What Waste Management Roadmap Exists Under PERMENLHK 75/2019?

Introduction: Indonesia's Producer Responsibility Framework for Waste Reduction

On December 5, 2019, Indonesia implemented a transformative regulatory framework that fundamentally shifts waste management responsibility from public authorities to private sector producers. Peraturan Menteri Lingkungan Hidup dan Kehutanan Nomor 75 Tahun 2019 tentang Peta Jalan Pengurangan Sampah oleh Produsen (Minister of Environment and Forestry Regulation No. 75 of 2019 on Waste Reduction Roadmap by Producers) establishes mandatory waste reduction requirements for manufacturers and food service businesses operating in Indonesia. This regulation implements Extended Producer Responsibility (EPR) principles, requiring producers to take responsibility for the entire lifecycle of their products and packaging, including post-consumer waste management.

The regulation's most significant innovation is the establishment of a ten-year national roadmap (2020-2029) mandating 30% waste reduction compared to baseline waste generation levels. This ambitious target applies across all covered business sectors, requiring systematic annual progress toward the 2029 deadline. The regulation addresses Indonesia's mounting waste crisis, particularly plastic pollution affecting marine environments, terrestrial ecosystems, and public health. By shifting responsibility to producers—the entities with greatest capacity to redesign products and packaging for reduced environmental impact—the regulation creates market incentives for sustainable production practices while establishing clear regulatory obligations backed by government monitoring and enforcement.

PERMENLHK 75/2019 represents Indonesia's implementation of Presidential Regulation No. 83 of 2018 on Marine Debris Management and fulfills mandates from Law No. 18 of 2008 on Waste Management and Government Regulation No. 81 of 2012 on Household and Similar Waste Management. Articles 12-15 of PP 81/2012 establish producer obligations for waste management, which PERMENLHK 75/2019 operationalizes through specific roadmap requirements, reduction targets, and compliance mechanisms. The regulation applies to two primary business sectors: manufacturing industries (including food and beverages, consumer goods, and personal care products), and food service operations (including cafes, restaurants, catering, and hotels).

The regulation mandates that producers develop, submit, and implement waste reduction roadmaps containing three core elements: baseline waste generation data, 3R (Reduce, Reuse, Recycle) implementation strategies, and annual reduction targets culminating in 30% reduction by 2029. Pasal 10 ayat (1) states: "Peta jalan harus memuat baseline, strategi 3R, dan target pencapaian" (The roadmap must contain baseline, 3R strategy, and achievement targets). Producers must quantify current waste generation, develop specific strategies using reduce-reuse-recycle principles, and set measurable annual targets demonstrating progressive movement toward the mandatory 30% reduction.

This comprehensive analysis examines PERMENLHK 75/2019's waste reduction roadmap requirements, focusing on covered producers, waste types targeted, roadmap content requirements, the ten-year timeline structure, monitoring mechanisms, and enforcement provisions. Understanding these requirements is essential for manufacturers and food service operators to achieve compliance with Indonesia's evolving waste management framework and contribute to national waste reduction objectives.

1.0 Covered Producers and Waste Types

The regulation defines "Produsen" (Producer) as entities or individuals conducting business and/or activities in manufacturing or food service sectors that produce goods, product packaging, and/or containers difficult to decompose naturally. This definition establishes two distinct producer categories based on business sector rather than corporate structure or size. Manufacturing producers include industries producing consumer goods—specifically food and beverage products, consumer products, and personal care products. Food service producers include hospitality and food service operations—specifically cafes, restaurants, catering services, and hotels. Both categories share common characteristics: they generate significant waste volumes through their business operations, and they have capacity to influence waste generation through product design, packaging selection, and operational practices.

The regulation focuses on specific waste types that pose particular environmental challenges due to persistence in the environment and limited decomposition. Pasal 4 specifies: "Pengurangan sampah meliputi produk, kemasan produk, dan/atau wadah yang sulit diurai oleh proses alam; tidak dapat didaur ulang; dan/atau tidak dapat diguna ulang, termasuk pascakonsumsi dari penggunaan produk, kemasan produk, dan/atau wadah tersebut" (Waste reduction includes products, product packaging, and/or containers that are difficult to decompose through natural processes; cannot be recycled; and/or cannot be reused, including post-consumption from use of products, product packaging, and/or containers). This provision targets three waste characteristics: difficult natural decomposition (plastics, composites), inability to be recycled (contaminated or multi-layer materials), and inability to be reused (single-use items).

