Indonesian regulations introduce 0% contamination limit on recycled paper, plastics and metals

Plastic waste Indonesia

New Indonesian regulations on the import of recycled materials appear to introduce a 0% contamination limit.

Indonesia’s Ministry of Trade has published the new rules on the import of “non-hazardous waste materials and toxic industrial raw materials”.


The regulations, which came into force on 23 November 2019, state that material for recycling may still be imported, but under new conditions including that they must only be used as raw materials for industry.

Under the rules, waste can be imported if it does not originate from landfill activities, is not rubbish and is not mixed with rubbish and homogeneous.

Crucially, the Indonesian regulations state that the material must be “uncontaminated”, which effectively suggests a 0% contamination level.

The recycled product must also be sent by the registered exporter in the origin country, and they must also be holding the material. This implies that brokers and traders will not be allowed to export to Indonesia.

Shipments must also be made directly and not via another country.

Importers will require a special license known as a PI to import that will be issued by the Ministry of Trade. As part of this application, the importer will require letters from their exporting clients showing that the material:

  • does not originate from landfill activities
  • is not rubbish and is not mixed with rubbish
  • is uncontaminated
  • is homogenous.

The importer must also take responsibility for the material it imports.

Inspections by government-approved inspectors must take place before shipment, which seems to suggest 100% inspection of material.

Imports of waste materials will only be allowed through the following ports:

  • Tanjung Priock in Jacarta
  • Tanjung Emas in Semarang
  • Tanjung Perak in Surabaya
  • Soekarno Hatta in Makassar
  • Belawan in Medan
  • Batu Ampar in Batam
  • Teluk Lamong in Surabaya
  • Merak in Cilegon.

However, those that are able to meet these regulations will find that they have a wide range of materials that can be exported to Indonesia.

For paper, OCC, sorted bleached paper, news & pam and mixed paper will all be permitted for import into Indonesia (commodity codes 470710, 470720, 470730 and 470790 respectively).

For plastic, waste polymers of ethylene, styrene, vinyl chloride and other plastic will continue to be allowed into the country (commodity codes 391510, 391520, 391530, 391590 respectively).

There is also a long list of metals and textile fibres that are permitted.

It is understood that exports to Indonesia have ground to a halt because of the implementation of the regulations in such a short time.

The Indonesian agency that oversees imports KSO Sucofindo is believed to have ordered a temporary suspension of imports from 22 November and ordered oversees inspection agencies to stop inspecting material from the same date.

It isn’t clear when that suspension will be lifted, and if exporting companies will be able to meet the new Indonesian regulations when it is.

Indonesia has been all over the place recently, changing its criteria on the import of recycled material regularly. In August for example, it stopped import of mixed paper (as shown above, this will now be permitted) and introduced a 0.5% contamination limit.

The Recycling Association had also called on it to drop a 0% contamination limit that was introduced in the summer.

A visit to Indonesia was also undertaken by The Recycling Association and the US Institute of Scrap Recycling Industries to meet officials from across the Indonesian Government to come up with a joint plan that worked in the interests of Indonesia and the recycling industry.

It is believed that an agreement on contamination levels was made in those meetings. However, it appears that the Indonesian Government has now decided to ignore those representations.

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