04 Oct 2026 · TAMA Insight
Indonesia’s Framework for the Procurement and Distribution of Fish Seed and Broodstock
Minister of Marine Affairs and Fisheries Decree No. KEP.07/MEN/2004 on the Procurement and Distribution of Fish Seed and Broodstock (Decree KEP.07/MEN/2004) establishes technical requirements governing the procurement, distribution,…
Minister of Marine Affairs and Fisheries Decree No. KEP.07/MEN/2004 on the Procurement and Distribution of Fish Seed and Broodstock (Decree KEP.07/MEN/2004) establishes technical requirements governing the procurement, distribution, conservation, monitoring, and reporting of fish seed and broodstock in Indonesia.
The decree took effect on 3 February 2004 and was issued under the regulatory framework applicable to fisheries, fish quarantine, Indonesian National Standards (SNI), and fisheries business activities at the time.
Although the decree is an older instrument, its provisions remain relevant to the extent that they have not been revoked or replaced and remain consistent with subsequent legislation and regulations governing fish seed and broodstock. In particular, its provisions should be read together with the more recent regulatory framework for Indonesia’s national fish seed system.
The principal requirements are outlined below.
1. Regulatory Position and Scope
Decree KEP.07/MEN/2004 was issued under, among others, Law No. 9 of 1985 on Fisheries, Law No. 16 of 1992 on Animal, Fish and Plant Quarantine, Government Regulation No. 15 of 1991 on National Standards, and Government Regulation No. 54 of 2002 on Fisheries Business.
The decree also expressly revoked Minister of Agriculture Decree No. 1041.1/Kpts/Ik.210/1999 concerning the Procurement and Distribution of Fish Seed. Accordingly, KEP.07/MEN/2004 replaced the earlier ministerial arrangement governing the same subject matter.
Its scope extends beyond the physical movement of fish seed. It regulates the procurement of seed and broodstock from natural sources, domestic hatchery and breeding activities, and foreign sources, as well as domestic distribution and exports.
The decree also addresses conservation, government guidance, monitoring, recordkeeping, reporting, and sanctions.
2. Procurement of Fish Seed and Broodstock from Natural Sources
Decree KEP.07/MEN/2004 permits fishermen and/or breeders holding a fisheries activity registration record to procure seed and broodstock from natural waters. Traders holding a Fisheries Business Licence (Izin Usaha Perikanan or IUP) for fish cultivation may also undertake procurement from natural sources.
A trader holding an IUP that procures seed or broodstock from natural sources must establish a partnership with fishermen or breeders.
The decree also limits procurement from natural sources to a maximum of 70% of the sustainable potential of fish seed or broodstock in the relevant waters. This provision establishes a quantitative limitation intended to prevent procurement from exceeding the available sustainable resource.
The Director General is authorised to determine further technical matters, including the species and size of seed or broodstock, fishing seasons, fishing areas, materials, equipment, and methods for capturing and trading naturally sourced seed and broodstock.
3. Procurement from Domestic Hatchery and Breeding Activities
Decree KEP.07/MEN/2004 permits individual breeders, legal entities, and government institutions to procure seed and broodstock produced through domestic hatchery or breeding activities.
As a general rule, individual and corporate breeders are required to hold an IUP for fish cultivation. The decree, however, provides exemptions for certain small-scale hatchery operations.
The exemption applies to hatchery businesses conducted on land not exceeding:
- 0.75 hectares for freshwater hatchery operations;
- 0.5 hectares for brackish-water hatchery operations; and
- 0.5 hectares for marine hatchery operations.
An operator benefiting from the small-scale exemption remains required to hold a fisheries activity registration record. The exemption therefore does not eliminate the administrative registration requirement.
National Standards for Fish Seed
The decree requires the procurement of cultivated fish seed classified as benih bina or benih sebar and meeting applicable SNI requirements to comply with those standards.
This connects the procurement of fish seed with national quality standards and establishes SNI compliance as part of the technical framework for cultivated fish seed.
Breeding Classes
The decree applies additional controls to broodstock at certain breeding levels.
Procurement of induk penjenis or GGPS, induk dasar or GPS, and induk pokok or PS produced through domestic breeding may only be undertaken by certified breeders.
