EV Battery Company Setup in Indonesia: Manufacturing Scope and Project Approvals

Separate the battery operations you will actually perform

An EV battery project needs an operating description precise enough for a classification reviewer, factory designer and environmental consultant to use the same assumptions. Start with a process diagram showing what enters the Indonesian facility, what changes there and what leaves. Identify the company that owns each production step; a group presentation describing the entire supply chain does not establish what this Indonesian entity will manufacture.

For this planning exercise, a cell is the individual electrochemical unit; a module combines cells into a subassembly; and a pack integrates cells or modules with the intended enclosure, connections and control or thermal components. Those distinctions describe the work to assess. They do not establish three automatic licensing categories, and a pack assembler should not describe itself as making cells when finished cells arrive from a supplier.

• Cell production: describe electrode preparation, cell assembly, electrolyte filling, formation and testing actually performed at the site. Mark any stages purchased or outsourced.
• Module and pack assembly: identify incoming cells or modules, joining and electrical work, control-system integration, enclosure assembly and end-of-line tests. State the intended vehicle application.
• Materials processing: distinguish captive electrode production from a separate business selling precursors, active materials, electrolytes or refined metals to other factories.
• Returns and recycling: distinguish storing the factory’s own rejected material, receiving used batteries from customers, dismantling batteries and recovering secondary materials.

Record rated annual output, working shifts, chemical inventories, floor area and storage arrangements beside the diagram. For a phased project, show the initial line separately from planned later operations. A future recycling line belongs in the expansion plan until its own scope and approvals have been assessed. This makes the first investment decision concrete: which production boundary is the company asking to establish now?

Translate the scope into current KBLI and a PT PMA file

Use the current five-digit Klasifikasi Baku Lapangan Usaha Indonesia (KBLI) description, then test it against the actual operations. BPS Regulation 6 of 2026 amended the KBLI 2025 annex and took effect on 10 September 2026. The amended classification text describes 27203 as vehicle-battery and large Battery Energy Storage System manufacturing; it includes EV batteries and BESS above 30 kWh. Code 27201 includes smaller BESS up to 30 kWh. The BESS capacity distinction should not be applied as a capacity threshold for vehicle batteries.

The amended 27203 description also includes EV batteries using self-produced cathodes and anodes. That wording deserves attention for an integrated factory, but it does not automatically settle the classification of a separate materials business. Code 27202 remains the electrical-accumulator category. Code 29300 expressly sends motor-vehicle battery manufacturing to group 2720, so “automotive parts” is not a sufficient classification reason.

The following are screening references, not a licence determination for an unspecified plant. For each proposed five-digit code, keep the supporting process description and record the current OSS activity, scale, location, risk result and conditions. If an OSS screen still displays a different classification version, preserve both descriptions and resolve the correspondence before filing; the OSS battery-group reference is visibly labelled KBLI 2020.

Foreign investment ordinarily calls for a Perseroan Terbatas structured as a PT PMA. Check foreign-ownership eligibility for every selected activity before fixing the shareholders. The underlying company registration requirements in Indonesia cover the entity work: consistent shareholder and beneficial-owner details, an Indonesian notarial deed, AHU legal-entity output, tax registration and the company information used in Online Single Submission (OSS). Those records should identify the same company that will hold the factory approvals.

For capital planning, Article 26 of Investment and Downstreaming Minister Regulation 5 of 2025 generally requires PMA investment above IDR 10 billion excluding land and buildings per five-digit KBLI per project location, with stated exceptions including products within one industrial production line. It separately sets minimum issued/paid-up capital at IDR 2.5 billion per PT, unless another rule applies. Document the applicable calculation rather than multiplying codes mechanically. Investment value and paid-up capital are distinct from incorporation service fees.

Test the proposed factory before committing to the site

Assess a factory parcel and a proposed building against the process before treating a lease as proof of readiness. A registered office address cannot supply evidence about industrial land use, chemical storage, electricity demand or a production building. Obtain the exact coordinates and site area, the landowner’s documents, proposed occupancy rights, the estate or landlord’s approved use and the building drawings relevant to your line.

