G/TBT/W/627  
 
8 April  2019 
(19-2234) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
INDONESIA - TECHNICA L GUIDELINES FOR THE  IMPLEMENTATION OF T HE  
ADOPTION AND SUPERVI SION OF INDONESIAN N ATIONAL STANDARDS  
FOR OBLIGATORY TOY S AFETY  
STATEMENT BY THE EUROPEAN UNION TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
6 AND 7  MARCH  2019 
The following communication, dated 5 April  2019, is being circulated at the request of the delegation 
of the European Union . 
_______________   
1.  The EU takes note of the recent amendment to Regulation of Minister of Industry No. 24/2013 
on the mandatory imple mentation of the Indonesia national standard (SNI) for Toys introduced by 
Regulation of the Minister of Industry 29 of last November 2018, and notified to this Committee on 
30 November  2018 (G/TBT/N/IDN/64/Add.3).  
2.  It is the understanding of the EU that the  new amendment aims at addressing the different and 
discriminatory treatment for testing requirements between imported and domestically produced 
toys, and which entails tests on every batch of imported toys as compared with tests of samples 
taken every 6 m onths for domestic products.  
3.  The new amendment introduces a so -called scheme 5, which applies to audits and inspection of 
toys production facilities as an optional scheme to replace the testing of each import. The European 
Union is concerned as regards th e overall implementation of scheme 5, in particular as to whether 
these newly -proposed audits, inspections and laboratory testing would be conducted in a timely and 
efficient manner under this new scheme.  
4.  The EU remains anyhow therefore disappointed that the recent modifications have not fully 
removed the different treatment between imported and domestically produced toys when it comes 
to testing methods.  
5.  Moreover, the expected implementation Guidelines that should provide further details on the 
requireme nts for toys importers and that were expected to be published in 2018, have not yet been 
released. Could Indonesia clarify the current state -of-play of the development of these Guidelines 
and how it intends to implement the newly -proposed scheme 5?  
6.  Another  issue of persistent concern is the lack of acceptance of test results from technically 
competent and adequately accredited foreign laboratories. This requires in -country testing carried 
out by a laboratory established in Indonesia and adds to the costs an d delays in completing the 
conformity assessment procedure. Given the limited number of Indonesia -based laboratories, 
allowing overseas laboratories to conduct product testing would streamline the certification process 
and allow proper access to the Indone sian market.  
7.  The EU reiterates therefore its request to Indonesia to reconsider its position on this issue and 
ensure that test results from laboratories accredited by ILAC MRA signatories are accepted, without 
the need of a government -to-government MRA.  G/TBT/W/627  
 
- 2 - 
 
  8.  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 In donesia.  
9.  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.  
__________