Regulation of the Minister of Trade Number 17 of 2026 Transfers Iron Alloy Export Activities to Export SOEs and Establishes a Transition Period until 2027

Introduction

On May 29, 2026, the Ministry of Trade (“MOT”) issued Regulation of the Minister of Trade Number 17 of 2026 on Policies and Export Regulations for Iron Alloy Strategic Natural Resource Commodities ("MOT Regulation 17/2026"), which took effect on June 1, 2026. MOT Regulation 17/2026 governs the export of iron alloy commodities by requiring that such exports be carried out through State-Owned Export Enterprises ("Export SOEs").

Based on the recitals, the Government enacted MOT Regulation 17/2026 to implement Article 2 paragraph (5) and Article 5 of Government Regulation Number 24 of 2026 on Export Governance of Strategic Natural Resource Commodities. The export regulation applies to iron alloy commodities categorized as Strategic Natural Resource Commodities. These commodities are designated by considering national interests, economic stability, domestic needs, and the management of national strategic natural resources.

Comparison

MOT Regulation 17/2026 repeals the provisions on Iron Alloy Export requirements previously stipulated in Annex I to Regulation of the Minister of Trade Number 23 of 2023 on Export Policies and Regulations ("MOT Regulation 23/2023"), as last amended by Regulation of the Minister of Trade Number 12 of 2026 ("MOT Regulation 12/2026"). The following is a comparison between MOT Regulation 17/2026 and MOT Regulation 23/2023 in conjunction with MOT Regulation 12/2026:

Key Provisions

Export Execution Through Export SOEs 

Article 2 paragraph (1) stipulates that businesses execute export activities for iron alloy strategic natural resource commodities through Export SOEs. Furthermore, Article 2 paragraph (2) divides iron alloy commodities into two categories:

1. Iron alloys subject to Technical Verification or Tracking obligations as set forth in Annex I.

2. Iron alloys exempt from Technical Verification or Tracking obligations as set forth in Annex II.

Additionally, Article 4 stipulates that export provisions for iron alloy strategic natural resource commodities apply to the release of goods outside the Customs Area, whether originating from the Customs Area, Free Trade Zones and Free Ports (Kawasan Perdagangan Bebas dan Pelabuhan Bebas, "KPBPB"), Special Economic Zones (Kawasan Ekonomi Khusus, "KEK"), or Bonded Storage Facilities (Tempat Penimbunan Berikat, "TPB").

Verification Mechanism and Issuance of Surveyor Reports 

For commodities subject to Technical Verification or Tracking obligations, Article 3 paragraph (1) stipulates that exporters submit electronic applications to the Surveyor. The Surveyor appointed by the Minister of Trade then issues the LS based on the results of the Technical Verification or Tracking as stipulated in Article 3 paragraph (4). Businesses utilize the LS as a supplementary customs document when submitting the Export Customs Declaration to the customs office. Moreover, Article 3 paragraph (5) sets forth that the Surveyor issues the LS electronically through the INATRADE System, which is integrated with the Indonesia National Single Window System ("SINSW").

Export Exemptions Based on Export SOE Certificates 

MOT Regulation 17/2026 governs several conditions allowing non-Export SOE exporters to conduct exports. One such condition applies to Ferro-silico-chromium (HS 7202.50.00), Ferro-niobium (HS 7202.93.00), and Other Ferro-Alloys (HS 7202.99.00). Non-Export SOE exporters may export these commodities after obtaining a certificate from an Export SOE as stipulated in Article 5 paragraph (2). Furthermore, exemptions to prohibitions, policies, and regulations on Iron Alloy Exports are executed in accordance with laws and regulations governing export prohibitions, policies, and regulations as set forth in Article 5 paragraph (1).

Export Exemptions Based on Contracts or Agreements with the Government 

Non-Export SOE exporters may also conduct exports if they hold a contract or agreement with the Government decided upon in a ministerial-level coordination meeting on economic affairs. The coordination meeting is chaired by the minister organizing government affairs in economic coordination and attended by relevant ministers or heads of non-ministerial government agencies as set forth in Article 8. The contract or agreement with the Government must include commitments related to:

1. Investment;

2. Divestment;

3. Domestic processing and/or refining.

Supervision of Export Execution 

The Directorate General of Consumer Protection and Trade Compliance supervises exporter compliance in iron alloy export activities in coordination with the Directorate General of Foreign Trade as set forth in Article 7 paragraph (1) and paragraph (2).

