How Long Can You Store Hazardous Waste? Indonesia's B3 Storage Timeline Framework

1.0 The Storage Obligation: Mandatory Temporary Management Before Final Disposal

Article 285(1) of PP 22/2021 establishes a fundamental obligation for all B3 waste generators: "Setiap Orang yang menghasilkan Limbah B3 wajib melakukan Penyimpanan Limbah B3" (Every person who generates B3 Waste must perform B3 Waste Storage). This mandatory storage requirement addresses the practical reality that waste generators cannot immediately transfer all generated hazardous waste to final treatment or disposal facilities. Industrial facilities producing hazardous waste must accumulate sufficient quantities before arranging collection by licensed waste management companies, or must temporarily store waste pending availability of treatment capacity. The regulation recognizes storage as a necessary intermediate step in waste management, but strictly controls storage duration to prevent indefinite accumulation that transforms industrial sites into de facto hazardous waste dumps. Article 285(2) imposes an absolute prohibition on mixing: generators cannot combine different types of B3 waste during storage, as mixing incompatible materials may create chemical reactions, complicate treatment processes, or render waste untreatable by conventional methods. Storage authorization differs based on environmental risk level (Article 285(3)): low-risk activities under SPPL requirements integrate storage standards into their NIB (Nomor Induk Berusaha), while higher-risk activities requiring AMDAL or UKL-UPL must include detailed storage specifications in their Environmental Approval (Persetujuan Lingkungan). Government agencies generating B3 waste face the same Environmental Approval requirement as private entities, eliminating any public sector exemption. Article 285(4) mandates that storage standards include five critical elements: waste identification (name, source, characteristics, quantity), facility documentation, packaging specifications, environmental compliance measures, and detailed obligations. The comprehensive nature of these requirements reflects Indonesia's shift from reactive pollution response to proactive risk management, requiring waste generators to plan and document their entire storage operation before generating the first kilogram of waste. These storage requirements apply exclusively to "Limbah B3" (B3 waste) - materials that have already become waste exhibiting hazardous characteristics - and not to "Bahan B3" (B3 materials), which are raw hazardous materials used in production processes before they become waste. This distinction is critical: the storage framework analyzed in this article governs waste management, not raw material inventory management (see Matrix 1.1 below).

Matrix 1.1: Five Environmental Instruments and B3 Waste Storage Authorization

2.0 The Time Limit Matrix: Four Storage Periods Based on Generation Rate and Category

Article 296(1)(b) establishes Indonesia's most intricate environmental compliance timeline: four distinct maximum storage periods ranging from 90 to 365 days, determined by two variables - daily generation rate and waste category. The 90-day rule applies universally to high-volume generators producing 50 kilograms or more of B3 waste per day, regardless of waste category: "90 (sembilan puluh) hari sejak Limbah B3 dihasilkan, untuk Limbah B3 yang dihasilkan sebesar 50 kg (lima puluh kilogram) per hari atau lebih" (90 days from generation for B3 Waste generated at 50 kg per day or more). This threshold targets large industrial facilities where high waste volumes create significant environmental and safety risks if stored indefinitely; a chemical manufacturer producing 100 kg daily of corrosive waste must remove or treat accumulated waste every 90 days, preventing storage areas from becoming overloaded hazardous material stockpiles. The 180-day period applies exclusively to low-volume generators (under 50 kg daily) of Category 1 waste, which represents the highest hazard level with characteristics such as explosive, flammable, reactive, infectious, corrosive, or acutely toxic properties. The regulation grants small generators of highly dangerous waste extra time because their lower volumes reduce immediate risk, but maintains heightened vigilance by limiting this extended period to 180 days rather than the full year allowed for less hazardous materials. The 365-day period applies to two distinct scenarios: Category 2 waste from non-specific or general specific sources generated at rates below 50 kg daily, and all Category 2 waste from special specific sources regardless of generation rate. Category 2 waste exhibits moderate toxicity rather than acute hazards, justifying the longer storage period. Special specific sources - highly specialized industrial processes producing unique waste streams - receive the 365-day allowance at any generation volume because their waste often requires specialized treatment facilities that may operate on annual collection cycles. A pharmaceutical research laboratory producing 10 kg monthly of Category 2 waste from specialized synthesis processes can store for a full year before arranging pickup by a licensed collector serving that niche waste stream. The time limit framework creates a cascading structure: the 50 kg daily threshold serves as the primary filter, with waste category and source type becoming relevant only for generators below that threshold. Industrial facilities must calculate their generation rate based on actual daily output, not monthly or annual averages, as a single high-production day triggering the 50 kg threshold subjects all waste from that period to the 90-day rule (see Matrix 2.1 below).

