COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2008/98/EC on waste, 94/62/EC on packaging and packaging waste, 1999/31/EC on the landfill of waste, 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and accumulators and waste batteries and accumulators, and 2012/19/EU on waste electrical and electronic equipment
Date: 2014-07-02
Institutions: European Commission
Subjects: air quality, electricity storage device, electronic waste, environmental protection, environmental standard, packaging product, prevention of pollution, public health, soil pollution, storage of waste, vehicle, waste disposal, waste recycling, water pollution













EUR-Lex - 52014SC0207 - EN











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52014SC0207

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directives 2008/98/EC on waste, 94/62/EC on packaging and packaging waste, 1999/31/EC on the landfill of waste, 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and accumulators and waste batteries and accumulators, and 2012/19/EU on waste electrical and electronic equipment /* SWD/2014/0207 final */









COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT

Accompanying the document
Proposal for a
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
amending Directives 2008/98/EC on
waste, 94/62/EC on packaging and packaging waste, 1999/31/EC on the landfill of
waste, 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and
accumulators and waste batteries and accumulators, and 2012/19/EU on waste
electrical and electronic equipment

TABLE OF CONTENT
1............ Procedural
Issues. 8
1.1......... Procedural issues. 8
1.2......... External expertise and
consultation of interested parties. 8
1.3......... Fitness check and
ex-post evaluations. 9
1.4......... Recommendations of the
Impact Assessment Board. 10
2............ Policy
context, Problem definition and Subsidiarity. 12
2.1......... Ex-post evaluation. 13
2.2......... Fitness check – main
lessons learnt 15
2.3......... Progress achieved &
implementation of existing targets. 16
2.4......... Problem definition. 17
2.5......... What are the underlying
causes of the problem?. 19
2.6......... How will the problem
evolve?. 32
2.7......... Who is affected and how?. 33
2.8......... The EU's right to act
and justification. 34
3............ Objectives. 35
4............ Policy
Options. 38
4.1......... Option 1: Ensuring full
implementation of the existing legislation. 39
4.2......... Option 2:
Simplification, improved monitoring and dissemination of best practices. 39
4.3......... Option 3: Measures to
upgrade the EU targets. 42
Executive
Summary
A. Need for
action
Although waste management continues to
improve in the EU, the EU's economy currently loses a significant amount of
potential secondary raw material which is found in the waste stream. In 2010,
total waste production in the EU amounted to 2,5 billion tons. From this total
only a limited (albeit increasing) share (36%) was recycled, with the rest
being landfilled or burned of which around 4 to 500 million tons could be
recycled or reused. The EU thus misses out on significant opportunities to
improve resource efficiency and create a more circular economy, create growth
and jobs, take cost-effective measures to reduce greenhouse gas emissions and
reduce its dependency on imported raw materials.
Without new initiatives to improve waste
management in the EU, significant amounts of valuable resources will continue
to be lost in the coming years. Without a clear perspective for the medium- to
long-term, the EU risks seeing increased investments in inflexible, large-scale
projects focused on the treatment of ‘residual’ waste, which may stand in the
way of the potential to improve resource efficiency though reducing waste
generation at source, and reusing and recycling more of the waste which is
generated. The dissemination of best practices between Member States (MS) will
remain limited and economic conditions will not enough incentive waste
prevention, re-use or recycling leading to the persistence of large divergences
in terms of waste management performances between MS. In addition, the quality
of essential monitoring tools such as statistics on waste generation and
management will remain sub-optimal and a number of reporting obligations will
remain complex without having much added value. 
B. Solutions
On the basis of an in depth analysis of
what has worked and not worked in the past and after extensive stakeholder
consultation, the following options (and a series of sub-options and specific
measures) were retained for more detailed analysis:
Option 1 – Ensuring full implementation:  No
additional EU action apart from compliance promotion
Option 2 – Simplification, improved
monitoring, diffusion of best practices: This includes
measures aimed at: 
•                
Aligning
definitions of key concepts (e.g. ‘recycling’ and ‘reuse’) and remove obsolete
requirements 
•                
Simplifying
measurement methods (only one method to measure 'household waste and similar
waste' target) and reducing reporting obligations
•                
Creating
national registries on waste collection and management and require third party
verification of key data and statistics
•                
Introducing
an early warning procedure to monitor Member States performance and require
timely correcting measures when needed 
•                
Establishing
minimum conditions for the operation of producer responsibility schemes 
Option 3 – Upgrade EU targets: 
No new targets will be proposed under
this option, existing target would be upgraded and clarified for some of them
though obsolete targets would be removed.  
The current performances of the most
advanced Member States and the time which was needed to meet these targets was
taken into account to propose realistic targets and deadlines for all MS while
meeting the main objectives of the 7th EAP.   
Option 3.1 –
Increase the recycling/reuse target for municipal waste: 
­   Low:
60% reuse/recycling target by 2030; 50% by 2025 
­   High:
70% reuse/recycling target by 2030; 60% by 2025 
Option 3.2 –
Increase the re-use/recycling targets for packaging waste:
­   Increased
material based targets between 2020 and 2030 (80% overall reuse/recycling) 
­   Variant:
specific separate target for nonferrous metals (‘metal split’)
Option 3.3 –
Phasing out landfilling of recoverable municipal waste: 
­   Ban
on plastic/paper/glass/metals by 2025 (max 25% landfilling), global ban by 2030
(max 5%)
Option 3.4 – Combination of options 3.1,
3.2 and 3.3 (with further sub-options 3.5-3.7)
C. Impacts of the preferred option
The preferred option is a mix of option
2 and option 3.4 in combination with an extended landfill ban (i.e. option 3.7).
Compared to full implementation, this preferred option will bring several
benefits in terms of: 
·        
Administrative
burden reduction in particular for SMEs, simplification and better
implementation including by keeping targets ‘fits for purpose’.
·        
Job
creation – more than 180.000 direct jobs could be created by 2030, most of them
impossible to delocalize outside the EU. 
·        
Greenhouse
gas emission reduction – around 62 million of tons could be avoided annually in
2030 (443 million between 2014 and 2030) .
·        
Secondary
raw materials will be re-injected in the economy – more than doubling what was
recycled in 2011for municipal and packaging waste.  Proposed measures will
serve as catalyst for ensuring the implementation of all EU targets which will
contribute to cover between 10% and 40% (depending of the material) of the EU
total raw material demand.  
·        
Positive
effects on the competitiveness of the EU waste management and recycling sectors
as well as on the EU the manufacturing sector (better EPR, reduced risks in
terms of raw material access and prices).
·        
Marine
litter levels 13% lower by 2020 and by 27,5% lower by 2030.
The proposed midterm targets will give
the needed clear signal to MS and waste operators so that new strategies and
investments can be adapted on time and with the required certainty.  Past
experience has shown that improving municipal and packaging waste management
while banning landfilling will act as catalyst for the management of all other
type of waste.
D. Follow up
This initiative is included in the
2013/14 Commission work program (WP 2013/40). The review of the targets
responds to the legal obligation to review the waste management targets of
three Directives by 2014 – the Waste Framework, the Landfill and the Packaging
and Packaging Waste Directives (PPWD). The findings of a fitness check on EU
waste five stream directives have been taken into account.
Introduction 
This impact
assessment responds to the legal obligation to review the waste management
targets of three Directives – the Waste Framework Directive (WFD), the Landfill
Directive and the Packaging and Packaging Waste Directive (PPWD)[1]
- see Box 1. It
accompanies a legislative proposal reviewing the targets and including measures
to support their implementation. The focus of this review is related to the
targets included in the 3 concerned Directives covering municipal waste,
packaging waste and construction/demolition waste. Actions to improve the management
of these waste – and particularly municipal waste - are considered as catalyst
for improvements regarding the other waste streams. 
The waste target
review is part of a broader process of reviewing European waste policy, the
other components being a ’fitness check’ of five Directives covering specific
waste streams – including the PPWD[2]
- and new initiatives following the publication of a Green paper on plastic waste.[3]
 As explained below, the PPWD is the only Directive covered by the fitness
check and by the target review. 
Waste
legislation was one of the first pieces of environmental legislation put in
place at EU level: the first Waste Framework Directive was adopted in 1975,
with additional EU texts being adopted since then. In line with the Commission's objective to ensure
the "regulatory fitness" of EU legislation[4], this target
review offers an opportunity to intensify the Commission’s efforts to simplify
the existing legislation and reduce regulatory burdens taking on board relevant
findings from the fitness check, and taking into account of what has or has not
worked. 
Under the combined
pressure of the expected increase of the world’s population and middle class in
emerging economies, a massive extra demand strain is expected on primary
resources in the coming years. This will drive up the prices of commodities,
many of which Europe imports, and may impact on the EU's competitiveness and
balance of trade. [5]

In order to face
this challenge, in 2011 the Commission adopted two key interlinked strategies:
a Communication on raw materials and a Communication on resource efficiency followed
by the Roadmap for a resource-efficient Europe.[6] These
strategies include clear orientations promoting the use of waste as a resource.
This approach has been confirmed in the 7th Environment Action
Programme adopted in November 2013 by the Parliament and the Council.[7]
The target review process will be guided by the relevant 2020 waste-related
objectives of the 7th EAP, namely: 

 Existing waste legislation based on
     a strict application of the waste hierarchy[8] is
     fully implemented in all Member States; 
 Absolute and per capita waste
     generation is in decline and a comprehensive strategy to combat
     unnecessary food waste is developed by the Commission;
 High quality recycling is ensured
     and recycled waste is used as a major, reliable source of raw material for
     the Union;
 Energy recovery is limited to
     non-recyclable materials;
 Landfilling is limited to ‘non
     recoverable’ waste;
 A quantitative reduction headline target
     for marine litter is established, which is supported by source-based
     measures.

These objectives
are to be met by 2020 though derogations already granted for 15 MS in the
context of the Landfill Directive should also be taken into account – see Box 1.
In order to
achieve these objectives and move towards a "lifecycle-driven circular
economy, with a cascading use of resources and residual waste close to
zero", the 7th EAP calls for a better application of
market-based instruments - including extended producer responsibility, for
removing barriers facing recycling activities in the EU internal market and for
reviewing existing waste management targets. This approach is line with the
objectives of the Bioeconomy Strategy aiming at using bio waste streams as
resources.[9]
Improving waste
management will directly contribute to improving resource efficiency which is a
flagship initiative of the EU's structural economic agenda, the Europe 2020
Strategy. A better application of the waste hierarchy leads to new economic
activities and creates jobs – most of them virtually impossible to outsource
outside the Union. Significant GHG emission reduction could be expected from
waste prevention and increased reuse and recycling, while proper waste
management can directly reduce litter, especially in the marine environment
since for most sea regions, up to 80% of litter is transported there from land
by rivers, drainage or wind.[10] 

Box 1: Main
legally binding targets, review clauses and measurement methods
Article
11.2 of the Waste Framework Directive includes two legally
binding targets to be achieved by 2020: a 50% ‘preparation for reuse and
recycling’ target for municipal waste and a 70% ‘material recovery’ target
which includes preparation for reuse, recycling and other material recovery
including backfilling operations for construction and demolition waste. 
Municipal
waste includes waste from households and from similar waste in nature or
composition from other producers. As detailed in Commission Decision
2011/753/EU, 4 calculation methods for verifying compliance with the municipal
waste targets are allowed:
Method 1: Recycling/preparation
for re-use for plastic, metals, paper and glass from household waste;
Method
2:
Same as 1 for household and ‘similar waste’; 
Method
3:
Recycling/preparation for re-use of all household waste; and 
Method
4:
Recycling/preparation for re-use of all municipal waste.
Article
11.4 stipulates that by end 2014 at the latest, the Commission should examine
the existing targets ‘with a view to, if necessary, reinforcing the targets and
considering the setting of targets for other waste streams’. Pursuant to
Article 9 (c) the Commission should propose by the end of 2014 waste prevention
and decoupling objectives for 2020.
Box 1
(continuing)
The
Packaging and Packaging Waste Directive includes an
overall recovery - covering both packaging material recycling and energy
recovery from packaging material - target of 60%, an overall recycling target
of minimum 55% and maximum 80% and material based targets of 60% for glass,
paper and board, 50% for metals, 22,5% for plastics and 15% for wood. 
The
targets apply to all packaging whether ‘primary’-end consumer packaging mainly
collected in municipal waste, ‘secondary’ – grouping packaging or ‘tertiary’ –
transport packaging. These targets had to be met by end 2008 with time derogations
granted to 8 MS to the end of 2012 and to specified times between the end of
2013 and 2015 for 4 other MS. Pursuant to Article 6.5, these targets have to be
reviewed in 2014.  
 The
Landfill Directive requires Member States to reduce
biodegradable waste going to landfills on the basis of biodegradable municipal
waste produced in 1995. By mid-2006 biodegradable municipal waste going to
landfills had to be reduced to 75 % of the 1995 level. By mid-2009 this had to
be reduced to 50 % of this amount, and by mid-2016 to 35%. 14 Member States -
those which relied heavily on landfilling in 1995 - New MS (except Hungary and Slovenia) plus Greece, Ireland, Portugal and the UK - were given a four year extension
period. According to Article 5.2, the targets should be re-examined by mid-2014
in order to ensure a 'high level of environmental protection'. 3 categories of
landfills are defined in the Directive – landfills for hazardous waste,
landfills for inert waste and landfills for non hazardous/non inert waste – with
related acceptance criteria. It is only permitted to landfill waste that has
been subject to a 'treatment' as defined in the Directive.  
1.                      
Procedural Issues 
1.1.        Procedural
issues
The
lead DG is DG ENV. This initiative is included in the 2013/14 work program of
the Commission - reference: WP 2013/40. 
The preparatory
work for this impact assessment started in 2012. An indicative list of issues
to be tackled was developed by the Commission and the first interviews with key
stakeholders started in February 2013. An online public consultation was
launched in June 2013, closing in September 2013. The following DG’s
participated in the 5 meetings of the Impact Assessment Steering Group: SG,
ENTR, CLIMA, JRC, ESTAT. 
1.2.        External
expertise and consultation of interested parties
Several sources
of data and information were used to build this impact assessment: first the
most relevant reports and evaluations were used to make a pre identification of
the success and limits of the EU waste legislation – see Section 2.1 and Error!
Reference source not found.. This also helped to identify the main
problems related to the implementation of the existing legislation and also the
remaining gaps. On this basis, a large stakeholder consultation was undertaken
and in parallel an ‘ex ante’ tool was developed to project waste generation and
management and their possible impacts. 
Evidence base
A consortium led
by Eunomia - was used to gather the evidence required to support this IA. In
addition to this specific contract, a modelling tool was developed: a first
model on municipal waste generation and management was developed by the EEA and
then updated and expanded together with the Commission and with the support of
the same consortium. Beyond this impact assessment, it is the intention to
transform this tool into a permanent ‘reference modelling tool’ for the EU on
waste generation and management to be hosted and regularly updated by the EEA.
Unless otherwise specified, the results used in this IA come from this
supporting study and from the modelling tool.[11] A summary of the
main features of the model is provided in Annex 6. Building on the Eunomia and
EEA modelling, additional analytical work, led by Arcadis, was carried out in
order to assess the impacts on marine litter of the policy options under
consideration – see Annex 7. 
Stakeholder
consultation 
A wide range of
stakeholder consultation was undertaken, including:

 in-depth preliminary consultations
     of key stakeholders, which was used to ensure that the range of issues
     raised by the existing Directives, and the options for addressing them,
     was as broadly-based as possible; 
 an on-line public consultation,
     including dedicated questionnaires for both technical experts and
     citizens;
 a specific seminar focusing on
     SMEs; and
 specific consultations on producer
     responsibility and on marine litter. 

The results of
the consultation on the Green paper on plastic were also taken into account. As
local and regional authorities are key players in waste management, an
‘outlook’ opinion was solicited by the Commission from the Committee of the
Regions. 
More details on
the stakeholder consultation process are provided in Error!
Reference source not found., detailed result per stakeholder
categories of the on line consultation is provided in Error!
Reference source not found. as well as in the relevant parts of the
impact assessment. . In summary, some elements were consistently 'scored' high
by most of the stakeholders and were subsequently reflected in the analysis and
policy choices including the need to: 
·        
move
beyond the recycling targets in the existing Directives while taking into
account the large differences between MS in terms of waste management
performances (stakeholder views on the level of the targets to be fixed is
given in section 4)
·        
take
further measures to restrict landfilling of waste and  limit the incineration
of waste;
·        
improve
the credibility of statistics, improve reporting and monitoring methods, and
improve and clarify existing definitions in the Directives
·        
simplify
and make the targets more consistent
·        
take
additional measures at EU level other than setting targets such promoting the
use of economic instruments and developing EU guidance on EPR schemes
·        
to
take measures to promote the use of economic instruments and to further harmonize
and encourage optimal producer responsibility schemes (EPR) 
The results of
the consultations were taken into account (1) to ensure that the main issues
and problems in relation with the implementation of the existing targets were
properly identified; (2) to narrow the range of options to be considered in
more detail in the final stages of the impact assessment; (3) to ensure that
the main potential impacts for possibly concerned stakeholder were properly
identified and assessed; (4) to 'test' the receptiveness of key stakeholders to
some of the proposed options; and (5) to define possible targets for the
cost/benefit analysis. 
Additional
concrete examples on how the results were taken into account will be provided
in the relevant sections of this IA. Some proposals emerging from the
consultation were not followed such as defining specific additional recycling
targets for biowaste, wood, composite packaging or textile, introduce an
overall target for prevention or re-use,  fixing maximum limits for
incineration – see Section 4. There was also a slight majority in favour of
targets for waste prevention, but a more considered review of the potential in
this regard suggested that setting targets of this nature was difficult given
the low quality of data relating to specific waste streams, and the lack of
comparability in the reporting of statistics on streams such as municipal
waste.
The minimum
standards of the Commission for consultation were met.  
The positions
expressed on waste management by the MS and the Parliament during the
negotiation process of the 7th EAP in November 2012-June 2013 were
also taken into account. In summary, although the midterm objectives of the 7th
EAP relating to waste prevention and management were broadly endorsed, several
MS expressed the need to take into account the large differences between MS
when fixing new targets.
1.3.        Fitness
check and ex-post evaluations  
Fitness check 
As part of the
review of EU waste legislation, a "fitness check" (ex post
evaluation) of five 'mature' Directives covering specific waste streams has
been undertaken, against four main criteria ("effectiveness",
"efficiency", "coherence" and "relevance"). On
top of the PPWD, the fitness check covers: (1) Directive 86/278/EEC on the
protection of the environment, and in particular of the soil, when sewage
sludge is used in agriculture[12];
(2) Directive 96/59/EC on the disposal of polychlorinated biphenyls and
polychlorinated terphenyls (PCB/PCT)[13];
(3) Directive 2000/53/EC on end-of life vehicles[14],
and (4) Directive 2006/66/EC on batteries and accumulators and waste batteries
and accumulators.[15]
Directives recently adopted or reviewed were excluded from the scope of the
fitness check as well as Directives purely related to ‘treatment’ operations
(landfilling, incineration and mining waste operation). 
The fitness
check and the review of waste targets were conducted in parallel and monitored
by the same Commission Steering Group, thus ensuring full coordination between
the two processes and a two-way flow of information. As was the case for the
waste targets review the fitness check was subject to extensive stakeholder
consultation. Taken together the fitness check and the target review provide a
comprehensive assessment of the main legal instruments in the field of waste
management. 
Ex-post
evaluations 
As explained in
section 2.1 below, several sources of data and information on what appears to
have worked or not worked are available on the targets of the Waste Framework
and the Landfill Directives. This includes notably an ex post evaluation
carried out by the EEA in the context of a ‘pilot project’ on better
implementation, a Communication of the Commission evaluating the added value
and remaining challenges related to the Thematic Strategy on Waste Prevention
and Recycling, additional ‘on the field’ information gathered during a recent
compliance promotion exercise aiming at disseminating best practices amongst
the less advanced MS and recent reports on the implementation of the waste
legislation published by the EU Court of Auditors and the European Investment
Bank (see section 2.1). 
All these
sources of information have allowed a clear picture to be gained of the main
barriers preventing MS from making progress but also on the key instruments to
be put in place to improve their waste management. It has also already allowed
the Commission to propose ‘Roadmaps’ to the 10 MS whose performance is weakest,
including a list of recommendations to improve their waste management
situation. These Roadmaps were discussed during seminars in each of the 10
identified MS and additional seminars are already programmed with other less advanced
MS.[16]

1.4.        Recommendations
of the Impact Assessment Board
A draft of this
Impact Assessment was submitted to the Impact Assessment Board on 19th
February 2014.  In its first opinion, the Board made recommendations for
improvements which were included in a revised version. This revised version was
submitted to the Board on  28th February 2014. In its second
(positive) opinion, the Board made additional suggestions to improve the
report. 
In summary, the
recommendations included in the first Board opinion were taken into account as
follows:  
(1) Improve the
problem definition and clarify the baseline 
The economic
rationale for waste recycling has been strengthened in the problem analysis
(section 2.5.1) and the analysis of the impacts (section 5.1.1). 
References to
and relevant findings of the fitness check have been included in new sections
(sections 1.3 and 2.2) as well as in other parts of the text when relevant. The
effectiveness of the EU targets - including the given time derogation to some
MS - is discussed in sections 2.1 (ex-post evaluation) and the new section 2.2
(main lessons learnt from the fitness check).  The main difficulties of the few
MS not meeting the current targets and more generally of the poor performing MS
are summarised in introduction of section 2.5 on the causes of the problem. The
problem definition has been clarified notably by renumbering the sections
related to the causes of the problem. More emphasis has been given to issues
related to governance on the basis of a better explanation of the measures
having contributed to the success of the more advanced MS (section 2.5.1). The
necessity to fix midterm targets is better explained in sections 2.5.1 and 4.4
in introduction of option3.
Additional data
expressed in terms of kg of waste per inhabitant not recycled have been
included in section 2.4. 
(2) Clarify the
proposed options 
In section 4.4
additional efforts have been made to better explain how the diverging MS waste
management performances has been taken into account when fixing new targets and
on what basis the targets have been set. In the same section, it is explained
why the targets should be set at the same level for all MS despite differences
in waste generation and why these targets are considered as feasible and realistic
without applying any time derogation. Subsidiarity aspects of limiting
landfilling at EU level are further discussed in section 2.8. The content of
Option 2 is clarified in section 4.2 by better explaining the practical
measures to be taken to implement the proposed actions. The relationship and
coherence between the targets and the proposed measures is further detailed in
sections 4 and 6.3.  Options have been renumbered following the suggestion of
the Board.        
(3) Improve the
assessment of impacts 
A more clear
reference to the cost and benefits associated to each treatment technology is
provided in Section 5.1 and in Error!
Reference source not found. and additional explanations are
provided in the high costs associated with the full implementation scenario in
Section 5.2. Distributional impacts among different MS are further detailed in
Section 5.2 and additional data on raw material access is provided in Section
6. Additional efforts have been made to try to quantify the impacts of the
proposed measures on administrative burden – see Section 5.2. Additional
explanations have been included in Section 6 on the formulation and the weight of
the criteria for comparing the options and the main challenges linked with the
implementation of the proposed measures have been identified in the same
section as well as how they can be addressed. 
 (4) Better
present stakeholder views
The different
stakeholder views have been detailed particularly regarding the type and the
level of binding targets and more details have been included on how the
stakeholder views have been (or not) taken into account (Sections 1.2, 4 and
Annex 3).  A new Annex has been added (Annex 4) with the detailed results of
the on line stakeholder consultation summarising for each question the position
of the main stakeholders groups. A summary on how stakeholder views have been
taken into account has been inserted in section 1.2.   
In addition, the
recommendations of the Board on the presentation of the report were also
followed, for instance the sections on the current targets and the present
situation was simplified and the options were presented in a more intelligible
way for a non expert reader. Additional improvements have been included at several
places of the document following the technical comments provided by the Board. 
The
recommendations of the second Board opinion were taken into account as
follows:  
(1) Clarify the
problem definition and the need for new midterm targets
Additional explanations
on how setting new upgraded midterm targets for 2030 will address some of the
problems identified (governance, lack of public awareness, lack of use of
appropriate economic instruments) were included in section 6.4. 
In section 2.5.1
the relation between the economic conditions and how the targets were fixed in
the past is better explained though in section 4.3 the link between the need of
targets and the economic rationale is developed. The main reasons for not
proposing new overall prevention targets were detailed in section 4.3.  
(2) Improve the
options
Additional
justifications for introducing landfill bans at EU level from the subsidiarity
and proportionality point of view were inserted in sections 2.8 and 4.3.  
The main reasons
for rejecting the option of country specific differentiated targets were better
substantiated in section 4.3. This includes additional explanations on the possible
effects on recycling potentials of divergent municipal waste composition between
Member States.  
The practical
implications of imposing a landfill ban on all similar waste were detailed in
section 5.2. Additional information on how the problem of illegal landfilling
will be addressed is provided in section 6.4. In section 5.2 it has been clarified
whether additional impact assessments would be achieved for the proposed
delegation given to the Commission for defining technical requirements
(National registries and third party verification).  
(3) Elaborate
the assessment of impacts 
In section 6,
the options have been compared in terms of efficiency and coherence. The feasibility
of the proposed targets for all MS was further discussed in section 4.3 and 6.4.
The views of the less performing Member States on waste management were better
reflected in section 4.3. Additional information on the impacts on the Member
States of the different scenarios was added in section 5. Additional
explanations were provided on the costs and revenues from recycled materials as
well as on the quality of the materials and its faculty to compete with virgin
raw materials (section 2.5.1). 
(4) Procedure
and presentation 
The differences
between sub options 3 were better explained and option 3.7 was included in the
summary overview in section 4.3. Additional explanations were inserted in
section 5 on how the impacts of the sub options were estimated. Stakeholder
views with regards to some proposed compulsory measures were detailed in
section 4.2. 
In addition,
some factual mistakes were corrected notably for what relates to the assessment
of the impacts of the proposed options on marine litter. 
2.                      
Policy context, Problem definition and Subsidiarity
This section
first summarises the main lessons learnt from the most relevant reports
evaluating ‘a postiori’ (‘ex-post’ evaluations) how the EU legislation has
functioned so far. A massive flow of data and information is available notably
on the management of municipal waste, on the main reasons for success and
failure to implement the waste hierarchy and for meeting or not the EU targets.
This information has been completed on one side by the recent compliance
promotion exercise undertaken by the Commission and by the main conclusions
from the fitness check on the PPWD. In the second part of this section, the
main available statistics on waste management are summarised and compared to
the EU targets.  
2.1.        Ex-post
evaluation 
Achievements and
remaining challenges  
In preparation
of this impact assessment, several analyses have been undertaken to evaluate
the added value, strength/weaknesses of the existing legislation:
1.      In
2011, following a large stakeholder consultation, the Commission adopted a
report evaluating ‘ex post’ whether the objectives of the Thematic Strategy on
the Prevention and Recycling of Waste are met or not, including the attainment
of the main EU targets.[17]
The report highlighted the progress achieved in terms of landfill reduction and
increased recycling at EU level and the role of EU wide quantitative targets.
These targets were considered by the stakeholders involved in the review
process as one of the key drivers for improving waste management in the EU. 
Remaining challenges
in terms of waste prevention as well as in terms of the persistence of large
difference between MS were also identified. For each waste related Directive,
MS performances were compared to available statistics and EU targets
demonstrating that some MS will have to make additional efforts to meet the
targets. Several recommendations were made including promoting measures to
improve the implementation of existing targets notably by developing an ‘early
warning’ procedure, to ensure a proper use of key instruments by MS such as
economic instruments and to improve the use of regional funds. More ambitious
targets were also recommended to move towards a ‘recycling society’ – one of
the key objectives of the Thematic Strategy. The necessity to improve knowledge
on waste management, notably through improved statistics, was also highlighted.

2.      As
one of the results of a ‘pilot project’ launched between the Commission and the
EEA to improve the implementation of key Directives, in March 2013 the EEA
published a report assessing ‘ex post’ the progress achieved on municipal waste
management.[18]  This
report includes an in depth analysis of MS performances which were used in the
context of this IA. In the conclusions of the report, the effectiveness of
targets in driving change was made clear, but large differences between MS
performance were highlighted, showing that European targets are necessary, but
not sufficient, to drive improved outcomes. This is notably the case for the Landfill
Directive for which the report mentioned “The Landfill Directive’s
differentiated, incremental approach to target setting, including intermediate
and long term targets, seems to be a valuable template for EU initiatives. It
has enabled biodegradable municipal waste landfill diversion to be planned in a
gradual fashion, allowing improved waste management systems to be developed”.[19] 
Additional
Regional and National initiatives are necessary to meet the targets and a clear
correlation between the use of a combination of key instruments and MS
performances was demonstrated. These instruments include appropriate waste
management planning, use of economic instruments such as landfill taxes or
pay-as-you-throw schemes, and mandatory separate collection of certain waste
fractions. The report also insists on the need to improve the quality of
statistics and reporting thereof. 
3.      In
2011/2012; following the publication of the report on the Thematic Strategy,
the Commission took the initiative to promote compliance with waste legislation
with a focus on municipal waste management. A ‘scoreboard’ classifying MS
according to several criteria related to their waste management performances
was established. 
The quality and
adequacy of the waste management plans was amongst others assessed for all MS.
This assessment revealed that quantitative targets are used by the vast
majority of MS and Regions as the main basis for establishing waste management
strategies. Without clear quantitative waste management objectives, it is indeed
difficult or even virtually impossible for these MS or Regions to deliver a
consistent and solid planning of the required infrastructures. In that context,
the European targets are recognised and used as the basis for the vast majority
of the National or Regional waste management plans. 
For the 10
weakest performing MS an in depth ‘ex-post’ analysis has been undertaken and
summarised into a ‘factsheet’ including key strengths and weakness of their
waste management system. Then a ‘Roadmap’ including key recommendations to
improve waste management and to meet the minimum targets was issued for each
MS. 
These documents
were discussed with the relevant national authorities in the 10 MS during ad
hoc seminars. The final report[20]
published in April 2013 includes recommendations to meet the EU targets notably
on how to improve statistics, better use of economic instruments, development
of the required infrastructures and separate collection, and improving
governance. Some MS have already revised their National waste management plans
and strategies in response: for example, Greece, Poland and Czech Republic where the introduction of new economic instruments - mainly landfill taxes has
been announced. A systematic follow-up of these seminars is planned at
Commission level as well as the extension of the exercise to at least 4 to 7
additional MS.   
4.      The
European Court of Auditors[21]
published a report in 2012 on the use of Regional funds for municipal waste
management. The Court recommended the promotion of source separation of waste
and the development of related infrastructures, a better application of the
landfill Directive, the imposition of conditions before granting funds to the
MS notably in terms of use of economic instruments such as landfill taxes and a
broader application of the polluter pays principle, the setting up of reliable
waste management databases by the MS, improvements to the regulatory framework
including the development of prevention targets, a clarification of some key
definitions and the dissemination of best practices. The report also highlights
the fact that EU Structural funds have been utilised in recent years with a too
heavy focus on the management of residual waste. These investments have
contributed towards achieving targets to reduce the amount of biodegradable
municipal waste landfilled, but if they become the focus of activity, they risk
undermining the potential for capturing the value of materials in the waste stream,
and limiting the potential for mitigation of climate change through improved
management of waste.
In
conclusion, most of the ex-post evaluations and reports
highlighted that for the vast majority of the Member States and operators
active in waste management, European legislation and particularly the setting
of legally binding targets, has been a key driver to change waste management
practices. For a small number of front running MS, EU legislation was not
considered as the only key driver as most of the policies necessary to achieve
the targets were already in place (if, indeed, the targets themselves had not
already been achieved) by the time they were adopted at EU level. But even for
those few MS the creation of an EU wide waste market was important for instance
to develop new recycling activities based on EU wide waste streams.  
Quantitative
waste management targets are indispensable to establish
robust and action-oriented waste management plans and to foresee, sufficiently
far in advance, the required infrastructure and efforts, for instance in terms
of separate collection. Without practical and measurable targets, these plans
remain vague and risk not acting as a driver for real change. Apart from few
front runner MS, European targets remain the reference for nearly
all MS to establish their waste management plans.  
Time
derogations were given nearly exclusively to MS that joined the European Union
more recently as time was needed for these countries to set up new
infrastructures and new ways of managing waste (as it was the case for the
other MS). As detailed in section 2.3, time derogations were an effective tool
to ensure a realistic implementation of the EU targets. 
2.2.        Fitness
check – main lessons learnt 
As noted in
section 1.3 above, as part of its review of EU waste legislation, the
Commission has conducted a “fitness check” of five waste stream directives
including the PPWD. The (preliminary) findings[22]
- based on in-depth literature review and extensive stakeholder consultation -
indicate that the assessed directives are essentially ‘fit for purpose’. 
Turning to the
PPWD more specifically, it is worth noting that, as regards its effectiveness,
the recovery and recycling targets set out in the Directive have been met by
nearly all MS, with a significant increase over the past 15 years (e.g.
packaging waste recovery rates increased from 53.7% in 1998 (EU15) to 77.3% in
2011 (EU27) and recycling rates from 47.3% to 63.6%). Under the coherence
criterion the fitness check identifies a number of differences between
definitions in the PPWD and those in the Waste Framework Directive. This
concerns for instance the notions of ‘prevention’, recycling’, ‘reuse’ and
‘recovery’ (see Annex 9). Other issues identified by the fitness check
concerning the PPWD include the need to repeal some obsolete requirements, the
effectiveness of producer responsibility systems, the reliability of
statistics, and the relation between separate collection systems and the
quality of the recyclable materials. 
Finally, stakeholder
consultations conducted in the context of the fitness check revealed the
following mainstream views for the PPWD:  

 There is broad consensus to
     maintain separate targets in the PPWD, rather than integrating targets
     into the WFD or splitting them according to their origin (end-consumer,
     commercial or industrial) 
 There was overwhelming support for
     more harmonisation, the development of clear technical requirements and
     statistical standards, and for the PPWD to include more legally binding
     language on the producer responsibility principle.

These
conclusions as well as other findings from the fitness check are reflected in
those parts of the IA relating specifically to the PPWD.  
Other general
conclusions of the fitness check shows that the 5 Directives – have achieved
their main objectives (as regards resource efficiency, protection of the
environment and human health, harmonisation of the internal market) and targets
(as regards recovery, recycling and reuse)[23],
at reasonable costs. They are generally speaking consistent with each other and
the broader EU waste acquis, even though some aspects of these (older) waste
stream directives would benefit from an alignment to the (more recent) Waste
Framework Directive (e.g. as regards the five step waste hierarchy, life-cycle
thinking, extended producer responsibility provisions and certain definitions).
The fitness check also concludes that the directives remain a relevant pillar
of the EU's overall waste policy - with the possible exception of the Sewage
Sludge Directive (dating from 1986) which is considered largely outdated - while
suggesting a number of elements for their further evolution (e.g. more emphasis
on prevention and re-use; addressing challenges triggered by new materials;
eco-design considerations etc). 
2.3.        Progress
achieved & implementation of existing targets  
Progress has
been made during recent years to improve waste management in the MS even though
EU averaged data masks significant differences between MS. 
Table 1 below
summarised the main existing target in the European legislation and how MS are
meeting or not these targets. More details are given on the attainment of each
target by each MS in Annex 4.  In summary, only a limited number of MS are
at risk of not meeting the existing targets without additional efforts. Most
of the MS have either exceeded the existing targets (sometimes by a significant
margin) or are expected to meet the current targets by the date to which the
target applies. Today no infringement procedure is open for non-attainment
of any of the European targets covered by the present review. Nevertheless,
additional information has been requested from a few Member States on the
measures they intend to take to ensure that the targets will be met on time.
This concerns particularly the landfill diversion target.   
Generally
speaking, the EU legislation has driven changes in waste management in
the MS. This is particularly true for the packaging waste and the landfilling
of biodegradable waste: as detailed in
the fitness check and in Table 1 below, the recovery and recycling targets set
out in the PPWD have been met by nearly all MS. Overall recovery and recycling
rates have increased since the adoption of the Directive (e.g. packaging waste
recovery rates increased from 53.7% in 1998 (EU15) to 77.3% in 2011 (EU27) and
recycling rates from 47.3% to 63.6%). Similarly, 23 MS are on good track to
meet the landfill diversion target and landfilling of biodegradable waste has
decreased in all MS following the introduction of the landfill Directive
targets in 1999 (see Error!
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Increased recycling
rates for packaging waste (of which a part is municipal waste) and diverting
biodegradable waste from landfilling have both influenced municipal waste
management in the right direction: municipal recycling rate in 2011 amounted to
40% - an increase of 8 percentage points compared to 2005.  Waste incineration
has increased from 95 kg per capita in 2005 to 111 kg in 2011 of which
89kg/inhab might be considered as ‘energy recovery’. At the same time, landfilling
of municipal waste has decreased from 65% in 1995 to 49% in 2005 and 36% in
2011. In addition to the influence of the landfill diversion target, this
reduction of landfilling seems also linked with social acceptance
considerations: as detailed in section 2.5.1, EU citizens are less and less
prepared to accept landfilling as a way to treat waste. Half of the 31 open
infringement cases for bad application of the waste Directives are related to
illegal landfilling or non-compliant landfills. Several petitions hare open or
have been treated by the EU parliament on the same issue.      
As detailed in Table
1 below, the vast majority of the MS will be able to meet the municipal waste
and the construction and demolition waste targets by 2020. As the targets of
the WFD were adopted in 2008 (and transposed into national legislations in
2010), it is too early to conclude on the influence of the targets on MS
performances for these two specific targets.  Whilst recycling rates vary from
one waste stream to another, overall waste recycling in the EU has increased:
in 2008, waste recycling was estimated at 36,5% (2011) – 38,5% -  indicates a
slight increase of 2 percentage points of the overall recycling rate. Less
waste was sent to landfill: 36% in 2011 compared to 49% in 2005 and 62% in
1995.
For what relates
to prevention, progress have been more limited: at  EU-27 level, total annual
waste generation decreased by 5% between 2006 and 2010 due to the impacts of
the economic crisis, the change in the structure of the economy - shifting
towards a more service-based economy but also changes in reporting methods. It
is difficult to isolate the possible effect of measures taken to favour waste
prevention, or the ‘dematerialising’ of some consumption - for example, music
being downloaded digitally. In most MS total waste generation appears to be
stabilising in the long run. 
Municipal solid
waste generation has now stabilised since the years 2000 around 500 kg per year
and per capita in the EU-27. There is a relative decoupling with consumption -
which increased by 16.3 % between 1999 and in 2007. Large differences persist
between MS - from around 300 to 700 kg per capita - which seem to be due not
only to different consumption levels and  patterns, but also, the varying scope
of wastes being reported as ‘municipal waste’ by MS – see section 2.5.2. 
   || Target || Attainment of the target – summary 
 Municipal waste preparation for reuse and recycling || 50% by 2020 || Target can be met for all MS only if the 4 measurement methods are allowed 
 Construction& demolition waste ‘material’ recovery || 70% by 2020 || 2/3 of MS will meet the target in the short term. Other MS should follow before 2020 
 Amount of biodegradable waste sent to landfill (basis = 1995), 14 MS without time derogation || 50% by 2009, 35% by 2016, or 50% by 2013, 35% by 2020 (14 MS with time derogation) || 23 MS are on track to meet the targets. Additional efforts required for 5 MS   
 Overall recycling target PPWD || 55% by 2008 16 MS with time derogation until 2016 || 21 MS have met the target, the remaining  MS are expected to meet the target on time 
Table
1: Attainment
of EU targets – summary
On the basis of
the achievement of the most advanced MS, and in line with the conclusions of
the fitness check, it is clear that further progress beyond the 2020 targets
are feasible for recycling and reuse of household/municipal waste and for
reducing waste sent to landfill, but also, before 2020, for recycling packaging
waste.
2.4.        Problem
definition
Loss of valuable
materials 
Today, a
significant amount of potential secondary raw material is lost to the European
Union's economy due to due to the fact that waste is not managed as well as it
could be. In 2010 total waste production in the EU amounted to 2,520 million
tons[24],
an average of 5 tons per inhabitant and per year.
Figure
1
shows that from this total only a limited share – 36% or 1,8 ton per year and
per inhabitant - was effectively recycled. The largest share – 37% or 1,9 ton
per year and per inhabitant was simply sent for disposal whether in landfills
or on lands (16% of the total) - or in areas designated for the storage of
mining waste (21% of the total). The remainder was either backfilled - 10% or
0,5 ton per year and per inhabitant, untreated 6%, incinerated 6% of which 4%
with energy recovery, the remaining 5% or 0.25 ton per year and par inhabitant being
disposed otherwise. In other words, around 1620 million tons of waste was lost
for the EU economy; even if, under current technical conditions not all this
waste could have been avoided, reused or recycled. All in all, the remaining
potential for recycling/reuse could be estimated at maximum 600 million tons if
mining waste is excluded as well as soils, what is energy recovered or sent to
backfilling. 
In 2011, municipal
waste represented around 253 million tons or around 500 kg/year and per
inhabitant of which 62% (or 157 million of tons, or 310 kg/year/inhabitant) was
not reused or recycled.  
Figure 1:
Overall waste treatment, Eurostat 2010
Packaging waste
amounted to 80 million tons of which 36% (or 29 millions of tons) were not
reused or recycled. Construction and demolition waste amounted to 860 million
tons in total of which 350 million tonnes of mineral waste – of which 19% or 64
million of tons was not recovered, the rest consisting of excavated soils.
These losses of valuable materials prevent the creation of a ‘circular economy’
aimed at keeping resources within the economy and using waste as the input material
for new products. 
Missed
opportunities for growth and jobs 
Losing this
material means that significant growth and competitiveness potential is not
being exploited through the development of a reuse/recycling industry in the EU:
in 2008 waste management and recycling industries in the EU had a turnover of
€145 billion representing around 1% of the EU's GDP and generating 2 million
direct jobs. European firms have also used this as a base from which to expand
and take up strong positions in the growing global markets for waste
management. Compared to 2008, full compliance with EU waste policy in the
coming years could create an additional extra 400.000 jobs and an additional
annual turnover of € 42 billion.[25] Moving
towards the objectives of the Roadmap on Resource Efficiency could help to
create 526.000 jobs and an additional turnover of € 55 billion.
Competitiveness and
EU dependency on raw material 
In addition to
this midterm stimulus, increased reuse and recycling can pump resources back
into the economy and ensures an at least equivalent, often cheaper and more
reliable access to raw materials - some of them considered as 'critical' -
which are indispensable for EU industrial competitiveness. Raw materials are
considered as essential for the EU industry:  at least 30 million jobs depend
on access to raw materials. [26]

Materials are
one of the most important input costs of European manufacturing companies making
up around 30 to 40 per cent of the sectors' cost structures. [27]
The
EU is not self-sufficient in many resources including for critical raw
materials.[28]
Globally, the Union imports six times more materials and resources than it
exports. For some of these materials, the import dependency is
significant. [29] 
On average, real prices increased by more than 300% between 1998 and 2011 for
resources – see Figure
2. In
general, the prices of commodities are expected to rise due to the expected
increase of the resource demand. 
            Figure
2:
Overall resources price evolution 1979- 2011 [30]
Energy and GHG
emissions, air pollutant emissions 
Improved waste
management can help reduce greenhouse gas emissions directly by cutting GHG
emissions from landfills and indirectly by recycling materials which would
otherwise be extracted and processed. These reductions could occur either
within or outside the EU depending on where the secondary raw materials are
used as input to manufacturing processes. Generally speaking, recycling
material is far less energy demanding than extracting, processing and
transporting virgin raw materials. For example recycling aluminium requires 5%
of the energy needed to extract and process bauxite leading to major efficiency
and competitiveness gains and reducing dependence on imported material. As
detailed in the fitness check, the level of packaging recovery and recycling
achieved by 2004 corresponds to about 10 million tonnes of oil equivalent
and 25 MtCO2-equivalent compared to a scenario where all packaging
waste would be landfilled or incinerated.[31]
Compared to 2004
emissions, it has been estimated that between 146 and 244 Million tons of GHG
emissions could be avoided by 2020 through reinforced application of the waste
hierarchy[32]
representing between 19 and 31% of the 2020 EU target.  Similarly, significant
air pollutant emissions can be avoided: as with GHG emissions, indirect emission
savings linked with increased use of recycled material would also take place,
either within or outside the EU depending on where the secondary raw materials
are used.  
Other impacts  
Improper waste
management can have direct consequences at local level such as landscape
deterioration due to landfilling, local water and air pollution, etc.
Inappropriate behaviour related to waste management is also one of the causes
of littering leading to significant costs, both direct (e.g (beach) clean-up
costs and damage to fishing vessels and fishing gear, especially in the marine
environment) and indirect (e.g. loss of property value and tourism potential in
affected areas). In addition, the accumulation of non-biodegradable waste
–plastic waste in particular - in the oceans has negative consequences on
marine biodiversity and ultimately, for those who consume fish. 
2.5.        What
are the underlying causes of the problem? 
As summarised in
Table
2,
improper waste management is due to a combination of causes. Some of these
relate to the adequacy of EU legislation, others to governance issues
particularly in MS with poor performances in terms of waste management. 
There are significant
differences between the MS and also between regions within MS in
terms of waste management practices - see Figure
3.
This uneven level of performance is partly linked to the time needed for
constructing the required infrastructure, developing at source separate
collection systems, ensuring appropriate information and building the necessary
competences from the local to the national levels. This is particularly valid
for MS having joined the Union more recently but also for some other MS.    
Some MS have not
given enough priority to improving waste management. Generally speaking, in the
less advanced MS the main difficulties are related to a combination of factors
including problems of governance illustrated for instance by the absence of
coordination between the National and the Regional or local authorities, the
lack of public awareness including amongst the decision makers, the lack of use
of appropriate economic instruments making low performing option such as
landfilling cheaper. These MS have often low performing EPR systems in place
making the launching of separate collection more complicated and at full costs
of the public authorities. The absence of midterm targets for the European
Union complicates their task as they are tempted to invest in infrastructures
aiming at just meeting the current targets without forwarding vision.   
Figure
3:
Municipal waste management in 2011[33]
This IA focuses on
the causes on which EU action can have a positive influence. For instance, issues
related to governance can be partly solved through dissemination of best
practices including the use of economic instruments to favour prevention,
recycling and reuse: for instance landfilling often remains the least costly
option which is detrimental to the creation of ‘circular economy’. As also highlighted
in the fitness check for the PPWD, the existing waste legislation could be
further simplified which will help to ensure proper implementation. Monitoring
MS performances can be simplified and improved in a more proactive way. 
And even if all
existing targets are met on time by all MS, there will remain a gap between the
EU aspiration of improving resource efficiency and being less dependent in
terms of access to raw materials and MS waste management performances.  
 Nature of the problem 
Table
2:
Links between problem definition and causes of the problem 
2.5.1.     Issues related to
governance 
In this section
the main success factors of the most advanced MS are identified and by contrast
what is lacking in the less advanced MS is illustrated. This relates mainly to
the use of economic instruments which are vital to meet the targets but also to
a proper organisation of separate collection and an appropriate use of
structural funds. Issues related to social acceptance are also discussed at the
end of this section.  
Economic conditions
  
As pointed out
in several reports including in the conclusions of the fitness check, and by
the Court of Auditors, key instruments and particularly economic instruments
are essential to support the development of the required infrastructure: the
experience of the most advanced MS has shown that appropriate economic
instruments are indispensable to meet the European legally binding targets and
more generally speaking, to create a sustainable recycling industry. 
As illustrated
in Figure 2, prices of primary raw materials - which influence the prices of
secondary materials - fluctuate over time depending on the balance between
supply and demand:

 For some materials, for which price
     levels have been consistently high, the case for separate collection,
     sorting and recycling will remain strong regardless of these fluctuations.
     This is, for instance, the case for some metals, such as copper or
     aluminium; 
 For other materials such as plastic
     bottles or paper/cardboard, these market fluctuations will directly
     influence the economic case for sorting/recycling operations. In some
     years, the sales of the recycled material will be higher than the costs of
     collecting and sorting the material, in other years it will not be the
     case;   
 For a last category of materials,
     the value derived from the sale of recycled materials is not high enough
     to ensure that the costs of separate collection, sorting and recycling are
     lower than the costs of dealing with the material as part of residual
     waste. This is the case for instance for plastic films from the municipal
     waste stream, for which market prices are low, and so the proportion of
     the material being recycled is also low.

Existing targets
in the waste legislation are not linked to these 3 categories of materials.
They   were fixed for priority waste streams from the environmental point of
view but also on the basis of consistent and identifiable waste streams (for
instance collected and treated together) and for which enough data were
available. The 3 categories of material are present in all these waste streams.
In addition, fixing targets on the basis of these categories would not make
sense as recycled material prices are fluctuating therefore some materials are
changing of category sometimes in few weeks. 
The quality of
the materials collected and sorted has also a direct influence on their markets
and on their prices: source separation of waste provides materials of better
quality and higher price. Obviously collection costs tend to increase but it is
more than compensated by the sales of materials and additional savings on the
collection and treatment of mixed waste. This is further detailed in section
5.1.    
Obviously, weak
demand and market price fluctuations present issues for potential investors in
recycling activities, including public operators: public funds are usually
based on annual budgets which are not adapted to market fluctuations. Partly
for this reason, public authorities are often somewhat less interested in
material revenues than perhaps they should be.
Market
fluctuations and low prices for some recycled materials represent clear
barriers for a broader development of recycling activities. In the most
successful MS, key economic instruments have allowed to create more favourable
economic conditions for recycling. 
These key
instruments include: progressive landfill/incineration taxes often
followed by bans on certain type of waste, extended producer
responsibility schemes (EPR) transferring the costs of separate collection,
sorting and recycling to those placing products on the markets, "pay-as-you-throw"
(PAYT) schemes making citizens/companies directly financially responsible for
the ‘unsorted’ waste they generate and systems of subsidies/charges
to favour the development of separate collection and reuse/recycling by the
competent local authorities - mainly the municipalities. These
conclusions are valid for all recyclable waste including packaging waste as shown
in the fitness check.  
Figure
4
shows for instance the relationship between landfilling rates of municipal
waste and the total landfill charge including fees and taxes in the Member
States. As expected, there is a direct influence of the landfill price on the
landfill rates: poor performing MS have all landfill charges below 50-60 € per
ton. On the contrary, MS with lowest landfill rates having all progressively
increased their landfill taxes some of them having supplemented this approach
by the progressive introduction of landfill material based bans. Similar
correlations exist between landfill and incineration charges and recycling and
composting rates.  
Figure 4:
Municipal waste landfilling and landfill costs [34] 
Similarly there
is a large variety of extended producer responsibility (EPR) schemes in
the MS notably in terms of waste covered by EPR schemes: most advanced MS have
developed EPR systems for several types of waste streams. As illustrated in the
fitness check for packaging waste, these EPR schemes are extremely important
to unblock the possible barriers for the development of separate collection.

