Indonesia bans copper concentrate and anode sludge exports under Permendag 10/2024

Mechanism

Permendag 10/2024 is an amendment, not a stand-alone instrument. It modifies the appendix of Permendag 22/2023 (the master list of prohibited-export goods) to push the copper-concentrate and anode- sludge ban from 1 June 2024 to 31 December 2024, after which the items remain on the prohibited-export list permanently. The companion ESDM Regulation 6/2024 governs the upstream mining-permit side: domestic smelter offtake obligations, royalty schedules, and Special Mining Business Licence (IUPK) extensions tied to smelter- build progress.

In practice, enforcement is mediated through export-permit (Persetujuan Ekspor / PE) issuance by the Ministry of Trade, which gives the executive discretionary room to extend permits in narrow circumstances — e.g. the post-fire Freeport extension granted Feb 2025. This is the same enforcement architecture used for the 2020-2023 nickel and bauxite bans: the rule is permanent, but the flow of export licences is controlled case-by-case until domestic smelter capacity is comfortably ahead of mine output.

Downstream implications

• Captures copper smelting + refining margin domestically. Freeport

Manyar (~1.7 Mt concentrate/yr capacity, ~600 kt refined Cu/yr) and Amman Sumbawa (~900 kt concentrate/yr capacity, ~220 kt refined Cu/yr) together convert Indonesia from a near-pure concentrate exporter to a refined-cathode + by-product (gold, silver, sulphuric acid) exporter once both smelters are at steady-state.

• Reshapes Asian smelter TC/RC markets. Indonesia accounts for

~5% of global mined copper. Removing this concentrate volume from seaborne trade tightens already-stressed Chinese/Japanese/Korean custom-smelter feedstock — the 2024 collapse of TC/RCs to negative territory was partially driven by anticipation of this and other concentrate-supply shocks.

• **Continues the "hilirisasi" template begun with nickel (2020) and

bauxite (2023).** Confirms that resource nationalism in Indonesia is now a settled cross-administration doctrine — Jokowi's framework continued under the Prabowo administration that took office October 2024.

• **Discretionary extension during smelter commissioning is the new

norm.** The Freeport Feb-2025 extension shows the rule will be enforced flexibly when domestic processing capacity is materially delayed, mirroring the case-by-case relaxations used for nickel-rule edge cases (low-grade ore, by-products) in 2020-2022.

Open questions

• How long will Freeport's discretionary export extension run, and

will Amman receive a similar extension if its Sumbawa smelter ramp-up slips? The cumulative volume of permitted concentrate exports in 2025-2026 will determine the actual market impact versus the headline ban.

• Will Indonesia attempt the same model for tin, where Bangka-Belitung

smelters already process most domestic output, or for further refined-product steps (copper rod, copper foil)?

• Does the eventual Freeport Manyar / Amman Sumbawa output capture

the by-product gold and silver streams that previously flowed through Japanese smelters, and at what rate (royalty / domestic- market obligation)?