Matrix 2.1: Four Storage Time Limits Based on Generation Rate and Waste Category

3.0 Facility Requirements: Six Approved Storage Types with Category-Specific Restrictions

Article 288(1) authorizes six distinct facility types for B3 waste storage, ranging from conventional buildings to specialized containment structures: bangunan (buildings), tangki dan/atau kontainer (tanks and/or containers), silo (silos), tempat tumpukan limbah (waste piles), waste impoundment (engineered containment structures), and bentuk lainnya sesuai perkembangan ilmu pengetahuan dan teknologi (other forms consistent with scientific and technological development). The regulation's technology-neutral final category acknowledges that storage methods will evolve as engineering advances, preventing the framework from becoming obsolete when new containment systems emerge. However, not all facility types suit all waste categories: Article 288(2) restricts buildings, tanks/containers, silos, and other technology-neutral forms to Category 1 waste, Category 2 waste from non-specific sources, and Category 2 waste from general specific sources. These waste types require fully enclosed containment preventing atmospheric exposure, unauthorized access, and environmental release. A battery recycling facility generating Category 1 lead-acid waste must use sealed buildings or tanks, not open waste piles. Article 288(3) expands facility options for Category 2 waste from special specific sources to include waste piles and waste impoundments - surface accumulation and lined excavation systems - reflecting the lower hazard profile of moderate-toxicity waste from specialized processes. A palm oil mill generating Category 2 waste from biomass processing may use engineered waste piles with proper liner systems and leachate collection, a more economical option than constructing enclosed buildings for hundreds of tons of organic waste. The facility type authorization creates a hierarchical system: Category 1 waste and higher-risk Category 2 streams require maximum containment (enclosed structures), while lower-risk Category 2 streams from specialized sources may use surface or excavation-based systems engineered with appropriate controls. Buildings used for Category 1 and Category 2 non-specific/general source storage must meet three physical requirements (Article 289(1)): weather protection through design and construction shielding waste from rain and direct sunlight, lighting and ventilation systems maintaining safe working conditions, and drainage channels with containment basins capturing spills or leachate. These requirements ensure storage areas remain dry, illuminated for safe handling, and equipped to contain any accidental releases. Category 2 waste from special specific sources (Article 290) need only weather protection and drainage/containment, exempting lighting and ventilation - a concession recognizing that lower-hazard materials may be stored in partially enclosed or outdoor facilities where ventilation is inherent and artificial lighting unnecessary during daylight operations (see Matrix 3.1 below).

Matrix 3.1: Six Authorized Facility Types and Waste Category Applicability

*Note: Lighting and ventilation NOT required for Category 2 special specific sources (Article 290)

