| Field | Solid waste management |
|---|---|
| Jurisdiction | Indonesia |
| Principal instruments | UU 18/2008, PP 81/2012, Permen LHK 75/2019 |
Extended producer responsibility in Indonesia is the set of legal duties that make the businesses which make, import or sell packaged goods responsible for the waste their products and packaging become after use. Indonesian law does not use the English term; the duties appear as the producer's obligation to manage packaging and goods that do not decompose naturally, and as "reduction of waste by producers" (pengurangan sampah oleh produsen). The obligation was created by UU 18/2008, the waste management law, and is part of solid waste management law in Indonesia.[1]
A producer (produsen) is defined as a business that produces goods using packaging, distributes imported goods using packaging, or sells goods in containers that cannot or can only with difficulty be decomposed by natural processes. Producers must limit waste generation, recycle and reuse, and the shift to decomposable, recyclable and reusable materials is to be phased over ten-year periods through a ministerial roadmap.[2][3] The first roadmap, Permen LHK 75/2019, covers 2020 to 2029 and sets a target of a 30 per cent reduction in waste by producers.[4]
Parallel duties apply to products containing hazardous substances under a 2020 regulation on specific waste.[5] In October 2025 the environment minister issued a circular letter, as reported by CRPG's regulatory tracker, directing that producers' reduction obligations be written into their environmental approval documents, linking the regime to environmental approval in Indonesia.[6]
UU 18/2008 contains two producer duties. Pasal 14 requires every producer to place on its packaging or products a label or mark relating to waste reduction and handling, and Pasal 15 requires producers to manage the packaging and goods they produce that cannot, or can only with difficulty, be decomposed by natural processes. The elucidation of Pasal 15 explains that managing packaging means taking it back (penarikan kembali) for recycling or reuse. The law also directs business actors to use production materials that generate as little waste as possible, and provides for government incentives for those who reduce waste and disincentives for those who do not; its elucidation gives producers using hard-to-decompose materials as the example of a disincentive.[1:1]
PP 81/2012, the government regulation on household waste, turned these duties into three obligations. Under Pasal 12 producers must limit waste generation by preparing a limitation plan or programme as part of their business, or by using packaging that decomposes easily and generates as little waste as possible. Under Pasal 13 they must recycle, by preparing a recycling programme, using recyclable raw materials, or taking back waste from their products and packaging; they may appoint another party, which must hold a business licence, and recycling into food packaging must follow food and drug supervision rules. Pasal 14 sets the same pattern for reuse.[3:1] Pasal 15 requires the use of decomposable, low-waste, recyclable and reusable materials to be phased every ten years through a roadmap set by the environment minister in coordination with the industry minister and after public consultation with producers.[3:2] The national waste policy under Perpres 97/2017 lists the strengthening of business commitment "through producer obligations" among its reduction strategies.[7]
The roadmap regulation, Permen LHK 75/2019, was signed on 18 October 2019 and promulgated on 5 December 2019 to implement Pasal 15 ayat (2) of PP 81/2012.[8] It applies to producers in three fields: manufacturing (the food and beverage, consumer goods, and cosmetics and personal care industries), food and beverage services (eating houses, cafés, restaurants, caterers and hotels), and retail (shopping centres, modern stores and traditional markets). Reduction applies to products, packaging and containers that are hard to decompose, cannot be recycled or cannot be reused, made of plastic, aluminium cans, glass or paper.[9] Pasal 2 sets the aim as a 30 per cent reduction of waste by producers compared with the volume of waste in 2029. The annex applies the target to each business field, measured against the baseline (baseline timbulan sampah) of the goods, packaging and containers producers make or use in 2029; the regulation defines a baseline as a figure built from the level, status, trend and projection of waste generation.[4:1][10]
Reduction is carried out by limitation, recycling and reuse. Recycling and reuse must be accompanied by taking waste back from products and packaging, which in turn requires collection facilities protected from rain and heat, with closed and labelled containers differentiated by material, shape or colour. Producers may provide these facilities through waste banks registered with the government, reduce-reuse-recycle processing sites (TPS 3R) or recycling centres, and residues must be processed or disposed of safely.[11] Each producer plans (naming a person responsible, setting its baseline, targets, methods, trials and a communication plan), implements, monitors at least once every six months, evaluates and reports. Products selected for reduction must carry a label stating that they can be composted, recycled or reused, and producers must adapt their plans to any regional ban on particular products or packaging. Planning in commercial areas is coordinated by the area manager and, for franchisees subject only to an environmental commitment statement (SPPL), may be coordinated by the parent company. Reports form part of the environmental permit or SPPL reporting and are verified by the minister, governors and regents or mayors.[12]
The annex lists methods by sector and material, and prohibits the use of plastic straws, foam food containers, single-use plastic bags and plastic foam with effect from 1 January 2030; where a regional government has already banned such items earlier, producers must follow the earlier date.[10:1]
For products containing hazardous and toxic substances (B3), PP 27/2020 on specific waste defines producers to include those who import, distribute or sell goods in packaging containing B3. Producers must limit such waste, including by making, importing or selling goods and packaging free of B3, and must take back waste containing B3 through collection facilities that are protected from rain and heat, have impermeable floors, and are registered with the regent or mayor. Limitation and take-back are also phased every ten years through a roadmap.[5:1] The wider regime is described at hazardous waste regulation in Indonesia.
