Quick answer
The holder should still be the actual factory, with the warehouse seller as its authorized importer. Goods stocked in Indonesia already count as imported and sold, so after the mandate date goods without a valid number are blocked at outbound, platform checks and distribution. Two arrangements are common: the factory certifies and authorizes the seller, or the factory files the seller's private label as a custom product; both must close the authorization loop on paper.
Detailed explanation
Two Facts to Settle First
- Goods in an overseas warehouse are already inside Indonesia, so rules apply whether or not orders existed at shipment.
- The review covers site and recipe; a warehouse operator that does not manufacture cannot replace the factory as holder. Stocking solves logistics speed, not the compliance entity.
Two Entity Arrangements
| Arrangement | Certificate holder | Typical case |
|---|---|---|
| Factory certifies and authorizes | The production factory | Generic lines sold by many sellers |
| Private-label custom filing | Factory files for the branded product | Seller-owned brand with independent packaging |
Under either, sales use a SIHALAL-registered number, and the seller keeps the authorization letter and record.
Document Steps Before Stocking
- Check every SKU against category dates; mandatory items get evidence before warehousing.
- Sign a factory agreement covering certification, extensions, mark use and end of authorization.
- For uncertified stock already stored, pause outbound, verify categories and agree disposal in writing.
- Keep the shop entity consistent with import documents so number binding works.
Still have questions?
Tell our consultants your product category and target market, and we will help you map out the path and the documents required.