Importer of Record Indonesia: Who Can Sign the Import?
Who can be the importer of record in Indonesia when you sell from Singapore or Malaysia? An Indonesian company whose business identification number (NIB) is valid as an importer identification number (API). Under Indonesia's current import rule, Permendag 16/2025, an importer must hold that NIB. The importer, or a customs broker it appoints, then lodges the declaration.
That one rule decides how you can price the deal. If your buyer asks for DDP or "door to door", someone in Indonesia still has to sign the import. If your company is not registered in Indonesia, that someone cannot be you.
This guide sets out who signs, which licence type fits which buyer, and the six questions to ask before you agree terms. IFG is a forwarder whose listed services include cross-border work into Indonesia. It does not act as importer of record for anyone, so nothing below is a pitch for that service.
Key points before you quote
Whoever signs an Indonesian import of business goods needs an NIB that works as an API (Permendag 16/2025, Article 3(1)).
The current rule is Permendag 16/2025, in force since 29 August 2025. It revoked Permendag 36/2023, which some guides still cite.
Each importer holds one type: API-U to trade goods, or API-P to use them in its own production.
An API-P buyer that resells certain imported goods breaches the rule, outside a short list of exceptions.
The importer files the declaration itself, or authorises a customs broker (PPJK) to do it.
Who is the importer of record on an Indonesian import?
The importer of record is the party named on the import declaration and answerable for it. Indonesian customs rules say who that is in plain terms. Under the Finance Minister's regulation on customs declarations, PMK 155/PMK.04/2008 as consolidated on 25 March 2024, the declaration for imported goods is made and submitted by the importer (Article 6(2)).
The Ministry of Trade then sets who may be an importer for business goods. Permendag 16/2025, Article 3(1), says the importer must hold an NIB that is valid as an API. The NIB itself is the business identity issued by Indonesia's Online Single Submission (OSS) system once a business registers, according to PMK 219/PMK.04/2019.
Put the two together and the answer for a seller is short. The importer of record is an Indonesian business with an NIB valid as an API. A Singapore or Malaysia company with no business registered in Indonesia has no NIB. Your buyer, or another Indonesian company your buyer chooses, signs the import.
This is the part to settle first. You can arrange the freight, the export papers and even the delivery truck. You still cannot be the name on the Indonesian declaration.
What does "NIB valid as an API" mean?
The importer identification number now travels inside the NIB. Permendag 16/2025 defines the API as the identification of an importer, and requires the NIB to be valid as one. The same NIB also opens the customs side. Under PMK 219/PMK.04/2019, Article 5, a business whose NIB is valid as a company registration, an API and customs access is treated as registered with customs as an importer or exporter.
Two details matter when you check a buyer:
Head office only. An NIB valid as an API can only be held by the head office of the business. Branches with the same type of business may use the head office's API (Permendag 16/2025, Article 3(4) and 3(5)). A branch name on your invoice that does not match the API holder is a mismatch worth fixing before shipment.
The current rule. Permendag 16/2025 came into force on 29 August 2025 and revoked Permendag 36/2023, with all its amendments (BPK legal database). It has since been amended by Permendag 37/2025 (same database). If a guide or a buyer still quotes Permendag 36/2023, the source is out of date, even where the idea it describes carried over.
API-U vs API-P: which one does your buyer need?
Permendag 16/2025 lets an importer choose one of two types, never both (Article 3(3)). Which one your buyer holds tells you what it may do with your goods.
Type | Who gets it | What it allows | Source |
API-U (general) | A business importing to trade | Import goods to sell or transfer to others | Permendag 16/2025, Article 7(1) |
API-P (producer) | A business importing for its own use | Import capital goods, raw materials, auxiliary materials and production inputs for its own use | Permendag 16/2025, Article 7(2) |
The trap sits in the second row. A factory buyer holding API-P may take your machine parts or raw materials. If it plans to resell part of the shipment to a distributor, that is a breach. Under Article 79(1)(b), an API-P holder that trades or transfers certain imported goods to another party is in breach, apart from listed exceptions such as leftover raw materials and capital goods used for at least two years. Under Articles 79 and 80, the first sanction is a written warning; after a warning, further breaches can lead to the buyer's import business licences being frozen.
So the useful question is not only "do you have an import licence?". It is "which type, and what will you do with the goods?". Ask it early, before the price is fixed.
Can you ship DDP to Indonesia?
DDP, Delivered Duty Paid, puts the import clearance, the duty and any destination tax on the seller, as our DDP explained guide sets out. In Indonesia that collides with the rules above. The import still needs an Indonesian importer holding an NIB valid as an API. A seller without an Indonesian business cannot fill that role. So a "DDP" deal into Indonesia only works when someone else in Indonesia is the importer, and you then pay costs on a declaration you do not control. For most first orders, the cleaner choice is a term where your buyer handles import clearance; the DDP guide compares DDP with DAP.
