We have discussed about the new regulation of SNI primary batteries, and now we also need to discuss about the SNI exemption letter for primary battery products. As we already know that the regulation for SNI primary batteries has determined type of primary battery products that categorized as SNI mandatory. However, not all types of primary batteries must be processed for SNI certification. The Ministry of Industry has issued a new regulation for type of primary battery products that out of scope of SNI mandatory.
In this article we will discuss all about new regulation of SNI exemption letter specifically for primary battery products.
What is SNI exemption letter?
The Ministry of Industry is policy maker for SNI mandatory for primary battery products. Based on new regulation of PERMENPERIN No. 69 year 2024 about SNI mandatory primary batteries, only primary battery is within the scope of SNI mandatory. The regulation also define that primary battery is a battery that can only be used once and cannot be recharged once depleted.
The implementation of SNI mandatory for primary battery products can be exempted if a primary battery has its own standards and different scope from SNI mandatory products. The battery products that meet the exemption requirements can apply for an SNI exemption letter. This exemption from SNI mandatory is proven by the ownership of an SNI exemption letter issued by the Ministry of Industry.
Primary battery products out of scope of SNI mandatory
Importers can apply for an SNI exemption letter if their primary battery products to be imported are outside the scope of SNI mandatory products. Here are some criteria of primary battery products that has different scope from SNI mandatory.
| HS code | Description | Within the scope of SNI mandatory | Out of scope of SNI mandatory |
| 8506.10.11 | Zinc-carbon | Primary batteries are included in SNI IEC 68006-1:2015 and SNI IEC 68006-2:2015 Category 1: R1, R03, R6P, R6S, R14P, R14S, R20P, R20S, LR8D425, LR1, LR03, LR6, LR14, LR20 Category 2: CR14250, CR15H270, CR17345, CR17450, BRI17335 Category 3: LR9, LR53, CR11108 Category 4: PR70, PR41, PR48, PR44, LR41, LR55, LR54, LR43, LR44, SR62, SR63, SR65, SR60, SR67, SR66, SR58, SR68, SR59, SR69, SR41, SR57, SR55, SR48, SR54, SR42, SR43, SR44, CR1025, CR1216, CR1220, CR1616, CR2012, CR1620, CR2016, CR2025, CR2320, CR2032, CR2330, CR2430, CR2354, CR3032, CR2450, BR1225, BR2016, BR2320, BR2325, BR3032 Category 5: R40, 4LR44, 2CR13252, 4SR44 Category 6: 3R12P, 3R12S, 3LR12, 4LR61, CR-P2, 2CR5, 2EP3863, 4R25X, 4LR25-2, 6AS4, 6AS6, 6F22, 6LR61, 6LP3146, 6F100 including primary batteries packaged together with other products other than primary batteries and/or being part of other products other than primary batteries. | Apart from primary battery regulated within the scope of SNI mandatory |
| 8506.10.12 | Alkaline | ||
| 8506.10.19 | Others | ||
| 8506.80.30 | Have an outer volume that does not exceed 300 cm3 | Primary batteries are included in SNI IEC 68006-1:2015 and SNI IEC 68006-2:2015 Category 1: R1, R03, R6P, R6S, R14P, R14S, R20P, R20S, LR8D425, LR1, LR03, LR6, LR14, LR20 Category 2: CR14250, CR15H270, CR17345, CR17450, BR17335 Category 3: LR9, LR53, CR11108 Category 4: PR70, PR41, PR48, PR44, LR41, LR55, LR54, LR43, LR44, SR62, SR63, SR65, SR60, SR67, SR66, SR58, SR68, SR59, SR69, SR41, SR57, SR55, SR48, SR54, SR42, SR43, SR44, CR1025, CR1216, CR1220, CR1616, CR2012, CR1620, CR2016, CR2025, CR2320, CR2032, CR2330, CR2430, CR2354, CR3032, CR2450, BR1225, BR2016, BR2016, BR2320, BR2325, BR3032 Category 5: R40, 4LR44, 2CR13252, 4SR44 Category 6: 3R12P, 3R12S, 3LR12, 4LR61, CR-P2, 2CR5, 2EP3863, 4R25X, 4LR25-2, 6AS4, 6AS6, 6F22, 6LR61, 6LP3146, 6F100 including primary batteries packaged together with other products other than primary batteries and/or being part of other products other than primary batteries. | Apart from primary battery regulated within the scope of SNI mandatory |
| 8506.80.90 | Others |
How to process SNI exemption letter?
In order to obtain an SNI exemption letter, importers must submit an application to the Ministry of Industry. Submission of SNI exemption letter is done electronically through the SIINas system. Therefore, it is important for importers to have a SIINas account before processing the application of SNI exemption letter.
The process of submitting an SNI exemption letter is done by filling in data and uploading documents in the importer’s SIINas account. Following are the required data and documents that need to be prepared before submitting the application of SNI exemption letter.
| Data | Document |
| 1). HS code number 2). Type of products 3). Brand of products 4). Specification of products 5). Purpose of use 6). Import period or production period 7). Port of origin and port of destination | 1). Application letter for issuance of SNI exemption letter 2). Business licensing documents 3). Statement letter 4). Product photos at least 4 sides 5). Product brochure for finished products 6). Brand certificate 7). LSPro assessment report |
LSPro assessment report for SNI exemption letter
Based on the new regulation, submission of SNI exemption letter for primary battery products require importers to upload LSPro assessment report. For submission of SNI exemption letter, LSPro that issue the assessment report must be designated for primary battery products according to KEPMENPERIN No. 1419 year 2025.
Based on the regulation, there are 5 LSPro for SNI primary battery products that can be used for LSPro assessment process. The appointed LSPro for SNI primary battery products can issue LSPro assessment report for the needs of SNI exemption letter application. Following is a list of LSPro designated for primary battery products for both SNI mandatory and SNI exemption letter process.
| Domestic produced products | Imported products |
| 1). B4T Bandung 2). LSPro PPMB 3). SUCOFINDO 4). Baristand Surabaya | 1). BSPJI Jakart |
The LSPro assessment process for SNI exemption letter application will be carried out by verifying documents and testing samples if necessary. In the document verification process, LSPro will request several documents below for product assessment:
- Photos of the product at least showing the front, back, right and left sides.
- Brochure or product catalog related to product technical specifications.
- Third party test results use different standards from the SNI mandatory standards, if any.
If LSPro still cannot make a decision during the document verification stage, then LSPro can conduct sample testing. Sample testing must also be carried out in a laboratory that has been appointed based on the same regulations as the appointment of LSPro. Generally, each LSPro already has their laboratory that is also appointed to conduct the sample testing for SNI primary battery products.
What importers need to do after obtaining SNI exemption letter?
If the SNI exemption letter has been issued by the Ministry of Industry, importers need to report the realization of imports on the SIINas system. This import realization reporting must be done at least once a month.
Importers that already received SNI exemption letter but do not report the realization of imports as requested will be subject to administrative sanctions in the form of rejection of SNI exemption letter application for the following year.
Conclusion
Processing the SNI exemption letter can be quite challenging, especially if the importer does not have a connection with LSPro. Dimulti has experience assisting importers with the process, from document preparation to import realization reporting. Therefore, please don’t hesitate to contact us by sending an inquiry to info@narmadi.com if you have any questions related to the SNI exemption letter.