Properly managed
EPR schemes can provide the required funds to help municipalities to launch
separate collection and sorting operations but also to cover the recycled
materials price fluctuations. EPR mechanisms where the producers essentially
take one the risks associated with material price fluctuations (such that
producers themselves, in supporting the scheme financially, pay lower fees when
material process are high, and higher fees when material prices are low). Such
approaches can help insulate public authorities from the vagaries of market
price fluctuations, and for producers, they pay higher fees at times when they
themselves may be beneficiaries of lower market prices for materials which they
use.      
The variety of
EPR schemes between MS also concerns the rules applied for the control of the
schemes, the level of ‘free riders’ – importers or producers not participating
in the systems, relations with the municipalities, and transfer of the whole
and true costs to those placing goods on the market (producers/importers). 
This has led to
differences in terms of cost effectiveness but also to divergent conditions
imposed on those placing products on the EU market. Generally
speaking, the most efficient EPR schemes are those based on a clear definition
of the responsibilities of the involved actors and a permanent dialogue between
these actors. [35]
As shown in the
following Figure, the best performing schemes are not necessarily the most expensive.
Comparisons between the schemes remain difficult as data are not always easily
available, there is a lack of transparency; some schemes only cover household
packaging, others only commercial and industrial packaging, others both types
of packaging waste; some schemes like in the UK, France or Romania do not cover
the whole collection and treatment costs of waste packaging. Other elements
could also justify this differences of costs/fees paid like geographical
conditions (AT) or differences in labour costs. Nevertheless, as shown in
Figure 13, a margin of progress in terms of cost effectiveness of these EPR
systems seems to exist: for similar levels of recycling rates there is a large
variety of fees paid to the system.  
Figure 5:
Cost effectiveness of EPR schemes – Packaging [36]
"Pay as you
thrown" (PAYT) schemes, if properly applied, have demonstrated their
effectiveness: in the areas where these schemes are in place, citizens are
making efforts to reduce their waste production and at the same time the
participation in separate collection dramatically increases. It has a direct
impact on the amount of residual waste to be treated which is significantly
reduced, leading to a reduction of the waste management costs for the local
competent authorities. The vast majority of the regions meeting high recycling
rates -more than 70% - are applying PAYT schemes. These schemes are not used
widely enough by local authorities: it has been estimated that only 3 MS
have PAYT systems in place in all municipalities although PAYT schemes are
not present at all in 11 MS – most of them with poor performances in terms of
waste management.   
In the most
advanced MS, , local authorities are  incentivised  to launch separate
collection of waste: EPR schemes are  well developed, landfill prices are high
enough, there are  sanctions in case of lack of initiative to favour
recycling/reuse or prevention – notably the application of PAYT systems - and
there is a financial support for the development of the required
infrastructures: By contrast, some MS have put in place very efficient systems
combining penalties and financial support for municipalities: this is the case
for instance in the Walloon Region of Belgium where residual waste has
dramatically decreased (minus 42%) within six years of the application of a system
combing subsidies and charges for municipalities in relation with the amount of
residual waste produced and the application of PAYT systems.[37] 
These incentives are generally missing in the less advanced MS. 
Experience shows
that  some MS are making extremely rapid progress towards meeting the EU
targets by an appropriate use of economic instruments: for instance, Slovenia
already performs better than several EU 15 MS, rapid progress has been seen in
the Czech Republic for packaging waste and Estonia is expected to move from a
situation of 75% landfilling to less than 5% landfilling in less than 7 years
thanks through a clever and ambitious use of economic instruments – See Box 2.   
Box 2:
From 75% to less than 5% landfilling in 7 years, the case of Estonia [38]
Estonia has decided to introduce a
strong waste management policy aiming in the first instance at avoiding waste
landfilling. A progressive increase in the landfill taxes has been sanctioned,
making alternative options such as energy recovery, recycling and MBT
financially more attractive: with tax increases, the price for landfilling went
from 8€/ton in 2001 to 50 €/ton today and is expected to increase to 60-70€ per
ton by 2015. Additional economic instruments such as EPR and deposit-refund
schemes were also applied.
This has attracted private investors, and without
any public financial support, major infrastructure has been put in place to
treat all municipal waste produced in Estonia. The landfill rate was at 74% in
2006, around 68% in 2010 and is expected to drop to a few percentage points in
2013 with the entry into operation of two new MBT facilities and one
Waste-to-Energy facility. In the medium term, the increase in the recycling
rate might imply the necessity to … import waste generated outside Estonia and/or adapt the MBT plant so that separately collected waste could be treated to
increase the overall recycling rates. 
This success story demonstrates on the one hand that
MS having recently joined the EU can, if they implement the best practices
having demonstrated their effectiveness in the past in the most advanced MS,
make very rapid progress. At the same time, the absence of midterm targets at
EU level is detrimental to adequate planning and dimensioning of the needed
infrastructures. 
Use of
structural funds 
Lastly, as
indicated in the recent report from the European investment Bank (EIB) and in
the report of the Court of Auditors[39],
EU funds whether originating from the EIB or from Regional funds have
been so far mainly orientated to the lower tiers of the waste hierarchy
– creation of landfills or incineration capacities. Existing funding procedures
do not really fit with the type and the 'smaller' size investments needed for
prevention, reuse and recycling. 
Issues related
to collection   
The necessity to
improve the quality of the recycled material is another issue
highlighted during the stakeholder consultation and in the fitness check.
According to the WFD, there is already a general obligation/principle for MS to
ensure that 4 waste streams are separately collected (plastic, metals, paper
and glass). This principle is not sufficiently strict to ensure an appropriate
quality of the recycled materials: experience suggests that the best performing
systems are those which keep certain materials separate from others. Glass
should be collected separately to avoid contamination of the other waste
streams. Similarly, paper and cardboard should also be collected separately to
ensure the quality and the value of the material. However, mixed
collection of plastics and metals is not detrimental to the quality of the
materials. Separate collection of biowaste gives excellent results in terms of
organic recycling and that the highest rates of recycling appear to be achieved
through door-to-door collections, where these are practical, and by deposit
refund schemes for instance for beverage containers.[40]
The
absence of coordination between the authorities in charge of waste
collection and those in charge of waste treatment is another reason for
inappropriate design of the waste management strategy leading to poor quality
recycling and increased costs.  As detailed below (section 5.2.1 and Figure
10), collection and treatment costs are linked. It is therefore essential to
ensure a full consistency between the collection and treatment strategies. 
Similarly higher
recycling rates of better quality seems to be met for C/D waste when minimum
sorting is ensured at source at least between the mineral fraction and the
other dry fractions. Some MS have imposed minimum sorting requirements for C/D
waste.  
Social
acceptance 
As illustrated
in a recent report from European investment Bank[41],
the lack of appropriate infrastructure might also be linked in some cases to
the absence of social acceptance of projects related to waste
management. In some countries where there is a significant lack of
infrastructure it has been virtually impossible to designate areas for the
construction of waste management facilities – See Box 3 below. Experience shows
that public opposition seems to be higher against incineration or landfilling
projects then for other facilities such as sorting centre for recycling/reuse
or composting plants based on source separated waste streams.   
Box 3:
Social acceptance – some concrete examples
In
several places, local people have sometimes vigorously campaigned against the
creation of incinerators or landfills. For instance, in Corfu Island it has not yet been possible to open a newly-built landfill - the Lefkimi landfill – due
to violent protests in 2008. This infrastructure was built with the support of
EU funds – a total of €6 million.  In the region of Athens and Thessaloniki,
but also around Naples in Italy, similar protests took place against the
possible opening or extension of landfill sites. In the UK, several projected waste infrastructure – mainly incinerators - were abandoned due to local
opposition including the King's Lynn incinerator as well as infrastructure in
Bradford, Merseyside and Yorkshire. These are just examples of some of the most
recent local opposition against major landfill and incinerator projects. 
2.5.2.     Issues related to the EU
waste legislation 
As pointed out
during the stakeholder consultation but also by the Court of Auditors, the
exiting waste legislation could be further simplified and clarified while
providing a midterm vision. For instance, the legislation includes the
obligation for the MS to respect the waste hierarchy. However, the absence
of clear and smart targets for each step of the waste hierarchy as well as
clear midterm perspectives represents a significant barrier and a clear
problem for appropriate planning of the required investments. In many cases,
the time which elapses between the decision to build new waste management
infrastructure and its actual operation is around 7 years[42],
the period being longer or shorter depending on the nature, and the
acceptability of the infrastructure at local level. Some of the infrastructure
which is built may have a useful of time of 20 years or more. This absence of
clear targets at each step of the hierarchy prevents MS from conveying a clear
vision on an optimal implementation of the hierarchy. 
It has also led
in some MS’s to the creation of overcapacities for instance of
incineration, which, in turn, appears to have lowered the fees paid for
incineration, and so reduced incentives for additional initiatives to be taken
to promote prevention, re-use and recycling. As shown in Figure
6,
four MS have an incineration capacity exceeding 50% of their annual municipal
waste generation, two of them – DK and SE – are even not producing enough
municipal waste to feed existing infrastructures. This situation may be
alleviated if the excess capacity is covered by waste imports from other MS
and/or by feeding the existing capacities with other categories of waste such
as industrial non-hazardous or commercial waste.  Figure 6 shows clearly that
some MS having excess capacities could progressively accept more and more waste
coming from countries still heavily relying on landfilling.  
Nevertheless,
there are clear signals of potential overcapacities which are even more
significant at local level. This is for instance the case in Rotterdam where an
incineration plant was recently closed due to its underutilisation – see Box 3.
Recent information from Germany indicates an overcapacity of incineration of
around 25%. By contrast, as shown in Figure
6,
some MS currently landfilling significant amounts of municipal waste have no
incineration capacities at all. 
Box 3:
Closure of the Rotterdam incineration plant 
The
private company owning an energy-from-waste plant in Rotterdam decided to close
it in 2010 due to the extent of overcapacity - around 10% according to the NL
public authorities - caused by a declining availability of waste. This
incinerator modernized in 1996 had a capacity of 450.000 tonnes. In 2012, the
company stated, "We closed one of our incineration plants in the Rotterdam area. There is overcapacity in Germany and we hope some of our colleagues will follow
suit. We hope more capacity will be taken out of the market. In the end, we
could harm recycling performance. The social importance of incineration will
decrease whilst recycling becomes increasingly relevant and important.”
Figure 6:
Municipal waste incineration capacity per municipal solid waste generation[43]
The absence of
EU midterm targets combined with longer term MS strategies could also lead to
sub optimal investments: for instance several mechanical biological treatment
- MBT- facilities treating mixed waste were created without source separation
of waste. Some of these facilities are leading to modest recycling rates, most
of the output products being landfilled due to their poor quality (contaminated
materials). 
Recent
assessments carried out on the existing waste management plans[44]
clearly shows that in some poor performing MS, investments currently planned
will lead to the creation of several MBT or incineration facilities which will
allow those MS to just meet the existing EU targets (on landfill diversion) but
‘blocking’ these MS into technological choices for, in some cases, 20 years
(lifetime for these facilities). 
This would limit
the perspective of progress for these MS while leading to relatively high levels
of residual waste landfilling. Recycling and re-use rates will remain modest in
these countries for a long period unless one or more of the following occur:

 capacity at these facilities can be
     sold to other countries still short of capacity – this is only possible,
     in principle, for facilities designated as recovery; or
 facilities, such as some MBT
     facilities, are adapted so that the biological treatment part of the
     facility is used for dealing with source separated organic materials; or
 some of the facilities are closed
     before the end of their amortization (and this may represent an additional
     cost).        

As detailed in Error!
Reference source not found., some definitions
are either unclear or not consistent between the concerned Directives - for
instance the notion of ‘recycling’ differs from the Packaging waste Directive
(PPWD) to the WFD The concept of ‘municipal’ waste remains too vague and
leads to divergent MS interpretations and hence widely differing levels of
re-use/recycling. Significant differences exist between MS in terms of
municipal waste generated per capita (between 300 and 700 kg/inhab/year).[45] Part of these
differences could be explained by economic characteristics - individual
consumption levels - but it seems that MS are reporting different realities
under the name ‘municipal waste’. 
The share of
household waste in the municipal waste varies from a MS to another mainly due
to difficulties experienced by MS in separating ‘household waste’ from
non-household waste collected in the same way. Additional effort is needed to
improve reporting on ‘municipal waste’ in order to get a sound basis for
comparing MS performance and ensure that the targets on municipal waste are
established on solid basis.    
Calculation methods
are
too complex
and
not sufficiently harmonised to allow a proper comparison of MS performance. For
instance, 4 calculation methods are permitted for assessing the municipal waste
recycling target - see Box 1. MS had to report by September 2013 on the recycling/reuse
rates according to the method they have chosen for the calculation of the
target. A comparison between the reported recycling rates by the MS according
to the method they have chosen and the recycling rates for municipal waste as
reported annually to Eurostat since the mid-nineties – equal to calculation
method 4 and based on OECD/Eurostat guidelines - shows that depending on the
method chosen, the results could vary significantly: methods 2 and 3 are less
demanding than method 4 - see Table
3. 
The reported
level of achievement under the WFD target can be more than 3 times what is
reported to Eurostat. This is also confirmed when considering recycling
performance based on typical waste composition – recycling rates of 50% could
be met with method 2 although the actual recycling rate for municipal rate
amounts to 25% - by using method 4. 
This means in
practice that the existing flexibility related to the calculation method is
leading to confusion about the actual performances of the MS and their
capability to re-inject recycled materials in the EU economy. 
This comes on
top of problems related to the quality of statistics – for instance ES, LV and Sl are using the method 4 but contrary to FI, they do not have the same recycling
rates than those reported by Eurostat.
   MS having reported (Jan 2014) || ||
 Method chosen by MS || Reported Re-use/recycling rate [1] || Recycling rate - Eurostat [2] || Ratio [1]/[2]   ||
 AT || 2 || Not reported || 62% ||   ||
 BG[46] || 3 || 31% || 6% || 5.2 ||
 CY || 2 || 22,4% || 20% || 1.1 ||
 CZ || 2 || 49,60% || 17% || 2.9 ||
 DE || 4 || Not reported || 62% ||   ||
 DK ||   || Not reported || 43% ||   ||
 ES || 4 || 27% || 33% || 0.8 ||
 FI || 4 || 35% || 35% || 1 ||
 GR || 2 || Not reported || 18% ||   ||
 HU || 2 || 39,80% || 22% || 1.8 ||
 IT || 2 || 38,50% || 33% || 1.2 ||
 LT || 2 || 43% || 21% || 2.0 ||
 LU || 3 || 49,80% || 47% || 1.1 ||
 LV || 4 || 17,8% || 11% || 1.7 ||
 MT || 1 || 23% || 7% || 3.3 ||
 PL || 2 || 18% (2012) || 28% || 0.6 ||
 PT || 2 || Not reported || 20% ||   ||
 SE || 2 || 62% || 50% || 1.2 ||
 SI || 4 || 34,20% || 40% || 0.9 ||
 SK || 2 || 13,38% || 11% || 1.2 ||
 UK || 3 || 43% || 39% || 1.1 ||
Table
3:
Reported recycling/reuse rates by MS and Eurostat recycling rates 
The
landfill diversion target - based on biodegradable waste produced in
1995 - opens the door to interpretation from the MS on what should be
considered as biodegradable waste and on what was the 1995 level of landfilling
of this type of waste. This increases the uncertainties around this target.
Similarly the absence of a practical definition of the notion of 'treatment'
makes it difficult to verify whether waste is actually treated before being
landfilled.   
The measurement
method for C/D – construction and demolition – waste also raises questions.
The WFD imposes a 70% target of ‘material recovery’ which includes recycling
but also ‘backfilling’[47]
which is extremely difficult to monitor in practice. Error!
Reference source not found. in Error!
Reference source not found. and Table
4
below illustrate the differences between the material recovery rates as
reported by MS, the rates calculated by Eurostat and the relative importance of
backfilling.
Backfilling
represents an important share of the reported data in some MS: on the basis of
the Eurostat data, 12 MS reported backfilling rate between 0% and less than
0,5%, 6 MS reported backfilling rates between 1,15 and 20% - 5 MS reported
backfilling rates higher than 20%. 
 Member State || Material recovery rate                                         of which backfilling 
 Reported by MS || Eurostat || Reported by MS || Eurostat   
 AT ||   || 91,8% ||   || 0% 
 BE ||   || 73,6% ||   || 0% 
 BG || 21% || 61,6% ||   || 0% 
 CY ||   || 0,32% ||   || 0,32% 
 CZ || 86,4% || 91,1% || 30,8% || 35,33% 
 DK ||   || 82,5% ||   || 0% 
 DE ||   || 95,3% ||   || 9,4% 
 EE ||   || 96,4% ||   || 9,3% 
 ES ||   || 64,8% ||   || 23,7% 
 FI || 33% || 5,5% ||   || 0% 
 FR ||   || 66% ||   || 7,6% 
 GR ||   || 0% ||   || 0% 
 HU || 60,2% || 60,7% ||   || 7,5% 
 IE ||   || 96,9% ||   || 30,14% 
 IT ||   || 96,9% ||   || 1,1% 
 LT || 65% || 73,2% ||   || 0% 
 LU || 90,8% || 98% ||   ||  ? 
 LV ||   || 90,8% ||   ||  ? 
 MT ||   || 14,2% ||   || 0,07% 
 NL ||   || 99,2% ||   || 0% 
 PL || 69% || 92,6% ||   || 22,5% 
 PT ||   || 48% ||   ||   ? 
 RO ||   || 37% ||   || 0% 
 SE || 60% || 77,6% ||   || 0% 
 SI || 78,7% || 94% ||   || 1,17% 
 SK || 45,4% || 46,7% ||   ||   ? 
 UK || 92,7% || 97,8% ||   || 22,1% 
Table 4:
Comparison between reported material recovery rates and Eurostat data
The articulation
of the target still causes problems: for instance and as highlighted in the
fitness check, there is no clear relationship between the landfill diversion
target for municipal biodegradable waste, the recycling target for municipal
waste and the recycling target for packaging waste which also partly covers
municipal waste. As also highlighted in the fitness
check, the existing legislation still includes some obsolete requirements
which could be removed. For instance, this is the case in the PPWD in which a
'maximum' target was fixed for recycling in contradiction with the evolution of
the recycling markets. 
Moreover, even though significant
efforts have been made to streamline and simplify reporting obligations, there
is still room to improve and further streamline these obligations.  MS are
required for each Directive to produce a tri annual report to the Commission
which in turn is required to produce reports on the implementation of the
Directives. In practice, these reports which are mainly qualitative have a very
limited added value compared to the administrative burden they involve. Error!
Reference source not found. in Error!
Reference source not found. summarises the demanding flow of MS
reporting obligations – more details being provided in Error!
Reference source not found..  
Similarly, according to the WFD a permit
is necessary for all undertakings managing waste (Article 23). During the
stakeholder consultation, it was pointed out that in some MS, SMEs producing
or managing small quantities of non-hazardous waste have to comply with
this procedure which leads to additional administrative burden for a very
limited added value.    
The problem of littering,
while covered by the general provisions on waste prevention and management
(e.g. articles 9-13 and 36 of the WFD), is not explicitly addressed in EU waste
legislation. It is only in the recent Commission proposal (COM (2013) 761)
amending the PPWD to reduce the consumption of lightweight plastic carrier bags
that the issue is referred to in its own right.
2.5.3.     Issues related to
monitoring
As repeatedly
mentioned by stakeholders, pointed out by the Court of Auditors, and
highlighted in the fitness check, another difficulty is related to the quality
of waste statistics. Significant efforts have been made at European
level with the creation of the Eurostat waste data centre. Nevertheless, as
illustrated in Table
3
and in Table
4,
additional efforts to improve statistics particularly on C/D waste are needed:
differences persist between what is reported under the WFD and otherwise to
Eurostat. No clear binding procedure is in place to ensure a minimum data
validation either at European level - the current approach is only indicative -
or at MS level. Only few MS have set an internal validation procedure. 
This might lead
to divergent data flows - there are some examples of MS in which the
Ministry of Environment is reporting different data from the official
statistical office – with differences up to 30% in the case of municipal waste
generation.[48]
Additional layers of uncertainty are related to the fact that some MS do not
follow the guidance provided: for instance, and as shown in the fitness check, under
the PPWD, MS are allowed to report as ‘recycling’ the material which is
separately collected. Difficulties also emerged from the absence of common
interpretation on what is or is not packaging.
However, losses
between what is collected and what is effectively recycled may be significant:
for example, the Court of Auditors report has indicated, loss rates of between
26% and 50% at the five facilities which were examined. In some cases, the
implications of such loss rates would be that if recycling was reported on the
basis of what was collected, this would amount to an over-estimate of the
recycling rate of between 33% and 100%. This could encourage MS to maintain poorly
designed waste collection systems and management not sufficiently focused on
quality and efficiency.
The absence
of anticipation of the risks of non-attainment of the targets by the MS is
another significant problem. The current approach to checking
whether targets are met is based on statistics reported a posteriori by MS. In
most of the cases, when the assessment is completed and possibly infringement
procedures launched, it is too late to take appropriate and timely
correcting measures due to the time needed for instance to launch
additional programs of separate collection and to build the required
infrastructure. 
Between the
non-attainment of one of the targets of the EU legislation and the launching of
an infringement procedure a period of three years is usually needed, in
particular to acquire and check the relevant statistics. 
2.5.4.     Gap between EU objectives and
existing targets  
The level of the
existing targets remains too low to ensure the creation of a circular
economy using waste as resource and to meet the concrete objectives provided by
the 7th EAP and recently endorsed by the European Council and the Parliament,
the Raw Material initiative and the Resource Efficiency Roadmap as well as
through one of the key Europe 2020 objectives to build a more ‘resource
efficient’ economy. 
Meeting the
existing landfill diversion target for biodegradable municipal waste will still
allow landfilling significant amount of valuable waste as this target is
based on 1995 data, covers only the biodegradable waste (and not all waste) and
allow for landfilling in 2020 of 35% of the amount of biodegradable waste that
was generated in 1995. Meeting the existing target for packaging waste (55%
recycling) will leave 45% of packaging waste not re-used or recycled although
the potential remains significant as illustrated by the current performances of
the most advanced MS (around 75% recycling in 2010). The four methods for
meeting the 50% recycling/re-use rate for municipal waste in practice leads to
not reuse/recycle between 25 and 50% of municipal waste as illustrated in
section 2.5.2.   
In addition and
as detailed in the following section, without additional EU initiative to raise
the existing targets, a significant amount of waste will still be lost to the
EU economy whilst no clear medium-term signal will be given to waste management
operators. 
The targets
should be revisited in the light of the multiple potential benefits linked with
improved waste management - job creation, new economic activities, innovation
in a promising sector, reduced GHG emissions, contributions to renewable energy
generation, improved amenity - and the increasing challenge of raw material
access for EU industry. 
The current
performances of the most advanced MS clearly show that a significant degree of
progress is possible for all MS in the midterm. As shown in the fitness check,
most MS have already met and surpassed the targets of the PPWD. The fitness
check also highlighted the fact that the PPWD has had a significant impact in
promoting the establishment of selective collection not only for packaging but
also for other waste streams.[49]

Some MS are
already today recycling more than 50% of their municipal waste – with some
peaks at regional level of 70 to 85% - while 6 MS are landfilling less than 3%
of their municipal waste - see Figure
3
and Figure
9.
The vast majority of stakeholders have also shown an ‘appetite’ for increasing
the recycling targets and building on progress already made to move closer to
the vision of a resource efficient economy.
2.6.        How
will the problem evolve?
Without further
policy action, significant amounts of valuable resources will continue to be
lost in the coming years. Without a clear midterm perspective on the vision for
waste management, there is a risk of investing in inflexible large-scale
projects such as incineration and/or MBT facilities which may hinder
longer-term ambitions to improve resource efficiency. The dissemination of best
practices will remain limited, the quality of essential monitoring tools such
as statistics on waste generation and management will remain sub-optimal and
reporting obligations will remain complex and with limited added value. 
In order to
assess the impact of the existing measures for municipal waste, a ‘Business
as usual scenario’ has been developed. This scenario presents an objective
view of likely future waste management based upon realistic expectations for
the performance and delivery of future waste management systems. A variant of
this scenario has been constructed presenting the intentions of MS -
understandably, in most cases the stated intention is that MS plan to achieve
the targets, thus this variant is close to the full implementation scenario.  
The functioning
of the model is summarised in Figure 3.1 - Annex 6 which includes a
summary of the key assumptions and data sources which have been used to
calculate the financial and environmental impacts of the policy options considered
in this IA.  
As shown in Figure
7
below, the business as usual scenario implies a modification of waste
collection and treatment: more waste will be recycled and reused,
energy recovery will slightly increase and landfilling will decrease by nearly
40.000 tons.  
Figure 7:
Changes in waste treatment - Business as usual scenario
Despite these
expected changes in waste management, there is a risk that some MS will fail to
meet the existing targets on time: without additional actions, 9 MS will have
difficulties in achieving the existing recycling target for municipal waste –
see Error!
Reference source not found. in Error!
Reference source not found.. 5 MS are not making enough progress
towards the landfill diversion target (see Error!
Reference source not found.). According to the marine litter
reduction model, it is estimated that a 4.4% increase of inflow of new marine
litter by 2020 can be associated with this scenario.
2.7.        Who
is affected and how?
Several
stakeholders are affected by the loss of valuable materials and improper waste
management:  
As explained in
section 2.2, the manufacturing industry might be confronted with
additional increases in raw material prices in the midterm. This risk might be
attenuated by improving waste management as a significant proportion of raw
materials needed for the manufacturing industry could be re-injected back into
the economy at a reasonable price level. At the same time, the manufacturing
industry placing goods on the market is confronted with different systems of
EPR in the MS. These differences might represent an obstacle to the functioning
of the internal market. In addition, as shown in Figure
5,
several EPR schemes are not cost effective which might be due to the lack of
transparency combined with the absence of minimum conditions (control, fair
competition etc.). Several MS are envisaging now additional EPR schemes and
without ensuring that they are meeting minimum conditions there is a risk of
creating ineffective additional systems.  
Waste operators whether
large companies or SME involved in waste collection and treatment might be
affected by the absence of new initiatives to ensure proper implementation of
the EU waste legislation and by the lack of mid-term clear and measurable
targets. As highlighted during the stakeholder consultation, improper waste
management could represent a barrier for the development of new business in the
collection, sorting or treatment sectors. Without a clear midterm vision on waste
management, there is a risk of sub optimal investments in the sector – see Box 3 as
an example. 
The recycling
industry has
already benefited from the European targets in the past. It has been
demonstrated that without clear European targets it would have been impossible
to develop sustainable recycling activities. Without further efforts to
simplify the EU legislation, SME’s might be confronted to administrative
burden – particularly when SME’s are handling small quantities of waste. 
EU citizens are
first in line to improve waste management as one of the key players in
the chain having to participate in separate collections schemes. Nevertheless,
they do not always benefit from optimal organisation of waste
collection. This has consequences in terms of general taxes to be paid which
might increase due to improper waste management – for instance due to
inappropriate investments, creation of overcapacities, lack of coordination
between collection and treatment or investments being made too late which might
ultimately lead to infringement proceedings and even fines. Also, EU citizens
often pay general taxes for waste management without links to efforts to
prevent and separate waste.
As consumers,
they pay a contribution to EPR systems without having a clear choice and in
absence of appropriate level of information on how the funds collected are
used. 
At local level,
landfills cause multiple nuisances including noise, dust, poor air quality and
negative impacts on landscape. Improper management of landfills, particularly
those located near water bodies, can lead to pollution of the rivers and sea.
This in turn can lead to contamination of the food chain, for instance when
plastic particles ending up in the marine environment is ingested by fish,
which has potential adverse impacts on public health. 
Public
authorities are also key players in waste management: at local
level - municipalities, associations of municipalities - they organise the
collection and the treatment of waste for household and similar sources whether
through their own operating means or through services provided by private
operators. Local authorities are also directly concerned by littering which
represent additional and frequently significant costs of cleaning of the
streets, beaches, forests. Without new initiatives for instance to promote best
practices, there is a risk that inefficient systems persist with different
effects notably on the public budgets devoted to waste management.   
Others - tourism
and fisheries: in some parts of the Union, improper waste
management, and in particular illegal landfilling and littering, have a direct
impact on the development of tourism. Beach littering has a particularly
detrimental impact, with clean-up costs estimated at €413,5 million per annum –
see Annex 7. 
The
fisheries industry is also negatively affected from marine litter causing damage
to propellers and fishing gear. Costs associated with this damage are estimated
to be €57.2m, equivalent to approximately 1% of the total revenues from catches
that are generated by the EU fleet (landed value from 2010).  
2.8.        The
EU's right to act and justification 
The proposal is
a direct response to the Europe 2020 Strategy, in particular its flagship
initiative on "A Resource Efficient Europe", and is closely related
to the EU's Resource Efficiency Roadmap and its Raw Materials Initiative. 
The Union
competence to take action on waste management derives from Article 191 of the
Treaty on the Functioning of the European Union related to the protection of
the environment: “Union policy on the environment shall contribute, among other
things, to protecting and improving the quality of the environment, protecting
human health, ensuring prudent and rational utilisation of natural resources,
and combating climate change”. 
In the WFD, the
Landfill Directives and the PPWD, the legislator has included review clauses
for the targets, calling on the Commission to envisage their reinforcement -
see Box 1.    Experience from the past has shown that European objectives and
targets for waste management have been a key driver for better resource and
waste management in the vast majority of the MS. Common objectives and targets
also help improve the functioning of the EU waste market e.g. by providing
guidance to investment decisions and ensuring cooperation between MS. EU wide
targets are also needed to create the minimum scale for the EU industry to
invest in new recycling techniques. 
Transnational
aspects of the initiative are also related to environmental aspects:
inappropriate waste management leads to additional GHG and air pollutant
emissions whether directly emitted by landfills or indirectly through
extraction and processing of virgin raw materials which could have been avoided
through increased reuse and recycling. 
Taking measures
to reduce landfilling will have impacts related to EU wide aspects such as GHG
emissions, transboundary air pollutant emissions and losses of valuable
resources. Reducing landfilling has therefore the potential to contribute to
European policies in terms on GHG and air emission reduction on top of resource
efficiency policies. A European wide approach is also necessary to avoid that
some MS by continuing to base their waste management strategies on ‘cheap’
landfilling creates the conditions to ‘import’ potentially massive amounts waste
preventing the creation of an EU wide recycling industry. These real risks of
increased shipments of waste for disposal to MS where landfilling continues to
be allowed for longer can be limited by fixing similar deadlines at European
level to progressively remove recoverable waste from landfills. 
Littering,
especially in the marine environment, is also a problem with transnational
implications. Material which escapes the waste management system is frequently
transported from one MS to another via inland waterways, and once it reaches
the sea, it does not respect maritime boundaries. Plastic litter in particular
is problematic, given its long lifetime, and its tendency to disintegrate into
ever-smaller pieces, which frequently enter the food chain when ingested by
marine life. Without setting coherent targets at European level, there is a
risk that the efforts achieved by some MS could be undermined by a lack of
similar efforts in neighbouring MS. A headline reduction target for marine
litter at EU level will support Member States in the establishment of
(sub-)regional marine litter reduction targets and in achieving the national
targets which they are obliged to adopt under the Marine Strategy Framework
Directive.[50]

3.                      
Objectives
The main
general objective of the review is to ensure that valuable material
embedded in waste is effectively re-used, recycled and re-injected into the
European economy – in other words, to make progress towards the creation of
a circular economy where waste is progressively used as resource. 
Moving towards a
circular economy will ensure that that opportunities linked with proper waste
management will be seized by the European Union – notably in terms of job
creation, GHG emission reduction, reduction of marine litter, improving the EU
security of supply of raw materials and contributing to the development of a EU
recycling industry.
The specific
objectives of the review could be summarised as follows: 
1. Ensuring improved
waste management in all MS by ensuring the dissemination of best practices
and key instruments already applied in the most advanced MS and notably by
promoting and if necessary imposing the use of key instruments including
economic instruments particularly in those MS considered as ‘at risk’ of
non-attainment of the targets, ensuring a minimum level of harmonization of the
EPR schemes at EU level to ensure their optimization and orientating the
forthcoming investments in the field of waste management as a priority towards
the first steps of the waste hierarchy.
2..
Simplifying the European legislation by clarifying and simplifying
measurements methods related to targets, by adapting and clarifying key
definitions, ensuring the consistency of the targets through an integrated
approach and removing obsolete requirements from the legislation and by
dramatically simplify reporting obligations.
3. Improving
monitoring of the legislation and the legally binding targets by improving
the quality of waste statistics,  particularly where targets are concerned, by
anticipating possible problems of implementation with the development of an
“early warning” procedure.  
4.  Ensuring
that the European mid-term targets are aligned with EU aspiration in
terms of resource efficiency and raw material access by
clarifying the waste hierarchy and fixing new midterm targets aiming at giving
a clear early signal to the MS and the industry on the vision of the EU.
Opportunities linked with improved waste management have to be seized – modern
waste management can contribute to innovation, competitiveness, job and
economic activity.  
The links
between the proposed objectives, the problem definition and the causes of the
problem are summarised in the first part of Table
5
below.  
In the midterm
and in line with the ambition of the 7th EAP recently endorsed by
the Council and the Parliament in Decision No 1386/2013/EU of the European
Parliament and of the Council of 20 November 2013 on a General Union
Environment Action Programme to 2020 ‘Living well, within the limits of our
planet’[51], the
following operational objectives have guided the review: 

 waste generation decline and is
     decoupled from GDP evolution;
 reuse and recycling are at the
     highest level feasible – 70% for municipal waste at the horizon 2030; 
 incineration is limited to waste
     which is not recyclable;
 landfilling is limited to
     ‘residual’ waste – around 5% of waste generated;
 achievement of significant
     reductions in marine litter, in order to prevent harm to the coastal and
     marine environment;
 best practices are in place
     progressively in all MS;
 a proper and reliable monitoring
     strategy is in place at EU and MS levels. 

These objectives
are in line with the Europe 2020 strategy and particularly with the
objective of promoting sustainable growth based on a ‘resource
efficient’ economy – one of the 7 flagships of the strategy. 
They also have
the potential to contribute to several targets of the EU 2020 strategy
including the creation of new skills and jobs especially in the less favoured
areas of the Union where waste management is often not yet optimised, the
promotion of innovation through research and the development of new
technologies for instance to improve waste sorting and recycling operations but
also to improve the eco design of products and the reduction of energy demand
and related GHG emissions at a promising opportunity cost compared to
other sectors by using more recycled materials compared to virgin materials. 
Some
contribution to poverty reduction might also be expected by the creation of
non-qualified jobs which are, for the most part, impossible to outsource as
well as by the development of re-use activities placing goods on the market for
a second or subsequent time, at a reasonable access price. 
The objectives
to simplify legislation and reduce regulatory burdens (including for SMEs) as
well as to ensure that targets are 'fit for purpose’ are in line with the
Commission's efforts to ensure regulatory fitness. 
Table 5:
Summary of the problem definition, objectives and possible measures
4.                      
Policy Options
A large scoping
exercise was undertaken during which a long list of possible measures for
change were considered. In the context of this IA, the most relevant and/or
most preferred measures are analysed. Further details on the main reason for
rejection of some of the Options considered during the consultation are given
in Annex 6. 
The links
between the proposed measures, the objectives and the problem definition is
summarised in Table
5
above which also takes into account the main conclusions from the fitness check
The proposed measures detailed in Table
5
above have been re-grouped into 3 main options (Option 1: ensuring full
implementation, Option 2: simplification, better monitoring and best practice
dissemination and Option 3: Upgrade the targets).  A summary of the proposed
options for analysis is given in the following Figure which makes the link with
Table
5
above. The content of each Option is discussed in the following Section. 
Figure
8:
Summary of the options considered
A ‘No policy
change’ Option  assuming that no policy change is introduced in the existing
legislation and that no additional actions are taken to ensure a proper
implementation of the existing targets has not been considered for further
analysis. As detailed in section 2.4, there is a risk of non-attainment of the
targets by some MS. This scenario - corresponding to the 'Business as usual'
scenario - will not allow meeting most of the objectives defined in section 3
and therefore was not considered as an Option as such but simply as a
‘scenario’ useful to assess the possible impacts of ensuring the full
implementation of the EU legislation.  
4.1.        Option
1: Ensuring full implementation of the existing legislation 
This option
assumes that all MS will meet all the existing targets on time. It will require
additional efforts in some MS even though some MS have already met ten years in
advance (2010) all existing targets. No additional EU legislative action is
considered under this option. 
Nevertheless,
ensuring the full implementation of the targets will not be possible without
disseminating some best practices – such as a minimum use of key economic
instruments. In that sense, the Commission will have to continue its efforts to
promote compliance on a voluntary basis notably by ensuring a follow-up of the
already launched initiatives such as the establishment of Roadmaps for MS at
risk and additional follow-up initiative.[52]
This option corresponds to the 'full implementation' scenario in the model on
municipal waste.  
4.2.        Option
2: Simplification, improved monitoring and dissemination of best practices   
This option
includes a combination of legislative and non-legislative measures to simplify
the existing legislation, improve its monitoring and ensure the dissemination
of best practices. These measures do not include any changes in the targets themselves
apart from simplifying the measurement methods. They imply some changes in the
legislation and will contribute to ensure a proper implementation of the
existing and future possible targets. In that sense, this option might be
considered as complementary to Options 1 and 3. 
Measures to
simplify the EU waste legislation 
Several problems
of definitions have been identified and highlighted during the stakeholder
consultation. There is a consensus to align the definitions of 'recycling' and
'reuse' between the PPWD to the WFD which is one of the main recommendations of
the fitness check. In practice, it is proposed to align the definitions
included in the PPWD to those of the WFD. A better definition of ‘municipal
waste’ in the WFD and in the Landfill Directive is needed to avoid major
differences of interpretation between MS. The definition of municipal waste
should be as far as possible aligned with the one used at international level
(OECD) and by Eurostat. In practice, it is proposed to include a definition of
‘municipal waste’ in the WFD.   The added value of launching a complex
discussion on the definitions of ‘biodegradable’ waste and ‘treatment’ in the
Landfill Directive might be limited at this stage if this target is not
extended beyond 2020 (see section 4.2), therefore no specific action to clarify
these concepts is proposed.  
Establishing a single
measurement method for the target for household and other similar waste is
a proposal supported by the stakeholders. It is proposed to allow only one
measurement method – that is, Method 4 - which is based on the total amount of
municipal waste recycled. The other methods were rejected due to their
complexity and lack of correspondence with the internationally recognised
definition of municipal waste.[53]
As detailed in section 4.4 (see Table
6),
knowing that changing the measurement method has implications on the level of
the target and for legal certainty reasons, it is proposed to move towards only
one measurement method by 2025 at the latest. This will give enough time to MS
to adapt their waste management plans (see section 4.4).  
Similarly, for
C/D waste further action should be taken to avoid abuse from some MS when
they report on backfilling which represents a significant and hard to monitor
amount in some MS – see Table
4. 
High levels of backfilling prevent MS from making enough efforts on
recycling C/D waste. It is therefore proposed to further analyse the possibility
of fixing a maximum ceiling for backfilling in the context of the calculation
of the recovery target. In practice, this should be achieved in the coming
months on the basis of additional studies aiming at gathering enough evidence
on the potential impacts of fixing such a ceiling.  
A drastic
simplification of the reporting obligations for MS will be
considered through the abandonment of the MS tri annual reporting obligations
which have a limited added value compared to the administrative burden. 
Based on the
conclusions of the Top 10 consultation on administrative burden on SME’s, specific
measures should be foreseen to oblige MS (it is only a possibility in the WFD) to
exclude SMEs producing or transporting non-hazardous waste in small
quantities from any permitting obligation. This is a repeated and reasonable
demand from SMEs when small quantities of non-hazardous waste are involved. In
practice, it is proposed to include these simplifications in the WFD.
To ensure MS
reinforce action to tackle the problem of littering, it is proposed to include
a more explicit reference to measures against littering in the WFD, for
instance in connection to the waste management plans that MS are required to
establish under article 28 of the Directive but also in the context of the EPR
schemes. 
Measures to
improve monitoring
Improving the
quality and validity of the reported statistics is one of the key
priorities identified by the vast majority of stakeholder as well as in the
fitness check. On top of the continuous efforts to improve the quality and
validation of the statistics undertaken by Eurostat, additional actions at MS
level are needed. Two additional measures are proposed: 
Ø  the creation of a
'National Registry' on waste collection and management: several MS[54]
have already put in place such registries with most of them being completely
computerised. It has allowed eliminating major inconsistencies between National
reporting bodies while improving the quality of the data collected. 
Ø  requiring third
party verification before transmitting data and statistics to the EU
particularly when legally binding targets are concerned – this will ensure that
data transmitted are validated and conform to EU guidance. 
In practice, it
is proposed to include the obligation of establishing National registries and
to ensure third party verification of key statistics in the WFD. A delegation
should be given to the Commission to define more technical requirements. Also
the Commission should organise exchange of best practices between MS. These
measures corresponds to the unanimous stakeholder demand but also to
Commission' concern to base its policy on reliable evidence. It is indeed
essential to ensure that targets are properly monitored on the basis of a
common methodology and with a reliable verification mechanism.    
The
reinforcement of the central role of the waste data centre of Eurostat in terms
of gathering all waste related statistics including in relation to the
attainment of the legally-binding targets will be considered. In that sense,
all waste statistics - including those needed to assess whether the legally
binding targets are met - should be directly reported to Eurostat. Whether the
waste statistics regulation could become the sole instrument for gathering and
validating all waste related statistics should be further investigated. In
practice, it is proposed to include in the WFD the obligation to report all
waste related statistics currently reported through the 3 annual reporting
obligations (to be repealed – see above) directly to Eurostat. Additional
guidance documents will be delivered, notably on how to report statistics on
packaging and the recycling thereof.        
Developing an 'Early
warning' procedure aiming at regularly monitoring MS performances against
key legally-binding targets was considered as an appropriate measure by 92% of
the respondents of the public consultation.  It is indeed essential to identify
well in advance of the legally binding deadlines those MS not making enough
progress so that correcting measures could be taken on time. These measures
could consist in taking concrete actions to ensure that best practices are
progressively applied in the identified MS – including the application of key
economic instruments at a sufficient level to enable to meet the targets on
time. The waste management plans of the MS identified under this procedure
should be evaluated by the Commission and additional measures such as for
instance additional sorting requirements for C/D waste, additional measure on
prevention, more public awareness, etc should be obligatory envisaged by those
MS.
In practice, it
is proposed to include the ‘early warning’ procedure in the WFD. With the
support of the EEA and using notably the ex post and ex ante tools (modelling)
developed by the EEA and the Commission, it is proposed to make regular
assessment (every 3 years) and projections of MS performances and ‘distance to
target’ in order to identify MS at risk of non-attainment of key targets
(landfill diversion, packaging, construction and demolition waste, municipal
waste). MS identified as ‘at risk’ should submit to the Commission a strategy
aiming at meeting the targets on time. 
Based on the
experience of the most advanced MS and on the Roadmaps established during the
compliance promotion exercise (see section 2.1), a list of measures to be
envisaged by the MS in this strategy will be proposed. A dialogue will be
organised between the Commission and the MS on the appropriateness of the
proposed strategy.  This approach will limit administrative burden while
ensuring that appropriate measures are considered in the MS where they makes
sense.
Measures to
ensure the dissemination of best practices 
As detailed in
section 2 as well as in the fitness check, economic instruments are considered
as indispensable to meet the EU targets. Nevertheless, imposing full
harmonization of these instruments appears to be excessive and not useful for
those MS making enough progress towards the targets. 
It is therefore proposed
to promote the use of these economic instruments through the ‘early
warning’ procedure - see above - with a focus on those ‘at risk’ MS. The same
approach should be followed to ensure that MS are taking the necessary measures
for 'incentivizing' local authorities to launch and intensify separate
collection to increase recycling and reuse rates. 
Establishing a
systematic procedure to evaluate the adequacy of
the National or Regional waste management plans will imply heavy
administrative burden which is not justified for those MS on their way to
meeting the targets. This systematic evaluation should therefore again be
reserved for MS identified under the ‘early warning’ procedure. 
In addition to
the promotion of EPR schemes, measures to improve the cost efficiency of the
schemes seem to be needed notably by ensuring a minimum harmonization between
the national EPR systems. In line with most of stakeholder views, and
in line with the conclusions of the fitness check, minimum conditions to
be defined at EU level for insertion in the national ad-hoc legislation
should be considered including measures to: clarify EPR
definition, their scope, objectives and the responsibilities of the different
actors; ensure that minimal enforcement measures are in place as well as a
enough transparency, fair competition, with sufficient control and equal rules
for all, and no distortion of the internal market; ensure that the fees paid by
producer/importer to a collective scheme are reasonable and reflect the true
and full cost for the end-of-life management of its product. Additional
guidance should be provided to MS notably to ensure proper enforcement and
combat effectively ‘free riders’, to ensure a fair competition, to ensure that
exports of waste are in conformity with the EU legislation. In practice, it is
proposed to include in the WFD minimum conditions that should be respected when
EPR schemes are established by MS. This will be completed by guidance provided
by the Commission on the best practices to establish cost efficient EPR
schemes. 
In order to
ensure a better use of EU structural funds, and following
the publication of the EU Court of Auditors report, the Commission has already
adopted new rules for the use of structural funds for the period 2014-2021
including ex-ante conditions partly aligned with the recommendations of the
Court. Four ex ante conditions have been defined in relation to waste
management including the adequacy of the waste management plans and of the
measures taken to meet the existing targets. The Commission is currently
assessing whether these conditions are met or not for each MS.  Additional
measures, for instance, to promote the use of economic instruments to support
the investments achieved with EU funds, are included in the proposed options of
this IA.    
Past experience[55] has
demonstrated that structural funds are useful to help MS to meet the European
targets but cannot be considered as an ‘alternative instrument’ to these
targets. The European legislation and particularly the targets are providing
the necessary frame to ensure that EU funds are properly used. As explained in
the report form the Court of the Auditors, too much EU money (around 50%) has
been invested in the lowest steps of the waste hierarchy (landfilling and
incineration) and this is partly due to the lack of clear midterm perspective
at EU level. Furthermore, the same report indicates that investments in sorting
and composting infrastructure appear to be functioning at a low level of
efficiency, potentially because of the poor linkages to appropriately-designed
collection systems.
4.3.        Option
3: Measures to upgrade the EU targets 
Removing the
targets from the legislation might be seen as a radical way of simplifying the
EU waste legislation. In this IA, the added value of each individual target will
be discussed and, where appropriate, it will be proposed to update existing
targets, as well as to remove unnecessary or obsolete ones. New targets are
only proposed if they are ‘fit for purpose’ and have a clear added value. 
As explained in
section 2.5.1 materials prices are fluctuating. They are not sufficiently attractive
for all materials to cover the costs of separate collection and sorting
activities needed to produce secondary raw materials. Waste streams are
composed by different type of materials – some of them being profitable, others
not and this changes over time. Targets are therefore necessary to ensure that
waste is properly treated independently from material market fluctuations. This
is absolutely needed to ensure that new investments will be accomplished on
safe grounds in the waste management (recycling/reuse) sector.  
As detailed in
section 2.2, time is needed to change collections systems, ensure proper
information of waste collection and management, build the required
infrastructure and put in place appropriate economic instruments. It is
therefore proposed to provide a medium term vision to the legislation by
defining targets to be met at 2030 time horizon, with interim targets for 2020
and 2025. This will provide to the operator a clear signal on the investments
to be achieved in the coming decade. 
The stakeholder
consultation has shown that this signal is awaited from the European Union. Apart
from the fact that quantitative targets are indispensable to establish concrete
and useful waste management plans, midterm targets will allow avoiding the
mistaken made by some front runner MS having created over capacities of
incineration (see section 2.5.1). It will also prevent the multiplication of
low performing MBT facilities based on mixed waste collection and leading to
high levels of landfilling. 
In summary,
midterm targets will clarify once for all the meaning of the waste hierarchy
and will provide a stable context favouring investments in reliable and long
term solutions based on high recycling/reuse rates and valid for several years.
While some measures will be considered for other categories of waste, the focus
will be on municipal, packaging and C/D waste since the management of these
types of waste represents a good proxy to measure the overall performance of
waste management: MS ensuring a proper management of their municipal waste have
set in place a package of measures which benefit to all waste including public
awareness, use of economic instruments, proper monitoring of waste generation
and treatment etc. The main reasons for not considering other waste streams are
summarised in Annex 6.
It is proposed
to limit measures linked with construction and demolition waste to general
measures detailed in Option 2 - improved statistics, limiting possible abuse on
backfilling, early warning procedure. Reviewing the 70% existing material
recovery target was rejected at this stage mainly because the priority is to
ensure a sound implementation of the existing target but also due to the lack
of ‘stable’ statistics on C/D waste – the statistical series being relatively
recent. When there is more experience and better availability of reliable data,
the target should be reviewed, including the possibility of material-specific
targets.
Prevention and
Re-use
Defining an overall
waste prevention target and/or a target for packaging prevention
appears to be attractive for some stakeholders (NGO’s, academics, part of
public authorities) but not for others. At this stage it does not seem
appropriate to define a legally binding weight-based quantitative target for
prevention. There is a problem of timing as according to the WFD, MS
are required to adopt by the end of 2013 National Prevention Programmes (NPPs)
and it would be logical to assess the effectiveness of these Programmes before
proposing any possible EU wide prevention targets. In addition, as highlighted
in the fitness check, prevention for packaging waste seems difficult to
implement and measure as the packaging materials, distribution systems and
consumer demand are constantly changing. Nevertheless, evidence shows that
efforts have been accomplished to limit the amount of packaging placed in the
market notably under the influence of EPR schemes. 
Nevertheless, progress
in terms of prevention should be better monitored and compared at EU level. It
is therefore proposed to define new indicators for waste prevention
based on actual data on GDP and internal consumption linked to municipal and
all waste generation. These indicators could be generated by the EEA, building
upon Eurostat's data, on an annual basis and without any additional reporting
obligation for the MS.   
Notwithstanding
the difficulties of setting waste prevention targets at the EU level – see Annex
6 - MS should be strongly encouraged to consider setting such targets within
their own prevention programs, particularly for those MS at higher per capita
income levels where, although recycling rates may be higher, consumption is
also at much higher levels, leading to higher levels of waste generation.
Regular inventories/benchmarking of prevention measures will be established by
the EEA.  
Defining
prevention targets for specific waste streams or products
having a higher environmental impact might be relevant, and a consensus has
emerged to focus on food wastage. As there is a specific impact assessment on
the sustainability of the food chain, this aspect will not be covered by the
current IA. Promoting the use of EPR schemes and fixing minimum conditions
notably on the application of the polluter pays principle will have some
impacts on prevention: producer/importers will indeed be financially
incentivized to place on the market better designed products generating less
waste, as well as products which are easier to reuse and recycle. 
Reuse will
be encouraged through the proposed increase of the recycling/preparation for
reuse targets both for municipal and packaging waste.  
In conclusion,
after having considered several options to review the targets, only the
following options 3.1 to 3.7 were retained for further consideration in the
context of this impact assessment. In order to properly assess the added value
of each option, they were first considered in isolation (options 3.1 to 3.3 –
increasing recycling/reuse rates for municipal waste, then for packaging waste,
then imposing a landfill reduction). A combination of measures is then proposed
into one option aiming at increasing recycling rates while reducing landfilling
at the time (option 3.4). In order to take into account the large variety of
performances between MS, different deadlines were applied to Member States
(options 3.5 and 3.6). Finally, an extension of the landfill ban to all waste similar
to municipal waste and  sent in the same landfills is envisaged in option
3.7.     
Municipal and
Packaging waste 
Options 3.1 -
increasing the recycling/preparation for reuse target for
overall municipal waste seems to be reasonable in the medium-term. The current
target of 50% with 4 allowed measurement methods by 2020 should not be changed
in order to maintain legal certainty. 
The actual
performance of some MS and regions in the MS indicates recycling/reuse rates
between 70% and 85% are already achieved today see Figure
3
and Figure
9.
On this basis, it is proposed to consider two levels of targets – 60 and 70%
for further consideration. This corresponds to the level identified during the
stakeholder consultation (see Annex 3), 84% of the stakeholder felt that
existing targets for municipal waste could be increased to an average of 70%
with some differences between NGO’s (80%), citizen (75%) public authorities
(70%) and industry (between 65% and 70%).  Tough similar levels were proposed
by NGO's respondents from the ‘less advanced MS’[56], the
proposed levels were slightly lower for industry (62,5%) and public authorities
(65%) originating from these MS.   
As several
regions and some MS have already met between 60 and 85% of re-use and recycling
in 2011, meeting between 60 and 70% recycling is considered as feasible (see Figure
3
and Figure
9).

Figure 9:
Recycling of municipal waste in EU Regions [57]
The large
divergence in terms of waste management performance between different Member
States has been taken into account to fix the deadline needed to meet the
proposed targets: past experience in terms of increasing the
recycling rates[58]
- average increase of 2 to maximum 3% per year, indicates that a reasonable deadline
for all MS to meet the higher proposed target would be 2030. For individual MS,
this evolution can take place far quicker. 
For example, the
Flemish and the Walloon regions of Belgium moved from less than 20% recycling
to more than 60% recycling in a period of 7 years. Generally speaking more
rapid progress can be expected in the future: based on the experience of the
most advanced MS, key instruments to favor recycling and reuse are well known –
see section 2.5.1. Also new techniques in separate collection, automatized
sorting techniques and recycling have emerged and should allow higher progress
rates in the coming years.  
Therefore, the
following sub options were considered as a means to understand the relative
merits of higher or lower targets:
   || 2020 (4 measurement methods) || 2025 (only method 4) || 2030 (only method 4) 
 Option 4.1 - Low || 50% || 50% || 60% 
 Option 4.1 - High || 50% || 60% || 70% 
Table
6: Option
3.1: considered re-use/recycling targets for MSW
Option 3.2 – Packaging
waste: As shown in Table
7
below, and in line with the conclusions of the fitness check, there is room to increase
the targets of the packaging waste Directive in the medium term.  Stakeholders
also provided a clear indication that they believed the recycling targets for
packaging waste could be increased. When asked what the highest level of
recycling they believe could reasonably be achieved for the materials included
in the current target, stakeholders provided the average response detailed in
Table 7 with some differences between stakeholder categories (between 65/70%
for all packaging for industry to 75% for public authorities and 80% for NGO’s
by between 2021 and 2024). Similar levels were proposed by respondents from the
 ‘less advanced MS’ except for NGO’s for which the proposed levels were
slightly lower (73%).   
   || Overall || Paper and Cardboard || Glass || Metals || Plastics || Wood 
 Recycling target || 55.0 || 60.0 || 60.0 || 50.0 || 22.5 || 15.0 
 EU Average || 61 || 83 || 68 || 68.5 || 37.2 || 38.6 
 MS Exceeding Target || 21 || 26 || 19 || 23 || 26 || 25 
 Top 3 MS || 75 || 96.3 || 96 || 93.8 || 61.1 || 81.1 
 Stakeholder views (2021-2024) || 70 || 75 || 80 || 75 || 60 || 60 
Table 7:
Packaging recycling rates (%) per material, 2010 data and stakeholder views[59]
In line with
stakeholder views, intermediate targets will be proposed in 2020 and 2025
though the 2030 targets will be fixed in the basis of the current performances
of the most advanced MS – see Table
8.
These targets should be progressively increased by 2030 and should be
consistent with the targets fixed for municipal waste. Preparation for reuse
should be taken into account in the calculation of the target. 
The possibility
to define additional targets for materials having a larger impact on the
environment and on energy demand such as non-ferrous metals – mainly aluminum -
will be analyzed (Option 3.2- nonferrous). Some MS are indeed meeting
the target on metal without making enough efforts on collecting/recycling
aluminum at source.   
The case of
plastics is somewhat different: actual 'top 3' MS are recycling 61% of
packaging plastics. According to the EU plastic industry, the target could be
increased to 62% with additional efforts on source separation of waste. 
Knowing the
significant impact of plastics on the environment, it is proposed to increase
the target to 45% by 2020 and to 60% by 2025. New mid-term targets should be
fixed by 2030 on the basis of the evolution of the types of plastics placed on
the market and the development of new recycling techniques. 
The 2030 levels are
considered as realistic as they were already met in at least 3 MS in 2011
though the 2020 and 2025 proposed targets are already met by several MS which
is confirmed by stakeholder views. Even though differences of performances
between MS is less significant for packaging waste than for other waste, these
differences have been taken into account by fixing reasonable targets to be met
in reasonable deadlines (15 years to pass from 55% recycling to 80%
recycling/reuse). The alignment of the definition of the target (inclusion of
preparation for reuse in the definition of the target) will also allow
additional flexibility particularly relevant in the case of packaging (notably
when considering reusable beverage packaging).   
   || 2020 || 2025 || 2030 
 Overall recycling/preparation for reuse Plastics Non ferrous metal Ferrous metal Glass Paper/Cardboard Wood || 60% 45% 85% 70% 70% 85% 50% || 70% 60% 90% 80% 80% 90% 65% || 80% To be reviewed 90% 90% 90% 90% 80% 
Table 8:
Option 3.2 - Proposed new target for packaging waste
In order to improve
the quality of the recycling and decrease the level of contamination of
materials separately collected, a reinforcement of the at source separation
provision will be envisaged, at least for the existing 4 materials targets in
the WFD. The added value of imposing additional at source separation for other
materials seems to be limited. Some flexibility should be left for the waste
management organization according to local circumstances. 
Option 3.3 will
include measures to limit landfilling to waste that is ‘not recoverable ’.
6 MS already today are landfilling less than 5% of their municipal waste –
which could be considered as corresponding to 'not recoverable waste'. The
majority of MS landfilling the smallest percentage of municipal waste initially
introduced landfill taxes followed in most cases, by landfill bans or
restrictions applied on to various materials/waste streams.
It is therefore
proposed to introduce a progressive ban on landfilling: firstly on the materials
already targeted in the WFD by separate collection obligations in 2015 -
plastics, glass, metals and paper/cardboard - followed by a ban on all
'recoverable' waste including biodegradable waste, wood waste, etc. In order to
properly monitor the implementation of these bans, a landfill diversion target
of respectively 25% and 5% corresponding broadly to the implementation of these
bans on the basis of the average EU municipal waste composition would be proposed.
Introducing
progressive landfill bans seems to be the most appropriate way of giving a
clear signal to all actors involved in waste management in the European Union –
which – according to the public consultation – is a clear demand from the vast
majority of stakeholder. In addition, this approach might limit the risks of
increased shipments of waste for disposal to MS where landfilling continues to
be allowed for longer. As experienced in the most advanced MS, in order to move
progressively in the direction of landfill bans which would be the final aim,
landfill taxes were introduced and progressively increased so that landfilling
was more and more discouraged until it was reduced to few percentages.    
As mentioned in
the 7th EAP and during the stakeholder consultation, realistic
targets should be defined in order to take into account variations between MS
in terms of waste management. The experience of the most advanced MS[60]
indicates that an average 3-5% annual landfill reduction could be met.
Therefore in order to take into account the large differences between MS in
terms of landfilling rates,  it is proposed to fix  realistic deadlines for the
introduction of these bans:  around 2025 (4 waste streams ban) and 2030 - wider
ban. These targets and these deadlines are considered as realistic as already 5
MS are landfilling less than 5% of their municipal waste today, one MS (Estonia
– see Box 3) has shown that dramatic reduction of landfilling could be met with
the use of some ad-hoc economic instruments and as the time needed to reduce
landfilling in the most advanced MS has been taken into account to extrapolate
the proposed deadlines. This approach was also supported by all categories of
stakeholders.
This new target
to limit landfilling should progressively replace the existing landfill
reduction target on biodegradable waste for which the latest deadline is 2020.
Prolonging and reinforcing this 1995 based target on biodegradable waste will
therefore be redundant and not justified also recognizing that its enforcement
remains difficult to monitor due to the absence of an agreed definition of
biodegradable waste. 
Combination of
measures
Under Option 3.4,
a combination of options is considered. Options 3.1, 3.2 and 3.3
interacts indeed directly together: increasing the overall recycling/reuse rate
for municipal waste can be achieved by increasing recycling of both the ‘dry’
fraction of the municipal waste – which includes a large share of packaging waste
(between 30 and 40%) and the ‘wet’ fraction of the municipal waste – mainly
organic waste (food waste, garden waste other organics). At the same time,
increasing reuse/recycling rates of municipal waste up to 60 or 70% will
mechanically have an influence on the landfilling rates of municipal waste. It
therefore makes sense to combine these options into a package of measure and to
assess their potential synergies. A summary of Option 3.4 is provided in Table
10.  

