Introduction

On December 12, 2025, the Minister of Trade issued Minister of Trade Regulation Number 43 of 2025 on Packaged Palm Cooking Oil and Governance of People’s Cooking Oil (“MOT Regulation 43/2025”). MOT Regulation 43/2025 takes effect 14 (fourteen) days after issuance, i.e. on December 26, 2025. MOT Regulation 43/2025 reorganizes the palm cooking oil trade system by clarifying the scope of government oversight over production, packaging, and distribution. MOT Regulation 43/2025 establishes obligations for all businesses in the supply chain, from producers to retailers, to ensure the equitable, high-quality, and affordable availability of People’s Cooking Oil (Minyak Goreng Rakyat or “MGR”).

MOT Regulation 43/2025 improves inefficient cooking oil distribution, prevent scarcity, and replace Minister of Trade Regulation Number 18 of 2024 on Packaged Palm Cooking Oil and Governance of People’s Cooking Oil (“MOT Regulation 18/2024”) which was deemed no longer relevant. MOT Regulation 43/2025 mandates producers to collaborate with State-Owned Enterprises (“SOEs”) and introduces administrative sanctions enforced through a digital system to ensure business compliance.

Comparison

The following is a comparison between MOT Regulation 43/2025 and MOT Regulation 18/2024:

Key Provisions

35% Supply Obligation to BULOG and Food SOEs

The Government mandates cooking oil producers to distribute a minimum of 35% of their Domestic Market Obligation (“DMO”) fulfillment through Perum BULOG and/or food-related SOEs. Producers may no longer freely select distribution partners. Perum BULOG and Food SOEs must report the realization of this distribution to the Minister by no later than the 10th of the following month.

Licensing Requirements and Specific KBLI

MOT Regulation 43/2025 regulates administrative requirements for Businesses participating in the MGR program and utilizing the “MINYAKITA” brand. Business entities must possess a Business Identification Number (NIB) with the Indonesian Standard Industrial Classification (KBLI), as follows:

1. Producers: Required to hold KBLI 10437 (Palm Cooking Oil Industry) and a valid business license.

2. Packers: Required to hold KBLI 82920 (Packaging Services) and 46315 (Wholesale of Vegetable Oil and Fat), or KBLI 10437 (Palm Cooking Oil Industry).

Supply Chain Governance and Partner Validation

Distribution is conducted in stages with the following flow:

1. Produsen to Line 1 Distributor (D1)

2. Line 1 Distributor (D1) to Line 2 Distributor (D2)

3. Line 2 Distributor (D2) to Retailer

4. Retailer to Consumer

Liability provisions:

1. Every businesses must ensure the legality of its trading partners.

2. Producers verify D1 permits; D1 verifies D2 permits, and so forth.

3. Distributors are required to prioritize supply to Retailers in people's markets monitored by the government (SP2KP) before serving other markets.

Retailer Obligations and Price Control

The Government regulates sales at the retail level to protect consumers. Retailers have three main obligations:

1. To sell MGR at a price below or equal to the Highest Retail Price (HET).

2. To comply with sales quantity restrictions (rationing) established by the Director General.

3. To display information regarding HET that is easily visible to consumers at the place of business.

Production Standardization and MINYAKITA Brand

Producers and Packers are required to apply for Approval to Use the MINYAKITA Brand through the INATRADE system, which is valid for 4 years. The use of this brand is restricted as follows:

1. Businesses are prohibited from using the MINYAKITA brand other than for the implementation of the MGR Program.

2. Packaging must be in the form of a pillow pack, standing pouch, bottle, or jerry can with a locked volume size (500 ml, 1 liter, 2 liter, and/or 5 liter).

3. Every package must include the MINYAKITA logo and HET information.

Administrative Sanctions Based on SIMIRAH Account

MOT Regulation 43/2025 establishes sanctions based on a digital system for Businesses. Violations of distribution, reporting, or pricing obligations will be subject to tiered sanctions:

1. Written Warning: Issued a maximum of 2 times.

2. Severe Administrative Action: If warnings are ignored, sanctions escalate to temporary suspension of activities up to a recommendation to freeze the account on SIMIRAH. As an account on SIMIRAH is mandatory for distribution activities, the freezing of such account effectively halts the company’s entire participation in the subsidized cooking oil trade.

3. Export Sanctions: Producers in violation may be subject to suspension or freezing of export approvals.
   

Transitional Provisions

Producers must adjust their supply chains to fulfill the 35% distribution obligation through Perum BULOG and/or Food SOEs by no later than 30 (thirty) days after this regulation comes into force, namely on January 24, 2026. Approvals to Use the MINYAKITA Brand issued based on MOT Regulation 18/2024 remain valid until their expiration. For license applications still in process when this regulation is promulgated, the applicant is required to update administrative documents in accordance with the new requirements.

Closing

MOT Regulation 43/2025 restructures the palm cooking oil trade system by mandating compliance with digital administrative requirements and enforced collaboration with SOEs. Key obligations of businesses include: (i) fulfillment of the minimum 35% DMO distribution obligation through Public Corporation BULOG and/or Food SOEs; (ii) ownership and suitability of business licensing and specific KBLI in accordance with their role in the supply chain; (iii) tiered verification of trading partner legality; (iv) compliance with price controls, sales restrictions, and information obligations at the retail level; and (v) the restricted use of the MINYAKITA brand in accordance with established packaging standards. Non-compliance with these obligations poses a direct risk of SIMIRAH account freezing, which effectively halts subsidized cooking oil distribution activities.

MOT Regulation 43/2025 mandates Producers to adjust supply chain structures and distribution contracts to fulfill the distribution scheme through BULOG/Food SOEs by no later than 30 days after the regulation comes into force. Meanwhile, approvals to use the MINYAKITA brand issued under the previous regulation remain valid until their expiration; however, any applications still in process must be adjusted to the new regime.