Special Report No 20/2012 ‘Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?’
Date: 2013-01-30
Institutions: European Court of Auditors
Subjects: domestic waste, dumping of waste, environmental impact, financial aid, municipality, waste recycling

EUROPEAN
COURT OF AUDITORS

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IS STRUCTURAL MEASURES FUNDING FOR MUNICIPAL 
WASTE MANAGEMENT INFRASTRUCTURE PROJECTS 
EFFECTIVE IN HELPING MEMBER STATES ACHIEVE EU 
WASTE POLICY OBJECTIVES?

EN

 
 
 
 
Special Report No 20 

 2012

IS STRUCTURAL MEASURES 
FUNDING FOR MUNICIPAL WASTE 
MANAGEMENT INFRASTRUCTURE 
PROJECTS EFFECTIVE IN HELPING 
MEMBER STATES ACHIEVE EU WASTE 
POLICY OBJECTIVES?

(pursuant to Article 287(4), second subparagraph, TFEU)

EUROPEAN COURT OF AUDITORS

EUROPEAN COURT OF AUDITORS
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1615 Luxembourg
LUXEMBOURG

Tel. +352 4398-1
Fax +352 4398-46410
E-mail: eca-info@eca.europa.eu
Internet: http://eca.europa.eu

Special Report No 20 

 2012

A great deal of additional information on the European Union is available on the Internet.
It can be accessed through the Europa server (http://europa.eu).

Cataloguing data can be found at the end of this publication.
Luxembourg: Publications Office of the European Union, 2012

ISBN 978-92-9241-005-6
doi:10.2865/4077

© European Union, 2012
Reproduction is authorised provided the source is acknowledged.

Printed in Luxembourg

3

CONTENTS

Paragraph

GLOSSARY

I–IV 

EXECUTIVE SUMMARY

1–13 

INTRODUCTION

1–9 

MUNICIPAL WASTE MANAGEMENT IN THE EU

10–13 

EU STRUCTURAL MEASURES CO-FINANCING OF MUNICIPAL SOLID WASTE INFRASTRUCTURES

14–19 

AUDIT SCOPE AND APPROACH

20–68 

OBSERVATIONS

20–34 

HAVE MUNICIPAL WASTE MANAGEMENT INFRASTRUCTURES BEEN SUCCESSFUL?

23–28 

29–34 

 WASTE MANAGEMENT PLANTS WERE EFFECTIVE TO VARYING DEGREES BUT THOSE RECEIVING UNSORTED 
WASTE UNDERPERFORMED

 ALMOST ALL INFRASTRUCTURES MET ENVIRONMENTAL REQUIREMENTS, BUT MORE THAN TWO THIRDS OF 
LANDFILLS LACKED THE REQUIRED FINANCIAL SECURITY FOR CLOSURE AND AFTER-CARE COSTS

35–44 

HAVE EU WASTE POLICY OBJECTIVES BEEN ACHIEVED AT REGIONAL LEVEL?

37–38 

INCONSISTENT DATA REPORTING

39 

THE GENERATION OF WASTE INCREASED IN SIX OF THE REGIONS SAMPLED

40–42 

43–44 

 ONLY ONE QUARTER OF THE REGIONS SAMPLED SIGNIFICANTLY INCREASED THEIR SEPARATE COLLECTION 
RATE, REDUCED THEIR RELIANCE ON LANDFILLING AND CONTRIBUTED TO MEETING EU TARGETS

 ILLEGAL DUMPS WERE ERADICATED IN HALF OF THE REGIONS BUT WASTE WAS GENERALLY LANDFILLED 
WITHOUT ANY PRIOR TREATMENT

45–68 

WERE MEASURES PUT IN PLACE TO MAXIMISE THE EFFECTIVENESS OF EU FUNDING?

47–54 

55–60 

 THE LEVEL OF IMPLEMENTATION OF INFORMATION, ADMINISTRATIVE AND ECONOMIC SUPPORTING MEASURES 
VARIED SIGNIFICANTLY AMONG THE REGIONS SAMPLED

 WHEN APPROVING OPERATIONAL PROGRAMMES OR PROJECTS, THE COMMISSION DID NOT ENCOURAGE THE 
IMPLEMENTATION OF SUPPORTING MEASURES

61–68 

WEAKNESSES WERE NOTED IN THE EU WASTE REGULATORY FRAMEWORK AND EU GUIDELINES

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69–77 

CONCLUSIONS AND RECOMMENDATIONS

70–72 

PERFORMANCE OF MUNICIPAL WASTE MANAGEMENT INFRASTRUCTURES

73–74 

EU WASTE POLICY OBJECTIVES AT REGIONAL LEVEL

75–77 

MEASURES PUT IN PLACE TO MAXIMISE THE EFFECTIVENESS OF EU FUNDING

ANNEX I 

—  WASTE MANAGEMENT SYSTEM FROM WASTE SOURCE TO FINAL DISPOSAL

ANNEX II  — 

STRUCTURAL MEASURES ASSISTANCE EARMARKED FOR WASTE 
MANAGEMENT PROJECTS

ANNEX III  — 

LIST OF INFRASTRUCTURES SELECTED FOR THE AUDIT

ANNEX IV  — 

RATES OF ASSISTANCE GRANTED COMPARED TO RATES THAT TAKE INTO 
ACCOUNT THE LEVEL OF COVERAGE OF OPERATING COSTS BY HOUSEHOLDS

REPLY OF THE COMMISSION

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

 
 
 
 
GLOSSARY

5

Administrative measures: In this report, measures adopted through legislation which require waste produ-
cers, waste managers and/or municipalities to observe certain requirements such as implementing a permit 
and inspection system for waste management facilities, establishing separate collection of waste at source or 
complying with quality standards in the production of compost.

Biodegradable waste: Any waste that is capable of undergoing anaerobic or aerobic decomposition, such as 
food, garden waste, paper and cardboard.

Cohesion Fund: Financial instrument designed to strengthen economic and social cohesion by financing 
envir onment and transport projects in Member States with a per capita GNP of less than 90 % of the EU 
average.

Economic measures: In this report, measures designed to provide incentives for selecting less damaging 
options for the management of waste in accordance with EU waste policy (for example recycling instead of 
landfilling). These include ‘pay as you throw’ tariffs as well as waste disposal taxes.

Effectiveness: Measure of the relationship between the results obtained and the objectives set.

European Regional Development Fund (ERDF): Financial instrument designed to promote economic and 
social cohesion between the regions of the EU. ERDF interventions are mainly implemented through oper-
ational programmes and single programming documents encompassing a large number of projects.

EU-27: The 27 Member States of the European Union.

EU-12: Member States which have joined the EU as part of the accessions of 2004 (10 Member States) and 2007 
(two Member States).

Information measures: In this report, measures concerning the provision of information intended to encour-
age good waste disposal practices on the part of the public to contribute to the effectiveness of waste man-
agement policy. Awareness-raising campaigns and educational strategies are two examples.

Instrument for Structural Policies for Pre-Accession (ISPA): Financial instrument to assist the candidate 
countries in the preparation for accession. It provides assistance for infrastructure projects in the EU priority 
fields of environment and transport. After accession, ISPA projects turned into Cohesion Fund projects.

Leachate: Any liquid percolating through the deposited waste.

Municipal waste: Waste collected by or on behalf of municipal authorities and disposed of through the waste 
management system. The bulk of this waste stream is from households, though ‘similar’ wastes from sources 
such as commerce, offices and public institutions are included. Municipal waste is composed, for example, of 
biodegradable material, paper, plastics, glass, metals, textile, etc. (source: Eurostat).

Operational programme: A document approved by the Commission, which takes the form of a coherent set 
of priorities comprising multiannual measures encompassing a large number of projects.

‘Polluter pays principle’: According to this principle, the costs of waste management shall be borne by the 
original waste producer or by the current or previous waste holders (source: waste directive).

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Programming period: The multiannual framework within which structural measures expenditure is planned 
and implemented.

Structural measures: In this report, interventions from the European Regional Development Fund (ERDF) and 
from the Cohesion Fund.

Waste disposal tax: An economic measure designed to increase the cost of landfilling and in some cases also 
of incinerating and therefore to provide an incentive to recycle. The tax, paid per tonne of waste disposed, is 
charged on top of landfill and/or incineration fees.

Waste tariff: Price charged by municipalities to households for the collection, treatment and disposal of 
waste. Waste tariffs can be calculated in different ways by municipalities (e.g. square metres of apartments or 
houses, number of persons in households, consumption of drinking water, weight or volume of waste gener-
ated, etc.).

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EXECUTIVE SUMMARY

I.
In 2010,  each  EU-27  citizen  generated  on  average 
approximately 500 kg of municipal waste, which if not 
collected, treated and disposed of properly, can cause 
negative  environmental  impacts.  However,  proper 
waste management can lead to an improvement of 
the use of resources as municipal waste is a source of 
raw materials. As a result, the EU has introduced com -
mon standards and targets in the form of directives for 
the management of municipal waste and co-finances 
waste management infrastructures in specific regions.

II.
The Court’s audit focused on EU co-financing of muni-
cipal waste management infrastructures and examined 
whether the funding was effective in helping Member 
States achieve EU waste policy objectives. The Court 
assessed  directly  the  per formance  of  26 sampled 
waste management infrastructures and reviewed the 
achievement of EU waste policy objectives as well as 
the implementation of supporting measures in the 
eight regions where the infrastructures were located. 
The role of the Commission was also examined.

III.
The Court concluded that, although in almost all the 
regions  selected  some  improvements  in  the  man-
agement of waste were observed, the effectiveness 
of structural measures funding for municipal waste 
management infrastructures was hampered by the 
poor implementation of supporting measures:

(a)  The performance of  the co-financed infrastruc-
tures was highly dependent upon waste collection 
strategies. Concerning landfills, waste was depos-
ited without adequate treatment and in general 
insufficient financial amounts were put aside to 
cover closure and after-care costs.

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EXECUTIVE SUMMARY

(b)  The reporting on the achievement of EU targets 
was hampered by the reliability of data, making 
monitoring by the Commission difficult. Although 
in almost all regions some improvements in waste 
management  were  obser ved,  per  capita  waste 
generation increased in six of the eight regions 
audited.  In  the  two  regions  which  contributed 
to the achievement of EU targets, biodegradable 
waste was collected separately and landfill taxes 
more widely implemented resulting in a reduction 
of the reliance on landfilling. Waste was generally 
landfilled without adequate treatment.

(c)  The  effectiveness  of  EU  funding  was  not  maxi-
mised due to the weak implementation of sup-
porting informative, administrative and  economic 
measures. The implementation of these support-
ing  measures was  not a condition for  receiving 
an EU grant. Weaknesses were also noted in the 
EU waste regulatory framework and EU guidelines.

IV.
The Court recommends that:

(a)  Member States should focus on waste manage -
ment  infrastructures  treating  waste  previously 
segregated  at  source  and  ensure  that  landfills 
treat waste before disposal and possess a suffi -
cient financial security to cover closure and after-
care  costs. The  Commission  should  request  the 
implementation of these recommendations from 
the Member States before granting EU financial 
support.

(b)  Member States should set up reliable and com-
plete  waste  management  databases  and  the 
 Commission  should  test  the  reliability  of  the 
statistics received from the Member States. The 
Commission,  the  Parliament  and  the  Council 
should consider  linking  EU financial  support to 
the achievement of EU waste policy objectives.

(c)  Member  States  should  implement  information, 
administrative  and  economic  measures  to  sup-
port the co-financed infrastructures. In particu-
lar, Member States should pay greater attention 
to public participation and adherence, focus on 
separate collection implementation including bio-
degradable waste when cost effective and imple-
ment a landfill tax as well as incentives via tariff 
to  encourage  waste  prevention  and  recycling. 
The Commission should request the implementa-
tion of these recommendations from the Member 
States before granting EU financial support; re-
duced rates of assistance should be applied when 
the ‘polluter pays principle’ is not applied.

(d)  The  Commission  should  improve  the  EU  waste 
regulatory framework and EU guidelines. In par-
ticular,  the  Commission  should  propose  waste 
prevention targets, clarify the concept of treat-
ment before disposal, consider the opportunity to 
develop with Member States EU quality standards 
for  compost  and  provide  appropriate  guidance 
and disseminate best practices in relation to the 
methodology to be used to estimate closure and 
after-care costs of landfills.

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

INTRODUCTION

9

1. 

2. 

MUNICIPAL WASTE MANAGEMENT IN THE EU

European society has grown wealthier over the last decade, with in-
creased levels of consumption and production. In 2010, each EU citizen 
generated on average 502 kg of municipal waste, ranging from 304 kg 
in Latvia to 760 kg in Cyprus (see  Figure 1 ).

Municipal waste, if not collected, treated and disposed of properly, is 
a threat to public health and can cause negative environmental impacts 
on air (by means of greenhouse gases), soil (via leachates due to illegal 
dumping or poorly controlled landfills) and water (through water coming 
into contact with waste and entering aquifers or surface water), as well 
as problems with odours.

FIGURE 1

PER CAPITA MUNICIPAL WASTE GENERATION IN 2010 BY MEMBER STATE

(in kg/capita)

800
700
600
500
400
300
200
100
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Source: Eurostat.

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Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

 
 
10

3. 

4. 

Proper waste management can lead to an improvement in the use of 
resources as municipal waste can be a source of raw materials. Paper, 
cardboard, metals, glass and plastic can be recycled, and biodegradable 
waste transformed into nutrient-rich compost to be used in agriculture 
as a soil improver. What remains can be incinerated (energy recovery) 
or disposed of in landfill.

A diagram  of the main elements of  municipal waste  management is 
provided in Annex I. The following types of infrastructures, together with 
the collection of waste (separate or non-segregated at source), make up 
the typical municipal waste management system:

(a) 

sorting plant: a facility intended to segregate recyclables such as 
paper and cardboard, glass, packaging and metals, through manual 
sorting belts and/or automatic processes such as air flow or optical 
separators;

(b)  composting and anaerobic digestion plants: facilities designed to 
treat biodegradable waste. Composting plants perform an aerobic 
biological process to convert biodegradable waste into a stable 
granular material which can be applied to land as soil improver 
whereas anaerobic digestion plants apply chemicals to aid the de-
composition process. Here, in the absence of air, bacteria acts on 
biodegradable waste to convert it into a digest and methane-rich 
biogas to be used to produce energy;

(c)  mechanical biological treatment plant: a facility combining sort -
ing  with  a form  of  biological  treatment  such  as  composting  or 
anaerobic digestion. The mechanical treatment stage separates 
the biodegradable and dry parts of the waste and in some cases 
segregates recyclables. Then the biodegradable matter undergoes 
a biological treatment;

(d) 

(e) 

incinerator: a plant intended to burn waste with or without energy 
recovery;

landfill: a site for the disposal of waste materials which are depos -
ited into or on to land.

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11

5. 

6. 

Landfilling remains the dominant waste management option in most EU 
Member States, even if energy recovery and especially recycling have 
gained importance in recent years (see Figure 2 ).

In order to reduce the negative impact of municipal waste on the en-
vironment and public health and to promote a more efficient use of 
resources, the EU has introduced general principles and common stand-
ards and targets in the form of directives, for the management of mu-
nicipal waste.

FIGURE 2

MUNICIPAL WASTE TREATMENT IN 2010 BY MEMBER STATE

100 %
90 %
80 %
70 %
60 %
50 %
40 %
30 %
20 %
10 %
0 %

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Incineration

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Source: Eurostat.

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

 
 
7. 

8. 

