Importing a Pressure Vessel into Indonesia: What Permenaker 37/2016 Requires Before First Use

Indonesia examines the vessel after it arrives

An imported pressure vessel in Indonesia comes under Ministry of Manpower Regulation No. 37 of 2016 (Permenaker 37/2016) on the occupational safety and health of pressure vessels and storage tanks. The regulation provides first examinations at the planning and manufacturing stages (Pasal 71(1)(a) and (b)), but it says nothing about how those apply to a vessel built abroad, and it contains no import clause. What it plainly does provide for an arriving vessel is the examination "before it is used or has never been examined and/or tested" (Pasal 71(1)(c)) and the examination on installation (Pasal 71(1)(d)), which in practice means in Indonesia, where the vessel and the examiners are. Each is done by a Specialist Labour Inspector or a Minister-appointed pressure vessel expert, includes a hydrostatic test at 1.5 times the permitted working pressure or the design pressure, and runs on the document set the manufacturer put in the crate. Under Pasal 85, a vessel that does not meet the requirements is dismantled or cut up.

In front of that sits a second gate that has nothing to do with safety. A mining licence holder buying capital equipment must, under Pasal 30 of the Energy Ministry's mining regulation Permen ESDM 25/2018, prioritise the domestic product, meet stated conditions before importing, and carry the purchase plan in its annual work plan and budget. That gate sits in front of the order before the safety regime reaches the vessel.

This is the fourth article in our jurisdiction series, after Australia, Singapore and Zambia. It is written from the buyer's side, from the regulation's text as at September 2026, and it says where the text is silent. Classification of any particular vessel is for the inspecting authority, not a supplier, to state.

What Indonesia's pressure vessel regulation actually covers

Permenaker 37/2016 was promulgated on 27 December 2016 and replaced the 1982 pressure vessel regulation. Its legal basis is the Occupational Safety Act of 1970 (UU 1/1970), whose scope expressly includes workplaces where metal ores are mined or processed. The regulation covers the whole life of a vessel, from planning and manufacture through use, repair and modification to examination and testing.

The threshold is low. Under Pasal 5(2) a pressure vessel is in scope at a pressure of more than 1 kg/cm² and a volume of more than 2.25 litres. Pasal 5(1) names five classes: gas and gas-mixture storage vessels, vehicle fuel-gas vessels, transport vessels, process vessels (bejana proses), and refrigeration apparatus. A filter for a process liquid reads naturally as a process vessel, a term the regulation lists but does not define. The definition that sits above the list is where the reading gets less ordinary.

Is a liquid-duty filter a "bejana tekanan"? The definition is written around gas

Pasal 1(1) defines a pressure vessel as a vessel, other than a steam apparatus, that contains pressure and is used to hold gas, air, a gas mixture or an air mixture, whether compressed to liquid, dissolved or frozen. Read alone, that sentence describes a cylinder or a receiver. It does not obviously describe a vessel full of hot copper electrolyte.

Two things pull a liquid-duty filter back inside. The first is the regulation's own category of process vessel. The second is practice: at least one Indonesian K3 inspection company lists heat exchangers, reactors and separators, vessel types that are commonly liquid-filled, among the vessels it examines under this regulation. A pressure filter that is blown down or cake-dried with compressed air also holds air under pressure for part of every cycle, which arguably brings it inside the literal words as well.

Set that next to the two jurisdictions we have already covered. Zambia's Factories Act reaches a vessel in which oil is forced out by compressed air, and Singapore's equivalent limb reaches any liquid or solid; the gap between those two is set out in our Zambia article on the Factories Act and SI 68. Indonesia draws a third line, around the gas itself, and then adds a process-vessel class the line does not mention. Three regimes, three scope tests, one machine.

Our advice is the same in all three: get the classification in writing from the inspecting authority for your configuration, and until you have it, plan on the vessel being examined. The cost of an unnecessary examination is the examination. The cost of a necessary one that was skipped is Pasal 85.

The first examination: what happens before the vessel may be used

Pasal 70 sets out four kinds of examination: first, periodic, special (after an accident, fire or explosion) and repeat (where an earlier result is in doubt). An imported vessel meets two of the first-examination triggers, "before use" under Pasal 71(1)(c) and installation under Pasal 71(1)(d); Pasal 74 repeats the internal and external inspection, the NDT and the 1.5 times hydrostatic test for installation, and whether one visit covers both triggers is for the inspector. Pasal 73(1) lists what the before-use examination covers, and the list reads as a packing list for the document crate:

• the construction and installation drawings;

• the material certificates and other particulars;

• the manufacturing data record;

• for a process vessel, a description of how it works;

• the external and internal parts of the vessel;

• the technical dimensions;

• non-destructive testing;

• a hydrostatic test.

The hydrostatic test pressure under Pasal 73(2) is 1.5 times the permitted working pressure or the design pressure, or the figure in the regulation's appendix. Under Pasal 73(3) the vessel must not sweat or leak, and must not take a permanent set that increases its volume by more than 0.2 per cent.

