Indonesia’s trade and investment landscape entered a new regulatory phase with the issuance of Permendag 47/2025. Officially titled Peraturan Menteri Perdagangan Nomor 47 Tahun 2025 tentang Barang yang Dilarang untuk Diimpor, this regulation significantly reshapes how import prohibitions apply across Indonesia—not only within the customs territory, but also inside Free Trade Zones (KPBPB), Special Economic Zones (KEK), and Bonded Zones (TPB).
For many years, Free Trade Zones and Special Economic Zones were perceived as offering a degree of regulatory flexibility, particularly for inbound goods intended for processing, storage, or re-export. Permendag 47/2025 removes much of that ambiguity. The regulation makes it clear that prohibited goods are restricted everywhere, including within Indonesia’s most investment-friendly zones.
For foreign investors, manufacturers, zone operators, and logistics companies, understanding how Permendag 47/2025 works in practice is no longer optional—it is now a fundamental compliance requirement.
Understanding the Legal Purpose of Permendag 47/2025
The issuance of Permendag 47/2025 is not merely an administrative update. The regulation explicitly replaces Permendag No. 18 Tahun 2021, as amended by Permendag No. 40 Tahun 2022, on the grounds that the previous framework was no longer aligned with Indonesia’s legal and economic developments.
The regulation is issued under the authority of:
- Indonesia’s Customs Law
- Trade Law
- Government Regulation No. 29 of 2021 on Trade Administration
By resetting the list of prohibited imports, the government aims to strengthen:
- Public health and safety protections
- Environmental safeguards
- Domestic industry protection
- Trade governance and enforcement consistency
Most importantly, Permendag 47/2025 removes interpretive gaps that previously allowed businesses to assume that special customs zones might fall outside the scope of import prohibitions.
The Core Policy Shift: Prohibited Goods Apply Inside FTZ and KEK
One of the most consequential elements of Permendag 47/2025 is found in Article 4, which explicitly extends import prohibitions to special zones.
Under this provision, importers are prohibited from:
- Bringing prohibited goods into Kawasan Perdagangan Bebas dan Pelabuhan Bebas (KPBPB)
- Importing prohibited goods into Kawasan Ekonomi Khusus (KEK)
- Importing prohibited goods into Tempat Penimbunan Berikat (TPB)
- Importing prohibited goods under export-oriented processing schemes, including imports intended to be processed and re-exported
This applies regardless of whether the goods are:
- Intended for storage only
- Intended for processing or assembly
- Intended solely for re-export
In practical terms, Permendag 47/2025 closes the long-standing assumption that FTZ or KEK status can function as a regulatory buffer for restricted goods.
Categories of Goods Prohibited Under Permendag 47/2025
Article 2 of Permendag 47/2025 establishes a definitive list of prohibited goods, with further technical detail contained in the regulation’s annex (Lampiran).
The prohibited categories include, among others:
- Sugar and rice
- Ozone-depleting substances
- Used sacks, used bags, and used clothing
- Fire-extinguishing cooling systems
- Non-fire cooling systems
- Electronics that rely on cooling systems
- Certain pharmaceutical and food-related substances
- Hazardous and toxic materials (B3)
- Registered hazardous and non-hazardous waste
- Finished hand tools
- Medical devices containing mercury
These prohibitions apply universally, including to imports routed directly into Free Trade Zones or Special Economic Zones.
Why FTZ and KEK Status No Longer Offers a Safe Harbor
Before Permendag 47/2025, many businesses structured their supply chains under the assumption that restricted goods could still be brought into bonded or free zones as long as they did not enter Indonesia’s customs territory.
The regulation now removes that assumption entirely.
By clearly prohibiting the physical entry of prohibited goods into KPBPB, KEK, and TPB, the government signals a policy direction that emphasizes:
- Preventive enforcement rather than post-entry control
- Alignment between customs law and trade policy
- Elimination of regulatory gray areas
For investors, this means that compliance risk must now be evaluated at the sourcing and contracting stage, not after goods arrive at port or zone gates.
Limited Exceptions Under Permendag 47/2025
Despite its strict approach, Permendag 47/2025 does provide narrow and clearly defined exceptions.
Re-import of Previously Exported Goods
Article 5 allows for the re-importation of goods that were previously exported from Indonesia, provided the re-import complies fully with customs regulations.
This exception is narrow and does not apply to:
- Newly sourced goods
- Third-country rerouting
- Processing or transformation activities
Transitional Provision for Certain Cooling-System Goods
Article 7 introduces a one-time transitional exemption for certain cooling-based goods using HCFC-123. To qualify, goods must:
- Have been shipped before the regulation took effect
- Be supported by valid Bill of Lading or Air Waybill documentation
- Arrive at the destination port no later than 31 January 2026
This transitional relief is temporary and should not be interpreted as an ongoing exemption.
Enforcement, Sanctions, and Compliance Risk
Article 6 of Permendag 47/2025 confirms that violations are subject to sanctions under prevailing laws and regulations
In practice, non-compliance may expose businesses to:
- Cargo detention or refusal of entry
- Mandatory re-export or destruction of goods
- Administrative penalties
- Reputational and operational disruptions
For FTZ and KEK operators, enforcement risk is particularly significant, as zone facilities remain under customs supervision despite fiscal incentives.
Practical Implications for Investors and Zone Operators
The implications of Permendag 47/2025 extend beyond legal theory. For businesses operating in or planning to enter FTZs or KEKs, the regulation requires a fundamental reassessment of supply-chain strategy.
Companies must now:
- Review HS classifications against the prohibited list and annex
- Audit inbound raw materials and components
- Revisit supplier contracts and compliance warranties
- Align logistics planning with import eligibility rules
- Ensure internal compliance teams understand zone-specific restrictions
This shift places greater emphasis on pre-import legal due diligence, rather than post-arrival remediation.
Frequently Asked Questions (FAQ)
Does Permendag 47/2025 apply inside Free Trade Zones?
Yes. Permendag 47/2025 explicitly prohibits the entry of prohibited goods into Free Trade Zones (KPBPB), removing any ambiguity about zone-based exemptions.
Can prohibited goods be imported into KEK for re-export only?
No. The regulation prohibits imports into KEK regardless of whether the goods are intended for domestic use, processing, or re-export.
Are bonded zones treated differently under Permendag 47/2025?
No. Bonded zones (TPB) are expressly included in the prohibition under Article 4.
Is there any grace period under Permendag 47/2025?
Only a limited, time-bound transitional provision applies to certain cooling-system goods shipped before the regulation took effect.
When did Permendag 47/2025 come into force?
The regulation entered into force on 1 January 2026
Conclusion: A Clear Regulatory Signal
Permendag 47/2025 represents a decisive shift in Indonesia’s import control policy. By extending import prohibitions fully into Free Trade Zones and Special Economic Zones, the government has clarified that investment incentives do not override trade restrictions.
For businesses, this means compliance must be proactive, strategic, and integrated into supply-chain planning from the outset. Regulatory assumptions that once seemed safe are no longer reliable.
Understanding Permendag 47/2025 is essential—but applying it correctly is where many businesses face challenges.
CPT Corporate assists foreign investors, manufacturers, and zone operators in:
- Interpreting import restrictions under Permendag 47/2025
- Conducting compliance and HS classification reviews
- Structuring lawful supply chains for FTZ and KEK operations
- Mitigating regulatory and customs risks before goods are shipped
If your business operates in or plans to enter Indonesia’s Free Trade Zones or Special Economic Zones, now is the time to reassess your import strategy.
