Indonesia Issues 2025 Framework for Listing Medicine in National E-Katalog

Indonesia’s E-Katalog is a centralized electronic catalog platform used for the procurement of goods and services by government agencies and other entities that utilize state or regional budgets. It plays a key role in Indonesia’s public procurement system, as governed by the following regulatory framework:

1. Government Regulation No. 29 of 2018, dated July 13, 2018, on the Empowerment of Industry, as partially revoked by Government Regulation No. 28 of 2021, dated February 2, 2021, regarding the Organization of the Industrial Sector (“GR 29/2018”); and
2. Presidential Regulation No. 16 of 2018, dated March 16, 2018, on Government Procurement of Goods/Services, as amended by Presidential Regulation No. 12 of 2021, dated February 2, 2021 (“PR 16/2018”).

Through the E-Katalog, designated procurement officials can carry out direct purchases (e-purchasing) of pre-approved goods and services that meet specified technical and administrative standards.

Each relevant ministry is responsible for issuing the criteria and technical specifications for product listings within its purview. These are periodically published through official announcements.

Ministry of Health Announcement in 2025

On February 24, 2025, the Ministry of Health issued Announcement No. 124/D23/DPPP/02/2025 concerning the Categories of Drugs, Natural Drugs, Vaccines and Processed Foods for Special Medical Purposes (“2025 MOH Announcement”). This document sets out the procedures and requirements for listing the following products in the E-Katalog:

1. Drugs: prescription, limited over-the-counter, over-the-counter, narcotics, psychotropics;
2. Natural Drugs: phytopharmaceuticals, standardized herbal drugs;
3. Quasi Drugs;
4. Health Supplements;
5. Vaccines; and
6. Processed Foods for Special Medical Purposes.

Requirements for Business Actors

Business actors intending to register in the E-Katalog must submit the following documents and/or meet the following requirements:

1. Comply with the E-Katalog’s terms and conditions;
2. Possess a valid Business Registration Number (Nomor Induk Berusaha or “NIB”);
3. Have the appropriate Indonesian Standard Business Classification (Klasifikasi Baku Lapangan Usaha Indonesia or “KBLI”) number;
4. Hold a Taxpayer Identification Number (Nomor Pokok Wajib Pajak or “NPWP”);
5. Provide a valid deed of incorporation and any amendments (for legal entities); and
6. Not be listed on the Government Goods/Services Procurement Policy Agency’s blacklist.

Specifically, business actors intending to list products in the categories of Prescription Drugs, Limited Over-the-Counter Drugs, Over-the-Counter Drugs, Narcotics, Psychotropic Drugs, and Vaccines are required to hold a valid Marketing Authorization and must have a cooperation agreement with a Pharmaceutical Wholesaler (Pedagang Besar Farmasi or “PBF”).

For those listing products in the categories of Phytopharmaceuticals, Standardized Herbal Medicines, Quasi Drugs, and Health Supplements, a valid Marketing Authorization is also required, along with a cooperation agreement with either a PBF or a Traditional Medicine Wholesaler.

Product Requirements

Eligible Products

Only medicines listed in the 2025 MOH Announcement can be listed in the E-Katalog.

Required Product Information

1. Basic Information: Product name, KBLI number, domestic product information, local content level (Tingkat Komponen Dalam Negeri or “TKDN” and Bobot Manfaat Perusahaan or “BMP”), Indonesian National Standard, trademark, price, stock, and shipping details.

2. Main Information: Product code (as listed in the Pharmaceutical and Medical Device Dictionary), trade name, product grouping, dosage form, drug classification, active ingredients, packaging, marketing authorization number, letter of appointment from the pharmaceutical manufacturer to the PBF, required purchase quantity, and pricing structure.

3. Additional Information: Any other relevant product-related data.

Emphasis on Local Content Requirements

The 2025 MOH Announcement reinforces local content requirements through the following provisions:

1. A combined TKDN and BMP threshold of 40%, with TKDN alone required to be at least 25%, in accordance with GR 29/2018 and PR 16/2018.
2. Only drug products that use domestically produced pharmaceutical raw materials or have a TKDN exceeding 52% may be listed in the E-Katalog for the relevant category.

Conclusion

The 2025 MOH Announcement establishes clearer and more stringent requirements for the listing of medicines in the E-Katalog. Business actors should ensure full compliance with both administrative and local content requirements to remain eligible for participation in public procurement in the health sector.

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