Regulation Watch · Business Licensing · Indonesia, with the new used-electronics route limited to the Batam Free Trade and Free Port Zone (KPBPB Batam) and separate exemption powers for other KPBPB.
Batam Opens a Regulated Route for Used Industrial Electronics
Permendag 23/2026 allows specified used electronic goods to be imported for industrial needs in KPBPB Batam from 9 October 2026, subject to an API-P NIB, prior import approval, destination controls, and the amended tariff and technical requirements.
- Published
- Established and promulgated on 9 September 2026 in State Bulletin 2026 No. 623.
- Effective
- 9 October 2026, 30 days after promulgation.
- Added to Watch
- 19 September 2026
- Updated
- 9 October 2026
Who is affected
Industrial companies and PT PMA manufacturers in KPBPB Batam, foreign investors and directors, holders of an NIB that functions as an API-P, industrial users of specified used electronic equipment, import and customs teams, logistics providers, suppliers, technical surveyors, advisers, and KPBPB businesses seeking an import-policy exemption.
Practical impact
The amendment adds 136 tariff lines of used electronic goods for industrial processing needs to the regulated categories under Permendag 24/2025 and creates a Batam-only import route. An eligible industrial importer must hold an NIB that functions as an API-P, obtain Import Approval (PI) before the goods enter the customs territory, complete technical verification in the country of origin and hold the resulting Surveyor Report (LS). Shipments must be homogeneous and have clearly identifiable physical characteristics so they are not treated as electronic waste. The goods cannot be moved from Batam to another KPBPB, a special economic zone, a bonded facility, or another part of the customs territory. Import realization must be reported monthly through SINSW, and processing must comply with environmental requirements for resulting residue and waste. The regulation also revises the KPBPB exemption mechanism and replaces the tariff-code and requirement attachment.
Permendag 23/2026 was established and promulgated on 9 September 2026 as State Bulletin 2026 No. 623. It takes effect 30 days later, on 9 October 2026, and amends Permendag 24/2025 on imports of goods in non-new condition and non-hazardous, non-toxic waste.
The amendment adds used electronic goods for industrial needs as a regulated import category and creates a narrowly defined route for KPBPB Batam. The importer must be an industrial business in Batam with an NIB that functions as an API-P and must obtain PI before the goods enter the customs territory. Eligibility also depends on the goods and requirements in the replacement attachment, so the precise HS code and technical conditions must be checked before ordering or shipping.
The geographic control is strict. Used industrial electronics imported under this route cannot be moved from Batam to another KPBPB, a special economic zone, a bonded facility, or another part of the Indonesian customs territory. Businesses should therefore document the final industrial user and site, control inventory and asset movements, and prohibit diversion or onward domestic sale in their contracts and operating procedures.
The amendment also changes the treatment of KPBPB exemptions. For KPBPB other than Batam, exemptions for specified used capital goods, used lithium batteries, and non-B3 waste may be based on a zone-council determination. In Batam, the Head of BP Batam may determine an exemption for the regulated categories after considering the zone council, while KPBPB import approvals are issued through an electronic system integrated with SINSW and INATRADE.
The regulation is an import-permission framework, not a waiver of customs, environmental, industrial, safety, installation, or operational requirements. A Batam investor should reconcile the NIB and API-P status, PI, tariff classification, technical verification, customs documents, environmental position, destination facility, and contract remedies before the shipment is committed. The amendment itself sets no new monetary fine, but non-compliant goods may be held, rejected, re-exported, or exposed to administrative measures under the applicable regimes.
Implementation update, 9 October 2026: the Directorate General of Foreign Trade confirmed that the route covers 136 HS tariff lines and requires a Surveyor Report based on technical verification in the country of origin. It also confirmed that shipments must be homogeneous and physically identifiable to prevent entry of electronic waste, that import realization must be reported monthly through SINSW, and that processing residue and waste remain subject to environmental requirements. BP Batam's task force will coordinate supervision with Customs and Excise and the Directorate General of Consumer Protection and Trade Compliance. These details should be built into procurement, pre-shipment inspection, customs, inventory, monthly reporting, production, and waste-management controls from the first shipment.
Required action
- Confirm that the equipment and HS code appear in the amended attachment and that the intended use is a genuine industrial need in KPBPB Batam; do not treat the amendment as a general permission to import used consumer electronics.
- Verify that the Batam industrial company holds an active NIB that functions as an API-P, and obtain the required PI before shipment or entry into the customs territory.
- Arrange technical verification in the country of origin and obtain the required Surveyor Report before shipment; align the contract, invoice, packing list, technical specifications, shipment route, port, destination facility, and customs filing with the amended import conditions.
- Confirm that each shipment is homogeneous and has clear physical characteristics, and document that it is qualifying industrial input rather than electronic waste.
- Implement asset, inventory, and logistics controls that prevent the imported goods from being transferred from Batam to another KPBPB, a special economic zone, a bonded facility, or elsewhere in Indonesia.
- File the import-realization report every month through SINSW and retain the filing evidence with the PI, LS, customs, inventory, and production records.
- If relying on a KPBPB exemption, obtain and retain the applicable determination from BP Batam or the relevant zone authority and confirm that the approval is processed through the electronic system integrated with SINSW and INATRADE.
- Review environmental, residue and waste handling, occupational-safety, installation, and operational approvals for the equipment and allocate rejection, re-export, storage, and compliance costs in the supply and logistics contracts.