Indonesian liquid producers have been talking about export for years. PPEI attended the World Vape Show in Dubai. Industry leaders speak about international cooperation. The ambition is real.
But ambition and readiness are different things. The honest picture is that most Indonesian e-liquid products are not currently export-ready, not because the flavors are poor or the production quality is insufficient, but because the documentation does not exist. And in every regulated export market, documentation is the product. Without it, a shipment does not enter. It gets seized at the border or rejected by the buyer before it even ships.
This article goes market by market. For each one it explains whether the market is open, what it specifically requires, and where Indonesian producers typically fall short. The goal is an accurate picture of what export actually involves so producers can make a plan rather than a wish.
It also covers three practical topics that almost nobody in the Indonesian vape industry talks about: customs classification codes, product liability insurance, and why the flavor profiles that sell best domestically often do not work in Western markets without adjustment.
Before Anything Else: The HS Code That Governs Every Shipment
Before a single bottle of e-liquid crosses any border, it needs to be correctly classified under the Harmonized System, the international customs coding framework maintained by the World Customs Organization and used by over 200 countries.
The correct HS code for e-liquid is 2404.12. This code covers products intended for inhalation without combustion that do not contain tobacco. Getting this classification right is the first step in every export transaction. Getting it wrong, or using an older, incorrect code, puts the shipment into what trade professionals call customs limbo, where goods are held at the border pending clarification, subject to additional inspection, and vulnerable to misclassification penalties.
In Indonesia, the Directorate General of Customs and Excise manages the national adaptation of the HS system through the BTKI classification framework. Indonesian exporters need to ensure their export documentation, including the Commercial Invoice, Packing List, Certificate of Origin, and any applicable phytosanitary or health certificates, all use the consistent and correct HS code from the point of departure.
Why does this matter in practice? Because several destination markets apply different tariff rates and documentation requirements based on HS classification. The UAE, for example, applies specific import duties and MoIAT certification requirements to products under 2404.12 that differ from other chemical or consumer goods categories. Malaysia’s MOH registration system and excise tax stamp requirements are triggered by this classification. Misclassifying a shipment, even accidentally, can result in seizure, return, or a requirement to re-export and resubmit with corrected documentation. Starting every export conversation with the correct HS code saves time and establishes immediate credibility with customs brokers and international buyers.
The ASEAN Map: Know Where the Doors Are Closed
Before discussing where Indonesian products can go, the closed markets need to be named clearly.
Singapore has a total ban on vaping. Under the Tobacco and Vaporisers Control Act which took full effect May 1, 2026, the import, sale, possession, and use of e-cigarettes and e-liquids is fully prohibited. Penalties for importers include fines of up to SGD 200,000 and up to six years in prison. Singapore is not a market. It is not becoming one. Proactiveinvestors NAThe Jakarta Post
Thailand, Cambodia, and Laos have also outlawed all e-cigarettes and vaping products. Vietnam enacted a total ban effective January 1, 2025, covering manufacture, import, distribution, and retail of all vape and heated tobacco products. dataEssence
The markets that are open and realistic for Indonesian producers are the UAE, Malaysia, the Philippines, and over the medium term, the European Union and UK through compliant distribution partners.
The UAE: Open, Growing, and Technically Demanding
The UAE is the most accessible high-value export market for Indonesian e-liquid producers and the one with the most realistic near-term opportunity.
Vaping was legalised in the UAE in April 2019 when the Emirates Authority for Standardization and Metrology introduced the regulatory framework that permitted approved e-cigarettes and e-liquids to enter the market. Regulatory oversight has since transferred to the Ministry of Industry and Advanced Technology, which manages the Emirates Conformity Assessment Scheme, known as ECAS, the certification programme that every legal vape product in the UAE must pass through. PubMed
The UAE e-cigarette market is expected to reach approximately USD 300 million by 2025, driven by regulatory clarity, increasing consumer demand, and product diversity. Dubai functions as a regional distribution hub for the wider Middle East, meaning a successful market entry in the UAE can open distribution into several neighbouring markets simultaneously. Frankfurt University of Applied Sciences
The specific requirements for e-liquid are the following.
Nicotine concentration must not exceed 20 mg per millilitre. Refill liquid containers are limited to 50ml. All packaging must display health warnings and a full ingredient list. E-liquids cannot contain residual heavy metals above specified limits, tobacco-specific nitrosamines NNN and NNK, or mineral or vegetable oils. Laboratory testing is required from MoIAT-accepted facilities covering nicotine concentration, product quality, and chemical composition. Economicsforhealth
A note on bottle size: Indonesia’s own PP 28/2024 limits open-system liquid to 10ml and 20ml containers from July 26, 2026. Both formats fall within the UAE’s 50ml limit, so domestically compliant Indonesian packaging is compatible with UAE requirements on this point.
