<![CDATA[This study aims to analyze the implementation of legal protection for importers regarding losses arising from the issuance of a Determination Letter on Prohibited and/or Restricted Goods (SPBL), which was subsequently annulled by the Tax Court in Decision Number PUT-005900.45/2024/PP/M.XVIIA of 2025. The study employs a normative-juridical method utilizing statutory, case, and conceptual approaches. The analysis focuses on the validity of the SPBL issuance, the forms of legal protection available to importers, and the mechanisms for recovering losses caused by the detention of goods during the dispute process. The findings indicate that the Tax Court provided repressive legal protection by annulling the SPBL after determining that the imported "Rack Fitting" was more appropriately classified under HS Code 9403.20.90 rather than HS Code 7308.90.99 (which falls under the category of prohibited and/or restricted goods). However, the annulment of the SPBL did not fully provide effective legal protection, as it did not automatically compensate the importer for material losses—specifically demurrage and storage costs—incurred while the goods were detained. These obstacles stem from the Tax Court's limited authority to award civil damages, jurisdictional ambiguities, and the inadequacy of customs procedural law in accommodating claims for losses resulting from administrative actions. Therefore, a regulatory reconstruction is required to establish certainty regarding the forum, authority, and mechanisms for recovering importer losses, ensuring that legal protection extends beyond the mere annulment of administrative decisions to effectively restore rights.]]>
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