Latest Regulatory Updates for Hazardous and Toxic Waste (B3) Management in Indonesia: Comprehensive Analysis of 2024-2025 Regulatory Framework, Compliance Requirements, and Industry Implementation Strategies

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Executive Summary

Indonesia's regulatory framework for hazardous and toxic waste (Bahan Berbahaya dan Beracun - B3) continues to experience significant changes during 2024-2025 period. The Ministry of Environment and Forestry has issued a series of ministerial regulations strengthening B3 waste management requirements across various industrial sectors^[3]. These regulatory updates respond to growing environmental challenges from industrial expansion, increasing waste generation volumes, inadequate treatment capacity, and enforcement gaps that have contributed to environmental contamination incidents affecting communities and ecosystems nationwide.

The cornerstone of Indonesia's B3 waste regulatory framework remains Government Regulation No. 101 of 2014 concerning Management of Hazardous and Toxic Waste, which establishes fundamental definitions, classification systems, management requirements, institutional responsibilities, and sanction mechanisms^[1]. This foundational regulation defines B3 waste as residues from business activities and production processes containing hazardous and toxic substances due to direct or indirect characteristics including flammability, explosiveness, reactivity, toxicity, infectivity, corrosivity, and radioactivity posing risks to environmental sustainability, human health, and other living organisms.

Recent regulatory developments include enhanced criteria under the Environmental Performance Rating Program (PROPER) 2025, which now requires all industrial facilities to demonstrate systematic waste identification, proper storage meeting regulatory specifications, complete manifest documentation, and waste minimization programs with measurable reduction targets^[2]. The program's expansion to all sectors marks a significant shift from previous years when only certain industries faced comprehensive B3 waste assessment requirements.

Regulatory Framework Overview: Key Legislation and Ministerial Regulations

Indonesia's B3 waste regulatory architecture comprises hierarchical legal instruments establishing progressively detailed requirements. At the apex, Law No. 32 of 2009 concerning Environmental Protection and Management provides overarching environmental governance framework including provisions for hazardous waste management as component of pollution control and environmental quality protection. This environmental law establishes fundamental principles including precautionary principle, polluter pays principle, sustainable development, and community participation.

Government Regulation No. 101 of 2014 translates the environmental law's general provisions into specific B3 waste requirements^[1]. The regulation defines B3 waste comprehensively encompassing wastes from industrial processes, commercial activities, healthcare facilities, laboratories, and other sources exhibiting hazardous characteristics. The classification system utilizes characteristic-based and list-based approaches, where wastes demonstrating hazardous characteristics or appearing on specified waste lists automatically qualify as B3 requiring special management.

Permen LHK No. 9/2024: Management of Waste Containing B3

Ministerial Regulation LHK No. 9 of 2024 addresses specific waste categories requiring specialized management including wastes with B3 characteristics generated from household and commercial sources^[3]. The regulation recognizes that certain waste streams from non-industrial sources contain hazardous components necessitating management approaches differing from conventional municipal solid waste systems.

Examples of covered waste categories include household products containing hazardous materials, contaminated packaging from consumer products, waste chemicals from laboratories and schools, electronic waste containing lead and mercury, expired pharmaceuticals, and medical wastes from small healthcare facilities. The regulation mandates source separation, proper labeling, manifest documentation when applicable, licensed collection and transportation, appropriate treatment and disposal at permitted facilities, and regular reporting to environmental authorities.

Implementation of this regulation requires coordination between central government, local governments, waste generators, treatment operators, and communities. Local governments bear responsibility for establishing collection systems for household B3-containing waste, facilitating access to licensed treatment facilities, and conducting public awareness campaigns about proper waste separation and disposal^[6].

Permen LHK No. 14/2024: Supervision and Sanctions Framework

Ministerial Regulation LHK No. 14 of 2024 concerning Environmental Supervision and Administrative Sanctions provides enhanced enforcement framework impacting all environmental compliance areas including B3 waste management^[5]. The regulation updates supervision procedures, clarifies violation assessment criteria, establishes standardized administrative penalty mechanisms, and strengthens enforcement coordination among environmental authorities at national and regional levels.

While not exclusively focused on B3 waste, this regulation significantly impacts B3 waste compliance by creating clearer enforcement protocols and more consistent sanction application across jurisdictions. The regulation establishes structured inspection procedures, documentation criteria for inspection findings, violation assessment mechanisms, and frameworks for applying administrative sanctions proportional to violation severity.

