Minister of Trade Regulation Number 47 of 2025 Providing for the Prohibition of Imports of Certain Goods

Introduction

On December 30, 2025, the Ministry of Trade issued Minister of Trade Regulation Number 47 of 2025 on Goods Prohibited from Import ("MOT Regulation 47/2025") which took effect on January 1, 2026. MOT Regulation 47/2025 updates Indonesia’s import regulations by restating the types of goods prohibited from entering Indonesia.

MOT Regulation 47/2025 reorganizes the regulatory framework governing several commodities that impact the environment and the domestic market, including cooling system-based electronic products. Previously, these commodities were governed through an import restriction mechanism. Through MOT Regulation 47/2025, the government formally replaces this mechanism with an outright import prohibition on goods deemed no longer suitable for entry into the country.

Comparison

MOT Regulation 47/2025 introduces several material changes to the previous regulatory framework, including the following:

1. Repeals Minister of Trade Regulation Number 18 of 2021 on Goods Prohibited from Export and Goods Prohibited from Import as amended by Minister of Trade Regulation Number 40 of 2022 ("MOT Regulation 18/2021").

2. Repeals partial provisions in Minister of Trade Regulation Number 21 of 2025 on Policy and Regulation of Import of Electronic and Telematics Goods ("MOT Regulation 21/2025"), specifically the regulation of the import of cooling system-based electronic goods and cooling system-based goods using hydrochlorofluorocarbon 123 (HCFC-123).

Based on these changes, the following is a comparison between MOT Regulation 47/2025, MOT Regulation 18/2021, and MOT Regulation 21/2025:

Key Provisions

Regulation of Cooling System Imports

MOT Regulation 47/2025 establishes cooling system-based goods as goods prohibited for import. Previously, MOT Regulation 21/2025 still governed the import of air conditioners (AC) and cooling machines using HCFC-123 through import restriction mechanisms, including import approvals and quota arrangements. With the enactment of MOT Regulation 47/2025, the import of air conditioners (AC) and cooling machines using HCFC-123 is no longer permitted, whether for commercial or industrial purposes.

Categorization of Prohibited Goods (12 Groups)

Businesses need to ensure the compliance of traded goods with the 12 categories in the Annex.

1. Sugar & Rice: Specific specifications (Raw Sugar ICUMSA <600 IU, certain husked rice) are prohibited to protect farmers.

2. Used Goods: Used clothing, sacks, and bags.

3. Chemicals & Environment: Ozone-depleting substances, Hazardous and Toxic Material (B3), B3 Waste, and Registered Non-B3 Waste.

4. Technology & Medical Devices: Mercury-containing medical devices and certain cooling system-based electronics.

5. Tools: Simple hand tools (hoes, shovels, sickles) in finished form are prohibited, except for goods listed in the Minister of Trade Regulation governing Import Policy and Regulation.

Restriction on the Use of Special Customs Facilities

MOT Regulation 47/2025 stipulates that fiscal facilities in Bonded Zones and Special Economic Zones cannot be used as a basis to enter goods prohibited for import. Article 4 asserts that the exemption from import duties and taxes in such zones does not set aside import prohibition provisions. Accordingly, businesses operating in Bonded Zones and Special Economic Zones are no longer permitted to import metal scrap or chemicals listed as prohibited goods, even where the entire output is intended for export.

Exemption for Re-Import

Article 5 of MOT Regulation 47/2025 stipulates an exemption to the import prohibition for re-import activities of goods that have been exported. This provision exempts re-import activities of goods that have been exported, the implementation of which must be carried out in accordance with statutory regulations in the customs sector.

Transitional Provisions

Article 7 stipulates an exemption from the import prohibition for cooling system-based goods other than fire extinguishers and cooling system-based electronic goods using hydrochlorofluorocarbon 123 (HCFC-123), provided that the goods were shipped prior to the effective date of MOT Regulation 47/2025 as evidenced by the date of the Bill of Lading (B/L) or Air Waybill (AWB), and arrive at the port of destination no later than January 31, 2026, as listed in the BC 1.1 manifest. Furthermore, Article 6 stipulates that importers failing to comply with import prohibition provisions, including the entry of goods prohibited for import into Special Economic Zones (KEK) or Bonded Storage Places (TPB), may be subject to sanctions in accordance with statutory regulations in the customs and trade sectors.

Closing

MOT Regulation 47/2025 which took effect on 1 January 2026, amends the import regime relating to import prohibitions on certain categories of goods. Under this regulation, electronic products and cooling system based goods using hydrochlorofluorocarbons (HCFCs) are now classified as prohibited imports. These provisions apply to all business actors and cover the entry of goods into areas with special facilities, including Free Trade Zones, Special Economic Zones, Bonded Zones, and facilities under the Import Facility for Export Purposes. Accordingly, business actors are required to reassess the classification of traded goods based on the 12 categories of prohibited goods and to ensure that cooling system based goods still within the transitional period have arrived at the port of destination and are listed in the customs manifest no later than 31 January 2026 in order to avoid legal consequences, re export obligations, or operational disruptions resulting from goods being held at the port.