Keep a site assessment with three separate conclusions: whether the location can accommodate the declared activity; whether the environmental route covers that activity and capacity; and whether the building can be constructed, altered and used for the intended factory. These conclusions should refer to the same parcel and layout revision. An estate’s sales brochure, a landlord’s promise and the company’s NIB answer different questions.

Check spatial-use conformity, including the applicable Kesesuaian Kegiatan Pemanfaatan Ruang (KKPR) route, through the project record. Regulation 5/2025 addresses industrial-estate documentation and verification of relevant exceptions to industrial-estate location requirements. Treat an outside-estate proposal as a specific eligibility question, rather than assuming any industrial-looking warehouse qualifies. Keep the estate’s confirmation of the proposed activity where that route applies.

Building Approval (PBG) and the Certificate of Proper Function (SLF) address separate stages. The official Jakarta building-service explanation states that PBG precedes construction and SLF precedes building use, and identifies changes that require a PBG amendment. This is a useful illustration of the distinction; the project’s competent local service and building documents govern its actual application. A pre-existing approval must be compared with the intended function and alterations.

Ask the engineering team to reconcile equipment loads, ventilation, fire protection, containment, access and storage with the approved design. For a leased shell, allocate responsibility for landlord-supplied documents, tenant fit-out submissions and any building modification. The approved building function matters as much as possession of an approval number. Do not set the equipment-installation date from the incorporation date alone.

The process boundary, site and waste profile meet at the same approval decision. None can be finalized reliably while the others describe a different version of the factory.

Match environmental controls to the process and waste streams

Environmental screening should use the full project description, scale and location. Environment and Forestry Minister Regulation 4 of 2021 lists AMDAL, UKL-UPL and SPPL routes; its battery entries for 27202 and 27203 refer to the multisector scale criteria. The battery label alone therefore does not establish the environmental document. Protected-area proximity and other applicable screening criteria also matter.

AMDAL is an environmental impact assessment; UKL-UPL records environmental management and monitoring measures; SPPL is the undertaking for activities outside the AMDAL and UKL-UPL requirements. Record the actual screening outcome and its approved scope. Do not select the lightest route because the first production phase is described as “assembly” or because a building already exists.

For an estate with the relevant area environmental approval, Regulation 5/2025 Article 166 provides for detailed RKL-RPL based on that approval, examined and endorsed by the estate manager. Obtain the underlying coverage and your endorsed detailed environmental management and monitoring plan. “Inside an estate” should lead to a documented route, not an assumption that the tenant has no environmental obligations.

• List every material stream: inputs, solvent or electrolyte use, rejects, cleaning residues, wastewater, emissions and used batteries accepted from outside the plant.
• Identify each control boundary: treatment done by the tenant, connection to estate infrastructure, temporary storage and transfer to an external operator.
• Compare the engineering design with the submitted environmental scope: capacity, equipment, discharge points and storage areas must remain traceable to the assessed project.
• Assign a named owner to each required technical submission, commissioning result and ongoing monitoring record.

Hazardous-waste management requires its own activity analysis. Under Regulation 6 of 2021, Article 220 , AMDAL- or UKL-UPL-required businesses undertaking listed hazardous-waste collection, utilization, treatment or landfill activities require the relevant technical approval and SLO-PLB3 operational-feasibility document. This is not a statement that every battery assembler needs a recycling licence. Identify whether the company generates and stores its own waste, or undertakes a regulated waste-management business.

A return arrangement can change that answer. Receiving another company’s spent batteries for dismantling and recovery is a different fact pattern from holding defective new cells pending supplier collection. Before accepting either stream, establish its classification, who may transport and receive it, and the facility’s permitted handling. Purchasing a shredder does not settle those questions; the acceptance list and treatment route must match the approvals.

