Knowledge Exchange on Product Surveillance in Indonesia and Germany


Product surveillance ensures that certain legal requirements are met and that products are safe for consumers. GPQI organised an online exchange to promote cooperation between Indonesia and Germany and address challenges in ensuring product safety.

Man inspects machine for functionality and safety.

Product surveillance is crucial in trade. Not only does it ensure the quality of the products sold on the market and provides fair competition between businesses, but it also safeguards the safety of consumers. Product surveillance guarantees that products meet certain legal requirements and do not present an unreasonable risk or harm. This is particularly important in cross-border trade and in an increasingly digitalised world where products are delivered in many individual consignments.


On 2 February 2023, GPQI organised an online knowledge Exchange on Product Surveillance in Indonesia and Germany. This exchange improved understanding between Indonesia and Germany in order to reduce trade barriers and ensure consumer’s safety.


Mr Joachim Geiß from the Federal Ministry of Economic Affairs and Climate Action (Bundesministerium für Wirtschaft und Klimaschutz – BMWK) opened the exchange by highlighting the importance of market surveillance processes. He noted that market surveillance can be perceived as a burdensome control by the state. However, it is not only in the public interest for safety, but it also serves to prevent unfair competition and protect businesses from disproportionate costs. He emphasised the growing opportunities and challenges that the use of technology presents for trade, such as the use of artificial intelligence (AI) and e-commerce. He also expressed that the exchange of knowledge between Indonesia and Germany will provide valuable insights to both countries.


Product Surveillance for Non-Food Products in Germany

In Germany product quality surveillance is part of the market surveillance process. Market surveillance ensures that products sold on the market meet all the applicable requirements and that corrective action is taken if public safety is compromised. Mr Geiß explained the main legislation governing market surveillance, Regulation (EU) 2019/1020, which entered into force on 16 June 2021 and the new German Market Surveillance Act (MüG). The EU Regulation ensures effective market surveillance of non-food products online and offline. It facilitates joint activities and improves the effectiveness of market surveillance. The MüG subsequently implements the relevant provisions of the EU regulation.


In terms of implementation, Mr Geiß conveyed that market surveillance usually takes place at national level. In Germany, the Federal States are the first line of defence . He emphasised that BMWK is responsible for cross-sectoral issues and represents Germany in the EU. The implementation of market surveillance is also supported by the German Market Surveillance Forum (Deutsches Marktüberwachungsforum – DMÜF), where members discuss and coordinate cross-sectoral level issues and current topics at the Federal States level.


The implementation of market surveillance in Germany is also supported by third-party conformity assessment bodies. Ms Tan Swee-Yin from TÜV Süd explained that third-party conformity assessment bodies help to provide the highest level of assurance as the bodies are independent from the manufacturer and the consumer. She also highlighted that third-party conformity assessment bodies provide voluntary certifications such as the GS (Geprüfte Sicherheit – Tested Safety) mark, which gives manufacturers a competitive advantage and reduces internal compliance costs in navigating the global market. According to the new German Product Safety Act (ProdSG), the GS mark must also provide additional data to identify products and further ensure compliance and safety.


Product Surveillance for Industrial Products in Indonesia

Cars are assembled in a factory
Carlos Aranda / Unsplash

According to Mr Sopar Sirait, Head of the Centre for Industrial Standards Surveillance of the Ministry of Industry (Kementerian Perindustrian – MoI), product surveillance for industrial goods in Indonesia is carried out by both the MoI and the Ministry of Trade (Kementerian Perdagangan – MoT). Product surveillance consists of factory and customs surveillance - the responsibility of the MoI, and market surveillance - coordinated between the MoI and the MoT.


Mr Sirait also informed that there are two types of surveillance, the regular surveillance, and the special surveillance. The regular surveillance is based on the annual regular surveillance plan. It is planned by the head of the respective agency in coordination with the Directorate General of Industrial Development (Direktorat Jenderal Pengembangan Industri). As for the special surveillance, Mr Sirait explained that it is carried out based on reports from the public. After reviewing the reports, the responsible Head of Agency will carry out the surveillance.


Mr Sirait also highlighted the different surveillance processes for mandatory and voluntary Indonesian National Standards (Standar Nasional Indonesia – SNI). For mandatory SNI, the surveillance will be carried out in all areas. Surveillance in the factory consists of document verification and laboratory testing of products. In the market area, products are tested according to the conformity markings on the products. Regarding the voluntary SNI, Mr Sirait explained that the surveillance will be carried out by the responsible Head of Agency together with the appointed conformity assessment bodies.


The exchange was concluded with a Q&A session. Both countries agree that there are still many challenges in product surveillance, especially in the advancement of technology such as the use of AI and e-commerce. However, both countries are positive that the exchange provided many insights and knowledge and will consolidate further cooperation between Indonesia and Germany.

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