In the complex landscape of international trade, determining the correct Indonesian Customs Valuation is a critical responsibility for every importer. Customs valuation serves as the foundation for calculating import duties and taxes, ensuring that the state receives its fair share while maintaining a level playing field for businesses. However, the transactional nature of global commerce often means that the final price of goods is not always set in stone at the moment the goods cross the border. To address these uncertainties, the Indonesian Directorate General of Customs and Excise (DGCE) provides a mechanism known as Voluntary Declaration (VD).

Under the framework of PMK Nomor 201/PMK.04/2020 concerning Voluntary Declaration and Voluntary Payment, VD is defined as a proactive disclosure by importers regarding estimated values that cannot yet be determined at the time of import. This mechanism is essential for handling costs that must be added to the transaction value but are subject to fluctuations or post-import calculations. By understanding the six core substances of VD, businesses can ensure full compliance and avoid the risks of administrative sanctions or valuation disputes during customs audits.

Understanding Transaction Value Adjustments in Indonesian Customs Valuation

The core principle of Indonesian Customs Valuation is the transaction value—the price actually paid or payable for the goods when sold for export to the customs territory. However, the transaction value is not always limited to the invoice price. According to PMK Nomor 201/PMK.04/2020, there are specific elements known as “adjustments” that must be added to the price if they are not already included.

Voluntary Declaration is specifically designed for situations where these adjustments are mandatory but their exact numerical value is unknown at the time the Import Declaration (PIB) is filed. Importers, operators in Free Trade Zones (FTZ), and those in Bonded Storage Facilities (TPB) are required to notify and estimate these values through the VD system. This process ensures that the customs value reflects the true economic worth of the imported goods.

The Legal Basis for VD Substances

The implementation of VD is governed by two primary regulations:

• PMK Nomor 201/PMK.04/2020: This Ministerial Regulation establishes the legal framework for Voluntary Declaration and Voluntary Payment.
• Peraturan Direktur Jenderal Bea dan Cukai Nomor 12/BC/2023: This provides technical guidelines for the monitoring and evaluation of Voluntary Declarations and Voluntary Payments on customs valuation.

By adhering to these rules, importers can manage financial risks associated with future price customs, customs royalties, and other post-importation costs.

Future Price and Royalties in Customs Valuation

Two of the most common substances handled through Voluntary Declaration are future prices and royalties. These elements are often contingent on market conditions or intellectual property agreements that extend beyond the initial import date.

1. Future Price (Harga Future)

In the context of future price customs, this refers to the price that should be paid in a sale and purchase transaction based on commodity prices. This is typical for goods traded on commodity exchanges where the final price is determined by a formula linked to market rates at a specific future date (e.g., the average price of the month of arrival). For a future price to be eligible for VD, there must be a written contract between the seller and the buyer explicitly stating the pricing formula.

2. Customs Royalties and License Fees

Customs royalties are costs that must be paid by the buyer, either directly or indirectly, as a condition of the sale of the imported goods containing Intellectual Property Rights (IPR). These fees are added to the transaction value if they relate to the goods being imported. Because royalty payments are often calculated based on subsequent sales in the Indonesian market, the exact amount is frequently unknown at the time of importation, making it a primary candidate for Voluntary Declaration.

Substance	Requirement	Basis for Calculation
Future Price	Written Contract	Commodity exchange rates / Market formulas
Royalties	Condition of Sale	Percentage of revenue or fixed fee per unit

The Role of Assists and Proceeds in Import Costs

Beyond the direct price of the goods, Indonesian Customs Valuation must account for indirect contributions and future earnings that benefit the seller. These are categorized as assists and proceeds.

3. Customs Assist

An assist refers to 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 includes:

• Materials, components, and parts incorporated into the imported goods.
• Tools, dies, and molds used in the production.
• Materials consumed in the production.
• Engineering, development, artwork, and design work undertaken outside of Indonesia.

The valuation of an assist must be based on objective and measurable data. If the exact value of the assist cannot be determined at the time of import—perhaps because the production cycle is ongoing—the importer must declare an estimate via VD.

4. Proceeds

Proceeds represent the value of any part of the revenue generated from the subsequent resale, disposal, or use of the imported goods that accrues directly or indirectly to the seller. Similar to royalties, proceeds are often unknown at the time of import because they depend on the importer’s future sales performance. If there is a contractual obligation to share a portion of the domestic profit with the foreign exporter, this amount must be captured in the Indonesian Customs Valuation through a Voluntary Declaration.

Calculating Freight and Insurance for Voluntary Declaration

Logistics costs are fundamental components of the CIF (Cost, Insurance, and Freight) value used in Indonesia. While many shipments have fixed freight and insurance costs, certain arrangements require these to be estimated.

5. Freight

Freight is the cost of transporting the goods from the place of export to the place of import within the Indonesian customs territory. In some global logistics contracts, the final freight cost might include surcharges (such as fuel adjustment factors or peak season surcharges) that are only finalized after the ship has departed or arrived. Under Peraturan Direktur Jenderal Bea dan Cukai Nomor 12/BC/2023, if the final freight invoice is unavailable, the importer must use an estimate based on objective data or written contracts.

6. Insurance

Insurance refers to the cost of insuring the goods during transport from the place of export to the place of import. For companies using global marine insurance policies where premiums are calculated periodically based on total shipment volume, the specific insurance cost for a single PIB might be an estimate at the time of filing. This estimate must be declared as part of the VD substance to ensure the Indonesian Customs Valuation remains accurate.

Summary of VD Substances and Documents

When filing a VD, the information is integrated into the following customs documents depending on the importer’s status:

• PIB (Pemberitahuan Pabean Impor untuk Dipakai): For general imports for consumption.
• PPFTZ-01: For goods entering Free Trade Zones and Free Ports.
• PPI TPB: For goods released from Bonded Storage Facilities for local consumption.

Note: If the standard customs declaration form does not yet accommodate the Voluntary Declaration, a specific Voluntary Declaration Form may be used as a supplement.

Conclusion

Mastering the nuances of Indonesian Customs Valuation is essential for any business engaged in international trade with Indonesia. The Voluntary Declaration mechanism, as outlined in PMK Nomor 201/PMK.04/2020, provides a vital pathway for importers to remain compliant even when facing price uncertainties. By accurately identifying and declaring substances such as future price customs, customs royalties, assists, and proceeds, businesses can proactively manage their tax obligations and build a transparent relationship with the Directorate General of Customs and Excise.