Foreign Investor FeasibilityKBLI 38220
§ 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 · open
Open under BUPM (subject to sector rules)
KBLI 38220 is not on Indonesia's closed, conditional, SME-reserved, or partnership-required schedules under BUPM (Pres. Reg. 10/2021). A foreign investor can incorporate a PT PMA under this code, but sector regulators (PSE/Kominfo, BPOM, OJK, Kemenkes, Permendag, ESDM) almost always add licensing and capital requirements on top — the practical answer depends on your specific business model.
This KBLI is open under BUPM (Pres. Reg. 10/2021) — it's not on any restricted, closed, SME-reserved, or partnership-required schedule. That's the BUPM verdict only, not a complete sector-readiness check: sector regulators almost always add requirements on top (PSE/Kominfo for digital platforms, BPOM for food and cosmetics, OJK for financial, Kemenkes for healthcare, Permendag for retail, ESDM for energy). BKPM's default capital floor is IDR 2.5 billion paid-up with IDR 10 billion+ total investment commitment per KBLI, but sector regulators frequently set higher minimums for specific activities. The practical answer depends on your business model — confirm with our team before committing capital.
§ 02
Activities included under KBLI 38220
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 38220
From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.
- 01Storage of Hazardous and Toxic Waste
- 02Processing of Hazardous Waste
- 03
§ 03
How we handle your KBLI 38220 setup
Emerhub is a corporate-services provider in Indonesia. We do the legal and regulatory legwork for foreign investors so you can focus on the business itself. Here's what the engagement looks like.
- 1
Confirm the optimal structure for your business
2–3 business daysWe confirm KBLI 38220 is the right primary code for your business, advise on secondary codes you may also need, and finalize the holding structure with you before any filing.
What we need from you- Founders' passport copies and proof of residence
- Intended share split and board composition
- 2
Incorporate your PT PMA
7–10 business daysWe draft the Articles of Association before a notary, register the entity with the Ministry of Law & Human Rights (Kemenkumham), and obtain the company's tax ID (NPWP). Under BKPM Reg. 5/2025, paid-up capital is IDR 2.5 billion (~USD 160K) — the cash actually deposited at incorporation. The IDR 10 billion+ figure many sources still cite is the total investment commitment per KBLI, realised over time via your LKPM reports.
Get an exact quote and timeline for KBLI 38220, scoped to your specific business plan.
Request a quote§ 06
Licensing requirements in detail
Specific permits, application requirements and ongoing obligations vary by business scale and the sub-activity within this KBLI. We file these on your behalf — this section is for transparency on what we'll be handling. Switch between scales below; by default we show Large (the PMA scale).
Sub-activity scopes · 4
Sub-activity scope
Storage of Hazardous and Toxic Waste
What's required to operate
NIB
Preparation only — additional permit needed below
Operating License (Izin)
Important: NIB is issued for the preparation stage. Commercial operation requires a full Operating License (Izin) issued by the competent ministry after a substantive review of the operator's capability, facility, and compliance. Operating with NIB alone exposes the entity to penalties, blacklisting, and contract invalidation.
Processing time
10Days
Statutory turnaround
Application requirements
3Documents and capabilities you must demonstrate at registration
- 01Operational Feasibility Letter
- 02Proof of ownership of funds for Environmental Pollution Control and/or Environmental Damage or funds for guaranteeing Environmental Function Recovery.
- 03Technical Approval from the Director General of PSLB3
Ongoing obligations
10Compliance and reporting duties throughout operation
- 01Identify the hazardous waste (Limbah B3) that is stored.
- 02Implementing the Storage of Hazardous and Toxic Waste in accordance with the standards for Hazardous and Toxic Waste Storage.
- 03Record the name and quantity of stored hazardous waste (Limbah B3).
- 04Storing B3 waste originating from other parties that will be deposited into the B3 Waste Collection site or directly into the B3 Waste Disposal facility.
- 05Meet environmental standards and/or environmental quality standards regarding the implementation of Hazardous Waste Landfilling.
- 06Comply with wastewater quality standards in accordance with the provisions of laws and regulations, if the disposal of hazardous waste (B3) generates wastewater.
- 07Establishing fencing and marking the location for the storage of hazardous waste (B3).
- 08Monitor groundwater quality and address any negative impacts that may arise from the release of hazardous waste (Limbah B3) into the environment.
- 09Close the top part of the Hazardous Waste Storage facility after the completion of the Hazardous Waste Storage activities.
- 10Prepare and Submit the Hazardous Waste Accumulation Report
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | All |
| Minister/Head of Agency | Foreign Investment |
§ 05
Auxiliary permits (PB UMKU)
PB UMKU permits sit on top of the main NIB and Sertifikat Standar — each is issued by a different ministry, and only when a specific operational activity is performed. This KBLI carries 4 candidate permits across 1 regulator; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Nuclear & Radiation Safety
4 permitsBAPETEN (Nuclear Energy Regulatory Agency). Applies whenever ionizing radiation sources are involved — radiology, radiotherapy, industrial NDT, certain manufacturing inputs. BAPETEN licenses the operator, the facility, and each radiation source separately.
- Construction Permit for Radioactive Waste ManagementIzin Konstruksi Pengelolaan Limbah Radioaktif11 requirements14 obligationsEnergy and Mineral Resources
- Decommissioning License for Radioactive Waste ManagementIzin Dekomisioning Pengelolaan Limbah Radioaktif4 requirements14 obligationsNuclear Energy
- Radioactive Waste Management Operating LicenseIzin Operasi Pengelolaan Limbah Radioaktif19 requirements17 obligationsNuclear Energy
- Statement of Exemption from Radioactive Waste ManagementPernyataan Pembebasan Pengelolaan Limbah Radioaktif5 requirements1 obligationNuclear Energy
Speak to Emerhub
Get your KBLI 38220 setup handled end-to-end.
Emerhub is a corporate-services provider in Indonesia. We handle PT PMA incorporation, licensing, tax registration and monthly compliance — so you focus on operating the business.