New Guidelines on Coal Blending Based on Minister of Energy and Mineral Resources Decree No. 323/2026

Introduction

On 13 August 2026, the Minister of Energy and Mineral Resources (“MEMR”) issued Minister of Energy and Mineral Resources Decree Number 323.K/MB.01/MEM.B/2026 on Guidelines for Procedures for the Application, Evaluation, and Approval of Coal Blending in Mineral and Coal Mining Business Activities (“MEMR Decree 323/2026”). This Decree establishes new guidelines for mineral and coal mining business actors in carrying out coal blending activities, including the procedures for submitting applications, the evaluation process, and the mechanism for granting approval by the Minister of Energy and Mineral Resources.

MEMR Decree 323/2026 was established to provide certainty and uniformity in the implementation of coal blending activities, particularly through the establishment of more structured procedures and evaluation parameters.

Key Provisions

• Delegation of Authority

Referring to the SECOND, THIRD, and FOURTH Dictums of MEMR Decree 323/2026, the authority to evaluate and grant approval or rejection of applications for coal blending is delegated to the Director General of Mineral and Coal, who, in exercising such authority, acts for and on behalf of the Minister of Energy and Mineral Resources. Furthermore, the Director General of Mineral and Coal is required to submit reports on the exercise of such authority to the Minister of Energy and Mineral Resources periodically every 6 (six) months or at any time if necessary.

• Application Procedures and Requirements

Referring to the FIRST Diktum of MEMR Decree 323/2026, holders of an IUP at the Production Operation stage, an IUPK at the Production Operation stage, an IUPK as a Continuation of a Contract/Agreement Operation for the Coal commodity, or a PKP2B are required to submit an application for approval of Coal blending through the information system by uploading the required application documents. Such documents include:

1. approval of the RKAB for each holder of an IUP, IUPK, IUPK as a Continuation of a Contract/Agreement Operation for the Coal commodity, or PKP2B that is the owner of the parent Coal and blending Coal;

2. copies of the agreement/contract for the purchase of blending Coal and sale of blended Coal that have been signed by the parties;

3. quality test results (certificate of analysis) of the parent Coal and blending Coal conducted by a surveyor registered with the Directorate General of Mineral and Coal; and

4. simulation results of Coal specifications before and after blending, covering calorific value on an as received and air dried basis, sulfur content, moisture content, and ash content.

Furthermore, referring to the Description of the Coal Blending Approval Application Flowchart in the Appendix to MEMR Decree 323/2026, the application is evaluated through the information system based on the evaluation criteria. If the required application documents are deemed incomplete or incorrect, the application is returned to the applicant. If the evaluation results indicate that the application does not meet the criteria, the information system issues a rejection notification to the applicant accompanied by the reasons for rejection. Conversely, if the documents are complete and the evaluation results meet the criteria, the Director General of Mineral and Coal issues a letter approving the Coal blending.

• Evaluation Criteria

In the document evaluation process, an application for Coal blending must meet several criteria, including:

Closing

MEMR Decree 323/2026 requires holders of an IUP, IUPK, IUPK as a Continuation of a Contract/Agreement Operation for the Coal commodity, or PKP2B to ensure that each application for Coal blending satisfies the prescribed administrative and substantive requirements. Business actors are required to prepare and upload complete, accurate, and consistent RKAB documents, agreements or contracts for the purchase and sale of Coal, Certificate of Analysis, and Coal specification simulation results. Applicants must also ensure that the simulation results conform to the contracts and the Coal quality test results, with the requirement that the quantity of parent Coal must be greater than that of the blending Coal. Applications that are incomplete, incorrect, or fail to meet the evaluation criteria may be returned or rejected through the information system.