The  framework  of  EU  waste  policy  was  established  in  the  directive 
of 15 July 1975 1. According to this directive, EU waste policy is based on 
the promotion of prevention, re-use and recycling of waste. If waste gen-
eration cannot be prevented, as many of the materials as possible should 
be recovered, preferably by recycling, with landfill only used as a last 
resort. It also introduced the ‘polluter pays principle’. The 2008 waste 
directive2 further developed these principles by establishing a compul -
sory five-step waste hierarchy pyramid (see Figure 3 ).

The waste directive was complemented by a number of specific direc -
tives for waste treatment operations (landfilling 3 and incineration 4) or 
specific waste streams, such as packaging 5 or electrical and electronic 
equipment6. These directives set quantitative targets to be met by Mem-
ber States in terms of percentage of biodegradable waste diversion from 
landfill, packaging recycling and recovery rates and separate collection 
of electrical and electronic equipment waste. Deadlines to comply with 
targets were extended for some Member States to take into account 
their starting situation in terms of waste management (see Table 1 ).

FIGURE 3

WASTE HIERARCHY PYRAMID

12

1  Council Directive 
75/442/EEC of 15 July 1975 
on waste (OJ L 194, 
25.7.1975, p. 39), amended 
in 1991 by Council Directive 
91/156/EEC of 18 March 1991 
(OJ L 78, 26.3.1991, p. 32) and 
subsequently codified by 
Directive 2006/12/EC of the 
European Parliament and of 
the Council of 5 April 2006 
(OJ L 114, 27.4.2006, p. 9), 
which was repealed by 
Directive 2008/98/EC of 
the European Parliament 
and of the Council of 
19 November 2008 (OJ L 312, 
22.11.2008, p. 3).

2  Directive 2008/98/EC.

3  Council Directive 
1999/31/EC of 26 April 1999 
on the landfill of waste 
(OJ L 182, 16.7.1999, p. 1).

4  Directive 2000/76/EC of 
the European Parliament 
and of the Council of 
4 December 2000 on 
the incineration of waste 
(OJ L 332, 28.12.2000, p. 91), 
repealed by Directive 
2010/75/EU of the European 
Parliament and of the Council 
of 24 November 2010 on 
industrial emissions (OJ L 334, 
17.12.2010, p. 17).

5  European Parliament and 
Council Directive 94/62/EC 
of 20 December 1994 on 
packaging and packaging 
waste (OJ L 365, 31.12.1994, 
p. 10), amended by Directive 
2004/12/EC of the European 
Parliament and of the Council 
of 11 February 2004 (OJ L 47, 
18.2.2004, p. 26) and by 
Directive 2005/20/EC of the 
European Parliament and of 
the Council of 9 March 2005 
(OJ L 70, 16.3.2005, p. 17).

Source: European Court of Auditors.

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

Disposal P r e v e n t i o nR e - u s eR e c y c l i n gR e c o v e r y9. 

The effectiveness of waste management policy can be improved through 
supporting measures such as the running of information and awareness 
campaigns, the redesigning of administrative procedures or the put-
ting in place of financial incentives or disincentives. Sometimes these 
are required by regulation, such as the need to adequately inform con-
sumers, but in other cases, they are the result of experience gained in 
the management of municipal waste, such as the implementation of 
a waste disposal tax or the separate collection of biodegradable waste.

13

6  Directive 2002/96/EC of 
the European Parliament 
and of the Council of 
27 January 2003 on waste 
electrical and electronic 
equipment (OJ L 37, 
13.2.2003, p. 24), amended by 
Directive 2003/108/EC of the 
European Parliament and of 
the Council of 8 December 
2003 (OJ L 345, 31.12.2003, 
p. 106) and by Directive 
2008/34/EC of the European 
Parliament and of the Council 
of 11 March 2008 (OJ L 81, 
20.3.2008, p. 65). This directive 
was recast by Directive 
2012/19/EU of the European 
Parliament and of the Council 
of 4 July 2012 on waste 
electrical and electronic 
equipment (WEEE) (OJ L 197, 
24.7.2012, p. 38).

TABLE 1

TARGETS TO BE MET BY MEMBER STATES

Directives

Landfill directive

Packaging directive

Targets

General target: Biodegradable municipal waste going to landfills must be reduced to 75 %, 50 % 
and 35 % of the total amount of biodegradable municipal waste produced in 1995, by the end of 2006, 
2009 and 2016 respectively.

Specific target for Portugal and Romania: Deadlines are the end of 2010, 2013 and 2020 respectively.

General target: By the end of 2008, 60 % as a minimum by weight of packaging waste must be  
recovered and between 55 % as a minimum and 80 % as a maximum recycled. Moreover, the  
following minimum recycling targets for materials contained in packaging waste must be attained: 
60 % by weight for glass, 60 % by weight for paper and cardboard, 50 % by weight for metals,  
22,5 % by weight for plastics and 15 % by weight for wood.

Specific target for Portugal: By the end of 2005 the recovery of packaging waste should  
reach 50–65 %, and 25–45 % by weight of the totality of packaging materials contained in  
packaging waste should be recycled (with a minimum of 15 % by weight for each packaging  
material). The 2008 general target should be achieved by 2011.

Specific target for Romania: The 2008 general target must be met by 2013 with intermediate targets.

Electrical and electronic  
equipment waste directive

A rate of separate collection of at least 4 kg on average per inhabitant per year of electrical  
and electronic equipment waste from private households must be achieved by the end of 2006.

Specific target for Romania: A rate of separate collection of at least 2, 3 and 4 kg on average per 
 inhabitant per year of electrical and electronic equipment waste from private  
households must be achieved by the end of 2006, 2007 and 2008 respectively.

Source: EU waste directives. 

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7  Article 17(1) TEU and 
Article 317 of the TFEU.

8  From 1 January 2007 to 
25 June 2010 the amount was 
25 million euro in the case of 
the environment.

9  Another directorate-
general, Eurostat, is 
responsible for coordinating 
the European Statistical 
System and providing 
relevant statistics to other 
Commission services. The DG 
is the main provider of waste 
statistics of which the main 
user is DG Environment.

10  During the 2000–06 
programming period DG 
Environment was also 
consulted by the regional 
policy DG in the case of 
Cohesion Fund project 
applications.

10. 

11. 

EU STRUCTURAL MEASURES CO-FINANCING OF 
MUNICIPAL SOLID WASTE INFRASTRUCTURES

In specific regions, Member States may request EU financial support for 
infrastructures in the field of municipal waste management through the 
European Regional Development Fund (ERDF) and the Cohesion Fund 
(CF). During the 2000–06 programming period, 4,6 billion euro was ear -
marked from these funds for urban and industrial waste infrastructures. 
For the 2007–13 period, the EU contribution to waste infrastructures will 
increase to 6,2 billion euro, of which around 70 % will be in the EU-12 
Member States. EU earmarked amounts by Member State for both pro-
gramming periods are provided in Annex II.

Co-financed infrastructures are implemented under shared management, 
with the Commission bearing the ultimate responsibility for the imple-
mentation of the EU budget7. During the 2000–06 programming period, 
in addition to the approval of operational programmes, the Commission 
approved the applications submitted by Member States for all Cohesion 
Fund projects and for ERDF projects whose total cost exceeded 50 mil -
lion euro (major projects). For the 2007–13 programming period, apart 
from the approval of programmes, only projects which have a cost in 
excess of 50 million euro have to be approved by the Commission 8.

12. 

Two directorates-general of the Commission9 have a significant role in 
the area of municipal waste:

(a)  DG Environment is responsible for EU environmental policy in the 
field of waste management. It is required to monitor the imple-
mentation of the related legislation (such as the achievement of 
specific targets) and is consulted by DG Regional and Urban Policy 
when examining the quality of operational programme proposals 
and major projects10;

(b)  DG Regional and Urban Policy is responsible for the EU budget in 
the area of regional policy, under which waste management infra-
structure projects can be co-financed.

13. 

During the 2000–06 programming period, structural measures mainly co-
financed the following types of waste management infrastructures: sort-
ing plants (see Picture 1 ), composting and anaerobic digestion plants 
(see Picture 2), mechanical biological treatment facilities, separate col-
lection systems and landfills (both the construction of new ones and 
the closure and rehabilitation of old ones) (see Picture 3 ). These types 
of infrastructure are expected to contribute to the achievement of EU 
waste policy objectives of diverting biodegradable waste from landfills 
and increasing recycling rates (see Box 1 ).

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BOX 1

EXAMPLES OF WASTE MANAGEMENT INFRASTRUCTURES CO-FINANCED BY THE EU

A sorting plant in Portugal (Resitejo), with a capacity of 9 000 tonnes per year, aimed at recuperating packag -
ing waste and paper and glass previously segregated at source in a group of municipalities. The recyclable 
materials, sorted manually, were sold to recycling operators and residual waste was conveyed to an adjacent 
landfill site. The cost of the project eligible for EU assistance was 2,28 million euro, with 1,71 million euro of 
ERDF co-financing.

In Romania, a composting plant (Râmnicu Vâlcea) intended to treat biodegradable waste collected separately 
from households as well as green waste from municipal parks and to transform it into compost. With a capacity 
to treat  14  400  tonnes of waste per year, the plant was designed to contribute to the diversion of biodegrad-
able waste from landfills in line with the landfill directive targets. The infrastructure was part of an integrated 
waste management project costing 14,67 million euro for which EU assistance amounted to 11 million euro.

A project in Spain (Alt Empordà) consisted of the enlargement of a landfill with a capacity of 1 167 603 m 3 as 
well as of the improvement of the existing cells in terms of gas and leachate collection and treatment in order 
to reduce the environmental impact of the site. The cost of the project was 5,71 million euro, 4,57 million euro 
of which came from the Cohesion Fund.

Picture 2 — Composting plant

Picture 1 — Sorting plant

Picture 3 — Landfill

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11  EU waste directives set 
objectives and targets at 
Member State level. However, 
as, in general, regions are 
responsible for establishing 
waste management 
plans and as they have 
received EU financial 
support for infrastructures 
in the field of municipal 
waste management, 
their contribution to the 
achievement of EU objectives 
and targets has been 
assessed in the framework of 
this audit.

12  Fifteen waste management 
infrastructures benefited 
from Cohesion Fund financial 
support (including five 
ex- ISPA facilities launched 
in Romania when the 
country was in the process of 
becoming a Member State). 
The grant was approved by 
the Commission. Eleven were 
ERDF projects contained in 
operational programmes and 
approved by the responsible 
managing authorities.

AUDIT SCOPE AND APPROACH

16

14. 

The main objective of the audit was to assess the effectiveness of struc-
tural measures funding of municipal waste management infrastructures 
in helping Member States achieve EU waste policy objectives.

15. 

The Court addressed the following three questions:

(a)  Have municipal waste management infrastructures been successful?

(b)  Have EU waste policy objectives been achieved at regional level11?

(c)  Were measures put in place to maximise the effectiveness of EU 

funding?

16. 

17. 

Assessment criteria used for the audit are explained further in the report, 
under each question (see paragraphs 20,  21,  35  and  45). As is usually 
the case in performance audit, they take into account examples of good 
practice observed in the domain (see paragraph 9).

The  audit  was  carried  out  at  the  European  Commission  and  in  eight 
regions in four Member States (Spain, Italy, Portugal and Romania). The 
sample of infrastructures audited focused on Member States and regions 
receiving a high-level EU financial support for waste management during 
the 2000–06 and 2007–13 programming periods and where a sufficient 
number of completed projects were available at the time of the audit, 
so that their effectiveness could be assessed.  Annex III contains the 
list of infrastructures audited as well as of the operational programmes 
reviewed.

18. 

The audit was based on an assessment of:

(a) 

the performance of a sample of 26 waste management infrastruc -
tures co-financed during the 2000–06 programming period 12: five 
sorting facilities, seven composting or anaerobic digestion plants, 
seven mechanical biological treatment plants and seven landfills;

(b) 

the achievement of EU municipal solid waste objectives in the eight 
regions audited;

(c) 

the implementation in the regions sampled of supporting measures 
as well as of the role of the Commission to maximise the effective-
ness of EU funding.

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19. 

The audit was conducted between January and November 2011. Project 
files were reviewed at the Commission and in the four Member States 
sampled and interviews were held with Commission staff, Member State 
authorities and infrastructure operators. All the waste management in-
frastructures in the sample were visited during the course of the audit. 
The Court was assisted by external independent experts knowledgeable 
in the field of municipal waste management. Audit criteria were estab-
lished with the assistance of external experts and discussed with the 
Commission when planning the audit.

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OBSERVATIONS

18

20. 

21. 

HAVE MUNICIPAL WASTE MANAGEMENT 
INFRASTRUCTURES BEEN SUCCESSFUL?

The performance of the co-financed infrastructures should be in line with 
their technical design, the funding application and generally accepted 
standards.

13  Ratio indicating the 
proportion between the 
tonnes of waste treated in 
the plant and the tonnes of 
materials recovered.

According to the waste directive, waste management infrastructures 
have to be designed and operated to guarantee that waste is treated 
and disposed of without risk to water, air and soil and without causing 
noise or odour problems. In addition, the landfill directive requires the 
setting-up of a financial security to cover closure and after-care costs for 
a  period of at least 30  years, as potential environmental threats extend 
after the operational phase.

22. 

The Court examined whether:

(a) 

co-financed municipal waste management infrastructures were 
 effective, in terms of the achievement of the expected results;

(b) 

the operation of co-financed municipal waste management infra-
structures had caused environmental problems.

WASTE MANAGEMENT PLANTS WERE EFFECTIVE TO VARYING DEGREES 
BUT THOSE RECEIVING UNSORTED WASTE UNDERPERFORMED

SORTING PLANTS

23. 

The five sorting plants reviewed by the Court, which were designed to 
recuperate packaging waste (and in some cases paper and glass) seg-
regated at source by households, generally performed satisfactorily in 
relation to their technical design and to generally acceptable standards 
in terms of ratio input/output13 and quality of the materials recovered:

(a) 

they recovered between 50 % and 74 % of the packaging waste 
received;

(b) 

the quality of the materials recovered was usually in line with mar-
ket specifications and therefore was saleable.

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24. 

However, three of the five sorting plants were operating at between 
106 % and 154 % of their design capacity after 6 or 7 years of operation 
due to weaknesses at the planning stage of the infrastructures. In one 
case more municipalities than initially planned were served by the plant 
and in two cases the quantity of waste collected separately at source ex-
ceeded the forecast. Overloading results in the risk of reducing the ratio 
of materials recovered as well as of not meeting the quality standards 
for recovered materials required by recycling companies.

COMPOSTING AND ANAEROBIC DIGESTION PLANTS

25. 

The performance of the seven composting or anaerobic digestion plants, 
intended to treat biodegradable waste producing compost, varied. The 
Court noted that:

(a) 

(b) 

the quantity of compost produced compared to the tonnage of 
municipal waste entering the facilities was below the design tar-
get in four of the selected plants (the ratio input/output ranged in 
those plants from 1 % to 22 %) resulting in significant quantities of 
residual waste being landfilled;

in two plants, the quality of the compost produced was below the 
objectives set in the applications, especially when it resulted from 
mixed waste, as a result of the high content of heavy metals, there -
fore reducing its suitability for other usages, such as agriculture. In 
a third plant the operator only tested the content of heavy metals 
during the first year of operation and not in the following 4 years;

BOX 2

AN EXAMPLE OF HOW COMPOST CAN SUCCESSFULLY BE MARKETED

A Portuguese composting plant (LIPOR), serving approximately 1 million inhabitants, received only separately 
collected biodegradable waste, whether food and kitchen or green waste. The operator of the plant, through 
actions such as the development of awareness campaigns, focused on the appropriate sorting and collection of 
biodegradable waste in order to improve the quality of the raw material going into compost. In 2010, the plant 
produced 10 027 tonnes of high-quality compost, which was easily marketed at an average price of 71,8 euro 
per tonne.

