In the complex landscape of international trade, importers often encounter situations where the final value of their goods cannot be determined at the exact moment of customs clearance. To address this, the Indonesian government has established the Customs Voluntary Declaration Procedure. This mechanism allows businesses to remain compliant by proactively declaring estimated values or additional costs that are part of the customs value but are not yet finalized. According to Peraturan Menteri Keuangan Nomor 201/PMK.04/2020, a Voluntary Declaration (VD) is an initiative taken by importers, entrepreneurs in Free Trade Zones (FTZ), or Bonded Storage Facility (TPB) operators to disclose estimated values that cannot yet be determined or specific costs that must be added to the transaction value.

The Customs Voluntary Declaration Procedure serves as a vital tool for maintaining transparency and avoiding administrative sanctions. By utilizing this procedure, importers can ensure that the import duties and taxes paid are accurate, even when variables like royalties, proceeds, or future prices are still in flux. This article provides a comprehensive operational guide on how to navigate the documentation and filing process across different customs jurisdictions in Indonesia.

How to File a Customs Voluntary Declaration Procedure

Filing a Customs Voluntary Declaration Procedure is a mandatory obligation for importers who are aware that their transaction value involves elements that cannot be finalized at the time of import. The procedure begins with the identification of specific cost elements that fall under the VD umbrella. According to the regulatory framework, there are six primary substances that qualify for a voluntary declaration.

The Six Substances of Voluntary Declaration

When an importer prepares their declaration, they must assess whether any of the following six elements apply to their shipment:

1. Future Price (Harga Future): This refers to the price that should be paid in a sale-purchase transaction based on commodity exchange prices. This typically applies to commodity goods traded on futures markets where a written contract exists between the seller and the buyer, but the final price is determined at a later date.
2. Royalty/License: These are fees that a buyer must pay, either directly or indirectly, as a condition of the sale of the imported goods. These costs are linked to Intellectual Property Rights (HAKI) contained within the imported items.
3. Proceed: This represents the value of any part of the proceeds from any subsequent resale, disposal, or use of the imported goods that accrues directly or indirectly to the seller.
4. Assist: This involves the value of goods and services supplied directly or indirectly by the buyer to the seller, free of charge or at a reduced cost, for use in connection with the production and sale for export of the imported goods. This must be based on objective and measurable data.
5. Freight: The cost of transporting the imported goods to the place of import in the customs territory. While often known, there are cases where final freight adjustments occur after the initial PIB declaration.
6. Insurance: The cost of insuring the goods during transport from the place of export to the place of import. Like freight, this must be supported by written contracts or objective evidence.

To successfully file the declaration, the importer must include these estimations in the relevant customs document. The Customs Voluntary Declaration Procedure requires the importer to not only declare the existence of these elements but also to provide a reasonable estimation of their value based on available contracts or historical data.

Types of PPI: PIB, PPFTZ-01, and PPI TPB

The implementation of the Customs Voluntary Declaration Procedure varies depending on the legal status of the importer and the destination of the goods. The declaration is integrated into the Pemberitahuan Pabean Impor (PPI) or Import Customs Declaration. There are three primary document types used for this purpose:

Filing the PIB Declaration

For most businesses, the PIB declaration is the standard route. When filling out the PIB electronically, the importer must select the Voluntary Declaration facility. They are required to input the estimated values for the relevant substances (such as Royalties or Assists). By doing so, the system calculates the estimated import duty and taxes. This proactive step prevents the importer from being flagged for under-declaration during a later audit.

Utilizing the PPFTZ-01 Document

Entrepreneurs operating within Free Trade Zones must use the PPFTZ-01 document. The Customs Voluntary Declaration Procedure in these zones is specifically tailored to the unique tax-exempt status of the area. However, if the goods are eventually moved to the domestic market, the VD values become crucial for the final calculation of duties.

The PPI TPB Procedure

For goods stored in Bonded Storage Facilities (Tempat Penimbunan Berikat), the PPI TPB procedure is used when the goods are cleared for domestic consumption. This is particularly common for manufacturers who import raw materials and pay royalties based on the final sales of the finished products. The VD allows them to declare these royalties even if the final sales figures are not yet known at the time of the goods’ release from the warehouse.

Monitoring and Evaluation under PER Number 12/BC/2023

Once a Customs Voluntary Declaration Procedure has been filed and the goods have been released, the process does not end there. The Indonesian Customs authority (Bea Cukai) maintains a rigorous oversight mechanism. This is governed by Peraturan Direktur Jenderal Bea dan Cukai Nomor 12/BC/2023, which provides the technical instructions for the monitoring and evaluation of Voluntary Declarations and Voluntary Payments on Customs Valuation.

Under this regulation, Customs officials will monitor the transition from the “estimated value” declared in the PIB declaration or PPFTZ-01 document to the “actual value” once it becomes known. The importer is required to settle the difference (Voluntary Payment) within a specified timeframe. The evaluation process ensures that:

• The data provided in the initial declaration was objective and measurable.
• The settlement of duties was done voluntarily before any customs audit or investigation commenced.
• The calculation of the final transaction value aligns with international customs valuation standards.

Failure to follow through with the monitoring process or failing to pay the difference once the actual value is determined can lead to the loss of the right to use the VD facility and may result in administrative penalties. Therefore, maintaining a detailed log of all VD-related transactions is a best practice for any compliant importer.

Using the Manual VD Form for Non-Accommodated Declarations

While the Indonesian Customs system is highly digitized, there are instances where the electronic system might not yet fully accommodate specific types of voluntary declarations. The Customs Voluntary Declaration Procedure includes a contingency plan for such scenarios. As noted in the official guidelines, if the electronic PPI system (whether for PIB, PPFTZ-01, or PPI TPB) cannot process the declaration, the importer may use the Formulir Deklarasi Inisiatif (Manual Voluntary Declaration Form).

This manual form serves as a formal notification to the Customs office that the importer is declaring an estimated value. It must be submitted alongside the standard customs declaration. The use of this form ensures that the importer’s intent to be transparent is legally recorded, even if technical limitations exist within the digital portal. This is particularly relevant for complex PPI TPB procedure filings where multi-layered royalty structures might be difficult to input into standard electronic fields.

Key steps when using the manual form include:

• Clearly identifying the import document (PIB/PPFTZ-01/PPI TPB) it refers to.
• Detailing the specific substance (e.g., Assist or Proceed) and the reason why the value is currently an estimate.
• Providing the methodology used to arrive at the estimated figure.
• Attaching supporting documents like contracts or price formulas.

Conclusion

The Customs Voluntary Declaration Procedure is an essential mechanism for modern importers in Indonesia, providing a legal pathway to handle uncertainties in customs valuation. By correctly identifying the substances of VD—such as future prices, royalties, and assists—and utilizing the appropriate PIB declaration, PPFTZ-01 document, or PPI TPB procedure, businesses can significantly reduce their risk of non-compliance. Guided by PMK Nomor 201/PMK.04/2020 and PER Number 12/BC/2023, this procedure empowers importers to take control of their customs obligations, ensuring that even when values are estimated, the commitment to transparency remains absolute.