TKDN POLICY UPDATE 2025 AND 2026
Changes under Minister of Industry Regulation No. 35 of 2025 and Directorate General of Chemical, Pharmaceutical and Textile Industry Regulation No. 13 of 2026
This article provides an overview of the latest TKDN policy updates under Minister of Industry Regulation No. 35 of 2025 and the technical regulatory developments in 2026, with particular relevance to the paint industry.
Minister of Industry Regulation No. 35 of 2025: The Latest Regulatory Framework
One of the key developments is the issuance of Minister of Industry Regulation No. 35 of 2025 concerning the Requirements and Procedures for Certification of Domestic Component Level (TKDN) and Company Benefit Weight (BMP).
The regulation was enacted and promulgated on September 11, 2025, and came into effect on December 11, 2025. It replaces several previous TKDN regulations and establishes a new framework for TKDN calculation and certification.
This policy reform is intended to make the TKDN process simpler, faster, more transparent, and more beneficial for the development of domestic industries.
Changes in TKDN Calculation
For manufactured goods, Minister of Industry Regulation No. 35 of 2025 establishes the following calculation structure:
- 75% main components
- 10% direct labor
- 15% factory overhead
The regulation also introduces provisions governing the treatment of main components, both those that have obtained TKDN certification and those that have not.
It is important to note that a 25% TKDN value is not automatically granted to every product. The final TKDN value remains subject to the applicable calculation structure and regulatory requirements.
Main Component Requirements
Minister of Industry Regulation No. 35 of 2025 provides more detailed provisions regarding main components used in TKDN calculations.
For main components that have obtained TKDN certification, a specific weighting mechanism applies based on the TKDN value of each component. Meanwhile, main components without TKDN certification are subject to separate provisions based on their domestic production status and the source of materials used.
Therefore, companies need to consider the origin of components, the production process, and the applicable sector-specific requirements, rather than simply where a component is purchased.
2026 Update: Directorate General of Chemical, Pharmaceutical and Textile Industry Regulation No. 13 of 2026
In 2026, further sector-specific updates were introduced for the chemical, pharmaceutical, and textile industries through Directorate General of Chemical, Pharmaceutical and Textile Industry Regulation No. 13 of 2026.
This regulation constitutes the second amendment to Directorate General of Chemical, Pharmaceutical and Textile Industry Regulation No. 3 of 2025, concerning the details of main components for goods used in TKDN calculations.
Regulation No. 13 of 2026 was enacted in Jakarta on July 30, 2026, and came into effect on the date of its enactment.
The update is particularly relevant to the paint industry because it provides more specific details on the main components used as the basis for TKDN calculations for paint products.
Main Components of Paint Products
Under the latest regulation, Primary Packaging is explicitly listed as one of the main components for paint products.
The main components are as follows:
1. Water-Based Paint
- Resin
- Pigments
- Solvents
- Fillers
- Additives
- Primary Packaging
2. Solvent-Based Paint
- Resin
- Pigments
- Organic Solvents
- Fillers
- Additives
- Primary Packaging
3. Powder Coating
- Resin
- Pigments
- Fillers
- Additives
- Primary Packaging
All three product categories are listed under KBLI 2020 20221 and KBLI 2025 20221.
What Should Paint Manufacturers Consider?
With the regulatory updates introduced in 2025 and 2026, paint manufacturers should review their TKDN structure, particularly by:
- Ensuring that the main components used are consistent with the latest applicable list.
- Reviewing the status and origin of each component.
- Reassessing the production cost structure in accordance with the applicable TKDN calculation requirements.
- Maintaining proper documentation of materials, labor, and production costs.
- Aligning certification documents and application processes with the latest regulatory requirements.
- Identifying opportunities to increase the use of domestic components and resources.
Conclusion
Minister of Industry Regulation No. 35 of 2025 establishes an important new framework for TKDN calculation and certification, while Directorate General of Chemical, Pharmaceutical and Textile Industry Regulation No. 13 of 2026 provides more specific updates on the main components applicable to the chemical, pharmaceutical, and textile industries.
For the paint industry, one of the key developments is the inclusion of Primary Packaging as a main component for Water-Based Paint, Solvent-Based Paint, and Powder Coating.
Manufacturers should ensure that their material composition and production processes are aligned with the latest requirements to support accurate TKDN calculations and certification.
Overall, the 2025–2026 TKDN regulatory developments involve not only changes to the certification and calculation framework but also more specific requirements concerning the main components applicable to individual industry sectors.
👉 The Domestic Component Level (TKDN) policy has undergone several important updates that should be considered by industry players. For a detailed explanation of the basic concepts, benefits, and requirements of TKDN, please visit the Domestic Component Level (TKDN) & Related Regulations page provided by IPMA.