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November 11, 2026
by Tiyana Sigi Pertiwi
Overview
Minister of Environment/Environmental Control Agency Regulation No. 4 of 2026 on Environmental Laboratories, enacted on 12 May 2026 and promulgated on 4 June 2026, provides a guideline for the development of laboratories into Environmental Laboratories and establishes registration procedures for Testing Laboratories.
The regulation sets out registration requirements, application verification mechanisms, and laboratory information management to improve the quality and standards of environmental laboratory services. Furthermore, the regulation governs obligations to update laboratory data, supervision and guidance mechanisms, and administrative sanctions for noncompliance with applicable requirements. It also establishes transitional provisions for laboratories registered under the previous regulation and revokes Minister of Environment and Forestry Regulation No. 23 of 2020 on Environmental Laboratories. In addition, the Regulation is also accompanied by four appendices, which cover the application format, the registration procedure and minimum parameter scope, additional requirements beyond SNI ISO/IEC 17025, and the procedure for handling laboratory user reports.
Matrix Summary
| Provision | Key Summary |
|---|---|
| Articles 1–5 | This Regulation serves as a guideline for laboratory operators in developing their laboratories into Environmental Laboratories. Testing Laboratories may be operated by the central government, regional governments, state-owned enterprises (SOEs), regionally owned enterprises (ROEs), universities, or private businesses. Regional governments may develop their institutional structure by establishing independent regional technical implementation units or converting existing units into regional public service agencies. |
| Articles 6–10 | Testing Laboratories may apply for registration through the Ministry/Agency’s information system by submitting an accreditation certificate covering environmental quality parameters and a recommendation letter from the National Accreditation Committee (KAN). Applications must be verified within 7 working days, and the Registration Certificate must be issued within 20 working days after verification confirms completeness. Its validity follows that of the accreditation certificate. |
| Articles 11–12 | Environmental Laboratories must enter and update data in the Ministry/Agency’s information system, including laboratory details, registration expiry dates, and registered parameters. Updated information is reviewed and used to identify potential needs for supervision. |
| Articles 13–18 | Supervision consists of regular supervision by KAN to assess compliance with the latest SNI ISO/IEC 17025 and applicable requirements, and non-regular supervision through user reports and/or on-site inspections (uji petik). On-site inspections are conducted to verify consistency or investigate suspected non-compliance. Guidance may be provided based on the supervision results. |
| Articles 19–25 | Administrative sanctions include written warnings, suspension, and/or revocation of registration status. Laboratories must implement corrective recommendations within 60 working days of receiving a written warning. Registration is suspended if corrective actions are not completed within 60 working days and revoked if recommendations remain unaddressed within one year of the suspension decision. Laboratories registered under Minister of Environment and Forestry Regulation No. 23 of 2020 must comply with the new requirements within one year of the Regulation’s promulgation, i.e. by 4 June 2027, failing which their registration will be suspended. |
Key Highlights
Institutional Development of Environmental Laboratories
Environmental Laboratories support environmental protection and management, and this Regulation serves as a guideline for laboratory operators in developing their laboratories into Environmental Laboratories. Testing Laboratories may be operated by the central government, regional governments, state-owned enterprises, regionally owned enterprises, universities, or private businesses. Regional governments may develop their institutional structure by establishing an independent regional technical implementation unit or converting an existing unit into a regional public service agency. Such development covers strategic planning and governance, human resource development, service quality and infrastructure improvements, financial and marketing strategies, and performance monitoring and evaluation. The establishment of a regional public service agency must comply with applicable laws and regulations.
Requirements and Procedures for Testing Laboratory Registration
Testing Laboratories may apply for registration as Environmental Laboratories through the information system managed by the Ministry/Agency. Applications must include an accreditation certificate covering environmental quality parameters and a recommendation letter issued by the National Accreditation Committee (Komite Akreditasi Nasional/KAN). The application is verified by the relevant senior official within 7 working days of receipt. If complete, the registration letter is issued within 20 working days after verification is completed and delivered to the applicant within 5 working days of issuance. Registration remains valid for the duration of the accreditation certificate. Incomplete applications must be corrected and resubmitted within 7 working days of receiving notification. The Minister/Head publishes information on registered laboratories, including registration number and date, laboratory identity and address, registered parameters, validity period, and registration status.
Environmental Laboratory Information System
Environmental Laboratories must enter and update data and information in the information system managed by the Ministry/Agency, including laboratory details, registration expiry dates, and registered parameters. Updates are reviewed by the senior official responsible for Environmental Laboratory registration and used to identify the need for supervision.
Supervision and Guidance of Environmental Laboratories
Supervision of Environmental Laboratories consists of regular and non-regular supervision. Regular supervision is conducted by KAN to assess compliance with the latest SNI ISO/IEC 17025 and the requirements set out in Appendix III. Non-regular supervision is conducted by the senior official responsible for registration through handling reports from laboratory users and/or on-site inspections. User reports are submitted to the senior official overseeing the registration function, following the procedures in Appendix IV. Reports indicating a possible criminal violation are referred to the official responsible for environmental law enforcement, and reports affecting a laboratory’s competence or impartiality are passed to KAN. On-site inspections are conducted incidentally to verify consistency or investigate suspected non-compliance. Guidance may be provided by the relevant unit based on supervision results.
Additional Requirements for Environmental Laboratories
Appendix III of the Regulation sets out additional requirements to the latest SNI ISO/IEC 17025 for Testing Laboratories in developing the quality management system of an Environmental Laboratory. For the purpose of meeting environmental management compliance needs, business actors must use an external Environmental Laboratory. Environmental Laboratories must conduct their own sampling of environmental parameters, and sampling, analysis, and reporting of test results must be carried out by the same Environmental Laboratory. Where sampling is intended for environmental law enforcement, it must be carried out by competent and certified officers, accompanied by officers authorized under laws and regulations, and supported by a sampling record (berita acara pengambilan contoh uji). Test result reports may not state a result as not detected, but must report it as less than the limit of quantification, and for parameters that have a quality standard, the limit of quantification must be below that standard. Personnel must consist of at least two managerial personnel, two technical personnel, and one administrative officer, whether internal or external, adjusted to the laboratory’s scope of activities. Laboratories must also comply with the requirements on laboratory waste management and occupational safety and health, and complete an Integrity Pact.
Administrative Sanctions and Transitional Provisions
Laboratories found through supervision to have failed to meet one of or more requirements in Appendix III are subject to written warnings, suspension, and/or revocation of registration status by the Minister/Head. Laboratories receiving written warnings must implement corrective recommendations within 60 working days; failure to do so results in a one-year suspension. During suspension, laboratories may not display their registration number on test certificates or reports or conduct conformity assessment activities within their registered scope. Failure to implement corrective recommendations within one year of suspension results in registration revocation. Registration may be reactivated if the corrective recommendations are implemented within the one-year suspension period. Laboratories whose registration is revoked may not issue or distribute publications in any form and may reapply through KAN conformity assessment within six months of revocation. Supervision and guidance are funded through the state budget (APBN) and/or other lawful, non-binding sources. Laboratories registered under Minister of Environment and Forestry Regulation No. 23 of 2020 must comply with the new requirements within one year of promulgation, failing which their registration will be suspended.
Tiyana Sigi Pertiwi, S.H., LL.M.
Knowledge Lawyer
