G/TBT/W/482  
 
18 April 2018  
(18-2402) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
 INDONESIA — TECHNICAL GUIDELINES  FOR THE IMPLEMENTATI ON OF THE ADOPTION 
AND SUPERVISION OF I NDONESIAN NATIONAL S TANDARDS FOR OBLIGAT ORY TOY 
SAFETY   
STATEMENT BY THE EUR OPEAN UNION TO THE C OMMITTEE ON TECHNICA L BARRIERS TO TRADE  
21 AND 22 MARCH 2018  
The following communication, dated 16 April 2018, is being circulated at the request of the 
delegation of the European Union . 
 
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1.  The E uropean Union would like to thank Indonesia for their availability to discuss this issue in a 
bilateral me eting. However, the EU remains concerned and would like to request an update on the 
status of the review of the Regulation of Minister of Industry No. 55 revising Regulation of Minister 
of Industry No. 24, which concerns the mandatory implementation of SNI  (Indonesia national 
standard) for Toys. At the last Committee meeting, Indonesia's representative repeated that 
Ministerial Regulation No. 55 was still under revision. He also stated that a separate 
revision/update of SNI on toys was ongoing; the draft SN I was still being consulted for consensus 
among related stakeholders. The revised SNI would then become the basis for the revision of the 
Ministerial Regulation.  
2.  Can Indonesia clarify what is exactly the SNI applicable to toys that is under revision and be ing 
consulted for consensus among stakeholders, and when the revision of this SNI is expected to be 
completed?  
3.  The EU would like to stress that the review of the Ministerial Regulation is both urgent and 
necessary, in particular to address the issue of the  testing requirements that appear to apply in a 
different way to imported and domestic products. Could Indonesia provide further details on this 
aspect of the on -going review?  
4.  Another issue of persistent concern is the lack of acceptance of test results fr om technically 
competent and adequately accredited foreign laboratories. Since the end of April 2016, the grace 
period for the recognition of foreign test results had expired. This requires in -country testing and 
adds to the costs and delays in completing the conformity assessment procedure.  
5.  At the last meeting, Indonesia stated that test results of foreign conformity assessment bodies 
accredited by national accreditation bodies signatory to APLAC and ILAC would be accepted in 
Indonesia only on the basis of  a government -to-government mutual recognition agreement (MRA).  
6.  In this regard, the EU reiterates its request to Indonesia to reconsider its position on this issue 
and ensure that test results from laboratories accredited by ILAC MRA signatories are accept ed, 
without the need of a government -to-government MRA.  
7.  Alternatively, the Indonesian authorities could consider explicitly permitting Indonesian 
certification bodies to enter into sub -contracting agreements with foreign laboratories for the 
recognition of  foreign test results as a basis for certification in Indonesia.  G/TBT/W/482  
 
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  8.  The EU would appreciate receiving further clarification from Indonesia about how the issue of 
the acceptance of foreign tests will be addressed in the context of the on -going review.  
 
 
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