Foreign Investor FeasibilityKBLI 11010
§ 01
Foreign investment rules
Indonesia's BUPM (Investment Business Fields) regulation places this code into one of five tracks. The track determines whether a foreign investor (PMA) can operate in this activity at all, and under what conditions.
Status · closed
Closed to all investment
KBLI 11010 appears on the list of business activities closed to investment under Pres. Reg. 10/2021. Neither domestic nor foreign capital may operate in this activity. The specific prohibited activities are listed below.
Listed restrictions
Prohibited activities
1- Alcoholic beverage industry
§ 02
Beverage manufacturing-specific guidance
Sector context that applies to KBLI 11010 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Industry (Kemenperin) / BPOM / Bea Cukai
- ·Alcoholic beverages (KBLI 1101–1103) carry restrictions on foreign equity and require NPPBKC excise license.
- ·Non-alcoholic and bottled water generally open to PMA up to 100% with BPOM registration.
- ·Halal certification mandatory for non-alcoholic beverages.
§ 03
Regulations governing KBLI 11010
Current status, what each regulation actually requires for this activity, and how it ties to the PB UMKU sector permits below. Click through for the plain-English summary.
- President of the Republic of Indonesia
- President of the Republic of Indonesia
- Indonesia, Kementerian Keuangan
§ 02
What this means for foreign investors
An honest read of the situation, plus the structures that work in practice. We've handled all of these — book a call to walk through your specific plan.
You can't operate this activity in Indonesia — neither as a foreigner nor a local.
This KBLI is on Pres. Reg. 10/2021's list of closed business activities. The activity is prohibited entirely; even Indonesian-owned entities cannot register for it. There is no PMA, joint-venture, or partnership structure that unlocks this code. Your option is to choose a different activity.
Pathways that work
Pivot to an adjacent open KBLI
Most closed activities have neighbours that solve a similar customer problem and accept full PMA. We help you map the closest open code that still fits your commercial thesis.
Off-take / commercial partnership
You can buy from, sell to, or service an Indonesian-owned operator without taking equity. We draft and structure the commercial framework so it stands up to scrutiny.
PMA-viable codes in adjacent industries
These KBLIs solve a related business problem and are open to foreign ownership. None are a perfect substitute for the activity above — but they often unlock 80% of the commercial outcome. Talk to us about which fits your plan.
Restricted KBLIs need a tailored structure. Book a call and we'll map the right entity, partner, and licensing path for your specific business.
Talk to a corporate-services specialist§ 07
Reference data: how this KBLI is regulated
The data below is the official OSS regulatory profile for this code. It applies to qualifying Indonesian operators (or to your operating partner). Foreign investors won't file these directly, but it's useful context when structuring a partnership or commercial arrangement.
Foreign investors:the licensing matrix below is for context only — direct PMA registration isn't possible for this code. See pathways above for what actually works.
What's required to operate
NIB
Preparation only — additional permit needed below
Operating License (Izin)
Important: NIB is issued for the preparation stage. Commercial operation requires a full Operating License (Izin) issued by the competent ministry after a substantive review of the operator's capability, facility, and compliance. Operating with NIB alone exposes the entity to penalties, blacklisting, and contract invalidation.
Processing time
7Days
Statutory turnaround
Application requirements
8Documents and capabilities you must demonstrate at registration
- 01Have a document outlining the plan for the type, specifications, quantity, and source of raw materials, as well as the source and amount/volume of energy and water needed to carry out industrial business activities for 1 (one) production cycle or for the next 6 (six) months.
- 02Possess documents in the form of: a. Machine specifications and/or equipment list b. Photos of machines/equipment c. Sales/rental agreement that proves: 1) Control (ownership/rental) of machines for producing food and beverage industry products and quality testing equipment 2) Compliance of installed production capacity with business data
- 03Have flowchart documents for: a. Procurement, receipt, and storage of raw materials, b. Production process, c. Quality control process, d. Packaging, storage, transportation, and distribution of production results.
- 04Have a facility layout planning document that aligns with the production process flowchart, demonstrating that the factory/business location is far from pollution sources to protect the processed food produced.
- 05Having a valid Alcoholic Beverage business license.
- 06Have a human resources organizational structure document that minimally consists of the company leader, the person in charge of the production department, the person in charge of the human resources development department, and the person in charge of the quality control department.
- 07Have a facility layout planning document that proves the availability of: a. Dedicated production space b. Quality control space
- 08Have documents in the form of photos that prove the availability of Occupational Accident Handling Facilities and rest areas for workers.
Ongoing obligations
5Compliance and reporting duties throughout operation
- 01Have proof of submission of mandatory validated Industrial Data every 6 (six) months in accordance with the laws and regulations in the industrial sector.
- 02Ensure the safety and security of equipment, processes, production results, storage, and transportation, in accordance with applicable laws and regulations.
- 03Having a recommendation for approval of changes to the alcoholic beverage business license from the Ministry responsible for government affairs in the industrial sector in accordance with the laws and regulations regarding the control and supervision of the alcoholic beverage industry in terms of making changes to the business license, including: a. Change of company name, ownership, or person in charge of the Alcoholic Beverage Industry Company b. Change of factory address c. Change of category of Alcoholic Beverage d. Relocation e. Merger of companies into one location / or f. Increase in production capacity (business expansion)
- 04Have SOP documents and implement the provisions for product packaging, labeling, product information, and product storage based on the principles of Good Manufacturing Practices for Processed Food.
- 05Have SOP documents and implement employee hygiene and sanitation provisions based on the principles of Good Manufacturing Practices for Processed Food.
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | All of them |
| Minister/Head of Agency | Foreign Investment |
§ 05
Auxiliary permits (PB UMKU)
PB UMKU permits sit on top of the main NIB and Sertifikat Standar — each is issued by a different ministry, and only when a specific operational activity is performed. This KBLI carries 10 candidate permits across 1 regulator; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Pharmaceuticals
10 permitsBPOM (National Agency of Drug & Food Control). Applies to drugs, processed food, traditional medicine, cosmetics, and health supplements — produced, imported, repackaged, or distributed for human consumption. BPOM is the gating regulator; product registration is required before any commercial sale.
- Approval for the Implementation of Processed Food Clinical TrialsPersetujuan Pelaksanaan Uji Klinik Pangan Olahan2 requirements1 obligationFood and Drug Supervisory Agency
- Certificate of Approval for Major Variations in Processed Food Mandatory SNISertifikat Persetujuan Variasi Mayor Pangan Olahan Wajib SNI2 requirements1 obligationFood and Drug Supervisory Agency
- Certificate of Compliance with Major Processed Food Commitment VariationsSertifikat Pemenuhan Komitmen Variasi Mayor Pangan Olahan2 requirements3 obligationsFood and Drug Supervisory Agency
- Certificate of Minor Variation Commitment Compliance for Processed FoodSertifikat Pemenuhan Komitmen Variasi Minor Pangan Olahan3 requirements3 obligationsFood and Drug Supervisory Agency
Speak to Emerhub
KBLI 11010 needs a tailored structure. Let's design it.
Restricted KBLIs need a structure designed around the restriction — partnership, alternative code, KEK, or commercial arrangement. We've handled all of these. One conversation tells you what works for your plan.