InfoSAWIT, JAKARTA – Loading ramps are emerging as a critical but often overlooked link in Indonesia’s palm oil supply chain as global markets demand greater transparency and traceability ahead of the implementation of the European Union Deforestation Regulation (EUDR).
The facilities serve as collection points where Fresh Fruit Bunches (FFB) from independent smallholders are purchased, weighed, sorted, consolidated, and subsequently delivered to palm oil mills.
The issue was discussed by Dr. M. Windrawan Inantha, Strategic Advisor at CECT Sustainability, Universitas Trisakti, during a multi-stakeholder forum titled Strengthening a Transparent, Inclusive and Sustainable Palm Oil Supply Chain that Meets ISPO and EUDR Requirements, organized by UNDP Indonesia in Jakarta on September 10, 2026.
Speaking during a session on the dynamics of loading ramps and palm oil mills without plantations, Windrawan said loading ramps should not automatically be treated as a problem within the FFB trading system.
“Loading ramps are the market’s answer to conditions on the ground because smallholder plantations are scattered and their harvest volumes are relatively small, while FFB cannot wait more than a day without losing quality,” Windrawan said in a statement cited by InfoSAWIT on Friday (11/9/2026).
According to him, loading ramps perform an important function by connecting independent smallholders with palm oil mills. Rather than eliminating them, policymakers should integrate these facilities into a transparent and traceable supply-chain system.
Non-Partner Supply Chain Remains a Gap
Windrawan said regulations governing FFB purchases from partner smallholders are relatively detailed. Minister of Agriculture Regulation No. 13/2024, for example, regulates pricing formulas and reporting obligations.
The challenge lies in transactions involving independent smallholders, many of which take place outside formal partnership arrangements. FFB can pass through traders, agents, cooperatives, and loading ramps before reaching palm oil mills.
“We have good regulations for the partner channel, while the non-partner channel, which actually represents a large volume, does not yet have an equivalent transparency architecture,” he said.
The issue is becoming increasingly significant following Presidential Regulation No. 16/2025 and Minister of Agriculture Regulation No. 33/2025, which expand the scope of Indonesia Sustainable Palm Oil (ISPO) across the supply chain.
At the same time, the EUDR requires traceability to the geographic location of plantations.
“When market requirements reach the plantation location, regulations that stop at the partnership gate are clearly no longer sufficient,” Windrawan said.
Palm Oil Mills Without Plantations Need a System-Based Approach
The discussion also covered palm oil mills without their own plantations. Windrawan said their existence should not automatically be viewed as a competition or governance problem.
Referring to the Competition Commission’s (KPPU) position, he said palm oil mills without plantations could provide smallholders with more buyer options, particularly in areas previously dominated by only one or two mills.
The risk, he argued, emerges when a mill’s processing capacity significantly exceeds the supply available in its surrounding area. In such circumstances, pressure to secure raw materials could increase the risk of receiving FFB whose origin and legality have not been verified.
“Integrated mills that purchase large volumes of external FFB face exactly the same risk as mills without plantations. The benchmark should therefore be behavior and supply systems, not the label attached to the mill,” he said.
Windrawan also pointed to approaches used under the Roundtable on Sustainable Palm Oil (RSPO), including independent collection centers in Thailand and dealer programs in West Africa, which demonstrate that intermediaries can be integrated into traceability systems rather than simply removed.
Under Indonesia’s ISPO framework, however, there is currently no specific certification category for loading ramps. Nevertheless, these collection points still have a responsibility to transmit information about the origin of FFB to palm oil mills subject to ISPO requirements.
For palm oil mills without plantations, the ISPO obligation is clearer because they fall under the category of processing businesses.
Regulated Inclusion Proposed Through Pilot Projects
To close governance gaps without undermining the economic role of loading ramps and small aggregators, Windrawan proposed a regulated inclusion approach.
He suggested that the policy should initially be tested through pilot projects rather than immediately implemented nationwide.
Pilot locations could be selected in major palm oil-producing districts with large smallholder plantation bases, numerous FFB aggregation points, competing palm oil mills, and sufficient local government capacity.
“Registration of loading ramps and mills, an initial supplier register, as well as price and weighing literacy for smallholders can begin in the first year of the pilot,” he said.
Success should not be measured simply by the number of registered loading ramps. More important indicators include the ability to identify FFB origins, the net price received by smallholders after logistics costs, payment speed, weighing and grading disputes, buyer concentration, and compliance costs per tonne for small businesses.
Windrawan warned that efforts to strengthen traceability should not unintentionally eliminate small aggregators that provide independent smallholders with access to markets.
“If the pilot project works well, its impact on smallholder prices, logistics costs, competition and traceability can become the basis before we discuss a national obligation,” he said.
He called on ministries, local governments, palm oil mills, smallholder associations and certification bodies to jointly determine pilot locations.
For Windrawan, the debate over loading ramps and palm oil mills without plantations cannot be resolved through discussions alone. Field trials are needed to determine whether regulated inclusion can strengthen traceability while maintaining market access for smallholders and the viability of small-scale aggregators. (T2)
