Bali’s waste problem isn’t news, but in 2026, the “out of sight, out of mind” approach to disposal has met a legal dead end. New national regulations have shifted the burden of proof from municipalities to producers and operators, leaving hospitality businesses and PT PMAs in a precarious position.
This transition to strict enforcement means your operational footprint is now under a magnifying glass.
The pressure stems from a tightening net of mandates, specifically Extended Producer Responsibility (EPR) targets demanding a 30% waste reduction by 2029. Whether you operate a villa complex or a retail brand in Badung or Gianyar, you are now legally responsible for the end-of-life of your packaging.
Ignoring these shifts risks the revocation of environmental approvals or public disclosure of non-compliance by provincial authorities.
The solution lies in understanding how the upcoming EPR Law Reshape Waste across the island’s commercial landscape. By auditing your supply chain and integrating waste roadmaps into your environmental permits (UKL-UPL), you can protect your license and align with Bali’s “Trash-Free 2027” goal.
This guide breaks down the transition to mandatory compliance to help you build a regulation-proof operation. For official standards, referring to the Ministry of Environment and Forestry (MenLHK) is the essential first step.
Table of Contents
- Legal Foundation: Indonesia’s EPR Framework 2026
- Understanding the Producer Waste Reduction Roadmap
- Bali’s Local Policies: CL 9/2025 and Plastic Bans
- How the EPR Law Reshape Waste for Hotels and Villas
- Integrating Compliance into Environmental Approvals
- Mandatory Waste Limitation and Design for Recyclability
- Real Story: An Uluwatu Beach Club’s Supply Chain Pivot
- Risks, Penalties, and the 2027 Trash-Free Vision
- FAQs about EPR and Waste Compliance
Legal Foundation: Indonesia’s EPR Framework 2026
The legal backbone of Indonesia’s current waste shift is rooted in Law 18/2008 on Waste Management. For over a decade, this law sat largely underutilized in the tourism sector, but the landscape changed with the introduction of PERMENLHK 75/2019.
This regulation created the first formal Producer Waste Reduction Roadmap, targeting the manufacturing, food and beverage, and retail sectors. As we move through 2026, the government is no longer just encouraging change; it is mandating it through a series of technical guidelines.
By mid-2026, a new Presidential Regulation is expected to harmonize these producer obligations across all provinces. This move elevates waste management from a local hygiene issue to a national security and investment priority.
For foreign investors, this means your PT PMA must now account for the lifecycle of every plastic bottle, aluminum can, and glass container you introduce to the market. The framework targets four priority materials: plastics, aluminum, glass, and paper, requiring a documented 30% reduction in waste generation by the end of the decade.
Understanding the Producer Waste Reduction Roadmap
The roadmap is a 10-year strategy (2020–2029) that requires obligated businesses to submit detailed plans for waste limitation, reuse, and recycling. In 2026, the focus has shifted from planning to verification. Producers must now provide annual progress reports backed by data from licensed waste-management partners. This transparency is intended to eliminate “shadow dumping” and ensure that recyclables actually reach processing facilities rather than the Suwung landfill.
Businesses are required to implement “Design for Recyclability” into their procurement. This involves selecting mono-materials and eliminating non-recyclable components like multi-layer sachets or PVC packaging.
For a PT PMA in Bali, this means auditing every supplier to ensure their packaging aligns with your company’s waste-reduction targets. The goal is to create a closed-loop system where the producer takes back or finances the recycling of their products, effectively internalizing the cost of waste.
Bali’s Local Policies: CL 9/2025 and Plastic Bans
While national laws set the baseline, Bali’s provincial government has accelerated the timeline. On April 2, 2025, the Governor issued Circular Letter No. 9/2025 (CL 9/2025), which launched the “Gerakan Bali Bersih Sampah.”
This directive is a direct assault on single-use plastics across the island, prohibiting the production and distribution of plastic bottled water in volumes under one liter. It also bans the provision of plastic bags, straws, and cutlery in all tourism facilities.
The local policy is significant because it ties waste management to business license reviews. Under Bali Province regulations, violations of these plastic bans can trigger administrative sanctions, including the public naming of non-compliant businesses in local media.
For luxury brands and high-end resorts, this reputational risk is often more damaging than the fines themselves. The provincial vision of a “Trash-Free Bali by 2027” relies on every operator in the hospitality chain becoming a waste-management hub at the source.
How the EPR Law Reshape Waste for Hotels and Villas
The hospitality sector in Bali is uniquely positioned at the intersection of production and retail. Large hotels and villa complexes are now viewed as “F&B producers” when they provide packaged water or toiletries to guests.
This means the EPR Law Reshape Waste by forcing these properties to transition from disposable amenities to refillable, bulk-dispensing systems. The traditional welcome basket filled with plastic-wrapped snacks and small water bottles is now a liability rather than a luxury.
Operational changes are no longer optional. Resorts are now expected to partner with licensed “take-back” operators who collect specific materials for high-value recycling. This shift also impacts construction and renovation waste for property investors.
If your PT PMA is developing a new site, your waste-reduction commitments must now be explicitly stated in your environmental permit. The government is moving away from the “municipal problem” model toward a system where the business pays for every gram of waste it produces.
