New Regulation On Import Identification Numbers

On September 2015, the Minister of Trade ("MOT") issued MOT Regulation No. 70/M-DAG/PER/9/2015 on Import Identification Numbers ("API") ("MOT Reg 70/2015"). MOT Reg 70/2015 came into effect on 1 January 2016 and revoked the previous API regulation: MOT Regulation No. 27/M-DAG/PER/5/2012 as lastly amended by MOT Regulation No. 84/M-DAG/PER/5/2012 ("Previous Regulation").

Under the Previous Regulation, the following restrictions applied to holders of General APIs ("API-U") and Producer APIs ("API-P"):

1. API-Us could only be issued to companies for importing goods from only 1 (one) section of the Goods Classification System (Sistem Klasifikasi Barang) attached to the Previous Regulation. To import goods from more than 1 (one) section, a company had to have a special relationship (based on, among other things, share ownership, their Articles of Association, a distributorship agreement etc.) with the overseas supplier, or the company's capital had to be wholly or