The regulation explicitly covers post-consumer waste—waste generated after consumers finish using products, packaging, or containers. This post-consumer focus distinguishes PERMENLHK 75/2019 from regulations targeting only production waste or industrial byproducts. Producers become responsible for waste management beyond their factory gates, extending responsibility through distribution, retail, consumer use, and ultimate disposal. This extended responsibility creates incentives for producers to design products and packaging that minimize post-consumer waste generation, facilitate recycling or reuse, or enable safe environmental decomposition.

Matrix 1.1 below details the two producer categories, their business sector coverage, and waste reduction obligations. Understanding these categories is essential for determining which businesses fall under roadmap requirements and must develop waste reduction strategies.

Matrix 1.1: Covered Producer Categories Under PERMENLHK 75/2019

Matrix 1.2: Targeted Waste Types Under PERMENLHK 75/2019

2.0 The 30% Reduction Target and Ten-Year Timeline (2020-2029)

The regulation establishes a mandatory 30% waste reduction target that all covered producers must achieve by 2029, calculated against baseline waste generation levels established in 2020. This target represents significant ambition—reducing waste by nearly one-third over a decade requires systematic operational changes, product redesigns, and supply chain transformations. The target applies uniformly across all business sectors covered by the regulation, though producers within each sector may collectively determine sector-specific reduction strategies through industry associations.

The ten-year timeline runs from 2020 through 2029, divided into annual reporting and monitoring periods that enable government oversight of progressive implementation. The regulation requires producers to calculate baseline waste generation in 2020, then project annual waste generation for 2021-2029, accounting for business growth, market expansion, or operational changes. Baseline calculations must quantify waste from products, product packaging, and containers provided to consumers during 2020 operations. Producers must then calculate projected waste generation for each year 2021-2029, establishing the denominator against which reduction targets are measured.

The 30% reduction is calculated against projected 2029 waste generation, not against 2020 baseline levels. This approach accounts for business growth—expanding businesses may generate more absolute waste in 2029 than in 2020 while still achieving 30% reduction compared to what waste generation would have been without reduction measures. For example, if a producer's 2029 projection shows 1,000 tons of waste generation, the 30% reduction target requires actual 2029 waste generation to be 700 tons or less (30% of 1,000 = 300 tons reduction).

Producers may establish collective reduction targets through industry associations representing their business sectors. This collective approach recognizes that some producers may achieve greater reduction percentages through operational changes or product redesigns, while others face technical constraints limiting reduction capacity. Associations can aggregate member reductions, allowing individual variation while ensuring sector-wide achievement of the 30% target. However, collective targeting does not eliminate individual producer obligations—each producer must still document their waste generation and reduction contributions to demonstrate participation in collective achievement.

Matrix 2.1 below details the timeline structure, reduction target calculation methodology, and monitoring requirements that structure the ten-year roadmap period.

Matrix 2.1: Ten-Year Roadmap Timeline and Reduction Target Structure

Matrix 2.2: Reduction Target Calculation Example

3.0 Roadmap Content Requirements: Baseline, 3R Strategy, and Targets

Pasal 10 ayat (1) establishes three mandatory roadmap elements: "Peta jalan harus memuat baseline, strategi 3R, dan target pencapaian" (The roadmap must contain baseline, 3R strategy, and achievement targets). These three elements create a comprehensive planning document that quantifies current waste generation, specifies reduction approaches, and sets measurable objectives for tracking progress over the ten-year period.

The baseline component requires producers to collect and analyze data on waste generation from their business operations, specifically focusing on products, product packaging, and containers provided to consumers. Baseline data must be established for 2020, serving as the reference point for all subsequent calculations and projections. Producers must quantify waste types, volumes, and characteristics resulting from their products and packaging. This baseline must account for the full product lifecycle through post-consumer disposal, requiring producers to estimate or measure waste generation beyond their direct operational control. Baseline data provides the foundation for projecting future waste generation and calculating reduction targets.

