A 24-Hour Update on the World’s Largest Palm Oil Exporter: Ministerial Regulation Number 25 of 2026 Establishes Export Controls, Phase 2 Scope Defined
Published: May 26, 2026
By: Zeeshan Khan
Reading time: 15 minutes
Category: International Trade / Anti-Corruption / Commodities
Note: May 26, 2026 – This is an update to the May 25, 2026 article: Indonesia’s Palm Oil Export Crackdown Enters Implementation Phase: New State Agency DSDI Formally Established, Two-Phase Rollout Confirmed
JAKARTA – May 26, 2026 – One day after the government formally established PT Danantara Sumber Daya Indonesia (DSDI) and confirmed a two-phase implementation timeline, the Ministry of Trade has now published the full list of commodities and products that will be subject to the new centralized export system. The list, contained in Trade Minister Regulation Number 25 of 2026, covers 21 tariff posts (Harmonized System codes) ranging from crude palm oil (CPO) to its derivative products.
The May 25 article correctly noted that the full list from the Trade Ministry was pending and that market participants were awaiting this clarification. The publication of the regulation now provides complete regulatory clarity for exporters and buyers before the June 1, 2026, transition period begins. The confirmed list includes not only CPO and specific refined oils mentioned in the May 25 article, but also a wide range of palm oil derivatives, including oleochemicals, biodiesel feedstocks, and palm fatty acid distillate (PFAD).
This development represents the final regulatory step before implementation. The regulation formally empowers DSDI to manage the export of these specific goods, establishing a mandatory export procedure through the Indonesia National Single Window (INSW) portal. With the list now published, the remaining unanswered question from the May 25 article – the full commodity list – has been resolved, though questions about potential Phase 2 fees and Singapore’s response remain.
The Essentials: Who, What, When, Where, Why, How (Last 24 Hours)
Who: PT Danantara Sumber Daya Indonesia (DSDI), the state-owned enterprise managing strategic commodity exports; Indonesia’s Ministry of Trade, which issued the regulation; exporters of the 21 listed tariff posts; global buyers of Indonesian palm oil and derivatives; and the Indonesia National Single Window (INSW) portal.
What: The Ministry of Trade has published Trade Minister Regulation Number 25 of 2026, which formally lists the commodities and products subject to the DSDI export system. The regulation covers 21 tariff posts (HS codes) including crude palm oil, various refined palm oils, palm fatty acid distillate (PFAD), oleochemicals, biodiesel feedstocks, and other palm oil derivatives.
When: The regulation was published on May 25 or early May 26, 2026. The Phase 1 transition period begins June 1, 2026. Phase 2 full implementation begins September 1, 2026.
Where: The regulation applies to exports from Indonesia. The export procedure is managed through the INSW portal. The policy affects global palm oil supply chains.
Why (Immediate Cause): The government is implementing the centralized system to capture revenue lost to under-invoicing, which President Prabowo estimates at $150 billion annually across palm oil, coal, and ferroalloys. The regulation provides the legal basis for DSDI’s authority over specific products.
How (Mechanism): Under the regulation, exporters must register their export plans through the INSW portal and secure a DSDI declaration before shipment. During Phase 1 (June 1 – August 31, 2026), exporters handle transactions while DSDI manages documentation and evaluates the system. During Phase 2 (starting September 1, 2026), DSDI takes charge of all transaction processes, including contracts, shipments, and payments.
Specific Updates in the Last 24 Hours (May 25–26, 2026)
1. Trade Minister Regulation Number 25 of 2026 Published
On May 25 or early May 26, 2026, Indonesia’s Ministry of Trade officially published Trade Minister Regulation Number 25 of 2026, which formally lists the commodities and products subject to the DSDI export system.
Legal Basis: The regulation is issued under the authority of the Trade Minister and establishes the legal framework for DSDI’s export management authority. It is the implementing regulation for the policy announced on May 21, 2026.
What the Regulation Contains: The regulation specifies 21 tariff posts (HS codes) that must go through the DSDI system. It also establishes the export procedure, including registration requirements, documentation standards, and the role of the INSW portal.
Relationship to DSDI: The regulation formally empowers DSDI to manage the export of these specific goods. DSDI is the operating agency responsible for verifying transactions, managing documentation, and, in Phase 2, controlling contracts, shipments, and payments.
2. Complete List of 21 Tariff Posts Confirmed
The full list of affected commodities has now been published. The list covers a broad range of palm oil products, from crude palm oil to highly processed derivatives.
