Government Reforms Palm Oil Export Governance through State-Owned Export Enterprises under Regulation of the Minister of Trade Number 16 of 2026

Introduction

On May 29, 2026, the Ministry of Trade (“MOT”) issued Regulation of the Minister of Trade Number 16 of 2026 on Policies and Regulations for the Export of Palm Oil Strategic Natural Resource Commodities (“MOT Regulation 16/2026”), which took effect on June 1, 2026. MOT Regulation 16/2026 regulates export policies and mechanisms for palm oil derivative products as part of the export governance of strategic natural resource commodities.

MOT Regulation 16/2026 was issued to implement Article 2 paragraph (5) and Article 5 of Government Regulation Number 24 of 2026 on Export Governance of Strategic Natural Resource Commodities. In the preamble, the government states that the regulation of strategic natural resource commodity exports is required to protect national interests, maintain economic stability, and ensure supply availability for domestic needs.

Comparison

MOT Regulation 16/2026 repeals and replaces Regulation of the Minister of Trade Number 26 of 2024 on Export Provisions for Palm Oil Derivative Products (“MOT Regulation 26/2024”), as amended by Regulation of the Minister of Trade Number 2 of 2025 (“MOT Regulation 2/2025”). The following is a comparison between MOT Regulation 16/2026 and MOT Regulation 26/2024 in conjunction with MOT Regulation 2/2025:

Key Provisions

Centralization of Exports through Export SOEs

Article 5 paragraph (1) and paragraph (2) stipulate that palm oil commodity export activities may only be conducted by Export SOEs holding a Business Licensing in the form of an Export Approval. To implement these provisions, Article 1 number 11 defines State-Owned Enterprises as business entities whose entire or majority capital is owned by the state through direct participation or which possess special privileges granted by the state. Article 1 number 12 further defines Export SOEs as SOEs assigned a specific task by the government to execute the Export of Strategic Natural Resource Commodities.

Geographical Scope and Classification of Palm Oil Derivative Commodities

Article 3 stipulates that the scope of palm oil strategic natural resource commodity exports encompasses the removal of goods from within the Customs Area, Free Trade Zones and Free Ports (Kawasan Perdagangan Bebas dan Pelabuhan Bebas, “KPBPB”), Special Economic Zones (Kawasan Ekonomi Khusus, “KEK”), and Bonded Storage Sites (Tempat Penimbunan Berikat, “TPB”) to outside the Customs Area. Pursuant to Article 2 paragraph (2) through paragraph (4) and the Annex, palm oil derivative commodities covered under this regulation include:

1. Crude Palm Oil (“CPO”) (tariff heading 1511.10.00);

2. Refined, Bleached, and Deodorized Palm Oil (“RBDPO”) (tariff heading ex 1511.90.20);

3. Refined, Bleached, and Deodorized Palm Olein (RBDPL) (tariff headings ex 1511.90.36, ex 1511.90.37, and ex 1511.90.39);

4. Used Cooking Oil (“UCO”) (tariff headings ex 1518.00.14, ex 1518.00.19, ex 1518.00.32, ex 1518.00.38, ex 1518.00.60, and ex 1518.00.90); and

5. Residue (tariff headings ex 2306.60.90 and ex 2306.90.90).

For UCO and Residue commodities, Article 4 stipulates that their export policies are determined based on the outcomes of inter-ministerial coordination meetings coordinated by the ministry responsible for government affairs in food.

Issuance of Export Approvals and Sources of Export Rights

The issuance of Export Approvals by the Director General of Foreign Trade is based on the commodity balance as stipulated in Article 15 paragraph (1). In addition, the issuance of Export Approvals requires the ownership of Export Rights pursuant to Article 6 paragraph (1). Such Export Rights may be obtained through participation in fulfilling the Domestic Market Obligation (“DMO”) for MINYAKITA cooking oil, which is recorded electronically in the Bulk Cooking Oil Information System (Sistem Informasi Minyak Goreng Curah, “SIMIRAH”), or through participation in the Acceleration Program.

