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On March 10, 2024, Regulation of the Minister of Trade No. 3 /2024 on Amendments to Regulation of the Minister of Trade No. 36 of 2023 on Import Policies and Regulations was enacted. The regulation contains, among others, new regulations regarding the import of Traditional Medicine, Health Supplements, Cosmetics, and Household Health Supplies (PKRT) products. Included in health supplements are vitamins as well as premixes that are fortified ingredients. To follow up on these changes, KFI reviewed, accommodated inputs and responses from relevant stakeholders, and then encouraged the Directorate General of Agro Industry of the Ministry of Industry to review the enactment of MOT 3/2024. This review resulted in an amendment to MOT 3/2024, which is contained in MOT 7/2024.
Permendag No.3 /2024 at that time needed to be reviewed because it contained additional requirements for importing premix fortifiers. The import of this group of health supplements, which originally only required a Surveyor's Report (LS) letter, became an LS and Import Approval (PI). The PI letter is issued by the Ministry of Industry (according to Minister of Industry Regulation No.4/2024). Various requirements must be met by importers before obtaining an import license, among others: (i) Business licenses in the field of wholesale trade with certain Indonesian Standard Industrial Classification (KBLI), (ii) Import realization report and distribution realization report of the previous year, (iii) Flow chart of use and / or distribution flow; and (iv) Proof of cooperation contract and sale and purchase contract between industrial companies and companies importing health supplement materials in the event that the product is used as raw material and / or auxiliary material for industrial companies.
The addition of these requirements is intended to support industry stability and improve the quality of the domestic industry, as well as increase the use of the same products from within the country. However, in communication with the Indonesian Wheat Flour Producers Association (Aptindo) and some flour producers, we obtained information that the addition of these requirements has the potential to hamper the smooth supply of the fortifying premix. Furthermore, because the fortificant content is a mandatory requirement for flour products, it is feared that the supply constraints will have an impact on the smooth production of flour, which in turn will disrupt the production process in the flour-based food processing industry, both small and large businesses. Previous experience shows that if relaxation is implemented, it will be very difficult to start again. This means that there will be a time when all flour is not fortified which will certainly be very detrimental to public health. Another possibility is the cessation of the flour industry due to fears of being accused of violating SNI due to unfortified flour. The disruption of the wheat flour industry that absorbs so many workers both in wheat flour factories and large, medium and small industries of derivative products that involve many MSMEs and if prolonged it is feared that it will slow down national economic growth and potentially have a double effect on the Indonesian economy.
Untuk menghindari dampak negatif yang dikhawatirkan bagi para pelaku usaha maupun kelangsungan program fortifikasi wajib tepung terigu, KFI sebagai bagian dari tim sekretariat Forum Koordinasi Fortifikasi Pangan Nasional mengirimkan surat permohonan peninjauan ulang pemberlakuan Permendag No.3 Tahun 2024 kepada Direktur Jenderal Industri Agro Kementerian Perindustrian. Hasil dari peninjauan ulang tersebut tertuang dalam Permendag No. 7 Tahun 2024 yang mengubah Permendag No.3/2024. Syarat untuk impor premiks fortifikan adalah Laporan Surveyor dengan penagawasan post border (pengawasan saat beredar bebas/pasar), dan tidak lagi dengan Persetujuan Impor (PI).