4.0 Location and Emergency Standards: Flood-Free Sites and Mandatory Fire Equipment

Article 287(1) imposes two absolute location criteria: storage sites must be "bebas banjir dan tidak rawan bencana alam" (flood-free and not prone to natural disasters). The flood-free requirement prevents scenarios where rising water inundates storage areas, breaching containers and dispersing hazardous materials into waterways contaminating downstream communities and ecosystems. The disaster-prone prohibition addresses earthquake zones, volcanic areas, landslide-prone slopes, and other geologically unstable locations where ground movement could rupture tanks or collapse buildings. However, Article 287(2) permits engineering exceptions: if no flood-free, disaster-resistant location exists within a generator's operational footprint, the site "harus dapat direkayasa dengan teknologi untuk Perlindungan dan Pengelolaan Lingkungan Hidup" (must be engineered with technology for Environmental Protection and Management). A coastal industrial zone in a flood-prone delta may elevate storage facilities above historical high-water levels on reinforced platforms, or construct flood walls with pumping systems preventing inundation. Generators pursuing engineered solutions bear the burden of demonstrating that protection systems meet the same environmental safety standards as naturally compliant sites. Article 287(3) requires that storage locations "harus berada di dalam penguasaan Setiap Orang yang menghasilkan Limbah B3" (must be under the control of Every Person who generates B3 Waste), prohibiting off-site storage at third-party facilities not licensed as waste collectors. This control requirement ensures generators maintain direct oversight and liability for their waste until it transfers to authorized handlers, preventing the practice of leasing remote storage yards to avoid compliance costs while externalizing environmental risks to landowners lacking waste management expertise. The emergency equipment mandate (Article 291) requires all storage facilities to maintain "alat pemadam api" (fire extinguishers) at minimum, plus "alat penanggulangan keadaan darurat lain yang sesuai" (other appropriate emergency response equipment) tailored to specific waste characteristics. Facilities storing flammable solvents need fire suppression systems exceeding standard extinguishers - deluge systems, foam generators, or inert gas flooding - while sites with corrosive acid waste require neutralization agents, emergency eyewash stations, and spill containment materials. The "appropriate emergency equipment" standard creates a performance-based rather than prescriptive requirement: regulators assess whether equipment matches actual hazards present, rejecting cookie-cutter approaches that provide inadequate protection for facility-specific risks (see Matrix 4.1 below).

Matrix 4.1: Location Criteria and Emergency Equipment Requirements

5.0 Packaging, Labeling, and Transfer Requirements: Container Integrity and Licensed Recipient Obligations

Article 292(1) establishes four packaging criteria ensuring containers protect both waste integrity and environmental safety. Containers must be "terbuat dari bahan yang dapat mengemas Limbah B3 sesuai dengan karakteristik Limbah B3 yang akan disimpan" (made from materials that can package B3 Waste in accordance with the characteristics of the B3 Waste to be stored) - acidic waste requires acid-resistant plastic or glass, while organic solvents demand steel or compatible polymers that won't degrade through chemical interaction. Containers must be "mampu mengungkung Limbah B3 untuk tetap berada dalam kemasan" (capable of containing B3 Waste to remain within the packaging), prohibiting porous materials or designs allowing leakage or volatilization. Closures must be "penutup yang kuat untuk mencegah terjadinya tumpahan saat dilakukan penyimpanan, pemindahan, atau pengangkutan" (strong closures to prevent spills during storage, transfer, or transportation), addressing the reality that containers face stress during normal handling and must maintain integrity across their lifecycle from filling through final disposal. Container condition requirements mandate packaging "dalam kondisi baik, tidak bocor, tidak berkarat, atau tidak rusak" (in good condition, not leaking, not rusted, or not damaged), prohibiting reuse of deteriorated drums or jerry cans showing visible degradation. Article 292(2) requires all packaging to display "Label Limbah B3 dan Simbol Limbah B3" (B3 Waste Labels and B3 Waste Symbols). Labels must identify four elements (Article 292(3)): waste name, generator identity, generation date, and packaging date - information enabling handlers to verify waste age for time limit compliance, trace origins if incidents occur, and confirm proper segregation. Symbols (Article 292(4) referencing Article 278(2)) use internationally recognized pictograms indicating whether waste is mudah meledak (explosive), mudah menyala (flammable), reaktif (reactive), infeksius (infectious), korosif (corrosive), or beracun (toxic). A drum containing infectious medical waste displays biohazard symbols alerting handlers to disease transmission risks requiring protective equipment and special handling protocols. Article 294(2) exempts Category 2 waste from special specific sources from packaging and labeling requirements, permitting bulk storage in lined pits or waste piles without individual container markings - a practical accommodation for large-volume, low-hazard streams where containerization would be economically prohibitive. When storage time limits expire (Article 297), generators face two obligations: self-manage through treatment/disposal at on-site facilities, or transfer to licensed third parties. Article 297(2) authorizes four recipient types - Pengumpul Limbah B3 (collectors), Pemanfaat Limbah B3 (utilizers converting waste to resources), Pengolah Limbah B3 (processors reducing toxicity or volume), and Penimbun Limbah B3 (disposers operating final landfills). Article 297(3) requires all recipients to hold "Perizinan Berusaha untuk kegiatan bidang usaha Pengelolaan Limbah B3" (Business Licensing for B3 Waste Management business activities), creating strict liability for generators who transfer waste to unlicensed operators: if a generator's waste ends up improperly dumped by an unlicensed collector, the generator faces sanctions for failing to verify recipient credentials. The licensing verification requirement transforms waste transfer from a commercial transaction into a compliance audit, where generators must maintain documentation proving every recipient's authorized status (see Matrix 5.1 below).