Where Indonesian producers typically fall short on the UAE market is documentation. The MoIAT ECAS certification process requires a full ingredient declaration at the compound level. A general food-grade certificate from a flavor supplier does not satisfy this requirement. You need compound-level GC-MS verified documentation of your formula. Without it the certification process cannot be completed.
The practical path starts with getting your formulas documented, verifying that no prohibited substances are present, and then engaging a UAE-based distributor who can sponsor the ECAS application. The distributor relationship is not optional. It is built into the regulatory structure.
Malaysia: Accessible, but Tightening Fast
Malaysia is the most natural first export market for many Indonesian producers. Geographic proximity, cultural similarity, a shared language, and a legal vaping framework all make it more accessible than more distant markets.
Vaping is legal in Malaysia under the Control of Smoking Products for Public Health Act 2024, Act 852, which came into effect October 2024. All smoking products including e-liquids must be registered with Malaysia’s Ministry of Health. Nicotine concentration is capped at 20 mg per millilitre from October 1, 2025. Pod capacity is capped at 3ml per cartridge, reducing to 2ml from October 2026. Online sales are completely banned. Products can only be sold through licensed physical retail. All products must carry graphic health warnings covering 75% of packaging and fiscal tax stamps. WikipediaIFRA
Laboratory testing is required at designated labs to screen for prohibited substances including illicit drugs. Products containing suspicious ingredients will be rejected outright. IFRA
Several Malaysian states including Terengganu, Perlis, Kelantan, and Johor have either banned vape sales or stopped issuing new licenses, which reduces the effective retail footprint despite national-level legality. Coptis
For Indonesian producers, Malaysia is the most accessible pathway because the regulatory standards are comparable to what PerBPOM 18/2025 is introducing domestically. A producer who is genuinely compliant with PerBPOM 18/2025 is most of the way to Malaysian compliance. The gap is primarily administrative, specifically MOH registration and fiscal stamp compliance, rather than a fundamental product reformulation.
The Philippines: Large Market, Dual Compliance Required
The Philippines is one of the fastest-growing vape markets in Southeast Asia. By 2025 the market is expected to exceed PHP 34.7 billion, approximately USD 617 million, with over 1.9 million adult users. The country has a relatively liberal regulatory framework, and starting January 2025, the government fully implemented a dual compliance mechanism requiring both mandatory product certification and excise tax stamps. IFRA
All vape products legally sold in the Philippines must be registered with the Philippine Food and Drug Administration. The dual certification requirement means documentation gaps are caught aggressively. As with Malaysia, the fundamental requirement is that you can prove what is in your product and that what is in it is permitted. nih
The practical challenge for Indonesian producers is that Philippine FDA registration requires product documentation that most do not currently have. Flavor ingredient disclosure requirements, testing certifications, and the excise tax stamp system all require investment in compliance infrastructure before the first shipment can be made.
The EU and UK: The Highest Standard, The Biggest Opportunity
EU and UK markets are not a realistic direct export destination for most Indonesian producers in the near term. But they are worth understanding for two reasons.
First, EU and UK standards are the reference framework for every other regulated market. A product that is fully compliant with the EU Tobacco Products Directive is compliant everywhere else. Build to EU standard and every other market becomes a subset.
Second, EU and UK markets represent significant demand for premium, differentiated e-liquid products. Indonesian producers with genuinely distinctive flavors, full compliance documentation, and clean GC-MS-verified formulas can access these markets through European distribution partners.
The EU TPD requires maximum nicotine concentration of 20 mg per millilitre, maximum refill container size of 10ml, notification to the relevant national competent authority in each member state at least six months before first placement on market, full ingredient disclosure including all additives and their quantities, emissions testing data, and no CMR substances at any concentration. nih
The UK applies the same standards with minor post-Brexit variations. Both markets require the product to have been tested and fully documented before the notification is submitted. For Indonesian producers, the path to these markets runs through a European distribution partner who manages the notification process, and through formulas that are genuinely clean and documented.
What Indonesian Products Currently Fall Short On
Across every export market above, the same gap appears repeatedly.
Most Indonesian producers cannot provide a full compound-level breakdown of their flavor concentrates because their suppliers never provided this documentation. This is the single most common barrier to export readiness.
Many flavor concentrates in the Indonesian market contain CMR-classified substances including diphenyl oxide, benzaldehyde, and in some cases Category 1B carcinogens such as estragol or methyl eugenol. None of these are permitted in any of the regulated export markets described above.
Nicotine concentration documentation is often insufficient. Every export market requires verified nicotine content at the batch level. A declared level on a label is not the same as a laboratory-verified result.
The Insurance Gap
This is the most overlooked barrier to export and the one that stops serious conversations with international distributors before they start.