Permen LHK 75/2019 already made producers' reduction reports part of their environmental permit or SPPL reporting.[12:1] According to CRPG's regulatory tracker, the Minister of Environment/Head of the Environmental Control Agency issued Circular Letter 11 of 2025 (Surat Edaran 11/2025) on 14 October 2025 on integrating producers' waste reduction obligations into environmental approvals (Persetujuan Lingkungan). The tracker reported that the circular applies to producers as defined in Permen LHK 75/2019 and cites UU 18/2008, UU 32/2009 as amended, PP 81/2012, PP 22/2021 and Permen LHK 75/2019 as its legal basis.[6:1]
As described in the tracker's series, the circular sets out steps in which producers inventory the products and packaging they place on the market, describe post-consumer waste as an impact in their UKL-UPL or RKL-RPL environmental management documents, set reduction targets and indicators (take-back percentage, reduction rate and leakage intensity), monitor at least monthly, and report together with their environmental approval reports, including whether they have registered a roadmap on the ministry's producer performance application (Aplikasi Kinerja Produsen).[13] The tracker reported that the minister, governors and regents or mayors may verify the reports against the application's data and field evidence, and that discrepancies or failure to submit a roadmap are to be dealt with under the applicable regulations.[14] The text of the circular was not held in the CRPG regulation vault, and these points rest on the tracker's account.
CRPG's regulatory tracker published three analyses of the roadmap regime on 17 December 2025, covering its legal basis and the 30 per cent target, the targets and methods by sector, and the position of retailers and importers, followed by a three-part series on the circular letter at the end of December 2025.[15][16][17][6:2][13:1][14:1]
K24[P] Undang-Undang Nomor 18 Tahun 2008 tentang Pengelolaan Sampah, Pasal 14, Pasal 15
(with its elucidation), Pasal 16, Pasal 20 ayat (3) and Pasal 21 (with its elucidation).
regulation_id UU_18_2008. https://peraturan.bpk.go.id/Details/39067/uu-no-18-tahun-2008 ↩︎ ↩︎
[P] Peraturan Pemerintah Nomor 81 Tahun 2012 tentang Pengelolaan Sampah Rumah Tangga dan
Sampah Sejenis Sampah Rumah Tangga, Pasal 1 angka 5 (Produsen). regulation_id PP_81_2012.
https://peraturan.bpk.go.id/Details/5295/pp-no-81-tahun-2012 ↩︎
[P] PP 81/2012, Pasal 12, Pasal 13 ayat (1) to (4), Pasal 14 and Pasal 15 ayat (1) to
(4). regulation_id PP_81_2012. ↩︎ ↩︎ ↩︎
[P] Permen LHK 75/2019, Pasal 2 ayat (1) and (2), and Pasal 1 angka 10 (Baseline Timbulan
Sampah). regulation_id PERMENLHK_75_2019_Peta_Jalan_Sampah. ↩︎ ↩︎
[P] Peraturan Pemerintah Nomor 27 Tahun 2020 tentang Pengelolaan Sampah Spesifik, Pasal
1 (Produsen), Pasal 10, Pasal 11, Pasal 12 and Pasal 13. regulation_id PP_27_2020.
