Importing pesticides into Indonesia: registration, importer standing and HS 3808 duty

In short: pesticides are a triple-gate product in Indonesia — product, company and filing. Any pesticide distributed, stored or sold must first hold a Ministry of Agriculture registration (Permentan 43/2019, 18–24 months for a new formulation). HS 3808 carries 5% MFN duty, with ACFTA ranging 0%–5% by code; household pesticides (mosquito coils / aerosols) also need a Ministry of Health PKRT licence. INSW lookup 2026-10-09.

What the INSW database returned for Chinese heading 3808 when we checked it during real shipment work: the insecticides and herbicides subheadings, the duty and tax readings, the border and post-border restriction lists, and the registration ladder every product must climb.

Verified via INSW 2026-10-09CN 3808 → BTKI 3808.91 · 3808.93Licensed PPJK Indonesia

Key figures (free to quote)

ItemReference figure
China HS heading (filing side)3808 — insecticides, fungicides, herbicides, plant-growth regulators, disinfectants
Indonesia 8-digit · insecticides (non-retail)38089199 — BM 5% · ACFTA 0%
Indonesia 8-digit · herbicides (non-retail)38089319 — BM 5% · ACFTA 5%
PPN (VAT)12% (INSW current reading)
PPh 22 · with / without API2.5% / 7.5%
Border control (Lartas)835 Ministry of Agriculture pesticide licence (named by active ingredient) + 871 Ministry of Health PKRT (household / aerosols only)
Registration permitsTrial 1 yr (extendable 2×) / Temporary ≤1 yr / Permanent 5 yr
Registration lead time18–24 months (incl. local field-efficacy + 12-commodity residue trials)
Lookup date2026-10-09 (INSW, code by code, readings kept verbatim)

Readings above come from our INSW lookup on the date shown. Duty rates and restrictions change with new regulations, so the licensed PPJK must re-check each shipment in INSW and CEISA 4.0 against the rules in force before filing.

1. Why pesticides are a "triple gate" product

One-line position: pesticides are not a "get a licence at import" product — it is a three-stage control: register first, hold the registration to import, then verify again at filing. To save time, the first question is whether the Indonesian importer already holds a registration for the same product; if it does, the 18–24 month registration window can be skipped entirely.

2. Three gates: who regulates what

GateCompetent authority / platformBasis in force
Product registrationMinistry of Agriculture (Kementan) · Pesticide Commission (SimpeL system)Permentan 43/2019 (repealed 39/2015 and 06/2018)
Importer standingInvestment Ministry OSS (NIB/API) + Trade Ministry INATRADEMoT 16/2025 jo. 37/2025; GR 29/2021
Customs filingDirectorate General of Customs (CEISA 4.0 / INSW)PMK duty rules + INSW Lartas list
Household pesticides (second gate)Ministry of Health (PKRT)Permenkes 60/2017 jo. 234/2018

3. Duty and the tax elements

ElementReading
BM import duty (MFN) · insecticides 380891995%
BM import duty (MFN) · herbicides 380893195%
ACFTA · insecticides 380891990%
ACFTA · herbicides 380893195%
PPN (VAT)12%
PPh 22 · with API import licence2.5%
PPh 22 · without API7.5%
PPnBM (luxury goods tax)N/A (not applicable)

4. HS codes and Lartas: insecticides vs herbicides

Point of comparison38089199 — Insecticides (non-retail)38089319 — Herbicides (non-retail)
BM import duty (MFN)5%5%
ACFTA (FORM E)0%5%
PPN (VAT), as read12%12%
PPh 22 · with / without API2.5% / 7.5%2.5% / 7.5%
Border control835 (named ingredients) + 871 (household / aerosols)none at the border
Post-border control835 + 871835 (PGR named ingredients)
Key warning835 is named by active ingredient — check the listno border flag ≠ no registration; the obligation still applies

Compiled from our INSW readings of 2026-10-09. Applicability follows the regulations and the restriction list in force.

5. Three registration permits and the 18–24 month timeline

Permit typeValidityNote
Trial permit1 year (extendable twice, 1 year each)No commercial distribution / use; normally the first step before a permanent permit
Temporary permit≤1 yearIssued when a pest outbreak occurs and no registered pesticide is available
Permanent permit5 yearsAllows commercial distribution and import — commercial cargo must have this
StepStatutory limit
Online submission (SimpeL) + administrative check≤3 working days
Technical evaluation (Pesticide Commission, monthly)—
Plenary review (accept / postpone / reject)rejection appealable once within 30 working days
Minister's decision≤90 working days
Total in practice18–24 months

Field-efficacy trials must run in Indonesia and 12-commodity residue studies are mandatory; overseas GLP toxicology reports are accepted. The applicant must be an Indonesian legal entity.

Legal sources

Verification note (2026-10-09)

Our own code-by-code readings at INSW (insw.go.id), kept verbatim for traceability:

Data source

Our own code-by-code INSW lookup (38089199 / 38089319). Working file version 2026-10-09 · source: INSW national trade repository insw.go.id/intr

Related pages

Garlic (seed vs table): a sibling agricultural-compliance page

Note for this page: the underlying verification note was recorded in Chinese at the time of the lookup and can be shared on request. Readings are snapshots from a specific lookup date — not a filing guarantee.

This page summarizes field practice and publicly available Indonesian import rules for general business reference only—it is not legal, customs, or pricing advice. Customs provisions, tariff rates, and licensing requirements keep changing, so the rules in force at the time and the official processing result always prevail. Wuhan Freedom International Logistics Co., Ltd. · Licensed PPJK in Indonesia · Jakarta / Semarang / Wuhan.

Frequently asked questions

Does importing pesticides into Indonesia require registration first?

Yes. Any pesticide distributed, stored or sold in Indonesia must first hold a Ministry of Agriculture (Kementan) registration, under Permentan 43/2019. A foreign factory cannot apply directly — an Indonesian legal entity must hold the registration and act as importer.

What is the import duty on pesticides? Does ACFTA remove it?

MFN duty is 5%. ACFTA differs by code: insecticides 38089199 read 0%, herbicides 38089319 read 5% — not zero across the board, so check the schedule in force code by code. PPN 12%; PPh 22 is 2.5% with an API and 7.5% without.

Are household pesticides the same as agricultural pesticides?

No. Mosquito coils, aerosols and electric mats need a Ministry of Health PKRT licence (Permenkes 60/2017) on top of the agriculture registration. Consumer-only products go through the health-ministry track alone; professional or public-health use needs both ministries.

How long does registration take and what is the process?

A new formulation takes 18–24 months in practice. Administrative check within 3 working days, then technical evaluation by the Pesticide Commission (monthly meetings), then the minister's decision (up to 90 working days). Start with a trial permit (1 year, extendable twice, no commercial sale), then move to the permanent permit (5 years).

Can a foreign factory apply directly?

No. The registration applicant must be an Indonesian legal entity. A Chinese factory or brand owner can only work through an Indonesian agent, a joint venture, or by setting up its own PT PMA to apply and hold the registration.

What most often holds up pesticide imports?

Three things: a registration holder that does not match the PIB importer; reading only the HS code instead of the active ingredient — the 835 list is named by active ingredient (e.g. thiram, benomyl); and a label that is not in Indonesian or is incomplete. Also note the 835 entry on INSW still cites 06/2018, which Permentan 43/2019 has repealed.

Key questions on this page, free to quote.

Official sources

Independently verifiable channels below. Rates, restrictions and lead times follow each agency's latest publication.