Chinese enterprises operating in Indonesia often face complex compliance challenges in handling industrial by-products. One recurring issue is the management of Fly Ash and Bottom Ash (“FABA”), residues from coal combustion in Steam Power Plants (PLTU). Mismanagement may lead to regulatory breaches, environmental concerns, and reputational risks for businesses.

Legal Basis for FABA Management

Government Regulation No. 22 of 2021 concerning the Implementation of Environmental Protection and Management (“GR 22/2021”) classifies FABA as Non-Hazardous and Non-Toxic Waste (Non-B3 Waste). While this means FABA is no longer regulated as hazardous waste, its management remains mandatory. Key obligations include:

• Integration into Environmental Approvals (AMDAL, UKL-UPL, or SPPL), covering how FABA is managed.
• Prohibitions on illegal dumping, open burning, or mixing with hazardous waste.
• Storage Requirements in designated facilities such as silos or waste piles, designed to prevent leakage and contamination.
• Utilization Options for reuse in construction, energy, and industry.
• Disposal Rules that allow FABA disposal only in approved facilities under strict technical safeguards.

Business Opportunities

Rather than being treated solely as waste, FABA can be turned into economic opportunities:

• Construction Industry: Used as raw materials for concrete, bricks, paving blocks, lightweight concrete, and cement.
• Energy Sector: Alternative fuel source, provided emissions and wastewater standards are met.
• Industrial Applications: Utilized in paper production, base oil, metal smelting, or as soil amendments.
• By-Products: Integrated into industrial processes that meet product standards and consistent quality requirements.

By aligning with GR 22/2021, enterprises not only ensure compliance but also leverage FABA as a sustainable input, contributing to cost savings and environmental responsibility.

If you, a prospective client, have further inquiries about the topic discussed above, Schinder Law Firm is one of many corporate law firms in Indonesia that has handled numerous similar matters, with many experienced and professional corporate and civil lawyers in its arsenal, making it one of the top consulting firms in Indonesia. Feel free to contact us at info@schinderlawfirm.com for further consultation.

Author:
Budhi Satya Makmur