https://peraturan.bpk.go.id/Details/138876/pp-no-27-tahun-2020 ↩︎ ↩︎
[E] "Embedding Producer Waste Reduction into Environmental Approvals: SE 11/2025", CRPG regulatory tracker, crpg.id, 29 December 2025. https://crpg.id/se-11-2025-epr-environmental-approvals/ (free sign-in required on crpg.id) The post carries a notice that it is AI-generated; it is cited for the record of the development, not for its legal content. ↩︎ ↩︎ ↩︎
[P] Peraturan Presiden Nomor 97 Tahun 2017 tentang Kebijakan dan Strategi Nasional
Pengelolaan Sampah Rumah Tangga dan Sampah Sejenis Sampah Rumah Tangga, Pasal 4 ayat (1) huruf
h. regulation_id PERPRES_97_2017. ↩︎
[P] Peraturan Menteri Lingkungan Hidup dan Kehutanan Nomor P.75/MENLHK/SETJEN/KUM.1/10/2019
tentang Peta Jalan Pengurangan Sampah oleh Produsen, Menimbang and closing formula (signed 18
October 2019; promulgated 5 December 2019), Berita Negara 2019 No. 1545. regulation_id
PERMENLHK_75_2019_Peta_Jalan_Sampah.
https://peraturan.bpk.go.id/Details/312182/permen-lhk-no-75-tahun-2019 ↩︎
[P] Permen LHK 75/2019, Pasal 3 and Pasal 4. regulation_id
PERMENLHK_75_2019_Peta_Jalan_Sampah. ↩︎
[P] Permen LHK 75/2019, Lampiran I, section B (tables by sector) and Keterangan huruf a
to c. regulation_id PERMENLHK_75_2019_Peta_Jalan_Sampah. ↩︎ ↩︎
[P] Permen LHK 75/2019, Pasal 6 to Pasal 8. regulation_id
PERMENLHK_75_2019_Peta_Jalan_Sampah. ↩︎
[P] Permen LHK 75/2019, Pasal 9 to Pasal 17, in particular Pasal 10 ayat (1), (3) and
(4), Pasal 11, Pasal 13 ayat (3) and Pasal 16 ayat (4). regulation_id
PERMENLHK_75_2019_Peta_Jalan_Sampah. ↩︎ ↩︎
[E] "The Six-Step Producer EPR Implementation Framework Under SE 11/2025", CRPG regulatory tracker, crpg.id, 30 December 2025. https://crpg.id/six-steps-epr-compliance-se-11-2025/ (free sign-in required on crpg.id) The post carries a notice that it is AI-generated; it is cited for the record of the development, not for its legal content. ↩︎ ↩︎
[E] "How Is EPR Compliance Verified Under SE 11/2025?", CRPG regulatory tracker, crpg.id, 30 December 2025. https://crpg.id/epr-compliance-verified-se-11-2025/ (free sign-in required on crpg.id) The post carries a notice that it is AI-generated; it is cited for the record of the development, not for its legal content. ↩︎ ↩︎
[E] "Indonesia's Extended Producer Responsibility (EPR): Legal Foundation and 30% Target by 2029", CRPG regulatory tracker, crpg.id, 17 December 2025. https://crpg.id/what-is-indonesias-extended-producer-responsibility-framework/ (free sign-in required on crpg.id) The post carries a notice that it is AI-generated; it is cited for the record of the development, not for its legal content. ↩︎
[E] "30% by 2029: Indonesia's Producer Packaging Waste Reduction Targets", CRPG regulatory tracker, crpg.id, 17 December 2025. https://crpg.id/30-by-2029-indonesias-producer-packaging-waste-reduction-targets/ (free sign-in required on crpg.id) The post carries a notice that it is AI-generated; it is cited for the record of the development, not for its legal content. ↩︎
[E] "Retail and Import Waste Responsibility Under Indonesian EPR Law", CRPG regulatory tracker, crpg.id, 17 December 2025. https://crpg.id/retail-and-import-waste-responsibility-under-indonesian-epr-law/ (free sign-in required on crpg.id) The post carries a notice that it is AI-generated; it is cited for the record of the development, not for its legal content. ↩︎