Indonesia promulgates Ministerial Regulation on export restriction/prohibition on chemicals and minerals 
On August 29, 2024, Indonesian government promulgated “Regulation of the Minister of Commerce No. 20/2024 Providing for the Second Amendment to Regulation of the Minister of Commerce No. 22/2023 on Goods Prohibited to be Exported”; and “Regulation of the Minister of Commerce No. 21/2024 Providing for the Second Amendment to Regulation of the Minister of Commerce No. 23/2023 on Export Policy and Regulations.” The former specifies goods that are prohibited from being exported from Indonesia, while the latter specifies goods that are subject to licensing or other requirements to be exported. Both Regulations will enter into force 30 working days after the promulgation.
Goods prohibited for export
Regulation of the Minister of Commerce No. 20/2024 completely revises the existing list of goods prohibited from being exported. The revised list designates a total of 405 goods related to forestry, agriculture, minerals, scrap metal, and scrap metal. Among the minerals are iron, tin, copper, nickel, and others.
Goods restricted for export
Regulation of the Minister of Commerce No. 21/2024 fully revises the existing Annex I (Goods Requiring a Business License for Export Business), Annex IV (Goods not Intended for Business Activities and Exempt from Export Restrictions), and Annex V (Goods Intended for Business Activities but Exempt from Export Restrictions). While most of the goods currently listed are related to wildlife, plants and flowers, fertilizers, and minerals, Annex I “Chapter XI: Non-pharmaceutical Precursors” designates a total of 24 chemicals as shown below as regulatory target. Export of these chemicals is allowed only when the exporting entity is registered as an Exporter (ET: Eksportir Terdaftar), an export license (PE: Persetujuan Ekspor) is obtained from the relevant authorities, and an inspection report (LS: Laporan Surveryor) is submitted.
| # | HS Code | Goods |
|---|---|---|
| 293 | 2806.10.00 | Hydrogen chloride (hydrochloric acid) |
| 294 | 2807.00.10 | Sulfuric acid and fuming sulfuric acid – Sulfuric acid containing more than 80% H2 SO4 by weight |
| 295 | 2807.00.90 | Sulfuric acid and fuming sulfuric acid – Others |
| 296 | 2841.61.00 | Potassium permanganate |
| 297 | 2902.30.00 | Toluene |
| 298 | 2909.11.00 | Diethyl ether |
| 299 | 2914.11.00 | Acetone |
| 300 | 2914.12.00 | Butanone (methyl ethyl ketone) |
| 301 | 2914.31.00 | Phenylacetone (phenylpropan-2-one) |
| 302 | 2915.24.00 | Acetic anhydride |
| 303 | 2916.34.00 | Phenylacetic acid and its salts |
| 304 | 2922.43.00 | Anthranilic acid and its salts |
| 305 | 2924.23.00 | 2-Acetamidobenzoic acid (N-acetylanthranilic acid) and its salts |
| 306 | 2932.91.00 | Isosafrole |
| 307 | 2932.92.00 | 1-(1,3-benzodioxol-5-yl)propan-2-one |
| 308 | 2932.93.00 | Piperonal |
| 309 | 2932.94.00 | Safrole |
| 310 | 2933.32.00 | Piperidine and its salts |
| 311 | 2939.41.00 | Ephedrine and its salts |
| 312 | 2939.42.00 | Pseudoephedrine (INN) and its salts |
| 313 | 2939.44.00 | Norephedrine and its salts |
| 314 | 2939.61.00 | Ergometrine (INN) and its salts |
| 315 | 2939.62.00 | Ergotamine (INN) and its salts |
| 316 | 2939.63.00 | Lysergic acid and its salts |
The original text of the above two ministerial regulations can be downloaded from the following URL:
- Regulation of the Minister of Commerce No. 20/2024
https://jdih.kemendag.go.id/pdf/Regulasi/2024/Permendag_20_2024_Perubahan%20Kedua%20Permendag%2022-2023_Barang%20Dilarang%20Ekspor_e-pengundangan.pdf - Regulation of the Minister of Commerce No. 21/2024
https://jdih.kemendag.go.id/pdf/Regulasi/2024/Permendag_21_2021_Perubahan%20Kedua%20Permendag%2023-2023_Kebijakan%20Pengaturan%20Ekspor_e-pengundangan.pdf
