Indonesia Import Guide › Importer of record
Last updated: 6 November 2026
Short answer: In Indonesia, the importer of record is the Indonesian company named as the importer on the customs declaration. It must hold a business identification number (NIB) with import rights, it pays the import duties and taxes, and it is responsible for the permits and product registrations the goods need. A foreign company without an Indonesian entity cannot play this role itself.
What does "importer of record" mean in Indonesia?
Indonesian customs law places the duty liability on the importer. Under Article 30(1) of Law 17/2006, which amends the Customs Law, the importer is liable for import duty from the date of the customs declaration. Permendag 16/2025 requires every importer to hold an NIB that serves as its importer identification number (API). A customs broker (PPJK) may file declarations on the importer's behalf, but the liability for duties stays with the importer.
When the importer and the owner of the goods are different companies, Customs can request data from the owner through the importer (PMK 78/2023). Clear contracts, invoices and payment records protect both sides.
In practice, the importer of record is the company that:
- files the import declaration (PIB) and pays import duty, VAT and income tax article 22 on imports;
- holds or uses the import permits the HS code requires, such as an import approval (Persetujuan Impor) for restricted goods;
- is accountable to customs if the goods, documents or values are wrong.
Can a foreign company be the importer of record in Indonesia?
In practice, no. The importer must hold an Indonesian NIB issued through the OSS system, which a company without an Indonesian entity cannot obtain, and a representative office cannot buy and sell goods. That is why foreign brands use one of the three routes below.
What are your options as a foreign brand?
| Route | Who is the importer of record | Good fit when | Things to weigh |
|---|---|---|---|
| Set up your own company (PT PMA) | Your Indonesian subsidiary | You plan long-term, high-volume sales and want full control | Setup time and cost. Under BKPM Regulation 5/2025 the minimum paid-up capital is IDR 2.5 billion, and your company takes on all licences and reporting |
| Appoint a local distributor | The distributor | You want a partner who also sells and stocks your products | The distributor often holds your product registrations; agree in writing what happens if the partnership ends |
| Work with an import procurement partner | The partner's Indonesian company, acting officially as importer | You want to test the market or sell through your own channels before setting up a company | Check the partner's licences, how permits and registrations are held, and who owns them |
Who holds product registrations such as BPOM, SNI and halal?
BPOM registrations and notifications are filed by an Indonesian business with an NIB, usually the importer or distributor, backed by an appointment or contract from the brand owner. Goods under mandatory SNI need an SNI certificate and an NPB registration by the importer. Because a local company holds these registrations, agree in writing who holds each one, who pays for it, and what happens to it if you change partners. See import licence and registrations.
How AsiaCommerce helps as an official import procurement partner
AsiaCommerce is a cross-border company operating in China, Indonesia, Malaysia and the Philippines. For brands bringing goods into Indonesia, our team:
- checks the regulations for your products and handles the required legal requirements, such as BPOM, SNI, postel, medical device, PKRT, quarantine or import quotas;
- calculates all costs transparently before the shipment is processed;
- checks goods at our shipping warehouse before they leave for Indonesia and helps with returns to the supplier when needed;
- pays suppliers in their own currency, such as RMB or USD;
- imports goods officially and settles import taxes according to Indonesian rules.
Some categories have their own limits. For example, fabric and raw iron materials are currently outside our scope.
Frequently asked questions
Is the importer of record the same as the product registration holder?
Not necessarily. The importer of record files the customs declaration and pays duties and taxes. The registration holder is the Indonesian company named on the BPOM, SNI or other registration. They are often the same company, but they can differ, so check both before you ship.
Who pays the import duties and taxes?
The importer of record pays them when the goods are cleared. The cost can be passed on to you through your agreement with the importer. See Indonesia import duties and taxes.
Can I switch to my own company later?
Yes. Many brands start with a distributor or an import partner and set up a PT PMA later. Plan the switch early, because registrations held by a partner may need to be applied for again in your own company's name.
Planning to bring your products into Indonesia?
Tell us what you sell and where it ships from. We will check the import requirements and give you a clear upfront quote.
Market entry solutionImport procurement solutionSources
- Law 17/2006 amending the Customs Law (JDIH Kemenkeu)
- Permendag 16/2025 on import policy and arrangements (full text)
- DDTC: using a customs broker (PPJK)
- Baker McKenzie / Global Compliance News: PMK 78/2023 and importer–owner data
- ASEAN Briefing: when an Indonesian sales operation requires a local company (Sep 2026)
- A&O Shearman: BKPM Regulation 5/2025
- USDA FAIRS Country Report Indonesia (Feb 2026): BPOM food registration
- SIP Law Firm: importing cosmetics into Indonesia
- SIP Law Firm: SNI certification
This guide is general information, not legal advice. Rules change; check the requirements for your specific HS code before shipping.