Indonesia mandates state approval for 2027 ferroalloy exports

Beginning 1 January 2027, declarations covering coal, palm oil and ferroalloys must be submitted through Indonesia’s NADI portal before reaching customs. They can proceed only after approval by PT Danantara Sumberdaya Indonesia (DSI), a subsidiary of sovereign wealth fund Danantara. Coordinating Minister Airlangga Hartarto describes DSI as the “sole intermediary”. In practice, the ferroalloys category in the statistics is almost entirely about nickel: ferronickel accounted for more than US$16.3 billion in 2025, nearly the full export value reported for the category. Under a customs decree’s broad definition, virtually any nickel pig iron (NPI) containing at least 2% nickel is included. In the most recent reporting period, China received 98% of Indonesia’s ferronickel exports.

Unclear Fees, Expansive Nickel Powers

Although the new fees take effect on 1 January, their amounts have yet to be disclosed, and payment is required before the customs declaration is filed. It is also unclear when approvals must be obtained or which price indices will apply to nickel products. Smelter association FINI cautions that the charges should not “erode margins,” while Jakarta defends the regime as a response to under-invoicing and transfer pricing. DSI does not currently purchase or negotiate transactions; it approves them and, after shipments have been made, verifies volumes and prices against the relevant indices. Government Regulation PP 24/2026 nevertheless authorises it to do more, including exporting as the owner, determining sale prices and retaining a margin. Jakarta is not exercising those powers at present, but they remain enshrined in the legislation.

Functional testing begins on 15 November, followed by registration on 15 December. Around 100 exporters have already tested the system. Will the state remain an inspector or become a price setter? The answer will emerge first in Chinese NPI prices, then in stainless steel costs. The EU and the UK will meet in Brussels on 20 November. According to media reports, the draft summit declaration states that negotiations to link their emissions trading systems have concluded. Goods from both sides are to be exempt from their respective CBAMs. Some reports even suggest that the exemption could apply retroactively from January 2026. The draft, however, states that exemptions will apply only in accordance with the respective laws and procedures. Other media reports indicate that the text contains no provision for retroactive application and that further legal acts are required. This is consistent with the CBAM Regulation: a third country is exempt only once its emissions trading system is actually linked and the Commission adds it to the exemption list in the relevant annex through a delegated act.

• Functional testing begins on 15 November, followed by registration on 15 December.
• Around 100 exporters have already tested the system.
• Whether the state remains an inspector or becomes a price setter will emerge first in Chinese NPI prices, then in stainless steel costs.
• The EU and the UK are due to meet in Brussels on 20 November.
• Media reports say the draft summit declaration states that negotiations to link their emissions trading systems have concluded.
• The draft says goods from both sides are to be exempt from their respective CBAMs, subject to respective laws and procedures.
• Some reports suggest the exemption could apply retroactively from January 2026.
• Other media reports say the text has no provision for retroactive application and further legal acts are required.
• The CBAM Regulation permits exemption only after actual emissions trading system linkage and a Commission delegated act adds the third country to the relevant annex’s exemption list.

A blanket exemption could create a back door to the single market, so full alignment seems unlikely. Instead, we expect only the UK’s CO2 price to be credited. Specialist publications report that the UK’s CBAM calculates liabilities much more leniently than its European counterpart. The rules governing the crediting of foreign CO2 prices in third countries are intended to address precisely this issue. The Commission adopted them on 5 November, as we reported, but they are still not publicly available.