PROPER 2025: Enhanced Environmental Performance Assessment

The Environmental Performance Rating Program (PROPER) represents Indonesia's flagship environmental compliance and beyond-compliance recognition initiative, publicly rating companies' environmental performance to incentivize continuous improvement beyond minimum regulatory requirements^[2]. The 2025 assessment cycle introduces enhanced criteria strengthening B3 waste components and expanding coverage to all industrial sectors.

PROPER utilizes five-color rating system ranging from Gold (excellent, significantly exceeding requirements) through Green (beyond compliance with proactive environmental management), Blue (meeting all compliance requirements), Red (non-compliance with efforts to improve), to Black (serious violations with no improvement efforts or causing significant environmental damage).

The 2025 PROPER criteria enhance B3 waste assessment by expanding mandatory coverage to all industrial sectors, whereas previously only certain sectors required comprehensive B3 waste assessment. All facilities must now demonstrate complete waste characterization and proper classification, storage facilities meeting regulatory specifications, manifests for all waste shipments, utilization of licensed transporters and treatment facilities, regulatory reporting submissions complete and timely, and personnel training programs with documented qualifications.

Critical Aspects of B3 Waste Management Compliance

Effective B3 waste management compliance requires systematic attention to multiple interconnected requirements spanning the complete waste lifecycle from generation through final disposal^[6]. Industrial facilities must establish comprehensive management programs addressing each regulatory requirement through appropriate policies, procedures, infrastructure, training, documentation, and continuous improvement mechanisms.

Waste identification and characterization constitutes the foundation of compliant B3 waste management. Generators must systematically identify all waste streams produced by their operations, evaluate each stream against B3 waste criteria, and properly classify wastes requiring specialized management^[8]. Characteristic-based classification involves testing representative waste samples using standardized analytical methods determining ignitability, corrosivity, reactivity, and toxicity.

Storage requirements establish critical controls preventing environmental releases and exposure during waste accumulation periods. Regulations specify maximum storage durations (typically 90 days for generators), container specifications matching waste characteristics, labeling requirements identifying waste contents and hazards, and facility design standards including impervious floors, secondary containment, adequate ventilation, fire protection systems, security controls preventing unauthorized access, and weather protection.

Licensing and Technical Approval Requirements

Facilities conducting B3 waste management activities including storage (over 90 days), transportation, treatment, disposal, or utilization must obtain technical approvals from KLHK or provincial authorities per Permen LHK No. 6/2021^[4]. Applications require facility descriptions, environmental assessments, technical specifications, personnel qualifications, emergency plans, monitoring programs, and financial assurance.

The technical approval process involves administrative review for documentation completeness, technical evaluation by expert teams assessing facility design and operational procedures, and field inspection to verify that infrastructure matches submitted specifications. Authorities may request additional information, design modifications, or operational control enhancements before granting approval.

Technical approvals typically remain valid for five-year periods and must be renewed before expiration. Renewal requires demonstration of satisfactory operational performance, compliance with approval conditions, absence of significant violations, and maintenance of qualified infrastructure and personnel. Facilities must report substantial modifications to operations or equipment and may require modification approval before implementation.

Industry Implementation Strategies and Best Practices

Industrial facilities implementing comprehensive B3 waste management compliance programs should adopt systematic approaches addressing all regulatory requirements through integrated management systems. Effective programs begin with top management commitment establishing environmental compliance as organizational priority, allocating adequate resources for compliance activities, designating qualified personnel with clear responsibilities, and creating accountability through performance metrics and consequences.

Comprehensive compliance programs establish policies and procedures addressing each regulatory requirement, assign responsibilities to qualified personnel, provide necessary training and resources, implement operational controls preventing violations, monitor performance through inspections and audits, document activities demonstrating compliance, investigate and correct deficiencies, and continuously improve through lessons learned and changing requirements^[9].

Implementation Challenges and Solutions

Despite the existing regulatory framework, many industrial facilities face significant challenges in achieving full compliance with B3 waste management requirements. Common challenges include inadequate treatment facility capacity in some regions, causing delays in waste disposal and difficulties maintaining the 90-day storage limit. This capacity gap is particularly acute for certain waste types requiring specialized treatment technologies.

Shortage of qualified personnel represents another significant challenge. Many facilities struggle to recruit and retain qualified B3 waste managers with required technical competence in waste characterization, environmental regulations, and management systems^[10]. Investment in training programs and internal competency development becomes critical to address this skills gap.

Compliance costs can be substantial, particularly for small and medium enterprises with limited financial resources. Costs include storage infrastructure, characterization testing, transportation and disposal fees, personnel training programs, documentation systems, and potential sanctions for non-compliance. Waste minimization strategies reducing generation volumes can significantly reduce compliance costs while providing environmental benefits.