The pre-quote importer check: six questions
We traced the questions a seller should ask an Indonesian buyer to the article of the current rule that answers each one. Ask them before you send a price, not after the goods are at sea.
# | Ask the buyer | What the rule says | Source | If it does not check out |
1 | Which company will be named as importer on the Indonesian declaration? | The importer makes and submits the import declaration | PMK 155/PMK.04/2008, Art. 6(2) | Nobody is in a position to lodge it |
2 | Does that company hold an NIB valid as an API? | An importer must hold one for business imports | Permendag 16/2025, Art. 3(1) | The goods cannot be imported for business use |
3 | Is it API-U or API-P? | One type only: trade, or own production use | Permendag 16/2025, Art. 3(3), 7(1)–(2) | The licence does not fit the goods' purpose |
4 | Will any of the goods be resold? | An API-P holder may not trade or transfer them, with listed exceptions | Permendag 16/2025, Art. 79(1)(b) | Sanctions on the buyer; your next order at risk |
5 | Is the NIB held by the head office? | Only the head office holds it; same-business branches may use it | Permendag 16/2025, Art. 3(4)–(5) | Branch name on papers does not match the API |
6 | Who files: the importer itself, or a customs broker (PPJK) it appoints? | If it does not file itself, it authorises a PPJK | PMK 155/PMK.04/2008, Art. 7 | Your documents go to a party nobody has authorised |
Write the answers down and put the importer's name and NIB on your commercial invoice and packing list, so the papers agree with the declaration. Our guide to shipping from Singapore to Indonesia covers the full document set for that route.
What if your buyer has no import licence?
Then the buyer cannot be the importer for business goods, and you have three honest options.
The buyer gets the licence first. An Indonesian business can register through OSS and choose its API type. That is the buyer's job, not yours, and it should be done before the order ships.
Another Indonesian company imports. A licensed trading company holding API-U may import the goods and resell them to your buyer. This is a commercial arrangement your buyer chooses and pays for. Check that the importer named on the declaration is the same company named on your invoice. IFG does not offer this service.
The shipment is not business stock at all. Permendag 16/2025, Article 42, lets importers without an API bring in goods not used for business, such as personal parcels, passengers' own goods and household removals. A domestic helper's own clothes sent home are the kind of shipment that article has in mind. Ten cartons for resale do not, because Article 42 covers imports that are not for business.
If your buyer cannot say which of these applies, wait. Without a valid importer, business goods cannot be imported under Article 3(1). Our guide to cargo held at Indonesian customs covers what happens when cargo is held.
What to agree and collect before the goods move
Agree the Incoterm with the buyer as the importer, unless you have a named Indonesian importer for a DDP deal.
Get the importer's legal name, NIB and API type in writing, from the head office.
Confirm the goods' purpose matches the API type (trade for API-U, own production for API-P).
Ask who files the declaration, and the customs broker's name if one is appointed.
Put the same importer details on the invoice and packing list.
Ask the importer's broker whether the goods need product permits before shipment; our cargo-held guide lists the common ones.
Shipping from Malaysia rather than Singapore? The importer rules are the same on the Indonesian side. The route detail is in our guide to Malaysia to Indonesia sea freight.
Send the shipment details to IFG
With the importer's name and API type confirmed, tell IFG about the shipment: pickup address, Indonesian destination, the goods and HS code if you have it, number of packages, weight and dimensions, ready date, the Incoterm, and the name of the Indonesian importer. The IFG services page covers road freight across Singapore, Malaysia, Thailand and Indonesia, customs clearance work, and delivery to the door. Send it on WhatsApp or email IFG, or use the contact page. You get a reply on how the route would run and which papers are still missing. IFG is not an importer of record for clients, and no forwarder can promise what customs will decide.
Importer of record Indonesia: common questions
Can a Singapore company be the importer of record in Indonesia?
Not without an Indonesian business. Permendag 16/2025 requires the importer of business goods to hold an NIB valid as an API, and the NIB is issued by Indonesia's OSS system to a business that registers there. A Singapore or Malaysia company with no Indonesian registration holds no NIB, so an Indonesian company has to be the importer on the declaration.
Does my buyer still need an API, or is the NIB enough?
Both, in one number. Under Permendag 16/2025 the importer must hold an NIB that is valid as an API, and must choose API-U or API-P. Ask your buyer which type its NIB carries, because the type decides whether it may resell your goods or only use them in its own production.
Who files the Indonesian import declaration?
The importer. PMK 155/PMK.04/2008 places the import declaration on the importer, who prepares and lodges it. If the importer does not file it itself, it authorises a customs broker, known as a PPJK. As the seller, you supply matching documents; you do not lodge the declaration.
This guide describes Indonesian rules as published on the dates cited. It is not legal advice. Rules change, so confirm the current position with your buyer, its customs broker or the authority named before you act.
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