As explained
above in Section 4.4, these targets were fixed on the basis of what is
currently (in 2010) achieved in the most advanced MS or regions thereof. Following
this, on the basis of the past experience of the most advanced MS, the time
needed to meet these targets by all MS was calculated to fix the deadlines. Therefore
no time derogation is proposed in the initial Option 3.4.   
Combination of
measures, more stringent deadlines and differentiated approach 
Fixing non
uniform recycling targets for Member States taking into account the
difference in terms of waste generation and composition, the current waste management
performances or the potential contribution in terms of potential amounts of
waste which could be recycled are options which was rejected for the following
reasons: 
·        
Even
though there are differences in terms of municipal waste composition between Member
States,  the potential for recycling remain broadly equivalent and independent
from waste composition: available recycling techniques cover a large spectrum
of waste (from organic/wet to dry waste). Therefore there are no objective
reasons to introduce different recycling targets based waste composition. In
addition, this option would dramatically complicate the legislation and its 
enforcement; 
·        
Waste
generation is expected to increase in the coming years in several MS (albeit
not necessarily coupled to GDP increases) particularly in those MS with lower
levels of per capita income (past experience shows that stabilisation of waste
per capita may be expected after a certain level of GDP/capita has been
attained); 
·        
During
the stakeholder consultation, there was a broad consensus on the ‘destination’
to reach in terms of waste management (aligned to the objectives of the 7th
EAP) but several stakeholder – including MS - insisted  for having enough time
to meet these objectives;   
·        
Resource
efficiency is an EU policy flagship of EU 2020 and should be promoted in all MS
– there are no objective reasons to allow some MS to not make efforts to
improve EU resource efficiency. 
Nevertheless, as
MS are not starting from the same level in terms of waste management – see
notably Figure
3,
it is proposed to consider differentiated deadlines for MS to assess the
possible impacts of alternative trajectories to implement option 3.4 in a
realistic way:
·        
Option
3.5: differentiated deadlines per group of MS based on their current level of
performance 
·        
Option
3.6: more stringent deadlines for all MS with the possibility of a 5 year
maximum time derogation for some MS  
To illustrate
the possible impacts of a differentiated approach, a tentative grouping of the
MS according to their level of performance is provided in Table
9
below. These
options – summarized in Table
10
- will allow the possible benefits of improved waste management to be harnessed
more rapidly in the MS where accelerated deadlines are achievable. 
 Group 1 || Group 2 || Group 3 
 7 MS landfilling less than 10% of municipal waste and recycling more than 40% (2010) AT, BE, DE, SE, DK, NL, LU || 7 MS landfilling between 10 and  60% of municipal waste and recycling between 30 and 40% (2010) IE,  SP, Sl, IT, FR, FI, UK || 14 remaining  MS 
Table 9:
Tentative grouping of the MS according to their performances
An alternative to
Option 3.4 (Option 3.7) extending the landfill ban on all waste similar to
municipal waste has also been tested. This extension might be easier to enforce
at landfill gates and bring additional benefits in terms of recycling. 
   || 2015 || 2020 || 2025 || 2030 
 Municipal overall recycling target 
 Option 3.4 and 3.7 || n/a || 50% - all any method || 60% - all one method || 70% 
 Option 3.5- Differentiated deadlines || n/a || 50% - Groups 1 & 2 one method only || 60% - all one method || 70% 
 Option 3.6 - Same deadlines + time derogations || n/a || 50% one method Group 3 derogated to 2025 || 60% - all one method || 70% 
 Landfilling 
 Option 3.4 ||   ||   || All - 25% max  landfilling || All - 5% max landfilling 
 Option 3.5 - Differentiated deadlines || Group 1 5% max  landfilling || Group 2 - 25% max  landfilling || Group 3 - 25% max  landfilling || Groups 2/3 - 5% max  landfilling 
 Option 3.6 - Same deadlines + time derogations ||   || All - 25% max  landfilling Derogations for Group 3 to 2025 || All - 5% max  landfilling Derogations for Groups 2 & 3 to 2030 ||   
 Option 3.7 – landfill ban extended to all similar waste ||   ||   || All - 25% max  landfilling || All - 5% max landfilling 
 Ban on plastic, paper, glass and metals = (25% max  landfilling) Global ban = (5% max landfilling) 
Table 10:
Summary of Options 3.4, 3.5, 3.6 and 3.7
Actual and
projected future performance rates in recycling are also important in light of
the development of the marine litter reduction target, since recycling
directly reduces the volume of waste which has the potential to escape into the
(marine) environment.
[1] Directive 2008/98/EC of 19 November 2008 on waste, OJ L 312,
22.11.2008, p. 3, Directive 99/31/EC of 26 April 1999 on
the landfill of waste, OJ L 182, 16.07.1999, p. 1 and  Directive
94/62/EC of 20 December 1994 on packaging and packaging waste, OJL 365,
31.12.1994, p.10
[2] A list of acronyms and abbreviations as well as a glossary is
provided in Annex 1
[3] COM (2013) 123 
[4] COM (2013) 685 Communication on Regulatory Fitness and Performance
(REFIT)
[5] References 17 and 18 in Annex 2 (Part 3/3 of the document)
[6] COM (2011) 25, COM (2011) 21 and COM (2011) 571
[7] Decision 1386/2013/EU of 20 November 2013, OJ L 354, 28.12.3012, p.
171
[8]The waste hierarchy gives the preference to prevention first
followed by reuse, recycling before energy recovery and disposal which includes
landfilling and incineration without energy recovery 
[9] http://ec.europa.eu/research/bioeconomy/pdf/201202_innovating_sustainable_growth.pdf 

[10] Reference 9, Error! Reference source not found.
[11] References 1 to 3 in Annex 2 (Part 3/3 of the document)
[12]                    OJ L 181,
4.7.1986, p. 6–12
[13]                    OJ L 243,
24.9.1996, p. 31–35
[14]                    OJ L 269,
21.10.2000, p.34
[15]                    OJL 266,
26.0.2006, p. 1-14
[16] More details including the country specific Roadmaps are available
from the following web site:  http://ec.europa.eu/environment/waste/framework/support_implementation.htm

[17] COM 2011 (13), http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0013:FIN:EN:PDF

[18] Reference 7 in Annex 2 (Part 3/3 of the document)
[19] Reference 7 in Annex 2 (Part 3/3 of the document)
[20] Reference 6 in Annex 1 (Part 3/3 of the document)
[21] Reference 13 in Annex 2 (Part 3/3 of the document)
[22] The fitness check's final findings will be summarized in a
Commission Staff Working Paper to be published as part of  the Commission's
overall waste review package.
[23]  A (partial) exception is the PCB/PCT Directive which suffers from
a persistent implementation gap by MS. 
[24]
Source: Eurostat 2013
[25]
Source: Annex 2, reference 10 (Part 3/3 of the document)
[26] Source : Note of the interserevice group set-up by BEPA on Raw
materials – November 2013
[27] Source: reference 17, in Annex 2 Error! Reference source not found.
[28] As defined under the EU Raw Materials Initiative.
[29] 100% for platinium, cobalt, most rare earth, 85% for iron ore, 57%
for metals and 46% for industrial minerals 
[30] Source: reference 19, Annex 2 (Part 3/3 of the document) 
[31] Source: Annex 2, reference 26 (Part 3/3 of the document)
[32]  Source: Annex 2, reference 12 (Part 3/3 of the document)
[33]
Source: Eurostat 2013
[34] Source: reference 4 in Annex 2 (Part 3/3 of the document) and
fitness check
[35] Sources: fitness check and references 4 and 5 in Annex 2 (Part 3/3
of the document)
[36] Reference 5 in Annex 2 (Part 3/3 of the document)
[37] See: http://ec.europa.eu/environment/waste/framework/pdf/seminar_03_2013/8.%20Martine%20Gillet.pdf

[38]Source:
http://ec.europa.eu/environment/waste/framework/pdf/seminar_03_2013/6.WM-Estonia_10MS-seminar_BRSL_Peeter_Eek_19-03-2013.pdf

[39] Source: reference 13 and 14 in Annex 1 (Part 3/3 of the document)
[40] Reference 1 in Annex 1 (Part 3/3 of the document)
[41] Reference 15 in Annex 1(Part 3/3 of the document)
[42] Source : reference 1 in Annex 2 (Part 3/3 of the document)
[43] Reference 14 in Annex 2 (Part 3/3 of the document)
[44] References 6 and 14 in Annex 2 (Part 3/3 of the document)
[45] Reference 1 in Annex 2 (Part 3/3 of the document)
[46] BG is in process of revising its reporting to Eurostat 
[47] 'Backfilling' is defined as 'a recovery
operation where suitable waste is used for reclamation purposes in excavated
areas or for engineering purposes in landscaping and where the waste is a
substitute for non-waste materials'
[48] Reference 6 in Annex 2 (Part 3/3 of the document)
[49] Source: reference 25, Annex 2 (part 3/3 of the document)
[50] Marine Strategy Framework Directive 2008/56/EC
[51] OJ L 354, 28.12.3012, p. 171
[52] See reference 6 in Error! Reference source not found. as
well as a summary of the actions taken at Commission level to promote
compliance: http://ec.europa.eu/environment/waste/framework/support_implementation.htm

[53] The impacts of changing the measurement method are assessed under
Option 3 – see below 
[54] This notably the case in SK, CZ, BE, UK, AT, DE, NL but the list is
not exhaustive 
[55] Reference 13 in Error! Reference source not found.
[56] Less advanced MS were identified in a study of the Commission – see
reference 6 in Annex 2. It includes BU, HR, CY, CZ, EE, GR, IT, LV, LT, MT, PL, RO and SK. 
[57] Source: EEA reference 7, Annex 1. 2008 data
were used for BE, DE, FR, HU, RO and Sl. 2009 data were used for the rest of
the countries. Data were not available for MS in  yellow and some uncertainties
were identified for data from some MS (lack of common reporting methodology at
regional level)    
[58] See EEA report, reference 7 in Annex 1
[59] Source: Eurostat 2013
[60] See references 1 and 7 in Error! Reference source not found.
Table of Contents
1............ Analysis of Impacts. 3
1.1......... Identification
of the main impacts. 3
1.1.1...... Economic
impacts. 3
1.1.2...... Social
impacts. 7
1.1.3...... Environmental
impacts. 8
1.2......... Impacts
of the key options. 9
Option 1: Full
implementation. 9
Option 2:
Measures to simplify the legislation, ensure proper monitoring and disseminate
best practices  11
Option 3:
Upgrade EU targets. 14
1.3......... Impacts
on groups of stakeholder 22
2............ Comparing the Options. 23
2.1......... Costs,
benefits, employment and marine litter 23
2.2......... Contribution
to the main objectives, efficiency and coherence. 24
2.3......... Preferred
Option. 26
2.4......... Key
implementation challenges. 27
2.5......... Access
to raw materials. 28
2.6......... Conclusions. 29
3............ Monitoring and Evaluation. 30
1.                      
Analysis of Impacts
In this section,
the main impacts will be first identified and some methodological elements to
assess these impacts will be provided. Then the main impacts of the selected
options under section 4 will be presented.  
1.1.        Identification of the main
impacts 
1.1.1.     Economic impacts 
Financial cost
and savings of waste collection and treatment technologies
Achieving higher
recycling rates will require changes to the collection systems operating in a
number of MS as they move towards capturing greater quantities of material. In
order to achieve the higher recycling rates, it is assumed that MS collection
systems will have to evolve over time. For example, a MS may
start with 'bring systems' focusing mainly on 'dry recyclables', but it is
assumed that households will have to move progressively to door to door
collection systems, insofar as this is possible, in order to target biowaste
and to increase the capture rates of the dry recyclable waste. 
At the same
time, less and less mixed waste will be collected and treated, therefore the
systems used for collection of mixed waste will have to switch to a lower
frequency of collection, or move to a pay-as-you-throw system. This allows for
savings to be made in the collection of mixed waste as either the collection
frequency or the set out rate falls. At the same time, the cost of collecting
recyclables becomes more costly as the system for collecting recyclables as
well as biowaste becomes more comprehensive. Hence, on the collection side,
there are opposing tendencies in the costs of collection: the costs of
recycling increase, but the costs of residual waste collection fall. 
This is
illustrated in the following figure related to investigations in Lombardia in Italy. The combined bars indicate the costs of collection and treatment, with the green
component related to waste collection, and the blue bar relating to the
treatment of waste. This indicates how the average costs of collection per
inhabitant barely change as one moves from systems delivering less than 20%
recycling to those delivering more than 70% recycling. 
On the other
hand, as this happens, the expenditure outlay on treatment, particularly on
residual waste, declines, so that those municipalities delivering higher
recycling rates can achieved progressive savings on waste management costs.  
Figure 1:  Collection and treatment costs in Lombardy and recycled rates[1]
The changing
collection and treatment costs associated with this transition were assessed
for each MS since many factors influencing the financial cost are specific to
MS conditions - energy costs, labour costs, etc. 
A summary of the
main unit costs used for treatment in this IA is given in Annex 7 - Table
3-10: the 4 main categories of treatment (composting/digestion, incineration,
MBT and landfilling) were divided between different sub treatment (4 categories
for incineration, 5 for MBT and 3 for composting/digestion) depending on the
technical characteristic of the treatment (for instance for
composting/digestion: open air composting, in vessel composting or anaerobic
digestion). For the 13 possible treatment technologies, specific unit treatment
costs were calculated for each MS on the basis of several parameters including
labour and energy costs. 
The costs used
in the model do not include taxes (e.g. landfill and incineration taxes) or
subsidies (such as those on energy generation) as the objective is to assess
the cost for society of the proposed options. In this IA, it has been assumed
that the efforts needed to meet the proposed targets on Packaging waste will
mainly be concentrated on municipal waste. 
This reflects
the assumption that systems will have prioritised the collection of commercial
waste at an early stages since it has been demonstrated [2] that
separately collecting and recycling secondary and tertiary packaging waste
originating from commercial and industrial sources is easier to achieve – more
homogenous waste streams from less waste producers, and even profitable in most
instances. On the contrary, municipal waste is produced by a multitude of small
mixed packaging waste producers which requires more collection and sorting
efforts. This approach – which is confirmed in the fitness check - is
considered as prudent, and could lead to an over estimation of the direct costs
linked with the increased targets for packaging waste. 
Additional
possible costs of imposing new sorting requirements for the dry fraction as
proposed in section 4.4 (separation of the 3 flows – paper/cardboard, glass and
plastics/metals) should be compensated by savings linked with simplified
sorting conditions and improved quality/prices for recyclable materials due to
the absence of cross contamination. Meeting the proposed targets will require
an increased involvement of households in prevention and separate collection at
source. No reliable method to monetise or even quantify this impact is
available due to the large number of factors to be taken into consideration and
the lack of generally accepted methodologies.
Access to raw
materials 
Similarly, it
has not been possible to ‘monetize’ the impacts in terms of access to raw
materials notably  in terms of reduced dependency from imported raw materials. Nevertheless,
the actual tonnages which could be recovered with the proposed option were
assessed and are detailed in Section 6.  
Administrative burden

In comparison to
the full implementation scenario, no additional significant administrative
costs have been identified linked with the increase of the targets. On the
contrary, proposing a single measurement method for the target on municipal
waste, removing the obsolete requirements of the PPWD like the maximum recycling
target, aligning the main definitions, replacing the current landfill diversion
target on biodegradable waste with an overall target which is easier to
monitor, removing the overall recovery target from the PPWD will simplify the
tasks of the MS. 
Apart from the
introduction of progressive bans on landfilling and the split between ferrous
and nonferrous metals in the PPWD targets, no new types of target are proposed,
and the possible additional efforts linked with the monitoring/enforcement of
these new targets will be largely compensated by the proposed simplifications. More
details are provided in Section 5.2 on the impacts on administrative burden of
the proposed measures included in Option 2. 
Functioning of
the internal market
Some positive
effects on the functioning of the internal market can be expected: for
instance, measures to increase recycling and limit landfilling will 'naturally'
push some MS having developed excess capacities for incineration to open their
facilities to MS still landfilling significant amounts of waste. This movement
has already been observed with an increasing amount of imported waste being
treated for instance in Sweden, Denmark and the Netherlands. Recent information
coming from the UK for instance clearly shows an acceleration of the trend in
exporting waste to energy recovery facilities (waste exports from UK to EU passed from few tons in 2010 to more than 1 Million tons in 2013).[3]
Some countries,
such as the Netherlands, are actively seeking to promote the utilisation of
capacity at domestic incinerators so as to free up the potential for additional
recycling. The new waste management plan in Denmark also, implicitly, seeks to
reduce the amount of waste sent for incineration in the country through setting
higher targets for municipal waste.[4]
Increasing
recycling rates could also contribute to the expansion of the EU waste
recycling market though the development of specific recycling industries for
which a critical mass of recyclable waste is needed before investments are
profitable. 
Defining common
principles for EPR will also have beneficial impacts on the internal market:
today producers and importers placing goods targeted by National EPR systems on
the EU market are facing significant different regimes. 
The proposed
harmonization will help reducing the differences between these regimes and
therefore contribute to the fluidity of the market. 
Competitiveness
and Innovation- manufacturing sector 
As explained in
section 2.2, materials are one of the largest shares of input costs of European
manufacturing companies - around 30 to 40 per cent of the cost
structures.
In absence of
solid forecasts on raw material prices, it has been assumed in this IA and in
the model that raw material prices will remain constant (outside inflation) on
time. This assumption is considered as prudent notably as regards the expected
pressure on raw material demand and the recent raw material price changes - see
Error!
Reference source not found..   
At the same
time, the implementation of the proposed Options will allow re-injecting
secondary raw materials on the EU market which might influence the prices of
raw materials for the EU industry. In the context of the IA, it has not been
possible to assess the possible effect on the raw material prices of the
production of additional secondary raw materials. These prices will remain
dependent on several factors including the worldwide demand for raw material
and their availability both from virgin and recycled materials. 
Broadly speaking
it can be assumed that fixing ambitious mid-term waste management targets now
will help mitigate against the risks which might be associated with increasing
prices for primary materials in future, potentially contributing to maintaining
and improving EU industry competitiveness in the medium term. The production of
additional secondary raw material in the EU will also attenuate EU dependency
on imports of raw materials - some of them being considered as ‘critical’ in
terms of availability.  
In addition,
improving the functioning of EPR schemes can bring additional savings for those
placing goods on the EU market – including the manufacturing sector - see Error!
Reference source not found..
Competitiveness
and Innovation- waste management sector 
Several
countries are implementing forward thinking strategies for managing waste in
the future. EU companies either already are, or may become, exporters of
technology or of services to markets outside the EU. A far-sighted approach to
managing waste and resources is, therefore, expected to foster innovation and
skills which make EU companies more competitive in non-EU markets.
This has been
confirmed during the stakeholder consultation: the main EU worldwide companies
involved in waste management and/or recycling activities are largely in favor
of EU ambitious targets considered as one of the key driver for their business
but also for innovation.  
Competitiveness
and Innovation- SME’s  
SME's active in
the waste/recycling sector will benefit from the above mentioned impacts –
notably in terms of business development potentials, safe access to raw
materials, etc.  SME's should be first in line to capture the potential
opportunities linked with innovation and the development of new business
models. Their flexibility has already allowed them to develop for instance new
sorting techniques or business models based on application of the concept of
circular economy. At the same time, meeting higher targets might imply for
other SME's a short term increase of at-source sorting costs, at least in the
lower performing MS in which landfilling and incineration remain more
economically attractive. In the mid-term, the potential cost increase should be
compensated by the saving achieved through better material management as a
whole in the SME’s. This would be all the more likely if material values
continue to increase in real terms in future, as trends over the last decade
indicate they may.
The proposed
measures to simplify permitting procedures for SME generating or handling small
amounts of non-hazardous waste should also allow for a reduction in SME’s
administrative costs. 
1.1.2.     Social impacts
Effects on employment
As
detailed in Annex 6, Section 4.1.6, the upper tiers of the
waste hierarchy (preparation for reuse and recycling) are much more labour
intensive than disposal and incineration; thus, the movement of waste up the
hierarchy is generally associated with an increase in employment opportunities.
Based on changes in material flows the model allows for a high level assessment
of the likely impacts that each option will have on employment.   
In the EU as a
whole, the potential employment opportunities will be greatest where the
materials being collected and sorted for recycling are recycled within the EU.
In this regard, it should be noted that where materials are collected for
recycling in a manner which ensures the quality of the materials (source
separation), it seems more likely that they will be reprocessed in the EU since
EU disposal costs are already much higher than in those countries to which
materials are exported: the lower costs of disposal can give countries an
advantage where the quality of the collected materials is low (and hence, the
proportion of contrary materials requiring disposal is high). 
Social
acceptance 
Actions to
promote prevention, infrastructures required to reuse and recycle waste are
generally more readily accepted than proposals for new incineration or
landfilling facilities. In many countries, citizens are willing to engage more
actively in recycling, but the services available to them are not adequate. In
the consultation, when citizens were asked whether they would sort out more
wastes for recycling, 88% said they would, with food waste, textiles, non-bottle
plastics and hazardous wastes among the most often cited materials that
citizens would like to be able to recycle. 
Notwithstanding
the potentially self-selecting nature of the respondents to the consultation,
this indicates a desire across EU citizens to recycle more (and more materials)
than they currently do. This is also
reflected in several so-called ‘willingness to pay’ studies seeking to elicit
the strength of households’ preference for recycling.[5] 
Public health,
safety, crime  
It is assumed in
the full implementation scenario that the existing Directives are applied and
that, as a result, the impacts of waste management facilities are regulated.
Clearly, where they are not, waste management can give rise to problems in
terms of emissions to air, land or water, with related health consequences. The
analysis of external costs in the assessment has included an assessment of the
change in the damages associated with emissions to air, which constitute some
of the main impacts on public health. The assessment has not been able to
monetise damages associated with several other impacts of waste management, not
least those associated with long-term impacts on water courses, for example.
However, in the main, these indicate a positive effect on public health. 
There are also
potential public health concerns related to marine litter. Microplastics may
contain persistent organic pollutants (POPs) or similar toxins. Ingested by
marine life, these toxins have the potential to end up in the food chain. Waste
management measures which reduce new marine litter inflows will mitigate these
risks to some extent.    
In a limited
number of MS or zones of MS, waste management remains in the hands of
uncontrolled groups managing waste in an illegal way which has led to a clear
deterioration of the local or even international environment - illegal export
of toxic waste outside the EU, for instance, or fires deliberately started at
waste facilities. Measures aiming at improving the implementation of waste
legislation can contribute to reducing those illegal activities: for instance
improving statistics through centralised registries or applying economic
instruments could contribute to identifying and combating these ‘underground’
activities. The lost revenue for the formal waste management sector is believed
to be very large. 
Similarly,
improved registries and improved EPR schemes can contribute to reduce illegal
shipment of waste outside the EU. 
1.1.3.     Environmental
impacts
In
this IA, both direct (linked with each treatment method and waste collection
system) and indirect environmental impacts (avoided emissions/impacts due to
the 'non-use' of virgin raw materials, energy produced in energy recovery
facilities) were assessed and as far as possible quantified. It includes an
assessment of GHG and air pollutant emissions, impacts on marine litter, and
benefits of improved soil structure and nutrient supply. The environmental
impacts were assessed assuming that all installations are in compliance with
the existing relevant Directives and notably the Landfill and the Industrial
Emissions Directives.[6]
Direct GHG and
air pollutant emissions from waste treatment 
Environmental damage associated with emissions to
air were assessed. The model defines the damage costs for GHGs and a number of
air pollutants and also identifies what emissions are likely from a
comprehensive range of waste treatment and disposal technologies. In this way,
the costs of damage can be calculated depending on the quantity of waste being
treated via each form of technology. Further details of what is included and
excluded from the environmental damage cost calculations is provided in Annex 8,
section 3.1.5. 
Marine litter 
Improved waste
management will have an impact on the presence of both terrestrial and marine
litter. For most sea regions, up to 80% of litter is transported there from
land by rivers, drainage or wind.[7] Plastic
waste is particularly problematic, consistently making up over half of marine
litter in all four marine regions, and in some cases accounting for over 80% of
marine litter.[8] Increasing
recovery rates will mean higher volumes of waste are captured within
appropriate management systems, which is likely to bring about a decrease in
new debris entering the marine environment. 
Many of the most
common items of marine litter are fully recyclable, e.g. plastics bags, plastic
bottles, bottlecaps, beverage cans, plastic cutlery. However, these items are
frequently not being recycled, and instead end up as marine litter. Waste which
is recycled into new products never ends up as marine litter. If the right
incentives/policies are put in place to drive recycling rates (everything from
an EPR scheme which gives consumers an incentive to return a plastic bottle to
ensuring the availability of recycling facilities/separate waste collection to
make the recycling choice an "easy" one), then by definition, much of
the waste currently "at risk" of becoming marine litter is taken out
of this category and reused as secondary raw materials for new products. 
As detailed in
Annex 7, a specific module was added to the modelling tool to assess the
possible impacts of improved waste management and revised waste-related targets
on marine litter. 
Impacts not
quantified
Due to the lack
of available methodologies, it has not been possible to quantify the following
impacts:

 Those associated with the
     production of leachate and waste water from all the processes 
 Effects of odour and bio-aerosols
     from landfilling, composting and anaerobic digestion processes, as well as
     other nuisances such as insects and vermin;
 Estimation of the financial
     disamenities linked with living in the vicinity of waste treatment
     facilities as well as impacts on landscape 

While the data
on both the magnitude of disamenities and their possible valuation are
inadequate, it is assumed that these impacts are likely to be relatively small
as it has been assumed that all plants are supposed to respect the EU relevant
legislation.
1.2.        Impacts of the key options 
The key impacts
– financial and environmental costs, the net social costs as well the impact on
employment have been assessed for each options identified in Section 4. 
The
added value of each option is presented against the full implementation
option which is considered as the starting point or the baseline in the
context of the IA. 
Nevertheless,
in order to get a complete analysis, the business as usual scenario was
used as the basis to assess the added value of ensuring the full
implementation of existing legislation.  
Option 1: Full
implementation
As detailed in Figure
2
below, moving from the business as usual scenario to the full implementation
scenario implies an increase of recycling by over 5 % across the EU whilst
landfilling falls by a corresponding amount. 
Figure 2:
Changes in mass flow - Full implementation vs BAU scenario (% - EU 28)
Financial Costs 
A comparison of
the full implementation scenario against the BAU scenario indicates that
significant investments will have to be made between now and 2020 if MS are to
be fully compliant with the targets. These costs are largely associated with
investments required to improve collection services mainly in the larger
countries (notably ES, PL, CZ, GR, RO, SK) where there appears to be a large
gap between then BAU scenario and the demands of full implementation. 
Generally
speaking, it is assumed that existing predominantly bring-based collection
infrastructure in the lower performing MS will have to be partly and
progressively supplanted by a door-to-door collection system where this is
feasible to ensure higher capture of recyclable waste. At the same time, the
existing bring-based collection systems may have to be intensified (increasing the
collection points) and adapted (buried collection points in urban zones), with
intensive communication campaigns used to support use of the services.
Investments in new collection trucks will be needed as well as, depending on
system choice, new sorting centres and composting or digestion facilities. In
this first phase, significant efforts of communication will be needed to change
citizen behaviour. As explained before, there is a large variety of tools
available for MS to cover the costs associated with this first investment phase
– EPR schemes notably have demonstrated their importance to launch the
necessary dynamic and to provide additional source of funding for this
necessary first phase of intense investments. 
Figure 3:
Full implementation vs BAU scenario - Financial Costs (million € - EU 28)
Figure
3
should be nevertheless interpreted with caution as it assumes that no efforts
would have been accomplished by MS between 2011 and 2016 to meet the targets –
which is an hypothesis taken in the model in absence of verified statistics for
the years 2012-2016. 
In addition,
some of the savings identified under the following options 3 (see below) might
also appear earlier in some MS even though experience shows that before
capturing savings from diminishing residual waste collection there is a first
phase where both collection systems (mixed residual waste and separate
recyclable waste) are necessary – leading to increase costs during the first
period of changes.
Environmental
Costs
There are clear
environmental benefits to be gained from full implementation. The majority of
these benefits are realised prior to 2020 when the 50% recycling target and the
final Landfill Directive target have to be met; however, the benefits continue
to accrue steadily over time once full implementation is achieved. It is
estimated that full implementation of the existing targets would lead to a reduction
of 4,6% of new marine litter inflow by 2020. However, without further action,
new marine inflow would increase by 2,9% by 2030. It is important to reiterate
that not all the environmental benefits can be monetised, not least those
associated with reduced marine litter. Research undertaken in specific
circumstances does indicate, however, that the benefits from reducing litter in
the terrestrial environment are potentially very significant indeed – see
section 5.1.3.  
Figure
4: Full
implementation vs BAU scenario - Externalities (million € - EU 28)
Net Social Costs
As shown in Figure 5
below, there is a net cost associated with full implementation relative to the
Business as usual scenario as the cost of implementation outweighs the
environmental benefits.  The overall picture, however, shows that the net cost will
progressively decrease over time (from €1.500 million to less than €600 million
across the EU28). Again this Figure should be interpreted with care: as
explained savings will progressively appear with the intensification of
separate collection and higher recycling rates. More and more waste will be
recycled and less and less residual waste will have to be collected and
treated. In a first phase, these savings will be modest as both collection
systems (separate and mixed) will have to be maintained. But in the longer
term, and if efforts are made to further increase the capture of materials for
recycling, the efficiency of logistics will improve, revenues from material
sales will (other things being equal) increase, and spending on treatment /
disposal will also increase. Net costs would then be expected to fall (see
below).  
In summary, it
is assumed that this first phase of investment linked with the achievement of
the existing targets requires a significant shift in the collection and
treatment modes as well as in the way of managing waste for citizen. This
implies additional costs with limited savings and benefits as the recycling
rates remain relatively low, and logistics are not fully optimised so that the
full benefits from a re-organisation of the system are not realised.  
Figure
6
below shows the costs and benefits per MS. As explained above, some MS (notably
ES, PL, CZ, GR, RO, SK) will have to upgrade their current waste management
systems to ensure the full implementation of existing target without
immediately capturing potential savings and benefits. It is important
to note that the increase in cost reflects the standpoint of a cost-benefit
analysis (CBA), and that the costs of landfilling, for example, do not include
(as is conventional under CBAs) landfill taxes. As such, the ‘avoided costs’
from ‘not landfilling’ are relatively low, and reflect what are often still
quite low costs of landfilling in the different MS.
Figure 5: Full
implementation vs BAU scenario – Net Social Costs (million € - EU 28)
Figure 6: Full Implementation vs BAU – Net Social Costs by
MS in 2030
Employment
Compared to the
BAU scenario, this scenario also leads to an increase in employment. The
estimated increase in direct employment is 36,761 FTEs (Full-time equivalent)
at EU 28 level. Most of the jobs will be created in the larger MS having to
make additional efforts to meet the existing targets (SP, PL, PT, RO, SK and CZ). 
Figure
7: Full
implementation vs BAU scenario - Changes in employment by 2030 
Option 2:
Measures to simplify the legislation, ensure proper monitoring and disseminate
best practices
Managing the
proposed 'early warning system' will require additional efforts both for
the Commission and the concerned MS notably to identify the MS ‘at risk’ of
non-attainment and to ensure that the appropriate measure are taken on time to
meet the targets. The Commission with the EEA has developed a modelling tool
which will be permanently maintained notably for that purpose. In addition,
Roadmaps have already been produced by the Commission for the 10 least advanced
MS[9]
which includes clear and tailored recommendations to improve the waste
management. With the early warning procedure, the focus will be limited to
those MS for which there is a clear added value of requiring additional
information with the perspective of limiting possible infringement procedures
later. Managing the early warning procedure will represent an additional workload
for the EEA (identification of MS at risk) and for the Commission (launching a
dialogue with the ‘at risk’ MS on the required measures to meet the targets). Nevertheless,
in the light of the existing information and tools (roadmaps and modelling) and
knowing that the Commission has already taken initiatives to promote
compliance, it has been estimated that this workload could be covered with
existing resources through a slight adaptation of the work priorities. 
Measures aiming
at improving statistics will require additional efforts by some MS who
have not yet developed tools to assist with this. This is the case for the establishment
of National waste Registries. The additional costs and potential savings
are extremely difficult to assess for each MS: all MS have indeed already in
place a system of data collection for waste management as they have to report
these statistics to Eurostat and to the Commission. During the country visits
carried out at the occasion of the compliance promotion exercise, it has been
established that some MS have set in place parallel systems of data collection
leading to significant differences in terms of waste generation, collection and
treatment between for instance the National Environment Ministry and the
statistical Agency. [10]
In the case of these countries, establishing a centralised registry could only
lead to savings despite the initial investment which will be needed to set up
the registry. In other MS these registries are already in place since several
years. No additional costs are expected for these MS. 
In fact, in the
midterm all MS should capture savings from the establishment of a centralised
waste management registry. The example of Austria shows that additional level
of sophistication could lead to additional significant savings not only for the
public authorities but also for waste operators. For instance, the Austrian
system is designed to cover a number of environmental fields and is reported to
cost around €4.5 million per year. Of this, €750,000 to €1,500,000 is reserved
for the on-going development of waste related components. According to the
Austrian Chamber of Commerce, this system helps to reduce the administrative
burden of reporting and has helped to reduce costs by between €4 million to €10
million.[11]
Imposing a third
party verification will represent a cost for Member States. Nevertheless, these
additional efforts should be compensated by the proposed dramatic
simplification of the reporting flows. Re-investing these means into
improving statistics, better monitoring of MS performances and ensuring the
dissemination of best practices with a proper management of the early warning
procedure seems to be largely justified. 
A broad
estimation has been made of the effects in terms of administrative burden of
the proposed measures under Option 2 – see Table 1. It
has been estimated that establishing tri annual reports by the MS requires
around 45 working days for the WFD (30 days to establish the report and 15 days
of additional follow up) and 30 working days for the other Directives[12]. 
Compiling the
information from all MS and producing a report from the Commission to the
European Council and the Parliament requires approximately 120 days (15 days to
establish the report, 30 days to check the data reported by MS and ask
additional questions, 60 days for translation of the incoming 20 pages reports
from the MS and the report produced by the Commission and 15 days for the
adoption procedure). [13]
This means an annual average of 40 days. 
The time needed
for the third party verification procedure has been estimated at 5 man days per
year for the key statistics with the exception of packaging for which
additional verifications are needed notably on data of packaging placed on the
market. In principle, these verifications should decrease the work load at
Eurostat level as part of these verifications is carried on by Eurostat.
Nevertheless, more actions will be undertaken by Eurostat to ensure the
reliability of the data collected therefore these savings are more
hypothetical.   
All in all as
shown in Table 1
below, the global balance of the proposed measures under Option 2 seems
positive leading to an annual average reduction of 10 working days for the MS
and 60 working days for the Commission. These results are broad estimates and
should be taken with precaution; the reality could vary from one MS to another
in positive or negative terms depending on the actual situation in each MS. In
this table, all data were reported on an annual basis, the time needed to
establish the tri-annual reports was therefore divided by 3.  
 Proposed initiative || Man/days/year Member States || Man/days/year Commission 
 Tri annual reports Waste Framework Directive Landfill Directive Packaging Directive Report from the Commission ||   - 15 per MS, – 420 for EU 28 - 10 per MS, -382 for EU 28 -10 per MS, – 280 for EU 28   ||         - 40 
 Third party verification Municipal waste statistics Landfill statistics Packaging statistics Construction and demolition waste Verification at EU level ||   +5 per MS, + 140 for EU 28 +5 per MS, + 140 for EU 28 +10 per MS, + 280 for EU 28 +5 per MS, + 140 for EU 28   ||           (-20) 
 Total || - 10 per MS, - 280 for EU 28 || - 60 
Table 1: Estimation of the annual impacts on administrative
burden of Option 2
As it is
proposed to introduce at the same time a package of measures aiming at
simplifying reporting obligations while improving the quality of the statistics
(third party verification and National registries) and as the main impacts of
these measures were assessed in this report (no significant impacts
identified), it is not the intention of the Commission to undertake separate
impact assessments when the technical requirements (third party verification
and National registries) will be later defined through delegation.    
Defining minimum
condition for EPR schemes might contribute to reduce the costs of the EPR
systems while ensuring higher recycling and reuse levels. As detailed in
section 2.3.3 some MS have managed to increase the recycling rate for packaging
waste to levels similar to the proposed targets for 2030 while ensuring a level
of fee to be paid by the importer/producer and at the end by the consumer lower
than in other less performing MS. It might therefore be expected that when a
minimum level of harmonization is ensured, the cost effectiveness of most of
the existing EPR will progressively improve. The elaboration of guidance on
best practice at EU level can also contribute to the cost effectiveness of the
systems. 
For instance, it
has been estimated that the full cost coverage of household packaging in Belgium through the EPR systems represents around €7.90[14] per
year per capita for an average recycling rate of 85 % which is the highest in
the EU. According to the available data, these costs vary
from €5.50 € per year and per inhabitant to €19.70/year in the
other MS – all of them meeting lower recycling rates. When comparing the fees
paid by producers/importers per ton of packaging material put on the market,
similar discrepancies appear: average fees charged to producers range from
€14/ton to €212/ton (€21/ton in BE), with an average of €105/ton.  In addition,
in Belgium – like in some other MS – a specific budget is reserved to combat
littering originating from packaging – around € 2M in 2012. In the NL, this
amount raise to €20 M per year or €1,19 per year and per inhabitant.[15]

Option 3:
Upgrade EU targets  
In order to
compare the added value of upgrading the EU targets, the basis for the
comparison of Options 3 is the full implementation scenario. Therefore, all
the results provided in this section are relative to the full implementation
scenario. 
Option 3.1:
Increased municipal waste recycling and preparation for reuse targets 
As detailed in
section 4, two levels of targets have been considered:

 First a low level of 60% by 2030
     (Option 3.1 – low)
 A high level of 70% by 2030 (Option
     3.1 - high)

The main results
are detailed below: 
 Option 3.1 –
Low: Increased MSW Targets at 60% in 2030
As shown in Figure
8
below, compared to the full implementation scenario, Option 4.1 (low) implies a
progressive increasing of recycling of 14% while at the same time landfilling
and incineration are progressively reduced by 5%. The mass loss line represents
losses from MBT processes, the use of which is also significantly reduced.
These effects occur because in some countries, investments in incineration and
MBT are made in the full implementation scenario, so the higher target
effectively forestalls some of the investment in incineration and MBT in some
countries.
Figure 8:
Option 4.1 low – Mass flow changes (% relative to full implementation, EU 28) 
Financial Costs 
Under this
Option, the overall costs for the MS become negative as from 2020. This is a
result from the avoided costs of waste being collected and treated as residual
waste: more and more waste is diverted from mixed door to door collection
systems into a combination of bring and door to door separate collection system
which allow progressive savings. 
The modelling
assumes that in the full implementation scenario, many countries have already
had to invest significantly in the upgrading of collection services relative to
the situation they were in in 2011 (the latest year for which data is
available).   
Figure
9:
Option 3.1 (low) - Financial Costs (M€ - relative to full implementation, EU 28)
In moving to
higher recycling rates, the capture of materials for recycling increases and
the revenue generated from the sale of materials increases (so the costs, net
of revenue generation, decline). At the same time, the quantity of residual
waste requiring collection and treatment declines leading to reduced frequency
of refuse collection and savings on the delivery of the collection service. In
summary, the effect of measures which encourage/ incentivise the use of the
services for recycling is to improve the efficiency of the logistics, and
capture more revenue from each household. This explains the effect on
collection costs in this and other high recycling scenarios in this impact
assessment
Environmental
Costs
There are
significant benefits derived from the recycling of more material. The majority
of these benefits are associated with the avoided GHG/Air emissions related to
recycling but other significant benefits result from avoiding GHG and air
pollutant emissions from residual waste treatment and disposal. 
Figure
10:
Option 3.1 (low) - Externalities (M€, relative to full implementation, EU 28)
Net Social Costs
With both the
financial and environmental costs proving to be favourable relative to full
implementation it is no surprise that the net position of Option 3.1 Low is
very favourable – see Figure
11.
The benefits exceed the costs in all years, though only marginally so in early
years. 
Figure 11:
Option 3.1 (low) – Net Social Costs (M€ relative to full implementation, EU 28)
Employment
This Option also
leads to an increase in employment. The estimated increase in direct employment
is 78,519 (FTE – Full-time equivalent) across the EU. The effects in each MS
are shown in the Figure below.
Figure
12:
Option 3.1 (low) – Employment change relative to full
implementation by 2030
Option 3.1-
High: Increased MSW Targets at 70% by 2030
Compared to the
full implementation scenario, Option 3.1 (high) implies a progressive increase
of recycling up to 70%. In this case, a higher proportion of the switch,
relative to full implementation, comes from reducing incineration (and MBT –
indicated, in part, by the change in ‘mass loss’, which is associated with this
management method). 
Figure
13: Option
3.1 low – Mass flows changes (% relative to full implementation, EU 28) 
Financial Costs 
Under this
Option, as for the previous one, the overall costs for the MS are negative.
This is as a result of significantly reduced residual waste collection and
treatment costs. However, the effect is more pronounced than in Option 3.1- low
for obvious reasons.
Figure
14:
Option 3.1 (high) - Financial Costs (M€, relative to full implementation, EU 28)
Environmental
Costs
The
environmental benefits from this Scenario are higher than those achieved under
the previous Option, and they are also delivered earlier in time. This option
sees new marine litter inflows which are 10% lower than those projected under
the full implementation scenario. 
Figure
15:
Option 3.1 (high) - Externalities (M€, relative to full implementation, EU 28)
Net Social Costs
At the level of
the EU28 net position is even more favourable than under the 60% recycling
Option as the benefits are higher, and the increase in benefits exceeds the
additional costs - see Figure
16.
However, one of the issues with this Option is that it might represent a
challenge to some countries to achieve the targets even if as explained in
Section 4.4 some EU Regions have already met higher recycling rates in 2010. A
more detailed view of the Net Present Value (2014 – 2030) of the costs and
benefits for each MS are shown in Figure
17.
All countries expect RO and PL will experience a net social benefit (i.e.
negative costs). 
Figure 16:
Option 3.1 (high) – Social Costs (M€, relative to full implementation, EU 28)
Figure 17: Option 3.1, high – NPV 2014-2030 costs/benefits (M€
to full impl EU 28)
Employment 
This Option also
leads to an increase in employment. The estimated increase in direct employment
is 137,585 FTEs in 2030.
Option 3.2:
Increased Packaging targets  
Option 4.2
implies a progressive increasing of packaging recycling up to 80%. As part of
packaging waste is of municipal origin, this will have an influence on the
municipal waste recycling rate (increase by around 10% by 2030. As shown in Figure
18,
landfilling is expected to progressively decrease as well as incineration in
some MS. Most of the changes will start in 2016 when the possible new targets
would be known by MS.
Figure 18:
Option 3.2 – Changes in mass flows (% relative to full implementation, EU 28) 
Financial Costs 
Under this
Option, the overall costs for the MS show net benefits very early on. As with
previous Options, this is a result of the two competing effects, one from the
increase in the cost of recycling, the other from the avoided costs of waste
being collected and treated as residual waste. The effects are more pronounced
because in Option 3.1 a significant proportion of the waste collected and
treated for recycling is biowaste. This entails costs both in collection and
treatment, whereas the collection of dry recyclables leads to the capture of
material which can generally be sold at a better price.   
Figure
19:
Option 3.2 - Financial Costs (M€ relative to full implementation, EU 28)
Environmental Costs - This
Option is associated with significant environmental benefits, primarily due to
the reduced reliance on incineration and landfill, both associated with fairly
significant environmental impacts (these relate to GHGs and emissions to air, see
Annex 6) 
Figure
20:
Option 3.2 - Externalities (M€ relative to full implementation, EU 28)
Net Social Costs
When considering
the EU28 as a whole the net position of this Option is very favourable and is
clearly linked to overall financial and environmental benefits – see Figure
21.
On a MS level this Option also yields net social benefits for the vast majority
of countries. Figure
21
shows the Net Present Value (2014 – 2030) of the costs and benefits for each
MS. It is evident from this that the variance across MSs is quite significant,
this is due, at least in part, to the size of the economies and the relative
amount of packaging materials that are placed on the market in these countries
(e.g. Germany, France, Italy, and the United Kingdom).   
Figure 21:
Option 3.2 – Net Social Costs (M€ relative to full implementation, EU 28)
Figure 22: Option 3.2 – NPV 2014-2030 costs/benefits
(M€ relative to full implementation)
Employment
Option 3.2 also
leads to an increase in employment. The estimated increase in direct employment
is 107,725 FTEs.
Option 3.2 –
Metal spilt 
The split
between targets for ferrous and non-ferrous metals is expected to bring
additional benefits as more Aluminium will be captured and recycled leading to
additional avoided GHG emissions due to the ‘energetic content’ of Aluminium
requiring a lot of energy for its production. The overall difference of NPV
(2014-2030 at EU 28 level) between Option 3.2 without metal split and with
metal split is estimated at 3,87 billions €.    
Option 3.3
Measures to limit landfilling 
As detailed in
section 4, in this Option, landfilling will be progressively limited to 25% by
2025 for all MS and to 5% by 2030. This Option assumes that a
landfill ban is implemented in isolation without additional efforts on
recycling – which might not correspond to the reality in all MS. Nevertheless,
in absence of clear indication on how MS would react to the introduction of a
ban in isolation of additional measures, it was assumed that MS will respond by
constructing treatment capacities – mainly incineration capacities see Figure
23
below - to deal with the residual waste remaining after full implementation has
been achieved. As for option 3.2, it was assumed that most of the changes will
start in 2016 when the possible new targets would be known by MS. 
Figure 23:
Option 3.3 - Changes
in mass flows (%relative to full implementation, EU 28)
Financial Costs 
The costs of
this upfront investment are clear in the graph below. The
increase in costs relates mainly to the fact that, because this is a cost
benefit analysis and excludes taxes and transfers from the analysis, the costs
of landfilling exclude the effect of instruments such as landfill and
incineration taxes, and the support mechanisms in place in some countries for
renewable energy. Under these assumptions, the costs of switching from landfill
(without tax) to other residual waste management options are relatively high
and not least in those countries where landfill clearly remains a very low cost
option.
Figure
24:
Option 3.3 - Financial Costs (M€ relative to full implementation, EU 28)
Environmental
Costs
This scenario is
associated with environmental benefits as materials are diverted from landfill
and additional energy is produced by burning more waste. 
Figure
25:
Option 3.3 - Externalities (M€ relative to full
implementation, EU 28)
Net Social Costs
The overall
position of this Option is that there is a net social cost as MS respond to the
ban by constructing residual waste treatment capacity to deal with the residual
waste that remains after MS have achieved full implementation of the existing
legislation. The slight environmental benefits associated with this change in
the early years are clearly outweighed by the costs. Essentially, this implies
that the additional costs of switching from landfill to other residual waste
treatments exceed the benefits that flow from such a switch. 
This is broadly
consistent with the majority of other studies on the costs and benefits of
landfill and incineration.
Figure
26:
Option 3.3 – Net Social Costs (M€ relative to full implementation, EU 28)
Employment
This Option also
leads to an increase in employment. The estimated increase in direct employment
is 46,165 FTEs. This reflects the fact that the residual waste treatments are
less ‘employment intense’ than other forms of treatment. 
Option 3.4: Combined
option 
On the basis of
the above analysis, the following option has been considered for assessment:

 The MSW targets stretched to 2030;
     with 
 The increased packaging targets;
     and
 The restriction on MSW landfilled
     (to 5% of total) by 2030. 

In the first
instance, this combined option has been considered as being applied at the same
level for all countries. The landfill restriction has been retained despite the
net social costs indicated by the analysis of the impact of a landfill ban in
isolation of an increase of recycling targets. The analysis from the modelling
does not include all environmental externalities, notably those associated with
emissions to water and land, which might be expected to be of some significance
for landfilling, possibly in the longer term. The approach is also aligned with
the vision set out in the Resource Efficiency Roadmap and 7th EAP. 
As shown in Figure
27,
this option implies an increase of recycling of 25% compared to the full
implementation Scenario. 
Figure 27:
Option 3.4 - Changes in mass flows (% relative to full implementation, EU 28)
The graphics
below indicate the financial costs (Figure
28),
the environmental costs (Figure
29),
and the net social costs of the proposed combination of options (Figure
30
and Figure 31). As
stated above all figures are given relative to full implementation. 
Figure 28:
Option 3.4 – Financial Costs (M€ relative to full implementation, EU 28)
Figure 29:
Option 3.4 - Externalities (M€ relative to full implementation, EU 28)
The marine
litter modelling demonstrates that the combined effect of Option 3.4 is that
projected new marine litter inflows are found to be 27,5% lower than those
projected by the full implementation of existing legislation only by 2030. The
decrease to 2020 is less pronounced  (13%) since most of the measures only
enter into force after 2020.
Figure 30:
Option 3.4 – Net Social Costs (M€ relative to full implementation, EU 28)
Figure 31: Option 3.4 – NPV 2014-2030 costs/benefits (M€
relative to full implementation)
As detailed in Figure
32,
the approach would generate an estimated 177,637 FTEs in terms of employment
across the EU.

Figure 32:
Option 3.4 - Changes in employment by 2030 relative to full implementation
Options 3.5 and
3.6 
The impacts of options
3.5 and 3.6 as detailed in Section 4.4 are the same in terms of mass flow
changes in the longer term than for option 3.4: imposing more stringent but
still realistic deadlines could be achieved thorough differentiated deadlines
per Group of MS or with time derogation for some MS according to their actual
situation in terms of waste management. The difference between options 3.5 and
3.6 with option 3.4 is more significant for ‘Group 2’ and less important for ‘Group
1’ MS. 
For Group 1 and
2 MS, the costs and benefits of increased recycling will be captured more
rapidly than in option 3.4 which will have an influence on the net present
value (NPV) at the EU 28 level: both options 3.5 and 3.6 will lead to an
additional NPV of the net benefits of € 27,2 billion compared to the NPV of
Option 3.4. Also the creation of jobs will be more rapid for Groups 1 and 2 if options
3.5 and 3.6 are implemented. 
Option 3.7- Extension
of landfill restrictions to other waste similar to municipal waste  
Extending the
proposed municipal waste landfill ban to all non-municipal waste landfilled in
‘Category 2’ landfills (designed to accept municipal waste and similar waste
according to the Landfill Directive) would concern around 58 million additional
tons of waste (55% increase compared to municipal waste). 
In absence of
any quality data on the composition of this additional waste and due to the
lack of a clear counterfactual in terms of how such wastes might be managed in
future, it has been assumed that:
·        
Such
waste have a composition similar to municipal waste;
·        
Extending
the ban to all similar waste would increase recycling in the same proportion
than for MSW (70%), as well as a shift in the management of residual waste from
landfill to various treatment options. 
On this basis,
it has been assumed that the present value (NPV 2014-2030, EU 28) of the social
costs increased by 3.35 billion € compared to Option 3.4. It should be noted,
however, that the different waste compositions will, in reality, affect
environmental benefits, whilst the costs may be expected to be different, in
reality, than for the municipal wastes. 
In practice,
extending the proposed ban to all waste entering ‘Category 2’ landfills will
facilitate the enforcement of the proposed ban as it would apply independently
from the origin of the waste as long as its composition is similar to municipal
waste.   
Main
uncertainties associated with the model 
The modelling
which forms the basis for the IA is complex and incorporates a range of
assumptions and variables which can be expected to influence the assessment.
The main uncertainties are related to the design of collection systems in the
MS, collection and treatments costs, waste composition and its evolution,
material and energy values over time and GHG damage valuation. A summary of the
main uncertainties is provided in Annex 8. 
Nevertheless, it
should be noted that:
1.    The
model has been subject to peer review;
2.    Considerable
efforts have been made to ensure assumptions are reasonable, and the modelling
is based on the best information available (20 country visits were achieved to
gather the most recent and relevant data);
3.    These
efforts will be carried on by the EEA as the model will become a permanent tool
maintained and improved by the EEA.
Finally, these
uncertainties if they might influence the results in absolute terms, they will
not change the relative position of the impacts of the different Options
assessed in this IA. 
1.3.        Impacts on groups of stakeholder 
Public
authorities/ citizens: Meeting the proposed targets will
imply in some zones additional direct costs particularly where separate
collection have to be launched.  These direct costs will be largely compensated
by the expected benefits at society level. As shown in section 5.2, direct
savings might be expected in the midterm as less residual waste will have to be
collected and treated. These savings should be beneficial for public
authorities and for citizens (less waste related taxes).  
Nevertheless, experience
confirmed by the results of the model (full implementation scenario), shows
that direct costs are expected to increase in the first years as it is
necessary to launch new ways of collecting waste (separate collection) and new
waste treatment infrastructures (sorting centre, composing and digestion
facilities, energy recovery infrastructures in the MS landfilling high level of
waste). These costs have to be partly covered by public authorities in charge
of waste management.  
There are
several ways of limiting he direct costs for the public authorities linked with
improved waste management techniques: 

 Focusing on the prevention of waste
     through fostering heightened awareness of the issue, and collaborating
     with private sector companies to design waste out of systems, or make the
     wastes more easily re-useable / recyclable; Citizens
     can be beneficiaries of waste prevention: for example, initiatives which
     have highlighted the level of waste of food have also brought to the
     attention of citizens the simple truth that wasting food wastes money;
 Improving governance - ensuring a
     better coordination between the authorities in charge of collecting and treating
     can lead to an integrated approach of waste management and a reduction of
     the costs;
 Focusing on efficiency of service
     delivery – the evidence suggests that there are further gains to be made
     in terms of improving the design of collection services and in ensuring
     citizens are able to participate easily in the system;
 Midterm targets – fixing at EU
     level a clear perspective at a mid-term horizon will avoid inappropriate
     investments which at the end are often paid by the local authorities; 
 EPR schemes – have proven to having
     helped to cover the costs for launching separate collection – as detailed
     above, there is still large possibilities of optimizing these EPR schemes
     while expanding them to other waste streams;  
 PAYT systems – the application of ‘clever’
     PAYT systems are very effective to favour prevention and the participation
     in separate collection schemes, which in turn limit/reduce the overall
     costs of waste management. 

