Regulation of the Minister of Trade Number 6 of 2026 Revises the Criteria for Prohibited Export Goods

Introduction

On March 26, 2026, the Ministry of Trade (“MOT”) issued a Regulation of the Minister of Trade Number 6 of 2026 on the Fourth Amendment to Minister of Trade Regulation Number 22 of 2023 on Prohibited Export Goods ("MOT Regulation 6/2026"). MOT Regulation 6/2026 amends the provisions on prohibited export goods, including updating the list of goods in the annexes to provide certainty for exporters in determining the classification of goods during export.

Comparison

MOT Regulation 6/2026 amends the Annex on the list of prohibited export goods set forth in Regulation of the Minister of Trade Number 22 of 2023 on Prohibited Export Goods ("MOT Regulation 22/2023"), which has been amended several times, most recently by Regulation of the Minister of Trade Number 8 of 2025 ("MOT Regulation 8/2025"). The following is a comparison between MOT Regulation 6/2026 and MOT Regulation 22/2023 as most recently amended by MOT Regulation 8/2025:

Key Provisions

Updates to the Export Prohibition Annexes

MOT Regulation 6/2026 amends the Annexes of MOT Regulation 22/2023. Exporting businesses must refer to the latest annexes to identify the Tariff Post (HS), goods descriptions, and applicable provisions for commodities prohibited from export during customs processes.

Forestry Sector Export Prohibition

Annex Part I prohibits the export of various forest commodities. Businesses cannot export plant materials for plaiting, including whole or split rattan. Furthermore, rough wood, sawn wood, and builders' joinery and carpentry of wood from coniferous and non-coniferous (tropical wood) species cannot be exported before fulfilling the value-added provisions.

Agricultural Sector Export Prohibition

Annex Part II prohibits the export of natural rubber outside the stipulated standards, and prohibits the export of the porang plant (Amorphophallus muelleri). The prohibition covers all parts of the porang plant, including its tubers, bulbils, flowers, leaves, seeds, roots, stems, and fruits. In addition, Annex Part II prohibits the export of the kratom plant (Mitragyna speciosa) in the form of whole leaves, chopped leaves, or powder with a particle size of more than 600 microns.

Removal of Rice Commodities from the Export Prohibition List

Based on the updates to Annex Part II, MOT Regulation 6/2026 entirely removes rice commodities from the list of prohibited export goods in the agricultural sector. Previously, in Annex Part II of the former regulation, the government prohibited the export of rice not produced through organic farming systems with a broken grain percentage above 25 percent. Following the enforcement of the latest annex, businesses are no longer subject to export prohibitions on rice commodities during customs processes.

Protection of Subsidized Fertilizers

MOT Regulation 6/2026 prohibits the export of mineral or chemical fertilizers containing nitrogen elements. The prohibition covers urea fertilizer, whether or not in aqueous solution, including those in the form of tablets or in packages with a maximum gross weight of 10 kg, as set forth in Annex Part III.

General Mining Sector Exemption Criteria

MOT Regulation 6/2026 prohibits companies from exporting various raw minerals, including silica sand, kaolin, bentonite, rare earth metals, and unrefined metal ores. However, exports can still be carried out under certain conditions as set forth in Annex Part IV Letter A, as follows:

1. Goods used for research and development purposes;

2. Goods re-exported to the country of origin because they do not meet specifications or are not fully utilized by importers holding a General Importer Identification Number (Angka Pengenal Impor Umum, "API-U") or Producer Importer Identification Number (Angka Pengenal Impor Produsen, "API-P");

3. Goods used in the production of industrial products derived from imported raw materials or metal scrap by producers holding an API-P;

4. Copper concentrates with a grade of ≥ 15% Cu can be exported during repair processes due to force majeure based on recommendations from relevant ministries.

Simplification of Solder Tin Product Criteria

MOT Regulation 6/2026 maintains the technical parameters for pure tin ingot commodities, but the government amends the prohibition criteria for solder tin derivative products. MOT Regulation 6/2026 removes the percentage threshold requirements for various impurity metals in solder products. Businesses now refer directly to the physical description of the product during customs processes, such as the prohibition on flux-free extruded solder bars and flux-free solder wires.

Preservation of Cultural Heritage Goods

MOT Regulation 6/2026 prohibits the export of collector's pieces of historical, archaeological, ethnographic, or paleontological value, as set forth in Annex Part V. Cultural heritage goods aged 50 years or more and antiques aged over 100 years that hold value for national history or identity cannot be exported from the territory of the Republic of Indonesia.

Prohibition of Metal Scrap Outside Batam

Businesses are prohibited from exporting metal waste and scrap originating from outside the Batam Island territory. This prohibition covers waste and scrap of cast iron, alloy steel, tinned iron, and tin waste, as set forth in Annex Part VI.

Export Prohibition on Marine Sedimentation Products

Natural sand and mud resulting from the cleaning of marine sedimentation are prohibited from being exported if they contain precious minerals above the threshold. Sea sand also cannot be exported if it has a grain size below 0.25 mm or above 2.0 mm, a shell percentage of more than 15%, a silica content above 95%, or a rare earth metal content above 100 ppm, as set forth in Annex Part VII.

Transitional Provisions

MOT Regulation 6/2026 becomes effective on April 1, 2026, as set forth in Article II. Export customs activities submitted from that date must follow the prohibition criteria set out in the applicable annexes. Exporters must ensure that commodity specifications are aligned with the Tariff Post (HS) and applicable exemption criteria.

Closing

MOT Regulation 6/2026 amends the list of prohibited export goods by updating the annexes covering the forestry, agriculture, mining, subsidized fertilizer, cultural heritage goods, metal scrap, and marine sedimentation products sectors, including adjustments to the types of goods, technical parameters, and exemption criteria for certain commodities. Businesses should note that most export prohibition criteria for commodities, such as kratom, pure tin ingots, urea fertilizer, and marine sedimentation products, do not undergo specification changes from the previous regulation. The primary updates requiring businesses to make operational adjustments include the removal of rice commodities from the list of prohibited goods and the simplification of technical criteria for solder tin products, which now focus more on direct physical product identification. Since its entry into force on April 1, 2026, export activities must follow the list and criteria set out in the annexes; thus, exporters must ensure the conformity of commodity specifications and Tariff Post (HS) classifications prior to export submission.