Export Rights and Export Approval Categories

The Indonesia National Single Window (“SINSW”) system calculates the basis for obtaining Export Rights by considering the applicable export multiplier ratio as stipulated in Article 6 paragraph (6). Within this process, the processing of DMO recognition data as the basis for Export Rights in the Ministry's information system also accounts for Export Right incentives. Export Rights may be held by Export SOEs and businesses. Furthermore, the National Single Window Agency is authorized to freeze or reactivate Export Rights based on the outcomes of ministerial-level coordination meetings pursuant to Article 7 paragraph (1) and paragraph (2). Issued Export Approvals consist of categories as stipulated in Article 5 paragraph (4), namely:

1. Export Approvals for CPO, RBDPO, RBDPL, UCO, and Residue specifically for the MGR Program;

2. Export Approvals for Palm Oil Derivative Products for the Acceleration Program.

Electronic Transfer and Conversion of Export Rights

Holders of Export Rights for the RBDPL type under the MGR Program may transfer their rights to Export SOEs or other businesses electronically through SINSW as stipulated in Article 8 paragraph (1) and paragraph (2). Additionally, RBDPL Export Rights may be converted into Export Rights for other commodities, such as CPO, RBDPO, UCO, or Residue, pursuant to Article 9 paragraph (1) through paragraph (3).

Mitigation of Technical Obstacles through Manual Submission

In the event that the electronic system is unavailable, Export Right holders may submit applications for the transfer or conversion of Export Rights to be processed by the Director General of Foreign Trade as stipulated in Article 8 paragraph (9) through paragraph (11) and Article 9 paragraph (8) through paragraph (10). Such submissions are executed by uploading scanned copies of the original cooperation contract documents.

Fulfillment of Fiscal Obligations and Tax Compliance Requirements

Exporters are required to settle export duties and service tariffs of the Public Service Agency for the Palm Oil Plantation Fund Management Agency (Badan Layanan Umum Badan Pengelola Dana Perkebunan) as stipulated in Article 10 paragraph (1) and paragraph (2). This obligation applies to executors of Export Approvals for both the MGR Program and the Acceleration Program. Furthermore, the issuance of Export Approvals is preceded by a tax status confirmation pursuant to Article 11 paragraph (1) through paragraph (3). Through the INATRADE and SINSW systems, exporters must possess a valid tax status statement as a requirement for the issuance of Export Approvals.

Electronic Application Procedures and SINSW Access Rights

Export SOEs and businesses submit applications electronically through SINSW by first registering for access rights as stipulated in Article 12 paragraph (1) and paragraph (4). To obtain such access rights, applicants use a Taxpayer Identification Number (Nomor Pokok Wajib Pajak, “NPWP”). In submitting a Certificate for export exemptions, foreign national officials of international agencies or foreign representative offices may obtain access rights using a passport as stipulated in Article 20 paragraph (5). Meanwhile, for applications submitted by the government for its own use or grants, access rights are obtained by uploading the NPWP of the working unit's treasurer pursuant to Article 20 paragraph (6). Exporters are also not required to re-upload supporting documents that are already available at ministries or agencies integrated with SINSW as stipulated in Article 12 paragraph (6).

QR Code-Based Issuance and Validity Period of Export Approvals

Export Approvals are issued automatically by featuring a Quick Response (“QR”) code as stipulated in Article 13 paragraph (1) and Article 14 paragraph (1). Export Approvals for the MGR Program are valid for 6 (six) months from the date of issuance pursuant to Article 13 paragraph (5), whereas the validity period of Export Approvals for the Acceleration Program is determined by the Minister pursuant to Article 14 paragraph (8). If the volume of goods in an Export Approval has not been fully realized by the expiry of its validity period, the remaining quota cannot be converted back into Export Rights as stipulated in Article 13 paragraph (6).

Obligation to Amend Export Approval Data

Businesses are required to submit an application for an amendment to the Export Approval no later than 30 (thirty) calendar days from the date of data modification as stipulated in Article 16 paragraph (1) and paragraph (2). Such amendments may include:

1. Identity;

2. Tariff heading (HS);

3. Type or description of goods;

4. Volume of goods;

5. Export loading port; and

6. Destination country.

Amendments to Export Approvals are issued within a maximum of 5 (five) working days pursuant to Article 17 paragraph (1).

Temporary Suspension and Further Verification

The Export Approval issuance process may be temporarily suspended if the system encounters disruptions or the trade technical team requires further administrative verification as stipulated in Article 18 paragraph (1). Further verification by the technical team may be conducted under specific conditions pursuant to Article 18 paragraph (3), namely if:

1. The applicant has never previously conducted exports;

2. Cross-administrative checks with relevant government agencies are required;

3. There are examination proposals or recommendations from related agencies; and/or

4. There are conditions requiring supply control and fulfillment of domestic needs.

Non-Commercial Export Exemptions and Issuance of Certificates

Shipments of palm oil derivative products not intended for commercial purposes are exempted from the obligation to hold a Business Identification Number and an Export Approval as stipulated in Article 19 paragraph (1). However, to execute such exports, applicants are required to obtain a Certificate electronically pursuant to Article 20 paragraph (1). Pursuant to Article 19 paragraph (2) and Article 21 paragraph (1) and paragraph (2), such exemptions apply to:

1. Personal effects of passengers or border crossers;

2. Exhibition goods, accompanied by an exhibition invitation and a legalized self-declaration; and

3. Product samples, scientific research purposes, and grants or charitable donations, accompanied by technical recommendations from the relevant agency and a legalized self-declaration.

