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.
Reserved for cooperatives & micro/small enterprises
KBLI 22121 is allocated to cooperatives and Indonesian micro, small and medium enterprises (UMKM) under the BUPM allocation list. Foreign investment via PT PMA is not permitted for the listed sub-activities below.
Reserved for SMEs / cooperatives
1- Rubber smoking industryAllocated for Cooperatives and UMKM.Sector: Industry
Manufacturing-specific guidance
Sector context that applies to KBLI 22121 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
- ·Industry data reporting via SIINas every 6 months.
- ·BPOM registration required for any food, drug, cosmetic, or medical device produced.
- ·Halal certification mandatory for most consumable products.
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.
This activity is allocated to Indonesian SMEs and cooperatives.
PT PMA is not permitted for this KBLI. The activity is reserved for cooperatives and Indonesian micro/small/medium enterprises (UMKM). The pathway for foreign investors is to operate a different value-chain step (e.g. processing or distribution rather than the reserved primary activity), or to support local SMEs as an off-taker / brand owner / financier.
Move to a different value-chain step
The cleanest path: operate a related but open KBLI. For example, foreign investors blocked from primary commodity production frequently succeed with the processing, distribution, branding, or export-trade codes upstream or downstream of the restricted activity.
Special Economic Zone (KEK) or Free Trade Zone (Batam)
Several restricted codes have higher or full PMA caps inside designated KEK zones (Sanur Health, Lido, Mandalika) or the Batam Free Trade Zone — manufacturing, logistics, and IT services especially. The IUK regime under BP Batam relaxes ownership rules selectively in exchange for export orientation. We assess whether your operation can benefit. See the for the requirements.
SME partnership / off-take model
You can't hold the SME licence yourself, but you can build a contractual ecosystem with cooperatives or UMKM partners — supplying them with capital, IP, brand, distribution, or technology. We structure these arrangements so they stay defensible and commercially aligned.
These siblings are usable by a foreign-owned PT PMA — they have a Large-scale licensing matrix and aren't on a restricted list. Each has its own context badge so you can pick by trade-off.
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.
Application requirements
6Documents 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 plastic and rubber industrial 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, Head of production, Head of quality control, Head of human resources development, and/or b. Head of marketing.
- 04Have a flowchart document 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
- 05Possess documentation in the form of photos proving the availability of occupational accident handling facilities and rest areas for workers.
- 06Have documents outlining the specifications and intended use of the produced goods.
Ongoing obligations
6Compliance 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.
- 03Possess periodic calibration documents for quality control equipment or periodic results from independent laboratory tests on the produced products.
- 04Have a document in the form of a disaster evacuation SOP, including the arrangement of workplace safety signs.
- 05Possess a Quality Management System certificate (ISO 9001).
- 06Have a document in the form of a Standard Operating Procedure (SOP) for customer service regarding the use of produced goods.