The 3R strategy component (Reduce, Reuse, Recycle) requires producers to specify concrete measures for waste reduction implementation. The "Reduce" strategy focuses on minimizing waste generation at source through product redesign, packaging optimization, or operational changes. Examples include eliminating unnecessary packaging layers, reducing packaging material thickness, or designing concentrated products requiring less packaging. The "Reuse" strategy focuses on enabling multiple use cycles for products or packaging before disposal. Examples include refillable containers, returnable packaging systems, or product designs enabling repair and extended use. The "Recycle" strategy focuses on designing products and packaging for material recovery and reprocessing. Examples include using mono-material packaging enabling easier recycling, implementing take-back programs for post-consumer waste collection, or using recycled content in new products.

The target achievement component requires producers to set specific, measurable annual targets showing progressive movement toward the 30% reduction by 2029. Producers must establish targets for each year from 2020 through 2029, demonstrating systematic reduction rather than last-minute compliance efforts. Annual targets enable government monitoring of implementation progress and early identification of producers falling behind roadmap commitments. Targets must be quantitative (measurable in tons or percentages), time-bound (assigned to specific years), and realistic (achievable through stated 3R strategies).

Matrix 3.1 below details the three mandatory roadmap content elements, their purposes, data requirements, and implementation considerations.

Matrix 3.1: Three Mandatory Roadmap Content Elements

Matrix 3.2: 3R Strategy Examples by Waste Reduction Approach

4.0 Roadmap Development and Submission Process

The regulation requires producers to develop roadmaps either individually or collectively through industry associations. Individual roadmaps enable producers with unique operational characteristics or competitive advantages in waste reduction to develop customized approaches matching their specific circumstances. Collective roadmaps enable industry sectors to coordinate reduction strategies, share best practices, and aggregate achievements toward sector-wide targets. The regulation permits both approaches, recognizing diversity in producer capacity, business models, and technical capabilities.

Producers developing collective roadmaps through associations must ensure that association-submitted roadmaps include data and commitments from all member producers. Collective roadmaps cannot obscure individual producer responsibilities—each producer must contribute data to baseline calculations, participate in 3R strategy development, and commit to implementation measures contributing to collective targets. Associations serve as coordination mechanisms rather than liability shields; member producers remain individually responsible for implementing roadmap commitments and achieving proportional contributions to collective reduction targets.

The regulation requires roadmap submission to the Ministry of Environment and Forestry (KLHK) for national-level producers, or to provincial/regency environmental agencies for regional-level producers. Submission deadlines and procedures are specified through ministerial implementing regulations and technical guidelines. As of the regulation's enactment in December 2019, producers had limited time to develop 2020 baselines and submit initial roadmaps covering the full 2020-2029 period. By 2021, 23 major producers had submitted roadmaps to KLHK, representing significant manufacturing and food service sectors.

Government agencies review submitted roadmaps for completeness, adequacy, and technical feasibility. Reviews verify that baselines use sound data collection methodologies, 3R strategies appropriately address identified waste types, and targets demonstrate realistic progression toward 30% reduction. Agencies may request revisions to roadmaps lacking adequate detail, unrealistic targets, or insufficient 3R strategies. Upon approval, roadmaps become binding commitments that producers must implement according to specified timelines and targets.

Matrix 4.1 below details the roadmap development and submission process, including individual versus collective approaches, submission requirements, and government review procedures.

Matrix 4.1: Roadmap Development and Submission Process

5.0 Monitoring, Incentives, and Enforcement

The regulation establishes comprehensive monitoring mechanisms enabling government oversight of roadmap implementation and waste reduction achievement. Producers must submit annual reports documenting actual waste generation, 3R strategy implementation progress, and achievement against annual targets. These reports enable environmental agencies to track whether producers are meeting roadmap commitments or falling behind reduction trajectories. Monitoring includes both document review (verifying reported data) and field verification (inspecting actual operations to confirm reported waste reduction measures).

Pasal 22 ayat (3) addresses enforcement phasing: the regulation applies publication of poor performance through print and electronic media as a disincentive during the 2020-2029 period, while administrative sanctions are planned for implementation post-2029 in the regulation's second phase. This enforcement approach recognizes the roadmap's transition nature—the first decade focuses on establishing producer capacity, developing reduction infrastructure, and achieving initial targets, with stronger enforcement measures applied in subsequent periods once producers have demonstrated implementation capacity.

