Indonesia's Ministry of Finance recently issued Regulation No. 52 of 2026, specifically governing the temporary import/export procedures for reusable returnable packaging. Signed by the Minister of Finance on July 15, 2026, and officially published on July 31, the regulation will take effect 60 days after publication, i.e., at the end of September 2026. It replaces the vague and incomplete provisions of the 2017 and 2021 regulations that did not specifically cover reusable packaging, providing cross-border logistics companies with clear, unified, and standardized customs compliance guidelines. The scope of the new regulation covers packaging carriers that are repeatedly used in cross-border supply chains and are not single-use consumables, including drums, pallets, specialized returnable containers, and transport racks. Standard maritime shipping containers are excluded from the scope of this regulation.
The regulation categorizes returnable packaging into two types: foreign returnable packaging entering Indonesia (RPLN) and domestic returnable packaging leaving Indonesia (RPDN). Compliant packaging must meet three conditions: no loss of form or function, no substantial deformation, and continuous identifiability. The new policy introduces major fiscal incentives, significantly reducing cross-border turnover costs for businesses. Compliant returnable packaging enjoys three major benefits: exemption from import duties, exemption from VAT and luxury goods tax, and exemption from import income tax (PPh Article 22). Differing from general temporary import/export policies, companies using this mechanism are not required to pay a customs deposit, greatly simplifying capital flow processes. The regulation specifies two categories of eligible entities: licensed entities may use the packaging for import/export cargo packaging and transport, while third-party companies may only use it for export operations.
All processes are submitted electronically through the customs online system, with customs completing approval within a maximum of 5 working days. The validity period of the qualification is up to one year and is renewable. Licensed companies must submit quarterly usage data reports and maintain standardized ledger management. In addition, foreign returnable packaging entering Indonesia is limited to a maximum stay of three years, after which it must be re-exported. Overdue packaging may be granted an additional 30-day extension, and exceeding the deadline will incur a fine of 100% of the customs duties. The regulation also specifies liability exemptions and penalty mechanisms: packaging damaged due to force majeure such as natural disasters or accidents may be fully exempt from taxes and fines; in cases of willful damage or loss, back taxes and fines must be paid. Violations such as unauthorized diversion of use, continuous failure to report, or customs-related criminal offenses will result in revocation of qualification, with a 12-month prohibition on reapplication. A 6-month transition period is also provided to ensure smooth compliance transition for existing companies.