Two design consequences follow, and both are cheap at the drawing stage and expensive on a vessel that has already landed.

First, the examination includes the internal parts. A vessel that cannot be opened for internal inspection in the field cannot complete the examination as written. For a horizontal pressure filter, the closure that opens the vessel for cake discharge also gives the inspector the access the regulation asks for.

Second, the regulation does not say, in the text we read, that a hydrostatic test witnessed at the manufacturer's works abroad stands in place of the Pasal 73 test. It may be accepted; we could not find the words that say so. The safe assumption is a second test in Indonesia at 1.5 times, so the design should carry the test connections, vents and blind flanges to do it without improvisation, with the internals and cloths out.

Who examines, and what you get at the end

Pasal 79 gives the examination to two kinds of person: the Specialist Labour Inspector for steam apparatus and pressure vessels, a government inspector, or an Ahli K3 in the same field, a technical specialist from outside the manpower authority appointed by the Minister. K3 service companies, known as PJK3, offer this examination commercially under the name the Indonesian market uses for it, riksa uji.

The output is not the inspector's report. Under Pasal 83 the result goes to the labour inspection unit, which issues a Surat Keterangan, a formal letter with the technical reasons on a separate sheet, in three copies: owner, local inspection unit, central unit. Pasal 84 gives it two forms, Memenuhi Persyaratan K3 (meets the requirements) or Tidak Memenuhi Persyaratan K3 (does not), and a compliant vessel receives a stamped K3 sticker.

Pasal 87 refers sanctions to the Occupational Safety Act UU 1/1970 and to the Manpower Act UU 13/2003. The 1970 Act's own penalty clause, Pasal 15(2), allows up to three months' detention or a fine of up to Rp 100,000 as the Act reads; we have not analysed the 2003 Act's sanctions. The consequence that matters is physical: under Pasal 85 a vessel that does not meet the K3 requirements is dismantled or cut up under a safe work procedure. The regulation provides for repair and modification followed by a fresh examination (Pasal 7(3), Pasal 74), but it does not say whether a vessel that has received a Tidak Memenuhi letter can take that route rather than Pasal 85; that is a question for the inspector before the examination, not after it. The regulation's own remedy for a non-compliant vessel is physical, not monetary.

What the manufacturer must have put on the vessel and in the file

The Pasal 73 list draws on requirements the regulation places on the design and manufacturing stage, and the text does not exempt a vessel whose manufacturing stage happened abroad.

Pasal 7(1) requires construction and installation drawings with the working method, a strength calculation, and materials for the main parts that carry test marks and/or a material certificate issued by an authorised body. Pasal 7(2) requires a Welding Procedure Specification and Procedure Qualification Record where the vessel is welded, manufacture in accordance with the design drawing, and a serial number. Pasal 7(5) says the WPS and PQR are evaluated by the Specialist Labour Inspector, so they need to be in the file, not at the works.

Pasal 12(5) matters for a stainless steel filter: a vessel made of any material other than carbon steel must carry test marks or a material certificate from an authorised body. Agree with the inspector before fabrication which document will be accepted, and make sure it is traceable to the plate and forgings actually used.

Then there is the marking. Among the marks Pasal 9(1) requires on a pressure vessel are: the owner's name; the manufacturer's name and serial number; the name and chemical symbol of the gas or substance it holds; the empty weight, waived for large vessels; the permitted filling pressure in kg/cm²; and the month and year of the first and each subsequent hydrostatic test. The marks must be clear, indelible and not easily removed, stamped on the thick head plate (Pasal 9(4)); a separate nameplate is allowed where stamping is not possible (9(5)); and stamping is prohibited on wall thickness under 4 mm (9(6)).

Read that list from the manufacturer's bench: the owner's name and the substance are fabrication inputs, and the nameplate needs a field for test dates someone else will add in Indonesia. All of it is far cheaper to get right before crating than after.

Periodic examination: the interval the regulation does not state for your vessel

Pasal 75 governs periodic examination and repeats most of the first-examination scope, with a hydrostatic test if the examination finds a defect. For storage tanks the interval is in the regulation itself: examination at most every two years and testing at most every five, in Pasal 75(8).

For pressure vessels, Pasal 75(1) sends the reader to the appendix, and the appendix table we could read is organised by gas type, with a test pressure and a maximum test interval against each named gas. We could not locate an interval for a process vessel in the text. One Indonesian inspection provider advertises a hydrostatic test at most every five years without citing a Pasal; another notes in its own guidance that it has not verified the specific article and recommends confirming with a pressure vessel Ahli K3. Get the interval in writing from the inspector at the first examination, and put the first periodic date in the plant register at handover.

