Approved in 2013, the law’s burdensome testing and certification requirements prevented more than 100 containers of toys from entering Indonesia last November.  As a result, full implementation was delayed while Indonesian officials considered an amendment to the standard that would make its requirements more feasible for companies and more closely aligned with international practice.  

As previously reported, the Toy Industry Association (TIA) – along with a coalition of manufacturers and officials from the U.S., Danish, British and Japanese embassies – had seemingly reached an agreement with senior members of the Indonesian government and its national standards body to delay implementation by an additional six months. However, that decision has been recently countermanded by the Minister of Industry based on what appear to be political reasons.

Toy companies currently exporting to Indonesia should now be prepared to comply with the following requirements:

·         Customs manifests (Form BC.1.1) for covered categories received by Indonesian Customs on or after April 30, 2014 will require accompanying Indonesian National Standard (SNI) documentation and must be labeled with the SNI mark (with specifically-assigned SNI number). If compliance is not met, the shipment is subject to re-exportation. If this occurs, TIA suggests abandoning the goods as an alternative, if this is economically feasible, to apply added pressure to the Indonesian authorities to modify the standard.

·         Covered products landing in Indonesia on or after April 30, 2014 must have an SNI certificate and be labeled with the SNI mark; to obtain the certificate and mark, the product must be sampled and tested to the new Indonesian national toy standard (a modification of ISO 8124, with additional azo dye, phthalate, and formaldehyde limits) by a laboratory that has a memorandum of understanding with a designated Indonesian appointment body (“LSPro”) and has been approved and listed by the MoI.

·        Every lot of imported product must be sampled and tested separately. 

·      All products in Indonesian retail stores as of April 30, 2014 will need to be removed from store shelves to be retested to the new Indonesian national toy standard and labeled with the SNI mark. Products already in commerce in Indonesia will be treated as a single lot for sampling and testing purposes.

To help toy companies meet compliance, TIA is providing a list of appointment bodies and approved testing laboratories, as well as the MoI Laboratory Appointment Regulation text.

TIA and its partners will continue to advocate with Indonesian officials on the global toy industry’s behalf; members will be kept apprised as further updates develop.  In the meantime, specific questions can be directed to Al Kaufman, TIA’s senior vice president of technical affairs .