Missing the 2020 Target of the Waste Framework Directive
Eunomia Study to Identify Member States at Risk of Non-Compliance with the 2020 Target of the Waste Framework Directive and to Follow-up Phase 1 and 2 of the Compliance Promotion Exercise
Dr Dominic Hogg Timothy Elliott Rebecca Burgess Thomas Vergunst
Missing the 2020 Target of the Waste Framework Directive – Introduction
Eunomia Research & Consulting (Eunomia) was commissioned by DG Environment of the European Commission to lead a consortium to undertake a Study to Identify Member States at Risk of Non-compliance with the 2020 target of the Waste Framework Directive and to Follow-up Phase 1 and 2 of the Compliance Promotion Exercise. The basis for this study is the “Early Warning System” that has been set out in the Commission’s proposed amendments to the Waste Framework Directive (see Recital 19 and Article 11b).1 The Early Warning System introduces the concept of Early Warning Reports which the Commission shall develop to assess ‘progress towards the achievement of the targets’. For each Member State these reports must:
- Provide an estimation of whether the targets are likely to be achieved by the stipulated deadline; and
- For countries deemed to be at risk of missing the target appropriate Priority Actions need to be drawn up to help the country achieve the target.
The Early Warning System does not apply to the existing 50% preparation for reuse and recycling target set out in Article 11 of the Waste Framework Directive (Directive 2008/98/EC). However, under this study, the Commission has decided to test the envisaged procedure, and in doing so, to help Member States to achieve the existing 50% target by 2020, and to highlight where issues may be arising in respect of the prospects for meeting targets that are likely to be higher in future years.
This Final Report provides an overview of the approach taken to the study, identifies those countries at greatest risk of failing to meet the 50% target in 2020, lists of Member States which were carried forward into Phase 2 of the study and synthesises the key issues found, and subsequent Priority Actions that were suggested. The results presented in this report are based on detailed reviews and discussions with Member States who had not achieved 50% recycling – under their chosen calculation method. The detailed results of this work are presented in the Early Warning Reports which have been developed for each Member State and which are appended to this report.
Missing the 2020 Target of the Waste Framework Directive – Approach to the Study
A two-phased approach was adopted to the study:
- Phase 1 – Identifying Member States at risk of not being able to achieve a preparation for reuse and recycling rate of 50% by 2020 (as defined by their chosen calculation method); and
- Phase 2 – Developing country specific Priority Actions for Member States found to be at greatest risk of not being able to achieve the target within the stipulated deadline.
In order to better understand the likelihood of Member States achieving the 50% target by 2020 it is necessary to understand the current levels of performance. This section sets out the latest recycling rate figures across all Member States (Section 3.1).
Details of historic recycling performance – as measured by Member States’ chosen calculation methods – were provided by the European Commission and are presented in Appendix 1. Figure 3-1 shows those Member States that were meeting the 50% target and those that were not in the latest year for which data was provided. The 20 Member States whose reported recycling rates were below 50% were consulted individually as part of Phase 1 of the study.
Missing the 2020 Target of the Waste Framework Directive – Data Accuracy
A recent study into the accuracy of European waste statistics, carried out for the Commission, concluded that there were still significant issues with many of the datasets, despite, in some cases, long time series.3 Two of the key causes were identified as:
- Insufficient verification of the data at EU and national level; and
- Lack of incentives for accurate data reporting.
With regard to the latter point the study notes that:
“The potential for mis-reporting of performance data linked to meeting mandatory targets is rarely discussed. Organisations, private or public, may have an incentive to mis-report, especially when there is some financial or reputational benefit to be gained from doing so. For instance, where producer responsibility applies, the challenge is to design the system in such a way that producers, and / or those who discharge obligations on their behalf, have no incentive to misreport their data. Producers have an incentive to under-report the amount of products placed on the market in order to save paying fees, and this also has the effect of increasing the reported recycling rate. Producer responsibility organisations, who seek to inflate recycling performance, might tend to under-report the total waste arisings (or amount placed on the market), and overstate the amount reported as recycled. Similar concerns apply to data gathered by public authorities: waste companies have an incentive, reputational, and sometimes, financial, to inflate their performance on recycling to indicate their contribution to meeting targets. Finally, Member States may not have incentives to engage with investigations regarding the quality of reporting in detail if the data indicate compliance with targets.”
The figures reported above, regarding current recycling performance, should therefore be viewed with some caution. Particularly, if unaudited data from producer responsibility organisations (i.e. compliance schemes) are used in the calculation. The issue of data reporting was raised in many of the country chapters given as Appendices to this report. To provide an overview of the potential scale of the issue, in terms of the magnitude of mis-reporting and the number of Member States affected, a cross-checking analysis was carried out.
Recycled From: Study to Identify Member States at Risk of Non-Compliance with the 2020 Target of the Waste Framework Directive and to Follow-up Phase 1 and 2 of the Compliance Promotion Exercise Download the Report here