IMPORTATION AND EXPORTATION OF HORTICULTURAL SEEDS

The Ministry of Agriculture of the Republic of Indonesia has issued the Regulation of the Minister of Agriculture (“MOA”) No. 14 of 2026 regarding the Importation and Exportation of Horticultural Seeds (“RM 14/2026″), which came into effect on 31 Juli 2026. This regulation replaces the Regulation of the MOA No. 15/PERMENTAN/HR.060/5/2017, as amended several times, most recently by the Regulation of the MOA No. 26/PERMENTAN/HR.060/5/2018. RM 14/2026 was enacted to support the availability of adequate and sustainable seed supplies, promote the development of the domestic seed industry, preserve genetic resources and genetic diversity, maintain biosafety, and enhance the competitiveness of Indonesia’s horticultural seed trade.

The following are several key provisions introduced under RM 14/2026:

1. Seed Importation

Under RM 14/2026, business entities, government agencies, and individuals are permitted to import horticultural seeds into Indonesia, subject to obtaining a seed import permit (izin pemasukan benih) issued by the MOA. This provision emphasizes that all seed importation activities are subject to government control to ensure seed quality, biosafety, and the protection of national interests.

RM 14/2026 provides clarity on the purposes and requirements for importing horticultural seeds into Indonesia by specifying the categories of permitted imports and the technical requirements applicable to each category. A seed import permit can be issued for various purposes, including the registration of horticultural varieties for commercial circulation, the procurement of quality seeds for commercial activities, and seed development programs intended to support export-oriented production.

2. Special Requirements for Genetically Engineered Seeds and Quarantine Risks

RM 14/2026 reinforces the regulatory framework governing the importation of seeds derived from genetically engineered products. Such imports are permitted only after the applicable biosafety requirements have been satisfied and a recommendation has been obtained from the Biosafety Commission for Genetically Engineered Products (Komisi Keamanan Hayati Produk Rekayasa Genetik).

RM 14/2026 also introduces additional safeguards for first-time imports. Where seeds are imported for the first time from a particular plant species or country of origin, applicants may be required to undertake a Pest Risk Analysis as part of the import licensing process.

3. Enhanced Quality Control and Relabelling Obligations

RM 14/2026 also strengthens the quality control regime for imported seeds. Under the regulation, imported seeds that have undergone quality testing must be repackaged and relabelled to include the relevant quality test results, providing transparency regarding the quality standards of the seeds being distributed in Indonesia. The required quality testing may be conducted either by the relevant government authority or by an accredited or certified laboratory, reflecting the government’s effort to ensure that imported seeds meet the applicable quality requirements before being marketed or used domestically.

4. Simplification and Certainty of Licensing Timeframes

RM 14/2026 further enhances the digital licensing framework by requiring all permit applications to be submitted and processed electronically through the agricultural licensing system integrated with the Indonesia National Single Window (“INSW”). Applicants must submit the relevant administrative and technical documents in accordance with the purpose of the importation or exportation.

For seed import permits, the document completeness review must be carried out within 2 (two) working days, followed by a verification and validation process of up to 5 (five) working days. Once the application is verified as complete and compliant, the Director General of the MOA will issue the seed import permit in the form of a Ministerial Decree.

In relation to seed export permits, the administrative review must be completed within 1 (one) working day, while the verification and validation process is subject to a maximum timeframe of 3 (three) working days.

Applications that are not rejected within these prescribed timeframes will be deemed approved.

RM 14/2026 provides that both seed import permits and seed export permits remain valid for the relevant calendar year and expire at year-end, regardless of the date of issuance.

5. Post-Licensing Obligations and Reporting Requirements

RM 14/2026 also strengthens post-licensing compliance requirements. Permit holders (seed import permit and seed export permit) are required not only to submit the necessary documentation to the relevant quarantine authorities and report the implementation of their activities, but also to ensure that any seed development or cultivation activities are carried out in accordance with the plans approved during the licensing process. Selain itu, realization reports must be submitted to the MOA to demonstrate compliance with these commitments.

6. More Stringent Administrative Sanctions

RM 14/2026 introduces a more detailed framework of administrative sanctions for violations of licensing requirements or seed usage obligations. Applicable sanctions may include written warnings, permit revocation, product withdrawal from the market, and prohibition from obtaining new permits for a period ranging from 1 (one) to 2 (two) years.

These sanctions may be imposed, among other things, for the submission of inaccurate or misleading documents, the use of seeds for purposes inconsistent with the approved permit, violations of relabelling obligations, failure to comply with reporting requirements, and failure to fulfil seed destruction obligations in certain activities such as testing, promotion, or exhibitions.

Conclusion

The most significant change introduced under RM 14/2026 is the strengthening of the purpose-based licensing framework for seed imports, accompanied by more detailed technical requirements, greater certainty in permit processing timelines, enhanced post-licensing compliance obligations, and the implementation of more stringent administrative sanctions.

This Client Alert is provided for general informational purposes only and does not constitute legal advice. Please contact us should you require further information regarding the implications of RM 14/2026 on your business activities.

LINK PDF: Client-Alert-regarding-Importation-and-Exportation-of-Holticultural-Seeds-2026-08-213.pdf