Future Outlook and Developments

Indonesia's B3 waste regulatory framework is expected to continue developing in response to emerging waste management challenges, technological advances, and international best practices. Emerging trends include digitalization of manifest and reporting systems, enabling real-time tracking and enhanced regulatory oversight. Integrated digital platforms can improve administrative efficiency, reduce documentation errors, and facilitate data analysis for evidence-based decision making.

Growing circular economy emphasis will likely influence future B3 waste management requirements, promoting waste utilization and resource recovery over disposal. Regulations may increasingly promote technologies converting B3 wastes into valuable materials or energy products, reducing dependence on limited landfill capacity while creating economic value from waste streams.

Strengthened performance standards for B3 waste management facilities will likely emerge, with more stringent requirements for emission controls, treatment efficiency, and environmental protection. Regulatory authorities may adopt risk-based approaches to oversight, focusing inspection resources on high-risk facilities and generators while implementing self-reporting mechanisms for compliant low-risk operations.

Conclusions and Recommendations

Indonesia's developing B3 waste regulatory framework requires proactive attention from industrial facilities to ensure compliance with strengthened requirements and performance criteria. New regulations issued during 2024-2025 reflect the government's continued commitment to strengthening environmental stewardship and addressing compliance gaps contributing to contamination incidents.

Facilities must adopt systematic approaches to B3 waste compliance, establishing comprehensive management programs integrated with broader environmental management systems. Investment in qualified personnel, adequate infrastructure, and compliance verification mechanisms will yield improved environmental performance, reduced regulatory risks, and enhanced corporate reputation. Waste minimization strategies reducing generation provide dual benefits of reducing compliance costs while achieving environmental sustainability objectives.

As regulations continue developing, facilities must maintain systems to track requirement changes, assess implications for their operations, and implement necessary modifications promptly. Engagement with industry associations, regulatory authorities, and environmental consultants can provide valuable insights into regulatory developments and implementation best practices. Proactive approaches to environmental compliance position organizations for long-term success while contributing to environmental protection and public health.

References and Regulatory Resources

1. Government of Indonesia. Government Regulation No. 101/2014 concerning Management of Hazardous and Toxic Waste.
https://www.transtrapermada.com/wp-content/uploads/2023/02/7.-PP-Nomor-101-Tahun-2014-tentang-Pengelolaan-Limbah-B3.pdf

2. Ministry of Environment and Forestry. PROPER 2025 Socialization - B3 Waste Management Criteria.
https://id.scribd.com/document/880432059/Sosialisasi-PROPER-2025-Kriteria-PLB3

3. Ministry of Environment and Forestry. Ministerial Regulation No. 9/2024 concerning Waste Containing B3 and B3 Waste Management.
https://peraturan.bpk.go.id/Download/351283/Permen%20LHK%20No%209%20Tahun%202024.pdf

4. Ministry of Environment and Forestry. Ministerial Regulation No. 6/2021 concerning Technical Approval Procedures for B3 Waste Management.
https://jdih.menlhk.go.id/new2/uploads/files/2021pmlhk006_menlhk_06082021104752.pdf

5. Ministry of Environment and Forestry. Ministerial Regulation No. 14/2024 concerning Environmental Supervision and Administrative Sanctions.
https://peraturan.bpk.go.id/Details/309107/permen-lhk-no-14-tahun-2024

6. BPK Banten Province. B3 Waste Management Mechanisms According to Regulations 2025.
https://banten.bpk.go.id/wp-content/uploads/2025/02/132-ND_2025_lamp_TH-Banten-Pengelolaan-Limbah-B3-sesuai-peraturan-perundangan_2025_20250221155646.pdf

7. Ministry of Environment and Forestry. Guidelines for B3 Waste Transportation Recommendation.
https://pelayananterpadu.menlhk.go.id/images/dokumen/nonperizinan/PEDOMAN-PENERBITAN-REKOMENDASI-PENGANGKUTAN-LIMBAH-BAHAN-BERBAHAYA-DAN-BERACUN-FINAL.pdf

8. Government of Indonesia. Decree on B3 Waste Management 2025 - Management Guidelines and Identification Methods.
https://id.scribd.com/document/899736094/2025-067-SK-PENGELOAAN-LIMBAH-B3

9. Ministry of Environment and Forestry. Legal Information and Documentation Network - Environment and Forestry Regulations.
https://jdih.kehutanan.go.id/new2/

10. Various Agencies. MOU on B3 Waste Management 2025 - Cooperation Framework.
https://www.scribd.com/document/887255300/MOU-B3-2025