Foreign Investor FeasibilityKBLI 20232
§ 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 · Open with carve-outs
Open to foreign investment, with carve-outs
KBLI 20232 is open as a class — a 100% foreign-owned PT PMA can be incorporated under this code — but Pres. Reg. 10/2021 carves out 1 specific sub-activity that are off-limits or restricted for foreign capital. The rest of the activity remains open to PMA. The carved-out items are listed below; any of them needs to be either avoided, served via an Indonesian operator, or structured around case-by-case.
Listed restrictions
Conditional sub-activities
1- Traditional cosmetic industryDomestic only100% Domestic capital
§ 02
Halal certification
Indonesia requires BPJPH Halal certification for an expanding range of consumer-product categories. This KBLI's activities fall in scope — see what's required and when.
BPJPH certification required
Halal certification will be mandatory for cosmetics by Oct 2026.
Mandatory by October 2026
Under PP 39/2021, cosmetics, personal-care, and household-chemical products entering the Indonesian market must be Halal-certified by October 2026. Foreign-brand cosmetics need to be ready ahead of that — covering raw materials (including sourcing), formulation, manufacturing facilities, and packaging. Plan 4-6 months for the BPJPH process; we manage it end-to-end alongside BPOM cosmetic registration.
- 01
Audit & gap analysis
Review your formulation, supply chain, and facility against BPJPH criteria. Identify ingredients or processes that need swapping.
- 02
LPH inspection
An accredited Halal Inspection Body (LPPOM-MUI is the largest) audits the facility and reviews documentation.
- 03
BPJPH issuance
The Halal certificate is issued under the BPJPH register and the Halal label can be applied to packaging.
Halal certification is a core Emerhub service. We've handled BPJPH projects for foreign-brand food, cosmetics, and pharma operators across Indonesia — including supply-chain re-sourcing where needed. Bundle it with your PT PMA setup and we coordinate both timelines.
Talk to a Halal advisor§ 04
How we handle your KBLI 20232 setup
Emerhub is a corporate-services provider in Indonesia. We do the legal and regulatory legwork for foreign investors so you can focus on the business itself. Here's what the engagement looks like.
§ 07
Licensing requirements in detail
Specific permits, application requirements and ongoing obligations vary by business scale and the sub-activity within this KBLI. We file these on your behalf — this section is for transparency on what we'll be handling. Switch between scales below; by default we show Large (the PMA scale).
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
5Documents 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 a duration of 6 (six) months ahead.
- 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 pharmaceutical products and quality testing equipment 2) Compliance of installed production capacity with business data
- 03Have a human resources organizational structure document that includes at least: a. Company leadership b. Production and/or quality control department c. Marketing department
- 04Have 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
- 05$46
Ongoing obligations
9Compliance 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 customer complaint/product service for: a. Adverse events b. Product quality that demonstrates a minimum service commitment to customers.
- 04Possess periodic calibration documents for quality control equipment or periodic results from independent laboratory tests on the produced products.
- 05Have a document in the form of a disaster evacuation SOP, including the arrangement of workplace safety signs.
- 06Possess a Quality Management System certificate (ISO 9001).
- 07Have a security and safety SOP for: a. Storage of raw materials in the form of chemicals b. Use of machinery/equipment, and c. Production processes
- 08The use of raw materials must comply with the Indonesian cosmetics code or other specified standards.
- 09Possess a document of the Technical Responsible Person Certificate for Cosmetic Industry.
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 20 candidate permits across 2 regulators; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Pharmaceuticals
19 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 Quasi Drug AdvertisingPersetujuan Iklan Obat Kuasi2 requirements1 obligationFood and Drug Supervisory Agency
- Approval for the Implementation of Clinical Trials for Quasi DrugsPersetujuan Pelaksanaan Uji Klinik Obat Kuasi2 requirements6 obligationsFood and Drug Supervisory Agency
- Approval for the Implementation of Cosmetic Clinical TrialsPersetujuan Pelaksanaan Uji Klinik Kosmetika2 requirements6 obligationsFood and Drug Supervisory Agency
- Approval for the Implementation of Preclinical Testing of CosmeticsPersetujuan Pelaksanaan Uji Praklinik Kosmetika2 requirements2 obligationsFood and Drug Supervisory Agency
Veterinary & Animal Medicine
1 permitMinistry of Agriculture. Applies if you produce, import, distribute, or sell animal medicines, vaccines, or feed; if you breed livestock; or if you operate a veterinary practice. A "veterinary control number" (NKV) is the entry-point permit for animal-product processors.
Speak to Emerhub
Get your KBLI 20232 setup handled end-to-end.
Emerhub is a corporate-services provider in Indonesia. We handle PT PMA incorporation, licensing, tax registration and monthly compliance — so you focus on operating the business.