The regulation provides for incentives encouraging producer participation and rewarding superior performance. Incentives may include public recognition of achievement, preferential treatment in government procurement, or regulatory flexibility for producers exceeding reduction targets. The regulation also contemplates disincentives for poor performance, including the public performance disclosure mentioned above. By publishing performance data, the regulation creates market-based pressure for compliance as consumers, investors, and business partners can assess producer environmental commitments.

Government supervision officials (Pejabat Pengawas Lingkungan Hidup) retain authority to inspect producer operations, verify waste reduction claims, and investigate compliance with roadmap commitments. Officials may request documentation, conduct site visits, review waste management records, and interview personnel to assess actual implementation versus roadmap commitments. Producers failing to implement roadmap measures face graduated enforcement ranging from warnings to operational restrictions.

The regulation requires ministerial evaluation of the roadmap framework itself, with periodic assessments of target appropriateness, 3R strategy effectiveness, and regulatory mechanism performance. These evaluations may result in adjusted targets, revised strategies, or enhanced enforcement mechanisms based on accumulated implementation experience. The roadmap functions as an adaptive management instrument, enabling course corrections as Indonesia develops producer responsibility infrastructure and capacity.

Matrix 5.1 below details monitoring mechanisms, incentive structures, enforcement approaches, and evaluation requirements governing roadmap implementation.

Matrix 5.1: Monitoring, Incentives, and Enforcement Framework

Matrix 5.2: Enforcement Phasing Under PERMENLHK 75/2019

Conclusion

PERMENLHK 75/2019 establishes Indonesia's comprehensive producer responsibility framework for waste reduction, creating mandatory obligations for manufacturing industries and food service operations to develop and implement ten-year waste reduction roadmaps targeting 30% reduction by 2029. The regulation shifts waste management responsibility from public authorities to private sector producers—the entities with greatest capacity to reduce waste through product redesign, packaging optimization, and operational improvements. By requiring baseline data, 3R strategies, and measurable annual targets, the regulation creates structured pathways for systematic waste reduction while enabling government monitoring of implementation progress.

The regulation represents significant regulatory innovation, implementing Extended Producer Responsibility principles that hold producers accountable for post-consumer waste management rather than limiting responsibility to production-phase waste. Producers must quantify waste generation throughout product lifecycles, develop concrete reduction strategies using reduce-reuse-recycle approaches, and demonstrate progressive achievement toward the mandatory 30% target. The phased enforcement approach—emphasizing capacity building and performance transparency during 2020-2029, with administrative sanctions planned for post-2029—recognizes the transition nature of establishing producer responsibility infrastructure in Indonesia.

Manufacturers and food service operators must assess their waste generation patterns, develop compliant roadmaps containing baseline data and 3R strategies, and implement systematic waste reduction measures to achieve the 30% target by 2029. Understanding PERMENLHK 75/2019's requirements is essential for legal compliance, avoiding enforcement actions, and contributing to Indonesia's national objectives for waste reduction and environmental protection. The regulation positions Indonesia among nations implementing producer responsibility frameworks to address plastic pollution, marine debris, and the mounting waste crisis affecting environmental quality and public health.

Regulation Reference

Full Citation:
Peraturan Menteri Lingkungan Hidup dan Kehutanan Republik Indonesia Nomor P.75/MENLHK/SETJEN/KUM.1/10/2019 tentang Peta Jalan Pengurangan Sampah oleh Produsen

Enactment Date: December 5, 2019

Official Source: https://peraturan.bpk.go.id/Details/312182/permen-lhk-no-75-tahun-2019

Legal Basis:

• Undang-Undang Nomor 18 Tahun 2008 tentang Pengelolaan Sampah (Law No. 18 of 2008 on Waste Management)
• Peraturan Pemerintah Nomor 81 Tahun 2012 tentang Pengelolaan Sampah Rumah Tangga dan Sampah Sejenis Sampah Rumah Tangga (Government Regulation No. 81 of 2012)
• Peraturan Presiden Nomor 83 Tahun 2018 tentang Penanganan Sampah Laut (Presidential Regulation No. 83 of 2018 on Marine Debris Management)

Status: Active

Pages: 54 pages (Berita Negara Republik Indonesia Tahun 2019 Nomor 1545)

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