7 Little-Known Restrictions Under Permendag 23/2025: What Importers Must Know Now

Introduction

The issuance of Permendag 23/2025 marks a significant turning point in Indonesia’s trade and consumer-goods import landscape. Designed to simplify regulatory hurdles and improve the flow of imported products into the domestic market, this new regulation has been welcomed by many global investors and local businesses alike. Its primary goal is to streamline consumer-goods imports, reduce unnecessary bureaucracy, and open wider access for essential and lifestyle products such as electronics, fashion, and beauty items.

Yet, while the regulation has been praised for its progressive approach, it has also created a wave of confusion and uncertainty. For many foreign businesses and importers, the critical question remains: does the removal of certain restrictions translate into full liberalization? Or are there still categories of goods subject to prohibitions, quotas, or special licensing requirements? This grey area is where investors must tread carefully—misinterpreting the policy could result in costly delays, compliance penalties, or shipment rejections at ports.

In this article, we will unpack the real meaning of Permendag 23/2025 for businesses, highlighting its deregulation aspects, the opportunities it creates for consumer markets, and—equally important—the categories of goods that remain restricted or prohibited despite the new framework. By the end, readers will gain a clearer picture of both the opportunities and boundaries under Indonesia’s latest trade regime, ensuring they stay compliant while taking advantage of the new rules.

What Permendag 23/2025 Aims to Achieve

Permendag 23/2025 represents a pivotal shift in Indonesia’s ongoing deregulation agenda, particularly for the importation of consumer goods. This regulation was designed to simplify the import landscape by removing unnecessary bottlenecks, harmonizing requirements, and aligning with broader economic reforms aimed at boosting trade efficiency. The central philosophy of this policy is a cluster-based approach, where goods are classified into categories with differentiated procedures rather than a one-size-fits-all restriction. This system gives importers more clarity and flexibility, while still allowing the government to safeguard strategic sectors.

The regulation replaces its predecessors—Permendag 8/2024 and Permendag 36/2023—which were heavily criticized for creating excessive red tape. Under those rules, importers faced multiple permits, overlapping approvals, and quota-based systems that often delayed shipments. By contrast, Permendag 23/2025 reduces the number of permits required and eliminates duplication in the approval process, signaling a clear effort to modernize Indonesia’s trade environment and bring it closer to global standards.

For businesses, particularly those in electronics, apparel, and beauty products, the change is highly significant. These sectors often faced constraints on quantity limits, brand restrictions, and complex approval layers. Now, with the new regulation, companies enjoy greater ease of entry, faster clearance processes, and a more predictable regulatory environment. For electronics, this means quicker market entry for gadgets and household devices. For apparel, it allows brands to refresh collections more frequently. For beauty and cosmetics, the policy streamlines pathways for trending international products to reach Indonesian consumers faster.

In essence, Permendag 23/2025 is not only a technical adjustment but also a strategic step toward strengthening Indonesia’s competitiveness in the global supply chain, while still maintaining a measured level of regulatory oversight.

Still Restricted: Consumer Goods That Remain Controlled

While Permendag 23/2025 is widely viewed as a deregulation breakthrough, it does not equate to a “free-for-all” in consumer-goods imports. Certain sensitive product categories remain subject to technical checks, approvals, and in some cases, surveyor verification before entering Indonesia. The intent is to protect domestic industries, safeguard consumers, and ensure that safety, quality, and environmental standards are upheld.

1. Textiles and Apparel
Despite relaxation in broader categories, imports of textiles and ready-made apparel still face layered requirements. Importers must often secure technical recommendations from the Ministry of Industry to verify compliance with local standards. For instance, fabric rolls and finished garments may need proof of origin and conformity testing, ensuring local producers are not undercut by low-quality or mass-subsidized imports.

2. Beauty and Personal Care Products
Cosmetics, skincare, and other beauty items continue to be tightly monitored. BPOM (Indonesia’s Food and Drug Authority) plays a central role, requiring product registration before items can be distributed in the market. Even if the import permit is granted under the new regime, without BPOM approval these goods cannot legally reach consumers. This safeguard is particularly important given health and safety concerns related to counterfeit or harmful ingredients.

3. Electronics and Household Appliances
Although deregulation has opened new opportunities, certain categories—such as home appliances, IT hardware, or telecommunications equipment—still need SNI (Indonesian National Standard) certification or additional permits. For example, smartphones may be imported more easily, but they remain subject to TKDN (local content) rules and certification requirements to prevent market flooding.