As detailed in
section 4.3, an optimal combination of economic instrument can contribute to
improve waste management while limiting the overall cost of the system. In that
sense, ensuring the dissemination of best practice is essential particularly in
those MS where additional efforts will be needed to meet the proposed targets –
which is one of the objectives of the proposed ‘early warning procedure’.  
Manufacturing
industries should be benefit from the re-injection in the EU
economy of secondary raw materials (limiting the risk of raw material prices
increase). In
addition, it has been demonstrated that EPR schemes could be optimised notably
through EU harmonisation which in turns could limit the fees to be paid by the
producers/importers when they pace goods on the EU market. In the midterm, the
manufacturing industry might also have to progressively modify the design of
the products in order to ease the achievement of the European targets. 
Waste operators whether
large companies or SME involved in waste collection and treatment should
benefit from better implementation of existing legislation and from new
targets. As highlighted during the stakeholder consultation, new business
opportunities will be created whether in collection, sorting or treatment
sectors. The main potential loser might be landfill and low performing MBT operators
but this should be limited as most of them are part of larger waste management
group already having diversified their activities. Similarly in a limited
number of countries few incinerator operators might meet difficulties to feed
their oversized infrastructures. This might be attenuated by imports from MS
lacking incineration infrastructures.  The recycling industry: Reinforcing
the target will create new opportunities and push for more innovation notably
in sorting and recycling techniques. Social enterprises active in waste
re-use could also benefit from additional stimulus to favour reuse for instance
in the second hand sector. 
Improved waste
management might impact SMEs as additional efforts might be required to
ensure proper at source waste separation. At the same time increasing
prevention, reuse and recycling might also reduce the costs of waste
management. SMEs flexibility, adaptability, and their willingness and ability
to innovate also represent an asset for instance for the development of new
techniques for improving waste sorting, reuse and recycling.  The SME sector is
a large part of the waste industry and some SMEs will be beneficiaries of a
more forward thinking vision for waste management. As suggested during the
seminar with SME’s held in preparation of this IA, some simplification measures
should be envisaged for SME’s handling small quantities of waste. 
The tourism and
the fishery sectors would also benefit from reduced marine litter.

2.                      
Comparing the Options
In this section,
the impacts of the options are compared between them. First the Options are
compared on the basis of quantified data when they are availbale ( costs and
benefits, impacts on employment and contribution to marine litter reduction).  Then,
a qualitative comparison of the options is achieved by assessing their relative
 contribution  to each objective identified under section 3. From this combined
analysis, a prefered  option is then identifed and proposed.    
2.1.        Costs, benefits, employment and marine litter  
The
following Graphic shows the net social costs of each option compared to the
full implementation scenario. 
Figure
33:
Comparing the options – Net social Costs (billions €, EU 28)
Option 3.4 with
an extended landfill ban to all waste similar to municipal waste provides the
highest ratio Cost/Benefits and represents the most interesting Option at
society level. 
The impacts from
2014 to 2030 of each option for key indicators is summarised in Table
2
below. The greatest net benefit on the period 2014-2030 is delivered by Option 3.7.
In terms of job creation, Options 3.4, 3.5, 3.6 and 3.7  are the most promising.
Options 3.4 and 3.7 delivers the best result in terms of GHG emission reduction
(- 44 million Tons of annual GHG equivalent emission in 2030 and -62 million
tons with an extension of the landfill ban to all similar waste). 
With the implementation of the Options
3.4 to 3.7 and compared to the full implementation scenario, marine litter
could be reduced by an additional 13% by 2020 and by an additional 27,5% by
2030.[16] Additional
savings coming from reduced marine litter inflows, by 2030 under these Options
are estimated at 143 m€, mainly as a result of reduced beach cleaning and
avoided damage to fishing vessels and gear (see Annex 9).   
 Option || Financial costs (NPV 2014-2030), € billion (1) || External costs (NPV 2014-2030) € billion (2) || Net social costs (1+2) || Jobs (FTEs in 2030) || GHG million tonnes CO2eq (2030) || GHG million tonnes CO2eq (2014-2030) 
 Option 3.1- low || -3.73 || -3.96 || -7.69 || 78,519 || -23 || -107 
 Option 3.1- high || -8.41 || -8.49 || -16.91 || 137,585 || -39 || -214 
 Option 3.2 || -11.2 || -8.45 || -19.66 || 107,725 || -20 || -183 
 Option 3.2 – metal split || -13.48 || -10.05 || -23.53 || 107,643 || -24 || -250 
 Option 3.3 || 5.64 || -0.65 || 4.99 || 46,165 || -13 || -49 
 Option 3.4 || -12.65 || -13 || -25.65 || 177,637 || -44 || -308 
 Option 3.5 and 3.6 || -13.62 || -13.58 || -27.2 || 177,628 || -44 || -320 
 Option 3.7 || -10.7 || -18.3 || -29 ||   || -62 || -443 
Note, negative
costs represent a benefit  
Table
2:
Comparison of key indicators of the options retained
2.2.        Contribution to the main objectives, efficiency and
coherence  
In Table 13
below, the relative contribution of each option to the main objectives as
identified in section 3 is summarised. 
With Option 1
– Full implementation, the legislation will remain complex and difficult to
enforce properly, there will be no guarantee that best practices will be
disseminated especially in the MS facing poor waste management performances,
the level of the targets will remain too low to build a 'circular economy'. 
All the other
Options are compared to Option 1 as they come on top of full implementation of
the existing legislation.  
Option 2
scores best in terms of meeting some of the key objectives of this IA: several
measures are proposed to simplify the legislation (dramatic reduction of
reporting obligation, simplification of the measurement methods, removing
obsolete requirements, reduction of administrative burden for SME’s, etc).
Monitoring will be improved with the proposed measures to increase the
reliability of statistics and with the new early warning procedure. Best
practice will be disseminated with the implementation of the early warning
procedure. Nevertheless, without new upgraded targets the contribution of
Option 2 taken in isolation to resource efficiency will remain limited.
This option
contributes to several objectives as defined in section 3 (see Table below)
while some net savings could be expected (simplified reporting which should
compensate efforts required on statistics – see section 5.2). In that sense,
Option 2 can be seen as relatively efficient. Nevertheless, this Option is less
coherent with some overarching objectives of the EU polices (resource efficiency,
climate change, raw material access) than the other options including higher
targets even tough it will contribute to a better implementation of the EU
legislation which is also one of the overarching objectives of the EU.     
Compared to the
full implementation scenario (Option 1), Options 3.1 has limited
advantages in terms of simplification and monitoring (one measurement method).
The contribution to resource efficiency of Option 3.1 is positive (higher for
Option 3.1 – high) and meeting the proposed targets implies that best practices
are disseminated. 
Compared to the
full implementation scenario (Option 1), Options 3.2 has limited
advantages in terms of simplification and monitoring (removing obsolete
requirements and targets). The contribution to resource efficiency of Option 3.2
is positive and meeting the proposed targets implies that best practices are
disseminated notably in terms of improved EPR schemes.   
Options 3.3 has
limited advantages in terms of simplification and monitoring (replacement of
the landfill diversion target for biodegradable waste by overall landfill bans)
compared to the full implementation scenario (Option 1), The contribution to
resource efficiency of Option 3.3 is positive but limited as part of the waste
diverted from landfilling will be incinerated including waste that could have
been recycled. Meeting the proposed targets implies that best practices are
disseminated notably in terms of use of key instruments (landfill taxes
followed by landfill bans).   
Option 3.4 has more
advantages in terms of simplification as the proposed targets are consistent
and synergetic between them. The proposed deadlines for each target are
consistent between them as well as the level of the proposed targets. This
simplification will facilitate the monitoring of the targets and meeting high
levels of recycling while reducing landfilling will require the dissemination
of best practices in all MS. The contribution to resource efficiency is
considered as positive compered to –the full implementation scenario.
Compared to
Option 3.4, options 3.5 and 3.6 are less performing in terms of simplification
and monitoring as fixing differentiated targets depending on MS and/or allowing
for time derogation will not contribute to simplify the legislation and the
monitoring of the targets. The contribution to resource efficiency is
nevertheless higher mainly because more raw materials and resources are
captured earlier in several MS.  
Option 3.7
performs better in terms of simplification and monitoring (landfill
restrictions are applied to all ‘municipal’ type landfills independently from
the municipal origin of the waste).  
Options 3.4 to
3.7 have the most positive impact in terms of reductions of marine litter.
However, a significant portion of the gains made are as a result of avoided
increases in litter, rather than actual reductions of current litter inflows.
Therefore further action is needed to achieve the significant reductions in
marine litter called for in the 7th Environment Action Programme.
All Options
between 3.1 and 3.7 will contribute to the objectives as defined in section 3, Option
3.3 being the less cost effective (and therefore the less efficient) though Option
3.7 has the best cost/benefit ratio while contributing highly to all objectives.
The other Options are more of less efficient depending on their contribution to
the objectives compared to their costs and benefits – see Table
3.
As shown in Table
2,
the coherence with some overarching objectives of the EU polices (resource
efficiency, climate change, raw material access, job creation) is highest for Option
3.7 and lowest for Option 3.3 with intermediate situation for the other Options.      

 
   || Objective 1 - Simplify || Objective 2 - Improving Monitoring || Objective 3  - Best practices || Objective 4 – Resource efficiency || Efficiency || Coherence 
 Option 1 || 0  || 0 || 0 || 0 || 0 || 0 
 Option 2 || + + + || + + + || + + || + || ++ || + 
 Option 3 Option 3.1 - low Option 3.1 - high Option 3.2 Option 3.3 Option 3.4 Option 3.5 Option 3.6 Option 3.7 ||   + + + + + + + + + + + + + + ||   + + + + + + + + + + + + + ||   + + + + + + + + + + + + + + + + + + + + + ||   + + + + +  + + +  + + + + + + + + + ||   + + + + + - + + + + + + + + + ||   + + + + + + + + +  + + +  + + + + + + 
Table
3:
Comparison of the effectiveness, coherence and efficiency of the options  
2.3.        Preferred Option
From the above
analysis, it could be concluded that:
Option 2 would
be useful to support the implementation of existing targets but seems
indispensable if the proposed new targets arte applied. The measures proposed
in Option 2 contribute to several objectives defined in section 3 and could be
seen as ‘accompanying measures’ to ensure a proper implementation of the
targets. Nevertheless, Option 2 taken in isolation will not deliver the
expected results in terms of resource efficiency.  
Options 3.1, 3.2
and 3.3
taken in isolation will not deliver the best results in terms of consistency
between the proposed targets and cost and benefit ratio. As explained above, Options
combining the different targets (Options 3.4 to Option 3.7) seems to
be the most attractive. These options give a consistent perspective to
waste management in the EU on the basis of past experience of the most advanced
MS: landfill restrictions are progressively introduced and at the
same time recycling targets are progressively increased which should avoid
the creation of overcapacities of residual waste treatment facilities. 
The
proposed rate of progression of the recycling/reuse rates for municipal waste
are fully consistent with the proposed packaging rates and with the progressive
diminishing of landfilling: MS will progressively increase their packaging
recycling/reuse rates which will contribute to increase the municipal
recycling/reuse rates and at the same time reduce landfilling of municipal
waste. By 2030, with the proposed approach a maximum of 30% of municipal waste
will not be recycled or reused. This residual waste will be treated in residual
waste facilities (incineration with energy recovery, MBT, others) so that only
5% corresponding to the not recoverable fraction will be at the end
landfilled.  This fully consistent approach for target setting was a repeated
demand from the majority of the stakeholders. 
Between Options
3.5 and 3.6 there is no clear preferences: fixing more
stringent deadlines for some MS as proposed in these options  allows capturing
the potential benefits linked with improved waste management earlier (higher
NPV). At the same time, fixing different deadlines complicates slightly the
legislation even if it is already the case for some waste related Directives
for which the deadline diverges according to the MS. Option 3.5 and 3.6 have
pro and cons in terms of acceptability by the MS depending on the position of
the MS. Fixing the same deadlines for all MS in a realistic way implies that
the less performing MS are driving the ambition level of the EU legislation. 
Nevertheless,
these targets are minimum targets, nothing prevents MS from meeting more
ambitious levels and/or more rapidly than the deadlines fixed in the
legislation.
Option 3.7
expanding the landfill ban to all waste similar to municipal waste is the most
attractive in terms of simplification, monitoring, best practice dissemination,
resource efficiency, but also in terms of Cost/benefit ratio, job creation and
GHG emission reduction.     
This Option is
similar to the main orientations provided by the Committee of the Regions[17] in
its outlook opinion on the target review – see Error!
Reference source not found. and is conform to the orientations of
the 7th EAP which were recently endorsed by the Parliament and the
Council. 
A combination of
Options 2 and 3.7 is therefore proposed. 
2.4.        Key implementation challenges  
The main
challenges related to the implementation of the proposed targets could be
summarised as follows (more details per stakeholder group are given in section
5.3):
·        
For
the less advanced MS, additional efforts will be required to develop separate
collection at source, build the required infrastructure, adapt the waste
management plans and strategies, and improve governance notably by ensuring a
better coordination between the local, regional and National levels. 
Measures
proposed to disseminate best practices notably through the ‘early warning’
procedure, the dissemination of economic instruments, proposed improvements of
EPR schemes (minimum requirements and guidance to MS) should ensure that these
MS are taking advantage of the experience of the other MS to design the
appropriate package of measures to meet the targets and at the end capturing
rapidly the potential savings linked with the implementation of the upgraded
targets.   
Enough time was
given to these MS to progressively meet the proposed targets (around 15 years
calculated on the basis of the past experience of the other MS). In addition,
as explained in section 4, all the proposed targets are already met today in
some MS which demonstrates that they are perfectly feasible from the
technical-economic point of view. In addition, new techniques have emerged at
all levels of the recycling chain (separate collection, sorting, recycling)
which should allow less advanced MS to make rapid progress in the coming
years.  
With the proposed
targets, a clear and robust perspective is provided allowing the development of
long term investment strategies. This will also provide clear lines for the
future use of structural funds which should be orientated on the first steps of
the waste hierarchy in line with the proposed targets. These funds could help
to accelerate the necessary changes even though the recent experience of some
MS (notably Estonia – see Box 2) has shown that an appropriate use of economic
instruments can deliver the expected results without using these funds. 
·        
For
few more advanced MS, some difficulties might appear when overcapacities of
incineration have been constructed. These temporary difficulties could be
addressed by increasing imports of waste from surrounding countries lacking of
infrastructure and not replacing the oldest or less performing facilities
notably in terms of energy recovery.   These changes have already started as
explained in section 2.5.2.
The experience
of the most advanced MS shows that meeting upgraded targets will not be
possible without a better use of key instruments, an improved organisation and
coordination of the competent authorities as well as the involvement of the
whole civil society from citizen, NGO’s to industry and public authorities. In
that sense, the proposed targets might be considered as a key driver to ensure
that enough efforts will be achieved by all MS to address the causes of the
problem identified in this impact assessment (such as issues related to
governance, lack of use of economic instruments, lack of public awareness,
inappropriate investments - see section 2.5). 
The proposed
“early warning” procedure will ensure that MS not making enough progress
towards the upgraded targets will be identified sufficiently well in advance so
that correcting measures (such as increased use of key instruments and improved
governance – see section 4.2) could be taken on time. 
Key compliance
challenges of the proposed targets are mainly related to the delivery of timely
and reliable waste generation and management statistics. This is a permanent
concern of the Commission which was also highlighted unanimously by the
stakeholder: without reliable data it is impossible to verify whether the
targets are met or not. Obviously perfect statistics do not exist but with the
proposed measures (development of additional guidance, establishment of
national waste registries, third party verification of key statistics,
reinforced role of Eurostat, clarification and simplification of the
measurement methods) the necessary data should be collected with a satisfactory
level of reliability. No new targets are proposed; simply the existing targets
are upgraded and simplified/clarified and some obsolete targets are repealed.  
In few member
States illegal landfilling still exists and pauses clear problems of
implementation. It is the responsibility of the Member States to combat illegal
landfilling by all means. From that point of view, the proposed revised targets
will not change the current situation – combatting illegal landfilling is a pre
requisite to meet the existing targets while respecting the existing EU
legislation (the Landfill Directive). From that point of view, no additional
impacts are expected from the introduction of the proposed upgraded targets compared
to the current situation. 
2.5.        Access to raw materials   
As shown in Table
4
below, model calculations estimate that from 2030 onwards more than 50 million
tonnes of the four key dry recyclables recovered from the municipal waste
stream may be available for processing in the EU under Option 3.7 relative to what
was recycled in 2011. This represents a more than doubling of what was recycled
in 2011. Compared to the EU consumption of raw material, the expected recycled
percentages in 2030 would vary from 3% (metals) to 43% for paper and cardboard, reflecting the relative consumption of the specific
materials in consumer applications. This represents an increased value of
around 7,2 billion € compared to what was recycled in 2011.  
 (Thousands of tons) || Recycling 2011 || Recycling 2030 – Option 3.7 || EU consumption 2011 || % recycled in 2030 / EU consumption 
 Paper/cardboard || 26,460 || 54,431 || 126,649 || 43% 
 Plastics || 8,595 || 20,093 || 146,256 || 14% 
 Metals || 6,562 || 10,799 || 315,174 || 3% 
 Glass || 12,601 || 18,449 || 95,516 || 20% 
Table 4: Additional recycled material with the proposed
option
As explained in
section 5.1.1, recognising that raw material costs are one the largest share of
input costs of the European manufacturing companies (between 30 and 40% of the
cost structures), increasing the availability of high quality secondary raw
materials for the EU market will have a positive  impact on raw material
prices. For several reasons, detailed in section 2.2 and 5.1.1, it is not
possible to make solid projections on this potential impact.  
The
implementation of the proposed package of measures will also have a direct
effect on other waste stream management: for instance, using economic
instruments for C/D waste and municipal/packaging waste such as improved EPR
systems or landfill/incineration taxes or PAYT systems will incentivize all
initiatives aiming at reducing, reusing and recycling all type of waste. These
positive effects can support the implementation of all waste related Directives
including Directives targeting waste streams including critical raw materials
(WEEE and end of life vehicle). 
As shown in the
following table, meeting all existing targets is more significant in terms of
raw material access. It has been estimated that more than 400 million tons
could be re-injected in the EU economy if all EU existing targets are
implemented, representing between 10 to 43% of the EU demand depending on the
material. 
  (Thousands of tons) || C/D waste || Recycling 2030 – Option 3.7 || WEEE/ELV’s || EU consumption 2011 || % recycled in 2030 / EU consumption 
 Paper/cardboard ||   || 54,431 ||   || 126,649 || 43% 
 Plastics || 7,842 || 20,093 || 1,279 || 146,256 || 20% 
 Metals || 15,684 || 10,799 || 5,865 || 315,174 || 10% 
 Glass ||   || 18,449 || 169 || 95,516 || 20% 
 Aggregates || 329,376 ||   ||   || 1568,457 || 21% 
Table 5: Amount of recycled materials – EU existing + proposed targets[18]    
2.6.        Conclusions 
Compared to the
full implementation scenario, this combination of Options 2 and 3.7 will bring
several benefits in terms of: 
·        
Administrative
burden reduction in particular for SMEs, simplification and better
implementation including by keeping targets ‘fits for purpose’
·        
Job
creation – more than 180.000 direct jobs could be created by 2030, most of them
impossible to delocalize outside the EU 
·        
GHG
emission reduction – around 443 millions of tons of GHG could be avoided between
2014 and 2030
·        
Positive
effects on the competitiveness of the EU waste management and recycling sectors
as well as on the EU the manufacturing sector (better EPR, reduced risk on raw
material access)
·        
Marine
litter levels 13% lower by 2020 and by 27,5% lower by 2030
·        
Reinjection
into the EU economy of secondary raw materials which in turn will reduce the
dependency of the EU on raw materials imports  
These midterm
targets will give a very clear signal to the MS, the municipalities, the
private waste management operators so that some mistakes made in the most
advanced MS – creation of over capacities of incineration – would be avoided.
It will also drive investments to the first steps of the waste hierarchy and
prevent the development of infrastructures leading to high level of residues
such as MBT facilities based on mixed waste. 
A set of
accompanying measures will allow facing most of the implementation challenges
related to the proposed upgraded targets. 
3.                      
Monitoring and Evaluation
The indicators
for measuring progress accomplished by MS to meet the key objectives are driven
by the legislation itself whether through the application of the waste
hierarchy or by the quantitative targets themselves. Key indicators to monitor
the achievement of the objectives are summarised in Table
6
below. Most statistics related to waste generation and treatment are already
collected by the MS and sent to the Commission (Eurostat/DG ENV).  As
explained, no new targets are proposed; the existing targets for which
monitoring tools are already in place are simply upgraded or clarified.   
 Indicator || Description, purpose || Who will collect/generate the indicator 
 Waste generation || Data on overall waste generation and per waste stream – comprising at least municipal, packaging, C/D waste are indispensable notably to follow progress of prevention || MS are already collecting these data and transmitting them to Eurostat 
 Prevention || As proposed in section 4, a specific new indicator might be calculated from existing data linking waste generation and GDP or consumption. This will give an indication on the effectiveness of prevention policies || Building upon EEA indicators under development, Eurostat databases and EEA reviews of waste prevention programmes 
 Waste treatment || Data on overall waste treatment and per waste stream – comprising at least municipal, packaging, C/D waste are indispensable notably to follow progress on targets || Eurostat - MS are already collecting these data based on existing legislation and gentlemen’s agreement 
 Distance to target       || Distance between most recent statistics/projected data and quantitative legal targets should be regularly generated to monitor MS progress towards the targets and take correcting measures if needed. Concerned targets are:  recycling/reuse rates for packaging/municipal waste, material recovery rate including backfilling for C/D waste, landfill diversion targets || MS are already reporting every 3 years on target attainment. As proposed in section 4, Eurostat should become the only recipient of all statistic even target related The EEA should generate regular projections 
 New possible indicators || Tonnages of various  type of materials lost for the EU economy, % of recycled materials re-injected into the EU economy, technical and economic viable potentials for recovering resources from waste in a circular economy || EEA 
Table 6:
Summary of the main indicators to be used for monitoring progress
A regular - every 3 years- follow-up of
the distance to target as they appear in the latest available statistics and
from projected data will be set in place notably in the context of the 'early
warning' procedure. As explained in section 4, this task might be accomplished
by the EEA notably by using the reference modelling tool. Other type of
indicators might be generated in the future such as the potential tonnage of
waste lost for the EU economy each year, the integration of secondary raw
materials into products et on the market, etc. It is also the
in the EEA intention to regularly update its ex post evaluation of MS
performances on municipal waste, so that progress achieved can be followed for
all MS. [19] 
[1] Reference 1 in Annex 2 (part 3/3 of document)
[2] Reference 1 in Annex 2 (part 3/3 of document)
[3] Source: reference 1 in Annex 2 (part 3/3 of document)
[4] Source : reference 21 in Error! Reference source not found.
[5] Source: reference 22 in Annex 2 (part 3/3 of document)
[6] Directive 2010/75/EU on industrial emissions, OJ
L 334, 17.12.2010, p. 17–119 
[7] Reference 23 in Annex 2 (part 3/3 of document)
[8]Issue Paper to the "International Conference on Prevention and
Management of Marine Litter in European Seas"http://www.marine-litter-conference-berlin.info/userfiles/file/28-03-13_Issue%20Paper_Version%20to%20be%20discussed%20at%20the%20conference.pdf

[9] See Reference 6 in Annex 2 (part 3/3 of document)
[10] Reference 6 in Annex 2 (part 3/3 of document)
[11] Reference 1 in Annex 2 (part 3/3 of document)
[12] Source: contacts in Member States 
[13] Based on Commission past experience 
[14] Source: reference 5 in Annex 2 (part 3/3 of document),  2011 data; due to
higher material prices, this cost was even lower in 2012
[15] Source: Annex 7 (part 3/3 of document)
[16] This is compared to a 12,3% increase to 2030 under the BAU scenario,
knowing that it does not take into account the reduction potential of up 80% in
the consumption of single-use plastic bags identified in the IA accompanying
the recent related Commission proposal
[17] This Committee represents local and regional authorities which are
in first line for what concerns municipal waste management
[18] Source : reference 24 in Error! Reference source not found.               
[19] See Reference 7 in Error! Reference source not found.
Table of Contents
Annex 1: List of Acronyms and abbreviations &
Glossary. 3
Annex 2: List of studies and sources used in the Impact Assessment 5
Annex 3: Summary of the main elements of the stakeholder
consultation. 8
Annex 4: Detailed results of the on line consultation on
the target review.. 13
Annex 5: Attainment of the European waste Targets. 15
Annex 6: Main reasons for rejecting some options. 20
Annex 7 : Summary of MS reporting obligations. 22
Annex 8: Overview of the European Reference Model 23
Annex 9: Overview of the Marine Litter module of the
European Reference Model 24
Annex 10: Summary of the main Model uncertainties. 33
Annex 11:  Comparison of the main definitions used in the
EU waste legislation. 35
Annex 1: List of Acronyms and abbreviations &
Glossary
7th EAP
- 7th
Environment Action Program  
Backfilling
means a recovery operation where suitable waste is used for reclamation
purposes in excavated areas or for engineering purposes in landscaping and
where the waste is a substitute for non-waste materials
BAU – Business
as usual
C&D waste –
Construction and demolition waste, which includes concrete, bricks, gypsum,
wood, glass, metals, plastic, solvents, asbestos and excavated soil arising
from activities such as the construction of buildings and civil infrastructure,
total or partial demolition of buildings and civil infrastructure, road
planning and maintenance 
EEA - The
European Environment Agency 
ETC/SCP - European
Topic Centre on Sustainable Consumption and Production 
Energy recovery – The
use of waste as fuel or other means to generate energy. Directive 2008/98/EC
introduced specific new criteria to determine the efficiency level at which
incineration in municipal waste incinerators can be deemed an energy recovery
rather than disposal activity
EPR - Extended
Producer Responsibility – these systems makes those placing goods on the market
– producers, importers - responsible for the waste collection and treatment of
the waste generated
EU-15 – EU
Member States having joined the Union before 2004.
EU27 – All
EU Member States except Croatia.
FTE – Full
time equivalent  
GDP - Gross
Domestic Product 
IA - Impact
Assessment 
IASG - Impact
Assessment Steering Group
Industrial waste
–
Industrial waste is waste generated in industrial and manufacturing processes
such as basic metals, food, beverage and tobacco products, wood and wood
products and paper and paper products
LCA –
Life cycle assessment (or analysis) – the investigation and evaluation of the
environmental impacts of a given product or service caused or necessitated by
its existence
MBT – Mechanical
Biological Treatment facilities – facilities combining different
mechanical and biological treatment usually aiming at treating residual waste
(after separate collection) 
MS – Member State 
MSW - Municipal solid
waste
– Article 2 of Directive 1999/31/EC defines municipal waste as waste from
households, as well as other waste which, because of its nature or composition,
is similar to waste from households
MSFD –
Marine Strategy Framework Directive (2008/56/EC)
NPP – National
prevention programmes – Article 29 of the WFD requires MS to prepare waste
prevention programmes by end 2013
Preparing for
re-use
– Article 3 of Directive 2008/98/EC defines preparing for re-use as ‘checking,
cleaning or repairing recovery operations, by which products or components of
products that have become waste are prepared so that they can be re-used
without any other pre-processing’
PAYT -
'Pay as you thrown' systems. These systems also called variable rate pricing
are systems in which residents are charged according to the waste they actually
produced. There are different ways of metering the waste produced either
sophisticated systems where waste is weighted or more simple systems where a
tax is applied per waste bag according to its volume
PPWD -
Packaging and Packaging waste Directive
PRO –
Producer Responsibility Organisation – collective organisation aiming at
ensuring that the obligations of financing/meeting waste management targets
(reuse/recycling) laying on producers/importers when they place goods on the EU
market are fulfilled
Recovery –
Article 3 of Directive 2008/98/EC defines recovery as ‘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’
Recycling –
Article 3 of Directive 2008/98/EC defines recycling as ‘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
organic material but does not include energy recovery and the reprocessing into
materials that are to be used as fuels or for backfilling operations’. As
detailed in Annex 11, there are some differences in the definition of
the concepts of ‘recycling’, ‘recovery’, ‘reuse’ and municipal waste between
the WFD, the Landfill and the PPWD 
REFIT - Regulatory
Fitness and Performance (REFIT) Communication, COM (2013) 685
Re-use –
Article 3 of Directive 2008/98/EC defines re-use as ‘any operation by which
products or components that are not waste are used again for the same purpose
for which they were conceived’
Waste Hierarchy –
Article 4 of Directive 2008/98/EC makes the waste hierarchy a ‘priority order’
in waste prevention and management legislation and policy, and defines it as,
in order of preference: (a) prevention; (b) preparing for re-use; (c)
recycling; (d) other recovery, e.g. energy recovery; and (e) disposal
Waste prevention
–
Article 4 of Directive 2008/98/EC defines prevention as
‘measures taken before a substance, material or product has become waste, that
reduce: (a) the quantity of waste, including through the re-use of products or
the extension of the life span of products; (b) the adverse impacts of the
generated waste on the environment and human health; or (c) the content of
harmful substances in materials and products’
Waste TS –
Thematic Strategy on the Prevention and Recycling of Waste COM (2005) 666
adopted in December 2005
WEEE - waste
from electric and electronic equipment 
WFD –
Waste Framework Directive originally adopted in 1975 and revised in 2008 as
Directive 2008/98/EC
Annex 2: List of studies and sources used in the Impact Assessment
1)      Target
review project, DG ENV support contract for the preparation of the impact
assessment, Eunomia with Argus, Öko Institute and Copenhagen Resource Institute
and Satsuma Media, final report in approbation process, http://www.wastetargetsreview.eu/ 
2)      Past
and future climate benefits from better municipal waste management in Europe, EEA 2011,  http://www.eea.europa.eu/publications/waste-opportunities-84-past-and  
3)      Technological,
Socio-Economic and Cost-Benefit Assessments Related to the Implementation and
Further Development of EU Waste Legislation, Eunomia with Argus, Öko Institute
and Copenhagen Resource Institute and Satsuma Media, final report in
approbation process, http://www.wastemodel.eu/

4)      Use
of economic instruments and waste management performances, Bio Intelligence Service
with IEEP, Eunomia, Ecologic, Arcadis and Umweltbundesamt, April 2012, http://ec.europa.eu/environment/waste/pdf/final_report_10042012.pdf 
5)      Application
of the ‘producer responsibility’ principle in the context of waste management,
Bio Intelligence Service with IEEP,
Eunomia, Ecologic, Arcadis and Umweltbundesamt, December 2013,  http://epr.eu-smr.eu/ 
6)      Support
to Member States in improving waste management based on assessment of Member
States' performances, Final report, May 2013, BiPro with Arcadis and
Enviroplan, http://ec.europa.eu/environment/waste/framework/support_implementation.htm

7)      Managing
municipal solid waste – a review of achievements in 32
European countries,  EEA report N° 2/2013, EEA 2013,   http://www.eea.europa.eu/publications/managing-municipal-solid-waste

8)      Treating
waste as a Resource for the EU Industry. Analysis of Various Waste Streams and
the Competitiveness of their Client Industries - Final report, ECSIP Consortium
for the European Commission, DG ENTR, August 2013 
9)      Study
of the largest loopholes within the flow of packaging material, Bipro Final
Report (ENV.D.2/ETU/2011/0043)
10)  Implementing EU
Waste Legislation for Green Growth – Final report, Bio Intelligence Service for
the European Commission DG ENV, November 2011  http://ec.europa.eu/environment/waste/studies/pdf/study%2012%20FINAL%20REPORT.pdf 

11)  EEA report
8/2011, "Earnings, jobs and innovation – the role of recycling in a green
economy", EEA 2011      
12)  Resource saving
and CO2 reduction potentials in waste management in Europe and the possible
contribution to the 2020 CO2 reduction target in 2020, PROGNOS and IFEU,
October 2008 http://www.prognos.com/CO2-study.609.0.html
13)   Is structural
measures funding for municipal waste management infrastructure projects
effective in helping Member States achieve EU waste policy objectives? European Court Auditor special report N° 20, 2012  http://www.eca.europa.eu/

14)  Municipal Solid
Waste Management Capacities in Europe (Draft), EEA-ETC/SCP, January 2014
15)  Investment
potential for the treatment of bio and recyclable municipal waste in the EU,
final report, EIB with the support of Prognos and Lameyer KW consult, November
2013 
16)  How to improve
EU legislation to tackle marine litter, IEEP for Seas at Risk, July 2013
17)  Assessment of
cumulative cost impact for the steel (2013) and aluminium industry (2013), http://ec.europa.eu/enterprise/sectors/metals-minerals/files/steel-cum-cost-imp_en.pdf and http://ec.europa.eu/enterprise/sectors/metals-minerals/files/final-report-aluminium_en.pdf
18)  EEA 2010 derived
from SERI GLOBAL 2000, Friends of the Earth Europe (2009), see: 
www.seri.at/resource -report    
19)  Mapping resource
price – the past and the future, Ecorys 2012
20)  Diverting
waste from landfill - Effectiveness of waste-management policies in the
European Union. EEA Report No 7/2009, http://www.eea.europa.eu/publications/diverting-waste-from-landfill-effectiveness-of-waste-management-policies-in-the-european-union

21)  Danish
Government (2013) Denmark Without Waste: Recycle More - Incinerate Less,
November 2013, http://www.mst.dk/NR/rdonlyres/EBE9E5D4-B765-4D4E-9954-9B713846E4CF/162130/Ressourcestrategi_UK_web.pdf
22)  Jakus P. M., et
al.  (1996) Generation of Recyclables by Rural Households, Journal of
Agricultural and Resource Economics, Vol 21 (1), pp 96-108; and Tiller K. H.,
et al. (1997) Household Willingness to Pay for Dropoff Recycling, Journal of
Agricultural and Resource Economics, Vol 22 (2), pp 310-320). A. Bruvoll, B.
Halvorsen and K. Nyborg (2002), Households' Recycling Efforts, Resources,
Conservation and Recycling, 36: 337‑354
23)  Bipro Final
Report (ENV.D.2/ETU/2011/0043): Study of the largest loopholes within the flow
of packaging material, p. 22
24)  Analysis of the
key contribution to resource efficiency, BIO Intelligence Service for DG ENV,
April 2012 
25)   EIMPack (2011) Economic
Impact of the Packaging and Packaging Waste Directive – literature review,
http://eimpack.ist.utl.pt/docs/Literature%20Review_final.pdf.
26)  ECOLAS and PIRA
(2005) Study on the implementation of the Directive 94/62/EC on Packaging
and Packaging Waste and Options to Strengthen Prevention and Re-use of
Packaging, http://ec.europa.eu/environment/waste/studies/packaging/050224_final_report.pdf
Annex 3: Summary
of the main elements of the stakeholder consultation 
Several
categories of stakeholder were consulted in the context of this IA: proper
waste management involves several actors including citizens, environmental
NGO’s, public authorities - from municipal, regional to national levels, public
or private waste management operators and industries placing goods on the
market involved in extended producer responsibility (EPR) schemes.    
A preliminary
consultation of 30 main European stakeholders was organised during the first
months of 2013. On this basis, the main themes for the review were identified
and a questionnaire was placed online for 14 weeks - between 4th
June and 10th September 2013. Additional in-depth consultations of
key stakeholders and MS were organised including 20 country visits between
April and July 2013 to discuss the assumptions used in the model and
preliminary results from the model. Two specific websites - one on the target
review and another on the model - were developed to inform stakeholders on
progress and allowed for further suggestions and comments.[1] 

As local and
regional authorities are key players in waste management, an ‘outlook’ opinion
was solicited by the Commission from the Committee of the Regions. This opinion
was adopted on 4th July 2013.  A summary of the main recommendations is given
below.   
An additional
online consultation was also organised on the establishment of a marine litter
reduction target, while a conference dedicated to the prevention and management
of marine litter in European seas was organised in April 2013 in Berlin.[2] 

Additional
presentations and discussions were organised around the target review including
in the relevant waste technical Committees created under the 3 Directives and
also workshops and seminars organised by key stakeholders. For instance, a
specific seminar on the application of the producer responsibility principle
was organised in September 2013, and was followed up by a stakeholder
consultation on the possible contents of guidance at EU level. 
The results of
the consultations on the Green paper on plastic waste including the report of
the Parliament on the Green paper[3]
were also taken into account, as well as the results of a specific seminar
focusing on SME’s and waste management held in December 2013 in follow-up of
the findings of the Top 10 most burdensome legislative acts for SME’s. 
On line
consultation 
Questions were
asked on the relevance of the issues pre-identified for the target review and
on this basis on the options proposed to solve these issues. Respondents were
asked to 'score' the proposed pre identified options as well as to give their
views on the possible evolution of the targets. They were invited to propose
additional issues and options to be considered. The results of the consultation
have been divided up to show the views of the different groups of stakeholders
- Industry, NGOs, Academics, Public authorities and European Citizens. [4]

A total of 670
responses were received during the consultation of which 216 from industry, 54
from NGO's, 49 from public authorities – whether National or Regional/local,
325 from citizens and 26 from other organisations including academic
Institutions. Detailed results of the on line consultation are provided in 
Annex 4. 
A consultation
on the establishment of a reduction target for marine litter was also
organised, asking respondents to identify relevant criteria for assessing
possible litter reduction actions and to evaluate the effectiveness of such
actions. 437 responses to the online questionnaire were received, predominantly
from consumers/interested individuals (273 responses). NGOs (43 responses),
academics/scientists (39 responses) and sectoral/industrial representatives (38
responses) were among those represented comparatively strongly. 8
local/regional authorities and 8 national authorities also responded.
Committee of the
Regions- summary of the outlook opinion 
On 4th
July 2013, the
Committee of the Regions issued an ‘outlook opinion’ on the waste target
review. In summary, the Committee recommended the following measures: 
·        
the
introduction of more stringent standards with respect to waste prevention,
based on the best results obtained to date. By 2020, the quantity of municipal
waste generated per person should be reduced by 10% in comparison with the
levels recorded in 2010;
·        
Member
States to be given binding, quantitative, separate, minimum targets for each
category of waste that is defined as reusable;
·        
raising
the current mandatory target for the recycling of solid municipal waste to 70%
by 2025, with intermediate targets and transitional periods to be negotiated;
·        
the
adoption of recycling targets for industrial waste. These targets could be set
for specific types of material rather than types of waste and should be just as
ambitious as those set for household waste;
·        
adopting
the most stringent common standards for waste sorting and cleaning. By 2020,
100% of waste should be subjected to selective sorting;
·        
the
landfilling of all forms of organic or biodegradable waste that can be reused,
wholly or partly recycled or that has value in terms of energy recovery, to be
prohibited by 2020;
·        
the
targets for recycling plastic packaging – for plastics of all kinds – to be
raised to 70%, and the recycling targets for glass, metal, paper, cardboard and
wood to 80%.
Summary of the
consultation on EPR
56 stakeholders
sent their feedback to the written consultation out of which: 22 industry and
industry federations, 12 Producer Responsibility Organisations (PROs), 9
treatment operators, 1 solid waste management association, 5 regional and local
authorities, 2 national authorities, 1 expert and 4 NGOs. 
73% of the
respondents agree that in general, an initiative by the European Commission,
aiming at clarifying the scope, definition and objectives of EPR, and at
defining common principles and minimal requirements for their implementation,
is necessary through a combination of guidance/recommendations and legislation.

More than half
of the respondents (53%) agree that the EPR definition, scope and objectives
should be clarified, and some examples of key principles that should be
included in the new definition were given.  67% of the stakeholders agreed that
responsibilities should be shared and clearly defined along the whole supply
chain. Treatment and waste management operators suggested including in the
Packaging and Packaging Waste Directive a provision which requires Member
States to assign roles and responsibilities to public authorities and economic
operators within the concept of shared responsibility for packaging waste
management.
51% of the
stakeholders also agree on the fact that, a clear and stable framework is
necessary, in order to ensure fair competition.  However, 32% failed to agree
with all the aspects proposed by the guidance. Some stakeholders go beyond and
recommend additional restrictions in the way competition takes place within
EPR, for example by imposing a single PRO for each product category. 84% of the
respondents agreed that a clearing house is likely to be a valuable addition to
the national systems, especially in certain circumstances, for example when
several PROs are competing. 
Depending on the
nature of the stakeholder, there are divergent opinions with regards to the establishment
of a full cost for end-of-life products, in line with the polluter pays
principle. An isolated number of stakeholders believe that EPR is not an
implementation of the polluter-pays-principle. 
Almost half of
the respondents agree that the fees paid by a producer to a collective scheme
should reflect the true end-of-life management costs of his products. Some
actors agree with the fact that there is a clear need of modulation of the fees
in relationship with the waste hierarchy.  12.5% partially disagree with the
guidance, as according to some, there is no point in independent third parties
establishing true costs. 
More than 55% of
stakeholders seem to agree that transparency of performances and costs is
necessary. However, according to some, full transparency has limits when for
example, competition does exist between PROs and confidentiality of some
information is mandatory. 
The majority of
stakeholders (83%) agreed that the harmonisation of key definitions and
reporting modalities is needed at the European level. According to waste
management stakeholders, the revision of the Packaging and Packaging Waste
Directive should contain harmonised definitions. 
Finally, 60% of
stakeholders agree that both MS and obliged industry are responsible for the
enforcement, and should ensure that the adequate means for monitoring and
control are in place. Several methods of responsibility-sharing were proposed
by different stakeholders. 
Main signals
coming from the consultations 
In summary, some
elements were consistently 'scored' high by most of the stakeholders as
essential options for further consideration, including the need to: 

 improve the credibility of
     statistics; 
 improve reporting and monitoring
     methods, and improve and clarify existing definitions in the Directives
 simplify and make the targets more
     consistent
 take into account the divergent
     starting point between MS; and 
 take additional measures at EU
     level other than setting targets such promoting the use of economic
     instruments and developing EU guidance on EPR schemes.

There was also
broad support for extending some of the existing targets, most notably for
recycling (85% of all respondents in favour), and to take additional measures
to limit landfilling or incineration (57% of all respondents in favour of
maximum ceilings). Fixing targets for waste prevention, (preparation for)
re-use and/or other waste streams received mixed responses, with different
stakeholder groups having fairly divided opinions on this. 
The results from
the consultation on the Green paper on plastic waste confirmed the necessity to
take additional actions at EU level notably to prevent plastics waste from
being landfilled and to dramatically increase the recycling rates of plastics
in the EU.[5] 
The European Parliament in its report13 called for an obligation to
collect and sort 80% of plastic waste, discourage incineration and phase out
landfilling of plastic waste.  
The majority of
the respondents to the consultation on EPR (73%) are in favour of an initiative
by the European Commission, aiming at clarifying the scope, definition and
objectives of EPR, and at defining common principles and minimal requirements
for their implementation through a combination of guidance/recommendations and
legislation. 
During the
seminar with SME’s different measures to simplify the legislation were
suggested notably to exempt SME’s handling small quantities of waste from some
registration and permitting procedures. 
From the marine
litter consultation, the effectiveness and feasibility of actions were found to
be the most relevant criteria when evaluating possible actions to combat marine
litter. From the possible sector-specific actions outlined, avoiding littering
behaviour and shifting away from single-use plastic bags and bottles, (in the case
of consumers), awareness-raising and improved enforcement of littering rules
(in the case of local and regional authorities) and extending producer
responsibility over the whole product lifecycle and the development of an
EU-wide harmonised monitoring strategy (EU policymakers) were among the most
widely-supported actions. [6]

Annex 4: Detailed results of the on line
consultation on the target review 
(Separate
document) 
Annex 5: Attainment of the European waste Targets  
Ø  Municipal waste
target 
As detailed in Box 1, the 50% preparation for reuse/recycling target for municipal waste is applicable by
2020 and MS can choose from any of four measurement methods as to whether the
target has been met or not. According to the 2010 Eurostat statistics, 7 MS are
recycling more than 40%, 7 MS are recycling between 30 and 40% and the 14
remaining MS are below 30%. 
As explained in
section 2.2 below, Eurostat data on recycling are similar to the most demanding
method – method 4 - for assessing whether the target is met or not, the other
methods providing higher recycling rates, and so making it easier to meet the
target. 
According to the
EEA report[7],
under the most demanding method around 14 MS would be able to meet the target
by 2020 at their existing rate of progress. 8 MS will have to accelerate their
recycling at annual rates which were previously met only in the most advanced
MS. For the 6 remaining MS (SK, HR, BU, RO, LV, LT), meeting the 50% target
with the most demanding measurement method by 2020 would require an
acceleration of recycling rates at a level faster than any found so far in
other MS. 
In other words,
nearly half the MS will have to use another measurement method to demonstrate
compliance with the target on time – which is perfectly permitted according to
the WFD and the related Commission Decision – see Error!
Reference source not found.. The results from the model confirm
this finding – see Table
1
below.  
     || Target Met ||   || Distance to Target, % ||   
 Method used || 1 || 2 ||  3 ||  4 ||   || 1 || 2 || 3 || 4 || 
 Austria || Yes || Yes || Yes || Yes ||   || 8% || 24% || 9% || 9% || 
 Belgium || Yes || Yes || Yes || Yes ||   || 4% || 27% || 5% || 5% || 
 Bulgaria || Yes || Yes || No || No ||   || 0% || 6% || -26% || -26% || 
 Croatia || No || No || No || No ||   || -20% || -19% || -31% || -31% || 
 Cyprus || No || No || No || No ||   || -15% || -12% || -29% || -29% || 
 Czech Republic || Yes || Yes || No || No ||   || 0% || 0% || -25% || -25% || 
 Denmark || Yes || Yes || Yes || Yes ||   || 12% || 19% || 5% || 5% || 
 Estonia || No || Yes || No || No ||   || -6% || 0% || -17% || -17% || 
 Finland || No || Yes || No || No ||   || -6% || 3% || -14% || -14% || 
 France || No || Yes || No || No ||   || -15% || 5% || -12% || -12% || 
 Germany || Yes || Yes || Yes || Yes ||   || 24% || 23% || 14% || 14% || 
 Greece || No || No || No || No ||   || -12% || -9% || -25% || -25% || 
 Hungary || No || Yes || No || No ||   || -5% || 2% || -19% || -19% || 
 Ireland || Yes || Yes || Yes || Yes ||   || 10% || 20% || 2% || 2% || 
 Italy || No || Yes || No || No ||   || -2% || 7% || -8% || -8% || 
 Latvia || No || No || No || No ||   || -12% || -11% || -33% || -33% || 
 Lithuania || No || Yes || No || No ||   || -3% || 2% || -21% || -21% || 
 Luxembourg || Yes || Yes || No || No ||   || 10% || 22% || 0% || 0% || 
 Malta || No || No || No || No ||   || -27% || -21% || -37% || -37% || 
 Netherlands || Yes || Yes || Yes || Yes ||   || 2% || 25% || 3% || 3% || 
 Poland || No || No || No || No ||   || -17% || -15% || -30% || -30% || 
 Portugal || No || No || No || No ||   || -21% || -21% || -38% || -38% || 
 Romania || No || No || No || No ||   || -24% || -20% || -37% || -37% || 
 Slovakia || No || No || No || No ||   || -16% || -10% || -31% || -31% || 
 Slovenia || No || Yes || No || No ||   || -1% || 5% || -7% || -7% || 
 Sweden || Yes || Yes || Yes || Yes ||   || 20% || 24% || 10% || 10% || 
 United Kingdom || Yes || Yes || Yes || Yes ||   || 10% || 20% || 2% || 2% || 
Table 1:
Modelled 2020 MSW recycling rates – BAU Scenario 
Ø  Construction and
demolition waste 
According to the
recent reports provided by 11 MS on the implementation of the WFD - reports due
by September 2013, 4 MS have already met the 2020 material recovery target, 3
MS reported rates below 50% and 4 MS reported rates between 50 and 70% - see Error!
Reference source not found.. 
Figure
1
below shows approximate values for material recovery rates for mineral C/D
waste estimated on the basis of the Eurostat data. [8] In
summary, it seems that 2/3 of the MS will be able to meet the 70% target in the
relatively short term. Additional efforts will be required for the other MS,
knowing that the target has to be met by 2020 – 10 years after this estimation
- which gives enough time to react for the remaining MS. 
Figure
1:
Approximate values for recovery rates for C&D Waste (2010)[9]
Ø  Packaging and
packaging waste target 
Figure
2
and Error!
Reference source not found. below summarise the current
performances of the MS compared to the PPWD targets.  In summary, 21 MS are
exceeding the 55% overall recycling target, with most MS well on track to meet
the deadlines taking into account the additional time offered to those with
derogations. 26 MS have surpassed the targets for paper/cardboard and plastics,
25 MS for wood, 23 MS for metals and 19 MS for glass. In the fitness check it
is highlighted that generally speaking higher recycling rates are achieved for
commercial and industrial packaging waste with household packaging lagging
behind.  The performances achieved by the 3 most advanced MS – the ‘top 3’ MS –
give an indication of the potential for future progress.  
Figure 2:
Packaging recycling rates 2011[10]
Ø  Landfill
diversion target
Figure
3
and Figure
4[11] show
the compliance status of MS with or without a time derogation period for
meeting the landfill diversion target for biodegradable municipal waste. These
data indicate that around 23 MS are on track to meet the target on time – i.e.
either by 2016, or by 2020 with derogation. For the remaining MS, additional
efforts will be necessary. At the other extreme, 6 MS are far beyond the target
– landfilling below 5% of their 1995 levels. 
Figure 3:
Percentage of biodegradable MSW landfilled compared to 1995
Figure 4:
Percentage of biodegradable MSW landfilled vs 1995 - MS with derogations
Annex 6: Main
reasons for rejecting some options
During the
stakeholder consultation around 60 different pre-defined measures were
considered in addition to open questions allowing stakeholders to suggest
additional measures that had not already been identified. These measures were
scrutinised in detail in light of the above objectives, their appropriateness
for implementation in the EU, and the views expressed by stakeholders. 
Scope of the
target review
Targets for industrial
and commercial packaging waste are already included in the EU waste
legislation. Their reinforcement is discussed in the IA. These targets might be
complemented by options that restrict the landfilling of recyclable waste which
would also address industrial and commercial waste insofar as it is currently
landfilled. Commercial waste is also partly covered by the targets on municipal
waste at least for the smaller retailers covered by municipal collection
systems.  
Additional
targets for industrial, mining and/or commercial waste were considered
as ineffective at this stage: it is indeed questionable whether the
establishment of general targets is appropriate for those waste streams.
Industrial and mining waste is completely different from one sector to another:
for instance waste generated by the steel industry, the food industry or the
textile industry is of a very different nature and composition. A sector-specific
approach appears to be a better option. In addition, the lack of reliable
statistics remains a barrier to target-setting. Large scale industrial and
mining activities are covered by BAT reference documents (BREF’s) drawn up
under the Industrial Emission Directive and the Mining Waste Directive that
include information on the prevention of resource use and waste generation,
re-use, recycling and recovery. The on-going revision of the BREFs and the
adoption of BAT conclusions will strengthen the impact of these BREFs on
industrial practices leading to further resource efficiency gains and increased
waste recycling and recovery. 
Similarly,
defining an overall target for hazardous waste seems inappropriate for
the same reasons – diversity of nature, composition and origin of this waste.
There is already a clear requirement in the WFD – all hazardous waste has to be
managed without endangering human health or the environment. Hazardous waste
from a range of industry activities is also addressed in BAT conclusions.
Moreover, the establishment of recycling targets may not be appropriate as
safety considerations should prevail over other policy objectives. In fact, it
is difficult to apply the waste hierarchy to the management of hazardous waste
since safe disposal can often be the best option available. Similarly on the
basis of existing evidence, fixing EU targets for sewage sludge in terms
of prevention or recycling/composting seems inappropriate.  
Reuse
Reuse may
appear as a very attractive option for specific waste streams such as textile,
packaging, furniture and electric and electronic waste (however WEEE is not
covered by this review exercise). Reuse of textiles and furniture could be
encouraged through an increase of the overall municipal waste preparation for
re-use and recycling target as it might be accounted for meeting the overall
target as it includes preparation for re-use. Re-use should also be encouraged
for packaging through an adaptation of the existing recycling target of the
PPWD to include preparation for re-use as it is the case for municipal waste. As
explained in the fitness check, the environmental benefits of reusable
packaging are dependent on a number of factors including transportation
distance. Therefore fixing specific legally binding targets for reusable
packaging appears to be excessive as local conditions have to be taken into
account. As with the waste prevention targets, MS should be encouraged to
establish re-use targets in their NPPs and to support the work of third sector
organizations in preparing items for reuse. In some MS such as in France, targets for reuse were introduced in the context of EPR schemes for furniture.
Nevertheless, defining specific targets for re-use or preparation for re-use
has been rejected at this stage mainly for data availability and enforcement
reasons: it has been so far extremely difficult to isolate data on reuse or
preparation for reuse in the waste statistics. 
EPR schemes 
Imposing
completely harmonized conditions for all EU EPR schemes and/or obliging MS to
put in place EPR schemes for specific waste streams is an option to be rejected
for several reasons including subsidiarity considerations, but also due to the
fact that some flexibility should be left to MS in the practical organization
of their EPR systems as long as some minimum essential requirements are
defined.   
Material based
target for municipal waste 
Defining material
based reuse/recycling targets for municipal waste seems to be unnecessary
and should be rejected as meeting ambitious recycling targets for municipal
waste will imply that the majority of potentially recyclable materials –
whether from the dry - plastics, glass, metals, paper, textile, etc - or the
wet - food and garden waste - fraction of municipal waste would have been
separately collected and recycled. It could, though, contribute to higher
recycling rates of Critical Raw Materials – particularly when electric and
electronic waste equipment (WEEE) are concerned. However, the scope of the
present target review does not include the WEEE Directive. Furthermore,
imposing additional material-based targets and the related reporting obligation
on the MS appears to be disproportionate while limiting the flexibility which
should be left to the MS to ensure that local conditions and specific waste
composition are taken into account when planning separate collection actions.
This conclusion also applies to specific targets for instance for textile or
biowaste even if these options were identified as attractive by some
stakeholder during the consultation. 
Maximum targets
for incineration 
Increasing the
minimum recycling/reuse rate to around 70% in the medium term implies de facto
that incineration will be limited to a maximum of 30% of waste generated which
would broadly corresponds to the concept ‘not recyclable’ waste on the basis of
the experience of the most advanced MS/regions. Therefore the option of defining
a maximum target for incineration appears to have a very limited added
value and should therefore be rejected, notably to keep the legislation as
simple as possible.   
Annex 7 : Summary of MS reporting obligations
Figure 5:
Summary of MS reporting obligations on a 3 year period
Annex 8: Overview of the European Reference Model 
(Separate
document) 
Annex 9: Overview of the
Marine Litter module of the European Reference Model 
General
Methodology 
The marine
environment works as a sink in which marine litter accumulates. It is very
difficult to remediate accumulated old marine litter, especially when
fragmented into e.g. micro-plastics. The most cost-effective way to tackle the
problem is to prevent new litter from reaching the marine environment.
Recent technical
guidance drawn up by the Technical Group on marine litter in the context of the
Marine Strategy Framework Directive, and endorsed by Member States’ Marine
Directors on 5 December 2013, identifies beach litter, sea floor litter,
floating litter, litter in biota and micro-litter as relevant indicators. For
the purposes of this modelling exercise, beach litter is used as a proxy for
marine litter, as most data are available for this type of litter, and because
beach litter represents a large proportion of new litter arriving in the marine
environment. 
For all
scenarios a similar approach is used:
·        
First,
future waste generation is assessed, using data on actual generation and on decoupling.
Time horizons to 2020 and 2030 are considered.
·        
Secondly,
the number and type of marine litter items found in 2020 and 2030 are
projected, if 1000 are found in 2015[12],
in option 1 (business as usual, no policy change).
·        
Thirdly,
the reduction impact of a given policy scenario on each litter type is
assessed. Recycled waste does not contribute to marine litter. Increased
recycling reduces marine litter at source. 
·        
For
each option, the reduced number of items was calculated and compared to the
number of items under the BAU (no policy change) and full implementation scenarios.

