Management of Hazardous and Poisonous Waste (B3 Waste)

1. General overview

    • In general, there are two main business entity types that are covered by this Regulation:
      • Business entities whose production activities generate B3 waste. This type of business entities is mandated to reduce the B3 and store B3. If possible, they shall conduct utiliztion, processing, and/or secured landfill of generated B3 waste. If they don’t have any approval to do so, they should hand over their B3 waste to others with licenses to do so.
      • Business entities who provide B3 waste management services, which inlude collecting, utilization, processing/treatment, secured landfill and dumping of such waste. To conduct provide such services, business entities shall obtain Environmental Approval and Business Permit that specifies what kind of service they can do (e.g collecting, utilizing, processing, etc).
    • Technical Approval is needed to conduct utilization, processing, and/or secured landfill of B3. Meanwhile, the activities of reducing and storing B3 are included in the EIA study, which will be a basis for granting Environmental Approval. So the business entities do not need specific Technical Approval for these activities.
    • For transporting of B3 waste business, it requires recommendation of B3 waste transportation from the minister instead of Environmental Approval.
    • Company need to obtain decree on termination of activity of they want to stop the activity related to B3 waste management entirely or change the activity (change of utilization activity, location, etc).
    • Business entity may conduct only B3 waste management activities that are explicitly stated in their Technical Approval and Environmental Approval.

2. B3 waste categories

  • B3 waste is categorized into B3 Waste Category 1 and 2 (see Annex IX)
  • In the case of waste that are not listed in Annex IX but has indication as dangerous and hazardous, the ministry will conduct property test to identify which category the waste falls under (see Annex X and Annex XI for test parameters).

3. B3 waste management activities

B3 waste management activities consists of:

  • Reduction (Articles 283-284): Reducion shall be conducted by business entities whose activities generate B3 waste. The efforts on reduction shall be reported once every 6 month to the ministry
  • Storage (Atricles 285-297): which shall be coducted conforming to conditions for storage location and facilities and packaging. There is also a time limit for storing B3 waste. Storage activity should be reported once every 6 month to the ministry, governor or regent/major based on their authority
  • Collection (Articles 298-309): Any hand-over of B3 waste to B3-waste collector shall be recorded in written minute. B3-waste collector cannot hand-over the waste to any other collector. The collecter can only store the waste for 90 days. When the time limit is exceeded, the collector shall hand-over the waste to other party who is licensed to conduct utilization, processin/treatment and/or secure landfill of B3 waste.
  • Transportation (Articles 310-314): Transporter shall submit the manifest of B3 waste transportation to the ministry. Transporters shall submit a report on the implementation of B3 waste transportation containing: name, source, property and quantity of B3 waste; the number and types of transportation vehicles used; final destination of the transportation; and written record of B3 waste hand-over. The report shall be submitted to the ministry at least once every 6 months
  • Utilization (Articles 315-341): B3 waste can be utilized as raw material substitute, energy resource substitute, raw material or others. In order to utilize the waste, business entities need to obtain Technical Approval. Utilization of specific source B3 waste that is generated from integrated cloded production cycle (see table 3 and 4 Annex IX) as byproduct is exempted from requirement to obtain Technical Approval. The utilization is forbidden for high radioactive waste unless the radioactivity level can be reduced under the level regulated in this regulation.
  • Treatment/ Processing (Articles 342-365): Treatment can be done by any of the following methods: a. thermal (technical standards are given in Article 345); b. stabilization and solidification (technical standards are given in Article 345, see also Annex XIII); c. other ways in according with advanced science and technology. If the business entity wants to terminate the treatment activity, the responsible authorative official will check whether any environmental restoration measure needs to be performed by the business entity. The termination is allowed only after necessary restoration measures are finished.
  • Landfill (Articles 366-389): Landfill can be done in landfill facilities in the form of: a) final landfill, b) injection well, c) replacement in ex-mining area, d) dam for mining waste storage, or e) other facilities in accordance with advabced science and technology. Each of these facilities are regulated by their own requirements and conditions. Post-operation monitoring should be conducted at least (since the declaration of termination) for:

30 years for final landfill and injection well

10 years for dam for storing mining waste

5 years for replacement in ex-mining area

  • Dumping (Articles 390-402): In principle, dumping of B3 waste to environment is forbidden unless they have technical approval from the government. The person who can get this approval is the party that generate the B3 waste the first time (original generator). Land dumping must follow the provisions on landfill as stated in this Regulation. Meanwhile conditions for dumping to the sea are stipulated in this sub-section, including what type of B3 waste can be dumped and the conditions for dumping areas.

4. Exemption for certain sources of B3 waste

B3 waste from specific sources can be exempted from requirements on B3 waste. Business entities may apply for this exemption to the Ministry.

5. Transboundary Movement (Export)

  • To export the B3 waste, business entities shall:
    1. Make an application to the ministry
    2. Inform the route of transport
    3. Fill the notification form of B3 waste export
    4. Obtain permit for exporting B3 waste
    5. The ministry will notify the destination country and country of transit of the export of B3 waste. If the destination country and transit country approve, the ministry will issue B3 waste export recommendation that will be a basis for issuing an export permit by Minister of Trade.


Management of Non-B3 Waste

1. General overview

  • Management of non-B3 waste does not need specific Technical Aproval. The activity of management of non-B3 waste is included in the EIA study which then will be the basis for granting Environmental Approval.
  • If there is a change in non-B3 management activity, the business entity shall file a change in Environmental Approval.
  • Non-B3 waste is categorized into:
    1. Registered non-B3 waste, which is listed in Annex XIV
    2. Special non B3 waste, which has been exempted from the requirements on B3 waste management under Article 407.

2. Management of special non-B3 waste

Management of special non-B3 waste is conducted pursuant to conditions stated in its Exemption Decree which sprcifies: identity, form, source, quantity and type of management/treatment method of the non B3 waste

3. Management of registered non-B3 waste

Management activities of Non-B3 waste are consisted of:

  • Reduction (Article 454)
  • Storage (Articles 455-458)
  • Utilization (Articles 459-464)
  • Landfill (Articles 465-466)

4. Transboundary movement (export)

If the destination country categorize the non-B3 waste as B3 waste, the export process follow the B3 waste export procedure.

5. Reporting

Reporting of implementation of non B3 waste management is submitted at least once a year to the minister, governor or regent/city mayor based on their authority

On October 29, 2021, the Regulation of the Minister of Environment and Forestry No. 19/2021 on Management Procedure of Non-Hazardous and Toxic Waste was established to implement the above requirements.


Government Regulation No. 22 of 2021 on Environmental Protection and Management: