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In brief

On behalf importation, locally known as “under-name importation”  or “QQ” importation, has been used by companies for more than a decade, ever since the Directorate General of Customs and Excise (“Customs“) first allowed the name of the owner of goods to be included in the import declaration form (“PIB“).

Under Indonesia’s Customs Law, the importer of record is the party that is subject to an audit or a re-examination (Penelitian Ulang), and there is no audit or re-examination of the owner of goods in a PIB using under-name importation.

However, in mid-August this year, the Minister of Finance (MoF) issued Regulation No. 78 of 2023 on Re-examination in the Field of Customs (“MoF Regulation No. 78/2023“), which will come into force on 21 October this year. One of the objects of re-examination is the owner of goods.

In more detail

Practice of under-name imports

In certain circumstances, companies carry out under-name importation because they do not yet have the required licenses (such as basic import/business licenses or additional import licenses) to import goods into Indonesia. Typically, these companies are companies that need to import goods during their establishment stage or companies that do not have sufficient import quotas.

In these cases, an import agent, as a service provider, is stated as the importer of record, while the beneficial owner of the goods is stated as the owner of the goods (Pemilik Barang) in the PIB, as shown below:


So in the PIB, there are two different columns for the importer of record and for the owner of goods when an importer of record acts as the importer ‘on behalf’ of the owner of goods

New provisions and implications for companies

Customs is authorized to carry out an examination of every importer and exporter within 30 days to two years after the date of the PIB and export declaration form (PEB) − in the form of an audit or a re-examination.

However, the MoF introduced a new provision on the re-examination procedure in MoF Regulation No. 78/2023. Customs will request data or documents, verbal or written information, and samples of goods from the owner of the goods through the importer stated in the PIB or the exporter stated in the PEB. If the importer, exporter or owner of goods cannot satisfy the request, Customs can issue a warning letter, and eventually can suspend import and/or export services if the parties do not comply with the warning letter.  

With the new provision, companies that are beneficial owners of the goods will also be ‘exposed’ to Customs scrutiny.

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Irvan is an Associate Partner in the Tax & Customs Practice Group at HHP Law Firm, a member firm of Baker & McKenzie International. He is a customs specialist. Before he joined HHP, he worked in the Directorate General of Customs and Excise ("Customs") as a Customs Auditor for 12 years, and he worked for the tax division of a big four public accounting firm for 11 years. He is adept in providing various types of customs advice, customs audit assistance, and customs dispute assistance in various industries, including in areas such as information and communication technology, electronics and mobile phones, energy & mining, automotive, plantation (palm and its derivatives, cocoa) and other consumer products.


Nandina Kusumaningrum is a Trade Specialist in Hadiputranto, Hadinoto & Partners, Jakarta office.

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