Commodity Balance

In order to ensure the availability of raw materials for domestic needs, the government issued Presidential Decree No. 32 of 2022 on Raw Materials Balance in February 2022. The raw material bal-ance contains data and information illuminating the consumption and production of certain raw materials for the needs of the population and industry in a specific period of time, and applies nationwide.

Later in the same year (i.e., October 2022), the Coordinating Minister of Economy issued the implementing regulation for the Commodity Balance, namely Regulation No. 16 of 2022 on Guidelines for the Implementation of the Commodity Balance ("Regulation 16/2022").

National System for the Commodity Balance (SINAS NK)

Regulation 16/2022 requires the integrated implementation of the Commodity Balance through a publicly available online system known as the National System for the Commodity Balance (SINAS NK).

The preparation of the Demand and Supply Plan (which is the basis for the National Commodity Balance) is essentially done at the ministerial level, based on data provided by economic operators and ministries or non-ministerial government agencies responsible for commodities.

Schedule and Relevance

The Commodity Balance is determined before the start of a new fiscal year, but can be amended during the year. Both, business operators and ministries or non-ministerial government agencies responsible for specific commodities may submit a request to amend the Commodity Balance if they deem it necessary. These amendments go through a review and coordination process before they can be included in the updated Commodity Balance.

The Commodity Balance is the basis for issuing business licenses to support export and import activities. The application for the issuance of such business license shall be submitted through SINAS NK at any time after the expiry of the Commodity Balance until the end of its validity period in the current year.

As the Commodity Balance is used as a basis for issuing business licenses to support export and import activities, it is expected that the Commodity Balance will impact many business practices, especially those of companies that are heavily dependent on export and import activities.

Roedl & Partner will continue to monitor the situation closely and provide regular updates.