Relaxation of the Importation of Used Goods and Special Arrangements in the Batam Free Trade Zone and Free Port Area based on Minister of Trade Regulation 23/2026

Introduction

On 9 September 2026, the Minister of Trade issued Minister of Trade Regulation Number 23 of 2026 concerning the Amendment to Minister of Trade Regulation Number 24 of 2025 concerning Policies and Regulations on the Importation of Goods in Used Condition and Non-Hazardous and Non-Toxic Waste ("Permendag 23/2026"), which will come into force on 9 October 2026. This regulation amends and adds several provisions to Permendag 24/2025, with the primary objective of expanding the scope of used goods that may be imported, while simultaneously reorganizing the licensing and exemption mechanisms applicable in the Free Trade Zone and Free Port Area (KPBPB).

The urgency of issuing Permendag 23/2026 lies in the need to improve the effectiveness of policies and regulations governing the importation of used electronic goods for industrial purposes. The Government considers the expansion of this category important to encourage economic growth, facilitate business activities, and create a more conducive investment climate, particularly in the Batam KPBPB, an area that has, from the outset, been accorded special treatment under the regime governing the importation of used goods.

Comparison

Key Provisions

• Expansion of the Goods Subject to Import Regulations

As regulated under Article 3 paragraph (1) of Permendag 23/2026, Goods in Used Condition and Non-B3 Waste subject to import regulations consist of:

1. 1. Used Capital Goods (BMTB);

   2. used lithium batteries;

   3. Non-B3 Waste as industrial raw materials; and

      1. used electronic goods for industrial purposes.

The addition of used electronic goods for industrial purposes constitutes an expansion of the goods subject to import regulations under Permendag 23/2026.

• Import Licensing Requirement (PI) for the New Category

Article 5 stipulates that importers of BMTB, Non-B3 Waste as industrial raw materials, and used electronic goods for industrial purposes must possess a Business License in the field of Importation in the form of an Import License (PI) before the goods enter the Customs Territory. The PI is issued by the Minister, and its issuance is delegated to the Director General.

• Used Electronic Goods: Exclusive to the Batam KPBPB

The most prominent provision in this amendment is Article 7A, which is inserted between Article 7 and Article 8. This Article specifically and strictly regulates the scope of used electronic goods for industrial purposes, subject to the following limitations:

• • Used electronic goods for industrial purposes may only be brought in for industrial purposes in the Batam KPBPB;

  • Such goods may not be removed from the Batam KPBPB to other KPBPBs, Special Economic Zones (KEK), Bonded Storage Places (TPB), and/or other places within the Customs Territory; and

  • The entry of such goods may only be carried out by Importers holding a Business Identification Number (NIB) that is valid as a Producer Importer Identification Number (API-P).

Based on Group VII of the Annex, this category of used electronic goods covers a relatively broad range of tariff headings, including:

1. 1. printing machines and photocopying machines (heading 84.43);

   2. data processing machines (heading 84.71);

   3. electric motors and generators (heading 85.01);

   4. electrical transformers (heading 85.04);

   5. vacuum cleaners (heading 85.08), telephone sets (heading 85.17);

   6. microphones and their stands (heading 85.18);

   7. transmission apparatus (heading 85.25);

   8. monitors and projectors (heading 85.28);

   9. parts and accessories (heading 85.29), semiconductor equipment (heading 85.41);

   10. other electrical machines and apparatus (heading 85.43); and

   11. instruments for measuring supply or production (heading 90.28).

Each tariff heading within this group is subject to specific requirements, such as the obligation to have a Commodity Balance (if one has been established) or a decision resulting from a coordination meeting facilitated by the Batam KPBPB Concession Agency (if a Commodity Balance has not yet been established), with the validity period of the PI following, at the latest, the validity period of the Commodity Balance or, if none has been established, the validity period of the decision of the relevant coordination meeting.

• Exemption from Import Policies and Regulations in the KPBPB

Permendag 23/2026 also relaxes the import regime in the KPBPB through the insertion of paragraphs (2a) and (2b) into Article 13.

Based on paragraph (2a), the entry of goods from outside the Customs Territory into KPBPBs other than Batam may be exempted from import policies and regulations based on a determination by the area council. Specifically for Batam, paragraph (2b) grants authority to the Head of the Batam KPBPB Concession Agency to determine exemptions for the entry of all categories of goods, after obtaining the consideration of the area council.

Closing

In essence, Permendag 23/2026 expands the scope of goods that may be imported in used condition by adding used electronic goods for industrial purposes as a new category. However, this expansion is accompanied by relatively strict limitations, particularly through Article 7A, which restricts the entry of used electronic goods for industrial purposes exclusively to the Batam KPBPB, for industrial purposes, and by importers holding an NIB that is valid as an API-P.

On the other hand, Permendag 23/2026 provides greater flexibility in the application of import policies and regulations in the KPBPB through an exemption mechanism based on a determination by the area council or, specifically for Batam, by the Head of the Batam KPBPB Concession Agency after obtaining the consideration of the area council. This amendment not only expands the types of goods that may be imported, but also provides scope for adjustments to import provisions in accordance with the needs of the area.