Import & Export Management

Importer of Record Indonesia

Your goods need an Indonesian company to act as importer. MDM helps international suppliers choose or review that company, check that its licences fit the goods and put responsibilities in writing before shipment.

Discuss Your Importer Arrangement

Updated 1 October 2026 · Meet the MDM team

What the importer of record means in Indonesia

Indonesian law does not use the term “importer of record”. In practice it means the company named as importer in the customs declaration (PIB). That company must be an Indonesian business entity whose NIB functions as an importer identification number (API) under Permendag No. 16 of 2025. A foreign supplier cannot act as importer itself. See the regulation.

The importer can be your own Indonesian subsidiary, your distributor or a third-party importing company. This page covers MDM’s support in choosing and reviewing that arrangement. MDM does not act as importer.

What the importer is responsible for

Bea Cukai’s guidance places these responsibilities on the importer:

Filing the import declaration and self-assessing duty, excise and import taxes.
Meeting import prohibitions and restrictions (lartas) and declaring them in the PIB.
Holding any import licences required for the goods. Where licences apply, the importer also files the monthly import realisation reports.

A licensed customs broker (PPJK) can file declarations on the importer’s behalf under authority, but the obligations stay with the importer. A freight forwarder is not your importer unless it is formally named as one. See Bea Cukai’s import guidance.

Check that the importer fits your goods

API type: an importer that will sell or transfer your goods to others needs an API-U. Goods imported under an API-P may not be traded or transferred, apart from limited exceptions.
Business activities: its registered business activities (KBLI) should cover the goods and the planned trade.
Import licences: it must hold any licence or approval required for the goods (Registered Importer, Import Approval and similar), issued before the goods arrive.
Product permits: for regulated goods, the product permit is often tied to the importer. For example, imported cosmetics are notified by the importer, which also applies for the import certificate for each shipment. Check the same point for BPOM products and medical devices.
Compliance record: it should file the required reports. Missed import realisation reports can lead to its licences being frozen.

The import licensing review checks these points for each HS code.

Put the responsibilities in writing

Agree a written responsibility schedule before the first shipment. It should cover:

Goods and scope: the products, HS codes, quantities and any exclusions.
Commercial flow: who buys from the supplier, who sells to the customer, payment terms and Incoterms.
Permits and documents: the holder of each product permit and import licence, and access to records.
Costs: service fees, duties and taxes, customs-broker fees, storage and extra handling.
Incidents: who decides and acts on inspections, document queries or delays.
Exit: how product permits, records and stock are handled if you change importer.

Changing importer is not only a commercial decision. Permits held by the outgoing importer may need to be transferred or obtained again. For cosmetics, BPOM requires documents covering the change of agency. Settle exit terms with your legal advisers when you first appoint the importer.

How MDM can help

Understand the plan. Review the goods, supplier, customers and any existing Indonesian arrangements.
Map the roles. Identify the proposed importer, customs broker and logistics providers.
Check fit. Review the importer’s NIB, API type, business activities, licences and product permits against the goods.
Agree the scope. Record responsibilities, document owners, costs and decision points.
Coordinate the start. Support communication between the parties as the first shipments are prepared.

What to send

Send the product list and specifications, HS codes if known, origin, expected volumes, delivery terms and the details of any proposed importer or distributor. Include existing product permits and your target dispatch date. This helps separate an importer-selection question from a licensing or logistics problem.

We provide a scoped estimate after reviewing the arrangement. The parties, the goods and the document gaps determine the work involved.

Frequently asked questions

Will MDM itself be the importer?

No. MDM advises on and coordinates the arrangement. The importer is an Indonesian company with the required NIB/API and licences, identified in the agreed scope.

Can my freight forwarder be my importer?

Only if it is formally named as importer and holds the right API type and licences for your goods. Ask which company will appear in the import declaration.

Can a manufacturer’s API-P company import our goods for resale?

Generally no. Goods imported under an API-P are for the importer’s own production and may not be traded or transferred, apart from limited exceptions. Resale needs an API-U importer.

Does an importer arrangement replace product registration?

No. Product permits must still be obtained for regulated goods, and often by or for the importer. Plan both together.

What if we change distributor later?

Review the effect on product permits, import licences, stock and records before agreeing the transition. Not every permit or record transfers automatically.

Import License Indonesia · Cosmetic Registration Indonesia · BPOM Registration Indonesia · SNI Certification Indonesia

Official references

This page summarises the rules as of October 2026. Confirm the requirements for the actual importer and goods before proceeding.

Discuss your importer arrangement

Send your product and shipment plan with the importer or distributor you are considering. We will help confirm the roles and the licences needed.