KBLI 38110 (Collection of Non-Hazardous Waste and Garbage) is the 5-digit Indonesian Standard Industrial Classification code for collection of non-hazardous waste and garbage. It sits within the Water Treatment, Wastewater Treatment, Waste Material Treatment and Recovery, and Remediation Activities category in the official KBLI 2020 taxonomy maintained by Badan Pusat Statistik (BPS).

Can foreign investors operate under KBLI 38110?

Not in practice. KBLI 38110 is not on Pres. Reg. 10/2021's closed list, but OSS RBA only defines licensing rules at the Micro and Small business scales for this activity — there is no Large-scale matrix. Foreign-owned PT PMA must register at the Large scale, so this code isn't structurally available to foreign investors. PT lokal (100% Indonesian-owned) at the Micro / Small scale can operate freely.

What is the risk level of KBLI 38110?

KBLI 38110 has no Large-scale licensing matrix in OSS — it's structured for Micro and Small business scales only. PT PMA cannot register under this code as a result.

What licenses does KBLI 38110 require?

Not applicable to PT PMA — KBLI 38110 is not viable for foreign-owned entities (closed, SME-reserved, domestic-only, or no Large-scale licensing matrix in OSS RBA, depending on the case). Foreign investors should pick a related KBLI that is open at the Large scale.

What is the minimum capital for a PT PMA under KBLI 38110?

Not applicable to PT PMA — KBLI 38110 is not viable for foreign-owned entities, so neither BKPM Reg. 5/2025's paid-up minimum nor any sector-specific capital floor enters the picture. The structural barrier comes first.

How long does it take to register a business under KBLI 38110?

Not applicable to PT PMA — KBLI 38110 is not viable for foreign-owned entities, so the 4-8 week PT PMA setup timeline doesn't apply. Move to a sibling code with a Large-scale matrix or a different structure.

Is KBLI 38110 eligible for Indonesian tax incentives?

Not on the Tax Holiday or Tax Allowance priority lists. KBLI 38110 businesses pay the standard 22% PPh Badan; Super Tax Deduction (300% R&D / 200% vocational training) may still apply for qualifying expenses.

Which authority issues the KBLI 38110 license?

Not applicable to PT PMA — KBLI 38110 is not viable for foreign-owned entities, so OSS doesn't designate a PMA issuing authority. Smaller-scale registrations (Micro / Small) for Indonesian operators are typically issued at the Regency / City level.

What other permits beyond the NIB does KBLI 38110 need?

Beyond the NIB, no specific auxiliary permits (PB UMKU) are recorded for KBLI 38110. Sector-specific obligations may still apply — verify with the relevant ministry.

What KBLI codes are similar to 38110?

KBLI 38110 is the only entry in its subgroup 3811. Browse the parent group 381 for related activities.

KBLI 2020 · 5-digit class

38110Collection of non-hazardous waste and garbage

Collection of Non-Hazardous Waste and Garbage

Last updated April 24, 2026 · Sourced from OSS Indonesia

This group includes the collection of non-hazardous solid waste in an area, such as the collection of household waste and businesses using trash bins, wheeled bins, waste containers, and others that include a mix of recoverable materials, collection of recyclable materials, collection of used cooking oil and fats, and collection of waste from public trash bins. It also includes the collection of construction and demolition waste, collection and cleaning of debris or rubble, collection of waste from textile factories, and operation of transfer stations for non-hazardous waste.

KBLI 38110 at a glance

Citation-ready summary

KBLI code: 38110
Taxonomy version: KBLI 2020
Activity (English): Collection of non-hazardous waste and garbage
Activity (Indonesian): Collection of Non-Hazardous Waste and Garbage
Category: Water Treatment, Wastewater Treatment, Waste Material Treatment and Recovery, and Remediation Activities
Risk level (Large scale, PMA): None recorded

§ 01

Foreign investment rules

Indonesia's BUPM (Investment Business Fields) regulation places this code into one of five tracks. The track determines whether a foreign investor (PMA) can operate in this activity at all, and under what conditions.