Matrix 5.1: Packaging Requirements and Licensed Recipient Categories

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Environmental Law Series

This is Article 43 in our comprehensive analysis of Indonesia's environmental regulatory framework.

Related Articles:
- [[ENV_051_B3_Waste_Management]] - Comprehensive B3 waste management framework
- [[ENV_042_Hazardous_Waste_Categories]] - B3 waste categorization system
- [[ENV_044_B3_Transportation]] - Transportation requirements for hazardous waste

Regulation Reference

Full Citation:
Peraturan Pemerintah Republik Indonesia Nomor 22 Tahun 2021 tentang Penyelenggaraan Perlindungan dan Pengelolaan Lingkungan Hidup

English Translation:
Government Regulation of the Republic of Indonesia Number 22 of 2021 on the Implementation of Environmental Protection and Management

Short Citation:
PP 22/2021

Chapter: BAB VII - Pengelolaan Limbah Bahan Berbahaya dan Beracun dan Pengelolaan Limbah Non Bahan Berbahaya dan Beracun
Section: Bagian Kedua, Paragraf 4 - Penyimpanan Limbah Bahan Berbahaya dan Beracun
Articles Analyzed: Pasal 285-297

Promulgation Date: February 2, 2021
Effective Date: February 2, 2021
Supersedes: PP 101/2014 (specific provisions on B3 waste management)

Official Source: https://peraturan.go.id/id/pp-no-22-tahun-2021

Legal Analysis by the CRPG Environmental Law Team | Analysis Date: December 17, 2025 | Regulation Effective: February 2, 2021

LEGAL DISCLAIMER: This article is provided for informational and educational purposes only and does not constitute legal advice, legal opinion, or professional consultation. The analysis presented herein is based on the authors' interpretation of PP 22/2021 and related regulations as of the publication date and may contain errors, omissions, or inaccuracies despite reasonable efforts to ensure accuracy. Laws and regulations are subject to amendment, judicial interpretation, and administrative clarification that may affect the applicability or interpretation of the provisions discussed. This article does not create an attorney-client relationship between the authors, the Center for Regulation, Policy and Government (CRPG), and any reader. Readers should not act or refrain from acting based solely on the information contained in this article without seeking appropriate legal counsel from qualified Indonesian legal practitioners licensed to practice environmental law. The application of B3 waste storage requirements depends on specific factual circumstances including waste generation rate, waste category determination, facility location characteristics, storage duration calculations, packaging material selection, emergency equipment adequacy, and third-party licensing verification, all of which require case-specific legal analysis. Neither the authors nor CRPG assume any liability for actions taken or not taken based on information in this article, nor for any direct, indirect, incidental, consequential, or punitive damages arising from use of or reliance on this material. For specific legal guidance on B3 waste storage compliance, consult with qualified legal counsel familiar with Indonesian environmental and administrative law and current regulatory practice.

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