·        
The
figure below illustrates the anticipated decrease from option 3.4, to the 2030
time horizon. The black figure represents the number of items in the BAU
scenario. The red figure represents the diminished number of items in the
selected option. In the case of overlapping targets (e.g. MSW and packaging
waste), the target with the largest reduction impact is considered definitive.
No
Policy Changes 
In this case,
recycling performance and levels of landfilling remain unaltered. We project
levels of future waste generation and assume marine litter is correlated in a
linear way to it. We assume that litter source is divided as follows between
items of consumer origin and those of industrial origin. We know the balance
between consumer and industrial for those items where the
distinction could easily be observed. We recalculate the number of items where
the origin is unclear or unknown using the same proportions:
Coastlines
are assessed as follows:
       || Km || Share of coastline 
 Baltic Sea || 13.456 || 27% 
 Mediterranean Sea || 16.628 || 33% 
 North East Atlantic || 19.885 || 39% 
 Black Sea || 631 || 1% 
 Total coast line || 50.600 || 100% 
Only coastlines
of countries within the EU territory are included, since the reduction target
only focuses on measures for reducing marine litter within the EU and since the
detailed analysis of the surveys proves that the on-site generation/disposal of
litter on beaches or its transportation over relatively short distances
prevails. Beach litter originates from land-based activities for between 53%
(North Sea) and 93% (Black Sea) of items while between 2% (Black sea) and 27%
(North Sea) of beach litter items are likely to be transported over a long
distances.
Taking into
account the EU-beach length for each of the regional seas, we assess the
distribution between industrial and consumer for the whole of the EU as: 68%
consumer origin, 32% industrial origin.
For 1000 marine
litter items found in 2015, we calculate that 104 items may be found in 2020
under a business as usual scenario, and thus that marine litter inflow will
increase
by
4,4%.
Conclusion:
with no policy change new marine litter inflow tends to increase by 4.4% in
2020 compared to 2015. It would increase by 12.3% by 2030. 
Option
1: Full implementation of existing legislation
In
this option we assume that all Member States comply with existing targets.
For consumer
waste (MSW), we assess the degree to which complying with the current
legislation leads to a reduction in the potential source of marine litter (i.e.
the non-recycled fraction). We apply the MSW recycling targets to the total
number of items, and apply the packaging recycling targets to the MSW packaging
items specifically. These targets are partially overlapping, and both must be
met; we thus take into account the outcome effecting the highest reduction. 
In general, we
apply full compliance with packaging recycling targets (but nothing more).
However in some cases, these performance levels have already been surpassed. In
such cases, we assume that the higher recycling percentages will not decrease.
For litter from
industrial sources (i.e. other than MSW), we assess the effect of the targets
on the industrial packaging fraction.
We calculate the
‘business as usual’ number of marine litter items in 2020 and 2030, assuming
that in 2015 there are 1000 items. We subtract from this figure the effects of targets
leading to a reduction of the litter source, as calculated above, and we assess
the possible marine litter reduction in the full implementation option.
Conclusion:
under option 1 (full implementation of existing legislation), new marine litter
inflow tends to decrease by 4.6% in 2020 compared to 2015. It would increase by
2.9% in 2030 without further policy action. 
Option 3.1: 70%
recycling by 2030
In this scenario
we apply a 70% overall recycling rate for municipal waste, with reassessed
recycling performances for the different MSW fractions.
Since no change
to the target is proposed for 2020, at the time horizon to 2020, this scenario
is exactly the same as option 1 (full implementation). However, the impact of a
70% recycling target by 2030 is significant, especially given the anticipated
growth in waste generation (and thus marine litter) without additional measures
and the effect of allowing only one measurement method for the WFD. This option
sees new marine litter inflows which are 10% lower than those projected by the
full implementation of existing legislation only. 
Conclusion:
under option 3.1 (70% recycling by 2030), new marine litter inflow tends to be
10% lower in 2030 than under the full implementation scenario. 
Option 3.2:
modernised packaging waste targets
Packaging
waste targets are as in Error!
Reference source not found. in the main body of this Impact
Assessment.
As no detailed
data on metal marine litter is available from the OSPAR screenings, we assume
the same ratio between steel packaging and aluminium packaging for marine
litter as is the case for general waste statistics: an average of 15% aluminium
and 85% steel packaging, based upon EUROSTAT data. The increased recycling
targets for material streams which frequently end up as marine litter have a
significant reduction impact at both the 2020 and 2030 timescales. 
Conclusion:
under option 3.2 (increased packaging waste targets), new marine litter inflow
tends to decrease by 12% by 2020 and by 21% by 2030 when compared to the full
implementation scenario.
Option
3.3 limiting landfilling to residual waste
Waste
generation, the ratios of municipal/industrial, MSW and packaging waste
recycling targets are the same as in the single measurement option.
Legal landfill
is already a relatively minor source for marine
litter:                                                      
   || Baltic sea || Black sea || Mediterranean || North sea 
 Landfills and dumpsites as a ML source || 0,94%                                                                                                                                                  || 3,88% || 0,14% || 1,09% 
On average,
taking into account the coastal length of each sea, the probability for marine
litter inflow to originate from landfills and dumpsites (e.g. landfill escapes)
is 0,68% of all litter inflow. The introduction of landfill bans is thus of
modest impact. This does not take account of escapes from illegal landfills,
which goes beyond the scope of this Impact Assessment.
Conclusion:
option 3.3 (limiting landfilling) is of negligible impact on new marine litter
inflow  at both 2020 and 2030 time horizons.
Option 3.4:
combining options 3.1, 3.2 and 3.3
The highest
parameter values for the options 3.1, 32 and 3.3 are combined. The combined
impact is significant in that projected new marine litter inflows are found to
be 13% lower (by 2020) and 27,5% lower (by 2030)  than those projected by the
full implementation of existing legislation only. 
Conclusion:
under the option 3.4 new marine litter inflow tends to decrease by 13% by 2020
and 27,5% by  2030 when compared to the  full implementation scenario.
Costs
related to marine litter 
This
section provides an assessment of the costs associated with the current
degradation of the marine environment, using a cost-based approach. Unit
costs from literature have been extrapolated to the EU level on a sectoral
basis. 
Coastal and beach cleaning
Cleaning
costs highlighted in existing literature are highlighted below:
 Beach type || Cost per km (€) || year data || Location || Sea[13] 
 Bathing || 34.450 || 2010 || Touristic beaches Netherlands & Belgium,10 municipalities || NS 
   || 28.320 || 2010 || Touristic beaches; Netherlands, 6 municipalities || NS 
   || 38.190 || 2010 || Spain: bathing beach || MED 
   || 31.796 || 2010 || Portugal: bathing beach || ATL 
   ||   ||   ||   ||   
 Non-bathing || 214 || 2010 || Sweden, non-bathing beach || BAL 
   || 372 || 2010 || Denmark, non-bathing beach || NS 
   ||   ||   ||   ||   
 Bathing & non-bathing || 7.150 || 2010 || UK, cleaning including beaches less intensively used by tourists || NS 
   || 3.750 || 2012 || Latvia (Riga) bathing & non-bathing beach || BAL 
   || 11.000 || 2007 || NL: average total coast length || NS 
   || 8.278 || 2010 || Portugal: bathing & non bathing beach || ATL 
Beach cleaning costs, per beach
type (source Mouat, 2010; Arcadis, 2013 ; Reinhard et al, 2012)
The
table highlights large differences in cleaning costs between bathing and
non-bathing beaches. One of factors influences the frequency of cleaning is the
intensity of beach use. Designated bathing beaches and the coast
around the area must be cleaned regularly, in particular between Easter and September[14].
Cleaning of non-bathing beaches is less frequent. In addition, soil type is a
factor affecting cost. Sandy beaches can be
mechanically cleaned, which is less costly, but this is not possible in coastal
areas with rocky beaches. 
No
data is available on the breakdown throughout the EU of bathing and non-bathing
coastal areas. However, based on the results outlined in Error!
Reference source not found. which covered to differing extents both
bathing and non-bathing areas, a minimum, maximum and average cleaning cost have
been calculated. All data have been converted to 2013 prices.
   || cost per km (€) || length of EU coastline (km) || cost in the EU (m€) 
 Average || 8.171 || 50.600 || 413,47 
 Minimum || 3.828[15] || 50.600 || 193,70 
 Maximum || 12.446[16] || 50.600 || 629,78 
The
estimates of cost to the tourism and recreation sector (in average €m per year)
are extrapolated from individual figures of beach cleaning activities and
therefore are subject to a high degree of uncertainty. 
Fishing sector 
The
total costs of marine litter related incidents for EU fisheries are estimated
using the average costs of marine litter per vessel in the Scottish fleet,
analysed by Fanshawe (2002), Mouat et al (2010) and KIMO (2010)[17].  In
the UK Cost Benefit Analysis for the MSFD (Cefas; 2012), average costs of
litter to the fishery sector have been disaggregated into two categories. This
is due to the different economic costs of marine litter impacts associated with
different fishing methods. 
·      Incidents
due to dumped catch, repairs to fishing gears and reduced fishing time by
clearing nets are mainly applicable to those fisheries that have contact with
the seabed. 
·      Incidents
due to fouling are more likely to be due to litter in the water column and can
therefore affect any type of fishing vessel. 
These
estimates should be interpreted with caution due the different probability of
incidence with marine litter across the EU fleet. These estimates are based on
best available evidence and some broad assumptions (simple extrapolation of
Scottish North Sea data). 
Costs related to marine litter on the sea bottom
Costs
to the EU fishing fleet (trawlers) associated with litter incidents that
involve dumping catch, repairing fishing gear and lost earnings as a
result of reduced fishing time are estimated at 40,4 m€ per annum. The
total cost has been estimated based on the average costs per vessel for this
category damage, multiplied by the number of active EU vessels that use
seafloor fishing gear[18]. 

Cost of reduced catch revenue
 cost per vessel (€) || # trawlers in the EU || cost for the EU (m€) ||   ||   
 2.340[19] || 12.238[20] ||                   28,64 ||   ||   
Cost
of removing litter from fishing gear
 cost per vessel (€) || # trawlers in the EU || cost for the EU (m€) 
                            959[21] ||                   12.238 ||                     11,74 
Costs related to marine litter in the water column: 
Costs
to the total EU fishing fleet associated with litter incidents that involve
fouling (e.g. of propellers) are estimated at between 16,8m€ per
annum. The expenses of the EU fishing fleet on these kind of incidents are
calculated by multiplying the average vessel costs with the number of active EU
fishing vessels.[22]
Cost of broken gear, fouled propellors
   || cost per vessel (€) || # fishing vessels in the EU || cost for the EU (m€) ||   ||   || 
   || 191[23] ||                   87 667 ||                     16,79 ||   ||   || 
Cost
to the fishing industry amounts to a total of 57,2 m€, using the cost-based
approach outlined above. These estimated costs generated by marine litter are
equivalent to a reduction of  nearly 1% of the total revenues that are
generated by the EU fleet in 2010 (landed value of 6600 m€[24]). 
Shipping
sector 
Marine
litter also poses a navigational hazard to vessels in general. Incidents
involving vessel damage caused by marine litter are widespread with over 70% of
  UK harbours and marinas reporting that their users had experienced incidents
involving marine litter. Costs of rescue operations involving the coastguard to
vessels with fouled propellers in UK waters reached between €830.000 and €2.189.000
in 2008 (Mouat et al; 2010). The most frequently reported cause of fouled
propellers was derelict fishing gear.  However, no unit costs per ship could be
deducted from literature. Several sources only give anecdotal evidence of the
dangers of blocked propellers and other gear.[25] Thus,
such costs are not accounted for in this model. 
Total sectoral results 
The
total quantified cost of degradation, taking together the cost of beach
cleaning and damage to fishing gear and vessels is estimated to be between 250,9
m€ and 687 m€. The ‘best estimate’ within this range is 469 m€.
Assuming marine litter inflow growth of 2.9% to 2030 under the full
implementation scenario, and a linear relationship between marine litter and
costs, projected marine litter-related costs are 483 m€ in 2030 (2013
prices). This is compared with the projected 27,5% decrease of marine litter
inflows (and associated costs) under scenario 3.4, whereby costs would fall to
340 m€ (2013 prices). This implies a total saving of 143 m€ in marine-litter
related costs by 2030. 
This
is, however, a conservative estimate as it has not been possible to quantify
impacts to all sectors and activities, including voluntary beach cleaning,
cleaning of harbours and marinas, damage to non-fishing vessels, rescue
call-out costs related to vessels damaged by marine litter or the cost of any
health impacts from marine litter. In addition, the ecological value not
directly related to money transfers, are not taken into account quantitatively.
Annex 10: Summary of the main Model uncertainties
Collection 
The model has,
necessarily, to simplify somewhat the complexity of the situation which
actually exists in MS. In each country, there are, and are likely to be in future,
a range of different collection systems in place. The model simplifies reality
by modelling a narrow range of systems. However, although the range is
narrowed, the general tendencies are expected to be a reasonable reflection of
the relative costs of systems delivering varying recycling rates.
The model makes
assumptions which determine the number of households which can be served by a
given vehicle. These are likely to vary from place to place. The model seeks to
deal with this through setting different parameters for urban, suburban and
rural households.
The costs are
modelled in real terms. They are essentially deemed to remain constant across
time in real terms. The time horizon for the assessment is, however,
considerable. Over such a period, the index of some input parameters to the
collection model, such as labour costs, might not be the same as the general
rate of price increases. As such, the costs might not remain constant in real
terms over the time period considered. This is, however, believed to be the
most reasonable assumption to make in the circumstances (projecting, for
example, the rate of increase in real wages would appear to be rather
speculative);
The value of
materials being captured for recycling is deemed to remain constant in real
terms. Following a period in history (roughly spanning the period 1950-2000)
over which real prices for commodities have experienced a secular decline, the
last decade has seen that secular decline completely reversed owing to
increased global demand, notably from China. Many commentators believe prices
may continue to rise in real terms, but there are, equally reasons why prices,
not least in real terms, may decline. As such, the assumption regarding
constant prices in real terms seems reasonable. 
For each
country, where municipal waste is concerned, the model uses data from MS
regarding the composition of their municipal waste. The composition data is of
variable quality. Because of the variation in composition from one country to
another, the revenue generated from the capture of recyclables varies across
countries (affecting net costs). 
Quite apart from
current waste composition, the modelling effectively has to consider waste
composition over the period to 2030-2035. Relatively little is known about
exactly how waste composition will change in future. What seems certain,
however, is that it will change. It is to be hoped that those changes that do
occur will increase the extent to which materials can be easily recycled. What
cannot be known, however, is how such changes will affect the costs of
collecting and processing materials, and the revenues generated from selling
the materials collected. The assumption of constant composition is on the one
hand unlikely to reflect reality, but on the other, it is felt that no
reasonable alternative assumption exists.
Treatment 
The costs of
treatment are assumed to remain constant in real terms. For some treatments, as
well as taking into account the sale of some materials (see above) the net
costs take into account the sales of energy. The revenue derived from the sales
of energy are assumed to be constant in real terms. This implies constant real
terms prices for energy. Energy prices could, of course, follow a different
path;
The costs are
influenced by assumptions regarding capital costs, assumed to be constant
across countries, and the costs of other inputs to the process. Labour costs
have been adapted to MS labour costs. There is variation in unit capital costs
of facilities, but the model assumes a single figure for a given treatment
type. This seems reasonable given that the high level, strategic nature of the
model means that assumptions regarding the size of specific facilities cannot
meaningfully be made;
The way in which
capital costs are financed will affect the costs for different facilities. In
different MS, there are different patterns of financing and ownership of waste
management facilities. Some facilities are funded from savings made by
municipalities, others are financed using public/private partnerships. These
situations lead to a variety in the costs of capital, and this affects the
costs of operating facilities. The model effectively assumes a single figure
for the real costs of capital.
Externalities
The overall
figures for externalities reflect the inclusion and exclusion of various
effects in the model. Main externalities of well operated facilities are
captured by the model, but even so, some externalities are not captured by the
model (see Annex 6).
The model
assumes different damage costs for the air pollutants with these adapted for
each Member State. These are based on the best evidence available, but clearly,
uncertainties exist;
The model
assumes a profile for the damages associated with GHG emissions. The debate
concerning how best to value damages associated with GHGs continues apace.
There are clearly alternative assumptions that could be made in this regard;
Some
characteristics of key processes influence emissions, and hence, externalities.
Key amongst these are:

 The modelling of the extent to
     which biodegradable material degrades in landfill;
 The capture of methane generated by
     landfills for energy generation and flaring (and crucially, the amount of
     methane escaping to the atmosphere);
 For technologies generating energy,
     such as incineration, the nature of the energy source which is assumed to
     be avoided, at the margin, when new facilities are introduced;
 The modelled GHG emissions from
     facilities relate back to waste composition. If composition is not well
     known, then the emissions will be similarly poorly understood (and as
     noted above, composition is likely to change in future).

Annex 11:  Comparison of the main definitions used
in the EU waste legislation   
 Definitions || Waste Framework Directive (WFD) || Packaging and Packaging waste Directive (PPWD) || Landfill Directive || Waste Statistic Regulation (Wstat R) 
 Prevention || Measures taken before a substance, material or product has become waste, that reduce: (a) the quantity of waste, including through the re-use of products or the extension of the life span of products; (b) the adverse impacts of the generated waste on the environment and human health; or (c) the content of harmful substances in materials and products || The reduction of the quantity and of the harmfulness for the environment of materials and substances contained in packaging and packaging waste, packaging and packaging waste at production process level and at the marketing, distribution, utilization and elimination stages, in particular by developing ‘clean’products and technology ||   ||   
 Reuse || Any operation by which products or components that are not waste are used again for the same purpose for which they were conceived Preparing for reuse: Checking, cleaning or repairing recovery operations, by which products or components of products that have become waste are prepared so that they can be re-used without any other pre-processing || Any operation by which packaging, which has been conceived and designed to accomplish within its life cycle a minimum number of trips or rotations, is refilled or used for the same purpose for which it was conceived, with or without the support of auxiliary products present on the market enabling the packaging to be refilled; such reused packaging will become packaging waste when no longer subject to reuse ||   ||   
 Recycling || 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 organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations || The reprocessing in a production process of the waste materials for the original purpose of for other purposes including organic recycling but excluding energy recovery Organic recycling: Aerobic (composting) or anaerobic (biomethanization) treatment, under controlled conditions and using micro-organisms, of the biodegradable parts of packaging waste, which produces stabilised organic residues or methane ||   || Same as PPWD Reporting is done on aggregation of the R-codes listed in Annex II to the WFD. It is not always clear which of these R – codes refer to recycling, or recovery 
 Recovery || 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. Annex II sets out a non-exhaustive list of recovery operations || Same as WFD Energy recovery: Use of combustible packaging waste as a means to generate energy through direct incineration with or without other waste but with recovery of the heat ||   || Same as WFD The reporting is linked to the recovery codes listed in Annex II to the WFD, it is not always clear which of these R – codes refer to recycling, or recovery 
 Municipal waste || (not a definition as such in the Directive) Waste collected from private households, including where such collection also covers such waste from other producers ||   || Waste from households as well as other waste which, because of its nature or composition is similar to waste from household ||   
 Disposal || Any operation which is not recovery even where the operation has as a secondary consequence the reclamation of substances or energy. Annex I sets out a non-exhaustive list of disposal operations; || Same as in the WFD || Landfill: a waste disposal site for the deposit of the waste onto or into land (i.e. underground) || Same as WFD and Landfill Directive (for Landfills) Reporting is done on aggregations of the D-codes listed in Annex I to the WFD 
 Biowaste || Biodegradable garden and park waste, food and kitchen waste from households, restaurants, caterers and retail premises and comparable waste from food processing plants ||   || Biodegradable waste: Any waste that is capable of undergoing anaerobic or aerobic decomposition, such as food and garden waste, and paper and paperboard ||   
 Treatment || Recovery or disposal operations, including preparation prior to recovery or disposal ||   || Physical, thermal, chemical or biological processes, including sorting, that change the characteristics of the waste in order to reduce its volume or hazardous nature, facilitate its handling or enhance recovery || Reporting is done on aggregates of the R and D codes of the WFD 
[1] http://www.wastemodel.eu/ 
and http://www.wastetargetsreview.eu/

[2] Full details of the conference, including the conclusions, are
available at: http://www.marine-litter-conference-berlin.info/

[3] http://www.europarl.europa.eu/plenary/en/texts-adopted.html
[4] The questionnaire and the results from the consultation are
available from the following link: http://www.wastetargetsreview.eu/section.php/4/1/consultation
[5] Results from the consultation on the Green paper are available from
the following link: http://ec.europa.eu/environment/consultations/plastic_waste_en.htm

[6] Results from the consultation on marine litter will be made available
from the following link: http://ec.europa.eu/environment/consultations/marine_litter_en.htm

[7] Reference 7 in Annex 2
[8] Reference 1 in Annex 2
[9] Data above 100% for EE and CZ seems to be linked with differences
between reporting times between C/D waste generated and treated (storage) and
imports of mineral waste treated in EE and CZ 
[10] Source: Eurostat 2013
[11] Extracted from the EEA report, reference 7 in Annex 2, updated in
2014. 2010 and/or 2011data are estimated for FR, IT, LU, NL, SE, HR and RO.
2009 data are estimated for BG, PL and PT. 2009 data were used for 2010 and
2011 for SP and SK
[12] 2015 is used as the baseline, as it will be the first full year for
which Member State data on the presence of beach litter will be available under
the monitoring programmes foreseen under Article 11 of the Marine Strategy
Framework Directive (Directive 2008/56/EC).
[13] NS: North Sea; MED: Mediterranean Sea; BAL: Baltic Sea; ATL: Atlantic Ocean; 
[14] Reinhard et al (2012) assumes that the Dutch bathing beaches are
cleaned 120 times a year.
[15] The data from the Latvian study converted to 2013 prices.
[16] The data from the Dutch study converted to 2013 prices. 
[17] GBP cost data have been converted using the exchange rate Euro 1 =
0,839 GBD (dec 2013).
[18] According to the
Community Fishing Fleet Register (http://ec.europa.eu/fisheries/fleet/)
12.238
trawlers (category “towed Gears”) are currently in use (2013). 
[19] Losses are reported
to amount €2.200/year/vessel, in 2010 prices (Mouat et al; 2010), corrected to
€2340 in 2013 prices.
[20] http://ec.europa.eu/fisheries/fleet 

[21] Vessels surveyed by KIMO (2010) spend an average of 41 hours a year
removing marine litter from fishing gear. This is multiplied by an average EU27
labour cost of 23,4€ per hour. 
(see : http://epp.eurostat.ec.europa.eu/statistics_explained/index.php/Hourly_labour_costs).
[22] 87.667 fishing vessels according to the  EC - Fleet Register on the
Net (2013) http://ec.europa.eu/fisheries/fleet/index.cfm?method=Search.ListSearchSimple

[23] In Mouat et al. (2010), the damage due to litter is budgeted at
€180/year/vessel, based on data of Scottish fishing vessels (191 € actualized
to 2013 prices).
[24] According to Member States DCF data submissions, the total amount
of income generated by the EU  fishing fleet in 2010 (excluding Greece) was €7 billion. This amount consisted of €6,6 billion in fish sales,  €34 million
in fishing rights rental income, €193 million in non‐fishing
income, and €126 million in direct  income subsidies (JRC; 2012).
[25] The economic study of Hall (2000) mentions
“costly repairs, loss of time and danger to boaters and crews”, but without
exact calculations as most incidents are not reported.  
Annex 4 – Detailed Results of the Consultation on the
Review of European Waste Management Targets
Contents
1.0      Introduction. 4
2.0      Analysis of Results. 5
2.1       Stakeholder Groups. 5
2.2       Analysis of Closed-ended Questions. 6
2.3       Analysis of Open-ended Questions. 6
3.0      Response Rates and
Country Profiles. 8
4.0      Waste Framework Directive. 12
4.1       Key Issues. 12
4.2       Suggestions for Revision. 13
5.0      Landfill Directive. 24
5.1       Key Issues. 24
5.2       Suggestions for Revision. 24
6.0      Packaging and Packaging
Waste Directive. Error! Bookmark not defined.
6.1       Key Issues. Error!
Bookmark not defined.
6.2       Suggestions for Revision. Error!
Bookmark not defined.
7.0      Roadmap to a Resource
Efficient Europe. Error! Bookmark not defined.
7.1       Waste Prevention. Error!
Bookmark not defined.
7.2       Preparation for Reuse. Error!
Bookmark not defined.
7.3       Recycling Rates. Error!
Bookmark not defined.
7.4       Limiting Incineration of Waste Which Might
Otherwise be Recycled.. Error!
Bookmark not defined.
7.5       Landfill Error!
Bookmark not defined.
8.0      Targets as a Tool in
Waste Legislation. Error! Bookmark not defined.
9.0      Citizen Consultation. Error! Bookmark not defined.

1.0                     
Introduction

The Targets Review Project has been
commissioned by DG Environment at the European Commission. The project is aimed
at identifying the issues and proposing possible solutions to the targets in the
Waste Framework Directive, the Landfill Directive and the Packaging and
Packaging Waste Directive. The basis for the review of the targets is twofold:
on the one hand it is to respond to the review clauses set out in the
Directives and, on the other, to bring these targets in line with the
Commission’s ambitions of promoting resource efficiency and reducing greenhouse
gas emissions.
This project is being delivered by Eunomia
Research & Consulting (Eunomia) with support from Öko-Institut, the
Copenhagen Resource Institute (CRI), ARGUS, and Satsuma Media. It is being
delivered under Eunomia’s contract with the European Commission on “Technological,
Socio-Economic and Cost-Benefit Assessments Related to the Implementation and
Further Development of EU Waste Legislation”.  
This document presents the results of the
consultation on the Review of European Waste Management Targets which was held
between the 4th June and 9th September 2013. Responses to
each of the questions have been analysed and have been broken down according to
the different stakeholder groups. The methodological approach to the data
analysis is summarised in Section 2.0. This is followed by a summary of
the response rates to each section of the consultation in Section 3.0.
Finally, the results are presented in Section 4.0 to Section Error! Reference source not found., each of
which deals with a different section of the consultation:
Ø 
Section 4.0 –
Waste Framework Directive;
Ø 
Section 5.0 –
Landfill Directive;
Ø 
Section Error!
Reference source not found. – Packaging and Packaging
Waste Directive;
Ø 
Section Error!
Reference source not found. – Roadmap to a Resource
Efficient Europe;
Ø 
Section Error!
Reference source not found. – Targets as a Tool in
Waste Legislation; and
Ø 
Section Error!
Reference source not found. – Consultation questions
for European Citizens.
It is important to note that this report
does not provide an analysis of the options which will be carried forward for
detailed analysis as part of the Commission’s impact assessment. This work is
being carried out in parallel to this and will be published in the near future.

2.0                    
Analysis of Results

The consultation questions were subdivided
into the following seven sections (the full consultation can be found in
Appendix A1.0):
Ø 
General questions;
Ø 
Waste Framework Directive;
Ø 
Landfill Directive;
Ø 
Packaging and Packaging Waste Directive;
Ø 
Roadmap to a Resource Efficient Europe; 
Ø 
Targets as a tool in waste legislation; and
Ø 
Consultation for European citizens.
The majority of the questions within each
section were voluntary and therefore respondents could choose to respond or
not, depending on whether they had an opinion on a particular subject. The
consultation included a number of closed- and open-ended questions to which
stakeholders could respond to. The closed-ended questions were straightforward
to analyse as the statistics are clearly presented in numerical form. In
contrast, the analysis of the open-ended questions required significantly more
effort. These questions were analysed by reading each of the responses and
coding the key themes that emerged from these answers. Each time a new theme
emerged it was added to the list. If themes emerged a number of times, as they
frequently did, these were coded accordingly. We describe below how the
different aspects of the consultation were analysed.    

2.1      
Stakeholder Groups

The consultation questions were developed
in close association with the Commission who provided the final sign off of the
document before it was published in the Commission’s Interactive Policy Making
(IPM) tool. The consultation sought to elicit views from the following
stakeholder groups:
Ø 
Industry, not-for-profit, and academic
organisations:
o   Industry trade bodies/organisations;
o   Industry representatives;
o   Not-for-profit/non-governmental organisations;
o   Academic institutions; and
o   Other organisations.
Ø 
Public authorities (e.g. Member States, regional
or local competent authorities); and
Ø 
European Citizens.
In most cases the results of the
consultation have been divided up to show the views of the different groups of
stakeholders. This is of particular importance when considering the proposed
suggestions for revising the targets as different stakeholders typically have
alternative, and often conflicting views, of what the best approach will be.

2.2       Analysis of Closed-ended Questions

In order to facilitate analysis the
consultation contained a number of closed-ended questions. Closed-ended
questions were used to allow respondents to rank various options as part of a
‘matrix’ or choose alternative answers from a finite list of options. Some of
the most important questions in the consultation consisted of the ‘matrix’
style questions in which respondents were asked to rank various – on a scale of
1 to 5 – options which were put forward as suggestions for revising the
existing Directive targets. There are many ways in which these data can be analysed
in order to determine which the most preferred options are. As part of the
analyses which have been presented in this report we have chosen two
alternative methods for depicting these results:
1.      
In order to enable the overall rank of each
option to be compared we calculated the weighted average rank for all options
presented in each ‘matrix’; and
2.      In order to ascertain the strength of the preference for or against
certain options we also present the results of the difference between the
number of respondents who ranked an option as 5 (i.e. very favourably) against
the number who ranked it as 1 (i.e. an option not worth considering). The
difference between the number of upper and lower rank responses provides a
clearer means for illustrating strong differences in opinion, something which
is not always clearly illustrated through a weighted average. In these figures
the most favoured options are shown by a large number and options which were
strongly disliked have low or even negative rankings. 
It is believed that together these two sets
of analyses provide a clear indication of which options may or may not be
preferred (assuming there is a spread of opinion across options). Analysis of
the remaining closed-ended questions was straight forward and, as shown in the
results sections below, consisted of providing weighted averages and averages
for different responses.   

2.3      
Analysis of Open-ended Questions 

The majority
of open ended questions in the consultation asked respondents to list
additional issues and solutions which had not already been identified in the
consultation. In a number of instances it was found that people had reiterated,
albeit in different words, issues and/or solutions which had already been identified.
In these instances responses were coded as ‘Issue/solution already listed’.
When asked to identify additional issues a number of respondents offered
solutions instead of presenting issues specifically related to the targets. To
prevent these solutions from being lost, these responses were added to the
questions which asked whether any additional solutions could be suggested.
These responses were coded as ‘Response is a solution, not an issue’. Likewise,
in cases where respondents were asked to propose additional solutions, but
instead raised concerns about issues, the responses were coded as ‘Response is
an issue, not a solution’. Finally, in a number of cases stakeholders
identified issues and solutions which were not related to the scope of work being
undertaken as part of the Review of Targets Project. These responses were coded
as being ‘non-target issues/solutions’. 
All other
responses were coded with the intention of identifying common themes. For each
open-ended question, lists of coded responses were created based on the answers
that were received. 


3.0                     
Response Rates and Country Profiles

A total of 670 responses were received from
various stakeholders across Europe. The number of responses from different groups
of stakeholder can be seen in Table 3‑1. This table also provides details on how many stakeholders from
each group responded to the different sections of the consultation. For example,
136 industry trade bodies responded to the consultation, with 122 of these
respondents choosing to answer questions under the Waste Framework Directive
section of the consultation. 
Table 3‑1: Response Rates Broken Down by Stakeholder
and Consultation Section
 Consultation Section  || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Total Number of Responses || No. || 670 || 136 || 80 || 54 || 6 || 20 || 49 || 325 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
 Waste Framework Directive || No. || 371 || 122 || 73 || 50 || 5 || 18 || 47 || 56 
 % || 80% || 90% || 91% || 93% || 83% || 90% || 96% || 48% 
 Landfill Directive || No. || 313 || 102 || 57 || 42 || 3 || 16 || 47 || 46 
 % || 68% || 75% || 71% || 78% || 50% || 80% || 96% || 39% 
 Packaging Waste Directive || No. || 368 || 101 || 63 || 50 || 5 || 19 || 46 || 84 
 % || 80% || 74% || 79% || 93% || 83% || 95% || 94% || 72% 
 Roadmap Section || No. || 462 || 136 || 80 || 54 || 6 || 20 || 49 || 117 
 % || 69% || 100% || 100% || 100% || 100% || 100% || 100% || 36% 
 Targets as a Tool in Waste Legislation || No. || 394 || 116 || 61 || 48 || 3 || 18 || 41 || 107 
 % || 85% || 85% || 76% || 89% || 50% || 90% || 84% || 91% 
 Citizen Consultation || No. || 278 || - || - || - || - || - || - || 278 
 % || 86% || - || - || - || - || - || - || 86% 
 Note: All percentages are given relative to the total number of responses received from each stakeholder group. 
Each group of stakeholders was asked to
identify which country they were based in and the results of this are
summarised in Table 3‑2.  

Table 3‑2: Distribution of Countries in which Stakeholders
are Based1
 Country || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 No. || % || No. || % || No. || % || No. || % || No. || % || No. || % || No. || % 
 Austria || 3 || 2% || 2 || 3% || 3 || 6% || 0 || 0% || 2 || 10% || 1 || 2% || 3 || 1% 
 Belgium || 54 || 40% || 7 || 9% || 8 || 15% || 1 || 17% || 3 || 15% || 1 || 2% || 21 || 6% 
 Bulgaria || 0 || 0% || 1 || 1% || 1 || 2% || 0 || 0% || 0 || 0% || 0 || 0% || 2 || 1% 
 Cyprus || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 0% 
 Czech Republic || 1 || 1% || 1 || 1% || 4 || 7% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% 
 Croatia || 0 || 0% || 0 || 0% || 2 || 4% || 0 || 0% || 0 || 0% || 1 || 2% || 4 || 1% 
 Denmark || 1 || 1% || 4 || 5% || 2 || 4% || 0 || 0% || 0 || 0% || 1 || 2% || 1 || 0% 
 Estonia || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 2 || 4% || 0 || 0% 
 Finland || 3 || 2% || 3 || 4% || 1 || 2% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 0% 
 France || 10 || 7% || 11 || 14% || 6 || 11% || 1 || 17% || 2 || 10% || 2 || 4% || 85 || 26% 
 Germany || 10 || 7% || 9 || 11% || 10 || 19% || 1 || 17% || 3 || 15% || 5 || 10% || 73 || 22% 
 Greece || 0 || 0% || 2 || 3% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 0% 
 Hungary || 2 || 1% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 0% 
 Ireland || 3 || 2% || 0 || 0% || 0 || 0% || 0 || 0% || 2 || 10% || 1 || 2% || 1 || 0% 
 Italy || 6 || 4% || 5 || 6% || 0 || 0% || 0 || 0% || 2 || 10% || 1 || 2% || 56 || 17% 
 Latvia || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 0% 
 Lithuania || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 5 || 2% 
 Luxembourg || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 2% || 0 || 0% 
 Malta || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% 
 Netherlands || 6 || 4% || 7 || 9% || 2 || 4% || 1 || 17% || 0 || 0% || 3 || 6% || 5 || 2% 
 Poland || 0 || 0% || 1 || 1% || 1 || 2% || 0 || 0% || 0 || 0% || 1 || 2% || 9 || 3% 
 Portugal || 5 || 4% || 3 || 4% || 0 || 0% || 1 || 17% || 0 || 0% || 1 || 2% || 3 || 1% 
 Romania || 1 || 1% || 3 || 4% || 2 || 4% || 0 || 0% || 0 || 0% || 5 || 10% || 7 || 2% 
 Slovakia || 1 || 1% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 0 || 0% || 2 || 1% 
 Slovenia || 0 || 0% || 0 || 0% || 1 || 2% || 0 || 0% || 0 || 0% || 0 || 0% || 1 || 0% 
 Spain || 7 || 5% || 1 || 1% || 6 || 11% || 0 || 0% || 2 || 10% || 6 || 12% || 20 || 6% 
 Sweden || 4 || 3% || 2 || 3% || 1 || 2% || 0 || 0% || 0 || 0% || 3 || 6% || 0 || 0% 
 United Kingdom || 19 || 14% || 11 || 14% || 3 || 6% || 1 || 17% || 4 || 20% || 12 || 24% || 17 || 5% 
 Other || 0 || 0% || 72 || 9% || 13 || 2% || 0 || 0% || 0 || 0% || 24 || 4% || 55 || 2% 
 Total || 136 || 100% || 80 || 100% || 54 || 100% || 6 || 100% || 20 || 100% || 49 || 100% || 325 || 100% 
 Notes: 1.        In the case of industry multinational organisations respondents were asked to identify the country in which their head office was based. All percentages are given relative to the total number of responses received from each stakeholder group. 2.       Six these stakeholders have their head offices in Switzerland and one in the USA. 3.        This stakeholder was from Norway. 4.       These two stakeholders were from Norway. 5.        These citizens were all from Switzerland. 

4.0                    
Waste Framework Directive

As per the consultation this section is
divided into two sections. The first presents a summary of the key issues that
were identified by stakeholders that were not already identified within the consultation
(see Appendix A1.0). The second looks at possible options for revising and/or
improving the targets.  

4.1       Key Issues

A number of issues were identified in the
consultation and respondents were asked to succinctly list up to three
additional issues that had not been listed in the consultation. As described in
Section 2.0 these open ended responses were coded to identify common themes and
allow the data to be subjected to more detailed analysis. The feedback on
issues received by respondents was intended to provide additional context to
the issues already identified in the consultation. In many instances
stakeholders chose to provide solutions to problems instead of listing
additional problems related to the existing targets that had not already been
identified within the consultation. Some of the issues that were reported were
also not directly related to the Waste Framework Directive targets or were
repeats, albeit in different words, of the issues that had already been listed
in the consultation. Some of the more commonly identified issues included the
following: 
Ø 
There are no separate targets for biowaste or
other waste streams such as textiles;
Ø 
The obligation to have separate collections is
not clearly defined and is not 'ambitious' enough;
Ø 
Targets focus too much on quantity of collected
waste and not enough on the actual rates of reuse and/or recycling;
Ø 
The Waste Framework Directive does not
distinguish well between different forms of recycling (e.g. closed- vs.
open-loop recycling);
Ø 
The quality of the recyclate/final product is
not taken into account in the existing targets;
Ø 
There is no harmonised definitions on treatment
options (e.g. reuse, preparation for reuse, and recycling);
Ø 
There are no targets on waste prevention and/or
reuse;
Ø 
There are no ‘communication targets’ to ensure
effective sharing of information and to promote the required behaviour change;
Ø 
Statistical/data issues (e.g. poor quality data
reporting/statistical analysis by some Member States);
Ø 
The weight based targets are inadequate as they
do not account for differences in the environmental impacts of different
materials;
Ø 
There are no recycling targets which cover
commercial and industrial waste; and
Ø 
There are no strict penalties for failing to
meeting the targets.

4.2       Suggestions for Revision

A number of suggested options for changes
to the Waste Framework Directive were identified in the consultation. The
following options were included in the consultation as part of a scoring matrix:
Targets on Municipal Waste, Article 11 (2) a
1. 
Establish a single target and
calculation method based only on the quantity of municipal waste
collected. This would require that a consistent definition of municipal waste
is used in all Member States.  
2. 
Extend the existing targets
to include other specific waste streams beyond paper, metal, plastic and glass
(for example, wood, food waste, textiles, and other materials in municipal
waste).
3. 
Establish a single target
and calculation method based only on the quantity of household
waste collected. This would require that a consistent definition of household
waste is used in all Member States.
4. 
Adjust the targets so that
biowaste is also included.
5. 
Set targets which reflect
environmental weightings for materials (for example, through reference to greenhouse
gas savings achieved through recycling).
6. 
Improve monitoring and
validation of the reports submitted by Member States so that the consistency
and reliability of data can be validated.
7. 
Introduce requirements on
businesses to sort a range of waste materials for recycling and composting /
anaerobic digestion.
Construction & Demolition Waste Targets, Article 11 (2)
b
8.  The 70% recycling target should not include backfilling. 
9.  Provide clear definitions of recycling and material recovery, and
how these should be calculated for the C&D waste stream.
10.   Mandate sorting of wastes at C&D sites with a special attention
to hazardous waste.
11.   Require facilities which sort ‘mixed’ C&D wastes to achieve a
high level of recycling of the input materials.
Respondents were asked to rank each of the
above options on a scale of 1 to 5, where:
Ø 
1 = poor idea, not worth consideration;
Ø 
3 = moderately good idea, may be worth further
consideration; and
Ø 
5 = very good idea, definitely deserves further
consideration.
The
results of the responses to this question are presented for all stakeholders in
Figure 4‑1 and for each
stakeholder group in Figure 4‑2 to Figure 4‑5.
In each of these figures the 11 options represent those listed above and the
reader should refer back to this list in order to identify which options were
most favoured by respondents. As described in Section 2.2 the results of this
ranking exercise are presented in two ways: 
1.      
As a weighted average rank; and
2.      As the difference in the number of respondents who ranked an option
as ‘5’ vs. those who ranked it as ‘1’.
In the pages below each figure contains two
graphs which present the results of the above two analyses.
Figure 4‑1: Scoring of Options by all Stakeholders
        Targets on Municipal Waste                              
Weighted Average Rank      
Construction
& Demolition Waste Targets
  
Difference in the Number of Rank 5 vs. Rank 1
Responses
Figure 4‑2: Scoring of Options by all Stakeholder
Groups – Targets on Municipal Waste, Weighted Average Rank
Figure 4‑3: Scoring of Options by all Stakeholder
Groups – Targets on Municipal Waste, Rank 5 vs. Rank 1
Figure 4‑4: Scoring of Options by all Stakeholder
Groups – Construction and Demolition Waste Targets, Weighted Average Rank
Figure 4‑5: Scoring of Options by all Stakeholder
Groups – Construction and Demolition Waste Targets, Rank 5 vs. Rank 1
In addition to the listed options which
were scored as part of the closed-ended scoring matrix respondents were also
asked to list solutions that they felt had not already been identified and
should potentially be considered. These open-ended responses were coded to
identify the different themes that emerged from these responses. The range of
additional solutions that were suggested by all stakeholder groups are
summarised in Table 4‑1. 
Table 4‑1: Additional Suggestions for Revision
Provided by All Stakeholder Groups
 Solution ||  Number of Times Solution Identified by Respondents 
 Introduce waste prevention and/or reuse targets || 27 
 Resource efficiency should be considered when setting targets || 26 
 There should be a clear distinction between different types of recycling (e.g. closed-loop vs. open-loop) || 25 
 C&D recycling targets should include backfilling under certain clearly defined conditions || 23 
 Targets should encourage/mandate separate collections (of dry recyclables and/or food waste) and the issues of separate collections should be clearly resolved by the EC || 21 
 Targets should be specified on a kg/capita basis and reduced over time || 14 
 All organisation collecting and recycling waste should report on quantities received/processed, there should be better reporting of end destinations || 13 
 Introduce recycling targets for commercial and/or industrial waste || 12 
 Establish a separate recycling target for biowaste || 9 
 Targets should incentivize local recycling rather than export to other EU countries or to outside the EU || 8 
 A better legislative definition of backfilling is required || 7 
 Targets for each material should be based on lifecycle assessment of environmental impacts || 7 
 Establish a specific target for hazardous waste || 6 
 Waste management at C&D sites should be more highly regulated (e.g. the requirement for Site Waste Management Plans in the UK) || 5 
 Ensure that existing targets are properly implemented || 5 
 Clarify all definitions in the legislation || 5 
 Extend producer responsibility legislation to other products/materials || 5 
 Introduce penalties for Member States who fail to meet the targets || 3 
 Targets should be equal or nearly equal across all Member States || 3 
 Better enforcement of the targets is required || 3 
 Targets should not mandate source segregation of recycling || 3 
 Targets should focus on the quality as well as quantity of recycled materials || 3 
 Introduce qualitative targets where technical specifications of raw materials are compared against secondary materials || 3 
 Target should be calculated on total waste arisings, not just municipal waste || 2 
 The targets should be more ambitious || 2 
 Put in place financial incentives to move waste to the top of the hierarchy || 2 
 Targets should be based on waste generated rather than waste collected as waste can be 'lost' from the system in the form of litter etc. || 2 
 Consider different targets for each member state which reflect the large variation in waste management across the EU || 2 
 Biowaste should not be included in the targets || 2 
 Source separation of hazardous wastes should be mandatory || 2 
 C&D recycling target should be more ambitious || 2 
 After 2020 set separate targets for household and municipal waste || 2 
 For C&D recycling target set individual/tailored improvement targets based on current performance of Member States || 2 
 Create targets to ensure recyclability of products and minimum resource use during manufacture || 1 
 Make the public advertisement of waste performance obligatory for local authorities || 1 
 Integrate the Packaging Waste Directive into the Waste Framework Directive || 1 
 Materials which can more easily/cost effectively be recycled should have higher targets || 1 
 Define the materials that can be included in backfilling || 1 
 Promote segregation of C&D waste || 1 
 High-efficiency energy recovery should be included in the targets || 1 
 Remove the exclusion of hazardous waste from the calculation method for the target of C&D waste. || 1 
 It is important to have a target for backfilling || 1 
 Waste streams should be based on  European Waste Catalogue (EWC) codes || 1 
 The 70% material recovery target for C&D waste should only include recycling of other fractions than aggregate || 1 
 There is a need for harmonization of the provisions of the Waste Framework Directive when they are transposed in Member States || 1 
 Do not extend targets to include other specific waste streams beyond paper, metal, plastic and glass || 1 
 Implement a residual waste target to drive waste prevention || 1 
 New targets to include other specific waste materials should be made at a local, rather than at EU, level. || 1 
 New targets should be set even if not all states have reached existing targets || 1 
 Weight is a more reliable and effective measure than environmental impact || 1 
 Packaging of construction materials should be incorporated into C&D targets || 1 
 NGOs and industry associations should play a role in the monitoring and validation of the reports || 1 
 Waste targets should be calculated using parameters that are captured by Eurostat already || 1 
 C&D targets should not be set || 1 
 There may need to be some flexibility in the targets to allow for market forces || 1 
 An impact assessment should be carried out to look into the effects of including backfilling in the targets || 1 
 Dismantling, sorting and collection of different types of C&D waste should be mandatory || 1 
 The C&D target should be adjusted if it is to exclude backfilling || 1 
 Implementation of targets should be left to member states || 1 
 Define targets for each of the three steps of the recycling value chain: collection, preparation recovery and final recovery || 1 
 The C&D recycling target should, under certain circumstances, include incineration || 1 
 Develop a Biowaste Directive || 1 
 Set waste prevention target for C&I waste || 1 
 Set targets for 'critical materials' || 1 
 Use alternative instruments (e.g. taxes, charges, voluntary agreements) to achieve objectives || 1 
 SMEs below a certain size should not be obliged to segregate their waste || 1 
 Non-target solution || 192 
 Response was a comment on proposed solutions / Solution was already listed in the consultation || 76 
 Response is an issue, not a solution || 9 

5.0                    
Landfill Directive

As per the consultation this section is
divided into two sections. The first presents a summary of the key issues that
were identified by stakeholders that were not already identified within the consultation
(see Appendix A1.0). The second looks at possible options for revising and/or
improving the targets. 

5.1      
Key Issues

A number of issues were identified in the
consultation and respondents were asked to succinctly list up to three
additional issues that had not been listed in the consultation. As described in
Section 2.0 these open ended responses were coded to identify common themes and
allow the data to be subjected to more detailed analysis. The feedback on
issues received by respondents was intended to provide additional context to
the issues already identified in the consultation. In many instances
stakeholders chose to provide solutions to problems instead of listing
additional problems related to the existing targets that had not already been
identified within the consultation. Some of the issues that were reported were
also not directly related to the Landfill Directive targets or were repeats,
albeit in different words, of the issues that had already been listed in the
consultation. Some of the more commonly identified issues included the
following:  
Ø 
The current targets are only for biodegradable
municipal waste rather than other waste streams;
Ø 
There has been a cack of enforcement and
implementation of the Landfill Directive in many Member States;
Ø 
Inconstant methodologies have been used to
report on the targets and landfill statistics under the Landfill Directive;
Ø 
A lack of recycling infrastructure in some
Member States means that they are unlikely to be able to meet the targets; and
Ø 
The Landfill Directive is not strongly linked to
current European Commission thinking on resource efficiency and the
implementation of the waste hierarchy.

5.2      
Suggestions for Revision

A number of suggested options for changes
to the Directive targets were identified in the consultation. The following options
were included in the consultation as part of a scoring matrix:
1.      
Revise the targets so that
they are set in such a way that they do not penalise countries whose economies
are growing faster after starting from a lower base.
2.      Establish a legal obligation for reporting on
‘municipal waste’ and enforcing the use of a single definition of the term by
all Member States. 
3.      
Standardise the approach to
performance measurement and progress reporting.
4.     
In Member States where no
data exists for 1995, a more recent baseline year should be set with targets
adjusted accordingly. 
5.     
Clarify when treated waste should
be considered ‘no longer biodegradable’ from the perspective of the Landfill Directive.
6.     
Further tighten existing
targets (e.g. move progressively towards zero biodegradable municipal waste
sent to landfill).
7.      
Progressively include all
biodegradable wastes (not just biodegradable wastes of municipal
origin) within targets similar to the existing ones.
8.     
Introduce targets for the
progressive reduction in the quantity of residual waste irrespective of how it
is subsequently managed (whether it is sent to incineration, MBT or landfill,
or any other residual waste management method).
9.     
Define ‘pre-treatment’ in an
unambiguous manner so that the ban on landfilling waste that is not pre-treated
is applied equally across all countries.
Respondents were asked to rank each of the
above options on a scale of 1 to 5, where:
Ø 
1 = poor idea, not worth consideration;
Ø 
3 = moderately good idea, may be worth further
consideration; and
Ø 
5 = very good idea, definitely deserves further
consideration.
The
results of the responses to this question are presented for all stakeholders in
Figure 5‑1 and for each
stakeholder group in Figure 5‑2 and Figure 5‑3. In each of these figures
the 9 options represent those listed above and the reader should refer back to
this list in order to identify which options were most favoured by respondents.
As described in Section 2.2 the results of this ranking exercise are presented
in two ways in the figures below: 
1.      
As a weighted average rank; and
2.      As the difference in the number of respondents who ranked an option
as ‘5’ vs. those who ranked it as ‘1’.
In the pages below each figure contains two
graphs which present the results of the above two analyses.
Figure 5‑1: Scoring of Options by all Stakeholders
Weighted Average Rank
Difference in the Number of Rank 5 vs. Rank 1 Responses
Figure 5‑2: Scoring of Options by all Stakeholder
Groups, Weighted Average Rank
Figure 5‑3: Scoring of Options by all Stakeholder
Groups, Rank 5 vs. Rank 1
In addition to the listed options which
were scored as part of the closed-ended scoring matrix respondents were also
asked to list any additional solutions that they felt had not already been
identified and should potentially be considered. These open-ended responses
were coded to identify the different themes that emerged from these responses.
The additional solutions that were suggested by all stakeholder groups are
presented in Table 5‑1 below.

Table 5‑1: Additional Suggestions for Revision
Provided by Stakeholders
 Solution || Number of Times Solution Identified by Respondents 
 Introduce landfill bans for recyclable and/or combustible materials || 36 
 Residual waste reduction targets should be specified (e.g. reduction in kg per capita per year) with suitable (i.e. environmentally sound and cost effective) alternatives treatment/recycling options are in place || 28 
 Member states should be financially rewarded for legislation which moves waste up the hierarchy || 22 
 Include more material streams in landfill diversion targets || 18 
 Residual waste reduction targets should be set in the WFD not in the Landfill Directive || 17 
 Progressive introduction of landfill bans on untreated waste || 16 
  Adopt the legal framework as devised by the German Landfill Ordinance which excludes the disposal of plastic waste in bulk in landfills || 13 
 No landfill bans unless feasible alternatives can be identified i.e. landfilling is not simply replaced by incineration || 12 
 Introduce a mandatory landfill tax || 10 
 Introduce landfill bans for biowaste || 6 
 Provide support to member states regarding infrastructure investments || 4 
 Stricter enforcement of the targets/Directive is required || 4 
 Levels of targets should be informed by environmental impact assessments || 4 
 Ensure all EU funding supports the waste hierarchy || 4 
 Countries starting from a low base should have the same targets but a longer time to achieve them || 2 
 There should not be an outright ban on landfill - some level of landfilling will always be required || 2 
 Specific diversion rules should be developed for different materials || 2 
 Penalise Member States who exaggerated their statistics for 1995 || 1 
 Implement landfill bans for specific materials and/or waste streams || 1 
 Gradual introduction of landfill and incineration bans with suitable (i.e. environmentally sound and cost effective) alternatives treatment/recycling options are in place || 1 
 Targets should be variable depending on waste produced per person and balanced against economic performance || 1 
 There should be a stronger link to EC resource efficiency policy || 1 
 More guidance required from EU on recommended treatment methods || 1 
 There should be two different targets for biodegradable wastes, one for household waste and one for commercial waste.  || 1 
 Baseline years and deadlines to reach the targets should be the same for all Member States || 1 
 Member States whose data is estimated or highly inconsistent should have a more recent baseline year with targets adjusted accordingly || 1 
 If member states are far from achieving targets, setting more ambitious targets may not be effective || 1 
 There should be an updated baseline year for all Member States to ensure a level playing field || 1 
 The first priority should be to avoid illegal and uncontrolled landfill sites  || 1 
 Targets should be set for household and industrial waste instead of municipal waste. || 1 
 The choice of measurement methodology is to be kept at national level bearing in mind the need to achieve comparability at the EU-level || 1 
 Member State which landfill more than X% of its waste should be required to agree an Action Plan of national measures to reduce the amount of waste sent to landfill || 1 
 Alternatives to targets should be considered, such as economic instruments etc. || 1 
 Replace percentage targets with a single target setting maximum amount of landfilled biodegradable waste of any origin in kg per capita || 1 
 Move towards a maximum level of landfilling for all waste of X% per year || 1 
  Post-consumer wood materials should be diverted from landfill || 1 
 Non-target related solution proposed by stakeholder || 70 
 Response was a comment on proposed solutions / Solution was already listed in the consultation || 50 
 Response is an issue, not a solution || 2 
Contents
1.0      Packaging and Packaging Waste Directive. 3
1.1       Key
Issues. 3
1.2       Suggestions
for Revision. 3
2.0      Roadmap to a Resource Efficient Europe. 15
2.1       Waste
Prevention. 15
2.2       Preparation
for Reuse. 23
2.3       Recycling
Rates. 25
2.4       Limiting
Incineration of Waste Which Might Otherwise be Recycled.. 31
2.5       Landfill 35
3.0      Targets as a Tool in Waste Legislation. 41
4.0      Citizen Consultation. 45

1.0                     
Packaging and Packaging Waste Directive

As per the
consultation this section is divided into two sections. The first presents a
summary of the key issues that were identified by stakeholders that were not
already identified within the consultation (see Appendix A1.0). The second
looks at possible options for revising and/or improving the targets. 

1.1       
Key Issues

A number of issues were identified in the
consultation and respondents were asked to succinctly list up to three
additional issues that had not been listed in the consultation. As described in
Section Error! Reference source not found. these open ended responses were coded to identify common themes and
allow the data to be subjected to more detailed analysis. The feedback on
issues received by respondents was intended to provide additional context to
the issues already identified in the consultation. In many instances
stakeholders chose to provide solutions to problems instead of listing
additional problems related to the existing targets that had not already been
identified within the consultation. Some of the issues that were reported were
also not directly related to the Packaging Waste Directive targets or were
repeats, albeit in different words, of the issues that had already been listed
in the consultation. Some of the more commonly identified issues included the
following:  
Ø 
Packaging Waste Directive does not include any
targets for beverage and food cartons made of composite materials;
Ø 
The weight based targets do not reflect the
environmental impacts associated with recycling different materials (e.g. glass
vs. aluminium);
Ø 
There are no waste prevention or preparation for
reuse targets in the Directive; and
Ø 
The targets are not ambitious enough and could
be extended for some materials.

