PLASTIC FILM · PROCESS AND PERMISSIONS
Plastic Film Factory Setup in Indonesia: Entity, Industrial Site, and Approvals
Separate film stock production from converting and finished packaging so the product scope, extrusion line, site and licensing evidence line up.
A plastic film factory needs an explicit decision about whether it will sell film rolls, convert purchased film, or integrate film extrusion with finished packaging. The current KBLI 2025 description for code 22204 covers plastic sheets and film, while packaging manufacture has a separate code family. That distinction affects the activity map, equipment footprint, quality evidence, site screening and the approval sequence.
Start with the saleable product and every process performed inside the Indonesian site. Then confirm the current OSS description and risk output, assess foreign-investment requirements, map building and environmental prerequisites, and define how each film or package will be tested and released. This guide is designed for manufacturing and converting decisions, not just a general company registration checklist.
Key takeaways
- Differentiate a film-roll producer, a converter and an integrated film-and-packaging operation before selecting KBLI.
- KBLI 2025 code 22204 is a starting candidate for film and sheet stock; finished packaging should be checked against its own official description.
- Select blown/cast extrusion, winding and conversion equipment from actual customer performance specs, not a headline output rating.
- Site and environmental screening must include printing, adhesives, lamination, waste handling and later-stage conversion when those steps are present.
- Keep licence evidence and SKU quality-release evidence separate but linked to the same defined operation.
Define the saleable film output and customer use
“Plastic film factory” can mean a producer of resin-based film rolls, a plant that converts bought-in film into printed or laminated structures, or an integrated operation that makes film and then produces bags or pouches. These operating models use different equipment, create different waste and emissions profiles, and may fall under different KBLI descriptions. The first document to prepare is a process-and-output map, not a list of machines.
For each saleable item, record whether it leaves the site as a roll, slit reel, printed web, laminated structure, sheet, pouch, bag or other finished pack. Add the resin family, thickness range, width, customer application, print/adhesive use, whether the film is food-contact or other regulated packaging, and every transformation performed in-house. This separates the intermediate material from any finished article made later.
Three common plant configurations
Identify the real business model before selecting KBLI or building the licence list.
| Configuration | Typical route | Planning question |
|---|---|---|
| Film stock producer | Resin preparation → blown or cast extrusion → winding → film rolls | Will customers buy an intermediate roll, and what performance data must each roll carry? |
| Converter | Purchased film → printing/lamination/slitting → bag or pouch conversion | Which steps are done internally, and does the finished output become a packaging article? |
| Integrated film and packaging | Resin → film extrusion → converting → finished packaging | Are both film manufacture and finished packaging activities included in the scope and licence review? |
This matters commercially as well as legally. A converter may outsource resin extrusion and need little or no pellet-handling infrastructure, while an integrated plant may require resin storage, dryers, extruder power, cooling, air movement, roll-handling systems, printing/lamination controls and solvent or adhesive management where used. The site layout and environmental profile must reflect the actual line rather than a generic “plastic film” business plan.
The boundary between film stock and finished packaging must be explicit in the product list. If customer demand could expand from rolls into bags or pouches later, record that as a future activity requiring review rather than assuming the initial setup automatically covers the expansion.
Fix the film-to-packaging boundary
Confirm which saleable outputs leave the site as rolls, converted webs, bags or pouches before finalising the product scope.
Map film stock and finished packaging to KBLI
The current OSS KBLI 2025 description for 22204, plastic sheets, expressly includes plastic sheets, plates, blocks, film, foil and related cut products. The official page also records a conversion from the previous 22291 to 22204. This makes 22204 an important starting candidate when the plant manufactures film or sheet as its principal output. It is not, however, a blanket code for every product that happens to contain film.
Review KBLI 2025 code 22204 — plastic sheets and film against the exact film output and planned activities. If the site transforms the film into plastic and bioplastic packaging, compare the finished output with KBLI 22202 — plastic and bioplastic packaging . The official descriptions are the evidence base, while the live OSS scope tells the applicant which scale, risk and obligations apply.
The same factory can have different classification questions at different stages of the film chain.
| Work performed on site | Initial classification question | Evidence to preserve |
|---|---|---|
| Extrude, cool and wind sheet/film | Does the saleable output match the 22204 description? | Film spec, material, line flow and examples of the roll or sheet. |
| Print or laminate bought-in film | Does the activity remain a conversion process, or are other activity descriptions relevant? | Process flow, print/adhesive details and the commercial output sold. |
| Seal or convert film into packs | Does the output match packaging under 22202 or another more specific class? | Finished-pack drawings, use, barrier/food-contact requirements and transformation steps. |
| Add recycling or waste processing | Does the operation do more than internal handling of its own production scrap? | Material origin, collection model, outputs, quantities and process controls. |
Do not rely on the older code in a legacy proposal without checking the current portal. A conversion mapping is a useful clue, not proof that every historical record or product fits the new description. Keep the dated official detail page, the product schedule and the decision notes together in the company’s registration file.
