26 Sep 2026 · TAMA Insight
New Import Restrictions on Non-New Industrial Electronic Goods in Indonesia
Indonesia has introduced a more restrictive import regime for non-new electronic goods intended for industrial use. Under the amended import framework, these goods are now expressly classified as…
Indonesia has introduced a more restrictive import regime for non-new electronic goods intended for industrial use. Under the amended import framework, these goods are now expressly classified as regulated imports and are subject to Import Approval (Perizinan Berusaha in the form of Import Approval or “PI”) prior to importation.
The new regime also imposes a specific geographical restriction: non-new industrial electronic goods may only be brought into the Batam Free Trade Zone and Free Port (Kawasan Perdagangan Bebas dan Pelabuhan Bebas or “KPBPB Batam”) for industrial purposes. Once imported into KPBPB Batam, the goods cannot be released or transferred to other free trade zones, Special Economic Zones, Bonded Storage, or other locations within Indonesia’s customs territory.
1. Non-New Industrial Electronic Goods Now Classified as Regulated Imports
The amended import framework expressly adds non-new electronic goods for industrial needs to the categories of goods subject to import controls.
This places non-new industrial electronic equipment within a regulated import regime alongside other categories of non-new goods and certain non-hazardous waste used as industrial raw materials.
As a result, non-new electronic equipment intended for industrial purposes can no longer be treated simply as goods that may be imported without a specific import authorization. Their importation is now subject to the requirements applicable to regulated goods under the amended framework.
The change is particularly relevant to businesses seeking to bring used or refurbished industrial electronic equipment into Indonesia for manufacturing, production, or other industrial activities.
2. Import Approval Required Before Importation
Importers of non-new industrial electronic goods must obtain Import Approval (PI) before the goods enter the customs territory.
The PI is issued by the Minister of Trade, with the relevant issuance authority delegated to the Director General of Foreign Trade. The application, amendment, validity, extension, cancellation, and revocation of the PI are subject to the applicable import-policy framework and the requirements specified in the regulation and its annex.
This means that obtaining PI is not merely an administrative step after shipment arrangements have been made. It is a prerequisite for the lawful importation of the relevant goods.
Businesses therefore need to ensure that the relevant PI has been obtained and remains valid before the goods enter the applicable customs territory.
3. KPBPB Batam as the Specific Entry Location
A key feature of the new regime is its geographical limitation.
Non-new electronic goods for industrial purposes may only be brought into KPBPB Batam for industrial use.
This creates a significantly narrower entry framework than the general rules applicable to certain other industrial or consumer goods entering Indonesian free trade zones. While other import regimes may allow certain goods to enter different KPBPB areas and impose import requirements primarily when the goods are released into the customs territory, the new regime specifically directs non-new industrial electronic goods to KPBPB Batam.
The location restriction therefore forms part of the substantive import requirement rather than merely serving as a logistical preference.
4. No Release or Transfer to Other Locations
The restrictions do not end once the goods have entered KPBPB Batam.
Non-new industrial electronic goods cannot subsequently be released from KPBPB Batam to:
- another KPBPB;
- a Special Economic Zone;
- a Bonded Storage facility; or
- another location within Indonesia’s customs territory.
The regime therefore effectively creates a closed-loop arrangement for these goods.
Businesses cannot rely on entry through KPBPB Batam as a means of subsequently moving the equipment to another industrial location in Indonesia. The goods must remain within the permitted framework established for KPBPB Batam.
This is one of the most significant differences between the new regime and the more general treatment of goods entering Indonesian free trade zones.
5. Importer Must Hold API-P Status
The importation is also limited to businesses whose Business Identification Number (Nomor Induk Berusaha or “NIB”) is valid as a Producer Importer Identification Number (API-P).
This requirement reinforces the industrial character of the regime. The importer must not only hold the necessary PI but also qualify as a producer importer under the applicable licensing framework.
Accordingly, the new regime is directed toward industrial users or producer-importers rather than traders seeking to import non-new electronic equipment for general commercial distribution.