Confirmed Commodity List (21 Tariff Posts):
| Category | Specific Products (HS codes) |
|---|---|
| Crude palm oil (CPO) | Crude palm oil (HS 1511.10) |
| Refined palm oils | Various refined, bleached, deodorized (RBD) palm oils and fractions |
| Palm fatty acid distillate (PFAD) | PFAD (HS 3823.19) |
| Oleochemicals | Various palm-based fatty acids, fatty alcohols, and derivatives |
| Biodiesel feedstocks | Palm-based biodiesel feedstocks and related products |
| Other derivatives | Additional palm oil derivatives and processed fractions |
Comparison to May 25 Article: The May 25 article reported that only CPO, 33-degree refined, and 24-degree refined palm oil were affected during the transition period (Phase 1). The full list confirms that Phase 2 (starting September 1) will cover a much broader range of products, including many that were not mentioned in the initial coverage.
Implication: Exporters of oleochemicals, biodiesel feedstocks, PFAD, and other palm oil derivatives now have clarity that these products will be subject to DSDI oversight starting September 1, 2026. They should prepare accordingly.
3. Export Procedure Formalized Through INSW Portal
The regulation establishes a mandatory export procedure that exporters must follow for all covered products.
Step-by-Step Export Procedure:
| Step | Action | Responsible Party |
|---|---|---|
| 1 | Register export plan in INSW portal | Exporter |
| 2 | Submit documentation for DSDI review | Exporter |
| 3 | DSDI verifies documentation and pricing | DSDI |
| 4 | DSDI issues declaration | DSDI |
| 5 | Exporter proceeds with shipment | Exporter |
Role of INSW: The Indonesia National Single Window (INSW) is the centralized electronic portal for export-import documentation. The regulation requires all covered exports to be processed through INSW, allowing DSDI to monitor and verify transactions in real time.
Documentation Requirements: Exporters must submit documentation including commercial invoices, packing lists, bills of lading, and pricing information. DSDI will verify that declared prices are consistent with international benchmarks.
Timing: This procedure applies starting June 1, 2026, for Phase 1 products (CPO, 33-degree refined, 24-degree refined). For the full list of 21 products, the procedure applies starting September 1, 2026 (Phase 2).
4. Phase 2 Scope Now Clearly Defined
With the publication of the full list, the scope of Phase 2 (starting September 1, 2026) is now clearly defined.
Phase 1 (June 1 – August 31, 2026):
- Affected products: CPO, 33-degree refined, 24-degree refined (subset of the full list)
- DSDI role: Documentation management, system evaluation
- Exporters: Handle transactions
Phase 2 (Starting September 1, 2026):
- Affected products: All 21 tariff posts (full list)
- DSDI role: Full transaction control – contracts, shipments, payments
- Exporters: Route all covered exports through DSDI
Transition Implication: Exporters of products not in the Phase 1 list (e.g., oleochemicals, biodiesel feedstocks, PFAD) have a window from now until September 1, 2026, to prepare for DSDI oversight. They are not required to route through DSDI during the Phase 1 transition period.
5. No Additional Fees Announced (Still Unchanged)
The May 25 article reported that no additional fees are being imposed during Phase 1, but that potential fees in Phase 2 could impact exporter margins. This position remains unchanged.
Phase 1 Fees: No additional fees beyond existing export taxes and levies. The regulation does not create new fees for Phase 1.
Phase 2 Fees: The regulation does not specify whether additional fees will be introduced in Phase 2. The government has not ruled out such fees. Analysts estimate that every Rp100,000 per ton increase in export-related fees could reduce plantation company earnings by 1-4%.
What to Watch: Any announcement of Phase 2 fees would come before September 1, 2026. Exporters and buyers should monitor government communications closely.
6. Market Response: Awaiting Impact of Full List
The May 25 article reported initial market response including Malaysian futures volatility and Indian buyers purchasing 100,000 tons for June shipment. The publication of the full list may generate additional market reaction.
Immediate Reaction: As of May 26, 2026, the market is digesting the full list. The broader scope of Phase 2 (21 products vs. 3 products in Phase 1) may affect pricing and supply expectations for derivatives such as oleochemicals and biodiesel feedstocks.
Potential Impact on Derivatives: Products such as oleochemicals (used in cosmetics, soaps, detergents) and biodiesel feedstocks (used in renewable fuel) are now confirmed to be within DSDI’s scope for Phase 2. Buyers of these products may follow the pattern of CPO buyers and seek to secure supply before September 1.
Price Spread: The May 25 article noted that Indonesian CPO is trading at a discount to Malaysian palm oil. The publication of the full list may affect this spread as market participants assess the implications for different product categories.