For product-market issues, use the product-specific SNI and import rule checklist as background and then verify the current obligations for the exact film or packaging SKU. Food-contact, pharmaceutical, electrical insulation or export-customer requirements should be assessed separately from the company’s core manufacturing classification.
A film-roll code does not automatically prove that every downstream pouch, bag or specialty laminate is covered. Ask the competent adviser to record the conclusion per material output and finished product, including any boundaries or future expansion conditions.
Design the extrusion line around film performance
Choose the extrusion configuration from film properties and customer specification. Blown-film and cast-film lines do not produce identical structures or quality characteristics; neither should be selected solely because a supplier offers a lower purchase price. The specification should state the resin blend, target thickness and tolerance, width, winding format, surface properties, optical requirements, coefficient of friction where relevant, sealing behaviour and the test methods the customer expects.
Use customer specifications, not generic marketing claims, to select the line.
| Engineering input | What to specify | Why it affects plant planning |
|---|---|---|
| Resin and formulation | Polymer grade, additives, masterbatch, recycled content policy and allowable variation | Drying, feeding, contamination prevention, material traceability and product performance. |
| Film geometry | Nominal thickness, tolerance, lay-flat width or web width, roll diameter and core size | Die/tooling, cooling, winder, material handling and storage design. |
| Performance targets | Tensile/elongation, seal strength, barrier, clarity, haze, gloss or puncture criteria as relevant | Process settings, online inspection and quality-lab requirements. |
| Output requirement | Kilograms/hour, saleable square metres, SKU mix, planned shifts and changeovers | Extruder sizing, winding capacity, staffing and working capital. |
| Downstream compatibility | Printing, lamination, slitting, sealing, the customer packaging line or filling speed | Surface treatment, tension control, edge quality and roll-consistency requirements. |
Request a technical proposal that includes extruder output under the chosen resin and film gauge, die width, cooling ring or chill-roll arrangement, thickness-control options, winder capacity, changeover time, utility demand, noise and maintenance access. The rated output may not equal saleable output at the required gauge and quality. The purchase comparison should therefore state the assumptions behind any kilograms-per-hour claim and the acceptance test that will confirm it.
Plan material flow before setting the footprint
Resin unloading and storage, dosing, masterbatch handling, roll staging, quarantine of nonconforming material, slitting and finished roll storage should fit a coherent one-way flow. A high-speed extruder can be underused if the winder, slitter or warehouse cannot handle its actual output. Confirm forklift turning, roll-lifting equipment, core supply, storage racking, moisture/temperature sensitivity and the safe route for maintenance access.
If recycled content or internal regrind is planned, document its source, allowable proportion, sorting rules, traceability and product-specific constraints. Keep post-consumer recycling, internal clean scrap and purchased recycled resin as separate supply categories in the process description. They are not interchangeable assumptions for regulatory or customer assurance.
Line capacity should be modelled from saleable output at the required film specification, not the extruder’s headline maximum. Include startup waste, gauge adjustment, roll changes, downtime, customer hold points and planned maintenance in the production plan.
Connect converting steps to quality controls
The converting stages after extrusion can determine whether a film roll is commercially usable. Printing, surface treatment, lamination, curing, slitting, pouch or bag conversion and final packing each add a different set of parameters to control. Even if a supplier quotes one integrated line, specify which process steps are installed at day one and which are future-phase options so the project’s footprint and approval assumptions remain accurate.
The inspection plan should follow the products actually sold, not simply the machine sequence.