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(c) 

(d) 

the  compost  produced  was  difficult  to  sell  in  five  of  the  seven 
facilities sampled due to the lack of development of the compost 
market14 and its poor quality. The compost was eventually disposed 
of for less than 1 euro per tonne. In two cases, stocks were accumu-
lated despite production being significantly below target;

two plants were operating at a rate below 10 % of their capacity 
as most biodegradable waste collected separately was unusable 
because it was mixed with other types of waste and had to be dir-
ectly landfilled. In contrast, two other plants were overloaded as 
they were operating at 102 % and 119 % of capacity.

14  An adequate compost 
market would imply the 
existence of compost quality 
standards, the indication of 
potential appropriate usages 
and the implementation 
of awareness campaigns 
intended to promote 
compost utilisation.

26. 

27. 

MECHANICAL BIOLOGICAL TREATMENT PLANTS

Six audited mechanical biological treatment plants were operational; 
however, a seventh, located in Puglia, for which the works were com -
pleted  in 2003  was  not  in  operation  at  the  time  of  the  audit  due  to 
significant problems in the awarding of the contract for the operation 
and in delays in obtaining the necessary permits. During this period 
since 2003, the plant has been kept under conservative maintenance at 
a cost of 3,5 million euro (or 24 % of the total investment cost) supported 
by the Member State.

Five of the six operational mechanical biological treatment plants audit-
ed, were intended to treat mixed waste (including biodegradable waste). 
The Court noted a very low performance in terms of recovered mater -
ials and waste diversion from landfill. In terms of performance these six 
mech anical biological treatment plants can be divided into three groups:

(a)  one mechanical biological treatment plant clearly contributed to 
the achievement of EU waste policy objectives and particularly to 
landfill diversion, even if not fully achieving the targets set in its 
technical design (see Box 3 );

(b)  another mechanical biological treatment plant had a mixed level of 
performance. It succeeded in sending the dry part of the waste to 
an external plant to produce refuse-derived fuel and less than 50 % 
of the waste entering the plant was landfilled. However, with the 
exception of a small amount of metals recovery, no other mater  ial 
recovery was carried out, and biodegradable waste was not recy-
cled as all the digest resulting from the process was landfilled;

(c) 

four mechanical biological treatment plants did not significantly 
reduce the quantity of waste landfilled (see Box 4 ).

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EXAMPLE OF ONE MECHANICAL BIOLOGICAL TREATMENT PLANT IN LINE WITH EU 
WASTE HIERARCHY AND WASTE DIVERSION FROM LANDFILL

One mechanical biological treatment plant in Spain (Sant Adrià de Besòs) received only residual waste, as 
packaging, glass, paper and cardboard, and biodegradable waste were previously separately collected through 
dedicated bins available for the entire population of the area covered by the facility. The plant separated the 
dry fraction from the biowaste. The remaining dry fraction, following the recovery of materials suitable for sale 
to reprocessors, such as glass, plastics, metals and paper and cardboard, was incinerated and energy recovered 
in a facility within the same waste management complex. Biowaste was subject to an anaerobic treatment to 
produce biogas which was then used as a source of energy. As a result of the process, in 2010, materials recovery 
amounted to 8 % of residual waste entering the plant compared to 10 % set in the application, biodegradable 
matter for biological treatment to 20 % compared to 26,5 % planned and residual waste for incineration to 70 % 
compared to 63,5 %.

BOX 3

BOX 4

FOUR MECHANICAL BIOLOGICAL TREATMENT PLANTS NOT ACHIEVING THEIR TARGETS 
AND NOT CONTRIBUTING TO WASTE DIVERSION FROM LANDFILLS

In three Italian mechanical biological treatment facilities ( Villacidro, Olbia and Cerignola) the operator entirely 
landfilled the outputs from the process: the dry fraction with no material recovery as well as the digest produced, 
amounting in total to 68 %, 82 % and 93 % of the waste entering the respective facilities. Only process losses 
(such as evaporation or leachate generation) reduced the quantity of waste landfilled. In two of the plants the 
co-financed machinery for refuse-derived fuel production was in one case not put into operation and in the 
other was dismantled as a result of the lack of potential buyers for the fuel. The mechanical sorting unit of the 
third plant was not in use 6 years after the plant entered into operation, as it was no longer required, since 
biodegradable waste was collected separately at source.

Moreover, the three plants were overloaded and as a result 13 %, 52 % and 65 % respectively of the waste re -
ceived by the facilities was not treated at all and directly landfilled with a high content of biodegradable matter, 
as biodegradable waste was not collected separately in two cases.

The fourth plant within this group (Linares, Spain) had implemented the recovery of materials and did not 
landfill the compost produced, which was used in civil works and in agriculture. However, recovery targets were 
not met: only between 6 % and 9 % of biodegradable waste and 4 % of recoverable materials were recovered 
compared to a target of 25 % to 28 % and 7 % to 8 % respectively. As a result 85 % of waste entering the plant 
was landfilled with a  high content of biodegradable matter. The resulting compost produced was difficult to 
sell and approximately 50 % of total production of the plant was stockpiled at the time of the audit.

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LANDFILLS

28. 

Regarding the seven selected landfill sites, the Court noted that the 
quantity of biodegradable waste landfilled ranged from 31  % to 55 % 
of total waste landfilled as a result of a failure to effectively treat such 
waste:

(a)  waste was landfilled without any treatment in five of the seven 
landfills reviewed. Even if, in three of these five landfill sites bio-
degradable  waste  was  collected  separately,  in  two  cases  more 
than 90 % of biodegradable waste was contaminated with non-
biodegradable waste and as a result directly landfilled;

(b)  waste deposited in the remaining two selected landfills was treated 
in mechanical biological treatment plants prior to disposal. How-
ever, the two treatment facilities did not perform satisfactorily. One 
of the plants was overloaded (52 % of the waste received was dir -
ectly sent to landfill without treatment). The second one did not 
reach the biodegradable waste recovery target set in its technical 
design and, as a result, waste was landfilled with a  high content of 
biodegradable matter (see Box 4 ).

ALMOST ALL INFRASTRUCTURES MET ENVIRONMENTAL REQUIREMENTS, 
BUT MORE THAN TWO THIRDS OF LANDFILLS LACKED THE REQUIRED 
FINANCIAL SECURITY FOR CLOSURE AND AFTER-CARE COSTS

29. 

For 25 of the 26 waste management infrastructures selected, the Court’s 
review of data indicated that environmental impacts on air, water and 
soil were generally monitored. Projects complied in most cases with their 
respective permits. One plant was not yet in operation at the time of the 
audit (see paragraph 26).

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30. 

31. 

However, at the time of the audit, in two of the seven selected landfills, 
gas resulting from the decomposition of biodegradable waste deposited 
was not collected and treated or flared, as required by the landfill direc-
tive (see Box 5 ). Uncontrolled landfill gas can pollute the atmosphere, 
affect vegetation and cause explosions.

The Court also noted problems regarding the applicable limits for odour 
emissions set out in the national environmental permits in one third of 
the infrastructures, at least during certain periods of their operation. 
A lack of monitoring with regard to odours was noted in another third of 
the selected infrastructures. Two of the plants failing to monitor odour 
levels were at the same time in receipt of EU co-financing for comple -
mentary works to deal with odour problems.

BOX 5

TWO LANDFILLS LACKED GAS COLLECTION AND TREATMENT OR FLARING

In one of the landfills in Italy (Cavallino), waste was being deposited for 3 years and at the time of the audit 
the utilisation rate was approximately 70 %. The gas generated as a result of the decomposition of biodegrad -
able matter was being released into the atmosphere without being treated or flared as the construction of the 
infrastructure for gas collection had not been completed.

In a  landfill in Romania (Piatra Neamt), almost 2 years after starting operation, the Court noted that no landfill 
gas collection system was either in place, under construction or being planned.

These two landfills received a significant amount of biodegradable waste as a result of a lack of or deficient 
treatment prior to disposal, which made the collection and treatment or flaring of gas even more relevant in 
order to safeguard the atmosphere.

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32. 

33. 

However, half of the infrastructures which had problems with odour 
management did not change their operational processes or make com-
plementary investments to solve such problems (see Box 6 ).

The potential impacts on the environment resulting from the operation 
of landfill sites are not limited to the operational period of the infra-
structure, as potential leachate infiltrations and landfill gas emissions 
last for decades after waste disposal has finished. For this reason, the 
landfill directive requires the setting aside of amounts to cover closure 
and after-care costs for a period of at least 30 years. However, five of 
the seven selected landfills lacked a sufficient financial security for this 
purpose. In these cases, the amounts actually deposited, regardless of 
the methodology for their calculation, are not sufficient to ensure that 
appropriate funding will be available, once landfills cease operation, to 
prevent long-term threats to the environment such as the pollution of 
groundwater by leachate infiltration into the soil or the pollution of the 
atmosphere by landfill gas emissions.

BOX 6

EXAMPLES OF WAYS TO DIMINISH ODOUR PROBLEMS

In two composting/anaerobic digestion plants ( Valorsul, Portugal and Gironés, Spain) odour problems were 
noted by independent monitoring. To tackle this situation the operators implemented changes in the oper ation 
process, such as modifying the schedule and timing of the turning of the compost, or in the maintenance of, for 
example, the biofilters. A reporting system was implemented in one of the plants to allow residents to complain 
of unpleasant odours by SMS to the operator.

In two of the landfills in Portugal (Residouro and Baixo Tâmega) complaints about odour problems were reg-
istered during the first years of operation. Deodorant emission systems were installed which were activated 
when necessary.

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34. 

The Court also noted significant differences in the methodologies in 
place in the regions to determine the amount of the financial secur-
ity,  resulting  in  ver y  different  amounts  (ranging  from 370 000 euro 
to 4 180 000 euro for a landfill with a capacity about 1,4 million m 3). 
These methodologies do not provide satisfactory assurance that suf-
ficient funding will be available to cover closure and after-care costs for 
a  per iod of 30 years. In some cases the financial security was determined 
by the cost of the landfill infrastructure, whereas in others the amount 
was set taking into account the capacity of the landfill, its surface or the 
tonnes deposited.

HAVE EU WASTE POLICY OBJECTIVES BEEN 
ACHIEVED AT REGIONAL LEVEL?

35. 

Structural measures funding for municipal waste infrastructures should 
help the beneficiary regions to meet the waste policy objectives set 
in EU directives. In particular, municipal waste prevention should be 
encouraged, regions should be increasing their separate collection rate 
so that they can contribute to achieving EU targets 11 for recycling and 
recovery, and the reliance on final disposal in landfills should be reduced.

36. 

The Court examined whether:

(a) 

(b) 

the situation regarding the prevention of municipal waste was im-
proving in the regions sampled;

regions had increased their separate collection rate, contributed 
to meeting EU targets for specific waste streams and reduced their 
reliance on landfilling;

(c) 

illegal dumps had been eradicated and waste was being pre-treated 
before disposal in landfills.

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INCONSISTENT DATA REPORTING

Following  its  visits  to  eight  regions  in  the  four  Member  States  sam-
pled, the Court noted some inconsistencies regarding the reporting of 
the achievement of EU targets. Data reported to the Commission could 
not always be reconciled with the figures available in Member States. 
Such inconsistencies can make it difficult for the Commission to assess 
whether EU waste targets are actually being achieved (see Box 7 ). The 
Commission checks the consistency of figures received, but does not 
assess their reliability.

Moreover, the Commission does not compile information on the contri-
bution of the regions to achieving EU targets despite the fact that, in six 
of the eight regions visited, waste management plans which take into 
account EU targets are prepared at regional level. Reporting at national 
level can mask major disparities in waste management performance 
within a Member State, as was the case for Andalucía and Puglia when 
compared with the overall situation in Spain and Italy respectively.

37. 

38. 

BOX 7

EXAMPLES OF CASES WHERE IT WAS NOT POSSIBLE TO RECONCILE DATA IN MEMBER 
STATES WITH DATA REPORTED TO THE COMMISSION

In Spain, in relation to the achievement of the landfill directive target, the Ministry of the Environment is re-
sponsible for consolidating the data from the regions and reporting to the Commission. Andalucía reported, the 
quantity of biodegradable waste landfilled in 2009 as being 500 000 tonnes, whereas based on data obtained 
during the audit the Court estimated that the quantity should have been approximately  1  800  000  tonnes. As 
a result, in 2009 Spain landfilled 58 % of the biodegradable waste produced in 1995, and not 47 % as reported 
to the Commission, and failed to meet the landfill target for the year set at 50 %.

In Portugal, where no data were available at regional level on the achievement of the targets set in EU directives, 
data reported at national level to the Commission showed compliance with the landfill directive for 2006 as well 
as with the packaging directive for 2005. However, data obtained during the audit indicated that the landfill 
directive target for 2006 was narrowly missed and that the packaging directive targets for 2005 were missed in 
respect of the recycling of plastic packaging (by 46,95 %).

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39. 

40. 

THE GENERATION OF WASTE INCREASED IN SIX OF THE REGIONS 
SAMPLED

Contrary to the trend observed for the EU-27 average, which shows that 
despite continuous economic growth until 2008 municipal waste genera -
tion has stabilised at around 520 kg/capita, since 2000 per capita waste 
generation increased in six of the regions sampled. In the two remaining 
regions, Sardinia and Catalonia, it stabilised. In 2009 the per capita waste 
generation in half of the regions sampled exceeded the EU-27 average 
as well as the average of the respective Member State, while this was 
not the case in 2000 for any of the regions sampled.

15  The analysis of the 
results achieved by the 
region Sud-Vest in Romania 
is influenced by the lack 
of reliability of waste 
management databases 
available in the Member 
State, especially in relation to 
the separate collection rate.

ONLY ONE QUARTER OF THE REGIONS SAMPLED SIGNIFICANTLY 
INCREASED THEIR SEPARATE COLLECTION RATE, REDUCED THEIR 
RELIANCE ON LANDFILLING AND CONTRIBUTED TO MEETING EU 
TARGETS

Only two of the regions selected, Sardinia and Catalonia, made significant 
progress with separate collection and diversion from landfill. The Court 
noted an increase in the separate collection rate for Sardinia from 2 % 
in 2000 to 43 % in 2009 and for Catalonia from  13 % to  38 % over the 
same period. There was also a resulting decrease in municipal waste 
landfilling over the same period from 74 % to 23 % for Sardinia and from 
64 % to 39 % for Catalonia (see  Figure 4 )15.

41. 

In these two regions a reduction of waste landfilled in kilograms per 
capita was observed, whereas this indicator remained almost stable or 
increased in the other six regions sampled (see Figure 5 ).

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FIGURE 4

EVOLUTION OF MUNICIPAL WASTE SEPARATE COLLECTION AND LANDFILL 
RATES IN THE REGIONS SAMPLED BETWEEN 2000 AND  20091

60

40

20

0

-20

-40

-60

ES-Catalonia

IT-Sardinia

IT-Puglia

ES-Andalucía

PT-Norte

PT-LVT

RO-Nord-Est

RO-Sud-Vest

Evolution separate collection rate 

Evolution landfill rate

1 

 For the region Nord-Est in Romania the landfill rate covers waste collected for the period 2003   –09 and the separate collection 2004–09; 
for Andalucía the separate collection rate refers to the period 2002–08; and for the region Sud-Vest the landfill of waste collected and 
separate collection rates correspond to the period 2006–09.

Source: European Court of Auditors based on data available at Commission and Member State levels.