Status · No foreign ownership

Reserved for small Indonesian operators

KBLI 38110 is set up for warungs, smallholders, individual practitioners and similar small businesses — Indonesia's licensing rules only define micro and small business sizes for it. Foreign-owned companies have to register at the Large business size, so even though this code isn't on the official "closed" list, foreign ownership isn't possible in practice. Pick a related KBLI that covers larger operations, or set up a partnership with an Indonesian operator who already holds the licence.

This activity is reserved for small Indonesian operators — think warungs, food stalls, smallholders, individual practitioners. KBLI 38110 only has licensing rules defined for micro and small business sizes. Foreign-owned companies have to register at the Large business size, so this code isn't available to them even though it's not on the "closed" list. Pick a related KBLI that covers larger operations, or ask us about partnering with an Indonesian operator who already holds the licence.

§ 02

Water, Waste & Remediation-specific guidance

Sector context that applies to KBLI 38110 beyond the generic OSS process. Verify with the relevant ministry before committing capital.

Lead regulator

Ministry of Environment & Forestry (KLHK)

·Hazardous-waste handling (B3) requires a separate KLHK permit.
·AMDAL typically required for treatment facilities.

§ 03

Regulations governing KBLI 38110

Current status, what each regulation actually requires for this activity, and how it ties to the PB UMKU sector permits below. Click through for the plain-English summary.

Indonesia, Kementerian Kesehatan

§ 04

Activities included under KBLI 38110

Sub-activities recorded under this KBLI in the OSS regulatory database. The classification covers any business operating in one or more of these areas.

Sub-activities under KBLI 38110

From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.

01
Collection of Non-Hazardous Waste (Excluding Non-Hazardous Waste as Defined in Appendix XIV of Government Regulation Number 22 of 2021 on the Implementation of Environmental Protection and Management) by Waste Banks (BSI), Entrepreneurs, and Sociopreneurs, Both Conventional and Digital Platforms.
02

§ 02

What this means for foreign investors

An honest read of the situation, plus the structures that work in practice. We've handled all of these — book a call to walk through your specific plan.

Pathways that work

Move to a different value-chain step
The cleanest path: operate a related but open KBLI. For example, foreign investors blocked from primary commodity production frequently succeed with the processing, distribution, branding, or export-trade codes upstream or downstream of the restricted activity.
Special Economic Zone (KEK) or Free Trade Zone (Batam)
Several restricted codes have higher or full PMA caps inside designated KEK zones (Sanur Health, Lido, Mandalika) or the Batam Free Trade Zone — manufacturing, logistics, and IT services especially. The IUK regime under BP Batam relaxes ownership rules selectively in exchange for export orientation. We assess whether your operation can benefit. See the for the requirements.
Indonesian-owned operating company + commercial agreement
A 100% Indonesian-owned operating entity can hold the restricted licence while you contract with it commercially. We structure these arrangements deliberately — without nominee shareholding, which is unenforceable and increasingly scrutinised.

PMA-viable codes in adjacent industries

These KBLIs solve a related business problem and are open to foreign ownership. None are a perfect substitute for the activity above — but they often unlock 80% of the commercial outcome. Talk to us about which fits your plan.

Restricted KBLIs need a tailored structure. Book a call and we'll map the right entity, partner, and licensing path for your specific business.

Talk to a corporate-services specialist

§ 08

Reference data: how this KBLI is regulated

The data below is the official OSS regulatory profile for this code. It applies to qualifying Indonesian operators (or to your operating partner). Foreign investors won't file these directly, but it's useful context when structuring a partnership or commercial arrangement.

Foreign investors:the licensing matrix below is for context only — direct PMA registration isn't possible for this code. See pathways above for what actually works.

