1. Introduction: Why KBLI is Your Business Roadmap in Indonesia
In every consultation regarding business licensing in Indonesia, the question about the Indonesian Standard Industrial Classification (KBLI) code is almost always a crucial starting point. KBLI is a standard five-digit code that every Business Actor (whether local or foreign company) must include when registering their business through the Online Single Submission Risk-Based Approach (OSS RBA) system.
However, choosing a KBLI is not just about listing a code that matches the business activity. There is a fundamental difference between Primary KBLI (KBLI Utama) and Supporting KBLI (KBLI Pendukung), and a misunderstanding can lead to the rejection of marketing authorization (such as the PKRT Notification Marketing Authorization from the Ministry of Health) or even administrative sanctions.
Through this article, INSIGHTOF Consulting Indonesia will thoroughly dissect the difference between Primary KBLI and Supporting KBLI. This is to ensure that you have a strong legal and operational foundation.
2. Introducing INSIGHTOF: Your Trusted Partner in Regulatory Compliance
INSIGHTOF Consulting Indonesia is a trusted expert focused on Regulatory Affairs (RA) in Indonesia, covering licensing from the National Agency of Drug and Food Control (Badan POM – for Cosmetics and Food/Beverages) and the Ministry of Health (Kemenkes – for Medical Devices and Household Health Products/PKRT). Since 2016, we have successfully registered over 1,000 products, helping our clients—ranging from Korean companies, multinationals, to Indonesian public companies—in navigating regulatory complexity quickly and accurately.
3. The KBLI Structure in the Business Licensing System
KBLI is a 5-digit classification code that reflects the type of economic activity carried out by the company. In the context of business licensing, KBLI divides business activities into three main groups:
3.1 Primary KBLI (KBLI Utama)
A Primary KBLI represents the company’s core business activity. It serves as the main reference for:
- Business risk classification in OSS
- Issuance of operational licenses
- Evaluation by technical authorities (BPOM, Ministry of Health, etc.)
Key Characteristics of a Primary KBLI:
- Generally only one Primary KBLI
- Determines whether the business is low-, medium-, or high-risk
- Always reviewed during technical license applications
- Must accurately reflect actual business activities
Examples:
- Medical device distributor
➝ Primary KBLI: Wholesale of Medical Devices - Cosmetic manufacturer
➝ Primary KBLI: Cosmetic Manufacturing Industry
Note: Many license applications fail not because of the product, but because the Primary KBLI does not match the real business activity.
3.2 Supporting KBLI (KBLI Pendukung)
A Supporting KBLI refers to additional business activities that help facilitate operations but are not the company’s main focus.
Key Characteristics of a Supporting KBLI:
- Can include multiple KBLIs
- Does not determine the main business risk level
- Is not always used as the basis for technical licenses
- Functions to support the Primary KBLI
Examples of Supporting KBLIs:
- Warehousing activities
- General wholesale trading
- Internal consulting or auxiliary services
📊 Key Differences Between Primary and Supporting KBLI
| Aspect | Primary KBLI | Supporting KBLI |
|---|---|---|
| Function | Core business activity | Supporting activity |
| Quantity | Usually one | Can be multiple |
| OSS risk impact | Determines risk level | Does not |
| Basis for BPOM / MoH licensing | Yes | No |
| Audit impact | Critical | Limited |
4. Common Mistakes in Practice⚠️
- 1. Using a Supporting KBLI as the Primary KBLI
➡️ Consequences:- Technical licenses rejected
- Mandatory OSS revisions
- Delays in licensing timelines
- 2. Assuming All KBLIs Can Be Used for Licensing
➡️ Reality:- Technical authorities primarily assess the Primary KBLI
- A Supporting KBLI cannot replace the role of a Primary KBLI
- 3. KBLI Exists, but the Activity Does Not
➡️ Examples:- Manufacturing KBLI without a factory
- Distribution KBLI without a compliant warehouse
🔄 Can a Primary KBLI Be Changed?
✅ Yes, through the OSS system.
However:
- Existing licenses may be affected
- Certain licenses may need to be re-aligned
- Changes should not be made without a regulatory impact analysis
🧾 Real Case Example
Case: Imported Cosmetics Company
- Primary KBLI: General Wholesale Trading
- Supporting KBLI: Cosmetics Wholesale
➡️ BPOM notification application: Rejected
➡️ Resolution: Primary KBLI changed to Cosmetics Wholesale
5. Frequently Asked Questions (FAQ) About KBLI
| Question | Answer |
| Does the Primary KBLI determine the licensing risk class? | Yes, the Primary KBLI can directly affect the licensing risk class in the OSS RBA, which in turn determines the type of authorization that must be met (e.g., Marketing Authorization, Notification Marketing Authorization, or Standard Certificate)19. |
| Can one company have more than one Primary KBLI? | Yes, but only the most relevant Primary KBLI to the product/service being registered will be verified by the relevant authority (Badan POM or Kemenkes). |
| What happens if my KBLI is incorrect? | If your KBLI is incorrect, your product licensing will be rejected at the administrative verification stage. You must apply for a KBLI change in OSS and resubmit the licensing application. |
✔️ INSIGHTOF Consulting Indonesia has deep experience in analyzing the basic licensing of companies (NIB/KBLI) before moving on to product licensing (Marketing Authorization/Notification). We ensure your business and legal structure is 100% aligned with the product regulatory needs of Badan POM and the Ministry of Health.
Conclusion
KBLI is not just a statistical code, it is the legal foundation that validates every one of your business activities. Errors in choosing or managing your KBLI can significantly delay the product licensing process.
Make sure you start your regulatory journey with the right step. Contact INSIGHTOF Consulting Indonesia for an accurate KBLI analysis and an integrated licensing strategy.
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