Jakarta. A gap between Indonesia’s crude palm oil (CPO) export records and trading partners’ import data does not by itself prove that the country is losing Rp 600 trillion ($33.51 billion) in state revenue each year, an economist said, urging further scrutiny of the government’s estimate.

Next Indonesia Center Director Herry Gunawan said the figure cited by Agriculture Minister Andi Amran Sulaiman should be assessed against international trade data and the methodology used to calculate the alleged losses.

“In my view, the figure presented by Agriculture Minister Amran Sulaiman is inaccurate,” Herry said in a written statement on Friday.

UN Comtrade data shows Indonesia’s palm oil exports averaged $20.3 billion annually over 2016-2025, equivalent to around Rp 305 trillion a year assuming an exchange rate of Rp 15,000 per dollar.

“That is only an allegation of misinvoicing,” Herry said.

Trade misinvoicing refers to discrepancies between the value of exports reported by one country and the corresponding imports reported by its trading partner. Herry said such gaps do not automatically indicate criminal activity or lost state revenue, as they can result from reporting errors and other differences in how trade is recorded.

“So it cannot simply be said that state revenue has disappeared. That would be an excessive claim without first understanding the issue of misinvoicing,” he said.

Herry also cited Next Indonesia Center estimates that Indonesia’s palm oil export under-invoicing amounted to around $1.2 billion annually between 2014 and 2023.

If around 20% of that figure was attributable to misinvoicing, the value would amount to about Rp 61 trillion a year at an exchange rate of Rp 15,000 per dollar — roughly 10% of the figure cited by the government.

Differences in reported trade values can also stem from exchange-rate differences and commercial arrangements, including discounts or other terms agreed between companies, Herry said.

Determining whether under-invoicing constitutes a violation therefore requires transaction-level examination, including whether companies manipulated Harmonized System (HS) codes or breached transfer-pricing rules.

“For alleged transfer pricing, the question is whether the transaction actually violates the arm’s-length principle,” Herry said.

Authorities should examine individual contracts, the classification of goods and other transaction-specific details rather than drawing conclusions from aggregate trade discrepancies, he said.

“The key is that further evidence is needed, and the issue cannot be generalized. Each contract between businesses, the classification of goods shipped and other details must be examined individually,” he said.

Herry said the government should also prioritize strengthening oversight across Indonesia’s export ecosystem through better integration of trade data and export documentation.

He pointed to Singapore’s TradeNet and the United States’ Automated Commercial Environment (ACE) as examples of systems that integrate trade information for more comprehensive monitoring.

Herry also called on Danantara Sumberdaya Indonesia (DSI), the government entity established to manage natural-resource assets, to strengthen oversight without disrupting existing commercial relationships between producers, sellers and buyers.

“DSI’s presence should strengthen the existing ecosystem, namely the relationship between producers, sellers and buyers,” Herry said.

Better governance and data integration would allow the government to strengthen export monitoring without hampering trade activity, he said.

“This is the kind of governance strengthening that is needed, with the hope that state revenue from natural-resource commodities will also increase,” Herry said.

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