Sub-activity scopes · 2

Sub-activity scope

Collection of Non-Hazardous Waste (Excluding Non-Hazardous Waste as Defined in Appendix XIV of Government Regulation Number 22 of 2021 on the Implementation of Environmental Protection and Management) by Waste Banks (BSI), Entrepreneurs, and Sociopreneurs, Both Conventional and Digital Platforms.

What's required to operate

NIB

Preparation only — additional permit needed below

Standard Certificate (Self-declared)

Important: NIB is issued for the preparation stage. To begin commercial operations, the operator must self-declare compliance with applicable standards via OSS, which generates the Sertifikat Standar. Operating commercially with NIB alone is not legally compliant at this risk level.

Application requirements

Documents and capabilities you must demonstrate at registration

No specific application requirements at this scale.

Ongoing obligations

Compliance and reporting duties throughout operation

01Business actors in the form of legal entities
02Have facilities to categorize waste based on waste type.
03Equipped with labels or signs on facilities.
04Area of location and waste management capacity according to needs.
05Easily accessible location
06Not polluting the environment
07Having waste processing facilities
08Having waste collection transportation equipment
09Have an institutional structure according to needs.
10Scope of services at the Provincial, City/District Level
11Have standard operating procedures for waste bank management.
12Meet the minimum facilities for simple leachate treatment, in accordance with the provisions of laws and regulations (during business activities) [if there are waste washing activities].
13Submit Waste Management Reports to the Local Government, including the recording of data on the types, quantities, and sources of waste that are collected, sorted, and transported (twice a year), every January and July.

Issuing authority

The authority that issues the license depends on your situation.

Authority	Applies when
Regent/Mayor	Waste collection with service area within 1 Regency/City
Minister/Head of Agency	Foreign Investment
Governor	Waste collection with service areas across districts/cities within 1 province.

Speak to Emerhub

KBLI 38110 needs a tailored structure. Let's design it.

Restricted KBLIs need a structure designed around the restriction — partnership, alternative code, KEK, or commercial arrangement. We've handled all of these. One conversation tells you what works for your plan.

Discuss your structure

Authority

Applies when

Regent/Mayor

Waste collection with service area within 1 Regency/City

Minister/Head of Agency

Foreign Investment

Governor

Waste collection with service areas across districts/cities within 1 province.

Risk level by business scale

Indonesia's OSS Risk-Based Approach assigns a separate risk level for each of the four business scales. The licensing instruments required (NIB, Standard Certificate, Operating License) are determined by the risk level. Foreign-owned entities (PT PMA) must register at the Large scale, so the rightmost column applies to most foreign investors.

KBLI 38110 at a glance

Foreign investment rules

Reserved for small Indonesian operators

Water, Waste & Remediation-specific guidance

Regulations governing KBLI 38110

Activities included under KBLI 38110

Sub-activities under KBLI 38110

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

Reference data: how this KBLI is regulated

Application requirements

Ongoing obligations

Issuing authority

KBLI 38110 needs a tailored structure. Let's design it.

Foreign investment rules

Reserved for small Indonesian operators

Water, Waste & Remediation-specific guidance

Regulations governing KBLI 38110

Activities included under KBLI 38110

Sub-activities under KBLI 38110

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

Reference data: how this KBLI is regulated

Application requirements

Ongoing obligations

Issuing authority

KBLI 38110 needs a tailored structure. Let's design it.

No. 23 of 2023

What is KBLI 38110?

Who needs KBLI 38110?

Why does the code matter?

Under the upcoming KBLI 2025

Carried forward into KBLI 2025

Risk level by business scale

Micro

Small

Medium

Large

Common questions about KBLI 38110

What is KBLI 38110?

Can foreign investors operate under KBLI 38110?

What is the risk level of KBLI 38110?

What licenses does KBLI 38110 require?

What is the minimum capital for a PT PMA under KBLI 38110?

How long does it take to register a business under KBLI 38110?

Is KBLI 38110 eligible for Indonesian tax incentives?

Which authority issues the KBLI 38110 license?

What other permits beyond the NIB does KBLI 38110 need?

What KBLI codes are similar to 38110?