Decree of the Minister of Finance Number 19/MK/BC/2026 on the Updated List of Export-Restricted Goods and the Tightening of Technical Export Requirements

Introduction

On 30 March 2026, the Minister of Finance (“MOF”) issued Decree of the Minister of Finance Number 19/MK/BC/2026 on the List of Goods Restricted for Export based on Regulation of the Minister of Trade Number 23 of 2023 on Export Policies and Regulations as amended several times, most recently by Regulation of the Minister of Trade Number 5 of 2026 on the Fourth Amendment to Regulation of the Minister of Trade Number 23 of 2023 on Export Policies and Regulations (“MOF Decree 19/2026”).

MOF Decree 19/2026 governs the supervision by the Directorate General of Customs and Excise (Direktorat Jenderal Bea dan Cukai, “DJBC”) over the export of goods requiring licensing from technical agencies prior to export, and updates the list of goods restricted for export. The list is stipulated based on Regulation of the Minister of Trade Number 23 of 2023 on Export Policies and Regulations as last amended by Regulation of the Minister of Trade Number 5 of 2026, and reflects the submission of export policy changes from the Ministry of Trade.

Comparison

MOF Decree 19/2026 revokes Decree of the Minister of Finance Number 6/KM.4/2025 on the List of Goods Restricted for Export based on Regulation of the Minister of Trade Number 23 of 2023 on Export Policies and Regulations as amended several times, most recently by Regulation of the Minister of Trade Number 9 of 2025 on the Third Amendment to Regulation of the Minister of Trade Number 23 of 2023 on Export Policies and Regulations (“MOF Decree 6/2025”). The following is a comparison between MOF Decree 19/2026 and MOF Decree 6/2025:

Key Provisions

Stipulation of the List of Goods Restricted for Export

The SECOND Dictum stipulates the list of goods restricted for export, while the FIRST Dictum stipulates the implementation of its supervision within the customs area. This list follows the policies of technical agencies, specifically the Ministry of Trade, and is utilized in the supervision of prohibitions and restrictions by the customs authority. Every listed commodity must fulfill licensing requirements prior to loading onto the conveyance.

Stipulation of Annexes as Operational References for Export Supervision

The SECOND Dictum stipulates that the Annex in MOF Decree 19/2026 constitutes the list of goods restricted for export. This list contains tariff posts, goods descriptions, and licensing requirements that businesses must fulfill. The customs authority uses this list in document examination and physical inspection to ensure compliance with export restriction provisions.

Customs Supervision Area Coverage Over Export Flows

Export restrictions apply to several zones within the customs area as set forth in the THIRD Dictum. Supervision by the customs authority covers:

1. The release of goods from Bonded Storage Places (Tempat Penimbunan Berikat, “TPB”) outside the customs area;

2. The release of goods from Special Economic Zones (Kawasan Ekonomi Khusus, “KEK”) outside the customs area;

3. The release of goods from Free Trade Zones and Free Ports (Kawasan Perdagangan Bebas dan Pelabuhan Bebas, “KPBPB”) outside the customs area, excluding the Sabang KPBPB; and

4. The entry of goods into the Sabang KPBPB from other places within the customs area.

Termination of Supervision Over Certain Goods

If the regulations of the relevant technical agency are repealed such that all goods in the list are no longer subject to customs supervision, this Decree of the Minister is repealed and declared invalid as set forth in the FOURTH Dictum.

Export Restrictions on the Agricultural and Food Sectors

Businesses in these sectors must possess an Export Approval (Persetujuan Ekspor, “PE”) prior to conducting exports based on the Annex to MOF Decree 19/2026 for the food and animal products commodity group. Commodities included in this group comprise:

1. Staple food materials in the form of rice in various varieties, including glutinous rice;

2. Animals and animal products, including livestock breeding stock, animal semen, and hatching eggs.

Export Restrictions on the Wildlife Sector

Businesses exporting Natural Plants and Wildlife (Tumbuhan Alam dan Satwa Liar, “TASL”) commodities included in the Appendices to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (“CITES”) must fulfill the following provisions:

1. Possess a Plant and Wildlife Export Approval (PE-TASL);

2. Cover specific types of flora and fauna, including their derivative products.

Export Restrictions on the Mining and Energy Sectors

Businesses in these sectors must fulfill requirements in the form of an Export Approval for metal scrap and waste commodities, as well as technical verification through a Surveyor Report (Laporan Surveyor, “LS”) for other mining and energy commodities prior to conducting exports based on the Annex to MOF Decree 19/2026. Commodities in this group comprise:

1. Coal and its derivative products such as lignite and briquettes;

2. Mining products resulting from processing and refining such as copper cathodes, nickel, and other mineral concentrates;

