In international trade, it’s quite common for imported goods to arrive at Indonesian ports—such as Tanjung Priok or Tanjung Perak—before the Persetujuan Impor (PI, or Import Approval) has been issued.

This delay can happen for several reasons: issues in the OSS-RBA (Online Single Submission Risk-Based Approach) system, mismatched HS Codes, or pending technical recommendations from ministries such as the Ministry of Industry (Kemenperin), Ministry of Health (Kemenkes), Ministry of Energy and Mineral Resources (ESDM), or Ministry of Agriculture (Kementan).

This is a serious issue: without a valid PI, the goods cannot be released from the port and may even be ordered for re-export (reekspor) or destruction.

Based on our extensive experience handling import legality and compliance matters, here are the main legal and practical options when your imported goods are detained due to the absence of a Persetujuan Impor (PI).

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A. Moving the Goods to a Bonded Logistics Center (Pusat Logistik Berikat / PLB)

A PLB (Bonded Logistics Center) is a bonded warehouse facility where imported or domestic goods can be stored, managed, or even lightly processed under the supervision of Customs (Bea dan Cukai), without immediate import duty or tax payment.

By moving the goods to a PLB, importers can delay import tax payments while completing the necessary documents such as PI, SNI (Indonesian National Standard certification), BPOM license (food/drug authority), or technical recommendations from relevant ministries.

Transferring goods from the port to a PLB is the most efficient and administratively legal option compared to re-exporting or temporary storage in a bonded zone (Kawasan Berikat / KB).

Key Advantages of Using a PLB:

1. Full legal standing under Customs Law — the goods remain in Indonesian territory but are not yet considered “imported for use.”

2. Deferred import duties — taxes are only paid when goods leave the PLB.

3. No administrative sanctions from the Ministry of Trade while the import permit is being processed.

4. Goods remain safe and under control — no need to ship them abroad (e.g., to Singapore).

5. Lower logistics costs — significantly cheaper than re-export or prolonged port storage (demurrage).

Administrative Steps for PLB Transfer:

• The importer must sign an official cooperation agreement (MoU) with a licensed PLB operator.

• The PLB operator will register the importer as a tenant with the Directorate General of Customs and Excise (DJBC).

• Customs will then issue a formal decree (Surat Keputusan Kepala Kantor Bea dan Cukai) confirming the importer’s PLB status.

Drawbacks and Risks:

1. Warehouse rental and handling costs — PLBs charge for storage and transfer from port to facility.

2. Layered bureaucracy — coordination with both Customs and the PLB operator may take up to two weeks, especially for first-time users.

3. Restricted goods — hazardous materials, pharmaceuticals, and defense equipment require special permits.

4. No domestic sales allowed — goods in a PLB are not legally imported and cannot be sold domestically.

5. Strict reporting obligations — all PLB activities must be periodically reported to Customs.

6. Maximum storage period of three years — after this, goods must be imported, re-exported, or destroyed.

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B. Re-exporting to Singapore (Reekspor ke Singapura)

Re-export means shipping goods that have entered Indonesian customs territory back overseas, often because:

1. Required permits (PI, SNI, BPOM, etc.) are missing;

2. Goods don’t match import documents; or

3. Goods are rejected by the authorities.

This is a preventive administrative action—not a violation—to avoid legal sanctions and storage costs.

Why Singapore Is the Best Re-export Destination:

1. Close and efficient — shipping from Tanjung Priok to Singapore’s PSA or Jurong Port takes about one day.

2. World-class logistics — Singapore offers Free Trade Zones (FTZs) and transshipment hubs ideal for temporary storage.

3. Easy re-import process — once your PI is approved in Indonesia, the goods can be easily shipped back with complete documentation.

4. Legally neutral — re-export to Singapore doesn’t create negative records in Indonesia’s customs system.

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C. Storing in a Bonded Zone (Kawasan Berikat / KB) or Special Economic Zone (Kawasan Ekonomi Khusus / KEK)

A Kawasan Berikat (KB or Bonded Zone) is a special customs area where imported and domestic goods can be stored or processed (assembled, combined, or manufactured) mainly for export purposes, with import duties and taxes suspended.

A Kawasan Ekonomi Khusus (KEK or Special Economic Zone) is an area designated by the Indonesian government to boost specific industries, offering tax incentives, customs facilities, and simplified licensing.

Goods stored in either KB or KEK are not yet considered “imported for domestic use” and remain under Customs supervision.

Benefits of KB or KEK:

1. No legal violation — goods are under customs control and not considered imported.

2. Lower operational costs compared to re-export.

3. Flexible cooperation — importers without their own facility can partner with an existing KB/KEK company.

Drawbacks:

1. Restricted items — hazardous, chemical, or pharmaceutical goods may need special permits.

2. Legal documentation required — a formal MoU or goods custody agreement must be signed to define responsibilities and prevent disputes.

3. CIPL documentation — every inter-zone movement must be accompanied by a Customs Invoice and Packing List (CIPL).

4. Mandatory customs reporting — every activity inside KB/KEK must be reported, and storage is limited to three years.

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Best Practices to Avoid Detained Imports

When your goods are detained due to missing PI, you must act swiftly and within the law. Indonesia offers administrative mechanisms to safeguard your goods legally through:

1. Transfer to a PLB (Bonded Logistics Center);

2. Re-export to Singapore; or

3. Temporary storage in KB (Bonded Zone) or KEK (Special Economic Zone).

All three are legally recognized by the Directorate General of Customs and Excise (DJBC).
However, these are temporary solutions. The best long-term strategy is to ensure all import licensing requirements are completed before shipment.

Recommended Steps:

1. Secure the PI before shipment.
   The PI application process takes time due to system synchronization (OSS-RBA, INATRADE, ministry databases).

2. Verify the HS Code accurately.
   Wrong HS Codes are the top reason for delayed or rejected PIs.

3. Use professional legal and customs consultants.
   Regulations change frequently—expert guidance prevents costly administrative errors.

4. Use PLB/KB/KEK only as a temporary measure.
   They are legal but monitored, with strict time limits. The goal is always to obtain your PI as soon as possible.

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MyLegal Indonesia Services

As a preventive and support partner, MyLegal Indonesia provides:

1. Free HS Code Validation for your imported products.
   We ensure your classification complies with the Ministry of Trade, Ministry of Finance, and Customs regulations.

2. Import Legal & Administrative Consulting.
   Our team has years of experience in import licensing, customs procedures, OSS-RBA compliance, and partnerships with PLB/KB operators.

3. Foreign Investment Assistance (PMA / Penanaman Modal Asing).
   We support both foreign and local investors in establishing companies in Indonesia—covering NIB (Business Identification Number), API (Importer ID), industrial permits, environmental compliance, and import-export licensing.