The Certificate is valid for 6 (six) months and may only be used for 1 (one) submission of an Export Customs Declaration as stipulated in Article 22 paragraph (6) and paragraph (7).

Obligation to Report Realization and Administrative Sanctions

Holders of Export Approvals and Certificates are required to submit realization reports electronically through SINSW no later than the 15th day of the following month as stipulated in Article 23 paragraph (1) and Article 24 paragraph (1), regardless of whether the goods have been exported or remain unrealized. For Export Approvals, realization reports contain data regarding the type or description of goods, tariff heading (HS), volume and unit of goods, value of goods, loading port, destination country, and the number and date of the Export Customs Declaration. Violations of the reporting obligation may be subject to administrative sanctions pursuant to Article 25 through Article 30 paragraph (1), in the form of a written warning, suspension of the Export Approval for 30 (thirty) days, deferral of the issuance of new Export Approvals, or revocation of the Export Approval. Revocation sanctions may be imposed if a business is proven to have altered information contained in documents, discrepancies are found in supporting documents and data, customs regulations are violated, or a criminal court decision is rendered. To support the monitoring of the implementation of these provisions, Article 41 regulates the establishment of an Integrated Export Monitoring Team involving relevant ministries, agencies, and institutions.

Transitional Provisions

Since MOT Regulation 16/2026 took effect, the application services for Export Approvals for UCO and Residue commodities are temporarily suspended until the coordination meeting referred to in Article 4 is concluded pursuant to Article 42. Furthermore, Article 43 stipulates that Export Approvals issued under MOT Regulation 26/2024 in conjunction with MOT Regulation 2/2025 remain valid until the expiry of their respective validity periods. 

During the transitional period, non-SOE businesses may continue to execute exports through Export SOEs and apply for amendments to Export Approvals until December 31, 2026. Transitional provisions also apply to goods that have obtained an Export Customs Declaration registration number prior to the entry into force of MOT Regulation 16/2026. Subsequently, Article 44 repeals Regulation of the Minister of Trade Number 26 of 2024 along with its amendments. Effective January 1, 2027, the export of commodities regulated under MOT Regulation 16/2026 may only be conducted by Export SOEs.

Closing

MOT Regulation 16/2026 regulates the export governance of palm oil strategic natural resource commodities by positioning Export SOEs as the entities authorized to conduct export activities based on issued Export Approvals, taking into account the commodity balance and ownership of Export Rights. MOT Regulation 16/2026 encompasses regulations on CPO, RBDPO, RBDPL, UCO, and Residue commodities; the sources and calculation of Export Rights derived from the fulfillment of MINYAKITA DMO and the Acceleration Program; the transfer and conversion of Export Rights via SINSW; manual submission mechanisms under certain conditions; obligations to settle export duties and service tariffs of the Public Service Agency for the Palm Oil Plantation Fund Management Agency; tax status confirmations; procedures for electronic Export Approval applications; and the issuance of QR code-based Export Approvals valid for 6 (six) months, with the provision that unrealized remaining quotas cannot be converted back into Export Rights. Beyond regulating amendments to Export Approval data, the temporary suspension of issuance, and further administrative verification under specific conditions, MOT Regulation 16/2026 also regulates non-commercial export exemptions through Certificates, export realization reporting obligations, the establishment of the Integrated Export Monitoring Team, and the imposition of administrative sanctions for violations of the applicable provisions. During the transitional period, Export Approval applications for UCO and Residue are temporarily suspended until the coordination meeting is concluded; Export Approvals issued under MOT Regulation 26/2024 in conjunction with MOT Regulation 2/2025 remain valid until the expiry of their respective validity periods; transitional provisions remain applicable to goods that have obtained an Export Customs Declaration registration number before MOT Regulation 16/2026 took effect; and non-SOE businesses may still execute exports through Export SOEs and apply for amendments to Export Approvals until December 31, 2026. Subsequently, effective January 1, 2027, the export of commodities regulated under MOT Regulation 16/2026 may only be conducted by Export SOEs.