3. Ferrous and non-ferrous metal scrap and waste, including copper, aluminum, and steel waste.

Export Restrictions on the Chemical Industry, Precursors, and Fertilizer Sectors

Businesses in these sectors must fulfill licensing requirements prior to conducting exports based on the Annex to MOF Decree 19/2026 for the chemical industry, precursors, and fertilizer commodity group. Commodities in this group comprise:

1. Hazardous chemicals (B3) and narcotics and psychotropic precursors;

2. Ozone-depleting substances (Bahan Perusak Lapisan Ozon, “BPO”);

3. Subsidized fertilizers such as urea and NPK, with mandatory verification of licensing documents from technical agencies through the Indonesia National Single Window system.

Export Restrictions on the Forestry and Wood Industry Sectors

Businesses exporting processed wood products and manufactured wood products must fulfill certification and technical verification requirements prior to conducting exports based on the Annex to MOF Decree 19/2026 for the forestry and wood industry commodity group. These provisions include:

1. V-Legal Documents or FLEGT Licenses;

2. Surveyor Reports for certain types of wood products such as sawn timber or veneer.

Export Provisions for Cultural Heritage Objects and Valuables

Businesses exporting cultural heritage objects or valuables must possess a license from the ministry in charge of cultural affairs prior to conducting exports based on the Annex to MOF Decree 19/2026 for the cultural heritage objects and valuables commodity group. Commodities included in this group cover cultural heritage objects or specific collections.

Export Provisions for Textile Industry Products and Other Textile Goods

Businesses exporting certain textile products must fulfill licensing or technical verification requirements prior to conducting exports based on the Annex to MOF Decree 19/2026 for the textile industry and other textile goods commodity group. Commodities in this group cover textile fibers and certain textile products.

Export Restrictions on the Explosives Sector

Businesses exporting explosives or related components must possess a license from the Indonesian National Police prior to conducting exports based on the Annex to MOF Decree 19/2026 for the explosives commodity group. Commodities in this group comprise:

1. Gunpowder and other industrial explosives;

2. Ammunition and parts thereof.

Export Restrictions on the Ozone-Depleting Substances (BPO) Sector

Businesses exporting ozone-depleting substances (BPO) must fulfill licensing requirements prior to conducting exports based on the Annex to MOF Decree 19/2026 for the ozone-depleting substances commodity group. These provisions include:

1. Possession of an Export Approval that has been validated by the ministry in charge of environmental affairs;

2. The conformity of chemical types with the tariff posts listed in the annex to prevent the illegal trade of hazardous chemicals.

Special Export Provisions for Kratom Plants

Businesses exporting kratom plants (Mitragyna speciosa) must fulfill technical requirements prior to conducting exports based on the Annex to MOF Decree 19/2026 under sequence number 1,697. These provisions include:

1. The obligation to attach a Surveyor Report as a supplementary customs document;

2. The obligation to fulfill technical specifications in the form of a maximum particle size of 600 microns, whether in the form of cuts, crumbs, or powder.
   

Transitional Provisions

Since MOF Decree 19/2026 took effect on 1 April 2026 as set forth in the SIXTH Dictum, export activities must align with the latest list in the annex. Businesses that already possess an Export Approval document based on the previous regulatory framework may continue to use the said license provided that the tariff posts and goods descriptions conform to the latest classifications in the Indonesia National Single Window system. Furthermore, supervision over certain goods may be terminated if technical agencies repeal their restriction provisions through sectoral regulation changes.

Closing

MOF Decree 19/2026 affirms the strengthening of export supervision by the Directorate General of Customs and Excise through the alignment of the restricted goods list based on the latest Ministry of Trade policies, including the rationalization of the commodity count to 1,697 items and the updating of the goods classification system in the annex as an operational reference, thereby directly impacting the obligations of businesses. Businesses must ensure accurate goods classification and the fulfillment of all licensing requirements from technical agencies prior to conducting exports. Sectorally, the customs authority focuses compliance obligations on the fulfillment of Export Approvals for food commodities, animal products, and wildlife; technical verification through Surveyor Reports for the mining and energy sectors and certain commodities; and special certifications such as V-Legal for forestry products, while simultaneously maintaining technical requirements on specific commodities including kratom plants, which are subject to a maximum particle size requirement of 600 microns. Since taking effect on 1 April 2026, businesses must align all documents and export processes with the list in the annex, including ensuring the conformity of tariff posts in the Indonesia National Single Window system, considering that any discrepancy may result in the automatic rejection of the Export Declaration (Pemberitahuan Ekspor Barang, “PBE”) registration and the detention of goods by the customs authority during inspection.