An Authorized Representative (AR) is an Indonesian legal entity appointed to represent an overseas automotive battery manufacturer. Under the draft SNI framework, this role carries compliance responsibilities beyond those of an ordinary sales agent or purchasing intermediary.
Appointment and Indonesian corporate records
The AR needs Indonesian incorporation documents, business authorization and formal appointment by the overseas manufacturer through an authentic deed before an Indonesian notary. The draft also specifies the persons authorized to appear in the appointment.
An ordinary commercial appointment letter should not be assumed equivalent to a notarized deed where the regulation explicitly requests the latter.
Trademark license and DJKI recordal
For manufacturer-owned brands, the AR receives a class 9 trademark license and responsibilities for the brand. The license agreement and recordal evidence from the Directorate General of Intellectual Property (DJKI) are important documents.
A special alternative is proposed where the AR itself owns the trademark and the overseas manufacturer is its subsidiary or owned entity, subject to evidence.
Warehouse, SIINas and product quality
The draft requires the AR to control a warehouse in the same or nearest regency/city and maintain a SIINas account. It also assigns important product-quality responsibilities to the AR within the imported-product framework.
Representation of multiple unrelated manufacturers is not generally available; qualifying group ownership exceptions are separately prescribed.
Must the AR import the batteries itself?
Not necessarily under the draft. The AR may import or appoint a qualified importer for batteries intended for vehicle assembly or specified aftersales purposes.
Importer business activity, warehouse and distribution documents differ by purpose and must be verified before appointment.
Two AR and importer structures
In the first model, one Indonesian company is both AR and importer. In the second, the AR and importer are separate legal entities. The draft envisages both arrangements, but a separately appointed importer must fall within the specified import purposes and satisfy the related requirements.
When an AR also owns the trademark, the draft includes a limited alternative to the normal license document if the overseas manufacturer is owned by or a subsidiary of the AR. Corporate ownership should be documented before any notarized appointment.
Frequently Asked Questions
Does an AR have to import directly?
No. The draft allows appointment of a qualified separate importer for specified purposes.
Is a simple appointment letter sufficient?
The draft calls for an authentic appointment deed before an Indonesian notary.
Related Reading
- SNI Certification Services for Car and Motorcycle Batteries in Indonesia
- SNI 38:2025 Car Battery Requirements in Indonesia
- SNI 4326:2025 Motorcycle Battery Requirements in Indonesia
Automotive Battery SNI Consultation
For an initial assessment, prepare a model list and specifications, manufacturer identity, management-system certificates, trademark documents and your proposed Authorized Representative/importer arrangement. Biruni Consulting can review the documentation and identify the next regulatory steps.
Regulatory status: SNI 38:2025 and SNI 4326:2025 are BSN technical standards. Draft mandatory-SNI provisions must be verified against the enacted regulation, if any. Certification outcomes and timelines are not guaranteed.