SNI certification for primary battery products

The Ministry of Industry has issued a new regulation of PERMENPERIN No. 69 year 2024 about the implementation of SNI mandatory for primary battery products. This regulation is established to protect consumers and domestic producers from low-quality imported products. The ministerial regulation number 69 should come to effect after six months since the promulgated date of the regulation. And because the regulation has been promulgated on 20 November 2024, then the enforcement of the new regulation should be on 20 May 2025. Therefore, in this article we will discuss all about new regulation of SNI mandatory for primary battery products.

Scope of SNI primary battery products

Referring to ministerial regulation number 69, the only type of battery that subjected to SNI mandatory is a primary battery type. The regulation defines primary battery as a battery consist of one or more primary cells, including a housing, terminals, and markings. This regulation also states that SNI certification for primary battery products is mandatory for:

• Every domestically produced and/or imported primary battery marketed within the territory of Indonesia, and
• A battery that can only be used once and cannot be recharged once depleted.

The SNI standards for primary battery are SNI IEC 60086-1:2015 (IEC 60086-1:2011) and SNI IEC 60086-2:2015 (IEC 60086-2:2011). Here are the complete list of SNI mandatory for primary battery products based on the HS codes:

• 8506.10.11
• 8506.10.12
• 8506.10.19
• 8506.10.91
• 8506.10.99
• 8506.50.00
• 8506.80.30
• 8506.80.90

SNI conformity assessment process

The implementation of SNI mandatory for primary battery products is carried out through conformity assessment activities based on certification system type 5 (five). Conformity assessment activities with certification system type 5 (five) are carried out based on two main stages below:

• Factory audit: SNI certification for type 5 (five) requires an audit of production process and implementation of quality management systems in accordance with ISO 9001:2015.
• Sample testing: SNI certification type 5 (five) also requires a quality conformity testing based on applicable SNI standards.

Both factory audit and sample testing must be carried out by appointed LSPro and testing laboratory. The appointment of LSPro and testing laboratory is regulated in different ministerial decree. The results of conformity assessment process is stated in the form of SNI Certificate.

SNI certificate holders

Basically, there is no significant change for SNI certificate holders in this new regulation. SNI certificates can still only be owned and hold by:

• Local manufacturer companies
• Foreign manufacturers

SNI certificate is issued to local manufacturer company or foreign manufacturer for one production site only. In the case there is a brand cooperation or maclon, the SNI certificate is issued to local manufacturer company or foreign manufacturer that receiving the brand cooperation or maclon for each brand cooperation or maclon provider.

Based on the new regulation, certificate holders can list more than one brand in SNI certificate. The SNI certificate is valid for 5 (five) years from the date of issuance of SNI certificate.

Local manufacturer companies as certificate holder

Here are several requirements if a local manufacturer company wants to be SNI certificate holder for SNI mandatory primary battery products:

1. Having a business license in the industrial sector according to the scope of KBLI 27201.
2. Local manufacturer companies should have their own brand for primary battery class class 9 registered in the Directorate General of Intellectual Property.
3. Having production facilities at least in the form of material mixing, assembly and packaging facilities.
4. Having test equipment at least in the form of a performance test after a storage period of 12 (twelve) months.
5. Implementing the quality management system of ISO 9001:2015.
6. Local manufacturer companies must have a SIINas account.

Foreign manufacturers as certificate holder

Here are several requirements if a foreign manufacturer company wants to be SNI certificate holder for SNI mandatory primary battery products:

1. Conducting business activities in primary battery industry.
2. Foreign manufacturers should have their own brand for primary battery class 9 (nine) issued registered in the Directorate General of Intellectual Property.
3. Having production facilities of at least in the form of material mixing, assembly and packaging facilities.
4. Having test equipment at least one in the form of a performance test after a storage period of 12 (twelve) months.
5. Implementing the quality management system of ISO 9001:2015.
6. Having an official representative company in Indonesia.

Official representative company is a new requirement for SNI primary battery products. Therefore, here are several requirements if a local Indonesian company wants to be official representative company of a foreign manufacturer :

1. Official representative company must be appointed by foreign manufacturers proven by a notarial deed.
2. Official representative obtain right to use and be responsible for the brand of primary battery class 9 (nine) from foreign manufacturers proven by registration of the license agreement in the Directorate General of Intellectual Property.
3. Official representative company should control warehouses located in the same city or district proven by the warehouse registration number.
4. Official representative company can act as a local importer company for primary battery products produced by foreign manufacturers.
5. Official representative company must have a SIINas account.

Please note that an official representative company can only represent 1 (one) foreign manufacturer company. Official representative company will able to represent more than 1 (one) foreign manufacturers only if both official representative company and foreign manufacturer come from the same parent company. The parent company have to conduct business activities in primary battery industry and also own shares in subsidiaries. If official representative company does not act as importer company, then the official representative company appoint more than 1 (one) importer company.

Maclon case for SNI primary battery products

Based on new regulation of SNI primary battery products, there is new requirements if primary battery products produced by OEM/ODM factories or also known as maclon. In the case there is a brand cooperation or maclon, the SNI certificate for the cooperated brand is owned by local manufacturer companies or foreign manufacturers that receiving the brand cooperation or maclon.

The brand cooperation or maclon can be carried out if both provider and recipient already have their own SNI certificate for their own brands. In addition, the brand cooperation or maclon recipient also need to obtain a license to produce primary battery products under the brand name of brand cooperation or maclon provider.

In the case both provider and recipient of brand cooperation or maclon are located outside of Indonesia, then both provider and recipient must have an official representative in Indonesia. If foreign manufacturers as brand owner insist on certifying primary battery products manufactured by maclon factories that do not have SNI certificate, it can not be processed because it against regulation.

Procedures for obtaining SNI certificates

Applications for SNI certification are submitted by local manufacturer or official representative companies electronically on SIINas system. If there is more than 1 (one) production site of the primary battery products, then applicants need to submit different SNI applications for each production site. Here are steps that need to be completed by applicants on their SIINas system:

1. Inputting data by filling out the application form.
2. Selecting the SNI category to be submitted for conformity assessment.
3. Selecting the LSPro that will conduct the conformity assessment.
4. Uploading brand certificate for primary battery class 9 (nine) issued by the Directorate General of Intellectual Property.
5. Uploading other supporting documents.

Because there are many supporting documents that need to be submitted, so it is better to prepare all supporting documents first before arrange the SNI application on SIINas. Here are the list supporting documents need to be prepared for SNI mandatory primary battery products:

1. Application letter printed through SIINas and signed by the director of the local manufacturer or official representative companies.
2. Copy of the company’s deed of establishment and its amendments from the local manufacturer or official representative companies.
3. Copy of business license with the scope of business activities of the primary baterry industry with KBLI 27201 for local manufacturer companies.
4. Certificate quality management system of ISO 9001:2015.
5. Statement letter printed through SIINas and signed by the director of the local manufacturer or official representative companies.
6. Production process flow diagram.
7. Information on primary baterry products including brand and type/model.
8. List of production facilities and testing equipment.
9. List of product quality control from raw materials to final products.
10. Illustration of affixing the SNI mark.
11. List of documented information according to ISO 9001:2015.
12. Organizational structure.
13. Business process.

Conclusion

The SNI certification process for primary battery products is now more complicated than old certification process. Therefore, it is crucial for manufacturers or local representative companies to understand the process for issuing SNI certificates based on the new ministerial regulation number 69. If you have any questions about SNI certification for primary battery products, please don’t hesitate to contact us by sending an inquiry to info@narmadi.com.