| Stage | Critical control or record | Typical failure to anticipate |
|---|---|---|
| Extrusion and winding | Gauge profile, tension, roll hardness, edge quality and roll traceability | Thickness variation, blocking, wrinkles or telescoping rolls. |
| Printing / surface treatment | Ink/adhesive specification, surface energy where needed, registration and cure conditions | Poor adhesion, odour, migration concern for relevant applications, or print mismatch. |
| Lamination / curing | Layer structure, adhesive ratio, coat weight, curing conditions and bond tests | Delamination, inconsistent barrier or insufficient cure. |
| Slitting / rewind | Finished width, edge trim, splice policy, core size and winding quality | Rolls fail on the customer’s converting or filling equipment. |
| Bag or pouch conversion | Seal temperature, dwell/pressure, seal strength, cut accuracy and leak tests where relevant | Weak seals, dimensional variation or product damage after filling. |
| Final release | SKU traceability, inspection plan, COA or test records and nonconformance disposition | A batch ships without evidence that the customer specification was met. |
Write a release specification for each SKU and decide which values are measured in-line, which are checked by sampling, and which require external laboratory or customer approval. The standard should identify tolerance, sample size, frequency, equipment calibration, pass/fail rule and corrective action. Where a customer uses its own print, barrier, migration or filling-line acceptance process, request that standard before the trial run rather than after the first commercial delivery.
For food-contact or pharmaceutical packaging, do not infer suitability from the resin name alone. Intended contact, layer structure, inks, adhesives, recycled content, storage conditions and the destination market can influence the required evidence. Confirm the applicable Indonesian requirements and the customer’s export-market obligations for each SKU; a general SNI reference is not proof that a particular film structure is approved.
Control change management. A different resin grade, masterbatch supplier, recycled-content percentage, ink, adhesive, film gauge, layer arrangement or customer use may require a new risk assessment or customer requalification. Tie each change to the affected specification, samples, production settings and release record so a commercial buyer can trace which version was made.
A film plant should be able to produce an evidence set for each shipped roll or finished pack: batch/material traceability, specification version, inspection result, nonconformance record if any, and the customer-specific document that applies. The release system is part of the production design, not a paperwork task added when an order arrives.
Tie quality controls to the customer specification
A SKU-level release plan makes clear which film properties and finished-pack tests must pass before product ships.
Screen the site for the complete process
A candidate site must support the whole process that will be installed. Film extrusion and converting can require substantial electrical supply, ventilation and heat removal, cooling, compressed air, resin unloading, roll handling, warehouse height, forklift circulation, waste segregation and safe storage of inks or adhesives where used. A unit that fits the extruder footprint may still fail when roll inventory, curing space, maintenance access and loading bays are added.
Check land and building use, the existing approved building function, the feasibility of modifications, floor/loading constraints, utility capacity, drainage and truck access. The SIMBG building approvals portal is the official starting point for PBG and SLF workflows. Review the specific documents for the real premises; do not assume a prior tenant’s certificate automatically fits a different process or renovation.
The site review should reflect the full line and its supporting operations.
| Site variable | Film-specific question | Planning response |
|---|---|---|
| Electricity and cooling | Can the line operate at the quoted load with the required cooling and ventilation? | Obtain a load schedule from the machinery vendor and a written utility assessment. |
| Air emissions and odour | What exhaust, printing, curing or adhesive processes are in scope? | List process inputs and emission points for environmental screening. |
| Waste and scrap | How will edge trim, startup film, rejected laminate, ink/adhesive residues and packaging waste be handled? | Map quantities, separation, storage and disposal or recovery routes. |
| Warehouse and logistics | Can jumbo rolls be stored, moved and dispatched without unsafe crossings? | Test roll dimensions, handling equipment, aisles, doors, floor and loading access. |
| Building function | Do existing approvals match the intended production and any planned modifications? | Confirm document relevance; budget the required approval/change route if not. |
Environmental screening depends on the process, project scale, location and impacts. A film extruder alone may have a different impact profile from an integrated facility with printing, solvent-based lamination, curing, washing or extensive waste processing. Record each process and material instead of choosing AMDAL, UKL-UPL or SPPL from a sector label. The appropriate instrument must follow the current screening and applicable rules.
Make the lease or purchase decision conditional on the facts most likely to block the project: permitted use, building status, power and utility feasibility, environmental route, loading access and any essential renovation. If a candidate site fails one of these tests, compare alternative properties before committing to line delivery. A lower rent can be false economy when it forces major grid work or an impractical roll-handling layout.
For integrated film and packaging, the site plan should show every process and storage point from incoming resin through finished pack. If the company intends to add solvent, adhesive or printing systems only in a later phase, note the expansion condition so the change can be screened and approved before it is installed.
Turn OSS requirements into release evidence
Under the current risk-based system, use the selected KBLI, business scale and site to obtain the actual OSS requirements. PP 28/2025 governs risk-based business licensing and replaced PP 5/2021; it covers basic requirements, business licences, supporting licences, the OSS system and oversight. The official PP 28/2025 regulation record is a better basis than a checklist copied from a previous project.
