00083160 Reducing Releases of Polybromodiphenyl Ethers (PBDE) in Indonesia GEF Mid-Term Evaluation

Report Cover Image
Evaluation Plan:
2016-2020, Indonesia
Evaluation Type:
Mid Term Project
Planned End Date:
Completion Date:
Management Response:
Evaluation Budget(US $):


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Download document 121819 PBDE MTR report_FINAL.pdf report English 1375.97 KB Posted 1239
Download document UNDP MTR TOR PBDEs-UPOPs.pdf tor English 402.33 KB Posted 1724
Download document 121819 PBDE MTR report_FINAL.pdf report English 1375.97 KB Posted 1447
Title 00083160 Reducing Releases of Polybromodiphenyl Ethers (PBDE) in Indonesia GEF Mid-Term Evaluation
Atlas Project Number: 00083160
Evaluation Plan: 2016-2020, Indonesia
Evaluation Type: Mid Term Project
Status: Completed
Completion Date: 09/2019
Planned End Date: 06/2019
Management Response: Yes
Focus Area:
  • 1. Others
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 1.4.1 Solutions scaled up for sustainable management of natural resources, including sustainable commodities and green and inclusive value chains
SDG Goal
  • Goal 12. Ensure sustainable consumption and production patterns
SDG Target
  • 12.4 By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle, in accordance with agreed international frameworks, and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment
Evaluation Budget(US $): 35,000
Source of Funding: PBDE project
Evaluation Expenditure(US $): 35,000
Joint Programme: No
Joint Evaluation: No
Evaluation Team members:
Name Title Nationality
Carlo Lupi
Carlo Lupi
GEF Evaluation: Yes
GEF Project Title: GEF Mid Term Evaluation: Reducing Releases of Polybromodiphenyl Ethers (PBDE) in Indonesia
Evaluation Type: Mid-term Review
Focal Area: Persistent Organic Pollutants
Project Type: EA
GEF Phase: GEF-5
GEF Project ID: 5052
PIMS Number: 5073
Key Stakeholders:
Countries: INDONESIA

In general, therefore, the project strategy seems still relevant and flexible enough to implement changes without affecting too much the potential to achieve the final objective. Verification during the MTR however brought to the surface some inconsistencies that need to be resolved through specific amendment of the project document. These are:

1)     The project is ambiguous concerning the number of mini-depots to be established. in page 22 of the project document, the target is set at 8; however, in the result framework, output 4, the target of mini-depots to be established is set at a maximum number of 6. Nevertheless, UNDP-CO and the PMU believe that the true number of mini-depots to be established is only 3. This aspect has obviously to be clarified.

2)     The schedule of disposal of plastic waste and its linkage with the availability of the mini-depots: The project document established quite a tight schedule for the disposal of PBDE contaminated plastic, starting from 100 t in the first year up to 1000 t in the last year (output 3.2 in the result framework). Even in this case, a significant discrepancy does exist between the alternative scenario description (page 20, activity 3.2.1 set the target at 50 t/year) and the result framework (from 100 t/yr in the first year up to a total of 1000 t/yr in the fourth year). The establishment of mini-depots and the disposal of PBDE plastic waste are not explicitly linked in the project and this aspect needs to be explicitly reconfirmed.

3)     The project therefore already contributed the level of awareness of the key actors, which is the first and fundamental brick to ensure that the sought changes will happen. The question is however whether the current socio-economic structure of the operators (recyclers and manufacturers) are efficient enough to support the change. On this aspect, learning how the project ensured the certification of PBDE-free plastic in the manufacturing sector was an interesting lesson.

4)     On the matter of environmental risk to sustainability of the project, in relation to the PBDEs and UPOPs release to the environment, several indicators shall be taken into consideration. One is the number of mini-depots for waste separation established at communities shall be one of the indicators in sustainability of the project. Currently, the project is at risk at achieving the reduced target of 3 mini-depots to be operational by project end.  Another indicator is the amount of PBDE-contaminated plastic segregated and disposed. Currently, no PBDE-contaminated has been segregated and disposed, against a cumulative target of 800 tons for the 3rd year, and the discussion on potential technologies for disposal of such waste did not start yet.

5)     To be fully sustainable from the environmental standpoint, it’s likely that the project deadline should be postponed to ensure enough time for achieving and monitoring the sought environmental targets.