1.2       Suggestions for Revision

A number of suggested options for changes
to the Directive targets were identified in the consultation. The following options
were included in the consultation as part of a scoring matrix:
1. 
The methodology for calculating recycling rates
should be standardised so that data (and hence performance levels) are
comparable across Member States.
2. 
Remove from the Packaging Directive the target
for packaging waste from municipal sources and include it into the Waste
Framework Directive to ensure full consistency with the existing target on
municipal waste recycling. 
3.  Bring the recycling targets for different materials closer together
to ensure a more level playing field.
4.  Incorporate “weightings” for materials recycled based on
environmental benefits derived from recycling the material.
5.  The targets for some packaging materials could be subdivided into
subcategories; for example, metals could be divided into non-ferrous and
ferrous metals. The same could apply for plastic; for example, separate targets
could be set for PET, LDPE, and HDPE.
6.  Set specific targets for recycling of packaging waste from
households to encourage further recycling of household packaging.
7.  Remove from the Directive the maximum limit of 80% that stipulates
how much packaging waste a Member State is allowed to recycle.
8.  Introduce a target for prevention of packaging waste (the
development of waste prevention targets is covered in a broader manner in a later
section of this consultation). 
9.  Adjust the definitions for reuse and recycling in the Packaging
Directive to be consistent with those contained in the Waste Framework
Directive.
10.   Expand the recycling target to include reuse, by allowing the reuse
of packaging to be credited to the recycling target.
11.   Introduce targets for reuse for commercial transit packaging.
12.   Introduce targets for reuse for all packaging.
Respondents were asked to rank each of the
above options on a scale of 1 to 5, where:
Ø 
1 = poor idea, not worth consideration;
Ø 
3 = moderately good idea, may be worth further
consideration; and
Ø 
5 = very good idea, definitely deserves further
consideration.
The results of the responses to this question are presented for all
stakeholders in Figure 1‑1 and for each stakeholder group in Figure 1‑2 and Figure 1‑3. In each of these figures
the 12 options represent those listed above and the reader should refer back to
this list in order to identify which options were most favoured by respondents.
As described in Section Error! Reference source not
found. the results of this ranking exercise are
presented in two ways: 
1.      
As a weighted average rank; and
2.      As the difference in the number of respondents who ranked an option
as ‘5’ vs. those who ranked it as ‘1’.
In the pages below each figure contains two
graphs which present the results of the above two analyses.
Figure 1‑1: Scoring of Options by all Stakeholders
Weighted Average
Difference in the Number of Rank 5 vs. Rank 1
Responses
Figure 1‑2: Scoring of Options by all Stakeholder
Groups, Weighted Average Rank 
Figure 1‑3: Scoring of Options by all Stakeholder
Groups, Rank 5 vs. Rank 1
In addition to the listed options which
were scored as part of the closed-ended scoring matrix respondents were also
asked to list any additional solutions that they felt had not already been
identified and should potentially be considered. These open-ended responses
were coded to identify the different themes that emerged from these responses.
The range of additional solutions that were suggested by all stakeholders are
presented in Table 1‑1. 
Table 1‑1: Additional Suggestions for Revision
Provided by Stakeholders
 Solution || Number of Times Solution Identified by Respondents 
 Introduce a 60% minimum target per member state for each packaging material by 2020 || 42 
 A prevention target for packaging should not be considered (e.g. because packaging helps to prevent food waste, issues with health and safety) || 27 
 Different types of recycling should be differentiated in the directive (e.g. closed- vs. open-loop recycling) || 27 
 Introduce an incremental ban on the landfilling and/or incineration of packaging waste || 24 
 The use of Extended Producer Responsibility, Eco-design, and other fiscal instruments should be extended/enhanced || 23 
 Target should set minimum levels for use of recycled materials in packaging || 22 
 Make source segregation of packaging materials mandatory || 20 
 Place greater emphasis on the European CEN standards || 19 
 Resource efficiency/environmental impacts should be the most important consideration when setting targets || 17 
 Set targets to limit the use of packaging that cannot easily be recycled || 13 
 Targets for reusable packaging should be the same for all materials and apply across all Member States || 9 
 The recycling target should be based on the actual amount of material that is reprocessed and not on what is collected || 6 
 Packaging manufacturers who use recycled materials in their products should be incentivised by having reduced recycling obligations || 5 
 The rates achieved in the best performing Member States should serve as a target for all other Member States || 4 
 Introduce targets for deposit refund schemes for certain packaging materials || 4 
 Impacts on quality must be taken into account when setting targets || 4 
 Introduce requirements to report on the end destinations of packaging waste || 3 
 Targets should consider biodegradable plastic packaging || 3 
 Set separate targets for ferrous and non-ferrous metals || 3 
 Set separate targets for secondary and tertiary packaging || 3 
 Reported recycling rates for exported materials should reflect the actual % of material recycled rather than the amount exported || 2 
 Introduce one single target comprising reuse, recycling and recovery of packaging waste || 2 
 Using life cycle analysis to determine targets for different materials is not cost effective || 2 
 Better regulation of the output and operation of MRFs (e.g. the MRF Code of Practice introduced in the UK) || 2 
 There is no need to bring the recycling targets for different materials closer together || 1 
 Material treated/recycled outside of the EU28 should not count towards the targets || 1 
 Remove the recovery targets from the Directive || 1 
 Introduce consistent minimum thresholds for companies that have no reporting/recycling obligations || 1 
 Remove the target for recycling wood packaging from Directive || 1 
 Targets for packaging should be separate from the target contained in the WFD || 1 
 Introduce a 'front runner' scheme whereby packaging standards are set by the best performing manufacturer || 1 
 Introduce more ambitious targets || 1 
 Targets should be simplified and differentiated by material || 1 
 Response was a comment on proposed solutions / Solution was already listed in the consultation || 139 
 Non-target related solution || 89 
 Stakeholder response was an issue, not a solution || 3 
The Commission is keen to encourage higher
rates of recycling. It recognises, however, the need to maintain the quality of
recycled material so that it can be used profitably and with losses kept to a
minimum between the collection and recycling stages. Keeping in mind the need
to maintain quality, respondents were asked what they believed the highest
level of recycling could reasonably be for the materials included in the
current targets. The weighted average recycling rate for the different
materials, and the proposed year in which stakeholders believed the reported
recycling rates could realistically be achieved, are presented for all stakeholders
in Figure 1‑4 and for
each stakeholder group in Figure 1‑5 and Figure 1‑6.
Figure 1‑4: Weighted Average Recycling Rate Reported
by all Stakeholders and Year in Which Proposed Recycling Rate May be Achieved
Proposed Recycling Rates
Year in Which Proposed Recycling Rate Could be
Achieved
Figure 1‑5: Weighted Average Recycling Rate Reported
by all Stakeholder Groups
Figure 1‑6: Year in which Proposed Recycling Rate
Could be Achieved Reported by all Stakeholder Groups
In addition to the materials already included in the existing
targets, stakeholders were asked to identify further packaging materials which
they believed should be include in any revised version of the target. The range
of additional materials suggested is summarised for the main stakeholder groups
in Table 1‑2. 
Table 1‑2: Packaging Materials that could be
Included in New Targets
 Packaging Material || Number of Times Material Identified 
 Industry, Not-for-Profit, Academic and Other Organisations 
 Composite packaging (e.g. beverage cartons) || 28 
 Polystyrene and/or similar type of protective material || 17 
 Textiles || 7 
 Glass || 1 
 Plastics || 1 
 Aluminium cans || 1 
 Beverage cans || 1 
 Non-ferrous metal || 1 
 Bio-plastics || 1 
 Public Authorities 
 Composite packaging (e.g. beverage cartons) || 7 
 Polystyrene and/or similar type of protective material || 1 
 Non-ferrous metal || 1 
 Textiles || 1 
 European Citizens 
 Composite packaging (e.g. beverage cartons) || 6 
 Textiles || 5 
 Glass || 1 
 Polystyrene and/or similar type of protective material || 1 
 Non-ferrous metal || 1 
 PET || 1 

2.0                    
Roadmap to a Resource Efficient Europe

In order to contribute to the development
of resource efficiency within Europe the Commission has adopted aspirational
targets for waste prevention and management in the Roadmap to a Resource
Efficient Europe (the Roadmap).[1]
These aspirational targets were proposed in the Commission’s proposal for a 7th
Environmental Action Plan. [2]
In the Roadmap, the following aspirations are included within the overall
Milestone for 2020:
1.      
Waste generated per capita is in absolute
decline; 
2.     
More materials, including materials having a
significant impact on the environment and critical raw materials, are recycled;

3.      
Reuse and recycling are economically attractive
options, with more material recycled and high quality recycling ensured;
4.     
Energy recovery is limited to non-recyclable
materials (compostable materials are also considered to be recyclable); and
5.      Landfilling is virtually eliminated.
This section of the consultation included
questions on the application of the Roadmap on Resource Efficiency and its
relation to the evolution of the main targets contained in legislation. We
present here how respondents felt that the ambitions of the Roadmap should be
implemented through the setting of targets in the context of this work.

2.1      
Waste Prevention

The first question of this section asked
respondents whether they agreed with the principle that there should be targets
for waste prevention. Responses to this question are summarised in Table 2‑1. Those stakeholders who
responded that they felt that there should be no waste prevention targets were
automatically directed to the next section of the consultation (see Section 1.1).
The results presented below therefore come from those respondents who felt that
the setting of new waste prevention targets would be a good idea.   
Table 2‑1: Should the Commission Set New Waste
Prevention Targets?  
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 256 || 57 || 35 || 42 || 4 || 12 || 41 || 65 
 % || 55% || 42% || 44% || 78% || 67% || 60% || 84% || 56% 
 No || No. || 206 || 79 || 45 || 12 || 2 || 8 || 8 || 52 
 % || 45% || 58% || 56% || 22% || 33% || 40% || 16% || 44% 
 Total || No. || 462 || 136 || 80 || 54 || 6 || 20 || 49 || 117 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
Respondents in favour
of waste prevention targets were asked which waste streams, materials, or
products they thought should be targeted (respondents were allowed to identify
up to four items). The range of materials identified by each of the three main
stakeholder groups is presented in Table 2‑2.
Table 2‑2: List of Waste Streams, Materials or
Products that could be the Focus of Waste Prevention Targets
 Industry, Not-for-Profit, Academic and Other Organisations || Public Authorities || European Citizens 
 Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses 
 Hazardous waste || 28 || Food || 11 || Packaging || 5 
 "Total" waste || 20 || WEEE || 7 || Hazardous waste || 4 
 Residual waste || 16 || Packaging || 6 || Biowastes || 4 
 Industrial waste || 15 || Biowastes || 5 || Plastics || 4 
 Food || 12 || Textiles || 5 || Metals || 3 
 Biowastes || 11 || Metals || 5 || Industrial waste || 2 
 Plastics || 11 || Plastics || 5 || WEEE || 2 
 Packaging || 11 || Composite materials || 4 || Batteries || 2 
 Metals || 8 || Municipal waste || 3 || Aluminium cans || 2 
 Composite materials || 8 || Industrial waste || 3 || Plastic bottles || 2 
 Municipal waste || 7 || "Total" waste || 3 || "Total" waste || 2 
 Household waste || 5 || Household waste || 2 || Residual waste || 2 
 WEEE || 5 || C&D waste || 2 || Composite materials || 2 
 C&D waste || 4 || Hazardous waste || 2 || Commercial waste || 1 
 Commercial waste || 3 || Commercial waste || 1 || C&D waste || 1 
 Textiles || 3 || Paper / Cardboard || 1 || Paper / Cardboard || 1 
 Plastic packaging film || 2 || Glass || 1 || Textiles || 1 
 Plastic packaging || 2 || Furniture || 1 || Food || 1 
 Medicines and healthcare waste || 3 || Garden || 1 || Non-packaging paper || 1 
 Batteries and/or accumulators || 1 || Plastic bottles || 1 || Other scrap metal || 1 
 Composites || 1 || Other rigid plastic packaging || 1 || Non-packaging rigid plastics || 1 
 Garden || 1 || Residual waste || 1 || Plastic packaging film || 1 
 Non-packaging paper || 1 || Single use carrier bags || 1 || Furniture || 1 
 Other rigid plastic packaging || 1 || Paint || 1 || Household oil || 1 
 Inert materials || 1 ||   ||   || Tyres || 1 
 Critical materials || 1 ||   ||   || Pesticides || 1 
 Beverage bottles and cans || 1 ||   ||   ||   ||   
 Asphalt || 1 ||   ||   ||   ||   
Respondents were asked to rank a number of
options for the introduction of waste prevention targets. As in other sections
of the consultation this ranking was on a scale of 1
to 5, where:
Ø 
1 = poor idea, not worth
consideration;
Ø 
3 = moderately good idea,
may be worth further consideration; and 
Ø 
5 = very good idea,
definitely deserves further consideration.
The five options that were
put forward were:
1. 
In line with the proposal in
the Roadmap, a requirement that waste generated per capita is in decline by 2020.
2. 
Targets for decoupling of
municipal waste from economic growth in line with Article 9(c) of the Waste
Framework Directive. For example, the difference between the annual change in
municipal waste per capita (X%) and the annual change in GDP per capita (Y%)
should demonstrate a decoupling tendency such that over comparable (e.g. four
year) periods, the value of (Y – X) is increasing in value.
3. 
Consistent reporting of
household waste arisings across Member States would act to produce a level
playing field for setting absolute targets on waste prevention (e.g. no greater
than X kg per household per year). The targets could exhibit a declining trend
over time.
4. 
New requirements could be
set on Member States to incrementally increase the number of prevention
measures in place and the overall coverage of these measures. For example, the number
of households who have signed up to say “no” to unwanted mail, or the number of
households covered by measures to reduce food wastage.
5. 
Introduce requirements for
progressive coverage of households by pay-as-you throw schemes. 
The results of the responses to this question are presented for all
stakeholders in Figure 2‑1 and for each stakeholder group in Figure 2‑2 and Figure 2‑3. In each of these figures
the 5 options represent those listed above and the reader should refer back to
this list in order to identify which options were most favoured by respondents.
As described in Section Error! Reference source not
found. the results of this ranking exercise are
presented in two ways: 
1.      
As a weighted average rank; and
2.      As the difference in the number of respondents who ranked an option
as ‘5’ vs. those who ranked it as ‘1’.
In the pages below each figure contains two
graphs which present the results of the above two analyses.
Figure 2‑1: Scoring of Options by all Stakeholders
Weighted Average
Difference in the Number of Rank 5 vs. Rank 1
Responses
Figure 2‑2: Scoring of Options by all Stakeholder
Groups, Weighted Average Rank
Figure 2‑3: Scoring of Options by all Stakeholder
Groups, Rank 5 vs. Rank 1

2.2       Preparation for Reuse 

Stakeholders were asked if they agreed with
the principle that separate targets should be set for preparation for reuse.
Responses to this question are summarised in Table 2‑3. Those stakeholders who
responded that they felt that there should be no such targets were automatically
directed to the next section of the consultation (see Section 2.3).   
Table 2‑3: Should the Commission Set New Preparation
for Reuse Targets?  
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 211 || 38 || 20 || 39 || 3 || 10 || 31 || 70 
 % || 46% || 28% || 25% || 72% || 50% || 50% || 63% || 60% 
 No || No. || 251 || 98 || 60 || 15 || 3 || 10 || 18 || 47 
 % || 54% || 72% || 75% || 28% || 50% || 50% || 37% || 40% 
 Total || No. || 462 || 136 || 80 || 54 || 6 || 20 || 49 || 117 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
Respondents in favour
of setting new preparation for reuse targets were asked which waste streams, materials,
or products they thought should be targeted (respondents were allowed to
identify up to four items). The range of materials identified by each of the
three main stakeholder groups is presented in Table 2‑4.
Table 2‑4: List of Waste Streams, Materials or
Products that could be the Focus of Preparation for Reuse Targets
 Industry, Not-for-Profit, Academic and Other Organisations || Public Authorities || European Citizens 
 Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses 
 Textiles || 35 || Textiles || 15 || WEEE || 10 
 WEEE || 35 || Furniture || 13 || Furniture || 7 
 Furniture || 34 || WEEE || 10 || Textiles || 3 
 Beverage bottles || 13 || End-of-life vehicles || 3 || Glass || 2 
 Toys || 6 || Construction & Demolition waste || 2 || Glass bottles || 2 
 Glass bottles || 4 || Glass || 2 || End-of-life vehicles || 2 
 End-of-life vehicles || 3 || Household waste || 1 || Toys || 2 
 Bulky waste || 2 || Bulky waste || 1 || Household waste || 1 
 Glass || 2 || Plastics || 1 || Wood  || 1 
 Plastics || 2 || Clothing || 1 || Plastics || 1 
 Wood  || 1 || Beverage bottles || 1 || Mobile Phones || 1 
 Metals || 1 || Paint || 1 || Bicycles || 1 
 Batteries and/or accumulators || 1 ||   ||   || Cans || 1 
 Cans || 1 ||   ||   || Chemicals || 1 
 Nappies || 1 ||   ||   ||   ||   
 Commercial transit packaging || 1 ||   ||   ||   ||   
 Specialty fibres such as aramides and carbon fibre || 1 ||   ||   ||   ||   

2.3       Recycling Rates

The European Commission is keen to see that more materials are
recycled, especially critical raw materials and those that have a significant
impact on the environment. In light of this, stakeholders were asked whether
they thought that recycling rates should be increased and /or made to include
more materials/waste streams. Responses to this
question are summarised in Table 2‑5. Those stakeholders who responded that they felt that there should
be no such targets were automatically directed to the next section of the
consultation (see Section 2.4).   
Table 2‑5: Should the Commission Increase or Expand
Existing Recycling Targets?  
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 390 || 101 || 66 || 44 || 5 || 17 || 42 || 115 
 % || 84% || 74% || 83% || 81% || 83% || 85% || 86% || 98% 
 No. || No || 72 || 35 || 14 || 10 || 1 || 3 || 7 || 2 
 % || 16% || 26% || 18% || 19% || 17% || 15% || 14% || 2% 
 Total || No || 462 || 136 || 80 || 54 || 6 || 20 || 49 || 117 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
Stakeholders who believed that current
recycling targets should be revised, were asked to define the highest level of
recycling that they felt could reasonably be obtained for the following waste
streams by 2025:
Ø 
Household waste;
Ø 
Municipal waste;
Ø 
Commercial waste;
Ø 
Industrial waste; and
Ø 
Construction and demolition waste.
The weighted average recycling rate
reported are presented for all stakeholders in Figure 2‑4 and for each stakeholder
group in Figure 2‑5.
Figure 2‑4: Average of Highest Achievable Recycling
Rates Reported by all Stakeholders
Figure 2‑5: Average of Highest Achievable Recycling
Rates Reported by all Stakeholder Groups
In order to take into account the large
differences between Member States’ current recycling levels, stakeholders were
asked whether they supported an approach which would set targets relative to
the existing situation in each Member State (for example, setting recycling
rates that increased by a given amount each year). Responses to this question
are presented in Table 2‑6.
Table 2‑6: Should Recycling Targets be Set According
to the Situation within Individual Member States? 
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 193 || 45 || 32 || 32 || 3 || 8 || 21 || 52 
 % || 60% || 58% || 70% || 82% || 60% || 50% || 58% || 51% 
 No || No. || 128 || 32 || 14 || 7 || 2 || 8 || 15 || 50 
 % || 40% || 42% || 30% || 18% || 40% || 50% || 42% || 49% 
 Total || No. || 321 || 77 || 46 || 39 || 5 || 16 || 36 || 102 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
At present only
municipal waste and construction and demolition waste are covered by specific
recycling targets in the Waste Framework Directive, whilst other Directives
cover packaging, WEEE, ELVs and batteries. The consultation asked whether
stakeholders thought that there was a case for setting recycling targets on
waste streams, materials, or products that are not already covered by targets
in existing Directives. A range of answers were provided and each of
these was coded to identify commonality across responses – the results of these
responses are presented in Table 2‑7 for the three main stakeholder groups. 
Table 2‑7: List of Waste Streams, Materials or
Products that could be the Focus of New Recycling Targets
 Industry, Not-for-Profit, Academic and Other Organisations || Public Authorities || European Citizens 
 Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses 
 Biowastes || 49 || Biowastes || 9 || Biowastes || 9 
 Textiles || 28 || Plastics || 6 || Beverage cartons || 6 
 Commercial and industrial waste || 18 || Textiles || 5 || Industrial waste || 3 
 Bulky waste || 17 || Commercial waste || 3 || Textiles || 3 
 Commercial waste || 15 || Industrial waste || 2 || Plastics || 3 
 Beverage cartons || 15 || Hazardous waste || 2 || Commercial waste || 2 
 Plastics || 14 || Food || 2 || Tyres || 2 
 Industrial waste || 12 || Critical materials || 2 || Commercial and industrial waste || 2 
 Furniture || 9 || All waste streams || 2 || Household waste || 1 
 Hazardous waste || 5 || Bulky waste || 1 || Bulky waste || 1 
 Food || 4 || Furniture || 1 || Hazardous waste || 1 
 All waste streams || 4 || Non-packaging rigid plastics || 1 || Furniture || 1 
 Wood  || 3 || Household oil || 1 || Other scrap metal || 1 
 Glass || 2 || Tyres || 1 || Toys || 1 
 Tyres || 2 || Commercial and industrial waste || 1 || All waste streams || 1 
 Flat glass || 2 ||   ||   ||   ||   
 Household waste || 1 ||   ||   ||   ||   
 C&D waste || 1 ||   ||   ||   ||   
 Paper / Cardboard || 1 ||   ||   ||   ||   
 Metals || 1 ||   ||   ||   ||   
 Ships || 1 ||   ||   ||   ||   
 Bio-plastics || 1 ||   ||   ||   ||   
 Incinerator bottom ash || 1 ||   ||   ||   ||   
 Waste oils || 1 ||   ||   ||   ||   
 Mobile phones || 1 ||   ||   ||   ||   
 Autoclaved Aerated Concrete || 1 ||   ||   ||   ||   
 Packaging waste || 1 ||   ||   ||   ||   
 Floor coverings, matrasses || 1 ||   ||   ||   ||   
 Composite materials || 1 ||   ||   ||   ||   
 Sewage sludge || 1 ||   ||   ||   ||   

2.4       Limiting Incineration of Waste Which Might Otherwise be Recycled

As stated above the Roadmap aims to ensure
that energy recovery is limited to non-recyclable materials. In light of this,
stakeholders were asked whether they supported the notation that a maximum
level should be set for the amount of waste that can be incinerated for
different waste streams. The responses to this question are presented for each
group of stakeholders in Table 2‑8. Those who stated that this would not be a good idea were not required
to respond to the remaining questions in this section. 
Table 2‑8: Should the Commission Set Maximum Levels
on the Amount of Waste that can be Incinerated? 
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 264 || 58 || 48 || 33 || 3 || 9 || 19 || 94 
 % || 57% || 43% || 60% || 61% || 50% || 45% || 39% || 80% 
 No || No. || 198 || 78 || 32 || 21 || 3 || 11 || 30 || 23 
 % || 43% || 57% || 40% || 39% || 50% || 55% || 61% || 20% 
 Total || No. || 462 || 136 || 80 || 54 || 6 || 20 || 49 || 117 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
Those in support of the idea that maximum
levels of incineration should be set were asked more specifically which waste
stream (or streams) this should apply to. The following options were provided:
Ø
Household/municipal waste;
Ø Commercial
waste;
Ø Industrial
waste; and
Ø
Construction and demolition waste.
The results of this question are presented
in Table 2‑9, which is broken
down by waste stream and stakeholder group. 
Table 2‑9: Number of Stakeholders Who Do and Do Not
Support Maximum Incineration Levels for Different Waste Streams
 Waste Stream / Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Household/Municipal Waste  
 Yes, introduce limits on incineration || No. || 151 || 27 || 24 || 30 || 2 || 5 || 12 || 51 
 % || 89% || 84% || 89% || 100% || 67% || 71% || 75% || 94% 
 No, do not introduce limits on incineration || No. || 18 || 5 || 3 || 0 || 1 || 2 || 4 || 3 
 % || 11% || 16% || 11% || 0% || 33% || 29% || 25% || 6% 
 Commercial Waste 
 Yes, introduce limits on incineration || No. || 135 || 25 || 14 || 30 || 2 || 6 || 11 || 47 
 % || 90% || 86% || 78% || 100% || 67% || 75% || 73% || 100% 
 No, do not introduce limits on incineration || No. || 15 || 4 || 4 || 0 || 1 || 2 || 4 || 0 
 % || 10% || 14% || 22% || 0% || 33% || 25% || 27% || 0% 
 Industrial Waste 
 Yes, introduce limits on incineration || No. || 118 || 19 || 14 || 29 || 1 || 4 || 7 || 44 
 % || 81% || 73% || 74% || 100% || 33% || 57% || 50% || 92% 
 No, do not introduce limits on incineration || No. || 28 || 7 || 5 || 0 || 2 || 3 || 7 || 4 
 % || 19% || 27% || 26% || 0% || 67% || 43% || 50% || 8% 
 Construction & Demolition Waste 
 Yes, introduce limits on incineration || No. || 110 || 16 || 13 || 27 || 0 || 4 || 9 || 41 
 % || 76% || 64% || 68% || 93% || 0% || 50% || 64% || 89% 
 No, do not introduce limits on incineration || No. || 34 || 9 || 6 || 2 || 3 || 4 || 5 || 5 
 % || 24% || 36% || 32% || 7% || 100% || 50% || 36% || 11% 
Respondents who supported the idea of
applying maximum levels of incineration to either one or more of the above
waste streams were asked to state what they believed was an appropriate maximum
level (as a percentage of each waste stream). The results of this question are
presented in Table 2‑10,
where the weighted average maximum incineration rate for each waste stream is
presented for each group of stakeholders.
Table 2‑10: Average Maximum Levels of Incineration
Suggested by Stakeholders
 Waste Stream || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Household/Municipal Waste  || 21% || 28% || 23% || 14% || 23% || 32% || 23% || 23% 
 Commercial Waste || 21% || 27% || 25% || 12% || 23% || 30% || 23% || 23% 
 Industrial Waste || 19% || 24% || 23% || 12% || 20% || 29% || 23% || 20% 
 Construction & Demolition Waste || 20% || 20% || 28% || 14% || 25% || 15% || 25% || 20% 
In addition to the above four waste streams
stakeholders were asked to identify any other waste streams to which a maximum
level of incineration should apply. These responses were coded to identify
common responses and the results are presented in Table 2‑11. 
Table 2‑11: List of Waste Streams to which it was
Suggested Maximum Incineration Levels Should Apply
 Industry, Not-for-Profit, Academic and Other Organisations || Public Authorities || European Citizens 
 Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses || Waste Streams/Materials/Products || No. of Responses 
 Packaging || 18 || Tyres || 2 || Packaging || 6 
 Biowastes and/or Biomass || 14 || Biowastes and/or Biomass || 1 || Biowastes and/or Biomass || 5 
 Medical waste || 13 || Plastics || 1 || Medical waste || 2 
 Plastics || 10 || Waste oils || 1 || Not a relevant response || 1 
 Paper and card || 7 || Medical waste || 1 || Hazardous waste || 1 
 Wood || 3 || PVC || 1 || Batteries || 1 
 WEEE || 3 || Non-toxic waste streams that can easily be recycled (e.g. paper) || 1 || Wood || 1 
 Packaging waste || 2 ||   ||   || Plastics || 1 
 Metals || 2 ||   ||   || WEEE || 1 
 Bulky waste || 1 ||   ||   || Paper and card || 1 
 Hazardous waste || 1 ||   ||   ||   ||   
 Tyres || 1 ||   ||   ||   ||   
 Waste oils || 1 ||   ||   ||   ||   
 End-of-life vehicles || 1 ||   ||   ||   ||   
 Food waste || 1 ||   ||   ||   ||   
 Refuse derived fuel (RDF) || 1 ||   ||   ||   ||   
 Textiles || 1 ||   ||   ||   ||   
 Furniture || 1 ||   ||   ||   ||   
 Biodegradable waste || 1 ||   ||   ||   ||   

2.5      
Landfill

There are a number of possible ways in
which the Commission’s aspirational target that landfill should be ‘virtually
eliminated’ could be implemented. Several options for achieving this were
presented in the consultation:
1.  Landfilling should be limited to residues from a specified range (to
be determined) of waste treatment operations. 
2.  Landfilling should be limited to a certain percentage of waste generated
(for instance 5%) from a particular date.
3.  Landfilling of recyclable/compostable waste (to be defined) should
be banned.
4.  Landfilling of waste that is combustible should be banned.
5.  Landfilling of waste should be banned if it has not been pre-treated
to a level where the potential to lead to methane emissions from landfills has
been virtually eliminated.
As described above, respondents were asked
to rank the above options on a scale of 1 to 5,
where:
Ø 
1 = poor idea, not worth
consideration;
Ø 
3 = moderately good idea,
may be worth further consideration; and 
Ø 
5 = very good idea,
definitely deserves further consideration.
The results of the responses to this question are presented for all
stakeholders in Figure 2‑6 and for each stakeholder group in Figure 2‑7 and Figure 2‑8. In each of these figures
the 5 options represent those listed above and the reader should refer back to
this list in order to identify which options were most favoured by respondents.
As described in Section Error! Reference source not
found. the results of this ranking exercise are
presented in two ways: 
1.      
As a weighted average rank; and
2.      As the difference in the number of respondents who ranked an option
as ‘5’ vs. those who ranked it as ‘1’.
In the pages below each figure contains two
graphs which present the results of the above two analyses.
Figure 2‑6: Scoring of Options by all Stakeholders
Weighted Average
Difference in the Number of Rank 5 vs Rank 1 Responses
Figure 2‑7: Scoring of Options by all Stakeholder
Groups, Weighted Average Rank
Figure 2‑8: Scoring of Options by all Stakeholder
Groups, Rank 5 vs. Rank 1
In addition to the listed options which
were scored as part of the closed-ended scoring matrix stakeholders were also
asked to list any additional solutions that they felt had not already been
identified and should potentially be considered. These open-ended responses
were coded to identify the different themes that emerged from these responses.
The additional solutions that were suggested by all stakeholder groups are
presented in Table 2‑12. 
Table 2‑12: Additional Suggestions Proposed by
Stakeholders
 Suggested Solution || Number of Times Solution Identified by Respondents 
 Introduction of targets should be staged or reduced by a given percentage each year || 13 
 Set landfilling and incineration rates as a maximum amount of pre-treated waste per capita which decreases over time || 11 
 Feasible alternatives must exist before landfill bans are implemented || 10 
 Outright bans are inappropriate - some landfilling will always be necessary || 7 
 The target should focus on distinct waste streams that can easily be monitored/identified (e.g. C&I waste and municipal waste) || 6 
 Targets and/or bans should not be set, Member States should use other instruments to achieve objectives || 6 
 Introduce mandatory landfill taxes || 5 
 Introduce a requirement that all waste should be sorted prior to land filling and/or incineration || 5 
 European Commission funding must enforce the waste hierarchy || 4 
 Implement a complete landfill ban as a future target || 3 
 Legislative efforts should focus on landfill taxes rather than bans || 3 
 Progressive increases in landfill taxes for member states || 3 
 Member State which landfill more than X% of its waste should be required to agree an Action Plan of national measures to reduce the amount of waste sent to landfill || 3 
 Ban sorted wastes from landfill || 3 
 Targets should be based on persistence of pollutants as well as toxicity of waste being landfilled || 2 
 Targets must be backed up by strict enforcement strategy || 2 
 Reduction in landfilling must be linked to a reduction in incineration || 2 
 Increase existing Landfill Directive targets on biodegradable waste || 2 
 Maintain existing landfill targets which focus on biodegradable waste only || 2 
 Disposal of waste in landfills should be restricted to residues of certain waste treatment processes || 2 
 Landfilling rate could be set as a maximum amount of waste per capita decreasing over a period of time || 1 
 The targets need to take into account the specific situation on islands and take this into account || 1 
 Member States should have the freedom to voluntary negotiate appropriate targets with the European Commission || 1 
 Ban single use plastics from landfill (e.g. single use plastic bags) || 1 
 Need better data before setting targets || 1 
 Strict acceptance criteria for landfills should be established for distinct waste streams || 1 
 Ban biodegradable waste from landfill || 1 
 Ban recyclable wood from landfill || 1 
 Ban certain critical materials from landfill || 1 
 Response was not relevant to this section || 66 
 Solution was already listed in the consultation / Response was a comment on proposed solutions || 28 
 Response highlighted an issue || 7 
In order to take into account the large
differences between Member States’ current levels of landfilling, respondents
were asked whether they supported an approach which would set targets relative
to the existing situation in each Member State (for example, setting a
landfilling reduction percentage per year). Responses to this question are
presented in Table 2‑13.
Table 2‑13: Should Landfilling Targets be Set
According to the Situation within Individual Member States? 
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 176 || 49 || 30 || 31 || 3 || 6 || 23 || 34 
 % || 68% || 60% || 67% || 78% || 75% || 46% || 64% || 83% 
 No || No. || 84 || 32 || 15 || 9 || 1 || 7 || 13 || 7 
 % || 32% || 40% || 33% || 23% || 25% || 54% || 36% || 17% 
 Total || No. || 260 || 81 || 45 || 40 || 4 || 13 || 36 || 41 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 

3.0                     
Targets as a Tool in Waste Legislation

The first question in this section of the
consultation asked whether stakeholders thought that the Commission should go
further than simply setting targets for Member States to achieve. The responses
received to this question are summarised in Table 3‑1. 
Table 3‑1: Should the Commission go Further than
Simply Setting Targets? 
 Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Yes || No. || 394 || 116 || 61 || 48 || 3 || 18 || 41 || 107 
 % || 85% || 85% || 76% || 89% || 50% || 90% || 84% || 91% 
 No || No. || 68 || 20 || 19 || 6 || 3 || 2 || 8 || 10 
 % || 15% || 15% || 24% || 11% || 50% || 10% || 16% || 9% 
 Total || No. || 462 || 136 || 80 || 54 || 6 || 20 || 49 || 117 
 % || 100% || 100% || 100% || 100% || 100% || 100% || 100% || 100% 
Those who felt that setting targets was
insufficient for achieving the objectives set out in the Roadmap were asked to
state, by simply entering ‘yes’ or ‘no’, whether they believed the following options
would be appropriate:
1.      
Develop guidance on the
implementation of effective producer responsibility schemes to improve the
transparency of the systems as well as their cost effectiveness.
2.     
Develop guidance on the
proper implementation of the waste hierarchy. 
3.      
Ensure a closer monitoring
by the Commission of progress accomplished by Member States in applying the
waste hierarchy.  For those Member States moving too slowly to meet the legally
binding targets, develop mechanisms to ensure that  key instruments such as a
combination of economic and legal instruments (landfill/incineration
taxes/bans, EPR schemes, incentives for municipalities and citizens, etc) are
applied.
4.     
Develop criteria for municipalities
to implement services of a minimum standard to enable sorting of a range of waste
materials for recycling and composting/anaerobic digestion.
5.     
Improve the consistency of
the definitions used in the legislation and ensure proper monitoring by
improved data collection and systematic reliability and validity checks of data
reported. 
The responses received to these options
were analysed for each group of stakeholders and the results have been
summarised in 
Table 3‑2. 
Table 3‑2: Number of Stakeholders Who Stated that
Proposed ‘Non-target’ Options were either Appropriate or Inappropriate
 Waste Stream / Answer || All Stakeholders || Stakeholder Group 
 Industry Trade Bodies || Industry Representatives || Not-for-Profit Organisations || Academic Institutions || Other Organisations || Public Authorities || European Citizens 
 Option 1: Develop guidance on the implementation of effective producer responsibility schemes to improve the transparency of the systems as well as their cost effectiveness. 
 Appropriate || No. || 314 || 85 || 37 || 44 || 3 || 14 || 35 || 96 
 % || 85% || 79% || 64% || 98% || 100% || 82% || 90% || 94% 
 Inappropriate || No. || 57 || 22 || 21 || 1 || 0 || 3 || 4 || 6 
 % || 15% || 21% || 36% || 2% || 0% || 18% || 10% || 6% 
 Option 2: Develop guidance on the proper implementation of the waste hierarchy. 
 Appropriate || No. || 302 || 100 || 53 || 39 || 2 || 16 || 36 || 56 
 % || 93% || 95% || 93% || 87% || 100% || 89% || 95% || 92% 
 Inappropriate || No. || 24 || 5 || 4 || 6 || 0 || 2 || 2 || 5 
 % || 7% || 5% || 7% || 13% || 0% || 11% || 5% || 8% 
 Option 3: Ensure a closer monitoring by the Commission of progress accomplished by Member States in applying the waste hierarchy.  
 Appropriate || No. || 339 || 98 || 51 || 45 || 2 || 14 || 29 || 100 
 % || 92% || 91% || 89% || 98% || 67% || 88% || 81% || 97% 
 Inappropriate || No. || 30 || 10 || 6 || 1 || 1 || 2 || 7 || 3 
 % || 8% || 9% || 11% || 2% || 33% || 13% || 19% || 3% 
 Option 4: Develop criteria for municipalities to implement services of a minimum standard to enable sorting of a range of waste materials for recycling and composting/anaerobic digestion. 
 Appropriate || No. || 255 || 69 || 41 || 43 || 2 || 10 || 27 || 63 
 % || 85% || 79% || 85% || 96% || 100% || 63% || 73% || 95% 
 Inappropriate || No. || 46 || 18 || 7 || 2 || 0 || 6 || 10 || 3 
 % || 15% || 21% || 15% || 4% || 0% || 38% || 27% || 5% 
 Option 5: Improve the consistency of the definitions used in the legislation and ensure proper monitoring by improved data collection and systematic reliability and validity checks of data reported. 
 Appropriate || No. || 366 || 109 || 57 || 46 || 3 || 16 || 35 || 100 
 % || 98% || 98% || 97% || 100% || 100% || 94% || 95% || 98% 
 Inappropriate || No. || 9 || 2 || 2 || 0 || 0 || 1 || 2 || 2 
 % || 2% || 2% || 3% || 0% || 0% || 6% || 5% || 2% 
In addition to the listed options which
were scored as part of the closed-ended scoring matrix stakeholders were also
asked to list any additional solutions that they felt had not already been
identified and should potentially be considered. These open-ended responses
were coded to identify the different themes that emerged from these responses.
The additional solutions that were suggested by all stakeholder groups are
summarised in Table 3‑3. 
Table 3‑3: Additional Suggestions for Revision
Provided by all Stakeholders
 Suggested Solution || Number of Times Solution Identified by Respondents 
 Make separate glass collections mandatory || 24 
 Make separate collections of certain waste streams mandatory || 16 
 The EC should no longer fund incineration facilities || 16 
 Encourage application of economic instruments to promote resource efficiency || 13 
 Create a register of EU approved facilities for recycling exports outside the EU || 10 
 Provide guidance on how to targets can be achieved || 9 
 Set up a platform to enable the exchange of good practices between Member States. || 8 
 Introduce extended producer warranties (e.g. extend from 2 to 10 years) || 8 
 Assess resource use with life cycle approaches || 6 
 Ensure that local NGOs have a say in the definition of waste plans || 6 
 Make separate biowaste and/or textile collections mandatory || 6 
 European Commission funding must enforce the waste hierarchy || 6 
 Member States should do more to raise public awareness of waste related issues (e.g. recycling and waste prevention) || 4 
 Strict enforcement of the targets and Directives || 3 
 All national, regional and local waste plans must explain how they are planning to fulfil EU legislation || 2 
 Measures should be taken to prevent incineration overcapacity || 2 
 Introduce a single overarching reuse, recycling, and recovery target || 2 
 Promote the implementation of voluntary initiatives/agreements with relevant stakeholders || 2 
 Need greater focus on eco-design and extended producer responsibility to improve recycling and reduce arisings || 2 
 Apply standardised methods to assess 'decoupling' || 1 
 More measures to minimize excessive packaging || 1 
 Charge companies for the cost of disposal/recycling of their products || 1 
 Ban planned obsolescence || 1 
 Guidance must not interfere with appropriate national and local decision making processes || 1 
 Place a tax proportional to total environmental impact on products sold || 1 
 Remove any waste regulation barriers to private sector recycling || 1 
 Improve Extended Producer Responsibility schemes for C&D materials/products || 1 
 Establish fiscal control measures for extended producer responsibility schemes || 1 
 Make an EU wide requirement for free public waste recycling centres || 1 
 Tiered levels of enforcement action to lift performance of the lowest achievers more quickly || 1 
 Set technical and environmental standards for landfills || 1 
 Monitoring the reuse and recycling initiatives should be the basis for future proposals || 1 
 There should be a greater focus on Extended Producer Responsibility || 1 
 Clamp down on the export of illegal waste || 1 
 Develop a Blueprint on Waste as has been produced for water || 1 
 Promote incentive schemes to encourage innovation and behaviour change || 1 
 European Commission funding should be conditional on pre-defined objectives/criteria || 1 
 Reduce burden of waste legislation on SMEs || 1 
 Provide clarification on the application of the waste hierarchy in relation to hazardous waste || 1 
 More focus is required on end of waste criteria || 1 
 The EC should provide guidance on stimulating and incentivising a circular economy || 1 
 Introduce quality standards for recyclates || 1 
 Not a relevant response for this section/ response is an issue rather than a proposal || 66 
 Response was a comment on proposed solutions / Solution was already listed in the consultation || 32 

4.0                    
Citizen Consultation

It will be evident from the results
presented in the above sections that European citizens were given the option of
responding to the more technical consultation that was open to all
stakeholders. In addition, the Commission developed a number of standalone
questions to which citizens could respond if they did not wish to respond to
the longer consultation that was open to all stakeholders. Citizens were able
to express their views in one of three ways:
1.      
Through the shorter
citizen consultation;
2.     
Via the technical consultation that was open to
all stakeholders; or
3.      
Through both the
shorter citizen consultation and the longer technical consultation.
The results of those citizens who responded
to the technical consultation have already been presented in the sections
above. This section presents the results of the responses which were received
to the shorter citizen specific consultation. The number of responses received
for each of the above three options is presented in Table 4‑1. 
Table 4‑1: Number of Responses Received From
European Citizens  
 Question ||  Number of Responses || % Based on Number of Responses to Question 
 I would like to express my views through the shorter citizen consultation. ||  208 || 64% 
 I would like to respond to the technical consultation that is open to all stakeholders. ||  47 || 14% 
 I would like to express my views through both the shorter citizen consultation and the longer technical consultation. ||  70 || 22% 
 Total ||  325 || 100% 
The first question asked of citizens was
whether they made efforts to reduce the amount of household waste that they
produce. The responses to this question are presented in Table 4‑2. 
 Table 4‑2: Number of Citizens Who Reported Making
Efforts to Reduce the Amount of Waste that They Produce  
 Answer ||  Number of Responses to Question || % Based on Number of Responses to Question 
 Yes, make efforts to reduce waste arisings ||  269 || 97% 
 No, make no efforts to reduce waste arisings ||  9 || 3% 
 Total ||  278 || 100% 
   
Those citizens who reported that they were
making efforts to reduce the amount of waste that they produced were asked what
steps they were taking to do so from a list of predefined options (respondents
could choose one or more options). This list is reproduced in Table 4‑3 which also provides a summary
of which actions were most popular.  
Table 4‑3: Types of Actions Taken by Citizens to
Reduce Waste Arisings
 Answer ||  Number of Responses to Question || % Based on Number of Citizens Who Make Efforts to Reduce their Waste Arisings 
 I avoid food and other waste by buying exactly what I need. ||  219 || 81% 
 I avoid buying ‘over packaged’ goods. ||  184 || 68% 
 I have taken efforts to stop receiving unwanted mail. ||  159 || 59% 
 I undertake home composting. ||  120 || 45% 
 I use rechargeable batteries as far as possible. ||  176 || 65% 
 I drink tap water to avoid packaging waste. ||  188 || 70% 
 I use reusable nappies on my children. ||  19 || 7% 
 I donate/sell items for reuse. ||  197 || 73% 
 I make efforts to get broken appliances repaired before buying new ones. ||  179 || 67% 
 Other actions ||  82 || 30% 
 Total ||  1,523 || - 
Those citizens who reported that they made
no efforts to reduce the amount of waste that they produced were asked what the
main reasons were for this. Again, respondents were given the option of
choosing one or more answers from a predefined list. The list of possible
answers and the results are presented in Table 4‑4.
Table 4‑4: Reasons for Citizens Not Acting to Reduce
Waste Arisings
 Answer ||  Number of Responses to Question || % Based on Number of Citizens Who do not Make Efforts to Reduce their Waste Arisings 
 Reducing waste is not important. ||  1 || 11% 
 There is no public incentive to produce less waste. ||  3 || 33% 
 I do not know how I can reduce waste (for example, through home composting). ||  5 || 56% 
 It is the responsibility of the product producer to reduce waste, not mine. ||  2 || 22% 
 Other reasons. ||  3 || 33% 
 Total ||  14 || - 
Moving on from waste prevention to
recycling, citizens were asked if they sort their waste material out for
recycling. The number of ‘Yes’/’No’ responses received to this question are
shown in Table 4‑5.
Citizens who reported making efforts to sort materials out for recycling were
asked what encouraged them to do this. The listed closed-ended answers which
were provided and the responses to these are shown in Table 4‑6. In a similar vein, citizens
who stated that they did not sort out materials for recycling were asked why
this was the case. The responses to this question are reported in Table 4‑7.  
Table 4‑5: Number of Citizens Who Reported Making
Efforts to Sort Materials Out for Recycling  
 Answer ||  Number of Responses to Question || % Based on Number of Responses to Question 
 Yes, I currently sort my waste out for recycling ||  273 || 98% 
 No, I do not sort my waste out for recycling ||  5 || 2% 
 Total ||  278 || 100% 
Table 4‑6: Reasons for Citizens Acting to Sort Waste
Out for Recycling
 Answer ||  Number of Responses to Question || % Based on Number of Citizens Who Make Efforts to Sort Waste Out for Recycling 
 Sorting waste is compulsory in my municipality. ||  131 || 48% 
 I pay less if I sort my waste for recycling. ||  41 || 15% 
 I think recycling is good for the environment. ||  259 || 95% 
 I need to sort my waste so that my refuse bin does not become too full. ||  54 || 20% 
 It is something that the public authorities recommend I do. ||  72 || 26% 
 All my neighbours are sorting their waste. ||  33 || 12% 
 Other reasons. ||  42 || 15% 
 Total ||  632 || - 
Table 4‑7: Reasons for Citizens Not Acting to
Sort Waste Out for Recycling
 Answer ||  Number of Responses to Question || % Based on Number of Citizens Who do not sort Waste out for Recycling 
 There is no separate collection service available in the area where I live. ||  3 || 60% 
 The recycling collection service is not convenient (e.g. I have to travel too far to reach the nearest facilities). ||  1 || 20% 
 There is not enough space in the recycling containers. ||  1 || 20% 
 The waste that is sorted for recycling is not collected often enough. ||  1 || 20% 
 It takes too much time to sort my waste. ||  3 || 60% 
 Organic wastes are not collected regularly enough. ||  1 || 20% 
 I have no place to store the sorted waste. ||  2 || 40% 
 Recycling is not my responsibility and should be done by the public authorities. ||  3 || 60% 
 There is no point in recycling as all the materials are burnt or landfilled anyway. ||  2 || 40% 
 I don’t understand the sorting instructions that are required for me to separate my waste. ||  1 || 20% 
 Other reasons. ||  1 || 20% 
 Total ||  19 || - 
Citizens who reported that they made
efforts to sort out materials for recycling were asked which wastes they
regularly sorted out. A predefined list of wastes was provided and the responses
to this list are presented in Table 4‑8. 
Table 4‑8: Materials Regularly Sorted by Citizens 
 Answer ||  Number of Responses to Question || % Based on Number of Citizens Who Make Efforts to Sort Waste Out for Recycling 
 Paper ||  268 || 98% 
 Card ||  170 || 62% 
 Glass ||  258 || 95% 
 Metals ||  193 || 71% 
 Beverage cartons ||  212 || 78% 
 Aluminium ||  178 || 65% 
 Plastic bottles ||  256 || 94% 
 Other plastics ||  163 || 60% 
 Textiles (clothing) ||  162 || 59% 
 Garden waste ||  145 || 53% 
 Food waste ||  135 || 49% 
 Batteries ||  229 || 84% 
 Households hazardous waste (paint, chemicals, etc.) ||  146 || 53% 
 Electric and electronic waste equipment ||  195 || 71% 
 Other ||  31 || 11% 
 Total ||  2,741 || 100% 
Citizens were also asked if they would sort
out more wastes for recycling if the option to do so was made available to
them. The number of ‘Yes’/’No’ responses to this questions can be seen in Table 4‑9. Those citizens reported that
they would like to sort out more wastes were asked to identify which materials
they would like to see collected in a manner which was convenient to them. The
responses to this question are shown in Table 4‑10.
Table 4‑9: Number of Citizens Who Would Sort Out
More Wastes for Recycling if the Option Was Available
 Answer ||  Number of Responses to Question || % Based on Number of Responses to Question 
 Yes, I would sort out more wastes for recycling ||  240 || 88% 
 No, I would not sort out more wastes for recycling ||  33 || 12% 
 Total ||  273 || 100% 
Table 4‑10: Additional Wastes that Citizens Would
Like to Sort Out for Recycling if it were Made Convenient to do so
 Answer ||  Number of Responses to Question || % Based on Number of Citizens Who Make Efforts to Sort Waste Out for Recycling 
 Paper ||  26 || 11% 
 Card ||  40 || 17% 
 Glass ||  27 || 11% 
 Metals ||  63 || 26% 
 Beverage cartons ||  35 || 15% 
 Aluminium ||  62 || 26% 
 Plastic bottles ||  28 || 12% 
 Other plastics ||  80 || 33% 
 Textiles (clothing) ||  77 || 32% 
 Garden waste ||  59 || 25% 
 Food waste ||  91 || 38% 
 Batteries ||  44 || 18% 
 Households hazardous waste (paint, chemicals, etc.) ||  87 || 36% 
 Electric and electronic waste equipment ||  67 || 28% 
 Other ||  61 || 25% 
 Total ||  847 || - 
It is recognised that municipal waste
management represents a cost for the public authorities. Citizens were
therefore asked to select one of five options to demonstrate how they felt that
these costs should be covered. The five options and the number of responses
received for each are summarised in Table 4‑11. 
Table 4‑11: How Should the Cost of Municipal Waste
Collections be Covered?
 Answer ||  Number of Responses to Question || % Based on Number of Responses to Question 
 General taxes paid by all citizens.  ||  19 || 7% 
 Partly by general taxes, and partly by those placing products on the markets (such as producers of electronic goods, companies whose products are sold in packaging, etc.). ||  37 || 13% 
 Partly by general taxes, and partly by charges linked to the amount of unsorted waste produced by the household (so that those households producing less waste, or making greater efforts to recycle, are paying less than the others). ||  29 || 10% 
 By a combination of general taxes, contributions from companies selling goods whose packaging may end up as waste, and charges linked to the amount of unsorted waste produced by the household. ||  179 || 64% 
 Other. ||  14 || 5% 
 Total || 278 || 100% 
Where citizens reported on ‘other’ means
whereby the costs of municipal waste collections should be recovered, the
following was identified:[3]
Ø 
Four citizens stated that the costs of
collection should be paid by a combination of pay-as-you-throw and companies
who contribute household waste arisings;
Ø 
Three respondents the costs should be covered
entirely by pay-as-you-throw schemes; and
Ø 
Three citizens felt that the costs should be
covered entirely be the companies who sell products which contribute to
household waste arisings.  
[1] European Commission
(2011) Roadmap to a Resource Efficient Europe, COM(2011) 571 final, http://ec.europa.eu/environment/resource_efficiency/about/roadmap/index_en.htm

[2] See Communication from the Commission to
the European Parliament and the Council (2012) Decision
of the European Parliament and of the Council on a General Union Environment
Action Programme to 2020 "Living Well, Within the Limits of our
Planet", COM(2012) 710 final, http://ec.europa.eu/environment/newprg/pdf/7EAP_Proposal/en.pdf
[3] One response was unrelated to the questions, while three of the
suggestions listed under the option ‘other’ were already identified in the
consultation question.  
Annex 8: An Overview of the European
Reference Model on Waste
Contents
1.0      Introduction. 2
2.0      Model
Creation. 3
3.0      Baseline
Scenarios Included in the Model 4
4.0      Outline
of Model Components. 5
4.1.1        Mass
Flow Module. 7
4.1.2       Waste
Prevention Module. 13
4.1.3        Collections
Module. 15
4.1.4       Financial
Costs Module. 15
4.1.5       Environmental
Impacts Module. 31
4.1.6       Employment
Module. 67
4.1.7        Costs-Benefit
Analysis Results. 69
4.1.8       Distance
to Targets. 69
4.1.9       Resource
Efficiency Indicators. 69

Introduction

This Annex is intended to provide a brief
overview of the European Reference Model on Municipal Waste Management which
has been used for analysing the policy options put forward in this Impact
Assessment (IA). DG Environment at the European Commission, working with the
European Environment Agency, commissioned Eunomia and Copenhagen Resource
Institute (CRI) to develop this model which covers all 28 EU Member States. This
model has been used, firstly, to develop scenarios which aid understanding of
the gap between likely waste management performance in specific Member States
and the targets for recycling, recovery and landfill diversion under existing
legislation. In addition, it can be used to quantify the impact of different
scenarios in respect of impacts on the environment, including (but not limited
to) greenhouse gas emissions, job creation, and costs.
This short overview will briefly cover the
following:
Ø 
How the model was developed;
Ø 
The baseline waste management scenarios in
Member States;
Ø 
The core components of the model and how these
are interlinked; and
Ø 
The key assumptions that underpin the analyses in
each component.
It is important to note that a summary
Annex such as this can only provide a very high level overview of the model.
The technical documentation which accompanies the model[1] runs
into many hundreds of pages and it is therefore not possible to fully expand on
all of the assumptions that are made in the model; however, we endeavour here
to provide a summary of the key points and assumptions that are essential to
the results presented in this IA.
The model, built as a spreadsheet tool in
Microsoft Excel 2010, is populated with national waste management data for all
Member States (including Croatia). At its core sits the mass flow modelling,
where data on waste arisings, recycling, and residual waste treatment are
recorded for each Member State. The model has been designed to provide
projections for the period 2010 to 2030. The model is to be housed and
maintained by the EEA and should provide a useful resource for analysing the
impacts of European waste policy.   

