

As stipulated in Article 11 paragraph (1), an Industrial Company applying for SNI certification for Solid NPK Fertilizer must possess a business license in the Solid NPK Fertilizer industry under KBLI number 20122, own a trademark for Solid NPK Fertilizer in class 1 (one), and have a SIINas account. The provision concerning KBLI 20122 replaces the previous use of KBLI code 20123 and/or 20124, as an adjustment to the changes in the classification of business activities in the Solid NPK Fertilizer industry.

In addition to these requirements, an Industrial Company applying for SNI certification using the type 5 (five) certification system must satisfy additional requirements in the form of implementation of the ISO 9001:2015 quality management system and ownership of production facilities appropriate to the Solid NPK Fertilizer production process. Such facilities include:

• mixing equipment (mixer) for the blending process;

• mixing equipment (mixer) and forming equipment (compactor) for the compaction process;

• melting equipment (melter) and a prilling tower for the prilling process;

• granulating equipment (granulator), drying equipment (dryer), cooling equipment (cooler), screening equipment (screener), and coating equipment (coater) for the steam granulation process; or

• reaction equipment (reactor), granulating equipment (granulator), drying equipment (dryer), screening equipment (screener), cooling equipment (cooler), and coating equipment (coater) for the chemical granulation process.

• Adjustment of Requirements for Authorized Representatives

Article 12 adjusts the requirements applicable to Overseas Manufacturers and Authorized Representatives. An Authorized Representative must be appointed by an Overseas Manufacturer, hold the license and responsibility for the trademark, have control over a warehouse, be able to act as an importer, and have a SIINas account. In principle, an Authorized Representative may only represent 1 (one) Overseas Manufacturer, with exceptions for certain corporate relationships, such as a parent company, a subsidiary of the same parent company, or a subsidiary of the Authorized Representative.

In addition, Article 13 provides that where an Authorized Representative has more than 1 (one) location, the domicile of the Authorized Representative shall refer to 1 (one) principal address, office, or correspondence address stated in the business licensing documents. Meanwhile, the warehouse address shall be the address stated in the SNI Certificate and SPPT SNI. Specifically for certification using the type 5 (five) system, the Overseas Manufacturer must also implement ISO 9001:2015 and possess production facilities appropriate to the Solid NPK Fertilizer production process used.

• Expansion of Authority to Appoint Importers

Article 14 amends the mechanism for the appointment of Importers by Authorized Representatives. Previously, an Importer could only be appointed if the Authorized Representative did not act as and did not function as the Importer itself. Minister of Industry Regulation 25/2026 removes this requirement, such that an Authorized Representative may now appoint an Importer subject to the following provisions:

● 1 (one) Importer company for each application for SNI Certification using the type 1 (one) b certification system; or

● a maximum of 5 (five) Importer companies for each application for SNI Certification using the type 5 (five) certification system, a number that was previously not expressly limited.

As a new provision, Article 14 paragraph (3) also stipulates that where an appointed Importer company has control over its own warehouse, the address of such warehouse must be stated in the SNI Certificate and SPPT SNI. The consequence of this amendment is also reflected in Article 41 paragraph (3), which now requires the name and address of the Importer company to be stated in the SNI Certificate “in the event that the Authorized Representative appoints an Importer”, rather than “in the event that the Authorized Representative does not function as an Importer” as provided previously.

• Apostille Mechanism for Document Legalization

Minister of Industry Regulation 25/2026 inserts 1 (one) new chapter between Chapter IV and Chapter V, namely Chapter IVA concerning Miscellaneous Provisions, containing Article 69A. Article 69A paragraph (1) provides that the legalization of the required documents as referred to in Article 20, Article 21, Article 22, Article 23, Article 24, Article 26, Article 27, Article 28, Article 29, and Article 30 may be carried out through the apostille mechanism. Previously, the provisions of these articles required 1 (one) original copy of the document to be legalized by a diplomatic official in the industrial or economic field, or by an Indonesian consular representative in the relevant country.

Accordingly, for Overseas Manufacturers or overseas business actors originating from countries that have ratified the Convention Abolishing the Requirement of Legalisation for Foreign Public Documents, legalization of documents required for SNI certification may be carried out through the apostille mechanism as an alternative to legalization by an Indonesian diplomatic official or consular representative.

• SNI Certification Scheme for Solid NPK Fertilizer

As stipulated in number 19 of Article I of Minister of Industry Regulation 25/2026, the provisions in the Annex to Minister of Industry Regulation 11/2025 have also been comprehensively amended. The new Annex sets out the Indonesian National Standard Certification Scheme for Solid NPK Fertilizer in greater detail and in a more structured manner in the form of a table of stages, covering the scope of application (initial certification, surveillance, and renewal/recertification), normative references (SNI 2803:2024 concerning Solid NPK Fertilizer and Regulation of the Minister of Industry Number 45 of 2022 concerning Industrial Standardization), as well as the procedures for obtaining an SNI Certificate through the type 1 (one) b and type 5 (five) certification systems in stages, beginning with the Selection Stage (application) through the subsequent stages of the conformity assessment process. The substance of this Annex consistently reflects the adjustment to KBLI 20122 and the adjustment to document requirements as described in the Key Provisions section above, such that business actors need to read this Annex in its entirety as a technical guide for the implementation of certification.

Transitional Provisions

Minister of Industry Regulation 25/2026 inserts Article 72A as a transitional provision. Business Actors that apply for the issuance of an SNI Certificate but have not yet adjusted their KBLI pursuant to Regulation of the Statistics Indonesia Number 7 of 2025 may continue to use KBLI 20123 and/or 20124 until 16 September 2027. After such period expires, Business Actors must use KBLI 20122.

Closing

Minister of Industry Regulation 25/2026 adjusts the provisions concerning the mandatory application of SNI to Solid NPK Fertilizer, particularly with respect to KBLI, the requirements applicable to Industrial Companies and Authorized Representatives, the appointment of Importers, and the legalization of documents through apostille.

Business Actors need to adjust their licensing and certification documents to comply with these new provisions. Specifically with respect to KBLI, the use of KBLI 20123 and/or 20124 remains permitted until 16 September 2027 for Business Actors that satisfy the transitional provisions; thereafter, KBLI 20122 must be used