Minister of Trade Regulation Number 1 of 2026 Tightens Natural Rubber Exports through Producer Identity Number Requirements and Administrative Sanctions

Introduction

On January 14, 2026, the Ministry of Trade issued Regulation of the Minister of Trade Number 1 of 2026 on Technical Specified Natural Rubber for Export ("MoT Regulation 1/2026"), which shall take effect fourteen (14) days after its promulgation, i.e. on January 28, 2026. MoT Regulation 1/2026 governs the export provisions for Technically Specified Natural Rubber (Standard Indonesian Rubber, "SIR") and serves to replace previous regulations regarding said commodity.

The issuance of MoT Regulation 1/2026 is intended to maintain quality and enhance the competitiveness and image of Indonesian natural rubber products in the international market. In its considerations, the Government states that provisions regarding technically specified natural rubber previously governed under Regulation of the Minister of Trade Number 26 of 2021 are no longer consistent with prevailing legal developments and requirements. On this basis, the Government establishes a separate regulation regarding the export of technically specified natural rubber to provide certainty for producers and strengthen export quality control.

Comparison

MoT Regulation 1/2026 repeals the provisions regarding the Producer Identity Number for Technically Specified Natural Rubber previously governed under Regulation of the Minister of Trade Number 26 of 2021 on the Stipulation of Business Activity Standards and Products in the Implementation of Risk-Based Business Licensing in the Trade Sector ("MoT Regulation 26/2021"), as amended by Regulation of the Minister of Trade Number 21 of 2023 ("MoT Regulation 21/2023"). The following is a comparison between MoT Regulation 1/2026 and MoT Regulation 26/2021 as amended by MoT Regulation 21/2023:

Key Provisions

Obligation to Possess SIR TPP and Issuance Requirements

All businesses engaging in SIR exports must hold the status of SIR Producer Exporter and possess an SIR Producer Identity Number (Tanda Pengenal Produsen, "TPP"). Article 4 paragraphs (1) and (2) stipulate that only producers who have complied with SNI 1903:2017 may obtain an SIR TPP. To obtain an SIR TPP, Article 6 and Article 7 require businesses to submit an application electronically through the INATRADE System by attaching:

1. Business Identification Number (Nomor Induk Berusaha/NIB); and

2. Product Certificate for the Use of SNI Mark (SPPT SNI) issued based on SIR compliance with SNI 1903:2017.

If the application is declared complete, the Director issues the SIR TPP within a maximum period of three (3) working days. The SIR TPP is used as a complementary customs document and must be included in the Export Customs Notification.

Amendment and Extension of Producer Identity Number

SIR Producer Exporters must maintain the validity of the SIR TPP. Article 10 paragraph (1) stipulates that exporters must submit an application for amendment electronically in the event of a change in company ownership or data changes, including company name, factory address, or SIR type. Regarding the extension of SIR TPP, Article 11 paragraph (1) sets the submission period as follows:

1. No earlier than 30 (thirty) days before the validity period expires; or

2. No later than seven (7) working days prior to the expiration of the validity period.

Packaging and Marking Standardization

MoT Regulation 1/2026 governs marking standards on export product packaging. Article 20 paragraph (1) mandates that every bale packaging of SIR to be exported must bear markings containing:

1. The SIR symbol containing the SIR TPP code and SIR type;

2. Net weight (SIR net); and

3. Company name of the SIR Producer Exporter.

Details regarding the SIR symbol format and colors are further regulated in Annex Letter C Number 1 letter c, with the following provisions:

1. Green Color: For SIR 3 CV, SIR 3 L, SIR 3 WF, and SIR LoV;

2. Green Color with a Brown horizontal line: For SIR 5;

3. Brown Color: For SIR 10 and SIR 10 CV/VK; and

4. Red Color: For SIR 20 and SIR 20 CV/VK.

Raw Material Quality Control and Supplier Development

MoT Regulation 1/2026 governs raw material quality control from the initial production stage. Article 17 paragraph (2) prohibits the use of processed rubber materials containing vulcanized contaminants (such as foam rubber) or heavy contaminants, and limits light contaminant content to a maximum of 5%. Furthermore, Annex Letter A mandates producers to conduct visual inspections of raw materials to ensure that raw materials:

1. Contain a Dry Rubber Content (Kadar Karet Kering/KKK) of at least 45% for coagulum and 25% for field latex;

2. Use recommended coagulants (such as formic acid or liquid smoke); and

3. Do not use coagulants that damage quality, such as: sulfuric acid, alum, fertilizer (TSP), pineapple, or wild yam/gadung.

Article 19 obliges SIR Producer Exporters to conduct periodic education and evaluation for raw material suppliers. Evidence of such education implementation becomes part of the audit examined by the Conformity Assessment Body (Lembaga Penilaian Kesesuaian, “LPK”) as governed under Article 24 paragraph (2).

Provisions on Special Areas and Emergency Procedures

The SIR TPP obligation applies nationally, including for the removal of goods from Free Trade Zones and Free Ports (KPBPB), Special Economic Zones (KEK), and Bonded Storage Places (TPB) to areas outside the Customs Area, with the following provisions:

1. Issuing Authority: Article 12 stipulates that the SIR TPP is issued by the Head of the Concession Body for KPBPB, the Head of the KEK Administrator for KEK, or the Director for TPB; and

2. Manual Procedure: In the event of a disruption to the INATRADE system or the Indonesia National Single Window (SINSW) System, Article 31 governs the use of manual procedures with an SIR TPP issuance period of no later than 7 (seven) working days.

Administrative Sanctions: TPP Revocation

Article 27 stipulates that SIR Producer Exporters may be subject to administrative sanctions in the form of SIR TPP revocation if they:

1. Commit violations in the customs sector regarding SIR exports based on information from the Directorate General of Customs and Excise that has been verified by the Director General (Ministry of Trade); and/or

2. Are declared guilty based on a court decision with permanent legal force for the criminal act of misusing SIR TPP documents.

In addition to sanctions for exporters, LPKs may be subject to sanctions ranging from written warnings to revocation of registration if they are negligent in reporting or auditing as governed under Articles 25, 26, and 28.

Transitional Provisions

Article 36 letter a stipulates that SIR TPPs issued based on MoT Regulation 26/2021 remain valid until the expiration of their validity period. Furthermore, Article 36 letter b stipulates that regarding such SIR TPPs, businesses may submit amendments or extensions by following the provisions in MoT Regulation 1/2026.

Conclusion

MoT Regulation 1/2026 establishes new regulations on the export of technically specified natural rubber by clarifying the obligations of SIR Producer Exporters, which include compliance with raw material quality standards, packaging marking, and Producer Identity Number management. Through this regulation, quality control focuses not only on the final product but also on raw materials and supplier relationships, including prohibitions on certain contaminants and coagulants, as well as mandatory education and evaluation of suppliers as part of the certification audit process. On the administrative side, this regulation affirms the obligation to submit SIR TPP amendments and extensions in accordance with the specified timeframes, as well as the use of SIR TPP as a complementary customs document in export activities. Non-compliance with these provisions, including violations in the customs sector or misuse of SIR TPP documents, may be subject to administrative sanctions in the form of SIR TPP revocation, which directly impacts the sustainability of natural rubber export activities.