Temporary Import and Temporary Export of Returnable Packaging

The Minister of Finance issued a Regulation No. 52 of 2026 concerning the Temporary Import and Temporary Export of Reusable Packaging (Returnable Package) on 15 July 2026, which will become effective on 29 September 2026. Previously, Returnable Package permits were processed under the general Minister of Finance Regulation concerning Temporary Imports. However, PMK 52 of 2026 was issued to establish a highly specific regulatory framework tailored for the movement of reusable packaging of both foreign origin (RPLN) and domestic origin (RPDN). A Returnable Package is defined as non-container packaging that is used repeatedly without substantial changes to its essential form and must be identifiable for subsequent return. Under this new specific regulation, all new applications must strictly follow its provisions, including electronic processing via the Customs Computer System (SKP), specific customs access requirements, and mandatory quarterly reporting submitted by the 10th day of the following quarter. The temporary importation of RPLN and re-importation of RPDN are granted full customs and tax facilities, including exemption from Import Duty, non-collection of VAT and Luxury Goods Sales Tax (PPnBM), and exemption from Article 22 Income Tax on imports, all without the requirement to provide a financial guarantee.

For businesses currently operating with active Returnable Package permits issued under the previous general regulation, PMK 52/2026 provides a clear transitional phase to ensure uninterrupted logistics operations. Temporary Import Permits for Returnable Packages issued prior to the enactment of PMK 52/2026 will remain valid for a maximum transition period of 6 (six) months after the new regulation takes effect. During this 6-month window, companies must align their existing permits with the new regulation by submitting a new permit application under PMK 52/2026. To facilitate this shift, any remaining unsettled RPLN from the old permit that has not yet been re-exported can simply be recorded as the opening inventory (saldo awal) in the newly issued permit.

Operationally, the licensing mechanism grants a 1-year permit validity, which can be extended up to a maximum cumulative limit of three years for RPLN. Upon reaching the 3-year limit, businesses may apply for a permit renewal by registering the remaining items as opening inventory. The packaging may also be utilized by registered Third Parties listed in the permit, strictly for transporting or packaging export goods. Customs supervision is significantly reinforced through administrative sanctions. In principle, RPLN must be re-exported, and delayed re-export triggers an administrative fine equal to 100% of the payable import duty. Packaging is only exempted from re-export duties and fines if it is severely damaged or destroyed by force majeure, which must be verified by official government certification. Conversely, if RPLN is lost or severely damaged during normal operations, the permit holder must still pay the import duty due, import taxes (PDRI) payable, and the 100% administrative penalty. Packaging that remains unresolved upon permit expiry will be subject to sealing measures for a maximum of 30 days prior to formal detention by Customs, and any customs criminal violations will result in a 12-month ban (blacklisting) on new permit applications.