FIGURE 5

WASTE LANDFILLED PER CAPITA (KG) IN 2000 AND  20091

)
g
k
(
a
t
i
p
a
c

r
e
p
d
e
l
l

fi
d
n
a
l
e
t
s
a
W

600

500

400

300

200

100

0

ES-Catalonia

IT-Sardinia

IT-Puglia

ES-Andalucía

PT-Norte

PT-LVT

RO-Nord-Est

RO-Sud-Vest

Year 2000

Year 2009

1  For the region RO-Nord-Est data refer to 2003 and 2009 and for RO-Sud-Vest to 2007 and 2009.

Source: European Court of Auditors based on data available at Commission and Member State levels.

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42. 

The same regions, Sardinia and Catalonia, are the only ones which con-
tributed to achieving EU targets for specific types of municipal waste:

16  For Portugal only data at 
national level were available.

(a) 

in terms of diversion of biodegradable waste from landfills, only 
Sardinia and Catalonia contributed to meeting the landfill direc-
tive targets. Two other regions did not contribute to meeting the 
EU targets; and for four others the deadline to achieve the target 
was 2010. Data for 2010 was not available at the time of the audit, 
but the trend in years prior to 2010 did not show an increase of 
biodegradable waste diversion16 (see Table 2 );

17  ES-Andalucía, RO-Nord-Est 
and RO-Sud-Vest. Regarding 
the two regions sampled in 
Portugal, Lisboa e Vale do 
Tejo and Norte, data were 
not available at regional level. 
However, the target was not 
met by the Member State as 
a whole.

(b)  concerning packaging directive targets, the situation noted in the 
eight regions varied significantly. Catalonia, Sardinia and Andalucía 
contributed to achieving EU targets. In the five other regions, no 
specific monitoring was carried out at regional level. The Court es-
timated, based on data obtained in the Member States, that these 
regions were unlikely to contribute to achieving EU targets due to 
the low separate collection rate;

(c) 

five of the eight regions sampled17 did not contribute to achieving 
the EU target for separate collection of electrical and electronic 
equipment to be achieved in  2006  in accordance to the electrical 
and electronic equipment waste directive, even if in general a posi -
tive trend was noted. Catalonia had already contributed in 2006 and 
Sardinia and Puglia in 2009 and 2010.

TABLE 2

BIODEGRADABLE WASTE LANDFILLED RATE TREND ON THE BASIS OF THE TOTAL 
AMOUNT OF BIODEGRADABLE MUNICIPAL WASTE PRODUCED IN 1995

Regions sampled

ES-Catalonia
IT-Sardinia
IT-Puglia
ES-Andalucía
Portugal1
RO-Nord-Est
RO-Sud-Vest

2006

Achieved

69 %
59 %
84 %2
87 %
79 %
56 %3
75 %4

Target

< 75 %
< 75 %
< 75 %
< 75 %
NA
NA
NA

2009

Achieved

45 %
36 %
85 %
93 %
78 %
69 %3
87 %

Target

< 50 %
< 50 %
< 50 %
< 50 %
< 75 %5
< 75 %5
< 75 %5

1  No figures available for the two regions, but only at the level of the Member State.
2  Data for 2008.
3  To be added, municipal waste not collected ,which amounted to 35 % and 27 % of the total municipal waste generation respectively.
4  Data for 2007.
5  Target for 2010.

Source: European Court of Auditors based on data available at Commission and Member State levels.

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18  To be noted that Romania 
was granted an additional 
deadline, until 2017, to 
ensure that all existing 
landfills comply with the 
requirements of the landfill 
directive.

ILLEGAL DUMPS WERE ERADICATED IN HALF OF THE REGIONS 
BUT WASTE WAS GENERALLY LANDFILLED WITHOUT ANY PRIOR 
TREATMENT

43. 

According to data provided by the regions audited, during the 2000–09 
period, illegal dumps had been either eradicated or their number sig-
nificantly reduced:

(a) 

(b) 

in  four  regions,  according  to  the  data  provided  by  the  relevant 
 authorities, no illegal dumps were operational at the time of the 
audit;

in the other four regions, illegal dumps were still being used, espe-
cially in the two regions selected in Romania where in 2009 munici-
pal waste collection only covered 54 % and 33 % of the population. 
The lack of collection of municipal waste in these two regions was 
especially noticeable in rural areas.

44. 

In the audited regions municipal waste was generally landfilled without 
proper treatment, despite the landfill directive stipulating that waste 
deposited in landfills should be treated to reduce the quantity of waste 
or hazards to human health or the environment. The Court noted the 
following:

(a)  municipal waste was generally landfilled without any treatment 
in four of the regions sampled18. In addition, in these regions the 
separate collection of biodegradable waste was only found in a very 
limited number of municipalities resulting in high levels of bio-
degradable matter in waste landfilled;

(b) 

in one region, treatment prior to disposal covered waste generated 
by only approximately 40 % of the total population of the region. 
However, this lack of treatment was partially mitigated by the fact 
that the separate collection of biodegradable waste was carried 
out in most of the region;

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(c) 

in the three remaining regions, there were more mechanical bio-
logical treatment plants carrying out treatment prior to disposal 
but  in  general  they  did  not  achieve  the  per formance  expected 
(see Box 8 ).

WERE MEASURES PUT IN PLACE TO MAXIMISE THE 
EFFECTIVENESS OF EU FUNDING?

45. 

In order to maximise the effectiveness of the co-financed infrastructures, 
information, administrative and economic supporting measures, such 
as awareness campaigns, quality standards and separate collection or 
‘pay as you throw’ schemes and landfill taxes (see paragraph 9), should 
be in place to encourage waste prevention and recycling in accordance 
with the EU waste hierarchy (see Figure 3 ). EU financial support should 
encourage the implementation of such supporting measures. An ap -
propriate regulatory framework and guidelines should be implemented.

BOX 8

EXAMPLE OF A REGION WHERE TREATMENT FACILITIES WERE IN PLACE, BUT WHERE 
THEIR PERFORMANCE WAS NOT SATISFACTORY

In one of the regions sampled  22  of the  28  landfills in operation at the time of the audit received pre-treated 
waste from mechanical biological treatment plants. However, these plants did not meet their performance 
targets. On average 76 % of waste entering the 23 treatment facilities available in the region was landfilled 
in 2008 with a high content of biodegradable matter despite the treatment process; in the case of the plant 
audited (Linares, Spain) the recovery of biodegradable waste only amounted to between 6  % and  9  % rather 
than the design target of 25 % to 28 %.

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46. 

The Court examined whether:

(a) 

informative, administrative and economic instruments were put 
in  place  at  Member  State  and/or  regional  level  to  support  the 
co-financed waste management infrastructures and whether the 
Commission encouraged their implementation when approving 
operational programmes or projects;

(b) 

the EU regulatory framework and guidelines were likely to maximise 
the effectiveness of EU funding.

THE LEVEL OF IMPLEMENTATION OF INFORMATION, ADMINISTRATIVE 
AND ECONOMIC SUPPORTING MEASURES VARIED SIGNIFICANTLY 
AMONG THE REGIONS SAMPLED

INFORMATIVE MEASURES

47. 

In general in the regions where the sampled waste management infra-
structures were located, there was evidence of complementary informa-
tion activities such as public awareness campaigns or the publication of 
waste management guidelines. Box 9  describes one such case.

BOX 9

A GOOD EXAMPLE OF HOW DEVELOPING PUBLIC AWARENESS CAN RESULT IN A  BETTER 
QUALITY OF PERFORMANCE FROM INFRASTRUCTURES

One of the composting plants in Portugal (Lipor) was operated by a company providing waste management 
services (separate collection and treatment) to eight municipalities accounting approximately for 1 million 
inhabitants. As the company considered communication and high levels of participation as key factors for the 
success of the management of waste, all its activities were associated with efforts to provide information, raise 
awareness and educate the public. In particular, the construction of the composting plant was accompanied 
by communication and awareness campaigns as well as a specific marketing strategy for the compost. Public 
satisfaction surveys were carried out periodically, a free information phone line was set up and waste man -
agement guidelines were published and distributed. All these efforts resulted in a satisfactory segregation at 
source of biodegradable waste by households and commerce, which allowed the production and selling of 
high-quality compost (see Box 2 ).

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48. 

However, the Court noted the following:

(a) 

(b) 

in  none  of  the  regions  sampled  did  the  responsible  authorities 
measure the success of their information campaigns and no meas-
urable targets had been defined at the outset;

in the two regions selected in Romania, despite some awareness 
campaigns, almost all biodegradable waste collected separately 
was found to be contaminated and had to be directly landfilled 
rather than being treated in the composting plants.

49. 

50. 

ADMINISTRATIVE MEASURES

As  required  by  the  waste  directive,  the  eight  regions  implemented 
a system of issuing of permits for establishments carrying out waste 
treatment. At the time of the audit, all the infrastructures were subject 
to inspections by the responsible authorities. Such inspections were, 
however, limited to the assessment of potential environmental impacts 
and did not cover the performance aspect of the waste management 
facilities (see Box 6 ).

Concerning separate collection, the Court noted significant discrepancies 
in its implementation in the regions and municipalities served by the 
waste management infrastructures audited. Whereas segregated col-
lection of packaging waste, paper and cardboard and glass was widely 
implemented, contributing to the good performance observed in the 
audited sorting plants, separate collection of biodegradable waste was 
satisfactory in two regions only. These regions contributed to meeting 
EU diversion targets for biodegradable waste and managed to reduce the 
kilograms landfilled per capita (see paragraphs 41 and 42). For the other 
six regions separate collection of biodegradable waste was generally 
not in place or was ineffective. As a result, composting plants treating 
mixed waste or biodegradable waste not properly segregated at source 
performed poorly.

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51. 

52. 

Figures show an inverse relationship between separate collection im-
plementation and percentage of waste landfilled (see Figure 6 ).

Regarding compost quality standards, the Court noted that, at the time 
of the audit, four regions lacked any such standard and for the remaining 
four regions the admissible concentration limits of heavy metals in the 
compost varied significantly and were less stringent than those con-
tained in EU draft guidelines. The lack of quality standards contributed to 
the difficulties faced by the composting and anaerobic digestion plants 
in selling their compost.

FIGURE 6

INVERSE RELATIONSHIP BETWEEN SEPARATE COLLECTION AND PERCENTAGE OF 
WASTE LANDFILLED 1

)

%

(
e
t
a
r
n
o
i
t
c
e
l
l

o
c
e
t
a
r
a
p
e
S

45
40
35
30
25
20
15
10
5
0

IT-Sardinia

ES-Catalonia

PT-LVT

PT-Norte

ES-Andalucía

IT-Puglia

RO-Sud-Vest

RO-Nord-Est

0

10

20

30

40

50

60

70

80

90

100

1  For RO-Nord-Est and RO-Sud-Vest, the landfill rate was calculated based only on waste collected.

Source: European Court of Auditors based on data available at Commission and Member State levels.

Landfill rate (%)

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ECONOMIC MEASURES

53. 

Based on the review of the waste management tariffs charged by munici-
palities to households in at least the three major municipalities served 
by each infrastructure in the sample, the Court noted the following:

(a) 

(b) 

in all cases, tariffs were flat 19 and not based on ‘pay as you throw’ 
schemes intended to take into consideration the ‘polluter pays prin-
ciple’ and to prevent or reduce waste generation;

some  municipalities,  despite  not  having  a  ‘pay  as  you  throw ’ 
scheme, introduced elements in the tariff to encourage recycling 
(see Box 10 ).

19  Tariffs were calculated 
based on the square metres 
of apartments or houses, 
on the number of persons 
per household, on drinking 
water consumption or on 
a combination of these 
elements, without taking into 
consideration the quantity 
of waste generated by each 
household.

20  As well as to private 
citizens in the case of disposal 
in landfills.

54. 

A waste disposal tax charged to municipalities 20 per tonne of waste land-
filled and/or incinerated on top of normal landfill and/or incineration 
fees is another economic incentive to try to change behaviour. Five of 
the eight regions sampled have introduced such a waste disposal tax to 
promote waste management options less damaging to the environment. 
The two regions with the highest level of landfill tax presented the lowest 
percentage of waste being disposed of in landfills in 2009 (see Figure 7 ) 
and the most significant improvements during the 2000–09 period. In 
order to encourage separate collection, two regions linked the amount 
of the waste disposal tax to the rate of separate collection achieved by 
each municipality (see Box 11 ).

BOX 10

EXAMPLES OF WASTE MANAGEMENT TARIFFS WITH ELEMENTS TO ENCOURAGE 
RECYCLING

In order to encourage recycling, some municipalities in Catalonia applied discounts to the waste management 
tariff paid by households based on home composting, use of collection centres or participation in awareness 
campaigns. The separate collection rate achieved by these municipalities (39 %) was higher than the one ob -
served in municipalities not applying economic incentives (29 %). Other municipalities in Catalonia took into 
account the proportion of waste landfilled when establishing the tariff to benefit the households of those 
municipalities with lower landfill rates.

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FIGURE 7

WASTE DISPOSAL TAX AND PERCENTAGE OF MUNICIPAL WASTE LANDFILLED IN 20091

IT-Puglia

RO-Nord-Est

ES-Andalucía
RO-Sud-Vest

PT-Norte

PT-LVT

d
e
l
l

fi
d
n
a
l
e
t
s
a
w

f
o
n
o
i
t
r
o
p
o
r
P

100 %
90 %
80 %
70 %
60 %
50 %
40 %
30 %
20 %
10 %
0 %

ES-Catalonia

IT-Sardinia

0

5

10

15

20

25

Average waste disposal tax in euro per tonne landfilled

1 

 For ES-Andalucía and IT-Puglia data refer to 2008. For RO-Nord-Est and RO-Sud-Vest the proportion of waste landfilled does not take 
into consideration waste not collected.

Source: European Court of Auditors based on data available at Commission and Member State levels.

BOX 11

AN EXAMPLE OF THE WASTE DISPOSAL TAX SET FOR WASTE LANDFILLED OR 
INCINERATED BASED UPON THE PERCENTAGE OF SEPARATE COLLECTION  
ACHIEVED BY EACH MUNICIPALITY

Since 2005, to promote separate collection of waste at source, Sardinia has adapted the tariff charged to waste 
landfilled or incinerated, based on the separate collection rate achieved by each municipality. For example, 
in 2010, if the separate collection rate reached a level between 50 % and 60 % a tax relief of 20 % was applied. 
If separate collection was above 60 % municipalities benefited from a tax relief of 40  %. However if separate 
collection was below 50  % (or 40  % depending on the number of inhabitants of the municipality) a penalty of 
an additional 5,16 euro/tonne was charged.

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WHEN APPROVING OPERATIONAL PROGRAMMES OR PROJECTS, 
THE COMMISSION DID NOT ENCOURAGE THE IMPLEMENTATION OF 
SUPPORTING MEASURES

55. 

Structural measures funding did not influence the implementation of 
information, administrative and economic supporting measures. The 
Commission required limited information on such instruments when 
deciding on the co-financing of waste management infrastructures:

(a) 

for ERDF funding, the Court noted that 9 of the 10 operational pro-
grammes selected did not contain information regarding specific 
administrative measures nor any reference to waste disposal taxes 
or types of waste management tariffs paid by households (flat rate 
or based on ‘pay as you throw’ schemes);

(b)  even if each Cohesion Fund project was individually assessed and 
approved  by  the  Commission  during  the 2000–06 programme 
 period, the Court noted that the level of detail concerning support-
ing measures requested by the Commission from Member States 
did not in general ensure their existence before the granting of 
EU funding.

56. 

57. 

Implementation reports submitted by the sampled Member States to 
comply with the requirements set in EU waste directives contain some 
information on such supporting measures (information on landfill tax im-
plementation, inspections, public information, etc.). However, the Court 
did not note any link between the assessment of the implementation 
reports by DG Environment and the EU funding of waste management 
infrastructures which is the responsibility of DG Regional and Urban 
Policy: Member States not reporting to the Commission or providing 
incomplete reports benefit in the same way from structural measures 
funding for waste management infrastructures.