The Evaluation has revealed findings as follow;

1.     During the Mid Term Review mission in Indonesia, interviews with representatives of manufacturing industries revealed that c-octa and c-penta PBDEs are not used anymore in plastic industry, and that deca-BDE has been recently replaced by the equivalent Deca-Bromodiphenyl-ethane. On the other side, it is evident that the presence of POP PBDEs in plastic is more a consequence of a lack of control and segregation in the plastic recycling sector rather than of the intentional introduction of this substance in the raw material. Therefore, the initial assumption of high use of PBDEs in production processes seem not anymore valid. Indeed, the project implementation has since the project inception focused more on the recycling sector than on the manufacturing of plastic, therefore the limited validity of project assumptions (use of PBDE in plastic production) seems having not significantly affected the project outcomes. It’s however evident that the problem of PBDE releases are more on the side of waste management and recycling than on the side of manufacturing and the implementation is currently mostly focused on waste management activities. The project strategy is still relevant, although the focus has shifted toward recycling activities.

2.     The visit to some plastic recycling sites during the MTR revealed that in these areas, the market pressure for plastic waste has become so important that the economy of plastic recycling replaced agricultural economy. The management of plastic waste, and among them, plastic waste contaminated by PBDE is obviously a high priority for Indonesia. The key project stakeholders (MOEF, MOI, MOF) were involved in project design, and during interviews they confirmed the relevance of the project strategy with country priorities. Interviews with recyclers also confirmed that the objective of the project is relevant, and there are high expectations that some specific project activities may contribute to an improvement of life conditions and reduction of environmental burden. While the deployment of mini-depots to improve the treatment and segregation of plastic waste is considered, by the communities of recyclers, a fundamental project output , the improvement and enforcement of the regulatory framework is seen by the institutional stakeholders  as the most important goal to be achieved to ensure that PBDE contaminated plastic is properly segregated and disposed and that plastic products are free of PBDE .

3.     Most of the key project stakeholders were involved in project design. More specifically, MOEF and MOI had an active role in the project design since PIF stage. The gender mainstreaming component seems therefore not well integrated in the project document, and the opportunity to better address the condition of women in the plastic recycling industry seems overlooked in the project strategy.

4.     Remaining barriers hinder project’s objectives;

a.     Socio-economic barriers. The project is currently at a crucial turning point. Most of the training and raising awareness activities have been completed, however the impact which may be observed on the field as a result of these activities is limited. Looking at the training materials and training reports, it seems that the activities have been carried out professionally, and the deliverables are of good quality. The question on why the impact of this activity is limited has then to be probably searched on the financial aspects of the recycling economy: the recycling activities are mostly carried out informally by small groups carrying out manually most of the work, and surviving on small marginal prices. The biggest recycling factory visited in Mojokerto has a staff of around 25 persons. The adoption of equal wages, measures for higher safety at work, best processing of plastic and environmentally sound disposal of unrecyclable plastic, would impact the operational cost in such a way that they can be sustained only through a substantial scale-up of the operations, or a substantial public subsidy. In the absence of that, very likely the recycling of plastic will remain a market were only informal operators who externalise al the social and environmental cost of the recycling can survive.

b.     Technical barriers. On the side of technical barrier, identifying PBDE contaminated plastic without affecting too heavily the speed and cost of recycling operation is challenging and could be addressed only by the synergy of a specific legislation and a combination of procedures. Indications for possible procedures have been proposed in the technical guidelines developed under the project, which should be tested and implemented. As there are no way to distinguish between different brominated flame retardants with portable analysers (like XRF), at legal level recyclable vs. non-recyclable plastic should be rather based on the total concentration of bromine. Even so, however, it would not be possible to analyse all the plastic during recycling operation with XRF or similar equipment (first of all because these equipment are expensive and out of the reach of small recyclers, and secondly because that would significantly slow down the recycling operations), hence a combination of approaches should be pursued to achieve the result of segregation, at an acceptable cost, of a stream of non-recyclable plastic potentially contaminated by BRF. These should include collection at source, segregation by type of waste, density tests (floating) and only as a confirmation, XRF testing.

c.     Financial barriers. No activity has been carried out so far on the identification of a technology for the disposal of the identified brominated plastic. As the choice is limited to incineration and co-incineration, that aspect should not represent a significant technical barrier. However, technical and financial discussion with cement kiln factories to understand their willingness and technical constraints, as well as costs, should be undertaken. Disposal cost or availability of a disposal technology could be a barrier in case the co-incineration in cement kilns prove to be not viable.

5.     The Project Manager and Project Management Unit are accountable to the NPD for sound administrative and financial management of the project as well as effective delivery of project activities. Accountabilities of project management are formally presented to the NPD by timely completion of annual and quarterly work plans and reports with required supporting documents.

