Decree of the Minister of Finance Number 20/MK/BC/2026 Updating the List of Goods Prohibited from Export and Strengthening Customs Supervision

Introduction

On March 30, 2026, the Ministry of Finance (“MOF”) issued Decree of the Minister of Finance Number 20/MK/BC/2026 on the List of Prohibited Export Goods Based on Regulation of the Minister of Trade Number 22 of 2023 on Prohibited Export Goods, as amended several times, Most Recently by Regulation of the Minister of Trade Number 6 of 2026 (“MOF Decree 20/2026”), which took effect on April 1, 2026. MOF Decree 20/2026 stipulates the list of goods prohibited from being exported and serves as the basis for the Directorate General of Customs and Excise (Direktorat Jenderal Bea dan Cukai, “DJBC”) in conducting customs supervision. MOF Decree 20/2026 was issued pursuant to Regulation of the Minister of Trade Number 6 of 2026 on the Fourth Amendment to Regulation of the Minister of Trade Number 22 of 2023 on Prohibited Export Goods.

Comparison

MOF Decree 20/2026 repeals the provisions on export supervision previously stipulated in Decree of the Minister of Finance Number 5/KM.4/2025 on the List of Prohibited Export Goods Based on Regulation of the Minister of Trade Number 22 of 2023 on Prohibited Export Goods, as amended several times, Most Recently by Regulation of the Minister of Trade Number 8 of 2025 on the Third Amendment to Regulation of the Minister of Trade Number 22 of 2023 on Prohibited Export Goods (“MOF Decree 5/2025”). It serves to replace the previous framework by directly adjusting the scope of commodities subject to supervision. The following is a comparison between MOF Decree 20/2026 and MOF Decree 5/2025:

Key Provisions

Export Ban on Forestry Sector

MOF Decree 20/2026 prohibits the export of various types of wood and its processed products as set forth in the FIRST and SECOND Dictums and the Annex. This prohibition includes:

1. Wood types: Coniferous, fir, spruce, pine, hem-fir, jongkong, merbau, albizia, rubber (Hevea brasiliensis), and other tropical wood types.

2. Material forms: Raw wood, baulk, sawlog, veneer log, wood chips, and wood that is sawn lengthwise, planed, sanded, or end-jointed.

3. Derivative products: Window frames, door frames, shingles, cellular wood panels, and simply carved stakes.

Export Ban on Agricultural and Plantation Sectors

MOF Decree 20/2026 prohibits the export of certain agricultural and plantation commodities as set forth in the FIRST and SECOND Dictums and the Annex. This prohibition includes:

1. Natural rubber: Various processed forms such as air-dried sheet, latex crepe, sole crepe, skim rubber, rubber scrap, to deproteinised natural rubber.

2. Porang plants: All parts of the plant, including tubers (dormant or sprouted), stems, flowers, bulbils, leaves, and seeds.

3. Kratom plants (Mitragyna speciosa): Whole leaves, cut, or in powder form with a particle size of more than 600 microns.

Export Ban on Mining and Mineral Sectors

The export ban applies to certain mining and mineral commodities as set forth in the FIRST and SECOND Dictums and the Annex. The scope of this prohibition encompasses:

1. Non-metallic minerals: Silica and quartz sand (including gravel pack sand, molding sand, and low iron silica sand), kaolin, bentonite, fireclay, marble, granite, and basalt.

2. Metal ores and concentrates: Iron (including nickel pig iron products below a certain grade), manganese, copper, unwrought nickel, aluminum, lead, zinc, chromium, tungsten, and pure tin ingots.

3. Precious metals and strategic materials: Gold, silver, platinum, palladium, zirconium, titanium dioxide, and rare earth metals (such as scandium, lanthanum, and yttrium).

4. Industrial residues: Waste, scrap, and slag from iron, steel, or tin production.

Export Ban on Marine Sector and Special Commodities

The export ban encompasses certain commodities as set forth in the FIRST and SECOND Dictums and the Annex, covering:

1. Natural sand and marine sedimentation mud with specific grain sizes and mineral content.

2. Subsidized urea fertilizer (including those in aqueous solution, tablet form, or in packages with a gross weight not exceeding 10 kg).

3. Cultural heritage goods, archaeological collections, and specific specimens aged 50 years or older.

Expansion of Supervision to Facilitated Zones

Export supervision encompasses the release of goods outside the customs area as stipulated in the THIRD Dictum. These provisions apply to companies operating in:

1. Bonded Storage Facilities (Tempat Penimbunan Berikat, “TPB”);

2. Special Economic Zones (Kawasan Ekonomi Khusus, “KEK”); and

3. Free Trade Zones and Free Ports (Kawasan Perdagangan Bebas dan Pelabuhan Bebas, “KPBPB”).
   

Automatic Revocation Clause

MOF Decree 20/2026 shall be revoked if the provisions issued by the Ministry of Trade that serve as the basis for determining the export ban are no longer valid, thereby ending the export supervision of such goods by the Directorate General of Customs and Excise, as stipulated in the FOURTH Dictum.

Closing

MOF Decree 20/2026, which took effect on April 1, 2026, stipulates the list of prohibited export goods encompassing 482 tariff line details. This is an increase from previous provisions and covers forestry, agricultural and plantation, mining and mineral commodities, as well as specific commodities such as subsidized fertilizers and marine sedimentation sand. It simultaneously expands export supervision over the release of goods from facilitated zones, including Bonded Storage Facilities, Special Economic Zones, and Free Trade Zones and Free Ports. Therefore, businesses must ensure the conformity of goods specifications and HS Code classifications prior to conducting exports to prevent compliance issues in the customs process.