The lack of a link between EU funding and the existence of supporting 
instruments was especially significant in relation to the implementation 
of the ‘polluter pays principle’, which is one of the principles on which 
EU environmental policy is based21. The 1975 waste directive established 
this principle22 which was then included in other specific directives on 
waste management, such as the landfill directive 23. According to co-
hesion policy regulations and to Commission internal guidelines, EU 
financial support should take into consideration the implementation of 
the principle through differentiated rates of assistance24.

21  Article 191(2) of the 
Treaty on the Functioning 
of the European Union 
(consolidated version).

22  Article 15 of Directive 
75/442/EEC, Article 15 
of Directive 91/156/EEC, 
Article 15 of Directive 
2006/12/EC and Article 14 of 
Directive 2008/98/EC.

23  Article 10 of Directive 
1999/31/EC.

24  Article 29 of Council 
Regulation (EC) No 1260/1999 
of 21 June 1999 laying 
down general provisions 
on the Structural Funds: 
‘The contribution of the 
Funds shall be differentiated 
through the application of 
the polluter pays principle’. 
Article 52 of Council 
Regulation (EC) No 1083/2006 
of 11 July 2006 laying 
down general provisions 
on the European Regional 
Development Fund, the 
European Social Fund 
and the Cohesion Fund 
and repealing Regulation 
(EC) No 1260/1999: ‘The 
contribution from the Funds 
may be modulated through 
the application of the polluter 
pays principle’. 
Article 55 of Regulation (EC) 
No 1083/2006: ‘In calculating 
the eligible expenditure on 
revenue-generating projects, 
the managing authority 
shall take account of the 
application of the polluter-
pays principle’.

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This principle of differentiated rates of assistance was further developed 
by the Commission during the 2000–06 period in a technical paper 25 
which established that ‘where the financing of a project includes a sys -
tem of charges (such as low flat rate charges), which are not based on 
the actual consumption of resources and do not provide the necessary 
financial means to properly maintain the infrastructure nor to cover the 
operational costs and a large part of the depreciation costs, then the 
rate of assistance should be reduced’. In these cases, the proposed rate 
of assistance should normally be as set out in column 5 of  Annex IV.

25  ‘The new programming 
period 2000-2006: Technical 
paper 1 — Application of the 
polluter pays principle — 
Differentiating the rates of 
Community assistance for 
Structural Funds, Cohesion 
Fund and ISPA infrastructure 
operations’ (6.12.1999).

The Court noted that although for the selected infrastructures, operating 
and depreciation costs were not covered by the waste management tariff 
charged to households, the Commission did not apply the principle of 
a differentiated rate of assistance by reducing the co-financing rate. As 
a result, in almost all the cases the co-financing rate granted was higher 
than the one that should have applied in accordance with the principle 
of differentiated rates of assistance (see Annex IV). Some municipalities 
did not charge any waste management tariff to households.

Tariffs charged by municipalities to households for the management of 
waste varied significantly, even within each region (see Table 3 ). Dif-
ferences, reaching in some cases up to 300 % within the same region, 
could not be solely explained by differences in the average income of 
households and their affordability level or in the cost of waste manage-
ment among the municipalities sampled.

58. 

59. 

60. 

TABLE 3

WASTE MANAGEMENT TARIFFS PAID BY HOUSEHOLDS IN THE MUNICIPALITIES SAMPLED 
IN 2009  OR 2010

Region

Lowest tariff noted

Highest tariff noted

Difference in %

ES-Catalonia
IT-Sardinia
IT-Puglia
ES-Andalucía
PT-Norte
PT-Lisboa Vale do Tejo
RO-Nord-Est
RO-Sud-Vest

40,25 euro per household
1,02 euro per m2 of surface
1,57 euro per m2 of surface
69,60 euro per household
0 euro
0 euro
8,69 euro per person (the infrastructures sampled served only one municipality)
16,2 euro per person (the infrastructures sampled served only one municipality)

166,50 euro per household
3,3 euro per m2 of surface
2,62 euro per m2 of surface
94,36 euro per household
76,20 euro per household
70,38 euro per household

314 %
224 %
67 %
36 %
-
-
NA
NA

Source: European Court of Auditors based on audit evidence obtained during the audit.

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26  Communication from the 
Commission to the Council, 
the European Parliament, 
the Economic and Social 
Committee and the 
Committee of the Regions 
on the sixth environment 
action programme of the 
European Community  
(COM(2001) 31 final).

27  Article 6(a) of Directive 
1999/31/EC stipulates 
that ‘by reducing the 
quantity of the waste or the 
hazards to human health 
or the environment’, while 
Article 2(h) stipulates that 
‘to reduce its volume or 
hazardous nature, facilitate 
its handling or enhance 
recovery’.

61. 

62. 

63. 

64. 

65. 

WEAKNESSES WERE NOTED IN THE EU WASTE REGULATORY 
FRAMEWORK AND EU GUIDELINES

The EU waste regulatory framework and EU guidelines can contribute to 
maximise the effectiveness of EU funding. The Court noted weaknesses 
in this area.

LACK OF FOCUS OF EU DIRECTIVES’ TARGETS ON WASTE PREVENTION

The EU waste hierarchy contained in the waste directive indicates pre-
vention as the first waste management option. The sixth environment 
action programme26 included an overall objective to substantially reduce 
waste generation and disposal.

However, targets set in EU directives in the waste management field 
relate only to recycling, recovery and diversion of biodegradable waste 
from  landfills  and  do  not  address  prevention  or  reduction  of  waste 
(see paragraph 39).

LACK OF CLARITY OF THE CONCEPT OF TREATMENT BEFORE DISPOSAL

According  to  the  landfill  directive  only  waste  that  has  been  subject 
to treatment should be landfilled. However, the directive is not clear 
enough on what such treatment should consist of and whether treat-
ment requires a reduction in the quantity of waste landfilled or only 
a reduction of its volume 27.

This lack of clarity regarding the concept of treatment before landfilling 
has resulted in different strategies at national and/or regional level. One 
of the regions sampled focused, for example, on mechanical biological 
treatment  plants,  the  performance  of  which  in  achieving  the  reduc-
tion of waste landfilled was not satisfactory. In two other regions, when 
high levels of separate collection were achieved, waste was considered 
as having been treated and could be taken to the landfill directly (see 
paragraphs 28 and 44).

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66. 

67. 

68. 

LACK OF EU QUALITY STANDARDS FOR COMPOST

The EU co-financed composting and anaerobic digestion plants in all 
eight regions sampled. However, at the time of the audit four of the 
regions reviewed lacked any quality standards for compost. In the four 
remaining regions, the admissible concentration levels of heavy metals 
varied significantly (see paragraph 52).

The fact that quality standards for compost at national/regional level 
either did not exist or if they existed, varied significantly, hampered the 
development of a compost market, making it difficult for plant oper-
ators to sell the compost produced. There are no EU compost quality 
standards.

NO EU GUIDELINE FOR THE FINANCIAL SECURITY FOR LANDFILL CLOSURE COSTS

Concerning the financial security to cover closure and after-care costs, 
the Court noted that significant differences existed in the methodolo-
gies applied for its calculation in the six regions where landfills were 
sampled, resulting in significantly varying amounts for a landfill of the 
same capacity, which indicates that they may not always be sufficient 
to cover all the costs for a period of 30 years as required by the landfill 
directive. The EU has neither provided any guidelines to Member States 
as to how the closure and after-care costs should be estimated nor pro-
moted any exchange of experiences among Member States in this area 
(see paragraphs 33 and 34).

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CONCLUSIONS AND RECOMMENDATIONS

41

69. 

In almost all the regions selected some improvements in the manage-
ment of waste were observed, however the effectiveness of structural 
measures funding for municipal waste management infrastructures in 
helping Member States achieve EU waste policy objectives was ham-
pered  by  the  poor  implementation  of  suppor ting  measures  and  by 
weaknesses in EU rules and guidelines. When assessing operational pro-
grammes or projects for which it had responsibility, the Commission did 
not encourage the implementation of supporting measures. The success 
of the co-financed infrastructures depends on the existence of effective 
separate collection at source, which was often not the case. Although all 
the regions sampled showed some improvements in the management 
of waste, only  25 % achieved EU waste policy objectives, mainly those 
who put supporting measures in place.

PERFORMANCE OF MUNICIPAL WASTE 
MANAGEMENT INFRASTRUCTURES

70. 

The performance of co-financed infrastructures was highly dependent 
upon waste collection strategies:

(a) 

(b) 

sorting  plants,  intended  to  recover  packaging  waste  segregat-
ed  at  source  by  households,  performed  satisfactorily  (see  para-
graphs 23 and 24);

in general, composting and anaerobic digestion plants treating 
biodegradable waste collected separately (when it was not con-
taminated)  performed  better  than  the  plants  treating  unsorted 
waste where performance was unsatisfactory (see paragraph 25);

(c)  mechanical biological treatment plants receiving waste unsorted 
at source did not manage in general to contribute to the achieve-
ment of EU waste policy objectives as most of the waste entering 
the plants was landfilled (see paragraphs 26 and 27).

71. 

Waste was deposited following either inadequate treatment or without 
any treatment whatsoever in all of the landfill sites sampled, resulting 
in a  high content of biodegradable matter being landfilled (see para-
graph 28).

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72. 

Almost all of the infrastructures audited met environmental require-
ments. However, five of the seven selected landfills did not set up a suf -
ficient financial security to cover closure and after-care costs. Significant 
differences were observed in the methodology used to determine the 
amount of financial security required. In most cases the amounts es-
tablished would be insufficient to cover all the associated costs (see 
paragraphs 29 to 34).

RECOMMENDATION 1

(a)  Member States should:

(i) 

focus on waste management infrastructures treating waste 
previously segregated at source (including biodegradable 
waste when cost-effective);

(ii) 

ensure that municipal waste deposited in landfills has been 
treated before disposal;

(iii)  make sure that landfill sites possess a suf ficient financial 
security to cover closure and after-care costs for a period of 
at least 30 years, the calculation of which should be based 
on an appropriate methodology.

(b) 

The  Commission should make the EU contribution subject to the 
implementation of these recommendations by the Member States.

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EU WASTE POLICY OBJECTIVES AT REGIONAL LEVEL

73. 

The Court noted significant weaknesses regarding the reporting by Mem-
ber States of the achievement of EU targets, resulting in the inability of 
the Commission to evaluate in all cases whether the performance  being 
achieved by Member States was in line with EU waste targets. The Com-
mission checks the consistency of the figures received, but does not 
assess their reliability and does not compile information on the achieve-
ment of EU targets at regional level (see paragraphs 37 and 38).

74. 

Although in almost all the regions selected some improvements in the 
management of waste were observed:

(a)  per capita waste generation increased in six of the eight regions 
sampled despite prevention being fundamental in the hierarchy of 
EU waste management actions (see paragraph 39);

(b)  only one quarter of the regions sampled significantly increased 
their separate collection rate resulting in a reduction of the reli -
ance on landfilling and contributed to achieving EU targets (see 
paragraphs 40 to 42);

(c)  waste was generally landfilled without having been adequately 

treated or not treated at all (see paragraph 44).

RECOMMENDATION 2

(a)  Member States should set up reliable waste management data-
bases, both to monitor their progress towards the achievement 
of EU waste policy objectives and to underpin their reporting to 
the Commission.

(b) 

The Commission should assess the data received from Member 
States for reliability.

(c) 

The  Commission, the Parliament and the Council should  con-
sider linking EU financial support to the achievement of EU waste 
policy objectives.

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75. 

76. 

MEASURES PUT IN PLACE TO MAXIMISE THE 
EFFECTIVENESS OF EU FUNDING

The effectiveness of EU funding was not maximised due to the weak 
implementation of supporting measures.

The development of supporting information, administrative and eco-
nomic measures varied significantly in the regions sampled:

(a)  A high level of public awareness and willingness to participate in 
waste management schemes appeared to be key factors for the 
success of waste management infrastructures, especially in rela-
tion to waste segregation at source by households. In none of the 
regions sampled did the responsible authorities measure the re -
sults of the information measures they had put in place (see para-
graphs 47 and 48).

(b)  Only regions having implemented separate collection at source of 
biodegradable waste contributed to meeting the related EU diver-
sion targets (see paragraphs 50 and 51).

(c) 

Four of the eight regions sampled lacked any quality standard for 
compost and in the remaining four regions the acceptable con-
centration limit for heavy metals varied significantly, contributing 
to the poor development of a market for the compost produced 
by the composting and anaerobic digestion plants in the sample 
(see paragraph 52).

(d)  The implementation of economic instruments via tariffs or through 
waste disposal taxes proved to have a significant impact on the 
performance of projects and regions in the management of waste 
(see paragraphs 53 and 54).

(e) 

The Commission did not encourage the implementation of sup-
porting measures, especially of the ‘polluter pays principle’ as no 
differentiated rates of assistance were found to have been applied 
in the projects sampled (see paragraphs 55 to 60).

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RECOMMENDATION 3

(a)  Member States should:

(i) 

(ii) 

pay greater attention to increasing public awareness and 
participation in waste management schemes, especially in 
relation to waste segregation at source by households. Re-
sults achieved by awareness-raising campaigns and educa-
tional strategies should be systematically measured;

focus on separate collection implementation, including bio-
degradable waste when cost-effective, in order to maximise 
the performance of waste management infrastructures and 
to progress towards the achievement of EU waste policy ob-
jectives;

(iii) 

introduce  economic  instruments  in  the  management  of 
waste  to  promote  waste  prevention  and  rec ycling,  par-
ticularly through a  waste disposal tax, ‘pay as you throw’ 
schemes and other incentives in the tariffs paid by house-
holds.

(b) 

The Commission should:

(i)  make the EU contribution subject to the implementation of 

these recommendations by the Member States;

(ii) 

in relation to the ‘polluter pays principle’, when approving 
operational programmes, request from the Member States 
the application of reduced rates of assistance when waste 
management tariffs paid by households do not cover operat-
ing costs and a large part of depreciation costs of municipal 
waste management. The Commission should apply itself this 
principle when approving major projects.

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4646

77. 

Improvements in the EU regulatory framework and EU guidelines can 
contribute towards maximising the effectiveness of structural measures 
funding of municipal waste management infrastructures. The Court not-
ed:

(a) 

a lack of focus of EU waste directives’ targets on waste prevention 
despite prevention being the first management option according 
to the waste directive (see paragraphs 62 and 63);

(b)  a lack of clarity of the concept of treatment before disposal, re -
sulting in different strategies at national and regional level (see 
paragraphs 64 and 65);

(c) 

a lack of EU quality standards for compost, despite the absence 
or  inconsistency  of  standards  available  at  Member  State  level, 
which hampered the development of a compost market (see para -
graphs 66 and 67);

(d)  a lack of guidance on the methodology to be used to assess the 

closure and after-care costs of landfills (paragraph 68).

RECOMMENDATION 4

The Commission should:

(a) 

(b) 

(c) 

propose waste prevention targets in line with the EU waste hier-
archy pyramid;

clarify the concept of treatment before disposal contained in the 
landfill directive, to ensure a consistent approach by Member 
States;

consider  the  oppor tunit y  to  develop  with  Member  States  EU 
quality standards for compost to encourage the development 
of a compost market;

(d)  provide appropriate guidance and disseminate best practices in 
relation to the methodology to be used to estimate closure and 
after-care costs of landfills to be covered by the financial security.

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4747

This report was adopted by Chamber II, headed by Mr Harald NOACK, 
Member  of  the  Cour t  of  Auditors,  in  Luxembourg  at  its  meeting  of 
24 October 2012.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

 
 
 
48

ANNEX I

Prevention

WASTE MANAGEMENT SYSTEM FROM WASTE SOURCE TO FINAL DISPOSAL

Prevention

Re-use

Re-use

MUNICIPAL WASTE GENERATION

Biodegradable waste

Separate collection

Recycling

Composting

Anaerobic
digestion
(biogas)

Organic 
waste

Remaining
fraction

Packaging,
glass, paper,
metals, etc.

