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Export Policies on Several Strategic Natural Resources Commodities

Export Policies on Several Strategic Natural Resources Commodities

The Government regulates the export policy of all Strategic Natural Resource Commodities (“SNRC”) through Government Regulation (GR) No. 24 of year 2026 (“GR-24/2026”) regarding the Governance of the export of Strategic natural resource commodities. The SNRC policy will be carried out gradually. For the initial stage, the SNRC comprise coal, palm oil, and ferro-alloys. The policy on the export of SNRC may be implemented through:

a. export control, including the conduct of technical verification or tracing;
b .regulation of export transportation and insurance; and/or
c. other mechanisms in accordance with the provisions of laws and regulations.

The SNRC may only be exported by state-owned (BUMN) exporting companies, either as the owner or as the sole intermediary.  An exception is provided for business actors holding a contract or agreement with the Government that contains at least the following provision:

a. investment;
b. divestment; and
c. domestic processing and/or refining.

In implementing the export of SNRC by the BUMN exporting companies, the selling price of the SNRC is determined by the BUMN exporting companies, which may determine a reasonable margin in accordance with the provisions of laws and regulations.

As the implementation of GR-24/2026, the Ministry of Trade (MoT) has issued 3 (three) MoT regulations:

1. MoT Regulation No. 15 of 2026, regarding the export policy of Coal;
2. MoT Regulation No. 16 of 2026, regarding the export policy of Palm Oil; and
3. MoT Regulation No. 17 of 2026, regarding the export policy of Ferroalloys.

GR-24/2026 is effective from 1 June 2026 and the export of SNRC as mentioned above must be conducted by designated BUMN Exporters. The government provides a transition period for private companies (non-BUMNs) until December 31, 2026.

The BUMN are granted full authority to set export selling prices to maintain domestic availability and economic stability. To handle all administration, business actors are required to use the government’s integrated online service systems (the INATRADE and SINSW systems). The breakdown of product types and simplified document requirements is as follows:

The detailed product descriptions and the complete list of tariff lines/HS codes governed under this framework are explicitly detailed in the Appendices of each MoT Regulation.

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