Minister of Trade Regulation Number 18 of 2026 Tightens Import Controls and Regulates Automated Sanctions

Introduction

On 3 June 2026, the Ministry of Trade issued Minister of Trade Regulation Number 18 of 2026 on the Second Amendment to Minister of Trade Regulation Number 16 of 2025 on Import Policies and Regulations (“MOT Regulation 18/2026”), which took effect on 4 June 2026. This regulation amends and introduces several mechanisms relating to the automation of licensing processes, the issuance of technical verification reports, and the imposition of administrative sanctions on import businesses.

The Government seeks to improve the smooth flow of goods at ports and ensure efficiency in the implementation of national import policies. By enhancing a more electronically integrated licensing system and introducing adjustments relating to surveyor reports and the validity period of import documents, the Government seeks to address bureaucratic constraints and barriers to the entry of goods that frequently disrupt the stability of the trade supply chain.

 

Comparison

MOT Regulation 18/2026 amends and adds several provisions of Minister of Trade Regulation Number 16 of 2025 on Import Policies and Regulations (“MOT Regulation 16/2025”), as most recently amended by Minister of Trade Regulation Number 37 of 2025 (“MOT Regulation 37/2025”).

 

Key Provisions

Certainty of Licensing Issuance and Rejection Timeframes

The Government accelerates legal certainty for importers through amendments to Article 12 paragraph (4), Article 19 paragraph (4), and Article 22 paragraph (4) of MOT Regulation 18/2026. Under these provisions, if an application for Business Licensing in the Import sector, whether a new application, amendment, or extension, does not satisfy the applicable requirements, the functional official will electronically reject the application through the INATRADE System, which subsequently transmits the information to SINSW.

The Government further clarifies the system integration flow and the authority of officials in processing Business Licensing in the Import sector. Functional officials must electronically reject new applications, amendments, or extensions that do not satisfy the requirements through the INATRADE System no later than 5 (five) working days. Conversely, if businesses have submitted all required documents in full but the functional official does not issue the license within the 5-day period, the INATRADE System will automatically execute the issuance of the license.

Requirements for the Issuance of Surveyor Reports After License Expiration

The Government provides flexibility in the shipment of goods by introducing new provisions in Article 29 paragraphs (6a), (6b), and (6c). Article 29 paragraph (6a) stipulates that a Surveyor may issue an LS only if the imported goods comply with the issued Business Licensing requirements in the Import sector. However, Article 29 paragraph (6b) permits a Surveyor to issue the report after the validity period of the license has expired, provided that the importer satisfies the following requirements:

1. The Surveyor has conducted Verification or Technical Inspection in the country of origin, country of loading, or foreign port of loading; and
2. The importer ensures that the goods arrived at the destination port before the license validity period expired, as evidenced by the date stated in the BC 1.1 manifest document.

Furthermore, Article 29 paragraph (6c) provides a specific exception for certain goods that arrive at the destination port after the validity period of the license has expired. The Surveyor may still issue the report if the importer can demonstrate that the goods were loaded onto the means of transport while the import license remained valid. The importer may use a Bill of Lading (B/L) or Airway Bill (AWB) as evidence of such loading.

Automation of Administrative Sanctions

The Ministry of Trade strengthens administrative supervision through an automated system as provided under Article 69, Article 70, and Article 86 paragraph (1). Pursuant to Article 69 paragraph (1) and Article 70 paragraph (1), the system imposes electronic warning sanctions on importers who fail to comply with their obligations to submit import realization reports or distribution reports. If the importer disregards the electronic warning for 30 (thirty) days, Article 69 paragraph (2) and Article 70 paragraph (2) provide that the system may impose more severe sanctions.

These sanctions include license suspension, suspension of the issuance of new licenses, and/or the issuance of recommendations to suspend verification services by Surveyors. Article 86 paragraph (1) stipulates that the Director General automatically executes warning sanctions, suspensions, deferments, and reactivations through the INATRADE System connected to SINSW.

Sanctions Relating to Business Licensing in the Import Sector

Under Article 69, the system imposes electronic warning sanctions on importers who fail to submit import realization reports or distribution realization reports. If the importer leaves the warning unaddressed for 30 (thirty) days without submitting the required report, Article 69 paragraph (2) provides that the system will execute further sanctions, including:

1. Suspension of Business Licensing in the Import sector that remains valid;
2. Suspension of the process for issuing new licenses, license amendments, or license extensions;
3. Suspension of the issuance of subsequent Business Licensing in the Import sector if the importer becomes subject to sanctions after the license validity period has expired;
4. Issuance of recommendations to suspend Verification or Technical Inspection services by the Surveyor; and/or
5. Suspension of Business Licensing for the same commodity if the affected license has expired but the importer holds another active license for that commodity type.

Sanctions for Holders of Certificates

Under Article 70 paragraphs (1) and (2), the system imposes electronic warnings that may escalate into severe administrative sanctions if the importer fails to fulfill its reporting obligations within a period of 30 (thirty) days. Sanctions for violations relating to Certificates include:

1. Suspension of a Certificate that is valid for more than 1 (one) submission of an Import Customs Declaration;
2. Suspension of the issuance of subsequent Certificates for the importer concerned; or
3. Suspension of Certificates for the same commodity type if the previous document has expired.

Discretionary Authority for Import Exemptions

The Government introduces Article 91A to anticipate potential crises and emergency situations affecting the national logistics supply chain. Pursuant to Article 91A paragraph (1), the Minister is authorized to grant exemptions from the import policies and regulations set forth in MOT Regulation 18/2026 if disruptions occur in the smooth flow of imported goods. The Minister may exercise this exemption authority by considering national interests, public welfare, the implementation of government programs, and/or directives from the President. Before issuing such a decision, Article 91A paragraph (2) requires the relevant ministry responsible for economic affairs or food affairs to convene a high-level coordination meeting, or the decision may be based on the results of a meeting or decision of a Task Force established by the President.

 

Transitional Provisions

With respect to the implementation timeline, Article II stipulates that the provisions on the issuance of LS, examination of data elements and/or LS information, suspension of Business Licensing in the Import sector, and suspension of Certificates shall become effective on 4 July 2026.

 

Closing

MOT Regulation 18/2026 aims to facilitate the flow of goods at ports and address bureaucratic obstacles in trade. The regulation provides for the automated issuance of licenses through the INATRADE System when officials exceed the 5 (five) working-day processing deadline, allows flexibility in the issuance of LS after license expiration provided that the goods had arrived or been loaded while the license remained valid, and enables the automatic enforcement of administrative sanctions if importers disregard reporting warnings for 30 days. In addition to granting discretionary authority to the Minister to establish exemptions during emergency logistics supply chain crises, the implementation of these key regulatory adjustments is scheduled to become fully effective on 4 July 2026.