Minister of Trade Regulation Number 20 of 2026 Prevents Cooking Oil Shortages by Reinforcing Producers’ Supply Obligations and Introducing Warehouse Closure Sanctions
Introduction
On 29 June 2026, the Ministry of Trade issued Minister of Trade Regulation Number 20 of 2026 on Amendments to Minister of Trade Regulation Number 43 of 2025 concerning Packaged Palm Cooking Oil and the Governance of People’s Cooking Oil (“MOT Regulation 20/2026”), which took effect on 3 July 2026.
MOT Regulation 20/2026 strengthens the governance of packaged palm cooking oil distribution by reaffirming producers’ responsibility to ensure the availability and smooth supply of cooking oil in the domestic market.
The issuance of MOT Regulation 20/2026 reflects the Government’s response to strengthen control over the distribution of cooking oil and to anticipate potential supply disruptions that may affect the availability of essential goods for the public. The Regulation reinforces the obligations of businesses in the manufacturing sector while strengthening enforcement mechanisms through the introduction of administrative sanctions that may directly affect business operations, thereby encouraging producers to maintain a stable supply of cooking oil in the domestic market.
Comparison
MOT Regulation 20/2026 inserts a new article and amends the sanction provisions previously stipulated under Minister of Trade Regulation Number 43 of 2025 concerning Packaged Palm Cooking Oil and the Governance of People’s Cooking Oil (“MOT Regulation 43/2025”). The comparison is set out below:
|
Aspect |
MOT Regulation 20/2026 |
MOT Regulation 43/2025 |
|
Producers’ Supply Obligation |
Introduces an obligation for producers to supply packaged cooking oil to meet domestic household consumption needs. |
Not regulated. |
|
Sanctions in the Event of a Shortage |
Where a shortage of goods occurs, producers that fail to fulfill their supply obligations are subject to graduated administrative sanctions, ranging from written warnings to government enforcement measures in the form of warehouse closures and temporary suspension of operations. |
Not regulated. |
Key Provisions
Household Supply Obligation
Pursuant to Article 4A, the Government requires producers to ensure the availability of packaged palm cooking oil supplies to meet household consumption needs in the domestic market.
This obligation applies to all types of packaged palm cooking oil produced, including Minyakita, premium products, and other brands.
However, the Regulation does not specify the parameters or standards for fulfilling this obligation. In particular, it remains unclear what actions would constitute sufficient compliance with the obligation to “ensure the availability of supply.” For example, it is uncertain whether the obligation is satisfied merely by allocating production for domestic consumption or limiting exports, or whether producers are also required to undertake additional measures to ensure adequate supply in the domestic market.
This lack of clarity may give rise to differing interpretations regarding the scope of producers’ responsibilities and the criteria for assessing compliance with the Regulation.
Graduated Administrative Sanctions in the Event of a Shortage
To anticipate shortages of goods in the market, Dictum Number 2 inserts Article 30A, which establishes a graduated administrative sanction mechanism.
Where a shortage of goods occurs, producers that fail to fulfill their supply obligations are subject to administrative sanctions in the form of written warnings.
Written warnings may be issued in stages, up to a maximum of three (3) warnings, with a compliance period of up to 14 (fourteen) working days for each stage.
Government Enforcement Measures Through Closure Orders
Pursuant to Article 30A paragraphs (3) to (5), where a producer continues to fail to fulfill its supply obligations after all stages of written warnings have been exhausted, the Government may impose enforcement measures in the form of warehouse closure and temporary suspension of operations.
Such enforcement measures remain in effect until the producer fulfills its obligations in accordance with the applicable laws and regulations.
Authority to Impose Administrative Sanctions
The amendment to Article 37 clarifies that the authority to impose administrative sanctions, ranging from written warnings to warehouse closure, rests with the Senior High Leadership Official responsible for the formulation and implementation of policies in the fields of consumer protection and orderly trade administration within the ministry responsible for government affairs in the trade sector.
Closing
MOT Regulation 20/2026 strengthens the governance of packaged palm cooking oil distribution by reaffirming producers’ obligation to ensure the availability of supplies for domestic household consumption.
To enforce this obligation, the Regulation introduces a graduated administrative sanction regime, ranging from written warnings to government enforcement measures in the form of warehouse closure and temporary suspension of operations where producers fail to fulfill their supply obligations.
Accordingly, businesses should carefully review their production planning, inventory management, and distribution systems to ensure the continuous availability of cooking oil in the domestic market and to avoid administrative sanctions that may directly affect the continuity of their business operations.
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