Integrating Compliance into Environmental Approvals
Circular Letter SE.11/2025 has introduced a critical technical hurdle: producer waste-reduction obligations are now embedded directly into environmental approvals like UKL-UPL and RKL-RPL. Effectively, this means that your waste-reduction plan is a condition of your legal right to operate.
If your business falls into the manufacturing, F&B, or retail categories, you cannot obtain or renew your environmental license without a credible 10-year roadmap that aligns with national targets.
This integration ensures that waste management is considered during the investment phase, not as an afterthought. For new tourism projects, this involves calculating the baseline waste generation of the proposed facility and providing evidence of partnerships with licensed recyclers. By making waste reduction a licensing requirement, the government has given the EPR Law Reshape Waste teeth, ensuring that every PT PMA is held accountable for its environmental footprint from day one.
Mandatory Waste Limitation and Design for Recyclability
Waste limitation is the first and most preferred tier of the EPR hierarchy. It requires businesses to avoid waste generation entirely whenever possible. In the Bali context, this translates to the elimination of single-use bottled products and the adoption of glass bottling plants on-site at major resorts.
The design phase of any product or service must now prioritize materials that do not contaminate existing recycling streams, such as switching from colored PET to clear PET or moving to aluminum which has an infinitely higher recycling rate on the island.
The transition to mono-materials is particularly challenging for the retail and personal care sectors within Bali’s PT PMAs. However, those who adapt early are finding a competitive advantage.
Guests are increasingly favoring “Eco-Certified” properties, and many booking platforms now highlight businesses that have moved away from single-use plastics. By investing in packaging that is designed for a circular economy, businesses reduce their future liability under the 30% reduction mandate and strengthen their market position.
Real Story: An Uluwatu Beach Club’s Supply Chain Pivot
Meet Marc, a 44-year-old entrepreneur from France who owns a high-traffic beach club in Uluwatu. Marc’s business was built on high-volume cocktails and premium bottled water, but in late 2025, he faced a grueling audit during his environmental license renewal.
The district authorities pointed out that his beach club was generating nearly 200 kilograms of plastic waste daily, much of which was non-recyclable single-use bottles prohibited under Bali’s CL 9/2025.
The humidity of the mid-day sun felt even heavier as Marc reviewed the potential administrative sanctions, including a public disclosure of his club’s violations.
He realized that the traffic and noise of his popular venue had made him a prime target for enforcement. That’s when he used our waste-compliance consulting service to restructure his entire supply chain.
We helped him negotiate a transition with his beverage suppliers to switch from plastic to glass and aluminum, and we integrated an on-site glass crushing system for local construction use.
The pivot was not without its challenges; Marc had to retrain his staff and explain the absence of plastic straws to thousands of tourists. However, the resolution was transformative.
By the time his 2026 audit arrived, he had reduced his plastic footprint by 65%. His beach club became a local pilot for “waste-free tourism,” and he secured a 5-year extension on his environmental approval. Today, Marc’s venue is a testament to how proactive circularity can turn a regulatory hurdle into a brand-building success.
Risks, Penalties, and the 2027 Trash-Free Vision
The risks of ignoring the EPR Law Reshape Waste are escalating. Nationally, failure to meet roadmap targets can lead to written warnings, orders to correct, and potential revocation of environmental approvals. In Bali, the enforcement of CL 9/2025 is particularly visible.
Local “Desa Adat” (traditional villages) are increasingly involved in waste enforcement, meaning that social pressure and local community relations are now tied to your waste performance.
One of the most common mistakes is assuming that waste management is purely a municipal responsibility. Many businesses fail to budget for the cost of professional recycling contracts, assuming the “local bin man” is sufficient.
However, in the era of digital reporting and state audits, you must be able to prove where your waste ends up. As Bali pushes toward its 2027 “Trash-Free” aspiration, the government will likely introduce mandatory EPR contributions or product-specific take-back quotas, making early adaptation a financial necessity.
FAQs about EPR and Waste Compliance
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Does the EPR law apply to small villas or only large hotels?
While PERMENLHK 75/2019 focuses on larger producers, the integration of waste roadmaps into environmental approvals (SE.11/2025) means any business requiring a UKL-UPL or RKL-RPL must comply. This includes most commercial villas and boutique hotels.
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What is the 30% reduction target exactly?
The EPR Law Reshape Waste mandates that producers reduce their generated waste by 30% by the year 2029, compared to their documented baseline generation.
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Can I still provide plastic water bottles to guests?
Under Bali’s Circular Letter 9/2025, the distribution of single-use plastic bottled water in volumes under one liter is prohibited. You should switch to glass bottles or refillable dispensers.
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How does the government track my waste reduction?
Businesses must submit an annual report of their waste-reduction progress, usually through the MenLHK portal or as part of their environmental license reporting. The upcoming mid-2026 Presidential Regulation will likely streamline this process.
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What happens if I don't have a 10-year waste roadmap?
Failure to provide a roadmap can lead to the rejection of your environmental license renewal or administrative sanctions, including business license reviews.
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Are there benefits to early compliance?
Yes. Proactive compliance protects your license, reduces long-term operational costs, and positions your brand as a leader in "Quality Tourism," which is a major focus for Bali in 2026 and beyond.
