Indonesia Repeals Fish and Fishery Products Export Registration Decree

Indonesia has formally repealed its export registration decree for fish and fishery products, rendering all related regulatory notifications null and void due to the repeal effective May 5, 2026

Compliance Answer: Impact of Indonesia’s Repeal of Export Registration Decree for Fish and Fishery Products

Direct Answer

Effective May 5, 2026, Indonesia’s repeal of its export registration decree for fish and fishery products nullifies all prior regulatory notifications tied to that system. However, import requirements for fish and fishery products entering Indonesia remain unchanged under existing laws, including registration of foreign establishments, traceability, HACCP compliance, and quarantine controls^{1, 2, 3}. The repeal specifically eliminates the export-side registration mandate but does not affect import-side obligations.

Regulation Analysis

1. Current Import Requirements for Fish and Fishery Products (Post-Repeal)

Despite the repeal of the export registration decree, Indonesia’s import requirements for fish and fishery products are governed by the following regulations:

Key Obligations for Exporters/Importers:

• Establishment Registration: Foreign aquaculture/processing plants/fishing vessels must be registered with IQA via their competent authority (e.g., submitting Format 2/3 questionnaires, HACCP plans, and facility profiles)^{4, 2}.
• Traceability: Exporters must maintain records from production to export, including:
  • Production stage: Species, origin, health status¹.
  • Transportation: Logs of temperature, handling, and biosecurity measures¹.
  • Exportation: Health certificates, quarantine inspection results^{1, 3}.
• HACCP/Hygiene Compliance: Processing plants/fishing vessels must implement HACCP systems and biosecurity principles (e.g., disease monitoring, sanitation)^{1, 2}.
• Record-Keeping: Establishments must retain records for audits by IQA, including:
  • Production logs (e.g., feed sources, water quality)¹.
  • Processing records (e.g., temperature controls, sanitation)¹.
  • Transportation logs (e.g., vessel sanitation, temperature monitoring)¹.

2. Impact of the Repeal on Export Registration

• Nullified Decree: The repeal eliminates the requirement for foreign exporters to register with Indonesia prior to export (e.g., no pre-export notification or approval process).
• No Change to Import Requirements: The repeal does not affect Indonesia’s import-side controls, including:
  • Establishment registration (foreign plants/vessels must still be registered with IQA)^{4, 2}.
  • Quarantine inspections (all shipments must comply with IQA Decision No. 677/2025)³.
  • Health certificates (must accompany all imports)^{1, 3}.
  • Traceability and record-keeping (exporters must still document production/transportation)¹.

3. Traceability and Record-Keeping Mechanisms

A. Traceability Requirements

Exporters must ensure end-to-end traceability for fish/fishery products, covering:

1. Production Stage:
   • Aquaculture: Records of species, origin, health status, feed sources, and water quality¹.
   • Wild Catch: Fishing vessel logs (e.g., catch location, date, species)¹.
2. Processing Stage:
   • HACCP plans (critical control points, monitoring records)^{1, 2}.
   • Sanitation logs (cleaning, pest control, employee hygiene)¹.
3. Transportation Stage:
   • Temperature logs (for frozen/chilled products)¹.
   • Biosecurity measures (e.g., vessel sanitation, disease prevention)¹.
4. Exportation Stage:
   • Health certificates (issued by competent authority of exporting country)^{1, 3}.
   • Quarantine inspection results (IQA clearance)³.

B. Record-Keeping by Establishments

• Frequency of Audits: IQA conducts annual inspections/audits of registered establishments (or more frequently if risks are identified)².
• Follow-Up Actions:
  • Non-compliance: IQA may suspend/revoke registration or require corrective action plans².
  • Postponement/Revocation Criteria:
  • Failure to maintain HACCP/biosecurity standards².
  • Disease outbreaks in aquaculture facilities².
  • Fraudulent documentation (e.g., falsified health certificates)².
• Documentation Requirements:
  • Format 3 Questionnaire: Exporters must submit updated questionnaires (company profile, HACCP plans, species lists)^{1, 4}.
  • Supporting Documents: Production logs, health certificates, and audit reports must be retained for at least 3 years¹.

4. Competent Authority Oversight

• IQA’s Role:
  • Desk Audits: Reviews registration applications (e.g., Format 2/3 submissions)^{4, 2}.
  • On-Site/Remote Audits: Verifies HACCP compliance, biosecurity, and traceability².
  • Monitoring: Tracks import volumes, disease incidents, and compliance trends^{1, 2}.
• Registration Process for Foreign Establishments:
  1. Application: Submitted by competent authority of exporting country via Indonesian embassy⁴.
  2. Desk Audit: IQA reviews questionnaires, HACCP plans, and facility profiles^{4, 2}.
  3. On-Site Audit: IQA verifies compliance with Indonesian standards².
  4. Approval: IQA issues registration certificate (valid for 3 years, renewable)^{4, 2}.
  5. Renewal: Must be requested 6 months before expiry; includes updated questionnaires and audit reports⁴.

Summary Answer

Indonesia’s repeal of its export registration decree for fish and fishery products, effective May 5, 2026, eliminates the pre-export registration requirement but does not alter import-side obligations. Foreign exporters must still comply with IQA’s registration, traceability, HACCP, and quarantine requirements under Government Regulation No. 29/2023, IQA Regulation No. 2/2025, and Deputy Decree No. 13/2025^{1, 4, 2, 3}. Key requirements include:

• Registration of foreign establishments (aquaculture/processing plants/fishing vessels)^{4, 2}.
• End-to-end traceability (production, processing, transportation, export)¹.
• HACCP/biosecurity compliance (audited annually by IQA)².
• Health certificates and quarantine inspections for all imports³.

The repeal simplifies export procedures but retains strict import controls to mitigate risks to Indonesia’s fisheries and public health.

Sources

1. ↩ WTO SPS notification 26-02381 — Indonesia https://members.wto.org/crnattachments/2026/SPS/IDN/26_02381_00_x.pdf
2. ↩ WTO SPS notification 26-01060 — Indonesia https://members.wto.org/crnattachments/2026/SPS/IDN/26_01060_00_x.pdf
3. ↩ WTO SPS notification 25-04207 — Indonesia https://members.wto.org/crnattachments/2025/SPS/IDN/25_04207_00_x.pdf
4. ↩ WTO TBT notification 26-01501 — Indonesia https://members.wto.org/crnattachments/2026/TBT/IDN/26_01501_00_x.pdf