Indonesia Permendag 20/2025 — import licensing for chemicals, hazardous materials, and mining inputs

Mechanism

Permendag 20/2025 is the chemicals/B2/mining-input cluster of a nine-Permendag deregulation-with-control package issued on 30 June 2025 alongside the umbrella Permendag 16/2025. It does two things at once:

1. Loosens the catch-all import regime by replacing Permendag 8/2024 (which had been criticised as over-broad) with a sector-tailored structure. 2. Tightens licensing for an explicitly enumerated list of strategic commodities — lubricant base oils, cement clinker and cement, rough diamonds, non-pharmaceutical precursors, crude oil and natural gas, nitrocellulose (NC), commercial-industrial explosives (handak), ozone-depleting substances (ODS), Hazardous Materials (B2), hydrofluorocarbons (HFC), and certain other chemicals (BKT).

Operational architecture:

• Only Importir Terdaftar (IT) or Importir Produsen (IP) designations

may import the listed commodities.

• A Persetujuan Impor (PI) must be obtained before shipment, requiring

a technical recommendation from the relevant sectoral ministry (Industry / ESDM / Bappebti depending on the cluster).

• A Laporan Surveyor (LS) verifies the cargo post-arrival.
• KEK / KPBPB / Bonded-zone and export-purpose flows get carve-outs to

prevent leakage from the controlled domestic regime.

The regulation has already been amended once — Permendag 32/2025 made technical adjustments to the PI/LS workflow.

Downstream implications

• This is the first Indonesia import-side B2/chemicals/mining-input

licensing entry in the IPTM register. It complements, but does not duplicate, the long export-side hilirisasi arc (nickel ore ban, bauxite ban, copper concentrate ban, DHE-SDA retention, Minerba 4th amendment, PP 19/2025 royalties, Permenperin 35/2025 TKDN, Permen ESDM 17/2025 RKAB).

• Net effect for upstream feedstocks flowing into Indonesia's smelter

and processing complex: importers face additional pre-shipment PI workflow + post-arrival LS verification. Margin and timing impact is non-trivial for cement-clinker importers and HFC/B2 specialty chemical channels in particular.

• Coverage of crude oil and natural gas imports under the same regime

is materially significant — Indonesia is a structural net oil importer; PI requirements for crude affect Pertamina and downstream refiners' procurement workflow.

• The deregulation-with-control framing matters for how Western

trading partners read it. The package is presented as easing bureaucratic burden, but on the listed commodities it tightens state discretion, consistent with the Prabowo administration's posture of using import policy as an industrial-strategy lever rather than a passive trade tool.

Open questions

• Tariff/quota interaction: Does the PI workflow translate into

effective volume rationing for any of the eleven clusters, or is it primarily administrative?

• Will subsequent Permendag amendments add or remove commodities

from the controlled list (Permendag 32/2025 already adjusted workflow — watch for substantive additions).

• Cross-impact on Permendag 16/2025 (the umbrella regulation) and

the other eight cluster-specific Permendags issued the same date.

• B2/HFC enforcement: how strict is the surveyor verification in

practice, and does it create de-facto barriers for smaller specialty-chemical importers?