Minister of Trade Regulation Number 9 of 2026 Prohibits the Import of Goods Produced by Forced Labor

Introduction

On 14 April 2026, the Ministry of Trade issued Minister of Trade Regulation Number 9 of 2026 on the Import of Goods Produced by Business Activities Involving Forced Labor (“MoT Regulation 9/2026”), which took effect on 15 April 2026. This regulation ensures that all goods entering the territory of Indonesia are genuinely free from labor exploitation practices.

MoT Regulation 9/2026 reinforces the commitment to eliminate the use of forced labor. The Government considers it necessary to take preventive and repressive measures to block products generated from business activities that violate humanitarian principles. Through this regulation, the Government aims to establish an ethical trade supply chain and prevent problematic goods from entering the domestic market.

 

Key Provisions

Primary Obligations of Importers

Pursuant to Article 2, every importer is required to import goods that are not produced through business activities involving forced labor. Each importer, whether an individual or a business entity, is responsible for selecting and ensuring that their supply chain is free from coercion or threats of punishment against workers.

Establishment of an Inter-Ministerial Investigation Team

Article 3 paragraph (1) provides that the Minister of Trade establishes a special investigation team to thoroughly examine allegations of the importation of goods produced by forced labor. This investigation team consists of representatives from various ministries, including:

1. The ministry responsible for synchronizing, coordinating, and controlling the implementation of governmental affairs in the economic sector; 
2. The ministry responsible for governmental affairs in the trade sector; 
3. The ministry responsible for governmental affairs in the financial sector; 
4. The ministry responsible for governmental affairs in the industrial sector; 
5. The ministry responsible for governmental affairs in the manpower sector; and 
6. The ministry responsible for governmental affairs in the foreign affairs sector. 

Investigation Mechanism and Right to Clarification

Pursuant to Article 3 paragraph (2), the investigation team initiates its actions based on complaints or information submitted by individuals or ministries/agencies, accompanied by supporting evidence regarding alleged imports of goods produced by forced labor. During the investigation process, Article 4 stipulates that importers are granted a maximum of 7 (seven) working days from the commencement of the investigation to submit clarification along with supporting evidence confirming that their imported goods are not the result of forced labor.

Blocking Measures and Supervision

Article 5 stipulates that the Ministry of Trade forwards the investigation team’s report to the Directorate General of Customs and Excise. This customs authority subsequently conducts supervision at border entry points. Article 6 prohibits importers from importing goods that have been proven, based on the investigation, to be the result of forced labor.

 

Transitional Provisions

With respect to goods that are in the process of shipment, Article 7 provides that the Government exempts the application of this import prohibition to goods that were shipped by importers prior to 15 April 2026. Importers are required to prove the shipment date using the date stated in the Bill of Lading (B/L) for sea transport or the Airway Bill (AWB) for air transport.

 

Closing

MoT Regulation 9/2026 requires every importer to ensure that imported goods are free from forced labor practices. To enforce this regulation, an inter-ministerial investigation team has been established to examine alleged violations, with importers granted a maximum of 7 working days to provide clarification regarding suspected imports of goods produced by forced labor. Goods proven to be the result of forced labor are prohibited from entering the country through supervision by the Directorate General of Customs and Excise at border points, with a specific exemption for goods shipped prior to 15 April 2026, as evidenced by a Bill of Lading (B/L) or Airway Bill (AWB).