Sorting plant
(packaging, glass, paper,
metals, etc.)

n
o
i
t
p
o
e
l
b
a
r
i
s
e
d
s
s
e
L

Recovery

Disposal

Compost applied
on land

Residual
waste

Mechanical
biological
treatment

Digest

Sorted materials

Residual
waste

Sorted/recycled
materials

Residues

Incineration
(energy recovery)

Residues

Landﬁll

Energy from
landﬁll gas

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49

Complementary notes to diagram

According to the waste directive,

Prevention: means measures, taken before a substance material or product has become waste, that 
reduce: the quantity of waste, the adverse impacts of the generated waste on the environment and 
human health or the content of harmful substances in materials and products.

Re-use: means any operation by which products or components that are not waste are used again 
for the same purpose for which they were conceived.

Recycling: means any recovery operation by which waste materials are reprocessed into products, 
materials or substances whether for the original or other purposes. It includes the reprocessing of 
biodegradable material but does not include energy recovery and the reprocessing into materials 
that are to be used as fuels or for backfilling operations.

Recovery: means any operation the principal result of which is waste serving a useful purpose by 
replacing other materials which would otherwise have been used to fulfil a particular function, or 
waste being prepared to fulfil that function, in the plant or in the wider economy.

Disposal: means any operation which is not recovery even where the operation has as a secondary 
consequence the reclamation of substances or energy.

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ANNEX II

STRUCTURAL MEASURES ASSISTANCE EARMARKED FOR WASTE MANAGEMENT PROJECTS

Member State

CF (urban and 
industrial waste)

CF (environment 
related to waste)

ERDF

TOTAL

% over total

2000–06 PROGRAMMING PERIOD

Spain

Greece

Portugal

Italy

Hungary

Germany

Poland

Lithuania

Romania

France

Ireland

Slovenia

Czech Republic

Latvia

EU cross-border 
cooperation

Bulgaria

Cyprus

Estonia

Slovakia

United Kingdom

Malta

EU interregional 
cooperation

Finland

Belgium

Netherlands

Denmark

Luxembourg

Austria

Sweden

TOTAL EU

1 393 087 080

365 649 728

385 910 757

0

75 120 816

0

8 908 090

0

176 848 871

27 958 830

0

74 031 202

90 372 374

0

0

6 903 275

62 572 651

47 345 000

32 405 111

0

0

0

23 096 673

0

0

11 723 250

0

0

0

0

0

0

0

0

0

29 438 760

16 563 950

107 489 325

0

0

20 331 730

0

22 928 732

0

51 800 193

28 722 415

0

0

0

0

0

0

0

0

0

0

0

0

220 099 852

297 647 168

51 652 744

313 677 576

15 167 782

197 557 502

91 424 570

1 446 008

0

103 931 777

80 617 000

0

16 328 485

7 538 163

56 691 788

0

0

2 389 009

22 870 561

16 864 095

3 166 065

13 985 683

6 222 300

5 706 707

5 680 360

0

0

0

0

1 688 307 748

663 296 896

446 471 591

313 677 576

219 975 483

197 557 502

194 894 532

108 382 332

107 489 325

103 931 777

87 520 275

82 904 381

63 673 485

62 872 006

56 691 788

51 800 193

28 722 415

25 485 682

22 870 561

16 864 095

14 889 315

13 985 683

6 222 300

5 706 707

5 680 360

0

0

0

0

36,78

14,45

9,73

6,83

4,79

4,30

4,25

2,36

2,34

2,26

1,91

1,81

1,39

1,37

1,24

1,13

0,63

0,56

0,50

0,37

0,32

0,30

0,14

0,12

0,12

0

0

0

0

2 669 945 972

389 262 841

1 530 665 195

4 589 874 008

100,00

Source: European Commission.

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51

% over total

21,01

12,71

8,34

7,40

6,93

5,91

5,87

5,42

4,82

4,47

3,59

3,29

2,16

2,08

2,01

1,13

0,89

0,77

0,77

0,32

0,05

0,04

0,04

2007–13 PROGRAMMING PERIOD

EU earmarked amount

1 311 253 636

792 840 872

520 258 572

462 015 554

432 176 450

368 600 000

366 500 000

338 072 531

300 521 138

278 995 046

224 088 076

205 568 426

134 470 000

129 500 000

125 495 000

70 302 813

55 250 000

47 745 110

47 890 793

20 230 668

3 000 000

2 382 219

2 667 500

6 239 824 404

100,00

Member State

Poland

Romania

Czech Republic

Spain

Greece

Slovakia

Hungary

Italy

Bulgaria

Lithuania

Portugal

Slovenia

France

Latvia

Cyprus

Estonia

Malta

Germany

EU cross-border cooperation

United Kingdom

Ireland

Belgium

Netherlands

TOTAL

Source: European Commission.

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ANNEX III

LIST OF INFRASTRUCTURES SELECTED FOR THE AUDIT

Region  
(Member State)

Project title

Type of waste  
management infrastructure

EU fund

Catalonia  
(Spain)

Catalonia  
(Spain)

Catalonia  
(Spain)

Sardinia  
(Italy)

Sardinia  
(Italy)

Sardinia  
(Italy)

Puglia  
(Italy)

Puglia  
(Italy)

Puglia  
(Italy)

Puglia  
(Italy)

Andalucía  
(Spain)

Andalucía  
(Spain)

Andalucía  
(Spain)

LVT  
(Portugal)

LVT  
(Portugal)

Norte  
(Portugal)

Norte  
(Portugal)

Norte  
(Portugal)

Mechanical biological treatment plant (Sant Adrià de 
Besòs)

Mechanical biological 
treatment 

Construction and adaptation of municipal waste 
management infrastructures in Catalonia (Project 17 — 
Enlargement and adaptation of the landfill in Alt Empordà)

Landfill

Cohesion Fund

Cohesion Fund

Construction and adaptation of municipal waste 
management infrastructures in Catalonia  
(Project 18 — Gironés composting plant)

Composting plant

Cohesion Fund

Plant for the production of quality compost (Serramanna)

Composting plant

Anaerobic digestion plant (Villacidro)

Mechanical biological 
treatment 

Plant for the selection, stabilisation and production of 
refuse-derived fuel (Olbia)

Mechanical biological 
treatment 

ERDF
(OP Sardegna)

ERDF
(OP Sardegna)

ERDF
(OP Sardegna)

ERDF
(OP Puglia)

ERDF
(OP Puglia)

ERDF
(OP Puglia)

ERDF
(OP Puglia)

Mechanical biological 
treatment 

Landfill

Mechanical biological 
treatment 

Not in operation at the  
time of the audit

Sorting plant

Cohesion Fund

Mechanical biological 
treatment 

Cohesion Fund

Landfill

Cohesion Fund

Plant for bio-stabilisation and composting in Cerignola

Landfill (Cavallino)

Bio-stabilisation plant (Cavallino)

Environment protection and regeneration through the 
development of the urban waste management cycle 
(Brindisi)

Packaging and packaging waste recovery plant in the 
integrated centre for the treatment of municipal solid 
waste Monte Marta-Cónica (Sevilla)

Recovery and composting plant (Linares) 

Fitting-out, closure and construction of a new cell  
in a landfill for depositing municipal solid waste,  
Guadiel (Linares)

Sorting plant, Resitejo

Sorting plant

ERDF
(OP LVT)

Construction of an organic recovery plant (Valorsul)

Anaerobic digestion plant

Cohesion Fund

Multi-municipal system for the recovery and treatment 
of municipal solid waste (Vale do Douro Sul, Residouro)

Sorting plant

Multi-municipal system for the recovery and treatment 
of municipal solid waste (Vale do Douro Sul, Residouro)

Landfill

Environmental rehabilitation of the plant for the 
treatment of municipal solid waste (Vale do Ave)

Composting plant

ERDF
(OP Norte)

ERDF
(OP Norte)

ERDF
(OP Norte)

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Type of waste  
management infrastructure

EU fund

Composting plant

Cohesion Fund

Sorting plant

Cohesion Fund

Region  
(Member State)

Project title

Integrated management of solid waste by LIPOR — 
organic recovery plant

Multi-municipal system for the recovery and treatment 
of municipal solid waste (Baixo Tâmega)

Multi-municipal system for the recovery and treatment 
of municipal solid waste (Baixo Tâmega)

Landfill

Piatra Neamt waste management programme

Composting plant

Piatra Neamt waste management programme

Sorting plant

Piatra Neamt waste management programme

Landfill

Integrated municipal waste management system 
(Râmnicu Vâlcea)

Integrated municipal waste management system 
(Râmnicu Vâlcea)

Composting plant

Landfill

Cohesion Fund

Cohesion Fund  
(ex-ISPA)

Cohesion Fund  
(ex-ISPA)

Cohesion Fund  
(ex-ISPA)

Cohesion Fund  
(ex-ISPA)

Cohesion Fund  
(ex-ISPA)

Complementary ERDF operational programmes reviewed for which no infrastructures were audited

Norte  
(Portugal)

Norte  
(Portugal)

Norte  
(Portugal)

Nord-Est  
(Romania)

Nord-Est  
(Romania)

Nord-Est  
(Romania)

Sud-Vest  
(Romania)

Sud-Vest  
(Romania)

Catalonia  
(Spain)

Andalucía  
(Spain)

Single programming document Cataluña 2000–06

Operational programme Andalucía 2000–06

Operational programme Castilla-La Mancha 2000–06

Single programming document Comunidad de Madrid 2000–06

Operational programme Madeira 2000–06

Operational programme Sicilia 2000–06

Castilla-La Mancha 
(Spain)

Comunidad de Madrid 
(Spain)

Madeira  
(Portugal)

Sicilia (Italy)

Source: European Court of Auditors.

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ANNEX IV

RATES OF ASSISTANCE GRANTED COMPARED TO RATES THAT TAKE INTO ACCOUNT THE 
LEVEL OF COVERAGE OF OPERATING COSTS BY HOUSEHOLDS

Infrastructure

Total cost coverage 
by tariffs

Operating cost 
coverage by tariffs

Rate assistance 
applied

Proposed rates of 
assistance to be 
applied3

Year of reference

ES-CA1

ES-CA2

ES-CA3

IT-SA1

IT-SA2

IT-SA3

IT-PU1

IT-PU2 and 3

IT-PU4

ES-AN1

ES-AN2 and 3

PT-LVT1

PT-LVT21

PT-NO1 and 2

PT-NO3

PT-NO4

PT-NO5 and 6

RO-PN1, 2 and 3

RO-RV1 and 2

40 %

56 %

76 %

78 %

77 %

78 %

96 %

85 %

42 %

59 %

80 %

84 %

83 %

84 %

100 %

91 %

80 %

80 %

80 %

50 %

50 %

50 %

50 %

50 %

50 %

50 %

50 %

40 %

40 %

40 %

40 %

40 %

2010

2010

2010

2009

2009

2009

2009

2009

NA. The project was not in operation at the time of the audit visit.

NA. The operating and depreciation costs of the sorting plant are covered by companies having introduced 
packaging into the market.

83 %

55 %

0 %

27 %

73 %

68 %

24 %

No info

No info

88 %

66 %

0 %

33 %

88 %

82 %

29 %

73 %

89 %2

80 %

75 %

50 %

75 %

75 %

50 %

85 %

75 %

75 %

50 %

50 %

50 %

50 %

50 %

50 %

50 %

50 %

50 %

2009

2010

2010

2010

2010

2010

2010

2010

2010

Information was only made available to the Court for two of the three municipalities for which it was requested.

1 
2  Not including the operating costs of the landfill and of composting plant.
3 

 Based on ‘Technical paper 1 — Application of the polluter pays principle — Differentiating the rates of Community assistance for  
Structural Funds, Cohesion Fund and ISPA infrastructure operations’ (6.12.1999). This technical paper proposes rates of assistance  
to be applied.

Source: European Court of Auditors based on data available at Commission and Member State levels.

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55

REPLY OF THE 
COMMISSION

EXECUTIVE SUMMARY

III.
In the framework of projects co-financed by the cohesion 
policy, the Commission was not empowered to check the 
appropriateness and assess on substance the waste man-
agement plans or to impose the inclusion of supporting 
measures. 

At the moment of the projects’ approval and their imple-
m e n t a t i o n ,   s e p a r a te   c o l l e c t i o n   w a s   n o t   a n   E U   l e g a l 
requirement. 

The Commission has proposed ex ante conditionalities for 
the Cohesion Policy 2014–20.

III. (a)
The Commission acknowledges that the issues concerning 
the concept of treatment and closure and after-care costs 
are systemic issues in need of a global approach, on which 
case-law will further develop and technical discussions will 
take place, respectively. 

I n  accordance  with  the ‘Roadmap  to  a  resource  effi-
cient Europe’ (COM(2011) 571 final), the Commission will 
develop  policy  aiming  at  minimising  the  landfilling  of 
waste while increasing the recycling rates. To this end, the 
implementation of economic instruments, e.g. landfill tax, 
‘pay as you throw’ schemes related to waste separate col-
lection, are regarded as crucial for success.

III. (b)
Improvements  in  the  collection  and  evaluation  of  data 
on  waste  have  been  made  in  the  years  after  the  period 
audited by the Court.

Concerning municipal waste, the Commission has estab-
lished since 1995 a system for the collection and compil-
ation  of  data  at  national  level  on  a  voluntar y  basis  and 
applies  the  quality  framework  for  official  statistics. The 
Commission has put in place a voluntary system for the 
production of regional level statistics since 2010.

During the period observed by the Court (2000–09) the per 
capita generation of municipal waste increased in 16 Mem -
ber States, decreased in nine and remained unchanged in 
two.

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56

For revenue-generating projects, the Commission currently 
applies the ‘polluter pays principle’ and reduced rates of 
assistance, using a comprehensive approach which takes 
into account affordability and effectiveness.

IV. (d)
The current waste framework directive (2008/98/EC) sets 
out  legally  binding  requirements  relating  to  the  waste 
management  hierarchy,  separate  collection,  rec ycling 
targets, waste management plans and waste prevention 
programmes.

In June 2012, the Commission published guidelines on the 
key requirements of this directive3.

The planned 2014 revision of the waste framework direc-
tive should focus on waste prevention objectives for 2020 
as well as the revision of the 2020 recycling targets. This 
will be linked with the revision of the landfill directive bio-
degradable diversion targets in order to avoid the landfill-
ing of recyclable waste, also required for 2014.

The  development  of  end- of-waste  criteria  for  biode -
gradable waste is being considered by the Commission. 
This should support the production of quality approved 
compost.

III. (c)
As regards waste management, one criterion in the ex ante 
waste conditionality proposed for 2014–20 requires the 
Member States to provide waste management plans com-
pliant with the requirements of the 2008 waste framework 
directive so that Member States will no longer be able to 
provide incomplete reports and at the same time benefit 
from structural measures.

IV. (a)
An ex ante conditionality linked to the provisions of the 
waste framework directive is included in the Commission's 
proposed common provisions regulation 1 for the 2014–20 
programming period.

IV. (b)
The  Commission  suppor ts  this  recommendation  and 
encourages Member States to establish public databases 
on waste management. A framework is provided by the 
Commission's proposal for a shared environmental infor-
mation system (SEIS)2.

IV. (c)
The  separate  collection  will  become  a  legal  obligation 
for a number of waste streams (except for biodegradable 
waste) as of 2015.