7. Singapore’s Response Still Not Reported
The May 25 article noted that Singapore’s official response to the under-invoicing allegations had not yet been reported. As of May 26, 2026, this remains unchanged.
Context: The investigation that prompted the policy revealed that Singaporean intermediary trading companies were central to the under-invoicing scheme, with prices reported to Singapore at half their true value. Singapore’s government has not issued an official response.
What to Watch: Any statement from Singapore’s Ministry of Trade and Industry or other relevant authorities would be a significant development, potentially affecting diplomatic and trade relations between the two countries.
Comparison: Before and After the May 26 Update
| Issue | As of May 25 Article | As of May 26, 2026 (Current) |
|---|---|---|
| Full list of affected commodities | PENDING | PUBLISHED – 21 tariff posts under Trade Minister Regulation Number 25 of 2026 |
| Legal basis | Not specified | TRADE MINISTER REGULATION NUMBER 25 OF 2026 |
| Phase 2 scope | Not specified beyond initial products | FULLY DEFINED – All 21 tariff posts starting September 1, 2026 |
| Export procedure | Documentation focus in Phase 1 | FORMALIZED – Registration through INSW portal; DSDI declaration required |
| Additional fees | No fees in Phase 1; potential fees in Phase 2 | UNCHANGED – No announcement on Phase 2 fees |
| DSDI leadership | Luke Thomas Mahony appointed | Unchanged |
| Phase 1 start date | June 1, 2026 | Unchanged |
| Phase 2 start date | September 1, 2026 | Unchanged |
| Market response | Malaysia futures volatile; Indian buyers purchased 100,000 tons | Awaiting reaction to full list |
| Price spread | Indonesian CPO at discount to Malaysian | Unchanged |
| Singapore’s response | NOT YET REPORTED | NOT YET REPORTED – unchanged |
Confirmed Commodity List: Detailed Categories
The following categories are confirmed to be within the scope of Trade Minister Regulation Number 25 of 2026 and will be subject to DSDI management starting September 1, 2026.
Category 1: Crude Palm Oil (CPO)
- HS 1511.10 – Crude palm oil
- Affected in Phase 1 (starting June 1)
- Full DSDI control starting September 1
Category 2: Refined Palm Oils
- Various refined, bleached, deodorized (RBD) palm oils
- RBD palm olein, RBD palm stearin, RBD palm oil
- 33-degree refined and 24-degree refined (specifically mentioned in Phase 1)
- Affected in Phase 1 (certain refined oils); full list applies September 1
Category 3: Palm Fatty Acid Distillate (PFAD)
- HS 3823.19 – Palm fatty acid distillate
- Used in soap manufacturing, animal feed, and industrial applications
- Subject to DSDI oversight starting September 1
Category 4: Oleochemicals
- Palm-based fatty acids, fatty alcohols, methyl esters
- Glycerin, soap noodles, and other derivatives
- Used in cosmetics, detergents, personal care products
- Subject to DSDI oversight starting September 1
Category 5: Biodiesel Feedstocks
- Palm-based biodiesel feedstocks
- Related products for renewable fuel production
- Subject to DSDI oversight starting September 1
Category 6: Other Derivatives
- Additional palm oil fractions and processed derivatives
- Industrial and food-grade products
- Subject to DSDI oversight starting September 1
What Has Not Changed (Since May 25 Article)
The following elements of the investigation and policy remain unchanged from the May 25 article:
| Element | Status |
|---|---|
| $150 billion annual revenue leakage estimate | Presidential estimate – unchanged |
| Under-invoicing scheme details | Investigators found prices reported to Singapore at half true value – unchanged |
| 10 major CPO exporters investigated | Unchanged |
| State monopoly on strategic commodity exports | Central policy objective – unchanged |
| DSDI formal establishment | COMPLETED (May 24-25) – unchanged |
| Phase 1 start date (June 1, 2026) | CONFIRMED – unchanged |
| Phase 2 start date (September 1, 2026) | CONFIRMED – unchanged |
| No additional fees in Phase 1 | CONFIRMED – unchanged |
| Potential fees in Phase 2 | NOT SPECIFIED – unchanged |
| Singapore’s official response | NOT YET REPORTED – unchanged |
| WTO challenge risk | Remains a potential challenge |
Why This Matters (Updated for May 26)
The publication of the full commodity list is the final regulatory step before implementation. It matters for several reasons.
For Indonesian palm oil exporters: The full list is now known. Exporters of CPO, refined oils, PFAD, oleochemicals, biodiesel feedstocks, and other derivatives must prepare for DSDI oversight. Those exporting products not in the Phase 1 list have until September 1 to prepare. Those exporting Phase 1 products face a June 1 deadline.
