INDONESIA Trends and Developments Contributed by: Vovo Iswanto, Albert Boy Situmorang, Wisnu Wardhana and Ingrid Gratsya Zega, Assegaf Hamzah & Partners
Product Safety in Indonesia (2026): Recalls, Halal Compliance and Trade-Driven Regulatory Change Indonesia’s product liability and safety landscape is entering a period of heightened scrutiny, shaped by tighter sectoral oversight, expanding compliance regimes and greater cross-border regulatory interac - tion. While Indonesia has a single, overarching Law No 8 of 1999 on Consumer Protection (“CP Law”), it has multiple regulators exercising supervisory and enforcement authority depending on the relevant sec - tor. In some industries, sectoral regulators have issued detailed implementing regulations that supplement the CP Law, while in others the regulatory framework continues to rely largely on the general provisions of that law without sector–specific elaboration. Against such backdrops, authorities are placing renewed emphasis on traceability, transparent correc - tive action and supply-chain accountability. The devel - opments below highlight three areas likely to drive risk and compliance priorities in 2026: (i) the specific recall mechanism in the motor vehicle sector; (ii) the scope and enforcement of mandatory halal product assur - ance as it moves into its next implementation phase; and (iii) the potential consumer-protection implications of a reciprocal trade framework between Indonesia and the United States. Product liability in the motor vehicle sector Product liability and consumer protection are critical issues in modern commerce, particularly in industries where defective goods can pose significant risks to public safety. In Indonesia, the framework for con - sumer protection is established under CP Law, which places clear obligations on business actors to ensure the safety and integrity of the products they trade. Legal basis for product recall Article 8 (2) of the CP Law explicitly prohibits busi - ness actors from trading damaged, defective, used, or contaminated goods on the market without full and accurate disclosure to consumers. Non-compliance with this provision gives rise to a mandatory product recall under Article 8 (4) of the CP Law. This recall mechanism functions both as a consumer protection measure and as a means of enforcing responsibility and compliance among business actors.
Special regulation in the motor vehicle sector Given its scale and implications for public safety, the automotive industry is subject to sector-specific regu - latory oversight. Motor vehicle recalls are governed by the Regulation of the Minister of Transportation No PM 53 of 2019 on the Procedure for Motor Vehicle Product Recall (“MOTR 53/2019”). Under the MOTR 53/2019, provisions related to the recall of the motor vehicle may be carried out by the assembler, manufacturer, importer, distributor, or brand holder of the motor vehi - cle in Indonesia (“Business Actors”). Furthermore, MOTR 53/2019 establishes the mecha - nism for Business Actors to conduct product recalls, by requiring them to carry out the following steps: (i) submit a recall plan to the Ministry of Transportation (“MOT”) at least 14 days before implementation; (ii) formally notify affected consumers of the recalled motor vehicle; (iii) inspect and remedy the recalled products; and (iv) report the results of the recall to the MOT. The recall plan that must be submitted to the MOT, as mentioned above, must at a minimum contain the following information: (i) the name of the company, (ii) address, (iii) brand/type, (iv) period of manufacture/ assembly year, (v) number of vehicles, (vi) issues, (vii) impact of the defect, (viii) reporting period), and (ix) method of notification to consumers. Furthermore, the report on the results of the recall must be submitted to the MOT at least twice a year for a period of two years from the date on which the product recall is determined. These requirements are intended to ensure transpar - ent and effective recall implementation. In urgent cir - cumstances, however, a recall may be initiated prior to the submission of the recall plan to the MOT. This exception reflects the principle of prioritising consum - er safety, whereby immediate action to prevent harm takes precedence over administrative formalities. This urgent-recall mechanism serves two important functions:
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