I n  accordance  with  the ‘Roadmap  to  a  resource  effi -
cient Europe’ (COM(2011) 571 final), the Commission will 
develop  policy  aiming  at  minimising  the  landfilling  of 
waste while increasing the recycling rates. To this end, the 
implementation of economic instruments, e.g. landfill tax, 
‘pay as you throw’ schemes, related to waste separate col-
lection are regarded as crucial for success.

The Commission has proposed ex ante conditionality for 
the cohesion policy 2014–20. As regards waste manage-
ment, one criterion of the waste conditionality requires 
the  Member  States  to  establish  waste  prevention  plans 
as  required  by  Ar ticle  29  of  the  2008  waste  framework 
directive.

1  COM (2011) 615 final/2 of 6 October 2011, as amended on 14 March 2012 
and 11 September 2012.

2  http://ec.europa.eu/environment/seis/

3  http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf

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REPLY OF THE COMMISSION57

INTRODUCTION

OBSERVATIONS

7.
Compared to the 1975 waste framework directive, the 2008 
waste  framework  directive strengthens  the  waste  hier-
archy and the ‘polluter pays principle’. 

Common Commission reply to  
Observations 10 and 11
There are two main types of EU funding: funds which are 
managed centrally and directly by the European Commis-
sion, e.g. for research; and funds whose management is 
shared between the EU and the Member States, e.g. the 
Structural  Funds  and  the  Cohesion  Fund.  For  funds  in 
'shared  management',  Member  States  implement  pro-
grammes at national level. Member States then allocate 
these funds to end recipients (companies, farmers, munici-
palities, etc.). The Member State has primary responsibility 
for setting up a management and control system which 
complies with the requirements of the regulations, ensur-
ing that this system functions effectively and also prevent-
ing, detecting and correcting irregularities. The Commis-
sion plays a supervisory role by satisfying itself that the 
arrangements  governing  the  management  and  control 
system are compliant. It does so by verifying the effective 
functioning  of  this  system  and  making  financial  correc-
tions, where necessary. 

Common reply to Observations 20 and 21
Among the 26 sampled projects, all were co-funded under 
the 2000–06 period; five were co-funded by ISPA, 10 by the 
Cohesion Fund and the remaining by the ERDF, but not as 
major projects; hence they were not subject to an ex ante 
assessment by the Commission services. For these projects, 
according to shared management principles, the national 
managing authorities are responsible for appraising grant 
applications, deciding the amount of the grant and follow-
ing-up project implementation.

24.
The over-utilisation of some sorting plants is sometimes 
also associated with significant and unexpected changes 
in economic activity and people’s behaviour in terms of 
waste sorting that could not be forecast beforehand. 

25. (a) 
As explained in the reply to Observation 24, it is difficult 
to forecast the composition of collected waste. This in turn 
has  consequences  for  per formance  in  terms  of  produc-
tion of compost. Nonetheless, the performance should be 
assessed on a global basis: for instance, for one project, 
the Member State stated that the greater biodegradability 
of waste led to a reduction of the quantity of compost pro-
duced but resulted in the production of biogas .

Member  States  have  then  the  primary  responsibility  for 
the  selection,  implementation  and  monitoring  of  ERDF 
projects.

25. (b)
The Commission refers to its reply to Observation 24. 

AUDIT SCOPE AND APPROACH

17.
One of the sampled countries, Romania, was not a Mem-
ber of the EU in the 2000–06 period but only from 2007 
onwards. The ISPA regulation was applicable for pre-acces-
sion countries.

For ISPA/Cohesion Fund projects, the fulfilment of project 
objectives is checked against objectives (set in the Com-
mission decision) by the Commission services during the 
project closure procedures. 

The Commission services take note of the Court’s observa-
tion and will consider it during the project closure pro-
cedure  when  verifying  the  information  provided  by  the 
Member State.

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

REPLY OF THE COMMISSION25. (c)
There are no EU legal obligations for Member States to set 
up compost standards as these were not specified by the 
legislator. 

There are no EU harmonised standards for compost. Please 
refer  to  the  2010  communication  from  the  Commission 
on  future  steps  in  bio-waste  management  in  the  Euro-
pean Union (COM(2010) 235 final) at http://ec.europa.eu/
environment/waste/compost/developments.htm.  More 
specifically, end-of-waste criteria for biodegradable waste 
are being considered by the Commission.4 

25. (d)
For the two projects operating below their capacity, the 
Commission services take note of the Court’s observation 
and will consider it during project closure procedure when 
verifying the information provided by the Member State.

The over-utilisation is extremely limited in one of the cases 
referred to. Furthermore, the Member State informed the 
Commission  that  current  plans  provide  for  the  installa-
tion of a new composting plant to meet the needs of the 
region. For the second case, in spite of the increase of the 
capacity of the plant, there is a higher production of waste.

58

26.
The sustainability of the action co-financed by the EU is 
a crucial  principle  of  the  EU  assistance.  Member  States 
have  to  guarantee  that  the  projects  are  operable,  func-
tional and comply with EU policies:

 — In the context of closure of ERDF programmes, Member 
States are required to submit to the Commission, to-
gether with the closure documents, a list of unfinished 
and non-operational projects and have up to 2 years 
(31 December 2012) to submit information about com -
pletion of these projects. If, by then, projects are still 
not completed then the Commission will ensure that 
the Member State recover the funds concerned or will 
apply financial corrections.

 — In the case of the Cohesion Fund, the closure process 
requires reporting on the investment in the final report 
which includes an initial assessment whether the re-
sults expected are likely to be achieved. For a period of 
3 years after the final payment by the Commission, the 
Member State authorities responsible have to provide 
all supporting documents regarding expenditure and 
checks on the project.

The project located in Puglia is in the list of unfinished/
non-operational projects. Moreover, following a Commis-
sion request for information, the managing authority of the 
operational programme for Puglia 2000–06 informed the 
Commission services on 7 March 2012 that the contract for 
the operation of the project IT-PU4 had in the meantime 
been awarded and entered into force on 20 July 2012.

27. (b)
According to the Member State, the objectives of the pro-
ject  did  not  include  the  production  of  compost  but  of 
stabilised waste or off-specification compost (waste). In 
view of the structure of the plant, the project could not 
be authorised to produce quality compost (secondary raw 
material) on an industrial scale but only in an experimental 
capacity as was the case at the time of the Court’s on-the-
spot inspection. Consequently, the waste produced is not 
expected to satisfy Italian legal requirements for fertilisers.

4  This communication concludes that ‘standards for compost and digestate 
should be established to enable their free circulation on the internal market 
and to allow using them without further monitoring and control of the 
soils on which they are used’ (p. 7). The ‘end of waste’ procedure under 
the waste framework directive could be the most efficient way of setting 
such standards. The Commission is starting work to assess the technical 
basis for a possible proposal. Standards for compost are being elaborated 
in the context of end-of-waste criteria (technical drafts being prepared to 
be adopted, if appropriate, in the course of 2013). For more information on 
recent developments please see  http://susproc.jrc.ec.europa.eu/activities/
waste/index.html.

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Box 4 — First paragraph
The Commission services take note of the Court's observa-
tion for the four plants, and will consider it during closure 
procedures when verifying the information provided by 
the Member States (see also reply to Observation 26).

28. (b)
For  one  landfill  site,  according  to  information  from  the 
M ember  State,  the  per for mance  had  been  inter  alia 
affected by hydrological conditions but works were under-
taken to address these issues.

Box 4 — Third paragraph
Regarding  the  sor ting  and  composing  plant  of  Linares 
in  Spain,  the  Member  State  indicated  as  a  reply  to  the 
Court observation that the low accomplishments of the 
targets  was  inter  alia  due  to  technical  issues  caused  by 
hydrologic al conditions. The composting process had been 
stopped in order to build some works to control the hydro-
logical  conditions. This  fact  has  had  also  an  impact  on 
the quantity of waste that had to be landfilled. According 
to the Member State, works were undertaken to address 
these issues.

28.
The landfill biodegradable diversion targets are to be met 
at national level. The first target was fixed from July 2006. 
The Commission is currently investigating the implemen-
tation of the current landfill diversion targets and EU Pilot 
cases5 have been launched accordingly. 

28. (a)
For one landfill, without pre-treatment system, only 31% 
of the waste deposited contained organic matter. Moreo-
ver, the ratio of population who had no access to separate 
collection of organic waste has decreased from 69 % to 
35 % in 2010. So the content of organic waste landfilled 
has been decreasing.

In  any  case,  the  Commission  ser vices  take  note  of  the 
Court’s  observation  and  will  consider  it  during  the  pro-
ject’s closure procedure when verifying the information 
provided by the Member State (see also reply to Observa-
tion 26).

For the other facility, the Commission understands from 
the Member State that the significant quantities of undif-
ferentiated waste coming from outside the area affect the 
performance. 

29.
The Commission refers to its reply to Observation 26 for 
the  plant  which  was  not  yet  in  operation  at  the  time  of 
the audit.

Common reply to Observation 30 and Box 5
Note is taken of these findings. To the extent the relevant 
provisions of the landfill directive on landfill gas control 
have been violated, the Commission will investigate the 
matter with the Member States concerned through the EU 
Pilot scheme.

For the Italian project mentioned in Box 5, the Commission 
services take note of the Court’s observation and will con-
sider it during the project’s closure procedure when veri-
fying the information provided by the Member State (see 
also reply to Observation 26).

With regard to the Romanian project mentioned in Box 5, 
the Commission notes that when assessing the documents 
submitted by the Romanian authorities in order to fulfil the 
specific conditions laid down in Article 8 of the Financ-
ing Memorandum, the environmental permit issued for the 
ISPA project by the national competent authority provided 
for ‘installations for collection and flare of landfill gas’ for 
the new landfill as well as for a monitoring programme on 
the ‘quantity and quality of the landfill gas on the repre-
sentative sections of the landfill’.

5  The EU Pilot is a system for the exchange of information between the 
Commission and Member States aiming to find solutions to potential 
breaches of EU law without the need to start infringement proceedings.

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REPLY OF THE COMMISSION60

Common reply to Observations 31 and 32
The landfill directive does not provide for quantified limits 
for odour emissions to be respected, but it provides a gen-
eral requirement6 whereby landfill operators are requested 
to  minimise  nuisances  such  as  odours.  For  one  project, 
complementary equipment (several fans and a biological 
filter) was added to avoid odour problems, according to 
the relevant permit at national level. 

The Commission services take note of the Court’s observa-
tion and will consider it during project closure procedure 
when verifying the information provided by the Member 
State (see also reply to Observation 26).

Common reply to Observations 33 and 34
The Commission acknowledges that the issue concerning 
the closure and after-care costs is a systemic problem, in 
need of a global approach. 

The Commission will open discussions with Member States 
at technical level. 

In the framework of cohesion policy, the 2007–13 applica-
tion form for major projects required applicants to dem-
onstrate that operating and maintenance costs including 
replacement costs will be covered over a given reference 
period  to  ensure  sustainability  of  the  project.  Residual 
value which can be defined as the virtual liquidation value 
must also be considered in the financial analysis of major 
projects.

The Commission services take note of the Court’s observa-
tion and will consider it during the project closure pro-
cedure  when  verifying  the  information  provided  by  the 
Member State.

Common reply to Observations 37 and 38
There  is  no  legal  reporting  obligation  at  regional  level: 
directives and their requirements, including targets, are 
addressed to the Member States.

Member States have to report on progress on the achieve-
ment  of  the  recycling  and  recover y  targets  for  munici-
pal  waste  under  the  2008  waste  framework  directive  at 
national level; reporting has started in 2012.

Nevertheless, the Commission has put in place the collection 
of regional municipal waste statistics at EU level as a new 
activity in 2010. The Commission applies the quality frame-
work as established for the production of annual municipal 
waste statistics, which are being produced since 1995.

The data collections on municipal waste are provided by 
Member  States  on  a  voluntary  basis  in  the  frame  of  the 
Commission’s annual statistical work programme.

Member States should report regularly on the achievement 
of the targets set in waste stream-specific EU directives.

The Commission is continuously working on the improve-
ment of data quality by producing guidance documents, 
training material and through the organisation of work-
shops with data producers from Member States.

Waste statistics and derived indicators are published on the 
Commission's website (http://ec.europa.eu/eurostat/waste).

6 

In its Annex I, point 5

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Common reply to Observations 40 and 41
The EU legislation applicable during the auditing period 
contains no legal requirement on separate collection. The 
2008 waste framework directive requires Member States to 
set up separate collection for at least paper, glass, metal 
and plastic by 2015. The legally binding waste hierarchy 
positions landfilling at the bottom of the waste manage -
ment  treatment  options.  In  line  with  the ‘Roadmap  to 
a resource efficient Europe’ (COM(2011) 571 final), by 2020 
landfilling should be minimised to non-reusable and non-
recyclable  waste.  Finally,  the    landfill  targets  are  estab-
lished at national level and not at regional level.

42.
As explained in the Court’s footnote, the relevant targets 
set in the EU waste legislation are national based. 

43. (b)
The Commission has initiated infringement proceedings, 
inter alia, against the four Member States subject to the 
audit for the existence of illegal landfills in their territory.

44. 
The Commission initiates infringement proceedings when-
ever such illegal practices are established. 

44. (a)
At the time the projects were implemented, there was no 
EU legal requirement whereby biodegradable waste had to 
be collected separately. 

Article 22 of the 2008 waste framework directive, encour-
ages Member States to practice the separate collection of 
biowaste. However it is not a legal obligation. 

47.
Publicity measures, including awareness campaigns pro-
moted directly by the operator of the system are compul-
sory for all projects co-financed by the Cohesion Fund or 
ERDF.  For  the  2000–06  Cohesion  Fund  projects  this  was 
verified at closure via the final reports.

48. (b)
It is the responsibility of the national/regional/local com-
petent authorities to ensure that information campaigns 
are carried out to raise the awareness of the population on 
the waste management practices and infrastructure avail-
able. However, it is recognised that sustained efforts are 
needed in order to ensure full participation of the popu-
lation to ensure the success of the waste collection and 
overall waste management. 

Furthermore, Romania obtained a 4-year derogation for the 
biodegradable diversion targets and therefore has only to 
be compliant by 2020. 

50.
The Commission refers to its reply to Observation 44 (a).

52.
The Commission refers to its reply to Observation 44 (a).

In  EU  waste  legislation  there  was  no  legal  requirement 
whereby compost standards had to be adopted.

Furthermore, end-of-waste criteria for biodegradable waste 
are being considered by the Commission. 

Common reply to Observation 53 (a) and (b)
The Commission concurs that the use of economic instru-
ments will help Member States in the implementation of 
the ‘polluter pays principle’ enshrined in the Treaty on the 
Functioning of the European Union7.

These  economic  instruments  will  help  Member  States 
to  achieve  the  targets  set  out  in  the  the ‘Roadmap  to 
a resource  efficient  Europe’  (COM(2011)  571  final).  The 
ex perience  of  the  best  per forming  Member  States  has 
shown that appropriate economic instruments are essen-
tial to improve their waste management record. Their waste 
management recipe is simple: make the first steps of the 
waste  hierarchy  more  economically  attractive  for  oper-
ators and more rewarding for citizens e.g. ‘pay as you throw’ 
schemes.

7  A recent study (http://ec.europa.eu/environment/waste/pdf/final_
report_10042012.pdf ) carried out on behalf of the Commission suggests 
that  economic  instruments  (e.g.  landfill  taxes,  extended  producer 
responsibility and ‘pay as you throw’ schemes) are instrumental and efficient 
in achieving recycling targets.

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

REPLY OF THE COMMISSION62

55.
According  to  the  regulator y  framework  on  Structural 
Funds, there was no obligation on Member States to pro-
vide information on such instruments. 

