Permit for industrial waste disposal (intermediate treatment): facility installation, zoning and the environmental impact survey

In short: to dispose of industrial waste as a business — by incineration, crushing, dewatering and the like — you need a permit from the prefectural governor under Article 14, paragraph 6 of the Waste Management Act (Act on Waste Management and Public Cleansing), which is a separate permit from the collection-and-transport permit (Article 14, paragraph 1). In addition, when you install an incineration or crushing facility of a type and processing capacity set by cabinet order, you separately need the industrial-waste-treatment-facility installation permit under Article 15 of the same Act, and you must attach to the application documents recording the results of a living-environment impact survey (Article 15, paragraph 3). Treatment facilities such as incinerators cannot be newly built or extended under Article 51 of the Building Standards Act unless the location of their site is fixed in the city plan or the specified administrative agency grants permission. This article is general information organising the disposal-business permit, the facility installation permit, zoning, disqualifications and the course, and the division of roles; it does not judge the outcome of any individual permit.

How does an industrial waste "disposal business" differ from the collection-and-transport permit?

Industrial waste permits are divided into a collection-and-transport business for "carrying" waste and a disposal business for "treating" it, and each is a separate permit. The disposal business is further divided into intermediate treatment, which changes the nature or volume of waste before final disposal, and final disposal such as landfill.

Category	Basis	Content
Collection and transport business	Article 14(1)	Collecting and transporting another party's industrial waste as a business
Disposal business (intermediate treatment)	Article 14(6)	Incineration, crushing, dewatering, neutralisation, sorting and other treatment that changes the nature or volume before final disposal
Disposal business (final disposal)	Article 14(6)	Landfill disposal and ocean disposal

Intermediate treatment includes, for example, crushing rubble into recycled crushed stone, crushing and incinerating wood chips, and dewatering sludge. The criteria for the disposal-business permit are set in Article 14, paragraph 10, and you must satisfy both the standards for facilities and the applicant's ability (paragraph 10, item 1) and the requirement of not falling under a disqualification (paragraph 10, item 2, which applies Article 7, paragraph 5, item 4 through paragraph 5, item 2). Within the scope of administrative-scrivener work, Yotsuba Administrative Scrivener Office supports confirming whether a permit is required, organising the requirements, preparing the application documents and acting as agent. The outcome of any individual permit is a matter for the prefecture's examination.

What do the Article 15 facility installation permit and the living-environment impact survey require?

Separately from the disposal-business permit (Article 14(6)), installing certain industrial-waste-treatment facilities requires the facility installation permit under Article 15, paragraph 1. This is a layer specific to intermediate treatment that collection and transport does not have.

Procedure	Basis	Point
Facility installation permit	Article 15(1)	Facilities of the type and capacity set in Article 7 of the cabinet order are subject
Attaching the impact-survey document	Article 15(3)	Survey the effects on air quality, water quality, noise, vibration and odour, and attach the results as a document
Public notice and inspection	Article 15(4)	For facilities set by cabinet order, such as incinerators and final-disposal sites, the application and survey are made available for public inspection
Submission of opinions	Article 15(6)	During the inspection period, interested parties may submit written opinions from the standpoint of preserving the living environment
Permit criteria	Article 15-2	Conformity with technical standards, appropriate consideration for the living environment, the applicant's ability, and not falling under a disqualification

If the facility's processing capacity falls below the scale set in Article 7 of the cabinet order (for example, a rubble or wood-chip crushing facility with a daily processing capacity exceeding five tonnes, or a sludge incineration facility of a certain scale or larger), the Article 15 facility installation permit is not required, but the disposal-business permit (Article 14(6)) is still separately required. For facilities other than incinerators and final-disposal sites, such as crushing facilities, the impact-survey document must be attached, but they are not subject to the public notice and inspection under Article 15, paragraph 4. Designing the facility's location and structure and the building-confirmation application are the domain of an architect and a designated confirmation and inspection body.

Where can an intermediate-treatment facility be located under zoning and the Building Standards Act?

Treatment facilities are restricted by the zoning under the Building Standards Act. The broad tendency is as follows, but it varies by the type and scale of the facility and by the municipality's operation, so always confirm with the specified administrative agency of the location.

Zoning district	Tendency for siting an intermediate-treatment facility
Exclusive industrial / industrial districts	Easier to site
Quasi-industrial district	Whether allowed varies by type and scale
Residential / commercial districts	In principle difficult

In addition, treatment facilities set by cabinet order, such as refuse incineration plants (including industrial-waste-treatment facilities), cannot be newly built or extended under Article 51 of the Building Standards Act unless the location of their site is fixed in the city plan. However, this does not apply where the specified administrative agency, after the deliberation of the prefectural city planning council, grants permission finding that the location of the site poses no obstacle to the city plan. Confirming zoning and acquiring or leasing a candidate site is the role of a licensed real estate broker. Yotsuba Real Estate Co., Ltd., a separate business from Yotsuba Administrative Scrivener Office, handles the property investigation, acquisition and lease under a separate contract as an independent business. Our office receives no referral fee.

How do the disqualifications, the course and the ability requirements change for a disposal business?

The criteria for the disposal-business permit (Article 14, paragraph 10) share the same framework as the collection-and-transport business, consisting of standards for facilities and ability and the disqualifications.