1.0                     
Model Creation

As well as initiatives taken by individual
Member States to establish national projections, two particular studies have
been taken at European level to model waste generation and management:
Ø 
The first undertaken for DG Environment in the
context of an impact assessment on biowaste developed a modelling tool on
municipal solid waste (MSW) generation and management;[2] and
Ø 
The second undertaken for the European
Environment Agency supported by the European Topic Centre on Sustainable
Consumption and Production calculated waste generation and treatment
projections for each Member State, including the modelling of greenhouse gases
(GHGs).[3]
These pieces of work provided a starting
point for the development of the European Reference Model on Municipal Waste
Management. The principles and methodologies established in the previous work
have been used to develop a new model, built from scratch as a fit for purpose
tool. 
It is an important tool for national and
pan-European strategic planning. Therefore, in order to ensure that it could be
used to best effect, consultation with relevant personnel in government
departments with responsibility for waste management was seen to be essential. Furthermore,
industry consultation was also seen to be important to the model’s development,
and this was sought as a means of improving the quality of the information in
the model.
As part of the model development relevant
officials in all Member States were identified and sent a detailed
questionnaire which requested country specific information which was required
for input into the model. These questionnaires were sent out prior Member
States being visited in person to gather further information and to better
understand the missing data gaps in the questionnaires which had been returned
prior to these face-to-face meetings. Nineteen Member States were visited by
members of the project team and these visits helped to develop a much more
detailed view of Member States’ current performance and future plans with
respect to waste management.[4]  The
countries which were not visited were felt to already being doing relatively
well in terms of waste management and a substantial amount of information and
data is already publically available; thus, information on these countries was
gathered via the country questionnaire that was sent out and publically
available sources of information. 
Industry was consulted via an online
consultation which was hosted on the project’s official website.[5] This
consultation sought to obtain further information from stakeholders on the
following:
Ø 
Waste composition;
Ø 
Collection systems operated in Member States and collection costs; and
Ø 
Treatment system costs.
These sources of information were used as
sources of input data for the model which had been developed by the project
team. 

2.0                    
Baseline Scenarios
Included in the Model

Baselines have been developed within the
model based on information gathered from a series of Member State visits and interviews with relevant national waste departments, and a questionnaire led
data gathering exercise for non-visited countries. 
The first challenge of this work was to
formulate a reasonable understanding of current Member State waste management
performance (i.e. how municipal waste arises and gets managed). This is not
always straightforward, not least because the availability and quality of
information and recent data varies from Member State to Member State. Beyond the current situation, future projections are required essentially to predict how
total waste arisings, waste prevention, recycling, residual waste treatment and
disposal levels will evolve over time. 
For current performance, existing data
sources (Eurostat data, the 2013 EEA “Managing Municipal Solid Waste” reports
for each country[6] and
any further specific national waste management studies) give an indication of
the waste management practices in the Member States. The questionnaires and
Member State visits conducted as part of the model development (Section 1.0) helped
supplement and explain such information and allowed for the inclusion of finer
levels of detail in the modelling, and in certain cases have led to an
adjustment of the official statistics (such as figures reported for total
municipal waste). 
For future performance, an understanding is
needed of the policies, strategies and plans for investment in municipal waste
infrastructure. For countries where National Waste Plans (or similar) have
recently been developed, and policies have been announced or put in place to
deliver the intended objectives, then the likely progression is more certain.
For other countries where national planning is less recent, currently still in
development or simply less thorough, then future expectations must be tempered.

With this in mind, two baselines and one
steady state waste management projection are established based on the existing
data and the gathered information. These are defined as follows:
Ø 
Business As Usual Scenario: Steady State Waste
Management:
·        
This assumes that the levels of recycling and
the share of waste treatment systems remain constant after the last reported
year. This provides a base case against which to compare the more dynamic
future projection baselines (and scenarios in the further analysis).
Ø 
Baseline 1: Likely Outlook Based on Current
Information:
·        
The primary baseline presents an objective view
of likely future waste management based upon realistic expectations for the
performance of deliverable future waste management systems. For certain Member
States it is likely to be a more moderated and objective version of the second baseline
scenario. It is intended to highlight what might be the outcome if nothing
happens other than:
o   Waste prevention / preparation for re-use measures whose
implementation has already commenced take full effect;
o   Collection systems remain as they are, unless a clear programme of
roll-out of new systems is underway or committed to; and
o   Residual waste facilities for municipal waste either already built,
or in the construction phase are fully utilised. These plans will affect
assumptions about how residual waste is managed
Ø 
Baseline 2: Member State Intentions:
·        
This secondary baseline simply reflects Member
States’ stated intentions. This implies a less critical review of what is
likely to happen in future, and takes Member State intentions ‘at face value’.
Where Member State plans or intentions have not yet been published or made
available, it was necessary to project conservatively. 
The policy options reviewed in this IA are
against an assumed baseline of full implementation. This baseline assumes that
existing targets are all implemented in all Member States on time. Apart from
measures taken to improve implementation such as improved statistics, promotion
of economic instruments, improvement of the functioning of the EPR schemes, no
additional changes in the legislation are included in this scenario. 

3.0                     
Outline of Model Components

A full description of the mass flow model,
together with technical documentation on the individual modules, can be found
in the reporting documents that are being produced as part of the European
Reference Model Project. The intention here is to summarise the model in
context of the IA and explain how it was used to model the policy scenarios included
in this document. 
A schematic of the overall model is
depicted in Figure 3‑1. From this it can be seen that the main model calculations consists
of six modules, or components, these include:
Ø 
Mass Flow Module – the central core of the model
which accounts for all material flows at each level of the hierarchy and how
they are treated/managed;
Ø 
Waste Prevention Module – this standalone module
allows the impacts and implementation costs of various waste prevention
initiatives to be calculated for Each Member State;
Ø 
Collections Module – this module is used to
define how municipal waste is collected in each Member State and what the costs
and logistics of this are;
Ø 
Financial Costs Module – this module, based on
the mass flow of MSW, will calculate the costs of managing it via different
pathways (e.g. via landfill, incineration and/or recycling);
Ø 
Environmental Impacts Module – this includes the
modelling of both GHGs and local air emissions (direct and avoided emissions
are monetised so as to compare directly with the financial costs); and
Ø 
Employment Module – this module is used to
quantify the impacts that proposed policy changes will have on employment. 
The outputs of the model are summarised in
two separate modules and include the following:
Ø 
Summary of Cost-Benefit Analysis results;
Ø 
Assessment of the distance to European waste
directive targets;
Ø 
Indicators relating to resource efficiency; and
Ø 
An evaluation of anticipated impacts on
employment.
Each of the modules are introduced below
with, as far as possible, important assumptions being highlighted to provide
clarity on the approach that was taken.
Figure 3‑1: Overall Model Schematic 

3.1.1                    
Mass Flow Module

A conceptual depiction of the mass flow
model is given in Figure 3‑2. The flow of waste within the excel model follows the principle of
the waste hierarchy, and individual sheets are included in the model for
recording tonnages generated and managed at each level of the hierarchy. For
instance, the first modelling sheet lays out total generated municipal waste
tonnages. The second sheet accounts for the impacts of any waste prevention
initiatives that come out of the Waste Prevention Module (Section 3.1.2). All
waste prevention impacts, assuming there are any, are then subtracted from the
total projected amount of generated waste. The remaining waste is then
collected for recycling, composting, and anaerobic digestion. All residual
waste is available for residual waste treatment, notably incineration or
mechanical and biological treatment (MBT). Note that these processes can
extract additional materials for recycling and this is factored into the
calculations for recycling rates in the model. The remaining waste (rejects
from recycling and residual treatment) and waste not subject to any treatment
goes to landfill. Each of the levels of the Mass Flow Module are briefly
introduced below.
Figure 3‑2 Overview of the Mass Flow Module 
A more detailed outline of the approach
taken to the mass flow modelling is presented in Figure 3‑3. The intention of the Mass
Flow Module is to ensure that all tonnages of waste that are generated, are
accounted for by the sum of the recovery and treatment pathways, including mass
losses where relevant.  There is also a clear distinction between mixed refuse
and segregated waste collection, which provides greater clarity concerning the
nature of the treatment of organic waste in particular. 
Clearly to operate a model with a more
intricate flow of material as depicted by Figure 3‑3, additional information is
needed. Nevertheless, these additional pieces of information are needed for a
model of this nature because:
a)     
Collection systems have related costs and
impacts;
b)    
Treatment plants (including those considered by
the current Eurostat Methodology as ‘pre-treatment’ plants) have related costs
and impacts; and
c)     
All tonnages (including uncollected waste) need
to be accounted for or the financial costs and environmental impacts will be
incomplete and consequently flawed.
Figure 3‑3: Approach Taken to Mass Flow Modelling
Note: Imports and Exports
excluded from this presentation but intended to be accounted for in the model. 

3.1.1.1                 
Waste Generation and Compositon

Waste Generation
As stated above each Member State (including Croatia) was contacted and asked to complete a questionnaire which was
designed to obtain the necessary country specific information for input into
the model. In terms of developing forward projections of MSW arisings for each Member State we used, where these were made available, projections that had been produced
by the Member States themselves. In situations where Member States had not
produced their own projections we produced independent projections based on the
2012 work by the ETC/EEA.[7] Full
details of these projections can be found as a technical Annex in the report
documents associated with the European Reference Model on Waste.[8]
Waste Composition
The model includes 51 fractions of MSW as
indicated in Table 3‑1. These fractions were
selected following detailed consideration of: 
Ø 
The available Member State compositional
datasets;
Ø 
Requirements for reporting of data on specific
materials to enable calculation of performance against the various European
waste Directives; and 
Ø 
Requirements for the model to perform distinct
functions to meet the broader purposes and objectives for this model, i.e. the
ability to model the environmental impact of the treatment of individual waste
fractions. 
Where Member States provided us with
compositional breakdowns of their municipal waste stream we inputted this into
the model based on the compositional breakdown shown in Table 3‑1. Where information on
composition could not be obtained directly from the Member State we used information obtained as part of research conducted by the ETC for the EAA in
2009.[9]
Table 3‑1 Waste Fractions Included in the Model
 Compositional Waste Fractions in the Model 
 Biowastes || Plastics (continued) 
 Food || Non-packaging rigid plastics 
 Garden || Film packaging (bags etc) 
 Other biowastes || Non-packaging films 
 Wood  || WEEE 
 Wood packaging || Large household appliances 
 Other wood || Small household appliances 
 Paper / Cardboard || IT and telecommunications equipment 
 Non-packaging paper || Consumer equipment and photovoltaic panels 
 Packaging paper || Lighting equipment 
 Cardboard || Electrical and electronic tools 
 Textiles || Toys, leisure and sports equipment 
 Clothing and footwear || Medical devices 
 Other textiles || Monitoring and control instruments 
 Glass || Automatic dispensers 
 Packaging glass || Rubble, soil 
 Non-packaging glass || Furniture 
 Metals || Batteries and accumulators 
 Mixed cans || Portable batteries 
 Steel cans || Accumulators 
 Aluminium cans || Other wastes 
 Aluminium foil || ELVs 
 Other scrap metal || Haz (exc WEEE) 
 Plastics || Fines 
 Plastic bottles || Inerts 
 Other rigid plastic packaging || Other 
By multiplying the total waste arisings for
each country by their MSW composition it is possible to come up with the
projected waste arisings by material stream. This then feeds down into the
lower tiers of the hierarchy as shown in Figure 3‑2. 

3.1.1.2                 
Waste Prevention

The Waste Prevention Module (see Section 3.1.2)
allows a number of waste prevention initiatives to be modelled over the period 2010
to 2035 (e.g. food waste reduction programmes, the promotion of reusable
nappies, and reducing unsolicited mail). The output from this module is a total
waste prevention impact (in tonnes) for the selected range of waste prevention
initiatives. This total tonnage is broken down by material and feeds directly
into the waste prevention component of the Mass Flow Module. The prevented
waste is then subtracted from the total amount of MSW generated to come up with
a final projection of MSW arisings in each Member State.   
The model recognises that not all MSW is
managed by the formal sector. The model therefore requires that the ‘collection
coverage’ be defined for each Member State. The larger the informal waste
sector in a country the lower the collection coverage was assumed to be. In all
countries with an informal sector it was assumed that the collection coverage
improves over time (the point at which 100% coverage is achieved naturally
varies from country to country). 
For material that is not collected by the
formal sector it was assumed that it goes to landfill. For all other waste –
that is, waste managed by the formal sector – the model assumes that this is
collected via official means and therefore is available for recycling,
composting, and other forms of treatment and disposal.

3.1.1.3                 
Recycling, Composing, and Anaerobic Digestion

In order to split all formally collected
MSW by the different tiers of the hierarchy the Mass Flow Module requires that
current and future trends are defined for the following: 
Ø 
Material recycling;
Ø 
Composting/anaerobic digestion;
Ø 
MBT;
Ø 
Incineration; and 
Ø 
Landfill.
These inputs are defined as proportions of
total waste arisings and are used to apportion the amount of waste that passes
through each tier of the hierarchy presented in Figure 3‑2. In order to set up the
baseline scenarios these parameters were defined for each Member State based on information that was made available through the detailed country questionnaire,
face-to-face interviews, and a search of publically available documents (see
Section 2.0 for a discussion of the baseline scenarios).
Data on current recycling and composting
rates in the different Member States was largely obtained from Eurostat.
However, in a few instances these rates were adjusted slightly after
discussions with Member State representatives who were able to provide updated
figures that had emerged since the figures had been reported to Eurostat. The
amount of material collected for recycling and/or biotreatment in the future is
determined by the projected trends in recycling rates.
The model is able to adjust the treatment
share between in-vessel composting (IVC), open air windrow (OAW) and anaerobic
digestion (AD). Different types of energy recovery from anaerobic digestion can
also be modelled.[10] 

3.1.1.4                 
Residual Waste Treatment

MBT
As stated above, the amount of MSW
requiring treatment via MBT or incineration is determined by current levels of
treatment and what is believed to be likely future trends. Mechanical
biological treatment is a residual waste treatment, where mixed waste is sent
to an integrated plant for mechanical treatment (separation, shredding) and a
biological treatment. The biological treatment typically consists of mixed
waste composting or more rapid ‘biodrying’ (for production of a fuel), and may
also include an anaerobic digestion element. The outputs from MBT plants can go
to a variety of sources:
Ø 
Recovered recyclables (e.g. metals and plastics
can get recycled) can contribute to recycling rates;
Ø 
Refuse Derived Fuels (RDF) can be sent for incineration
at EfW plants or cement kilns; and 
Ø 
Stabilised or rejected waste can be sent to
landfill. 
The proportion of material which goes to
each source can be assigned in the model based on the type of MBT facilities
that are operating in each Member State. Five variants of MBT have been defined
in the model. They include: 
Ø 
MBT 1 – Biostabilisation;
Ø 
MBT 2 – Biodrying no plastics recycling;
Ø 
MBT 3 – Biodrying with plastics recycling;
Ø 
MBT 4 – AD based; and
Ø 
MBT 5 – Basic sorting + energy generation.
Assumptions concerning the level of
recycling, RDF production, mass loss etc. are specific to the five types of MBT
included in the model. Extraction rates from residual treatments for recycling
are calculated as the ratio between output (for recycling etc.) and input for a
given material. 
Incineration
Four incineration variants have been included
in the model: 
Ø 
Incineration – Electricity only;
Ø 
Incineration – Combined Heat and Power (CHP);
Ø 
Incineration – Heat only; and
Ø 
Incineration – No energy recovery.
The proportion of residual waste going to
each type of facility is defined for each Member State. The efficiency with
which metals are recovered from incineration facilities is modelled based on a
recent literature review undertaken by Grosso et al, which suggested that 70%
of the ferrous metal could be recovered as well as 30% of the non-ferrous metal.[11] As shown in Figure 3‑2, all recovered metals are taken out of the
residual waste stream and added to the recycling stream where they count
towards the overall recycling rate reported by the model.

3.1.1.5                 
Landfill

Landfilling is the final part of the waste
management chain. This Mass Flow Module has been developed to ensure a mass
balance between the MSW generated (after waste prevention has been taken into
account) and the waste treatments outlined above. 
As discussed in Section 3.1.1.2, all
uncollected waste is assumed to go to landfill. In addition, all the rejects
from sorting facilities are assumed to be MSW sent to landfill and /or
incineration. For this reason, the amount of waste landfilled calculated in the
model may conservatively give a higher figure than amounts sent to landfill as
reported by Eurostat.

3.1.2                    
Waste Prevention Module

An overview of the Waste Prevention Module
is presented in Figure 3‑4 which illustrates the model processes. From this it can be seen
that user defined inputs, along with a number of assumptions, feed into the
Waste Prevention and Financial Calculations sheets. These results are
amalgamated in the Summary Tables. The results presented in the Summary Tables
then feed directly into the waste prevention component of the Mass Flow
Module.  
Figure 3‑4: Overview of the Waste Prevention Module
The Waste Prevention Module allows for the
waste prevention impact and financial cost of the following initiatives to be
calculated:
Ø 
Home composting;
Ø 
Say no to unsolicited mail;
Ø 
Promotion of reusable nappies;
Ø 
Door stepping campaign promoting the prevention
of food waste; 
Ø 
Media based campaign promoting the prevention of
food waste;
Ø 
Campaign to promote General Waste prevention
initiatives;
Ø 
Paint reuse at bring sites;
Ø 
Community swap days;
Ø 
Reducing the size of residual waste containers;
Ø 
No side waste policies;
Ø 
Pay as you throw; and
Ø 
'Other' initiative.
The waste prevention impact of any
initiative depends on two factors:

 The number of people/households
     participating; and 
 The amount of waste prevented by each
     participant.

Each initiative uses the above logic to
calculate the amount of waste that is likely to be prevented if it were to be
implemented. Naturally, the number of participants involved and the amount of
waste prevented will depend on a number of factors, for example, the type of
initiative, the socioeconomic demographic of the target population and the
degree to which an initiative is promoted by the authorities. As such, careful
consideration needs to be given to the inputs in this section to ensure that
they are in alignment with the amount of funding that is made available to
promote the initiative, and to ensure that the amount of waste prevented per
participating household/person is realistic for the country being modelled. 
As stated above and shown in Figure 3‑4, the waste prevention
impacts arising from the implementation of these initiatives feed through into
the Mass Flow Module. For the sake of brevity further details and assumptions
will not be outlined here, instead the reader is referred to the documentation
that accompanies the European Reference Model on Waste.

3.1.3                    
Collections Module

The Collection Cost Module provides two core functions for the
European Reference Model. In the first instance it allows current collection
systems for any country to be defined in the model, and for the associated
collection costs to be calculated. It then allows the user to consider what
changes to collection systems might be required if ambition for recycling is to
change, and what would be the associated costs of service change.
A broad categorisation of collection system
types operated within Member States can be given as follows:
Ø 
Door-to-door (D2D) collections;
Ø 
Bring sites; and
Ø 
Civic amenity (CA) sites (sometimes also
referred to as recycling centres).
The collection cost model covers all three
of these collection systems, each of which may collect a range of recyclables,
organic wastes, or mixed residual waste. A diagrammatic representation of the
Collections Module is provided in Figure 3‑5. 
Figure 3‑5: Overview of the Collections Module
The Mass Flow Module’s tonnages of mixed
and segregated MSW are used as an input to the Collections Module. This
provides the core information on levels of current and future collected
recycling. 
Currently operated Member State collection systems are defined in the model in the first instance by the consultant team
using information gathered during the consultation phase of the model
development. These systems are described in more detail in the documentation
accompanying the model. The resource requirement for the collection operations
(numbers of vehicles, containers, staff etc.) are calculated by the model.
These resource requirements generate a cost of collection for recent systems. 
Collection system costs for future years
relate to the recycling rate to be achieved in the respective year. The model
automatically moves a country from one collection system to another, depending
on the recycling rate to be achieved. The costs of the mix of collection
systems to be operated in future years are thereby calculated. This gives a
profile of collection costs for each Member State as collection systems may
evolve over time to satisfy future recycling ambitions.
The model also assumes that the values
shown in Error! Reference source not found. are derived from the sale of the core materials collected and
sorted (as necessary) for recycling. These values are indicative of those
generated over recent years. It goes without saying that these fluctuate over
time. It should also be noted that the model allows for deduction from this
value to indicate the cost of haulage (to end markets) of the different
materials. 
Table 3‑2: Material Values Assumed in the
Collections Module
 Material || Revenue (€/kg) 
 Paper || € 0.118 
 Card || € 0.106 
 Paper & Card || € 0.095 
 Textiles || € 0.296 
 Glass || € 0.024 
 Steel || € 0.166 
 Aluminium || € 0.887 
 Metals || € 0.310 
 Plastics || € 0.118 
 Other || € 0.059 

3.1.4                    
Financial Costs Module

As part of the modelling exercise we have
sought to make financial cost estimates as country-specific as possible. There
are some limits as to how much detail can be developed in this respect, but the
approach gives, we believe, a sensible compromise between the desirability of
generating country specific cost data, and the difficulties experienced in
finding country specific cost figures.
Consequently, for modelling individual
waste collection and treatment process we have tended to fall back on data for
which we have sound knowledge of the breakdown in costs, and have sought to
adapt that to the specific Member State situation through varying specific cost
factors to reflect local markets (for example labour), and with various taxes
(for example on landfill) and subsidies (for example feed-in-tariffs for
renewable energy). 
We have attempted to research and use up to
date figures for Member State specific data, but specific figures may have changed
since the time of writing.[12] The
following subsections lay out the generic approaches and assumptions used in
the financial cost modelling which are not specific to individual treatments
(for example the financial cost terminology, the cost of finance, revenues from
energy sales, labour rates in individual member states etc.). 
An overview of the module is presented in Figure 3‑6. A summary of the unit costs
of treating a tonne of waste via each of the treatment technologies listed in
this figure is presented at the end of this section in Table 3‑10. In essence, the tonnage
output from the Mass Flow Module is multiplied by the calculated unit cost of
treatment and/or disposal to come up with a final cost. Some of the assumptions
pertaining to how these unit costs are described here, with further details
being provided as part of the technical documentation that is being produced as
part of the modelling project.
Figure 3‑6: Overview of the Financial Costs Module

3.1.4.1                 
Note on Costs with Regard to Gate Fees

Where matters of cost are concerned, the
waste sector is typically used to dealing with the issue in terms of ‘gate
fees’. Gate fees are not ‘costs’, and there are various reasons why the gate
fee at a facility may differ from costs, as they might be conventionally understood.
Gate fees may, depending upon the nature of the treatment, be affected by,
inter alia:

 Local competition (affected by, for
     example, haulage costs);
 Amount of unutilised capacity available
     at facilities;
 The desire to draw in, or limit the
     intake of, specific materials in the context of seeking a specific
     feedstock mix;
 Strategic objectives of the facility
     operator; and
 Many other factors besides.

Any one of these can influence the market
price, or gate fee, for a service offered by a waste management company. 
Another feature of the waste treatment
market is the use of long-term contracts in the municipal waste market to
procure services where the private sector is involved. The nature and length of
these contracts, and the nature and extent of the risks which the public sector
may wish to transfer to the private sector, influences the unitary payment, or
gate fee, offered under any given contract. The nature of risk transfer may
relate, for example, to technology and its reliability, or to specific outputs
which a contract seeks to deliver (e.g. energy, materials), and these may, in
turn, relate to existing policy mechanisms. 
The key point is that the nature of the
risk transfer associated with a given contract affects gate fees. In the
municipal waste sector, contract prices may typically be wrapped up in the form
of a single payment, which may be composed of a number of different elements
associated with the delivery of the contract against the specified outputs.
This ‘unitary payment’ is typically determined on a contractual basis, and so
is somewhat different to gate fees which might be realised at facilities
operating in a more openly competitive market. In the approach used in this
study, issues of risk transfer are not considered.
It should also be noted that whilst some of
the major items of infrastructure for treating municipal waste have been
financed using project finance, it remains possible that corporate finance
could be used to support projects, or that public funding could be available to
fund projects. This would have the effect of changing the cost of capital used
to support any given project. 
Generally, therefore, the costs we have developed
will be different to ‘gate fees’ or payments which may be experienced in a
given contractual agreement, or spot market transaction, though they will
approximate to them in competitive markets which are not characterised by
over-supply of capacity of one or other type. 
It should also be recognised that different treatments a re more and less sensitive to variables which underpin the analysis of costs.
For example, changes in the cost of capital affect the unit (per tonne) cost of  more capital intense treatments in a more significant way than is the case for those processes with lower unit capital costs (such as waste collection). Similarly, assumptions concerning landfill taxes, and levels of support for renewable energy outputs will affect different treatments in different ways. Value added taxes, on the other
hand, are not typically charged on waste equipment and operations, and do not
therefore appear in the model.

3.1.4.2                
Accounting Principles and the Cost Metrics
Included in the Model

The model is intended both as a tool to
indicate the financial implications within the waste industry of changes in
waste management, as well as calculating the net costs and benefits including
(as far as possible) environmental impacts. For the former, the model
calculates costs under a ‘private metric’ (reflecting the costs as
discussed in Section 3.1.4.1 above). For the latter, a ‘social metric’
is used. Additionally, a ‘hybrid’ between the two metrics is included to
indicate the level of actual economic activity in the waste sector. The three
metrics can be defined as follows:
Ø 
The ‘Private Metric’ is intended to
represent the market conditions from the perspective of those undertaking waste
operations or those developing and operating facilities. It uses retail prices,
includes taxes and subsidies, and applies a weighted average cost of capital
(WACC, typically 10-15%) to capital equipment. Taking a treatment facility as
an example, this approach essentially indicates an approximate ‘break even’ gate
fee, inclusive of taxes, at a level where the facility would cover its capital
and operating costs under typical market conditions.
Ø 
The ‘Social Metric’, on the other hand,
is appropriate for use in cost benefit analyses and impact assessments
attempting to calculate an overall cost to society. This metric uses the European Commission’s standard 4% discount rate for
inter-temporal comparisons within impact assessments.[13] Subsidies and taxation are also stripped away so as
to only value the true ‘resource cost’ of an activity. This also avoids
any double counting of environmental effects that are intended to be
internalised within environmental taxes and subsidies. Under this metric,
environmental damage costs can be added to, the financial costs so as to
determine, for instance, whether the impact of a policy is positive or negative
with respect to society.
Ø 
The ‘Hybrid Metric’ is essentially to
attempt to put a measure on the economic activity within the municipal waste
sector. To summarise the approach, it values capital investments in the same
way as the private metric, but excludes all taxes and subsidies. 
The net present value of any future
investments or contextual changes in the waste sector uses the Commission
standard 4% discount rate (the social rate of time
preference), no matter which approach is considered.
All costs are
calculated and displayed in real terms at 2012 prices in the model, using the EU average GDP deflator for historic years (as shown in Table 3‑3) or the European Central Bank
price stability target for future years (“below but close to 2% over the
medium term”)[14].
Table 3‑3: Historic and Future GDP Deflators Used in
the Model
 2004 || 2005 || 2006 || 2007 || 2008 || 2009 || 2010 || 2011 || 2012 || Future years 
 2.7% || 1.9% || 2.3% || 2.9% || 0.4% || -1.6% || 2.4% || 0.8% || 3.1% || 2% 
Source: Eurostat mid year (Q3)
seasonally adjusted price index (percentage change compared to corresponding
period of previous year, based on 2005=100 and national currency (including
'euro fixed' series for euro area countries). Data for the European Union (27
countries) and Croatia. Gross domestic product at market prices. Eurostat
online database, GDP and main components - Price indices [namq_gdp_p] accessed
11/6/2013. 

3.1.4.3                 
Disposal Taxes

The current taxes for landfill and
incineration for each Member State are shown in Table 3‑4. These figures are compiled
from a range of sources, with data from the 2012 ETC/SCP source[15]
taking precedence, where available, over other data from more disparate and
historic sources.
Table 3‑4: Taxes on Landfill and Incineration by Member State (prices in nominal terms)
 Member State || Landfill Tax - Municipal (€/tonne) || Other waste taxes (€/tonne) 2012 prices unless otherwise indicated 
 2010 || 2011 || 2012 || 2013 || 2014 || 2015+ || Hazardous disposal* || Incineration tax || MBT residues || Incineration residues 
 Austria || € 87.00 || € 87.00 || Ban on landfilling of untreated waste from Jan 2012. Landfill via MBT only (tax applied as shown to right) || € 29.80 || € 8.00 || €29.80 ||   
 Belgium - Flanders || € 79.56 || € 79.56 || € 79.56 || € 79.56 || € 79.56 || € 79.56 ||   || € 7 (2008) ||   ||   
 Belgium - Wallonia || € 65.00 [indexed] || € 65.52 || € 67.55 || € 68.90 || € 70.28 || € 71.69 || As landfill || € 8.00 ||   || €12.50 
 Belgium - Brussels || No data, assume all exported to other two regions at their respective rates of tax ||   ||   ||   ||   
 Belgium - weighted || TBC || TBC || TBC || TBC || TBC || TBC || TBC || TBC ||   || TBC 
 Bulgaria || € 1.53 || € 1.53 || € 4.00 || € 8.00 || € 18.00 || € 18.00 ||   ||   ||   ||   
 Cyprus ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Czech Republic || € 20.00 || € 20.00 || € 20.00 || € 20.00 || € 20.00 || € 20.00 || € 68.00 (2011) ||   ||   ||   
 Denmark || € 63.00 || € 63.00 || € 63.00 || € 63.00 || € 63.00 || € 63.00 || € 21.30[16] || € 44.00 (2008)** ||   ||   
 Estonia || € 12.00 || € 12.00 || € 12.00 || € 12.00 || € 12.00 || € 12.00 || € 12.00 (2010) || € 7.00 ||   ||   
 Finland || € 30.00 || € 40.00 || € 40.00 || € 50.00 || € 50.00 || € 50.00 ||   ||   ||   ||   
 France || € 20.00 || € 20.00 || € 30.00 || € 30.00 || € 30.00 || € 40.00 || € 20.00 (2010) || € 11.20[17] ||   ||   
 Germany ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Greece ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Hungary ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Ireland || € 30.00 || € 50.00 || € 65.00 || € 75.00 || € 75.00 || € 75.00 ||   ||   ||   ||   
 Italy || € 30.00 || € 30.00 || € 30.00 || € 30.00 || € 30.00 || € 30.00 || € 5.16 – € 25.82 ||   ||   ||   
 Latvia || € 4.27 || € 7.11 || € 9.96 || € 9.96 || € 9.96 || € 9.96 || € 21.34 ||   ||   ||   
 Lithuania || € 22.00 || € 22.00 || € 22.00 || € 22.00 || € 22.00 || € 22.00 ||   ||   ||   ||   
 Luxembourg ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Malta ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Netherlands ||   Previously €107.00 but abolished in January 2012 ||   ||   ||   ||   
 Poland || € 26.60 || € 26.60 || € 26.60 || € 26.60 || € 26.60 || € 26.60 ||   ||   ||   ||   
 Portugal || € 4.00 || € 4.00 || € 4.00 || € 4.00 || € 4.00 || € 4.00 || € 6.00 (2011) || € 1.07 (2011) ||   ||   
 Romania ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Slovakia ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Slovenia || € 11.00 || € 11.00 || € 11.00 || € 11.00 || € 11.00 || € 11.00 || € 22.00 (2010) ||   ||   ||   
 Spain - Catalan only || € 10.00 || € 12.00 || € 12.00 || € 12.00 || € 12.00 || € 12.00 ||   || € 5.50 (2011) ||   ||   
 Spain  - remainder ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
 Spain - weighted || TBC || TBC || TBC || TBC || TBC || TBC ||   || TBC ||   ||   
 Sweden || € 47.00 || € 47.00 || € 47.00 || € 47.00 || € 47.00 || € 47.00 || € 47.00 ||   ||   || €47.00 
 United Kingdom || € 57.60 || € 67.20 || € 76.80 || € 86.40 || € 96.00 || € 96.00 ||   ||   || As landfill || €3.13 
 Croatia ||   ||   ||   ||   ||   ||   ||   ||   ||   ||   
Notes: 

 *Hazardous
     disposal tax applied in the modelling to incineration air pollution
     control residues. 
 **Source:
     Fischer (2008) The use of landfill and incineration waste taxes in
     selected EU countries, Presentation for the European Environment Agency,
     April 2008, http://www.ea-swmc.org/download/CBPII/Landfill%20and%20%20incineration%20taxes170408.pdf   
 In Italy,
     prior treatment by Incineration and MBT leads to a discount in landfill
     tax, but this is not specified and varies in value so has not been
     included in the modelling. For hazardous disposal we take an average value
     of €15.50/tonne.
 For Spain, relevant taxes on municipal waste are only known to be charged in Catalonia.[18] Within the modelling for Spain, we multiply the tax by the current relative quantity of waste originating from Catalonia by the total for Spain as a whole. A higher landfill tax rate (€21/tonne) is
     payable in Catalonia if the municipality does not operate separate
     biowaste collection. As of 2010, however, at least 692 of the 947
     municipalities of Catalonia had implemented separate biowaste collection,
     and this number continues to increase. As such, the assumption going
     forward for the financial modelling is that the lower rate applies. 
 For Belgium, rates are different in Flanders, Wallonia and the Brussels Capital Region. Once again, a
     weighting is conducted across the three regions depending on arisings from
     one to the other. We note that any waste generated within Flanders
     attracts the Flanders taxes even if shipped for treatment or disposal
     outside the region. 
 UK prices converted at €1.2 per pound.
3.1.4.4                
Revenue from Electricity Sales

Ideally it would be possible to accurately establish, for each Member State, the wholesale prices that generators would receive for the electricity they produce. However, this process is complicated due to a number of factors. The first of these is the lack of properly developed and integrated wholesale markets within the EU. Ultimately, there may be a single European energy market with a single wholesale price at any one time, but currently the market is fragmented, and in a number of cases, such as Romania and Bulgaria, prices are set by the Government regulator. Where wholesale markets do exist, and data is available, it is not clear what proportion of this price would be received by the generator, and how much might be taken by the supplier.
As a proxy, we have used, as a first step,
Eurostat’s most recent half-yearly electricity prices, without taxes, for
industrial consumers.[19] 
These values are shown in Table 3‑5. 
Table 3‑5: Prices for Electricity for Industrial Consumers in each Member State (2012)
 Member State || Revenue from Electricity Sales (€/MWh) || Member State || Revenue from Electricity Sales (€/MWh) 
 Austria || € 88.80 || Latvia || € 111.00 
 Belgium || € 96.10 || Lithuania || € 114.00 
 Bulgaria || € 76.60 || Luxembourg || € 97.00 
 Cyprus || € 226.20 || Malta || € 180.00 
 Czech Republic || € 101.70 || Netherlands || € 85.50 
 Denmark || € 85.60 || Poland || € 90.70 
 Estonia || € 68.20 || Portugal || € 99.20 
 Finland || € 67.30 || Romania || € 82.80 
 France || € 63.20 || Slovakia || € 122.70 
 Germany || € 87.80 || Slovenia || € 86.60 
 Greece || € 102.80 || Spain || € 113.80 
 Hungary || € 101.70 || Sweden || € 77.00 
 Ireland || € 136.70 || United Kingdom || € 115.60 
 Italy || € 143.80 || Croatia || € 93.30 
Source: Eurostat
In using prices for one of the larger groups of industrial users (country specific prices become increasingly sparse when looking at the largest consumers), and stripping out taxes, it is expected that the prices are a reasonable, if slightly elevated, reflection of the variations in wholesale prices between Member States. While these figures may not accurately represent the wholesale price, they have the benefit of having been gathered using a standard methodology. 
We then adjust these figures to represent an assumed differential between wholesale prices and prices for industrial consumers, and a further differential between wholesale prices and the prices that a gene rator would receive. We assume the price received by generators to be 60% of the price for large industrial consumers, giving the data in Table 3‑6.
Table 3‑6: Assumed Electricity Revenues for Generators in each Member State
 Member State || Revenue from Electricity Sales (€/MWh) || Member State || Revenue from Electricity Sales (€/MWh) 
 Austria || € 53.28 || Latvia || € 66.60 
 Belgium || € 57.66 || Lithuania || € 68.40 
 Bulgaria || € 45.96 || Luxembourg || € 58.20 
 Cyprus || € 135.72 || Malta || € 108.00 
 Czech Republic || € 61.02 || Netherlands || € 51.30 
 Denmark || € 51.36 || Poland || € 54.42 
 Estonia || € 40.92 || Portugal || € 59.52 
 Finland || € 40.38 || Romania || € 49.68 
 France || € 37.92 || Slovakia || € 73.62 
 Germany || € 52.68 || Slovenia || € 51.96 
 Greece || € 61.68 || Spain || € 68.28 
 Hungary || € 61.02 || Sweden || € 46.20 
 Ireland || € 82.02 || United Kingdom || € 69.36 
 Italy || € 86.28 || Croatia || € 55.98 
Source: 60% of data in Table 3‑5
These values represent the back stop
position for sale of electricity to the grid within the modelling, and the
revenue that may be derived under the social or hybrid accounting metrics.
Price support mechanisms are also often relevant for generation of electricity
when calculated under the private metric, and are discussed further in Section 3.1.4.5.


3.1.4.5                
Levels of Support for Renewable Electricity

For reasons outlined in the technical annex
on financial costs that accompanies the EU waste model, some caution needs to
be applied in the interpretation of data on renewable support mechanisms. Furthermore,
the very nature and level of support mechanisms in EU countries is in a considerable state of flux, and are unlikely to remain stable in future years. The
impact of the Renewable Energy Directive, setting even more ambitious targets
for the proportion of electricity to be generated by renewables is likely to
promote a revision of schemes across the EU.[20] The
values used for the modelling are shown in Table 3‑7, though the value applied in
the calculation of prices under the private metric are the greater of either
this data or the data in Table 3‑6.
Table 3‑7: Levels of Support for Renewable Elect ricity Identified for each Member State - 2012 figures
 Member State || Renewable Electricity Support – Landfill Gas (€/MWh) || Renewable Electricity Support – Incineration (€/MWh) || Renewable Electricity Support – Anaerobic Digestion (€/MWh) 
 Austria || € 5.00 || - || € 130.00 
 Belgium || € 90.00 || - || € 90.00 
 Bulgaria || € 115.00 || - || € 205.00 
 Cyprus || € 114.50 || - || € 135.00 
 Czech Republic || € 110.00 || - || € 110.00 
 Denmark || € 110.00 || - || € 110.00 
 Estonia || € 53.70 || - || € 53.70 
 Finland || € 83.50 || - || € 83.50 
 France || € 97.45 || - || € 81.21 
 Germany || € 58.90 || - || € 60.00 
 Greece || € 99.45 || - || € 200.00 
 Hungary || € 110.00 || € 119.69 || € 50.00 
 Ireland || € 81.00 || - || € 100.00 
 Italy || € 140.00 || - || € 140.00 
 Latvia || € 75.48 || - || € 75.48 
 Lithuania || € 120.00 || - || € 120.00 
 Luxembourg || € 120.00 || - || € 120.00 
 Malta || - || - || - 
 Netherlands || € 70.00 || - || € 70.00 
 Poland || € 63.58 || - || € 63.58 
 Portugal || € 102.00 || - || € 115.00 
 Romania || € 54.00 || - || € 27.00 
 Slovakia || € 93.08 || - || € 144.88 
 Slovenia || € 66.17 || - || € 129.15 
 Spain || € 88.70 || - || € 88.70 
 Sweden || € 23.20 || - || € 23.20 
 United Kingdom || € 111.04 || - || € 111.04 
 Croatia || - || - || € 159.00 
Main source: Res Legal (2013) Legal
sources on renewable energy, accessed 28/4/2013, http://www.res-legal.eu/en/search-by-country/
Additional sources:
http://www.schoenherr.eu/news-publications/legal-insights/bulgaria-the-energy-regulator-announced-the-new-feed-in-tariff-and-the-available-grid-for-renewable-energy-projects-in-bulgaria-for-2012-2013


3.1.4.6                
Levels of Support for Renewable Heat

In the absence of a well-developed market
for renewable heat, and the associated lack of up-to-date figures, we note that
caution must be exercised in the interpretation of the figures applied in
relation to renewable heat sales. The values used for the modelling are shown in Table 3‑8.
Table 3‑8: Revenue from Heat Sales in Member States
- 2012 figures
 Member State || Revenue from Heat Sales (€/MWh) || Member State || Revenue from Heat Sales (€/MWh) 
 Austria || € 62.04 || Latvia || € 36.16 
 Belgium || € 47.94 || Lithuania || € 36.16 
 Bulgaria || € 25.34 || Luxembourg || € 47.94 
 Cyprus || € 0.00 || Malta || € 0.00 
 Czech Republic || € 41.67 || Netherlands || € 47.94 
 Denmark || € 72.49 || Poland || € 32.05 
 Estonia || € 25.25 || Portugal || € 0.00 
 Finland || € 34.32 || Romania || € 24.42 
 France || € 49.31 || Slovakia || € 36.20 
 Germany || € 57.60 || Slovenia || € 37.45 
 Greece || € 0.00 || Spain || € 0.00 
 Hungary || € 38.98 || Sweden || € 56.60 
 Ireland || € 27.53 || United Kingdom || € 27.53 
 Italy || € 69.42 || Croatia || € 37.45 

3.1.4.7                 
Labour Cost Ratios Between Member States

The costs of
labour, taxes and social security and associated rates used in the modelling
are shown in Table 3‑9.
These are used to proportionally weight the labour related costs associated
with the individual technologies which are included in the model.
Table 3‑9: Labour Costs Used as Ratios Between
Member States
   || Mean Net Annual Earnings € || Tax rate (% of salary) || Social Security and other labour costs paid by employer (% of total labour costs) || Mean Gross Annual Earnings € 
 Austria || € 35,653 || 21% || 26% || € 67,359 
 Belgium || € 42,850 || 26% || 29% || € 95,117 
 Bulgaria || € 4,009 || 21% || 18% || € 6,538 
 Cyprus || € 26,552 || 0% || 12% || € 30,304 
 Czech Republic || € 11,206 || 14% || 25% || € 18,404 
 Denmark || € 54,524 || 35% || 11% || € 102,392 
 Estonia || € 10,089 || 16% || 25% || € 16,965 
 Finland || € 38,920 || 18% || 24% || € 67,150 
 France || € 31,207 || 18% || 30% || € 60,373 
 Germany || € 36,997 || 30% || 22% || € 78,152 
 Greece || € 25,398 || 16% || 0% || € 30,236 
 Hungary || € 9,403 || 24% || 28% || € 19,428 
 Ireland || € 35,321 || 6% || 23% || € 49,980 
 Italy || € 29,766 || 21% || 30% || € 60,341 
 Latvia || € 8,086 || 29% || 21% || € 16,172 
 Lithuania || € 6,935 || 17% || 27% || € 12,480 
 Luxembourg || € 51,197 || 15% || 13% || € 70,920 
 Malta || € 25,398 || 8% || 14% || € 32,903 
 Netherlands || € 42,567 || 22% || 23% || € 76,794 
 Poland || € 9,988 || 22% || 16% || € 16,230 
 Portugal || € 15,884 || 14% || 18% || € 23,390 
 Romania || € 5,415 || 26% || 21% || € 10,254 
 Slovakia || € 9,609 || 13% || 25% || € 15,461 
 Slovenia || € 20,218 || 23% || 14% || € 31,950 
 Spain || € 27,802 || 9% || 27% || € 43,441 
 Sweden || € 36,314 || 20% || 29% || € 70,240 
 United Kingdom || € 34,434 || 20% || 12% || € 50,750 
 Croatia* || € 9,403 || 18% || 16% || € 14,269 
Sources:
Tax and social security rates from Deloitte (2012) Tax Highlight 2012 Slovenia,
http://www.deloitte.com/assets/Dcom-Global/Local%20Assets/Documents/Tax/Taxation%20and%20Investment%20Guides/2012/dttl_tax_highlight_2012_Slovenia.pdf
Labour rates from Eurostat  http://epp.eurostat.ec.europa.eu/portal/page/portal/labour_market/earnings
Note: Croatia not included in this dataset so assume earnings as for Hungary
which has similar GDP per capita.  

3.1.4.8                
Summary of Country Specific Costs for Waste Treatments

Table 3‑10
presents draft country specific costs for the various waste treatments for each
  Member State under the private cost metric (i.e. including all taxes and
revenues, and using the higher costs of capital). Details on how these costs
were derived can be found in the technical appendix on financial costs which
accompanies the model.
Table 3‑10: Member State Specific Waste Treatment
Costs Summary (2012 prices)
 Total Unit Treatment Costs: Private Metric || Composting/Digestion || Incineration || MBT || Landfill 
 Open Air Composting || In-Vessel Composting || Anaerobic Digestion || Electric Only || CHP || Heat Only || Combustion Only || Bio-stabilisation || Biodrying with no Plastics Recycling || Biodrying with Plastics Recycling || AD based MBT || Residual MRF + Combustion 
 Austria || € 30 || € 50 || € 64 || € 107 || € 117 || € 30 || € 90 || € 110 || € 95 || € 91 || € 95 || € 68 || € 124 
 Belgium || € 30 || € 50 || € 80 || € 111 || € 129 || € 56 || € 96 || € 109 || € 98 || € 94 || € 98 || € 69 || € 108 
 Bulgaria || € 24 || € 43 || € 26 || € 90 || € 115 || € 61 || € 70 || € 62 || € 71 || € 68 || € 71 || € 47 || € 30 
 Croatia || € 24 || € 43 || € 40 || € 87 || € 108 || € 47 || € 73 || € 64 || € 73 || € 69 || € 73 || € 49 || € 33 
 Cyprus || € 25 || € 44 || € 51 || € 41 || € 95 || € 100 || € 73 || € 70 || € 77 || € 73 || € 77 || € 52 || € 42 
 Czech Republic || € 25 || € 44 || € 55 || € 86 || € 106 || € 43 || € 75 || € 69 || € 75 || € 71 || € 75 || € 51 || € 44 
 Denmark || € 30 || € 49 || € 76 || € 151 || € 155 || € 58 || € 131 || € 106 || € 98 || € 94 || € 98 || € 69 || € 97 
 Estonia || € 25 || € 44 || € 70 || € 97 || € 121 || € 65 || € 74 || € 72 || € 76 || € 72 || € 76 || € 51 || € 51 
 Finland || € 27 || € 47 || € 74 || € 105 || € 125 || € 59 || € 80 || € 86 || € 87 || € 83 || € 87 || € 60 || € 64 
 France || € 27 || € 46 || € 73 || € 117 || € 130 || € 49 || € 91 || € 83 || € 85 || € 81 || € 85 || € 57 || € 60 
 Germany || € 26 || € 46 || € 81 || € 100 || € 112 || € 29 || € 83 || € 78 || € 86 || € 82 || € 86 || € 57 || € 37 
 Greece || € 24 || € 43 || € 33 || € 85 || € 126 || € 101 || € 74 || € 66 || € 76 || € 72 || € 76 || € 50 || € 30 
 Hungary || € 24 || € 43 || € 67 || € 49 || € 82 || € 44 || € 72 || € 63 || € 73 || € 70 || € 73 || € 49 || € 28 
 Ireland || € 28 || € 48 || € 67 || € 78 || € 109 || € 66 || € 78 || € 97 || € 88 || € 84 || € 88 || € 62 || € 98 
 Italy || € 26 || € 45 || € 56 || € 76 || € 88 || € 8 || € 78 || € 78 || € 83 || € 80 || € 83 || € 56 || € 46 
 Latvia || € 25 || € 43 || € 63 || € 81 || € 105 || € 49 || € 74 || € 68 || € 74 || € 71 || € 74 || € 50 || € 41 
 Lithuania || € 24 || € 43 || € 50 || € 78 || € 102 || € 47 || € 71 || € 61 || € 72 || € 68 || € 72 || € 48 || € 26 
 Luxembourg || € 26 || € 45 || € 63 || € 94 || € 112 || € 40 || € 80 || € 74 || € 83 || € 80 || € 83 || € 56 || € 31 
 Malta || € 24 || € 44 || € 58 || € 59 || € 108 || € 101 || € 75 || € 66 || € 76 || € 72 || € 76 || € 51 || € 29 
 Netherlands || € 31 || € 51 || € 83 || € 101 || € 117 || € 42 || € 82 || € 120 || € 99 || € 95 || € 99 || € 71 || € 143 
 Poland || € 26 || € 44 || € 67 || € 129 || € 153 || € 96 || € 115 || € 75 || € 77 || € 73 || € 77 || € 53 || € 59 
 Portugal || € 24 || € 43 || € 54 || € 87 || € 127 || € 101 || € 75 || € 66 || € 75 || € 71 || € 75 || € 50 || € 33 
 Romania || € 24 || € 43 || € 69 || € 90 || € 116 || € 64 || € 73 || € 63 || € 72 || € 69 || € 72 || € 48 || € 33 
 Slovakia || € 26 || € 45 || € 47 || € 76 || € 101 || € 48 || € 72 || € 82 || € 79 || € 75 || € 79 || € 55 || € 78 
 Slovenia || € 25 || € 44 || € 53 || € 93 || € 114 || € 50 || € 76 || € 72 || € 78 || € 74 || € 78 || € 53 || € 44 
 Spain || € 25 || € 44 || € 66 || € 89 || € 131 || € 108 || € 82 || € 70 || € 79 || € 75 || € 79 || € 53 || € 34 
 Sweden || € 28 || € 48 || € 85 || € 117 || € 128 || € 43 || € 96 || € 95 || € 90 || € 87 || € 90 || € 63 || € 85 
 United Kingdom || € 29 || € 48 || € 65 || € 85 || € 114 || € 66 || € 78 || € 100 || € 89 || € 86 || € 89 || € 61 || € 107 

3.1.5                    
Environmental Impacts Module

This section introduces the Environmental
Impacts Module and, as far as possible, outlines some of the technical
assumptions used in the modelling of the environmental impacts of the different
waste management methods used by Member States. An overview of the Module is
presented in Figure 3‑7.
From this it can be seen that the tonnage inputs are received from the Mass
Flow Module (broken down by waste stream). The Environmental Impacts Module
considers the environmental impacts associated with the following types of
waste management: 
Ø 
Waste prevention;
Ø 
Recycling;
Ø 
The treatment of source segregated biowaste such
as food and garden waste;[21]
Ø 
Mechanical Biological Treatment (and related)
methods for managing residual waste;
Ø 
Incineration of residual waste; and
Ø 
Landfill of residual waste.
It can be seen from Figure 3‑7 that the model uses two
methods to assess the impacts of managing waste via each of the above routes:
Ø 
Climate change impacts are considered using the
life cycle assessment (LCA) approach. Results in this case consider the impact
in tonnes of CO2 equivalent;
Ø 
The combined impact of both the climate change
impacts together with those impacts associated with other emissions to air such
as NOx and PM is considered using the cost benefit approach (CBA). Pollutant
impacts are given a monetary value, such that the outcome can be considered in
€. For the climate change impacts, the CBA model builds on the analysis
undertaken for the LCA, as the two assessment methods use the same pollution
inventory.
Figure 3‑7: Overview of the Environmental Impacts
Module

3.1.5.1                 
Assessing the Impacts

In general, the modelling is based around a
cost benefit framework. This type of approach seeks to understand the
environmental consequences of different approaches to waste management in terms
of the monetised impact of the changes being made. In principle, this allows
for trade-offs to be made between the resource costs of any change, and the
environmental benefits associated with them. The approach is rooted in
‘life-cycle thinking’, in that it considers not only direct emissions, but
also, avoided emissions associated with the recycling of materials, or the
generation of energy by waste management processes. It seeks, however, to
express the impact of emitting pollutants, or avoiding their emission, in
monetary terms. 
There are some limitations regarding the
extent to which this can be undertaken. For example:
Ø 
For all pollutants other than those (like
greenhouse gases) which exert a global impact (i.e. an impact which is the same
irrespective of the location of their emission), the impact is dependent upon
the location of the emission. The location of the emission will determine the
likely exposure of key receptors, whether they be human beings or other living
organisms, or buildings (as with acidifying pollutants, for example). In such
cases, the link between the emission and the impact is highly localised. Work
in respect of understanding the link between the emission of a pollutant, and
its impact, is furthest advanced where air pollutants are concerned. For some
of these, ongoing work at the European level allows for some variation in the
damage costs depending upon the country from which the emission originates, For
others, a single value for the whole of Europe has been used;
Ø 
Whilst waste treatment processes may also lead
to emissions to soil and water, research in respect of the quantification, at
the margin, of the related impacts of this is less well advanced. As such, it
has not been possible to include these in the model. It is expected that the
impacts of these would be highly location specific, depending on the nature and
quality of the medium into which the pollutant was emitted; 
Ø 
Where the emissions have a global impact, the
issue of the location of the emission is less of an issue. However, where
climate change emissions are concerned, there are a range of values suggested
for the value of damages caused by marginal emissions of greenhouse gases into
the environment. It should be noted that the value of ETS allowances in the
market place does not reflect a measure of the damages caused by emissions of
greenhouse gases (GHGs). Rather, it represents the cost, at the margin, of
ensuring the overall level of emissions remains below the specified cap for the
sectors covered by the EU-ETS; 
Ø 
Waste management facilities also give rise to a
loss in amenity, related to dust, noise, odour, and other forms of nuisance.
These tend to be experienced by people and businesses in close proximity to a
facility (or close to transport routes linked to a facility). There is a body
of literature related to the assessment of disamenity at waste facilities, but
it remains largely focused on landfill and incineration. Whilst the model
allows for the inclusion of such values, the default approach is not to include
them given the potential for bias associated with the absence of values for
some facility types.
Ø 
Air Emissions other than the following are not
included in the analysis: CO2, CH4,
N2O, NH3, NOx, PM2.5 / PM10, SO2, VOCs,
Arsenic, Cadmium, Chromium, Nickel, 1,3 Butadiene, Benzene, PAH, Formaldehyde, and
Dioxin. These air pollutants cover all of the pollutants which are routinely
monitored at waste treatment plant, although plant will not typically measure
the emission of all of those listed above (for example, most facilities do not
regularly measure emission to air of formaldehyde). The list reflects those
pollutants for which the environmental impacts are best understood and for
which the most robust emissions measurement data is available. Although the
analysis is based on emissions harmful to human health, there is a good overlap
between the health impacts and ecological damage.
Ø 
The model does not consider the potential impact
of bioaerosol pollution, as no exposure response relationship has yet been
developed for this type of pollutant.
Ø 
No emissions to land have been included other
than in respect of incinerator fly ash residues. This almost certainly means
that the treatment of landfills is too favourable. In the case of the latter,
impacts are more likely to occur over long timescales – potentially beyond the
100 year cut off point considered as the boundary of the analysis.
Ø 
The model considers the relative impact of
compost application in comparison to the use of synthetic fertiliser, and as
such the impact of compost utilisation on nitrate pollution is considered. 
Aside from this, the model does not consider the impact of water pollution as
at present no damage cost data exists with which to consider the impact of
water pollution.
Ø 
We have not considered external costs associated
with construction of facilities. It is generally stated that these account for
a small proportion of the overall impacts. However, it is difficult to be quite
so sanguine about this when a cost-benefit perspective, incorporating non-zero
discount rates, is employed. All construction-related externalities occur early
in time (by definition). Consequently, the construction related externalities
will weigh proportionately greater in an analysis using discounting than in one
where no discounting is used. Even where such an approach is used, however, the
construction related impacts remain relatively insignificant in comparison the
emissions to air. In addition, many of the materials with the greatest embedded
environmental impacts (i.e., the metals) are likely to be recovered for
recycling when the facility is decommissioned, reducing the overall burdens.
Ø 
The effect on household time has not been
considered in this study.
Ø 
The consumption of water at facilities is also
not considered within the model.
Further details the rationale for these
omissions from the analysis can be found in the documentation that accompanies
the European Reference Model on Municipal Waste Management.
[22]
The set of data that we have used for the
assessment of the externalities associated with emissions to air is based on
modelling recently undertaken for the European Environment Agency (EEA).[23] Table 3‑11
and Table 3‑12 present
the assumptions used in the model for the pollutants affecting air quality,
reflecting the damage to human health. The EEA data also includes a monetary
cost for the climate change impacts, which are attributed a cost of €33 per
tonne of CO2 equivalent emissions. The
damage costs arising from the CO2 impacts are based on the estimated
marginal abatement cost based on the approach developed by the UK Government. 
Our model uses the EEA value for the carbon
damage cost out to 2029. After this point, we have based our assumption on the
price projections given in the latest iteration of the EU-ETS and provided to
us by DG Clima which suggest the cost of each EU Allowance unit (EUA) to be €35
in 2030 and €57 in 2035. For values after 2035 (used in the modelling of future
landfill emissions) the model allows for impacts to be calculated using a fixed
value of €57, or a declining impact based on the application of the EC’s
discount rate of 4%.
The model uses the following assumptions to
calculate the global warming potential of the main greenhouse gases:[24]
Ø 
Methane is assumed to have a GWP of 25. This
value is based on emissions of fossil methane. However, most methane emissions
in the waste sector are biogenic methane emissions. A credit is applied to
account for the differential in impact between the fossil and biogenic methane
impacts in landfill. As a consequence of the credit, the effective GWP for
biogenic methane is 22.25; and
Ø 
N2O is attributed a GWP of 298.
The above assumptions have been taken from
the fourth assessment report of the IPCC. It is understood that the yet to be
finalised fifth version of the assessment report will indicate an increase in
the GWP for methane from 25 to 28 (if climate carbon feedbacks are excluded
within the analysis) or 34 (including the impact of the climate carbon
feedbacks). As the fifth report is currently scheduled for publication in
January 2014, the project team consulted with DG Environment and DG Clima in
respect of the inclusion of the revised assumptions for the GWP in the model.
We have been advised to retain the assumptions from the fourth report, as the
second phase of the Kyoto Protocol – currently being transposed into EU
legislation – is based on the assumptions contained within this report. As
such, we understand that European climate change policy will not be updated to
reflect data from the fifth report until 2020 at the earliest.  