For global buyers of palm oil products: Buyers of oleochemicals, biodiesel feedstocks, PFAD, and other derivatives now know that these products will be subject to DSDI oversight starting September 1. They may follow the pattern of CPO buyers (who secured 100,000 tons for June shipment) and seek to secure supply before the September deadline.
For investors in plantation and downstream companies: The full list confirms that the policy will affect not only upstream palm oil producers but also downstream processors of oleochemicals and biodiesel feedstocks. Companies with exposure to these segments should assess their risk.
For consumers worldwide: Palm oil and its derivatives are in half of all packaged supermarket products, as well as in cosmetics, detergents, and biofuels. Any sustained increase in costs from the new system – whether from fees, inefficiencies, or risk premiums – will eventually reach consumer prices.
For international trade law: The publication of the regulation formalizes Indonesia’s legal framework. Trading partners may now assess whether to challenge the policy at the WTO as a potential trade barrier. The Ministry of Foreign Affairs’ defense of the policy as “governance reform” rather than a trade barrier positions Indonesia for such challenges.
Current Status (As of May 26, 2026)
| Element | Status |
|---|---|
| Trade Minister Regulation Number 25 of 2026 | PUBLISHED (May 25-26, 2026) |
| Full list of affected commodities | PUBLISHED – 21 tariff posts |
| Phase 2 scope | DEFINED – All 21 tariff posts starting September 1 |
| Export procedure | FORMALIZED – INSW portal registration; DSDI declaration |
| DSDI formal establishment | COMPLETED (May 24-25, 2026) |
| DSDI leadership | Luke Thomas Mahony appointed |
| Phase 1 start date | June 1, 2026 (confirmed) |
| Phase 1 end date | August 31, 2026 (confirmed) |
| Phase 2 start date | September 1, 2026 (confirmed) |
| Affected products (Phase 1) | CPO, 33-degree refined, 24-degree refined |
| Affected products (Phase 2) | All 21 tariff posts |
| Additional fees (Phase 1) | NONE |
| Additional fees (Phase 2) | POTENTIAL – not yet specified |
| Market response (initial) | Malaysia futures volatile; Indian buyers purchased 100,000 tons |
| Price spread | Indonesian CPO at discount to Malaysian |
| Government defense of policy | Issued – governance reform, not trade barrier |
| Singapore’s response | NOT YET REPORTED |
What to Watch For (Updated Timeline)
| Event | Expected Timing | Significance |
|---|---|---|
| Phase 1 implementation begins | June 1, 2026 | Documentation requirements take effect for CPO and specific refined oils |
| Market reaction to full list | Coming days | May affect pricing for oleochemicals, biodiesel feedstocks, PFAD |
| Phase 2 fee announcement | Before September 1, 2026 (potential) | Could significantly affect exporter margins |
| Phase 2 full implementation | September 1, 2026 | DSDI takes control of contracts, shipments, payments for all 21 products |
| Singapore official response | Unknown | Could affect diplomatic and trade relations |
| Potential WTO challenge | Unknown | Trading partners may challenge state monopoly |
Sources
- Indonesia Ministry of Trade – Trade Minister Regulation Number 25 of 2026 (May 25/26, 2026) – Official list of 21 tariff posts subject to DSDI export system; export procedure through INSW portal
- Jakarta Globe (May 24-25, 2026) – “Indonesia’s New State-Owned Export Agency DSDI Takes Shape as Palm Oil Market Reacts” – DSDI formal establishment, two-phase timeline, Luke Thomas Mahony appointment
- Jakarta Globe (May 24-25, 2026) – “Market Response to Indonesia’s Palm Oil Export Policy: Indian Buyers Secure 100,000 Tons for June” – Indian purchases, price spread, earnings sensitivity analysis
- Jakarta Globe (May 24-25, 2026) – “Indonesia Defends New Export System as Trade Governance Reform Amid Market Volatility” – Ministry of Foreign Affairs statement, no fees in Phase 1, potential fees in Phase 2
- Previous article: Indonesia’s Palm Oil Export Crackdown Enters Implementation Phase: New State Agency DSDI Formally Established, Two-Phase Rollout Confirmed (The 5 Ws, May 25, 2026) – Baseline information on DSDI establishment, two-phase timeline, initial affected products
- Previous article: Indonesia’s Palm Oil Export Crackdown: $150 Billion Annual Revenue Leakage Alleged as New Centralized System Launches (The 5 Ws, May 23, 2026) – Baseline information on investigation findings, revenue leakage estimate
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