• Standards for facilities and ability (paragraph 10, item 1): facilities matching the disposal method, and ability sufficient to conduct the business accurately and continuously (including a financial basis)
• Disqualifications (paragraph 10, item 2): not falling under Article 7, paragraph 5, item 4, which is applied via paragraph 5, item 2 (imprisonment or a heavier penalty, fines for violating environment-related laws, organised-crime ties, bankruptcy without restoration of rights, etc.)
• Course: completion of the industrial-waste disposal course run by the Japan Waste Management Association (JW Center). It is a different course from the collection-and-transport course, and you must complete it before applying

Imprisonment (kokin-kei) is the unified form created by the 2022 revision of the Penal Code, and the provision is worded as imprisonment or a heavier penalty. The number of days of the course, the validity of the completion certificate and the treatment by each municipality differ, so check the latest guidance of the prefecture to which you apply. Disqualifications extend not only to the applicant but also to a company's officers and certain employees.

Who handles the permit application, the building work and the tax matters?

Planning an intermediate-treatment facility involves separate fields: the permit, the property, the design, registration, tax and labour affairs. The roles are as follows.

• Confirming requirements, preparing documents and acting as agent for the disposal-business permit and the facility installation permit → Yotsuba Administrative Scrivener Office (administrative scrivener)
• Confirming zoning and acquiring or leasing the candidate site → Yotsuba Real Estate Co., Ltd. (licensed real estate broker)
• Structural design of the facility and the building-confirmation application → an architect and a designated confirmation and inspection body
• Registration such as company incorporation and change of officers → a judicial scrivener
• Tax on capital investment, depreciation and consumption tax → a certified public tax accountant
• Employees' labour insurance and work rules → a certified social insurance labour consultant

Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are separate businesses. Each field is on the premise that you contract separately with each qualified professional as an independent business, and our office receives no referral fee. For expanding from collection and transport, see How to obtain a collection-and-transport permit; for the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the whole picture of our services, see Permits and Applications.

FAQ

Q. To carry out intermediate treatment, is a collection-and-transport permit alone enough?
A. No. The collection-and-transport business for "carrying" waste (Article 14(1)) and the disposal business for "treating" it by incineration, crushing and the like (Article 14(6)) are separate permits. To carry out intermediate treatment on entrustment from another company, you need a disposal-business permit, and its scope is set for each category of waste handled.

Q. Is the facility installation permit (Article 15) required for any facility?
A. No. The facility installation permit is required for facilities of the type and capacity set in Article 7 of the cabinet order. For example, for a rubble or wood-chip crushing facility, whether the daily processing capacity exceeds five tonnes is the benchmark. If the scale falls below this, the facility installation permit is not required, but the disposal-business permit is separately required.

Q. Is the living-environment impact survey placed on public inspection even for a crushing facility?
A. Attaching the document recording the results of the living-environment impact survey (Article 15, paragraph 3) is required for facilities subject to the installation permit. On the other hand, the procedure of making the application and survey available for public inspection so that interested parties may submit opinions (Article 15, paragraphs 4 and 6) applies to facilities set by cabinet order, such as incinerators and final-disposal sites; a crushing facility is not subject to this inspection procedure.

Q. Can I build an incineration facility on idle land near a residential area?
A. You need to confirm zoning and Article 51 of the Building Standards Act. A treatment facility such as a refuse incineration plant cannot be newly built unless the location of its site is fixed in the city plan, or the specified administrative agency has granted permission after the deliberation of the prefectural city planning council. Whether a candidate site meets the requirements is a matter for the specified administrative agency of the location and the prefecture's examination.

Sources (Primary Information)

• e-Gov Law Search, "Act on Waste Management and Public Cleansing" (Act No. 137 of 1970), Article 14, paragraphs 1, 6 and 10; Article 15, paragraphs 1 to 4 and 6; Article 15-2; Article 7, paragraph 5, item 4 (accessed 2026-09-11)
• e-Gov Law Search, "Order for Enforcement of the Act on Waste Management and Public Cleansing" (Cabinet Order No. 300 of 1971), Article 7 (types and processing-capacity scale of industrial-waste-treatment facilities) (accessed 2026-09-11)
• e-Gov Law Search, "Building Standards Act" (Act No. 201 of 1950), Article 51, and the Order for Enforcement of the Building Standards Act, Article 130-2-3 (accessed 2026-09-11)
• Ministry of the Environment, "Guidelines for the living-environment impact survey of waste-treatment facilities" (explaining the attachment of the survey document, public notice, inspection and hearing of opinions) (accessed 2026-09-11)
• Japan Waste Management Association (JW Center), "Course on the permit application for industrial waste treatment businesses (disposal course)" guidance (accessed 2026-09-11)

This article is general information and does not guarantee the outcome of any individual permit, whether a facility installation permit is required, the items of the living-environment impact survey, the application of zoning or Article 51 of the Building Standards Act, or the examination period. The permit outcome and examination are matters for the prefecture, and the application of zoning and Article 51 is judged by the specified administrative agency of the location. Confirming zoning and acquiring or leasing a candidate site is handled by Yotsuba Real Estate Co., Ltd. (licensed real estate broker); the structural design and building-confirmation application by an architect and a designated confirmation and inspection body; registration such as company incorporation and change of officers by a judicial scrivener; tax such as capital investment and consumption tax by a certified public tax accountant; and employees' labour affairs by a certified social insurance labour consultant, each as an independent business under a separate contract. Our office receives no referral fee. Individual judgements are made by a qualified professional after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.