This requirement places particular emphasis on maintaining the quality and traceability of broodstock used within breeding and genetic improvement programmes.
4. Procurement from Foreign Sources
Decree KEP.07/MEN/2004 regulates the importation of fish seed and broodstock into Indonesia.
Importation may be carried out by individuals or legal entities that hold an IUP for fish cultivation and an import permit for fish entering Indonesian territory.
The decree imposes specific restrictions on imported seed. Imported fish seed is permitted only as benih sebar intended for grow-out and may not be imported for use as broodstock.
The Director General determines the timing, quantity, species, and size of imported seed and broodstock, taking into account the availability of fish seed within Indonesia.
Imported Broodstock
For imported breeding stock, the decree generally permits the importation of GPS and/or PS broodstock.
Importation of GGPS broodstock is subject to a more restricted regime. Such broodstock may only be imported by research institutions and government agencies with the approval of the Director General.
The distinction reflects the different levels of control applied to breeding material according to its position within the breeding hierarchy.
Technical Import Requirements
The decree establishes several requirements for imported seed and broodstock.
These include compliance with fish quarantine requirements, documentation evidencing the origin or variety of the imported material, testing or observation at an accredited or officially designated laboratory, and additional quality and/or biosafety assessment for new species or varieties where required by applicable regulations.
The importer must also report the arrival of the seed or broodstock to the Director General no later than 30 days after arrival, including information on the species, quantity, and size.
Accordingly, importation is subject not only to licensing requirements but also to quarantine, traceability, testing, and post-arrival reporting requirements.
5. Domestic Distribution of Fish Seed and Broodstock
Decree KEP.07/MEN/2004 permits breeders and/or traders, whether individuals or legal entities, to distribute fish seed and broodstock within Indonesia.
For inter-island distribution, the shipment must comply with applicable quarantine requirements and be accompanied by a Certificate of Origin issued by the relevant regency or city government agency responsible for fisheries.
The Certificate of Origin provides an administrative mechanism for identifying the source of the seed or broodstock being distributed and supports traceability within the domestic distribution chain.
The distribution framework therefore combines business eligibility with quarantine and origin-documentation requirements.
6. Export of Fish Seed and Broodstock
The decree also regulates the removal of fish seed and broodstock from Indonesia.
An exporter must hold an IUP for fish cultivation and obtain a recommendation for the export of fish seed and/or broodstock from the Director General or an authorised official.
Export of Fish Seed
As a general rule, exported fish seed must consist of benih sebar or benih bina produced through breeding or hatchery activities rather than captured from natural waters.
The export of naturally captured fish seed is subject to further regulation by the Director General, taking into account the availability of seed within Indonesia.
Export of Broodstock
The export of broodstock is subject to additional restrictions. The decree generally permits the export of PS broodstock produced through breeding rather than captured from natural waters.
An exception is provided for scientific, technological, and international research cooperation.
Where broodstock is exported for research purposes, the decree establishes additional requirements, including that the activity must provide benefits to Indonesia and fish-farming communities, and that the quantity, species, size, and timing of collection from natural sources must be determined with regard to the availability of broodstock in the relevant waters.
The research must also involve an Indonesian government research institution and cooperation with the relevant foreign research institution. The results of the research are to be owned jointly by the Indonesian government research institution and the foreign research institution involved.
Prior recommendation for the export must also be obtained from the Director General or an authorised official.
These provisions establish additional controls over the export of genetic material and naturally sourced broodstock while permitting limited international research cooperation.
Quarantine and Handling Requirements
Exports may also be subject to fish quarantine requirements where required by the destination country.
The decree further requires the domestic and international distribution of fish seed and broodstock to comply with applicable SNI requirements concerning storage, packaging, and transportation.
7. Conservation of Fish Seed and Broodstock
Decree KEP.07/MEN/2004 provides for conservation measures concerning naturally occurring fish seed and broodstock.
The Minister may designate waters and/or land as spawning grounds for broodstock and nursery grounds for naturally occurring fish seed.
The decree also requires breeders and traders to participate actively in the conservation of fish seed and broodstock.
Further implementation of these conservation obligations is to be regulated by the Director General and the relevant local government.