6.     During the implementation period, the project has started to introduce and provide training on financial planning and management by impacting knowledge to both women and men’s workers at plastic recycling sectors. Meetings to budget planning to sustain the work plan has been held since 2016, which involved the institution related to finance. Such budgeting is prepared annually through the Annual Work Plan (AWP) of the project. The project intends to ensure sustainability during the implementation period through the financial incentives, provided for the corporate social responsibility programs, such as supporting the ISO certification of manufacturers to prevent the use of PBDE contaminated plastic, equipment investments for environmentally sound operations and management. Still, financial resource in dealing with the chemical management in both of the government and industry are still lacking and therefore need to be assisted. 

7.     In enhancing the sustainability from the perspective of the institutional framework and governance risk, the project initiated to build up the focal point for knowledge management and institutional knowledge on PBDEs and gender in the context of hazardous chemical risk exposures. An arranged group of potential trainers, both men and women, is tasked to facilitate trainings on gender-sensitive health and safety protection and financial literacy. Further, to further mitigate the risk, Ministry of industries has developed module trainings reporting period (BAT/BEP module) for industries and plastic recycling sector, gender and gender sensitive health and safety protection module training, financial literacy module training. It is aimed to serve as tools for sustainable capacity building in the proper handling of PBDEs containing plastics.

8.     Additionally, the sustainability of this project can be seen from the strong support from relevant ministries/agencies. Ministry of Environment and Forestry, Ministry of Health, Ministry of Trade, BPPOM and Bappenas has also been involved in this project to support it in line with the Indonesia’s comiitment to reduce PBDE as hazardous chemicals and UPOP’s emissions by ratifying the Stockholm Convention on POPs through the Law No. 19 of 2009.


The number of mini depot to be developed is three, located in Cirebon, Malang, and Depok. The three mini depots should reduce hazardous and unrecyclable plastic. 


PBDE Project recommends that -- while mini depots are still in progress and not able to work on plastic disposal – an effort to safely dispose PBDE containing plastic should be done with third parties (recyclers, cement kiln, hazardous waste companies).  


PBDE Project recommends “no additional cost” extension of nine months, in order to allow the project to complete component 3 and 4  

1. Recommendation:

The number of mini depot to be developed is three, located in Cirebon, Malang, and Depok. The three mini depots should reduce hazardous and unrecyclable plastic. 

Management Response: [Added: 2019/08/06]

The project has conducted meetings with Ministry of Industry to establish three mini depots in the beginning of the project and the target each mini depot should achieve.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
1. Develop contact with prospective agencies and/or local governments in which mini depots will be consructed. 2. Discuss the technical matters with the project prospective partners (agencies, or local governments) and consultants in regards with the development of mini depots in three locations. The tehcnical matters include the building construction, machine specifications, feasibility studies, environment studies, economic studies, and environment studies.
[Added: 2019/08/20] [Last Updated: 2021/02/15]
UNDP CO and Implementing partner 2021/01 Completed Planned key actions were completed, and the mini depots are established. History
2. Recommendation:

PBDE Project recommends that -- while mini depots are still in progress and not able to work on plastic disposal – an effort to safely dispose PBDE containing plastic should be done with third parties (recyclers, cement kiln, hazardous waste companies).  

Management Response: [Added: 2019/08/06]

PBDE project has developed communications with some parties who have capabilites in disposing hazardous wastes.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Develop contact with cement industries and companies who have expertise in hazardous waste disposal.
[Added: 2019/08/20] [Last Updated: 2021/02/15]
UNDP CO Indonesia and Implementing partner 2021/01 Completed The coordination with cement industries and companies were held to support the waste disposal system. All results will be measured in Terminal Evaluation. History
3. Recommendation:

PBDE Project recommends “no additional cost” extension of nine months, in order to allow the project to complete component 3 and 4  

Management Response: [Added: 2019/08/20]

The project conducted a series of meeting with Ministry of Industry as the implementing partner to repsond the recommendations from MTR finding and to discuss the extension of the project.

This recommend will be discussed in the project board meeting on 31 Juli 2019

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Conduct meetings with Ministry of Industri as the implementing partner regarding the posibility of extension. The discussion also focus on the timeline schedule and budget to spend for the extension.
[Added: 2019/08/20] [Last Updated: 2020/01/16]
UNDP CO and Implementing partner 2019/12 Completed The meeting had been conducted engaging the Ministry of Industry as implementing partner History

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