Indonesia Indonesia fully reforms hazardous waste recycling rules

The Regulation of the Minister of Environment and Forestry No. 18 of 2020 on the utilization of hazardous waste was enacted in Indonesia on August 28, 2020. It came into effect on the same date of its enactment, that the previous Regulation of the Minister of Environment No. 2 of 2008 became invalid accordingly. This new regulation provides details on the utilization of hazardous waste (B3 waste), including the relevant requirements for B3 waste generators. “Utilization activities” of B3 wastes are defined as “the reuse, recycling, and/or recovery of B3 waste for the purpose of converting them into products which can be used as raw materials, secondary materials, or alternative fuels, that are safe for human health and the environment.”

The original text of this regulation is downloadable at the following URL.


Obligations of B3 waste generators

B3 waste generators must carry out the utilization activities of B3 waste on their own. However, they may entrust a third-party with the tasks. Under the regulation, there are four types of final applications by utilizing B3 waste as follows.

    1. Use of B3 waste as a substitute for raw materials
    2. Use of B3 waste as an alternative energy source
    3. Use of B3 waste as raw material
    4. Utilization of B3 waste along with advancement in science and technology

Each utilization application has its own set of terms and conditions. For example, in the case of “a. Use of B3 waste as a substitute for raw materials,” the following requirements must be complied with.

    1. The B3 waste to be used must meet the minimum clarifications as follows.
    2. The same properties or functions as the raw material being substituted, and
    3. Less than 100% of the total raw materials used to produce the product (i.e., B3 waste should not be the single-sourced component of raw materials)
    4. Products manufactured by B3 waste utilization are subject to Indonesia National Standards (SNI)
    5. Environmental standards must be met in accordance with relevant regulations.


Monitoring of B3 waste use

B3 waste generators must monitor the B3 waste utilization activities as follows.

    1. Type, characteristics, and the total amount of B3 waste to be used
    2. Quality test results of B3 waste utilization products along with the applicable standards
    3. Total amount of products manufactured in a given period of time
    4. Total amount of B3 waste generated in a given period of time
    5. B3 waste offset activities

“B3 waste offset activities” consist of receiving B3 waste, storing B3 waste, using B3 waste, and recording new B3 waste generated as a result of B3 waste utilization activities. The record-keeping templates and details are specified in Annex II of this regulation. The documentation of the B3 waste offset activities must be submitted to the Minister of Environment and Forestry at least once every three months.