4. Food and Beverages
Some consumer food items, especially those involving dairy, processed meats, or beverages with specific ingredients, still require import recommendations from the Ministry of Agriculture or Health. These measures help ensure compliance with halal certification, food safety standards, and local agricultural protection.

5. Surveyor Reports and Exceptions
Permendag 23/2025 also outlines cases where independent surveyors must verify imports prior to shipment. This is common for goods categorized as sensitive—such as used clothing (which remains outright prohibited), or products that could affect national health, safety, and security. Exceptions may be granted for research, exhibition, or non-commercial use, but these are processed on a case-by-case basis.

In short, while the regulation eases the path for many consumer goods, importers must remain cautious. Knowing which product clusters still require permits, recommendations, or surveyor involvement is critical to avoiding delays and compliance penalties.

Hidden Compliance Triggers Importers Can’t Overlook

While Permendag 23/2025 is framed as a deregulation breakthrough, importers should not mistake this as a complete relaxation of oversight. Beneath the headlines, several hidden compliance triggers remain embedded in Indonesia’s trade ecosystem. Overlooking them could result in delays, penalties, or even shipment rejection.

First, every importer is still required to process licensing through Online Single Submission (OSS) and ensure that their Business Identification Number (NIB) is properly updated to cover import activities. For certain products, importers may need additional product-specific endorsements, such as approvals from sectoral ministries before goods are released at customs. Electronics, cosmetics, and health-related items, for example, often require certification that the products meet national safety or labeling standards.

Second, Permendag 23/2025 maintains references to Indonesian National Standards (SNI), meaning that even deregulated items must comply with mandatory SNI where applicable. Importers of children’s toys, food-contact materials, or electrical appliances should expect continued technical checks and, in some cases, testing through accredited laboratories in Indonesia before distribution.

Third, while the regulation scrapped many restrictive quotas and surveyor requirements, trade remedies such as anti-dumping duties and safeguard measures remain active. For instance, certain steel products, footwear, or textiles may still be subject to higher duties if imported in large volumes, based on existing WTO-aligned safeguard clauses.

Another subtle yet crucial factor is system readiness. The government announced that the Ministry of Trade’s INATRADE portal is being synchronized with OSS to prevent duplication and simplify submissions. However, businesses have reported transitional hiccups—delays in data synchronization, unclear instructions, or backlogs in approvals. As noted in recent Ministry guidelines (Antara News, DFDL), importers are encouraged to cross-check both systems and maintain proactive communication with local customs officials to avoid unnecessary holdups.

In short, while Permendag 23/2025 opens new doors, compliance still requires precision. Success depends not just on celebrating deregulation but on recognizing the regulatory nuances that continue to govern Indonesia’s import ecosystem.

Step-by-Step: How Importers Should Approach Permendag 23/2025

For businesses planning to bring consumer goods into Indonesia under the new Permendag 23/2025, the most effective strategy is to follow a structured, compliance-first approach. While the regulation offers greater flexibility compared to its predecessors, the process still requires diligence and alignment with official systems.

1. Identify your product cluster.
Start by determining where your goods fall within the new consumer-goods clusters introduced under the regulation. The clusters classify products into broad categories such as electronics, apparel, footwear, cosmetics, and household items. This step is crucial because the rules, requirements, and possible restrictions differ by cluster.

2. Check for restricted status.
Even though Permendag 23/2025 removes many barriers, certain items—particularly textiles, apparel, and beauty products—still require additional permits. Importers should consult the official annexes and cross-check against existing safeguard or anti-dumping measures before proceeding.

3. Prepare documentation.
Gather the required paperwork early. Depending on the product, this may include surveyor reports, technical recommendations from relevant ministries, a Nomor Induk Berusaha (NIB), and certifications proving compliance with the Indonesian National Standard (SNI). Timely preparation reduces the risk of delays at customs.

4. Submit via OSS/INATRADE.
All applications and approvals flow through Indonesia’s Online Single Submission (OSS) and INATRADE platforms. Importers must ensure their profiles are complete and accurate to avoid processing bottlenecks. Seamless integration between systems remains a government priority, but importers should anticipate occasional technical issues.

5. Monitor regulatory updates.
Permendag 23/2025 is part of Indonesia’s wider deregulation drive, meaning adjustments or clarifications may still follow. Regularly tracking announcements from the Ministry of Trade and related agencies will help businesses stay compliant while capitalizing on the new flexibility.

By approaching the process step by step, importers can minimize compliance risks and maximize the opportunities offered by Indonesia’s updated trade framework.

Industry Response & Expert Insights

The release of Permendag 23/2025 has sparked a wave of responses across Indonesia’s import-dependent industries. Many trade associations and business groups have welcomed the regulation as a long-awaited step toward easing bottlenecks created by Permendag 8/2024 and 36/2023, which were criticized for creating uncertainty and backlog at ports. Platforms such as Expat Indonesia have highlighted that the cluster-based model now provides more predictability, especially for importers of electronics, cosmetics, and household appliances, who had been struggling with repeated rejections due to vague category restrictions.

However, stakeholders have also raised concerns. Associations in the textile and apparel sectors note that while deregulation has improved, technical recommendations and licensing requirements are still intact for many consumer goods. Some fear that overlapping rules between the Ministry of Trade, Ministry of Industry, and BPOM (for cosmetics) could continue to cause delays unless digital systems like OSS and INATRADE achieve full integration.

Legal and tax advisory firms have begun issuing strategic recommendations for businesses. Leading advisors recommend importers:

1. Conduct proactive compliance audits to ensure their product clusters align with the new categories.
2. Update internal SOPs for trade documentation, as surveyor reports and technical endorsements still apply in specific cases.
3. Monitor safeguard duties and anti-dumping measures, which remain enforceable even under the new deregulation framework.
4. Engage in continuous monitoring of Ministry of Trade circulars, as enforcement practices are expected to evolve throughout 2025.

In essence, while Permendag 23/2025 opens more doors for importers, industry experts stress that businesses must maintain vigilance. Success under the new system will not depend only on flexibility but also on how well companies adapt to hidden compliance triggers and ongoing inter-ministerial coordination.

FAQ: Permendag 23/2025 in Practical Scenarios

Q1: Is importing electronics now completely unrestricted?
Not entirely. Permendag 23/2025 relaxes entry for common consumer electronics like laptops, tablets, and mobile phones. However, importers must still ensure products meet SNI (Indonesian National Standard) or other safety requirements. Certain categories like communication equipment with frequency usage may still fall under Ministry of Communication oversight.

Q2: What still needs a technical rec for apparel?
Most fashion and apparel goods are under lighter control, but some categories still require technical recommendations (e.g., protective wear, uniforms for public service, or apparel with safety functions). Importers should check whether their items fall under the “functional apparel” list where Kementerian Perindustrian (Ministry of Industry) retains authority.

Q3: How to check if a consumer product remains restricted?
The Ministry of Trade advises using OSS (Online Single Submission) and INATRADE portal to verify restrictions. By entering the HS Code, importers can see whether an item falls under open general import, conditional import (requiring permits), or restricted import. This remains the most reliable step before shipping.

Q4: Are old approvals still valid under the new system?
Yes, but with caution. Approvals such as import recommendations, technical recs, or surveyor reports obtained before Permendag 23/2025 generally remain valid until their expiry date. However, renewal requests must comply with the new framework. Businesses should prepare documentation early to avoid rejection during transition.

Q5: Will surveyor reports still be required for certain goods?
Yes. While the regulation significantly reduces surveyor involvement, some consumer goods with health, safety, or environmental implications (cosmetics, certain processed foods, chemicals) still require pre-shipment surveyor reports. The Ministry has signaled that the requirement will be gradually reduced, but until full integration, importers should budget both time and costs for surveyor engagement.

Takeaway: Permendag 23/2025 marks a shift toward streamlined access but still embeds several compliance obligations. Importers who cross-check HS Codes, maintain updated permits, and adapt to OSS/INATRADE updates will avoid costly disruptions.

Conclusion & Key Actions

Permendag 23/2025 represents a pivotal shift in Indonesia’s trade policy, offering broader flexibility for importers of consumer goods. The removal of many restrictions reflects the government’s intent to streamline supply chains and support domestic demand. Yet, this new landscape does not mean a “free-for-all.” Importers must still pay close attention to the fine print: certain items remain tied to technical recommendations, surveyor report obligations, and Indonesian National Standard (SNI) requirements.

The biggest risk lies in assuming all categories are unrestricted—when in fact, hidden compliance triggers still exist across specific product clusters. Moreover, system readiness, particularly with OSS and INATRADE integration, requires importers to remain proactive in monitoring changes and updates issued by the Ministry of Trade.

For businesses, the key actions are clear: always verify your product category before importation, ensure licensing and documentation are complete, and consult with experienced trade and legal experts to avoid costly missteps. By combining opportunity with compliance discipline, importers can not only benefit from a more open regime but also safeguard their long-term position in Indonesia’s evolving market.

‍