The procurement gate: Permen ESDM 25/2018 and the domestic product

Before any of the above, an Indonesian mining licence holder has to satisfy Pasal 30 of Permen ESDM 25/2018, the Energy Ministry's mining business regulation, before importing. It applies to holders of exploration and production IUP and IUPK licences, of the IUP for processing and refining, and of mining services licences. A buyer outside those categories, such as an EPC purchasing on its own account, is outside Pasal 30 as written; other domestic-content rules may reach such a buyer, and we have not researched them. As read in the 2018 text:

• Pasal 30(1): they must prioritise domestically produced capital goods, equipment, raw materials and supporting materials.

• Pasal 30(2): where the domestic product is not available, they may buy an imported product sold in Indonesia, provided it meets quality standards and after-sales service, and can guarantee supply continuity and delivery timing.

• Pasal 30(3): where those conditions are not met, they may import the goods directly.

• Pasal 30(4): an importing licence holder must notify a list of goods purchased, temporary imports and remanufactured goods.

• Pasal 30(5): the purchase plan for capital goods and equipment must be submitted in the annual RKAB, the licence holder's work plan and budget.

• Pasal 30(6): imports may obtain import facilities under the applicable regulations.

The commercial consequence is timing. The purchase plan belongs in the RKAB for the year (Pasal 30(5)), so an order that is not in the plan is, at minimum, an order that needs the plan amended. The moment to establish that the domestic product is unavailable, and that the import belongs in the plan, is when the plant's engineers are writing the duty.

The regulation has been amended at least three times since 2018 according to the listings we could reach; those summaries concern export sale deadlines and refinery construction, not Pasal 30, but we read Pasal 30 in the 2018 text and have not verified it against each amendment. We could not fetch the BTKI 2022 customs rate for the filtering-machinery heading at source and do not quote it; confirm the tariff line and rate with your broker.

Why this matters now

Two new copper smelter and refinery complexes began commissioning in Indonesia in 2024. The one in West Sumbawa has a stated concentrate capacity of 900,000 tonnes a year and a copper cathode capacity of 222,000 tonnes a year, according to its owner's July 2024 release. The one at Gresik in East Java began commissioning in mid-2024 with cathode production to follow, according to its owner. Alongside them sits the nickel cobalt hydromet cluster, whose filtration duties are mapped in our guide to which filter goes where in a nickel cobalt hydrometallurgy plant.

Every one of those plants is a workplace under UU 1/1970 Pasal 2(2)(e), and every filter vessel that arrives at any of them meets Pasal 71(1)(c) of Permenaker 37/2016 before it is put into service.

What to put in the enquiry and the purchase order

These close the two gaps the article describes.

• Get the classification in writing from the inspecting authority for your configuration, described with and without any compressed-air blow-down step.

• Name the design code, and state the design pressure and permitted working pressure in kg/cm² as well as bar, since the regulation and the nameplate use kg/cm².

• Require the Pasal 7 and Pasal 73 document set as a deliverable in its own right: drawings, strength calculation, traceable material certificates, WPS and PQR, a manufacturing data record, and a working-method description.

• Specify the Pasal 9 marking: owner's name, manufacturer and serial, substance and chemical symbol, permitted pressure in kg/cm², and a field for hydrostatic test dates.

• Require a means of internal access, and confirm that the internals can be removed for the hydrostatic test.

• Require test connections, vents and blind flanges sized for a 1.5 times hydrostatic test in the field.

• Agree who appoints the Ahli K3 or requests the Specialist Labour Inspector, who pays, and make the Surat Keterangan a condition of handover.

• Ask the inspector, at the first examination, to state the periodic interval in writing, and record it in the plant register.

• On the Permen ESDM 25/2018 leg, establish early that the item is not available as a domestic product, and confirm the purchase sits in the RKAB for the year it is needed.

Where we sit in this

We have designed and built to ASME BPVC Section VIII Division 1, and we have designed to AS 1210, the code covered in our article on designing electrolyte filters to AS 1210. Across all applications there are approximately 1,000 units installed worldwide across 460+ installations, with 25 units in copper refining, capacities from 5 to 350 m³/hr, and repeat orders coming after 20 to 25 years. Where a country or a project requires certification, it is arranged to the requirement of the destination country through a reputed certification body, and the equipment is supplied certified to that requirement.

Indonesia's route does not ask a foreign manufacturer for a mark. It asks for a file and a vessel that an Indonesian inspector can examine, test and stamp. What decides whether that goes smoothly are design decisions: the access, the test connections, the nameplate fields, the traceability of the stainless steel. We build to the specification nominated in the enquiry, and these belong in it.

Getting it right

Permenaker 37/2016 is easy to underestimate because it reads like a gas cylinder regulation, and Permen ESDM 25/2018 is easy to miss because it is addressed to the buyer, not the supplier. Both are handled with a paragraph in the specification and a conversation held early. For the process context on where these vessels sit in a refining circuit, see our complete guide to electrolyte filtration for copper refineries, and for the sister regime with the opposite structure, our article on the Singapore fabrication survey step most import specs miss.

If you are specifying filtration for an Indonesian plant and want the classification and documentation route set out before the specification is written, send us the duty and the destination site and we will map it.