Product liability insurance that covers international markets is a standard requirement from distributors and retailers in the UK, UAE, Australia, and the EU. When a major UK distributor or UAE wholesaler reviews a potential supply relationship, one of their first questions is whether the manufacturer carries product liability insurance that covers their territory. Most Indonesian producers do not have this coverage and are not aware it is expected.
The reason it matters is straightforward. If a product causes harm to a consumer in a foreign market, every party in the supply chain is potentially liable, including the original manufacturer, even if they are based in Indonesia. In markets with strong consumer protection frameworks like the UK and UAE, this exposure is real and distributors protect themselves by requiring suppliers to carry adequate coverage before signing any contract.
Product liability insurance for e-liquid manufacturers covering international markets is a specialist category. Standard Indonesian business insurance does not cover it. Getting coverage requires working with an insurance broker who has experience in the vaping sector and who can source policies that explicitly cover e-liquid products and the health-related claims specific to the category. Policies need to be checked carefully for health hazard exclusions, which some insurers use to exclude coverage for claims arising from inhalation products specifically.
Building export readiness means getting your insurance in order alongside your documentation. Arriving at a negotiation with a UAE or UK distributor without product liability insurance in place signals that you are not yet operating at the level they require, regardless of how good your product is.
The Flavor Profile Gap: Why Indonesian Liquid Needs Reformulation for Western Markets
Indonesian e-liquids have a well-deserved reputation for bold, layered flavor profiles with high sweetness levels. This is a strength in the domestic market and in markets with similar consumer preferences. In most Western export markets, it is a challenge that needs to be anticipated and planned for.
The issue is ethyl maltol and sucralose, the two sweeteners most commonly used in Indonesian liquid to achieve that rich, sweet character. Both are widely used and entirely legal. But at the concentrations common in Indonesian formulations, they cause coil-gunking, where the sweeteners caramelize and build up on the heating coil, significantly shortening its lifespan and producing a burnt taste that degrades quickly. Western consumers who use premium coils in rebuildable devices are particularly sensitive to this issue and will reject a product that destroys their equipment.
Beyond coil performance, Western consumers, particularly in the EU and UK, have moved toward more nuanced, lower-sweetness profiles over the past three years. The regulatory environment in these markets has also introduced scrutiny of certain sweeteners at high concentrations. Products that taste overpowering or one-dimensional to a Western palate, even if they are extremely popular domestically, will struggle to find repeat buyers.
Reformulating for Western markets does not mean abandoning what makes Indonesian liquid distinctive. It means recalibrating. Reducing sweetener load while maintaining flavor complexity. Adjusting the balance between top notes and base notes so the profile opens up at the lower sweetness level rather than collapsing. This is where working with a flavor house that understands both the Indonesian profile tradition and the technical requirements of Western consumer expectations produces something genuinely competitive rather than merely compliant.
Indonesian brewers who want to access EU and UK markets specifically should expect to invest in at least one round of reformulation before their domestic formulas are export-ready by flavor profile standards, separate from and in addition to the documentation and regulatory compliance work.
The Practical Sequence for a Producer Who Wants to Export
The first step is getting your formulas documented through GC-MS analysis. This gives you a compound-level picture of what is in your product and whether any prohibited substances are present.
The second step is resolving any compliance issues found. If prohibited substances are identified, reformulate before investing in any export market process.
The third step is building your documentation package. This includes GC-MS results, full ingredient declarations, nicotine concentration verification from batch-level testing, and safety testing data. Having this ready before you approach a buyer or a registration process is the difference between a serious conversation and a dead end.
The fourth step is getting your HS codes right and working with a licensed customs broker who has specific experience with nicotine products under 2404.12.
The fifth step is obtaining product liability insurance that covers your target export markets. Do this before approaching any international distributor. It is a basic credibility requirement and the conversation will go further if it is already in place.
The sixth step is identifying a distribution partner in your target market. Every regulated export market requires local regulatory knowledge and in some cases a local sponsor or registered importer. A good distribution partner guides the registration process and opens retail relationships. Finding the right one requires having a product that is worth their investment, which means the documentation, the insurance, and for Western markets, the flavor profile work all need to be done first.
The Indonesian vape industry has genuine export potential. The flavor creativity developed by Indonesian brewers, the manufacturing infrastructure that exists in Bandung and elsewhere, and the compliance foundation being built through PerBPOM 18/2025 are all ingredients of a credible international story. The gap between potential and reality is documentation, insurance, and in some cases flavor adaptation. Close those gaps in the right order and the markets described above become genuinely reachable.
We are based in Bandung and work with a certified R&D laboratory in Europe. If you want to understand where your current formulas stand before approaching any export market, we can help you get a clear answer.
