Indonesian Ministry of Trade (MOT) issued a new MOT Regulation No. 36 of 2023 on Import Policy and Import Arrangement on 11 December 2023 (“MOT Regulation 36”), which will revoke MOT Regulation No. 25 of 2022. MOT Regulation 36 will come into force within 90 days after 11 December, which falls on 10 March 2024.

MOT Regulation 36 stipulates that import approval (Persetujuan Impor/PI) applications can only be submitted to the MOT after the regulation comes into effect on March 10. This is because the MOT and the relevant technical ministries or institutions are preparing the readiness of the new system in accommodating the import requirements as mandated in MOT Regulation 36.

This limited 90-day transition or grace period may cause significant business disruptions due to the potential lack of readiness in the system for submission of import approval (PI) applications. This can lead to a “blackout period”, as companies may postpone importation of goods between the transition period and the issuance date of the new import licenses. Any delays of the import license application system may result in financial losses, supply chain challenges, and eventually affecting the companies’ ability to meet the domestic market demand.