Build a licence-and-proof register
For each activity, record the live KBLI detail page, the OSS risk result, the NIB and any other standard certificate or licence required for that activity. Add basic requirements that arise from the location and project, including spatial suitability, environmental screening and building status. Record the evidence required, responsible owner, submission reference, review or verification status, conditions, renewal date if applicable, and the point at which it must be complete.
- Legal entity: names, ownership, company purpose, address and activity list agree across the underlying documents.
- Site: the proposed location and building use are supported by relevant records, and the environmental route is documented.
- Activity: the exact KBLI, business scale and scope produce a current OSS requirement list.
- Product: any sector-specific standards, customer validations or destination-market certificates have an owner and deadline.
- Release: the required evidence is verified before trial or commercial operation at the stage specified by the applicable rules.
Do not state that NIB issuance alone makes every production activity ready. An NIB is the business identification record; additional standards, licences or supporting approvals may be required depending on the risk output and the actual activity. Similarly, an industrial building certificate is not a product conformity certificate, and a customer’s quality approval is not a government operating licence.
If the line includes printing, adhesives, cleaning, special barrier structures, post-consumer recycling or a new type of end-use, update the activity and environmental assumptions. For foreign ownership, also check each relevant KBLI against the current investment restrictions and conditions. Save the source and date for the decision because product scope and official portal entries can change.
For each unresolved issue, state whether it blocks lease signature, construction/modification, equipment installation, trial production or commercial release. This produces a real launch sequence instead of a generic list of permits. If a required approval depends on information that the machine supplier or site owner has not supplied, make that missing information a named dependency.
Use the film-line readiness test before launch
Before launching, test whether the company could hand an auditor, customer or competent official a consistent story from the planned product to the actual line and the documents covering it. The readiness check should compare the activity schedule, finished-product list, equipment layout, site documents, environmental result, OSS status and quality-release method. Any mismatch becomes a corrective action before the affected process begins.
A five-gate release test specific to film manufacturers and converters.
| Readiness question | Evidence of readiness | If the answer is no |
|---|---|---|
| Is the output defined? | SKU schedule with material, dimensions, application, customer spec and process steps | Pause the classification and equipment scope; do not file on a broad “film factory” description. |
| Is the activity map current? | Current OSS detail pages and documented decision for film stock vs finished packaging | Ask for clarification and update the scope before adding a second product stage. |
| Can the site host the full process? | Utility/load review, building documents, material/waste plan and process layout | Hold unconditional lease or installation approval until the missing item has a solution. |
| Are operational obligations trackable? | OSS output list, environmental/building route and assigned product-specific tasks | Define owner, authority, evidence and due date before production milestones are fixed. |
| Can every batch be released? | SKU specification, inspection record, traceability, change control and customer sign-off where needed | Resolve quality-system gaps before relying on expected output or customer sales. |
Run a final “what changed?” review against the project brief. A new layer, width, gauge, resin, print or adhesive; a new customer end-use; a second extrusion line; or an in-house conversion stage may change the production flow, product family, waste profile, utility demand and approval assumptions. Do not wait until the next formal renewal to record a material change that affects the current operating scope.
Use Indonesia company registration guidance to scope the initial entity workstream, then track factory, product and site requirements as separate controlled tasks. The company can be legally formed while the film line is still waiting for site modifications, environmental completion, customer qualification or another required output. Those states should be visible rather than compressed into “registered”.
Release the plant only when the sold product, the installed process, the site and the applicable permissions describe the same operation. If an important condition remains uncertain, record it as a stop item and get a competent determination rather than treating a hoped-for approval as a completed milestone.
Build a controlled route from product brief to launch
Align the product schedule, line design, premises, OSS requirements and quality evidence before fixing the commercial production date.
Frequently asked questions
What is the main KBLI candidate for plastic film production?
KBLI 2025 code 22204 covers plastic sheets and film and is an important starting point when film stock is the principal output. Verify the exact activity in the current OSS entry.
Does code 22204 automatically cover pouches and plastic bags?
Do not assume so. Compare finished packaging with the official packaging description and check whether the integrated operation needs additional activity classification.
Should a film factory use blown film or cast film?
The line choice depends on resin, film gauge, width, clarity, barrier and mechanical targets, output mix and customer acceptance criteria. Get specifications into the supplier quote.
Can existing factory documents be reused for a new film line?
Only after their relevance to the actual building, use, modifications, process and site requirements has been confirmed.
Does an NIB prove the film and finished packaging are ready to sell?
No. Activity-specific OSS requirements, site prerequisites and any product/customer qualification obligations need their own evidence.
