Alert: Onerous New Indonesian National Standard for Toys to Go into Effect April 30

28 April 2014

Beginning on 30 April 2014, toy companies that export products to Indonesia will be required to comply with a new Indonesian National Standard for Toys (SNI Regulation 24/M-IND/PER/4/2013) that calls for additional sampling, testing, labeling and import documentation.

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.

The U.S. 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 30 April 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, it is encouraged to abandon 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 30 April 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 30 April 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 ensure compliance, toy companies are encouraged to consult this list of appointment bodies and approved testing laboratories, as well as the MoI Laboratory Appointment Regulation text.

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