Businesses planning to import such equipment should therefore assess both their import licensing status and their underlying business activities before commencing the import process.
6. PI Validity, Amendment, and Extension
The amended framework also introduces specific rules concerning the duration and administration of PI for non-new industrial electronic goods.
Where a Commodity Balance (Neraca Komoditas) has been established for the relevant goods, the validity of the PI follows the validity period of that Commodity Balance.
Where no Commodity Balance has been established, the PI may generally be valid for up to one calendar year.
The PI may also be amended to reflect certain changes in the import transaction, including information relating to the importer, tariff classification, description and specifications of the goods, quantity, unit, country of origin, loading country, and loading port.
An extension is subject to more limited conditions. The PI may generally be extended only once and for a maximum period of 30 days following its expiration, subject to the applicable requirements.
These limitations indicate that the PI regime is intended to provide relatively close regulatory control over the timing and substance of imports of non-new industrial electronic goods.
7. Relationship with General KPBPB Import Rules
The new provisions should be distinguished from the general treatment of goods imported into KPBPB.
Under certain general import regimes, industrial or consumer goods may enter a free trade zone without the full application of import requirements at the point of entry, with certain import controls becoming relevant when the goods are subsequently released into the Indonesian customs territory.
The amended regime for non-new industrial electronic goods takes a different approach.
These goods are subject to PI requirements and are specifically restricted to KPBPB Batam. They are also prohibited from being released or transferred to other zones or locations within Indonesia.
Accordingly, the specific provisions governing non-new industrial electronic goods should be applied to that category where they overlap with broader provisions governing imports into KPBPB.
8. Limited Relevance of General Import Exemptions
The general import framework provides certain exemptions for specific non-business import activities, such as personal shipments, passenger baggage, household moves, and other limited categories.
These exemptions do not provide a general alternative route for the importation of non-new industrial electronic goods.
The industrial nature of the goods, combined with the requirement for PI and an importer whose NIB functions as API-P, indicates that the regime is designed for business and production activities rather than personal or non-commercial imports.
Businesses therefore should not assume that general exemptions from import licensing requirements can be used to circumvent the specific requirements applicable to non-new industrial electronic goods.
9. Practical Implications for Businesses
The new regime has several practical implications for businesses intending to use non-new electronic equipment for industrial activities in Indonesia.
First, the importer must establish that the equipment falls within the regulated category of non-new electronic goods for industrial needs.
Second, the importer must ensure that it satisfies the relevant producer-importer requirements and holds an NIB functioning as API-P.
Third, PI must be obtained before the goods enter the applicable customs territory, with the import transaction remaining within the scope and validity period of the approval.
Fourth, the import logistics must be structured around KPBPB Batam as the permitted entry location.
Finally, businesses must consider the long-term location and use of the equipment. The goods cannot subsequently be moved from KPBPB Batam to another KPBPB, Special Economic Zone, Bonded Storage facility, or other location within Indonesia’s customs territory.
This means that the new regime should be considered at the planning stage of an industrial investment or equipment procurement, rather than only when the goods are ready to be shipped.
Conclusion
The amended import framework introduces a specific and restrictive regime for non-new electronic goods intended for industrial purposes.
The principal requirements are that the importer obtain the required PI, qualify as a producer importer through an API-P-valid NIB, and bring the goods specifically into KPBPB Batam. Once imported, the goods are subject to strict restrictions on movement and cannot be released or transferred to other free trade zones, Special Economic Zones, Bonded Storage, or other locations within Indonesia’s customs territory.
For businesses considering the importation of used or non-new industrial electronic equipment, these restrictions should be assessed before procurement and shipment arrangements are finalized, particularly where the equipment is ultimately intended to be used outside Batam.
This alert is part of a series examining recent developments in Indonesia’s trade and import regulatory framework. As import controls for specific categories of goods continue to evolve, further developments should be monitored for their potential implications for manufacturers, importers, and businesses using non-new equipment in Indonesia.
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