Build an approval record for each project milestone

Organize execution by the next activity the project wants to undertake, rather than by a single “registration complete” date. Regulation 5/2025 Article 186 distinguishes NIB-only, Standard Certificate and Business Licence routes according to validated risk. For medium-high risk, Article 189(6) limits an NIB with an unverified Standard Certificate to preparation; it does not authorize operational or commercial activity. Check the actual project result before scheduling production.

Use the following sequence as a coordination plan. It is not a promise that every approval is sequential or has the same processing time. Corporate documents, engineering and supplier preparation can progress together; construction, commissioning and commercial release must respect the applicable conditions for their respective stage.

1. Fix the application inputs: authorize the shareholder structure, activity boundaries, capacity, site and funding assumptions. Give the notary, technical consultants and OSS preparer one controlled project description.
2. Complete the entity record: obtain the deed and AHU output, confirm the tax identity and reconcile company data before the authorized company account submits the OSS project.
3. Populate each project accurately: enter the location, activity and investment information required in OSS; review the risk result and record the basic requirements, sector standards and supporting-business approvals shown.
4. Submit the corresponding evidence: provide the required spatial, environmental, building and sector materials through the applicable workflow. Save submission receipts and any official request for correction.
5. Close each stage against its output: retain issued documents and technical annexes, confirm their status and scope, and reconcile the physical line before permitting the next activity.

Maintain a short approval record containing the document number, issuing body, activity, parcel, capacity, status, conditions and file location. An uploaded document or payment receipt proves an event in the application; it does not by itself prove that the authority accepted the scope. When a correction arrives, identify the disputed field or technical assumption and update the connected evidence together.

Before a pilot run, commissioning test or customer trial, identify what the applicable permissions allow at that stage. Do not assume that calling output a “sample” removes an operational restriction. Separately record any product-conformity, import, customs or supporting-business approval triggered by the actual goods and activity. A manufacturing business approval should not be presented as universal clearance for every battery model, imported input or finished shipment.

Control expansion, costs and continuing factory obligations

Treat scope changes as investment decisions with approval consequences. The practical control is to compare the proposed change with the last assessed project, not merely ask whether the NIB number stays the same. The assumptions to settle before committing factory investment can be kept alongside a battery-specific change record so commercial commitments expose their licensing assumptions before money is committed.

The matrix below is a planning tool derived from the activity, site and environmental distinctions above. Its close conditions are suggested project controls, not additional government certificates. Use it when an engineering or sales request would change what the factory does.

Regulation 5/2025 Article 168 identifies environmental-approval changes including environmentally relevant changes to equipment or materials, capacity additions and land expansion. Screen those triggers before ordering the alteration. An unchanged company name does not establish that an expanded factory remains covered. Assign the assessment to a person who can compare the technical revision with the legal scope.

Budget the corporate establishment work separately from plant engineering, land or rent, environmental studies, building work, laboratory testing, equipment and any activity-specific approvals. HSJGlobal’s approved standard low-risk and medium-low-risk incorporation packages do not automatically price this sector. A battery project needs an agreed scope naming the entity work, locations, technical work, excluded approvals, third-party disbursements and any applicable VAT treatment. No factory-wide price or approval date follows from an incorporation package.

After the line starts, assign owners for the conditions in each approval, environmental monitoring and waste records, applicable industrial reporting, Investment Activity Reports (LKPM), tax and accounting, employment and equipment obligations. Build reporting dates from the rules and approvals applicable to this company. Save the baseline now so later capacity declarations and compliance records can be compared with the project actually authorized.

Approve the battery project by its remaining dependencies

Authorize the next battery-project milestone only after its dependencies are visible and resolved. For a pack-only investment, preserve the incoming-cell boundary and the particular factory conditions. For an integrated cell and materials project, keep the captive and standalone activities explicit. For recycling, establish the waste-management route before accepting spent batteries. Those distinctions determine what the company, designers and permit preparers must deliver.

The immediate action is a signed scope-and-site record linked to the current KBLI assessment and approval register. Escalate any mismatch between the intended process, the filed project and the physical facility before making the affected commitment. A complete entity file is useful progress; the decision to construct, test or sell requires the evidence for that specific milestone.