Trade Regulation 15/2026 Sets Transition for Coal Exports via State-Owned Enterprise

The Ministry of Trade has issued Minister of Trade Regulation Number 15 of 2026, which governs the phased implementation of coal exports through a state-owned enterprise appointed as the sole exporter. Director of Industrial and Mining Product Exports at the Ministry’s Directorate of Foreign Trade, Muhammad Rivai Abbas, stated that the principal spirit of the regulation is to ensure that exports of the strategic commodity coal can only be carried out through a state-owned export enterprise. However, during an online dissemination event on Tuesday, he noted that the implementation would be carried out in stages through a transition period until the end of 2026. ‘Initially, the spirit was that exports of the strategic commodity coal can only be carried out by a government exporter. Nevertheless, adjustments are certainly needed in the process, in this case a gradual transition,’ Rivai said. Rivai explained that the transition period runs from 1 June to 31 December 2026. During this period, export activities may still be conducted by business actors who already possess a business licence and registered exporter status for coal, although they are required to submit reports to the SOE exporter appointed by the government. Throughout the transition period, the entire export process will continue to use registered exporter documents and surveyor reports under the names of the previously operating business actors. Furthermore, exporters are obliged to submit export documents, sales contracts, and other necessary data to the SOE exporter through an integrated system. The commodities regulated in the policy encompass eight tariff headings, consisting of four sub-headings derived from HS 2701, two from HS 2702, and two from HS 2703. All remain subject to prohibition and restriction provisions in the form of mandatory registered exporter status and surveyor reports. ‘During this period, an evaluation of the implementation or governance of the existing exports will be conducted within three months,’ he said. Starting 1 January 2027, coal exports may only be conducted by the government-appointed SOE exporter, namely PT Danantara Sumberdaya Indonesia. At this stage, the entire export process, from pre-customs and customs clearance to post-clearance, will be executed by PT DSI. Nonetheless, the SOE exporter is still required to hold a coal registered exporter status and a surveyor report as complementary customs documents. To obtain registered exporter status, DSI must possess a special mining business licence for operation and production specifically for transportation and sales, or a transportation and sales permit, and fulfil several other administrative requirements. Regulation 15/2026 also stipulates several exemptions to the mandatory coal registered exporter status and surveyor report requirements. These exemptions apply to goods not intended for commercial activities, such as those for research and development purposes, sample goods for exhibitions, and re-exported goods that do not conform to specifications or have not been fully consumed. Exemptions are also granted to business actors whose products are not coal but share the same harmonised system code as the coal commodities whose exports are restricted. Similar provisions apply to coal registered exporter status holders whose business licences have expired but who still hold production stock from when the licence was valid. Rivai added that exporters remain obligated to submit electronic export realisation reports to the Minister of Trade, covering both realised and unrealised exports. Violations of this reporting obligation will incur administrative sanctions in accordance with prevailing regulations. He confirmed that coal registered exporter licences issued prior to the enactment of Regulation 15/2026 shall remain valid until 31 December 2026, or in accordance with the validity period of the business licence if it expires sooner.