Shipping Emissions and Ship Recycling in Indonesia

Originally published in Lexology Panoramic: Shipping 2027.

By Setyawati Fitrianggraeni, S.H., LL.M., FCIArb., FAIADR, Reynalda Basya Ilyas, and Tiyana Sigi Pertiwi, S.H., LL.M.

In brief

There is no emission control area in force in Indonesia’s domestic territorial waters, but since 1 January 2020 vessels sailing in Indonesia must use fuel with a maximum sulphur content of 0.50 per cent by mass, although no sanctions for non-compliance are prescribed. On recycling, Indonesia applies the Basel Convention and its own ship-scrapping rules, and requires larger Indonesian-flagged vessels to comply with the safety standards of the Hong Kong Convention even though Indonesia is not an official party to it. The law is stated as at 22 May 2026.

Shipping emissions

Emission control areas

The emission control area (ECA) regime is based on Annex VI of the Protocol of 1997 to the International Convention for the Prevention of Pollution from Ships 1973. There is no ECA in force in the domestic territorial waters of Indonesia.

Sulphur cap

The sulphur content of fuel oil is regulated in Circular Letter of the Director General of Sea Transportation No. SE 35 of 2019 concerning the Obligation to Use Low Sulfur Fuel and the Prohibition of Transporting or Carrying Fuel that Does Not Meet the Requirements and Management of Waste from Exhaust Gas Recirculation from Ships. Since 1 January 2020, vessels sailing in Indonesia must use fuel with a sulphur content containing a maximum of 0.50 per cent by mass. However, there are no sanctions for non-compliance.

Ship recycling

Regulation and facilities

Indonesia has ratified the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal through Presidential Decree No. 61 of 1993. Hazardous wastes due to ship recycling activities are considered as wastes under this convention.

The Shipping Law defines “ship scrapping” as acts of cutting and destroying ships that are no longer used in a safe and environmentally sound manner that must be done in line with the marine environment protection’s requirements. Ship recycling activities in violation of protection of the marine environment are subject to two years’ imprisonment and a maximum fine of Rp3,000,000.

Although Indonesia is not an official party to the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships 2009, Minister of Transportation Regulation No. 24 of 2022 has made reference to the convention by stating that all sea-going Indonesian-flagged vessels of 500 GT and above should comply with the safety standards of the convention.

Meanwhile, all Indonesian-flagged vessels of 100 gross tonnage and above should comply with the safety standards of Minister of Transportation Regulation No. 24 of 2022. The ship recycling facilities in Indonesia must also comply with the safety and environmental standards as outlined in that regulation.

For advice on shipping emissions, ship recycling, and environmental compliance in Indonesia, contact Anggraeni and Partners at connect@ap-lawsolution.net.