A. Background: Strategic Regulation of Iron and Steel Imports

Iron and steel are categorized as critical industrial goods in Indonesia. As such, their importation is subject to strict controls, especially due to:

• Risks of over-supply and market dumping,
• Domestic production protection,
• National infrastructure priorities.

In response, the government issued Regulation of the Minister of Trade (“Permendag”) No. 22 of 2025, which regulates the import of certain industrial goods, including iron and steel, through an administrative approval mechanism involving:

• Import Approval (PI),
• Surveyor Report (LS), and
• Online submissions through INSW and SIINAS.

B. Types of Eligible Importers Based on API Classification

In Indonesia, companies must hold an Import Identification Number (API) to legally import goods. The API type reflects the company’s business nature and legal purpose for import.

1. API-P (Producer Importer – Industrial)

Designated for manufacturing companies importing raw materials or auxiliary components solely for internal production. To qualify, the company must:

• Hold a valid Industrial Business License (IUI)
• Be registered under a KBLI (Indonesian Business Field Code) that starts with “241xx”, and already activated in the OSS system,
• Submit regular reports via SIINAS related to production capacity and material usage.

This category aligns with national industrial policy and is prioritized for PI issuance.

2. API-P Non-Industrial (Contractors / EPC Companies)

This applies to construction firms or EPC (Engineering, Procurement, Construction) companies importing goods for specific project execution. To qualify, the company must:

• Provide a valid project contract or Letter of Award,
• Possess an active Sertifikat Badan Usaha (SBU) corresponding to their sector (construction, electrical, mechanical, etc.),
• Clearly demonstrate that the imported items are necessary for the awarded project.

Approval is conditional and depends on the relevance of the materials to the declared project.

3.    API-U (General Importer – Trader/Distributor)

For companies importing goods for resale or distribution. As traders do not use goods internally or in projects, they face stricter compliance:

• Must submit a Purchase Order (PO) from the end user,
• Provide supporting documents showing downstream industrial use.

This is the most restricted category, as it poses the highest risk of speculative or uncontrolled importation.

Legal Compliance Table: Who Has Easier Access?

Conclusion

Permendag 22/2025 is more than a procedural regulation—it’s a filter designed to ensure that only legitimate, verifiable importers participate in the flow of strategic commodities like iron and steel.

Whether you’re a factory, project implementer, or distributor, you must match the legal documentation with your declared business function to stay compliant and competitive.