During the 2000–06 and 2007–13, no ex ante condition-
ality mechanism (as currently envisaged for 2014–20) as 
an enforceable legal instrument was built into cohesion 
 policy funding by the legislator, allowing rejecting a pro-
ject on grounds of insufficient supporting measures such 
as financial measures. 

55. (a)
In particular, the 1975 waste framework directive did not 
foresee any requirements on the use of economic instru-
ments. However, the 2008 waste framework directive states 
that  Member  States  may  describe  the  use  of  economic 
instruments in their waste management plans. 

56.
There  was  no  specific  legal  provision  in  the  cohesion 
policy regulations linking EU funding with provisions on 
implementation reports in EU waste legislation. 

The Commission has proposed ex ante conditionalities for 
the cohesion policy 2014–20. As regards waste manage-
ment, one criterion in the waste conditionality requires the 
Member States to provide waste management plans com-
pliant with the requirements of the 2008 waste framework 
directive so that Member States will no longer be able to 
provide incomplete reports and at the same time benefit 
from structural measures.

Common reply to Observations 57, 58 and 59
The ‘polluter pays principle’ is taken into consideration by 
the Commission for the Cohesion Fund and major projects, 
through the inclusion of tariffs (user charges) into the cal-
culation of the rate of assistance. 

The application of this principle needs to be seen in con-
junction with the ‘affordability principle’. For the revenue-
generating  projects,  the  granted  rates  of  assistance  are 
based on a balanced approach taking into account several 
elements such as the ‘polluter pays principle’, affordable 
tariffs  and  effectiveness  as  part  of  the  analysis  of  wider 
costs and benefits, as prescribed in the ‘Cost–benefit analy-
sis’ (CBA) guide published by the Commission in 2002 and 
updated in 2008.

The Technical  Paper  1 ‘Application  of  the  polluter  pays 
principle’ issued in 1999 encourages a wider application 
of the principle by the differentiation of rates of Commu-
nity assistance, while avoiding setting lower rates of assis-
tance for Member States who integrate the ‘polluter pays 
principle’  into  co-financed  operations  than  for  Member 
States who do not. It only provided indicative guidance. It 
is stated in this technical paper that the application of this 
principle ‘must be compatible with the goals of economic 
and social cohesion’, that ‘its development should be pro-
gressive’ and that ‘it should take into account the social 
acceptance of charging’. It is also explicitly underlined that 
‘it is therefore important not to see application of the pol-
luter pays principle in isolation’. It therefore leaves room for 
an adaptation of the suggested rate of assistance based on 
the specific conditions of each project.

60.
Article 14 of the waste framework directive requests the 
costs of waste management to be borne by the original 
waste producer, to be defined at national level. 

63.
Member States are requested to adopt waste prevention 
programmes by 12 December 2013. Furthermore, waste 
prevention will be addressed by the Commission in accord-
ance with Article 9 of the waste framework directive that 
provides that, by the end of 2014, the Commission shall 
submit  to  the  European  Parliament  and  Council  reports 
accompanied if appropriate by legislative proposals inter 
alia  on  waste  prevention  and  decoupling  objectives  for 
2020.

Common reply to Observations 64 and 65
The treatment of waste needs to reduce as far as possible 
negative effects of waste on the environment and human 
health as well as being in line with resource efficiency prin-
ciples. The Commission acknowledges that the issue con-
cerning the concept of treatment is a systemic problem in 
need of a global approach.

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REPLY OF THE COMMISSION63

CONCLUSIONS AND RECOMMENDATIONS

69.
In the framework of projects co-financed by the cohesion 
policy, there was no legal obligation for the Commission 
to  check  the  appropriateness  and  assess  on  substance 
the  waste  management  plans  or  to  impose  the  inclu-
sion of supporting measures when assessing operational 
programmes. 

At the moment of the projects’ approval and their imple-
m e n t a t i o n ,   s e p a r a te   c o l l e c t i o n   w a s   n o t   a n   E U   l e g a l 
requirement. 

The Commission has proposed ex ante conditionalities for 
the Cohesion Policy 2014–20. As regards waste manage -
ment, one criterion in the waste conditionality requires the 
Member States to provide waste management plans com-
pliant with the requirements of the 2008 waste framework 
directive so that Member States will no longer be able to 
provide incomplete reports and at the same time benefit 
from structural measures.

I n  accordance  with  the ‘Roadmap  to  a  resource  effi -
cient Europe’ (COM(2011) 571 final), the Commission will 
develop  policy  aiming  at  minimising  the  landfilling  of 
waste while increasing the recycling rates. To this end, the 
implementation of economic instruments e.g. landfill tax, 
and ‘pay as you throw’ schemes related to waste separate 
collection are regarded as crucial for success. 

Common reply to Observations 70 (b) and (c)
National/regional  integrated  approaches  in  the  area  of 
waste management are essential to increase performance 
of waste facilities. 

71.
The Commission is currently investigating the implementa-
tion of the landfill diversion targets through EU Pilot cases. 

72.
The Commission acknowledges that the issue concerning 
the setting-up of financial securities to cover closure and 
after-care costs is a systemic problem in need of a global 
approach.

The Commission will open discussions with Member States 
at technical level.

The Commission has initiated infringement proceedings 
against Italy for sending untreated waste to a landfill (not 
part of the Court’s sample), which is at the stage of Rea-
soned  Opinion. This  infringement  case  could  reach  the 
Court of Justice of the Europepan Union, in which case, 
the  Commission  would  expect  the  Court  in  its  ruling  to 
clarify the meaning of ‘treatment’ as laid down in the land-
fill directive.

Should the case never reach the Court of Justice, the Com-
mission would envisage addressing the issue at technical 
level with the Member States as a first stage.

Common reply to Observations 66 and 67
There are no EU legal obligations for Member States to set 
up compost standards as these were not specified by the 
legislator. 

The 2010 communication from the Commission sets out 
the future steps on bio-waste management in the Euro-
pean Union (COM(2010) 235 final)8.

68.
The Commission acknowledges that the issue concerning 
the closure and after-care costs is a systemic problem, in 
need of a global approach. The Commission will open dis-
cussions with Member States at technical level.

8  This communication concludes that ‘standards for compost and digestate 
should be established to enable their free circulation on the internal market 
and to allow using them without further monitoring and control of the 
soils on which they are used’ (p. 7) (http://ec.europa.eu/environment/
waste/compost/developments.htm ).The ‘end of waste’ procedure under 
the waste framework directive could be the most efficient way of setting 
such standards. The Commission is starting work to assess the technical 
basis for a possible proposal. Standards for compost are being elaborated 
in the context of end-of-waste criteria (technical drafts being prepared to 
be adopted, if appropriate, in the course of 2013). For more information on 
recent developments please see http://susproc.jrc.ec.europa.eu/activities/
waste/index.html.

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REPLY OF THE COMMISSION64

Recommendation 1 (b)
An ex ante conditionality linked to the provisions of the 
waste framework directive is included in the Commission’s 
proposed common provisions regulation 9 for the 2014–20 
programming period.

73.
No targets had been set at regional level. 

The Commission has put in place the collection of regional 
municipal waste statistics at European Union level as a new 
activity in 2010. 

The Commission applies the quality framework as estab-
lished for the production of annual municipal waste statis-
tics, which are being produced since 199510.

74. (a)
At the time the audit was carried out the EU waste man-
agement  hierarchy,  strengthened  by  the  revised  waste 
framework directive (2008/98/EC) promoting prevention 
as the best waste management option, was not yet legally 
binding. 

During the period observed by the Court (2000–09) the per 
capita generation of municipal waste increased in 16 Mem-
ber States, decreased in nine and remained unchanged in 
two.

74. (b)
The EU legislation applicable during the auditing period 
contains no legal requirement on separate collection. The 
2008 waste framework directive requires Member States to 
set up separate collection for at least paper, glass, metal 
and plastic by 2015. The legally binding waste hierarchy 
positions landfilling at the bottom of the waste manage -
ment  treatment  options.  In  line  with  the ‘Roadmap  to 
a resource efficient Europe’ (COM(2011) 571 final), by 2020 
landfilling should be minimised to non-reusable and non-
recyclable waste. Finally, the landfill targets are established 
at national level and not at regional level.

74. (c)
The Commission initiates infringement proceedings when-
ever such illegal practices are established. 

Recommendation 2 (a)
The  Commission  suppor ts  this  recommendation  and 
encourages Member States to establish public databases 
on waste management. A framework is provided by the 
Commission proposal for a shared environmental informa-
tion system (SEIS)11. Waste statistics and derived indicators 
are published on the Commission website12.

Recommendation 2 (b)
Concerning municipal waste, the Commission has estab-
lished since 1995 a system for the collection and compi-
lation  of  data  at  national  level  on  a  voluntary  basis  and 
applies  the  quality  framework  for  official  statistics. The 
Commission has put in place a voluntary system for the 
production of regional level statistics since 2010.

Recommendation 2 (c)
The Commission has proposed ex ante conditionality for 
the cohesion policy 2014–20. As regards waste manage-
ment, one criterion in the waste conditionality requires the 
Member States to take the necessary measures to achieve 
the  2020  targets  as  required  by  the  waste  framework 
directive. 

75.
The  Commission  agrees  with  the  Cour t  that  suppor t-
ing measures help in maximising the effectiveness of EU 
funding.  During  the  2000–06  and  2007–13  periods,  no 
ex  ante conditionality mechanism as an enforceable legal 
instrument was built into cohesion policy funding allow-
ing requesting detailed information on these measures or 
rejecting a project on grounds of insufficient supporting 
measures.

76.
There was no legal obligation for the 2000–06 period for 
the  Commission  to  impose  the  inclusion  of  supporting 
measures.

9  COM (2011) 615 final/2 of 6 October 2011, as amended on 14 March 2012 
and 11 September 2012

10  http://ec.europa.eu/eurostat/waste

11  http://ec.europa.eu/environment/seis/

12  http://ec.europa.eu/eurostat/waste

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

REPLY OF THE COMMISSION65

Recommendation 3 (b) (ii)
The Commission currently applies the ‘polluter pays prin-
ciple’ and reduced rates of assistance, using a comprehen-
sive approach which takes into account affordability and 
effectiveness.

77. (a)
No waste prevention targets are set in EU waste legisla-
tion. By 12 December 2013 Member States shall draw up 
waste prevention programmes containing waste preven-
tion measures examples of which are provided in Annex IV 
to the 2008 waste framework directive. 

77. (c)
There are no EU legal obligations for Member States to set 
up compost standards as these were not specified by the 
legislator14.

Furthermore, end-of-waste criteria for biodegradable waste 
are being considered by the Commission.

77. (d)
The Commission acknowledges that the issue concerning 
the setting-up of financial securities to cover closure and 
after-care costs is a systemic problem in need of a global 
approach.

The Commission will open discussions with Member States 
at technical level.

76. (b)
The landfill directive biodegradable diversion targets apply 
at national level and not at the regional one.

76. (c)
There are no legal obligations at EU level to set compost 
standards at national level. 

Common reply to Observations 76 (d) and (e)
The Commission concurs that the use of economic instru-
ments will help Member States in the implementation of 
the ‘polluter pays principle’ enshrined in the Treaty on the 
Functioning of the European Union13.

The ‘polluter pays principle’ is being applied in conjunc-
tion with the ‘affordability principle’. The co-financing rates 
granted  are  based  on  a  balanced  approach  taking  into 
consideration both principles, which can lead to differenti-
ated rates of assistance.

Recommendation 3 (a) (ii)
The  separate  collection  will  become  a  legal  obligation 
for a number of waste streams (except for biodegradable 
waste) as of 2015.

Recommendation 3 (a) (iii)
I n  accordance  with  the ‘Roadmap  to  a  resource  effi -
cient Europe’ (COM(2011) 571 final), the Commission will 
develop  policy  aiming  at  minimising  the  landfilling  of 
waste while increasing the recycling rates. To this end, the 
implementation of economic instruments, e.g. landfill tax 
and ‘pay as you throw’ schemes related to waste separate 
collection, are regarded as crucial for success.

Recommendation 3 (b) (i)
The Commission has proposed ex ante conditionality for 
the cohesion policy 2014–20. As regards waste manage-
ment, one criterion of the waste conditionality requires 
the  Member  States  to  establish  waste  prevention  plans 
as  required  by  Ar ticle  29  of  the  2008  waste  framework 
directive.

13  A recent study (http://ec.europa.eu/environment/waste/pdf/final_
report_10042012.pdf ) carried out on behalf of the Commission suggests 
that  economic  instruments  (e.g.  landfill  taxes;  extended  producer 
responsibility; and ‘pay as you throw’ schemes) are instrumental and 
efficient in achieving recycling targets.

14  Please refer to the 2010 communication from the Commission on future 
steps in bio-waste management in the European Union (COM(2010) 235 
final) (http://ec.europa.eu/environment/waste/compost/developments.
htm). The Commission has produced guidelines on applying life-cycle 
thinking to management of biowaste (http://lct.jrc.ec.europa.eu/pdf-
directory/D4A-Guidance-on-LCT-LCA-applied-to-BIO-WASTE-Management-
Final-ONLINE.pdf ).

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REPLY OF THE COMMISSION66

Recommendation 4 (a)
The Commission shall submit by the end of 2014 to the 
European Parliament and Council 15 reports accompanied 
if appropriate by legislative proposals inter alia on waste 
prevention and decoupling objectives for 2020. Waste pre-
vention targets were proposed by the Commission for the 
2008 revision of the waste framework directive; however 
no agreement was reached in the co-decision procedure.  

Recommendation 4 (b)
The Commission has initiated infringement proceedings 
against Italy for sending untreated waste to a landfill (not 
part of the Court’s sample), which is at the stage of Rea-
soned  Opinion. This  infringement  case  could  reach  the 
Court of Justice of the European Union, in which case, the 
Commission would expect the Court in its ruling to clar-
ify the meaning of ‘treatment’ as laid down in the landfill 
directive.

Should the case never reach the Court, the Commission 
would envisage addressing the issue at technical level with 
the Member States as a first stage.

Recommendation 4 (c)
The development of end-of-waste criteria for biodegrad-
able waste is being considered by the Commission. 

Recommendation 4 (d)
The Commission acknowledges that the issue concerning 
the setting-up of financial securities to cover closure and 
after-care costs is a systemic problem in need of a global 
approach.

The Commission will open discussions with Member States 
at technical level.

15  In accordance with Article 9 of the waste framework directive.

Special Report No 20/2012 – Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States achieve EU waste policy objectives?

REPLY OF THE COMMISSIONEuropean Court of Auditors

Special Report No 20/2012
Is structural measures funding for municipal waste management infrastructure projects effective in helping Member States  
achieve EU waste policy objectives?

Luxembourg: Publications Office of the European Union

2012 — 66 pp. — 21 × 29.7 cm

ISBN 978-92-9241-005-6
doi:10.2865/4077

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C

M U N I C I PA L   WA S T E   I F   N OT   CO L L E C T E D,  T R E AT E D   A N D   D I S P O S E D   O F 

PROPERLY CAN CAUSE NEGATIVE ENVIRONMENTAL IMPACTS. AS A RESULT, 

T H E   E U   H A S   I N T R O D U C E D   CO M M O N   S TA N D A R D S   A N D   TA R G E T S   I N 

T H E  F O R M  O F  D I R E C T I V E S  A N D  CO - F I N A N C E S  WA S T E  MA N AG E M E N T 

INFRASTRUC TURES  IN  SPECIFIC  REGIONS.  IN THIS  REPOR T THE  COUR T 

EXAMINED WHETHER THESE INVESTMENTS IN INFRASTRUCTURE HAVE BEEN 

EFFECTIVE AND HAVE HELPED TO ACHIEVE EU WASTE POLICY OBJECTIVES.

EUROPEAN COURT OF AUDITORS