Iron Alloy Export Rules with LS Obligations 

Annex I stipulates iron alloy commodities subject to Technical Verification or Tracking obligations, namely:

1. Ferro-manganese containing by weight ≥60% Mn (HS 7202.11.00 and ex 7202.19.00);

2. Ferro-silicon alloys containing by weight ≥75% Fe (HS 7202.29.00);

3. Ferro-silico-manganese containing by weight ≥60% Mn (ex 7202.30.00);

4. Ferro-chromium alloys containing by weight ≥75% Fe (ex 7202.41.00 and ex 7202.49.00);

5. Ferro-nickel (FeNi) in lumps, in ingots, containing by weight ≥8% Ni (HS 7202.60.00);

6. FeNi Luppen, FeNi Nuggets, Sponge FeNi containing by weight ≥4% Ni (ex 7202.60.00);

7. FeNi Luppen, FeNi Nuggets, Sponge FeNi containing by weight 2%≤Ni<4% and ≥75% Fe (ex 7202.60.00);

8. Ferro-molybdenum containing by weight ≥75% Fe (ex 7202.70.00);

9. Ferro-tungsten and ferro-silico-tungsten alloys containing by weight ≥75% Fe (ex 7202.80.00);

10. Ferro-titanium containing by weight ≥65% Ti (ex 7202.91.00);

11. Ferro-silico-titanium containing by weight ≥75% Fe (ex 7202.91.00); and

12. Ferro-vanadium containing by weight ≥75% Fe (ex 7202.92.00).

From June 1, 2026, to December 31, 2026, businesses holding a Mining Business License (Izin Usaha Pertambangan, "IUP"), Special Mining Business License (Izin Usaha Pertambangan Khusus, "IUPK"), Transportation and Sales License, or Industrial Business License (Izin Usaha Industri, "IUI") shall execute exports through Export SOEs. Furthermore, starting January 1, 2027, the export of these commodities may only be conducted by Export SOEs or Production Operation IUPK holding companies that have a downstream cooperation agreement with the Government.

Iron Alloy Export Rules Exempt from LS Obligations 

Annex II stipulates iron alloy commodities exempt from Technical Verification or Tracking obligations, namely:

1. Ferro-silico-chromium (HS 7202.50.00);

2. Ferro-niobium (HS 7202.93.00); and

3. Other Ferro-Alloys (HS 7202.99.00).

From June 1, 2026, to December 31, 2026, exporters may conduct exports without a Certificate from an Export SOE, but remain obligated to submit export execution reports to the Export SOE. Furthermore, starting January 1, 2027, non-Export SOE exporters may conduct exports after obtaining a Certificate from an Export SOE. The Certificate is non-transactional in nature, an exporter may hold more than one Certificate, and it must at least contain:

1. Exporter's name;

2. Tariff Post/HS Code;

3. Description of goods; and

4. Validity period.

Transitional Provisions

Article 9 establishes a transition period until December 31, 2026, for businesses that have conducted export activities prior to the enactment of MOT Regulation 17/2026. During this period:

1. Businesses use the LS as a supplementary customs document when executing exports through Export SOEs;

2. Businesses submit export documents, sales contracts, and additional data through a system integrated with Export SOEs;

3. The export of iron alloy strategic natural resource commodities after December 31, 2026, is conducted by Export SOEs;

4. In the event that the export execution of iron alloy strategic natural resource commodities has been transitioned to Export SOEs before December 31, 2026, the export is conducted by Export SOEs from the date of such transition;

5. Export activities that have secured an Export Customs Declaration registration number and date from the customs office before MOT Regulation 17/2026 took effect continue to be serviced by the Directorate General of Customs and Excise; and

6. Surveyors appointed prior to the enactment of MOT Regulation 17/2026 may continue to perform their duties provided they do not conflict with applicable provisions.
   

Closing

MOT Regulation 17/2026, which took effect on June 1, 2026, amends the export regulations for iron alloy strategic natural resource commodities previously governed in MOT Regulation 23/2023 and its amendments. The revision introduces a key innovation by expanding the commodity scope to 15 types of iron alloys, regulating export execution through Export SOEs, and dividing commodities into categories subject to and exempt from Technical Verification or Tracking obligations as set forth in Annex I and Annex II. For commodities in Annex I, exporters use the LS issued through the Technical Verification or Tracking mechanism and submitted via the INATRADE System integrated with SINSW, whereas for commodities in Annex II, non-Export SOE exporters are required to obtain a Certificate from an Export SOE starting January 1, 2027. MOT Regulation 17/2026 also governs exemptions for non-Export SOE exporters under specific conditions, including for parties holding contracts or agreements with the Government that contain minimum provisions on investment, divestment, and domestic processing and/or refining. During the transition period up to December 31, 2026, businesses continue to submit export documents and data through a system integrated with Export SOEs, while Surveyors appointed before MOT Regulation 17/2026 took effect may continue to execute their duties in accordance with applicable provisions. Upon the conclusion of the transition period, the export of iron alloy strategic natural resource commodities is conducted by Export SOEs, including where the transition of export execution has already occurred prior to December 31, 2026. Export activities that have secured an Export Customs Declaration registration number and date before MOT Regulation 17/2026 took effect continue to be serviced by the Directorate General of Customs and Excise. Export execution is supervised by the Directorate General of Consumer Protection and Trade Compliance in conjunction with the Directorate General of Foreign Trade, and violations concerning the use of LS documents or Certificates may be subject to administrative sanctions under applicable laws and regulations. In alignment with these provisions, MOT Regulation 17/2026 also repeals the provisions on Iron Alloy export requirements previously stipulated in Annex I to MOT Regulation 23/2023 and its amendments.