The framework therefore places conservation responsibilities not only on the government but also on businesses engaged in the procurement and distribution of fish seed and broodstock.
8. Government Guidance, Monitoring, and Reporting
The decree assigns the Director General and the relevant local government responsibility for providing guidance and assistance to breeders and traders involved in the procurement and distribution of fish seed and broodstock.
Breeders and traders are also required to maintain records of their activities and submit written reports periodically every six months to the relevant local government.
These recordkeeping and reporting requirements provide an administrative basis for monitoring procurement and distribution activities and supporting government oversight of the fish seed sector.
For businesses operating across multiple locations, the reporting obligation should therefore be considered together with the relevant local government authority responsible for fisheries in each applicable area.
9. Sanctions
Decree KEP.07/MEN/2004 provides that violations of its requirements are subject to the sanctions framework under Law No. 9 of 1985 on Fisheries, as referenced by the decree.
The sanction provision does not itself establish a separate and independent sanction regime. Rather, it connects violations of the technical requirements under the decree with the fisheries legislation applicable at the time.
In assessing potential enforcement exposure, however, the relevant provisions of current fisheries legislation should also be considered, including subsequent amendments and replacement legislation. The legal consequences of a particular violation should therefore not be determined solely by reference to the sanction provision in the 2004 decree.
10. Relationship with the Subsequent Fish Seed Regulatory Framework
The continued application of Decree KEP.07/MEN/2004 should be assessed in conjunction with subsequent regulations governing fish seed and aquaculture activities.
In particular, Minister of Marine Affairs and Fisheries Regulation No. 21 of 2024 concerning the National Fish Seed System provides a more recent regulatory framework for Indonesia’s fish seed system.
Accordingly, the fact that Decree KEP.07/MEN/2004 has not been expressly identified as revoked does not, by itself, mean that every provision of the decree can be applied independently of later legislation.
Where a provision of KEP.07/MEN/2004 conflicts with a later regulation of higher or applicable equal legal authority, the later or higher-level provision should prevail in accordance with the applicable hierarchy and principles of statutory interpretation.
The 2004 decree may therefore continue to serve as a technical reference to the extent that its provisions remain in force and are consistent with the current regulatory framework.
This point is particularly relevant for licensing, quarantine, standards, import and export controls, reporting obligations, and other matters that have subsequently been subject to regulatory developments.
11. Practical Considerations for Fish Seed and Broodstock Businesses
For breeders, traders, importers, exporters, and other participants in the fish seed supply chain, the decree establishes several areas that warrant continued attention.
Businesses procuring seed or broodstock from natural sources should consider the applicable registration or licensing requirements, partnership requirements, sustainable procurement limits, and any technical requirements established by the Director General.
Domestic hatchery operators should assess their licensing or registration status, the applicable SNI requirements, and the certification requirements for the procurement of higher-level broodstock.
Importers should review their IUP, import authorisation, quarantine documentation, origin or variety documentation, laboratory testing requirements, biosafety requirements, and post-arrival reporting obligations.
For domestic distribution, particularly inter-island movements, businesses should ensure that applicable quarantine requirements and Certificates of Origin are available. Exporters should separately assess the applicable export recommendation, quarantine, SNI, and restrictions concerning naturally sourced seed and broodstock.
Finally, because the decree dates from 2004, compliance assessments should not rely on the decree in isolation. The relevant provisions should be read together with the current fisheries, aquaculture, quarantine, licensing, standards, and fish seed regulations applicable to the particular activity.
Decree KEP.07/MEN/2004 remains a relevant part of the technical framework for fish seed and broodstock procurement and distribution to the extent that its provisions remain effective and consistent with subsequent legislation. Its practical application should, however, be assessed against the current regulatory framework governing Indonesia’s national fish seed system.
Disclaimer: Here
For additional insights on Indonesian immigration compliance and global mobility matters, explore our related publications:
Indonesia Clarifies Double Bottom Construction Requirements for Cargo and Passenger Ships
Indonesia Revises the Accounting Framework for Upstream Oil and Gas Non-Tax State Revenue
Indonesia Establishes Carbon Trading Framework for the Waste Sector
Indonesia Updates Preclinical In Vivo Toxicity Testing Guidelines
