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The EUDR has been postponed for the second time and will now take effect on 30 December 2026 for large enterprises (as operators) and 30 June 2027 for small businesses (SMEs).
Processed Natural Rubber — an SDA Commodity

PROCESSED NATURAL RUBBER

MUST RETAIN 100% OF DHE FOR 1 YEAR

Applies to exports with a per-PPE value above USD 250,000, under Government Regulation No. 21/2026 (the Third Amendment to GR No. 36/2023), effective 1 June 2026.

Retention
100%
of DHE in the Special Account
Duration
1 Year
equal to 12 months
Value Threshold
> USD 250,000
export value per PPE
Rupiah Conversion
Max 50%
the remainder may stay in foreign currency
The old rule 30% for 3 months no longer applies
Crumb Rubber / TSNR RSS Concentrated Latex
Key Provisions of Government Regulation No. 21/2026

Government Regulation No. 21/2026 is the Third Amendment to GR No. 36/2023 on Export Proceeds (DHE) from the exploitation, management, and/or processing of Natural Resources. It takes effect on 1 June 2026.

  1. Natural-resource exporters must repatriate 100% of their DHE into the Indonesian Financial System. The covered sectors include mining, plantation, forestry, and fisheries.
  2. Natural rubber (TSR20, RSS, Latex, Crepe) falls under the plantation (non-oil-and-gas) natural-resource group, so it remains subject to the DHE SDA obligation.
  3. Retention rules relevant to rubber commodities (non-oil-and-gas):
    • Applies to DHE with a per-PPE value above USD 250,000.
    • Must be placed in a Special Account (REKSUS) for 1 year (12 months).
    • May be converted to Rupiah up to a maximum of 50% (previously up to 100%).
  4. DHE is generally placed through state-owned banks (Himbara); conversion to Rupiah is done at appointed foreign-exchange banks.
  5. Special treatment (Article 18A) is available to exporters whose buyers are from countries that have a trade agreement, understanding, or cooperation with Indonesia.
  6. Incentive: income from DHE SDA placement instruments is subject to a lower Income Tax (PPh) rate, down to 0%, depending on the placement period.
  7. Transitional provision: PPEs issued before 1 June 2026 follow the previous rules and are not applied retroactively.
Policy Objectives & Impact for Rubber Exporters

Policy objectives

  1. Keep export proceeds within the country.
  2. Strengthen development financing, especially investment and working capital for natural-resource downstreaming.
  3. Strengthen national economic resilience amid global uncertainty.
  4. Maintain macroeconomic stability and deepen the domestic financial market.
  5. Still provide flexibility for international trade.

Practical impact for rubber exporters

  • DHE placement remains mandatory — rubber exporters must comply with the DHE SDA rules.
  • There is room for relaxation if the buyer country has trade cooperation with Indonesia.
  • Conversion to Rupiah is capped at 50%, so part of the proceeds may be kept in foreign currency during the retention period.
  • Monitor implementing rules from Bank Indonesia, the Ministry of Finance, and OJK technical guidelines that set the operational details.
Government Regulation No. 21/2026

Third Amendment to GR No. 36/2023 on DHE SDA

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