3.1.5.2                
System Boundaries

The environmental model covers the
following aspects of the waste management system:
Ø 
The fuel use associated with waste collection
(for residual waste, source segregated organic material and dry recyclables) as
well as impacts associated with sorting recyclables;
Ø 
Benefits associated with dry recyclables (calculated
by comparison with the impacts associated with producing material from virgin
inputs); 
Ø 
Impacts associated treating source segregated
organic material; and
Ø 
Impacts associated with
treating residual waste.

3.1.5.3                 
Dealing with Impacts over Time – the Discount
Rate

There are two ways in which the issue of
time has to be considered in the context of the existing model:

 First, the model is designed to project
     waste management out to the year 2030. Impacts will, therefore, occur at
     different points in time depending upon the year in which waste is
     consigned to one or other management method; and
 Second, some waste management processes –
     notably biological processes (landfill, composting, anaerobic digestion,
     MBT) – give rise to emissions which occur over an extended period of time
     after the waste was first received. 

In order to account for the different time
period in which impacts occur, the model applies a social discount rate of 4%
(which is the value proposed for use in Impact Assessments undertaken by the
European Commission). 
For waste treatments which lead to
emissions over an extended time horizon, such as landfill, then if the material
is landfilled in Year X, the model assigns all the impacts associated with
future emissions from the waste landfilled in Year X, discounted in the
appropriate manner, to that year. We believe this gives the most realistic view
to policy makers of the effect of changes in waste management in that it
assigns the effect to the year in which a given change takes place. 
Table 3‑11: Damage Costs Applied to the Air
Pollutants (2010 Prices) – Key Air Pollutants
 Country || NH3 || NOx || PM2.5 || PM10 || SO2 || VOCs 
 Austria || € 15,696 || € 12,383 || € 30,569 || € 19,850 || € 10,094 || € 812 
 Belgium || € 27,980 || € 8,566 || € 44,388 || € 28,823 || € 11,392 || € 1,980 
 Bulgaria || € 6,561 || € 5,929 || € 19,809 || € 12,863 || € 4,300 || -€ 132 
 Cyprus || € 17,569 || € 9,013 || € 27,591 || € 17,916 || € 7,390 || € 378 
 Czech Republic || € 1,372 || € 665 || € 13,288 || € 8,629 || € 1,441 || -€ 49 
 Denmark || € 20,340 || € 8,887 || € 21,430 || € 13,915 || € 8,693 || € 498 
 Estonia || € 8,011 || € 3,919 || € 11,231 || € 7,293 || € 4,835 || € 735 
 Finland || € 6,982 || € 1,954 || € 7,328 || € 4,759 || € 4,353 || € 214 
 France || € 4,639 || € 1,470 || € 7,333 || € 4,762 || € 3,024 || € 253 
 Germany || € 10,877 || € 10,633 || € 31,239 || € 20,285 || € 9,893 || € 1,023 
 Greece || € 21,117 || € 14,314 || € 45,861 || € 29,780 || € 12,650 || € 1,283 
 Hungary || € 5,214 || € 1,694 || € 18,724 || € 12,158 || € 3,238 || € 62 
 Ireland || € 17,195 || € 11,801 || € 30,195 || € 19,607 || € 8,389 || € 269 
 Italy || € 2,420 || € 4,109 || € 15,656 || € 10,166 || € 5,960 || € 642 
 Latvia || € 13,497 || € 8,629 || € 36,601 || € 23,767 || € 8,218 || € 643 
 Lithuania || € 5,882 || € 3,106 || € 9,961 || € 6,468 || € 4,570 || € 381 
 Luxembourg || € 5,923 || € 4,702 || € 9,978 || € 6,479 || € 5,118 || € 453 
 Malta || € 23,898 || € 12,545 || € 33,080 || € 21,480 || € 10,241 || € 1,831 
 Netherlands || € 8,077 || € 588 || € 16,271 || € 10,565 || € 2,926 || € 282 
 Poland || € 20,319 || € 7,970 || € 40,980 || € 26,610 || € 13,180 || € 1,432 
 Portugal || € 13,308 || € 6,803 || € 21,018 || € 13,648 || € 7,536 || € 581 
 Romania || € 4,806 || € 1,389 || € 24,644 || € 16,002 || € 3,682 || € 331 
 Slovakia || € 7,722 || € 9,256 || € 21,448 || € 13,927 || € 6,323 || € 162 
 Slovenia || € 18,882 || € 10,482 || € 21,163 || € 13,743 || € 8,184 || € 294 
 Spain || € 17,909 || € 10,308 || € 22,464 || € 14,587 || € 8,360 || € 517 
 Sweden || € 5,445 || € 3,440 || € 19,934 || € 12,944 || € 5,463 || € 302 
 United Kingdom || € 6,516 || € 2,370 || € 11,521 || € 7,481 || € 3,204 || € 381 
 Croatia || € 15,583 || € 5,326 || € 25,322 || € 16,443 || € 8,033 || € 1,007 
Table 3‑12: Damage Costs Applied to the Air
Pollutants (2010 Prices) – Heavy Metals
 Country || Arsenic || Cadmium || Chromium || Nickel || 1, 3 Butadiene || Benzene || PAH || Form-aldehyde || Dioxins/furans 
 Austria || € 369,000 || € 29,000 || € 39,000 || € 4,000 || € 500 || € 80 || € 1,315,000 || € 220 || € 28,000,000 
 Belgium || € 435,000 || € 50,000 || € 67,000 || € 6,700 || € 840 || € 120 || € 1,332,000 || € 360 || € 28,000,000 
 Bulgaria || € 328,000 || € 17,000 || € 22,000 || € 2,200 || € 280 || € 50 || € 1,304,000 || € 120 || € 28,000,000 
 Cyprus || € 340,000 || € 20,000 || € 27,000 || € 2,700 || € 340 || € 50 || € 1,307,000 || € 140 || € 28,000,000 
 Czech Republic || € 371,000 || € 30,000 || € 40,000 || € 4,100 || € 500 || € 80 || € 1,315,000 || € 220 || € 28,000,000 
 Denmark || € 323,000 || € 15,000 || € 20,000 || € 2,000 || € 250 || € 40 || € 1,301,000 || € 110 || € 28,000,000 
 Estonia || € 301,000 || € 8,300 || € 11,000 || € 1,100 || € 140 || € 30 || € 1,296,000 || € 60 || € 28,000,000 
 Finland || € 304,000 || € 9,100 || € 12,000 || € 1,200 || € 150 || € 30 || € 1,296,000 || € 60 || € 28,000,000 
 France || € 390,000 || € 33,000 || € 49,000 || € 4,800 || € 610 || € 90 || € 1,320,000 || € 270 || € 28,000,000 
 Germany || € 420,000 || € 45,000 || € 61,000 || € 6,100 || € 760 || € 110 || € 1,328,000 || € 330 || € 28,000,000 
 Greece || € 330,000 || € 17,000 || € 23,000 || € 2,400 || € 290 || € 50 || € 1,304,000 || € 120 || € 28,000,000 
 Hungary || € 368,000 || € 29,000 || € 39,000 || € 3,800 || € 480 || € 70 || € 1,314,000 || € 210 || € 28,000,000 
 Ireland || € 324,000 || € 15,000 || € 20,000 || € 2,000 || € 260 || € 40 || € 1,302,000 || € 110 || € 28,000,000 
 Italy || € 380,000 || € 33,000 || € 44,000 || € 4,400 || € 540 || € 80 || € 1,317,000 || € 240 || € 28,000,000 
 Latvia || € 307,000 || € 10,000 || € 13,000 || € 1,300 || € 160 || € 30 || € 1,297,000 || € 70 || € 28,000,000 
 Lithuania || € 316,000 || € 13,000 || € 17,000 || € 1,700 || € 220 || € 40 || € 1,300,000 || € 90 || € 28,000,000 
 Luxembourg || € 377,000 || € 32,000 || € 43,000 || € 4,300 || € 530 || € 80 || € 1,317,000 || € 240 || € 28,000,000 
 Malta || € 312,000 || € 12,000 || € 15,000 || € 1,500 || € 200 || € 30 || € 1,298,000 || € 80 || € 28,000,000 
 Netherlands || € 446,000 || € 53,000 || € 71,000 || € 7,200 || € 890 || € 130 || € 1,334,000 || € 390 || € 28,000,000 
 Poland || € 358,000 || € 26,000 || € 35,000 || € 3,500 || € 430 || € 70 || € 1,312,000 || € 190 || € 28,000,000 
 Portugal || € 331,000 || € 18,000 || € 24,000 || € 2,400 || € 300 || € 50 || € 1,305,000 || € 120 || € 28,000,000 
 Romania || € 339,000 || € 20,000 || € 27,000 || € 2,700 || € 330 || € 50 || € 1,306,000 || € 140 || € 28,000,000 
 Slovakia || € 366,000 || € 28,000 || € 38,000 || € 3,700 || € 470 || € 70 || € 1,313,000 || € 210 || € 28,000,000 
 Slovenia || € 371,000 || € 30,000 || € 40,000 || € 4,100 || € 500 || € 80 || € 1,315,000 || € 220 || € 28,000,000 
 Spain || € 329,000 || € 17,000 || € 23,000 || € 2,200 || € 280 || € 50 || € 1,304,000 || € 120 || € 28,000,000 
 Sweden || € 318,000 || € 13,000 || € 18,000 || € 1,800 || € 230 || € 40 || € 1,300,000 || € 90 || € 28,000,000 
 United Kingdom || € 376,000 || € 32,000 || € 42,000 || € 4,300 || € 530 || € 80 || € 1,316,000 || € 230 || € 28,000,000 
 Croatia || € 349,000 || € 23,000 || € 31,000 || € 3,100 || € 390 || € 60 || € 1,309,000 || € 160 || € 28,000,000 

3.1.5.4                
Energy Generation

Given that the scenarios appraised in this
study reflect changes to current waste management, the use of the marginal
energy source appears to be the right approach to take within the current
analysis. However, determining which is the marginal source across each Member State is not straightforward. A detailed discussion of this subject is provided in
the documentation which accompanies the model. [25]
As part of the consultation process
undertaken as part of the project Member States were asked to supply specific
data on the marginal electricity and heat generation source including
projections of this data going out to 2030. Respondents were also asked to
provide information on the generation mix for both types of energy. Responses
were received from some member states in respect of the marginal source of
electricity generation, although the majority were not able to provide any
information in respect of the marginal heat source, and few provided
information in respect of future variations in the mix. The approach taken in
the model is as follows:
Ø 
Where countries have
supplied us with assumptions on the marginal sources, this data is incorporated
into the model;
Ø 
Where only the grid mix data was supplied by MS,
this was used in the model;
Ø 
Where no information on
energy generation was supplied by the Member State we have used data on the
electricity and heat generation mix from the IEA and European Commission (see
tables below). 
Table 3‑13
presents the assumptions used for electricity impacts for each Member State in 2011 and Table 3‑14
presents the heat mix for each Member State in 2011. The emission factors (i.e.
air pollutants) associated with the generation of heat and electricity from
each of the sources identified in these tables are presented are summarised
within the documentation accompanying the model. 
Table 3‑13: Electricity Generation Mix – EU Member
States 
 Member State || Coal || Gas || Nuclear || Renewables1 || Other2 
 Austria || 7.29% || 17.88% || 0.00% || 72.00% || 2.83% 
 Belgium || 6.74% || 32.13% || 51.76% || 7.02% || 2.35% 
 Bulgaria || 48.71% || 5.17% || 31.47% || 13.79% || 0.86% 
 Croatia || 25.99% || 0.00% || 0.00% || 48.01% || 25.99% 
 Cyprus3 || 0.00% || 0.00% || 0.00% || 0.00% || 100.00% 
 Czech Rep. || 59.20% || 1.19% || 33.08% || 6.32% || 0.21% 
 Denmark4 || 91% || 5% || 0% || 24.84% || 4% 
 Estonia3 || 0% || 2% || 0% || 9% || 89% 
 Finland4 || 100% || 0% || 0% || 0% || 07% 
 France3 || 5% || 4% || 78% || 10% || 2% 
 Germany || 43.40% || 13.31% || 22.77% || 16.18% || 4.33% 
 Greece || 55.71% || 17.96% || 0.00% || 13.78% || 12.54% 
 Hungary3 || 18% || 30% || 44% || 2% || 5% 
 Ireland3 || 28% || 62% || 0% || 8% || 3% 
 Italy || 14.84% || 50.32% || 0.00% || 24.61% || 10.23% 
 Latvia4 || 0.00% || 100% || 0.00% || 0% || 0.00% 
 Lithuania || 0.00% || 60.38% || 0.00% || 28.30% || 11.32% 
 Luxembourg || 0.00% || 73.31% || 0.00% || 24.99% || 1.70% 
 Malta4 || 0.00% || 0.00% || 0.00% || 2% || 98% 
 Netherlands || 23.44% || 60.53% || 3.73% || 8.16% || 4.14% 
 Poland4 || 100% || 0% || 0% || 0% || 0% 
 Portugal4 || 0% || 100% || 0% || 0% || 0% 
 Romania || 34.16% || 12.05% || 19.14% || 33.50% || 1.16% 
 Slovak Rep. || 16.35% || 7.53% || 53.84% || 19.59% || 2.69% 
 Slovenia4 || 100% || 0% || 0% || 0% || 0% 
 Spain3 || 9% || 32% || 21% || 31% || 8% 
 Sweden4 || 0% || 100% || 0% || 0% || 0% 
 UK4 || 0% || 100% || 0% || 0% || 0% 
 Notes: Includes biofuels and biomass Includes oil and waste Fuel mix data supplied by Member State Marginal source data supplied by Member State 
Sources: IEA
Statistics (available from www.iea.org/stats/ ); European Commission Country Factsheets
(available from http://ec.europa.eu/energy/observatory/countries/doc/2012-country-factsheets.pdf )
Table 3‑14: Heat Generation Mix – EU Member States 
 Member State || Coal || Gas || Oil || Biomass || Other 
 Austria || 5% || 44% || 10% || 33% || 9% 
 Belgium || 0% || 86% || 0% || 2% || 12% 
 Bulgaria || 37% || 49% || 9% || 0% || 6% 
 Croatia || 0% || 0% || 0% || 0% || 0% 
 Cyprus || 0% || 0% || 0% || 0% || 0% 
 Czech Rep. || 68% || 23% || 2% || 2% || 4% 
 Denmark || 26% || 28% || 5% || 20% || 21% 
 Estonia1 || 0% || 42% || 26% || 31% || 0% 
 Finland || 35% || 25% || 8% || 27% || 5% 
 France || 10% || 61% || 16% || 0% || 13% 
 Germany || 32% || 49% || 2% || 3% || 14% 
 Greece || 99% || 0% || 1% || 0% || 0% 
 Hungary || 13% || 76% || 6% || 2% || 3% 
 Ireland || 0% || 0% || 0% || 0% || 0% 
 Italy || 1% || 60% || 35% || 3% || 3% 
 Latvia1 || 1% || 81% || 2% || 16% || 0% 
 Lithuania1 || 0% || 73% || 3% || 23% || 1% 
 Luxembourg || 0% || 0% || 0% || 100% || 0% 
 Malta1 || 0% || 0% || 95% || 2% || 3% 
 Netherlands || 11% || 77% || 4% || 1% || 7% 
 Poland1 || 0% || 31% || 18% || 51% || 0% 
 Portugal || 0% || 70% || 30% || 0% || 0% 
 Romania || 25% || 64% || 9% || 2% || 0% 
 Slovak Rep. || 23% || 53% || 12% || 6% || 7% 
 Slovenia1 || 57% || 31% || 2% || 10% || 0% 
 Spain || 0% || 0% || 0% || 0% || 0% 
 Sweden2 || 0% || 0% || 0% || 100% || 0% 
 UK2 || 0% || 100% || 0% || 0% || 0% 
 Notes Fuel mix data supplied by Member State Marginal source data supplied by Member State 
Sources: IEA
Statistics (available from www.iea.org/stats/ ); European Commission Country Factsheets
(available from http://ec.europa.eu/energy/observatory/countries/doc/2012-country-factsheets.pdf )
Table 3‑15 confirms
the emissions factors used to estimate the impacts of electricity generation
for the different generation sources considered within the current analysis,
whilst Table 3‑16
confirms the emissions factors used to estimate the impacts of heat generation.

Table 3‑17
presents the emissions factors used for diesel combustion. The source of the
emissions data is the ecoinvent database, which includes for the majority of fuels
a dataset considered to be representative of European facilities.
Table 3‑15: Emissions Factors for Electricity
Generation (tonnes pollutant / kWh)
   || CO2e || NH3 || NOx || PM || SO2 || VOCs 
 Gas || 0.4 || 1.4034E-10 || 2.5304E-07 || 1.275E-09 || 1.6263E-09 || 1.5578E-09 
 Coal || 0.8 || 2.6636E-10 || 7.1098E-07 || 2.428E-09 || 4.1141E-08 || 1.6624E-08 
 Nuclear || 0.001 || 1.4504E-10 || 3.8024E-09 || 6.398E-10 || 1.6195E-08 || 1.8067E-10 
 Renewables || 0.001 || 3.675E-11 || 8.6228E-09 || 1.619E-09 || 1.3942E-08 || 2.3682E-09 
Source:
ecoinvent
   || Arsenic || Cadmium || Chromium || Nickel || 1, 3 Butadiene || Benzene || PAH || Formaldehyde || Dioxins/furans 
 Gas || 2.76E-15 || 2.3269E-15 || 1.2903E-16 || 2.2382E-12 || 2.0709E-19 || 1.7024E-12 || 2.4785E-13 || 1.9003E-12 || 6.3519E-19 
 Coal || 6.735E-12 || 1.7428E-12 || 1.3353E-13 || 1.4377E-11 || 6.5556E-19 || 1.0881E-14 || 6.5846E-13 || 2.996E-11 || 1.5426E-18 
 Nuclear || 2.006E-13 || 3.1833E-13 || 8.9085E-15 || 6.4668E-12 || 1.3962E-18 || 1.6996E-11 || 2.5287E-13 || 1.0827E-11 || 4.2164E-19 
 Renewables || 3.126E-13 || 8.2309E-14 || 3.0718E-14 || 2.623E-12 || 6.548E-19 || 2.8188E-11 || 2.1087E-13 || 5.3271E-12 || 3.6474E-18 
Source:
ecoinvent
Table 3‑16: Emissions Factors for Heat Generation
(tonnes pollutant / kWh)
   || CO2e || NH3 || NOx || PM || SO2 || VOCs 
 Gas || 0.2 || 2.97E-11 || 1.37E-07 || 1.18E-09 || 9.53E-09 || 1.09E-09 
 Coal || 0.3 || 1.52E-10 || 9.13E-07 || 1.82E-07 || 2.27E-06 || 8.03E-09 
 Oil || 0.25 || 6.47E-11 || 1.23E-07 || 5.97E-09 || 2.35E-07 || 2.22E-09 
 Solid biomass || 0.001 || 8.31E-09 || 7.31E-07 || 5.61E-07 || 1.73E-08 || 5.19E-08 
Source:
ecoinvent
   || Arsenic || Cadmium || Chromium || Nickel || 1, 3 Butadiene || Benzene || PAH || Formaldehyde || Dioxins/furans 
 Gas || 1.47E-13 || 9.46E-14 || 6.94E-15 || 4.75E-12 || 6.74E-18 || 1.46E-09 || 3.65E-11 || 3.72E-10 || 1.36E-18 
 Coal || 1.14E-10 || 7.35E-12 || 1.02E-10 || 9.36E-11 || 1.21E-17 || 2.28E-09 || 5.38E-13 || 3.79E-10 || 9.08E-17 
 Oil || 1.31E-12 || 2.95E-12 || 1.95E-14 || 3.59E-11 || 2.13E-18 || 6.37E-10 || 1.95E-12 || 3.59E-11 || 9.77E-19 
 Solid biomass || 4.91E-12 || 3.47E-12 || 2.00E-13 || 3.06E-11 || 1.41E-17 || 4.38E-09 || 5.33E-11 || 6.27E-10 || 1.59E-16 
Source:
ecoinvent
Table 3‑17: Emissions Factors for Diesel Combustion
(tonne / litre)
   || CO2e || NH3 || NOx || PM || SO2 || VOCs || Arsenic || Cadmium 
 Diesel || 0.0026 || 6.83E-10 || 1.30E-06 || 5.78E-08 || 2.48E-06 || 2.34E-08 || 1.39E-11 || 3.12E-11 
   || Chromium || Nickel || 1, 3 Butadiene || Benzene || PAH || Formaldehyde || Dioxins/furans ||   
 Diesel || 2.06E-13 || 3.79E-10 || 2.25E-17 || 6.73E-09 || 2.05E-11 || 3.79E-10 || 1.03E-17 ||   

Source: ecoinvent
3.1.5.5                
Impacts of Differente Waste Mangement Options

Section 3.1.5.1 outlines the damage costs
that were used to monetise the impact of climate change and air pollution
resulting from a number of common pollutants. Simply put, the model uses these
damage costs and multiplies them by the quantity of each air pollutant that is
created or avoided by the option that is being modelled. This process is
summarised in Figure 3‑8.
Figure 3‑8:  Calculating the Damage Costs Resulting
from Emissions to Air
  
The model includes default assumptions for
the amount of air emissions that arise or are avoided from each of the waste
management options shown in Figure 3‑8. These are very briefly introduced below.
Waste Prevention
Table 3‑18
presents the data on avoided manufacturing burdens for key waste materials. The
table shows the data on avoided greenhouse gas burdens and that associated with
the main air quality impacts.[26] Biogenic CO2 emissions are also separately presented
where data is available. 
Table 3‑18: Avoided Manufacturing Burdens
 Material || Global Warming Potential, tonne CO2 eq. per tonne material (excl. biogenic CO2) || Biogenic CO2 (tonne CO2 eq. per tonne material) || Air Quality Impacts (tonne pollutant per tonne of material) 
 NH3 || NOx || PM2.5 || PM10 || SO2 || VOCs 
 Paper || 0.96 || 3.01E-03 || 2.00E-05 || 0.00379 || 3.42E-05 || 6.90E-05 || 3.90E-03 || 7.54E-05 
 Card || 1.32 || 3.25E-03 || 1.63E-05 || 0.00351 || 4.71E-05 || 1.20E-05 || 4.08E-03 || 9.46E-05 
 Plastics || 1.95 || 1.08E-06 || 3.13E-06 || 3.23E-03 || 8.25E-05 || 3.17E-05 || 4.10E-03 || 9.38E-05 
 Glass || 0.88 || 1.19E-03 || 2.09E-06 || 0.00316 || 5.72E-05 || 5.37E-05 || 0.0039 || 0.00022472 
 Ferrous metal || 1.79 || 1.76E-03 || 8.67E-06 || 0.003803 || 0.001461 || 0.003126 || 0.004 || 0.00026858 
 Non-ferrous metal || 11.46 || 2.52E-02 || 5.84E-05 || 0.0171 || 0.002025 || 0.006594 || 0.0349 || 0.0020501 
 Food waste || 3.80 || No data || 5.32E-04 || 3.49E-03 || 3.70E-05 || 7.70E-05 || 1.46E-03 || 3.87E-05 
 Textiles || 26.12 || 4.62E-02 || 0.017222 || 0.077 || 0.001379 || 0.000809 || 0.153 || 0.0016132 
 Wood || 0.41 || 0.56 || 6.00E-05 || 1.80E-03 || 4.00E-04 || 6.00E-05 || 7.40E-04 || 0.0012 
 WEEE || 5.28 || 0.01 || 1.7572E- 5 || 0.0138 || 0.001261 || 0.001258 || 0.0238 || 0.000806 
Sources: ecoinvent and Sima Pro life cycle databases; Stoessel F, Juraske R, Pfister S and
Hellweg S (2011) Life Cycle Inventory and Carbon and Water Footprint of Fruits
and Vegetables: Application to a Swiss Retailer, Environmental Science &
Technology, 46, pp3253-3262
Recycling
A summary of assumptions with regard to the
climate change impacts of recycling different materials is presented in Table 3‑19 which also contains the
sources of the information used.[27] The
climate change impacts associated with recycling are global impacts – as such,
there is no difference in the impact of one tonne of CO2 emitted
within Europe’s geographical boundaries to the same quantity emitted outside Europe. 
Table 3‑19: Impacts of Dry Recycling – Values Used
in the Model
   || GWP || Biogenic CO2 || Source 
 Card || -0.001 || -1.421 || ecoinvent 
 Newsprint || -0.231 || -0.258 || ecoinvent 
 Bottle plastics || -1.182 || 0.042 || APME (via WRATE) 
 Mixed dense plastics || -1.075 || 0.056 || APME (via WRATE) 
 Textiles || -4.459 || -0.604 || WRATE 
 Wood || -0.062 || 0.000 || Prognos 
 Glass - aggregate || -0.025 || -0.001 || WRATE 
 Glass - containers || -0.229 || 0.001 || British Glass 
 Ferrous metal || -1.631 || -0.003 || ecoinvent 
 Non-ferrous metal || -9.17 || - || EEA 
 WEEE || -1.482 || - || UN University 
Sources:
ecoinvent; WRATE; Huisman, J., et al (2008) 2008 Review of Directive 2002/96 on
Waste Electrical and Electronic Equipment – Study No.
07010401/2006/442493/ETU/G4, United Nations University, Bonn Germany, cited in
Zero Waste Scotland (2011) The Scottish Carbon Metric, report for Scottish
Government, March 2011; Prognos / IFEU / INFU (2008) Resource Savings and CO2
Reduction Potential in Waste Management in Europe and the Possible
Contribution to the CO2 Reduction Targets in 2020, October 2008
The air quality impacts of recycling are
considered under the CBA approach. Whereas a number of authors have considered
the climate change benefits of recycling, much less data is publicly available regarding
the air quality impacts of recycling.
Where damage cost data is used within the
assessment, air quality impacts vary geographically across European Member
States. This makes it possible to estimate impacts where the emissions are
known to occur in EU countries. However, both the recycling of the material,
and the location of the ‘avoided primary production’ might well be outside the
EU. There is a long history of exports of fibres to Asia, whilst the export of
plastics for recycling has also become increasingly significant. For scenario
analysis, therefore, it would ideally be known where any additional material
was going to be recycled, in what location primary production was being
avoided, and what the relevant set of damage costs would be in those countries.
In practice, these questions are difficult to answer, not least because no
damage cost data exists for countries outside of Europe. These issues add a
further layer of complexity to the consideration of the air quality impacts
associated with dry recycling, where some of both the primary and secondary
manufacture of certain materials is likely to take place outside Europe, and where material flows across Member States are also likely to occur. 
High level data on European production and the
extra-European imports and exports of the materials commonly recycled is
available through several databases as well as via publications of the European
trades associations and other publications of the European Commission.[28] The
project team also surveyed Member States for information on the proportion of
collected recyclate exported outside of Europe for re-processing, and received
relevant information in this respect from a number of countries. This data is
summarised in Table 3‑20.
The data is used to inform the decision for the inclusion or exclusion of the
air quality benefits associated with recycling. 
Where the available data suggests a significant
proportion of both the primary and secondary manufacture takes place within Europe, the air quality benefits of recycling are included within the analysis. This is
assumed to be the case for paper/card, plastics, glass and wood. Although a
significant proportion of metal reprocessing takes place within Europe, a significant proportion of the primary manufacture takes place outside it. The
latter is also true for a significant proportion of primary textiles
manufacture, and in this case a significant proportion of material collected
through “recycling” collections is actually sold for resale in countries
outside of the EU. Air quality benefits associated with recycling are therefore
excluded for these materials, as the impacts are felt to be too uncertain to be
quantified using damage cost data.
Given this methodology, the principal air
quality impacts used in the model are outlined in Table 3‑21 which provides this
information in terms of the tonnes of pollutant per tonne of recyclate. 
Table 3‑20: Treatment of Air Quality (AQ) Benefits
from Recycling in the Cost-Benefit Analysis (CBA)
   || Location of primary manufacture || Reprocessing of recyclate || Treatment of AQ benefits in the CBA 
 Paper / card || A significant proportion currently takes place within the EU || Some is exported but the majority is remanufactured within the EU || AQ benefits of recyclate included 
 Plastic || A significant proportion currently takes place within the EU || Some is exported but the majority is remanufactured within the EU || AQ benefits of recyclate included 
 Textiles || A significant proportion currently takes place outside of the EU || Recycled textiles largely treated within the EU but textiles suitable for reuse may be exported outside it || AQ benefits of recyclate excluded 
 Wood || A significant proportion takes place within the EU || Much is reused within the EU although relatively little is recycled || AQ benefits of recyclate included 
 Glass || Most takes place within the EU || Not typically exported outside the EU || AQ benefits of recyclate included 
 Ferrous metal || A significant proportion of primary steel production takes place outside of the EU || A significant proportion of steel reprocessing takes place within the EU || AQ benefits of recyclate excluded 
 Non-ferrous metal || A significant proportion of primary aluminium production takes place outside of the EU || A significant proportion of aluminium reprocessing takes place within the EU || AQ benefits of recyclate excluded 
Sources: Comext
database (see http://epp.eurostat.ec.europa.eu/newxtweb/ ) and Market Access Databases (see http://madb.europa.eu/madb/indexPubli.htm );  Ecorys / Danish Technical Institute /
Cambridge Econometrics / CES ifo / Idea Consult (2008) Study on the
Competitiveness of the European Steel Sector: Within the Framework of Sectoral
Competitiveness Studies ENTR/06/054, Final Report for DG Enterprise and
Industry, August 2008; Plastics Europe (2010) Plastics – the Facts 2010: An
Analysis of European Plastics Production, Demand and Recovery for 2009; CEPI
(2013) Key Statistics: European Pulp and Paper Industry 2012
Table 3‑21: Principal Air Quality Impacts of Dry
Recycling– Values Used in the Model
   || Tonnes of pollutant per tonne of recyclate 
 NH3 || NOx || PM2.5 || PM10 || SO2 || VOCs 
 Card || 0.0000505 || -0.00122 || -0.000385 || -0.00000646 || -0.0000065 || -0.000161 
 Newsprint || -0.00000333 || -0.00122 || -0.000128 || -0.0000073 || -0.00000735 || -0.0000443 
 HDPE (bottles) || 0.00000914 || -0.00227 || -0.000108 || 0.000000565 || 0.00000488 || -0.00351 
 PP PS (mixed dense plastic) || 0.00000577 || -0.00221 || -0.0000984 || -0.00000414 || 0.00000318 || -0.00302 
 Wood || -2.26E-07 || -5.89E-06 || -0.00000475 || 0.0000057 || 0.0000034 || -0.0000751 
 Glass aggregate || -0.00000107 || -0.000122 || -0.00000412 || -7.47E-07 || -0.00000265 || -0.0000266 
 Glass container || -0.00015 || -0.000588 || -0.0000429 || -0.00000573 || -0.0000277 || -0.0000533 
 Notes: Recycling processes also result in minor benefits in respect of heavy metal emissions, which are not shown in the table. Air quality impacts for metals and textiles are not included in the model. 

3.1.5.6                
Biowaste Treatment

Composting
The following assumptions have been made
with regard to air emissions from open-air windrow and in vessel composting
facilities. 
Greenhouse Gases
Our assumptions for biogenic CO2
generation assume the production of a relatively mature compost, such that more
of the gas is emitted during the composting phase than would be the case with a
less mature product.
There is some
debate as to whether methane is emitted in any significant quantities at well
managed compost sites. Some have suggested that where process is managed
correctly, methane emissions will be negligible as those that occur in the
middle of the composting mass will be oxidised at the surface of the composting
piles.[29]
For enclosed facilities we assume emissions
of 700 g of CH4 per tonne of waste to facility, whilst the figure
for open (windrow) processes is taken to be 50 g of CH4 per tonne.
These values reflect the lowest values seen in Amlinger et al (2008) and are
taken to be indicative of well managed composting processes.[30]
N2O emissions from composting
plant are closely linked to ammonia emissions and are therefore discussed
below.
Nitrogenous Emissions
There are two principle sources of nitrous
oxide emissions in composting processes:
Ø 
Direct emissions of the gas to air from the
composting process itself; and
Ø 
Additional emissions resulting from the use of
biofilters in enclosed processes to reduce emissions of ammonia.
For enclosed (in vessel) facilities, we
assume the use of a biofilter. This has the effect of converting some of the
ammonia to N2O, such that emissions of the latter are higher for
enclosed facilities. Ammonia emissions are therefore higher at open air
facilities, where no such abatement equipment can be used. Data in this respect
is presented in Table 3‑22. Ammonia emissions are somewhat higher for food waste as the
material typically contains more nitrogen than is the case with garden waste. 
Table 3‑22: Nitrogenous Emissions to Air from
Composting Facilities
   || Open air composting facilities (g gas per tonne of waste treated) || Enclosed (in vessel) composting facilities (g gas per tonne of waste treated) 
 N2O || 100 || 150 
 Ammonia – food waste || 540 || 27 
 Ammonia – garden waste || 339 || 17 
Emissions of ammonia can be further reduced
through the use of a scrubber prior to the biofilter. This is not included
within the model as the technology is not employed as standard throughout Europe. The approach taken in the model will therefore overestimate pollution impacts from
enclosed facilities in countries such as Germany and Austria where the use of
this type of abatement equipment is more prevalent. The use of such equipment
can result in a reduction in ammonia emissions of 80%.
VOCs
Relatively few studies make reference to
emissions of VOCs. In the UK, however, the Environment Agency did measure emissions
from sites suggesting VOC emissions in the order of 25 g per tonne of waste
treated at the facility.[31] This
figure is reduced for in-vessel facilities where it is assumed the use of
biofilters reduces the emissions by 80%. The use of biofilters is assumed to
result in zero damage cost for the remaining 20% of VOC emission (i.e. the
biofilter is assumed to remove those pollutants that result in the health
effects).
In addition to the above impacts the model
also takes into account the benefits of using compost on agricultural land as
this helps to offset the use of chemical fertilisers. Further details on this
and the assumed energy use at composting facilities can be found in the
documentation which accompanies the model.
Anaerobic Digestion
As is the case with composting processes,
direct emissions to air from AD systems result both from the treatment process
itself as well as from the use of the digestate. In addition to biogenic CO2
emissions, some fugitive methane emissions occur. Further emissions impacts
arise from the combustion of the biogas during its utilisation for energy
generation; as such emissions impacts are typically higher than is the case for
composting processes, although the energy generation also results in avoided
emissions impacts which are discussed below. Assumptions are presented in Table 3‑23.
Table 3‑23: Emissions from the AD process
   || Emissions impacts, tonnes pollutant per tonne of waste treated 
 Biogenic CO2 Food waste Garden waste ||   0.45 0.27 
 CH4 Food waste Garden waste ||   0.002 0.001 
 NH3 || 1.25E-05 
 NOx || 0.00025 
 PM || 0.00002 
 SO2 || 0.00002 
 VOCs || 0.00004 
In addition to the process emissions,
additional climate change impacts result from the use of digestate:
Ø 
Assumed to be 0.05 tonnes CO2
equivalent per tonne of feedstock where food waste is the feedstock;
Ø 
Assumed to be 0.98 tonnes CO2
equivalent per tonne of feedstock where garden waste is the feedstock.
Energy requirements for the AD process are
typically met through energy generated at the plant. Benefits from energy
generation included within the model account for the use of energy through the
AD process, taking into account the electricity and heat used by the AD
process. 
Assumptions regarding the net energy
generation for each option are outlined in Table 3‑24, which presents values for
food and garden waste. The data confirms that energy generation from garden
waste is much lower than that of food waste, as garden waste is more resistant
to the anaerobic degradation process. Avoided emissions from the energy
generation are calculated based on the data presented in Section 3.1.5.4. 
Table 3‑24: Energy Generation from AD Facilities 
   || Biogas combustion in a gas engine || Upgraded biogas (bio-methane) 
 Electricity (kWh / tonne of waste) || Heat (kWh / tonne of waste) || Gas grid1 (kWh / tonne of waste) || Vehicle fuel2 (litres vehicle fuel / tonne waste) 
 Food || 376 || 182 || 915 || 80 
 Garden || 161 || 78 || 395 || 38 
 Notes Bio-methane utilised in this way is assumed to offset an equivalent amount of natural gas.  Bio-methane utilised in this way is assumed to offset an equivalent amount of diesel combusted in a heavy goods vehicle 

3.1.5.7                 
Landfill

Data on the generation of landfill gas from
the degradation of the organic waste streams was obtained from the ETC/EEA
landfill model.[32] This
allowed for the development of country-specific emissions factors for
landfilled wastes. The ETC/EEA landfill model was developed on the basis of the
2006 IPCC guidelines.[33]
Methane emissions were calculated on the basis of a first order decay model,
provided by the IPCC and used by countries for the National Inventory Reporting
(NIR).[34]
Some of the main environmental assumptions
associated with lanfilling are presented below.
Gas Capture Assumptions under the Life
Cycle and Cost Benefit Approaches
The model assumes that 50% of the landfill
gas is captured from all sites in all Member States. 
Gas Capture Assumptions under the
Inventory Approach
The ETC/EEA model assumes a maximum
feasible recovery rate for landfill gas of 50%. This percentage is considered a
maximum technically achievable recovery rate, and it has been used as the
maximum, regardless of the values reported in the NIR and CRF.[35] For
countries with a recovery rate smaller than 50%, the model uses the countries’
reported recovery figures. Estimates of gas collection are based on 2007 data
which was reported in 2009.
Oxidation of Landfill Gas
Some of the uncaptured landfill gas will be
oxidised as it passes through the cap to the surface, the proportion being
dependent upon the nature of the cap. The model assumes that this is 10%, based
on information from the IPCC and US EPA; however, it is acknowledge that in
many cases this may overestimate fugitive emissions of methane occurring from
landfill. 
Direct Emissions to Air
Direct emissions to air will relate to gas
generation assumptions and landfill gas management. Impacts from landfilled
waste occur over a considerable time period. The approach used to consider the
effect of this time delay is outlined for each assessment method. 
Life Cycle Approach
Thee life cycle approach used in the model
considers only the climate change impacts through calculating the GWP of each
treatment method.
Landfill impacts are calculated over a 100
year period, with the total impact over this period being attributed to the
year in which the waste is deposited. Impacts are only considered for the
biogenic materials (food and garden waste, paper, textiles, wood, miscellaneous
combustibles and fines). At the end of the 100 year period, some of the
biogenic carbon remains un-emitted. The GWP results for landfill are therefore
adjusted with a credit for the un-emitted biogenic carbon, which is intended to
account for the exclusion of the biogenic CO2 impacts from the GWP
calculation. 
The size of the credit will depend on the
assumptions contained within the MS landfill models in respect of the behaviour
of the degradable organic carbon, and will also vary between different types of
organic waste. For example:
Ø 
Where food waste is landfilled in Austria, 50%
of the biogenic carbon is assumed to be stored at the end of the period of
analysis, leading to a temporary storage credit of 366 CO2 eq. per
tonne of food waste (food waste is assumed to contain 200 kg of biogenic
carbon);
Ø 
Where paper is landfilled in Spain, 192 kg of carbon is assumed to be stored out of a total of 300 kg of biogenic
carbon, leading to a temporary storage credit of 704 kg CO2
equivalent per tonne of paper.
Some biogenic carbon is converted in
landfills to methane, not CO2. Under the life cycle methodology the
impact of the methane emissions is adjusted downwards by an amount equivalent
to the GWP associated with the emissions of CO2 from the amount of
carbon in the emitted methane. This approach results a smaller credit to the
landfill emissions than that applied to account for the sequestration effects.
For example:
Ø 
For food waste landfilled in Austria with a methane emission of 33 kg the credit for the biogenic carbon emitted as
methane is 91 kg CO2 equivalent;
Ø 
 For paper landfilled in Spain with a similar methane emission of 32 kg the credit for the biogenic carbon emitted
as methane is 89 kg CO2 equivalent.
Cost Benefit Approach
Where the cost benefit methodology is used,
the model applies a discount rate for time delayed emissions such as those from
landfill. This approach includes the biogenic CO2 emissions and so
there is no need to make allowance for sequestration (long-term storage).
The cost benefit methodology considers air
quality impacts as well as the climate change impacts. Whilst landfill gas is
principally comprised of methane and carbon dioxide, approximately 1% of the
volume of the gas is made up of trace elements.  This can include up to 150
substances including halogenated organics, organo-sulphur compounds and
aromatic hydrocarbons depending on the nature of the waste.[36] 
The gases which are emitted in any one year
are assumed to be related to the quantity of methane or CO2 produced,
depending upon whether one is considering raw gas or gas once combusted – as is
shown in Table 3‑25.
Methane emissions to the atmosphere and methane emissions captured are both
used to estimate, on a proportional basis, emissions of different trace gases
in a given year using the relative composition of gas outlined in below. The
way this is done is to normalise the concentrations (by weight) so that:
Ø 
Where gas is flared (i.e., captured but not used
for energy generation), the emissions of other gases are calculated with
reference to the studies by Enviros et al and White et al. The way this is done
is by calculating the CO2 content of flared gas and calculating the
emissions of other gases through the quantities relative to CO2 as
specified in the two studies mentioned;
Ø 
A similar approach is used to calculate fugitive
emissions, but in this case, the other emissions are calculated relative to the
calculated quantity of methane emissions; and
Ø 
For gas which is emitted from the gas engine
following its utilisation for energy generation, the emissions of other gases
are calculated using the quantities estimated in other studies relative to
calculated CO2 emissions. 
Table 3‑25: Non Greenhouse Gas Emissions to Air from
Landfilling
   || Emissions mg/Nm3 landfill gas || Source 
 Fugitive Ratio to CH4 || Flaring Ratio to CO2 || Energy generation Ratio to CO2 
 Methane || 1 || 0.001818 || 0.005714 || Enviros 
 Carbon dioxide || 1.733333 || 1 || 1 || Enviros 
 Carbon monoxide || 3.03E-05 || 4.09E-04 || 4.09E-04 || White et al 
 Hydrogen sulphide || 4.66E-04 || 1.69E-08 || 1.69E-08 || White et al 
 Hydrogen chloride || 2.67E-06 || 8.64E-05 || 1.14E-05 || Enviros 
 Hydrogen fluoride || 5.33E-07 || 1.82E-05 || 1.14E-05 || Enviros 
 Chlorinated HC || 8.10E-05 || 5.10E-06 || 5.10E-06 || Enviros 
 Dioxins and furans || 0 || 3.36E-13 || 5.43E-13 || Enviros 
 Total Particulates || 0 || 3.64E-05 || 0.00002 || Enviros 
 Nitrogen oxides || 0 || 0.000455 || 0.002571 || Enviros 
 Sulphur dioxide || 0 || 0.000545 || 0.0002 || Enviros 
 Cadmium || 0 || 0 || 2.86E-07 || Enviros 
 Chromium || 7.12E-08 || 1.25E-08 || 1.25E-08 || White et al 
 Lead || 2.00E-08 || 2.49E-09 || 2.49E-09 || White et al 
 Mercury || 1.41E-08 || 2.49E-09 || 4.57E-09 || Enviros 
 Zinc || 1.68E-07 || 6.64E-11 || 6.64E-11 || White et al 
 Nickel || 0 || 0 || 3.71E-08 || Enviros 
 Arsenic || 0 || 0 || 4.57E-09 || Enviros 
 Total VOCs || 0.000333 || 7.73E-06 || 0 || Enviros 
 Non-methane VOCs || 0 || 8.64E-06 || 8.57E-05 || Enviros 
 1,1-dichloroethane || 0.000036 || 0 || 0 || Enviros 
 Chloroethane || 1.33E-05 || 0 || 0 || Enviros 
 Chloroethene || 1.47E-05 || 0 || 0 || Enviros 
 Chlorobenzene || 0.000032 || 0 || 0 || Enviros 
 Tetrachloroethene || 0.000044 || 3.64E-08 || 5.71E-07 || Enviros 
 Poly-chlorinated biphenyls || 0 || 0 || 0 || White et al 
 Benzene || 3.2E-06 || 0 || 0 || Enviros 
Source: Adapted
from White P R, Franke M and Hindle P (1995) Integrated Solid Waste Management:
A Lifecycle Inventory, Blackie Academic & Professional, Chapman and Hall;
Enviros, University of Birmingham, RPA Ltd., Open University and Thurgood M
(2004) Review of Environmental and Health Effects of Waste Management:
Municipal Solid Waste and Similar Wastes, Final Report to Defra, March 2004
There are some inconsistencies in this
approach, the principal one being that the White et al data make little
allowance for changes in the level of oxidation of methane through the cap of
the landfill site. Our model incorporates this as a variable. It is important
to appreciate here that oxidation may appear not only at the cap (and typical
estimates in the literature are 10%), but also in the leachate, so that total
oxidation of methane to carbon dioxide may be greater than is sometimes
suggested.
Landfills produce less of the pollutants
for which dose response functions are tolerably well known. No external damage
costs have therefore been developed for many of pollutants listed in Table 3‑25.
These figures include impacts associated with the use of diesel at the
facility, and a small amount of avoided emissions resulting from the generation
of electricity from landfill gas.
Energy Generation
For landfilled wastes, avoided impacts
relate solely to energy generation from captured landfill gas, as no recyclate
is recovered through the process. The amount of energy generated is directly
related to the amount of landfill gas that is generated and subsequently
captured. Assumptions used with regard to the generation of electricity from
landfill gas are presented in Table 3‑26.
Table 3‑26: Assumptions Used for Electricity
Generation from Landfill Gas
 Parameter || Value 
 Proportion of landfill gas used to generate energy || 50% 
 Gas engine efficiency || 35% 
 Calorific value of methane || 38 MJ / kg 
The proportion of methane contained within
landfill gas varies by member state, depending on the assumptions contained in
the National Inventory Reports. For most member states, it is assumed that 50%
of the carbon contained in waste forms methane, although several (the Netherlands and the Czech Republic) assume 60%, whilst Denmark assumes the same proportion is 45%.

3.1.5.8                
Incineration 

Emissions to Air
Greenhouse gas emissions occurring as a
result of the incineration of waste will be dependent upon the carbon content
of the dry material, along with the overall efficiency of energy generation
that results from the combustion of that material. As such, climate change
impacts are directly dependent on the outputs from the Mass Flow Module for
each Member State. Table 3‑27 presents the assumptions used in the model in respect of the carbon
content of waste materials. 
N2O emissions are modelled based
on previous research undertaken by Eunomia on behalf of WRAP.[37] The considerable uncertainty with respect to these emissions is
acknowledged within the EU BREF note, which provided a range of 5.5 – 66 g N2O
per tonne of waste treated by the facility.[38] We use the mid-point of these values within the current analysis. CH4
emissions are negligible from incineration facilities.
Table 3‑27: Carbon Content of Waste Materials
 Waste Category || Carbon content, % fresh matter 
 Biogenic || Fossil 
 Biowastes || 16% ||   
 Food || 13% ||   
 Garden || 18% ||   
 Other biowastes || 16% ||   
 Wood  || 32% ||   
 Wood packaging || 32% ||   
 Other wood || 32% ||   
 Paper / Cardboard || 32% ||   
 Non-packaging paper || 32% ||   
 Packaging paper || 32% ||   
 Cardboard || 31% ||   
 Textiles || 15% ||   
 Clothing and footwear || 15% || 15% 
 Other textiles || 5% || 25% 
 Glass ||   ||   
 Metals ||   ||   
 Plastics ||   || 60% 
 Plastic bottles ||   || 60% 
 Other rigid plastic packaging ||   || 60% 
 Non-packaging rigid plastics ||   || 55% 
 Film packaging (bags etc) ||   || 56% 
 Non-packaging films ||   || 56% 
 WEEE ||   || 5% 
 Large household appliances ||   || 5% 
 Small household appliances ||   || 5% 
 IT and telecommunications equipment ||   || 5% 
 Toys, leisure and sports equipment ||   || 40% 
 Other ||   ||   
 Rubble, soil ||   ||   
 Furniture || 10% || 10% 
 Batteries and accumulators ||   ||   
 Other wastes ||   ||   
 ELVs ||   ||   
 Haz (exc WEEE) ||   ||   
 Fines || 7% ||   
 Inerts ||   ||   
 Other || 9% || 8% 
When analysis of pollution impacts is
undertaken using the damage cost approach, typically the most significant
contribution to the total pollution impacts comes from the NOx pollution. The
model therefore considers emissions from incineration facilities with SNCR
installed to control the NOx, and those that use SCR. Emissions data for
incineration facilities included in the model are detailed in Table 3‑28.
Table 3‑28: Emissions from Incineration Facilities
   || Emissions to air, tonnes pollutant per tonne of material treated 
 Incineration with SNCR || Incineration with SCR 
 NH3 || 1.46E-05 || 1.46E-05 
 NOx || 0.000828 || 0.000214 
 PM2.5 || 4.87E-06 || 4.87E-07 
 PM10 || 9.74E-06 || 9.74E-07 
 SO2 || 3.9E-05 || 9.74E-06 
 VOCs || 3.9E-06 || 9.74E-07 
 Arsenic || 8.77E-09 || 8.77E-09 
 Cadmium || 9.74E-09 || 9.74E-09 
 Chromium || 5.84E-09 || 5.84E-09 
 Nickel || 7.79E-09 || 7.79E-09 
 Dioxins/furans || 1.52E-13 || 1.52E-13 
Sources: Information Centre for Environmental
Licensing (2002) Dutch Notes on BAT for the Incineration of Waste, Report for the
Ministry of Housing, Spatial Planning and the Environment, The Netherlands,
February 2002; European Commission (2006) Integrated Pollution Prevention and
Control: Reference Document on Incineration, August 2006; ExternE (1999)
Externalities of Energy, Vol 10: National Implementation, prepared by CIEMAT
for the European Commission, Belgium; Chang M B, Huang C K, Wu J J, and Chang S
H (2000) Characteristics of heavy metals on particles with different sizes from
municipal solid waste incineration, Journal of Hazardous Materials 79(3):
pp229-239
Energy Use and Generation
The model assumes the incinerator uses 82
kWh of electricity per tonne of waste and 3 litres of diesel in line with
values seen in several literature sources as well as recent permit applications
for proposed incineration plant in the UK.[39]
As is the case with the climate change
emissions from the incineration process, the energy content of the residual
waste treated by the plant is directly linked to the composition of the
feedstock. Table 3‑29
presents assumptions used in the model in respect of the calorific values of
waste materials. The data presented is the net calorific value as received by
the plant.
The model separately considers the
performance of four types of incineration plant:
Ø 
Facilities generating only electricity;
Ø 
Plant generating electricity and exporting heat
for use outside the plant;
Ø 
Facilities exporting only heat;
Ø 
Incineration plant combusting waste without
utilising the energy that is generated through the combustion process.
The model has been set up so that different
assumptions regarding generation efficiencies for each of the four types of
plant can be made for each Member State; in addition, there is scope for these
efficiencies to vary annually from 2011 to 2030 where such data is available
for individual Member States.
Table 3‑29: Calorific Values of Waste Materials
 Waste Material || Calorific value, MJ / kg fm (as received) 
 Biowastes || 6 
 Food || 5 
 Garden || 8 
 Other biowastes || 6 
 Wood  || 15 
 Paper / Cardboard || 12 
 Non-packaging paper || 12 
 Packaging paper || 12 
 Cardboard || 12 
 Textiles || 13 
 Clothing and footwear || 13 
 Other textiles || 13 
 Glass ||   
 Metals ||   
 Mixed cans ||   
 Steel cans ||   
 Aluminium cans ||   
 Aluminium foil || 2 
 Other scrap metal ||   
 Plastics || 34 
 Plastic bottles || 34 
 Other rigid plastic packaging || 34 
 Non-packaging rigid plastics || 30 
 Film packaging (bags etc) || 32 
 Non-packaging films || 32 
 WEEE || 3 
 Large household appliances || 3 
 Small household appliances || 3 
 IT and telecommunications equipment || 3 
 Toys, leisure and sports equipment || 25 
 Other ||   
 Rubble, soil ||   
 Furniture || 10 
 Batteries and accumulators ||   
 Other wastes ||   
 End of life vehicles ||   
 Hazardous waste ||   
 Fines || 3 
 Inert ||   
 Other || 14 
Sources: Phyllis
Database for Biomass and Waste, available from http://www.ecn.nl/phyllis/; Beker D and Cornelissen A A J (1999)
Chemische Analyse Van Huishoudelijk Restafval: Resultaten 1994 en 1995,
National Institute of Public Health and the Environment, Nederland; Davidsson A, Gruvberger C, Christensen T,
Hansen T and la Cour Jansen J  (2007) Methane Yield in Source-sorted Organic
Fraction of Municipal Waste Management, Waste Management 27  pp.406-14; Komilis
D, Evangelou A, Giannakis G, Lymperis C (2012) Revisiting the elemental
composition and the calorific value of municipal solid wastes, Waste
Management, 32(3), pp372-381 
Where no data was provided by MS on the
efficiency of incineration facilities the model uses the default assumptions
for energy generated at incineration plant presented in Table 3‑30. This data was confirmed as
being a reasonable representation of typical operating efficiencies for
European plant through consultation with the European Suppliers of Waste to
Energy Technology (ESWET) and the Confederation of European Waste to Energy
Plants (CEWEP). Some member states provided specific information as to the
efficiency of their plant; where this was the case, the data was incorporated
into the model.
Table 3‑30: Energy Generation Efficiencies for
Incineration Plant – Default Values
   || Gross electricity generation efficiency  (% exported of total energy content) || Heat utilisation (% heat used of total energy content) 
 Electricity only || 25% || - 
 CHP || 14% || 42% 
 Heat only || - || 80% 
Recycling
The efficiency with which metals are
recovered from incineration facilities is modelled based on a recent literature
review undertaken by Grosso et al, which suggested that 70% of the ferrous
metal could be recovered as well as 30% of the non-ferrous metal.[40] The materials recovery is assumed to result in offset emissions as
described in Table 3‑19. 
The mass flow model also assumes that
bottom ash is also recovered for recycling. However, this results in only
negligible environmental benefits and as such this has not been included in the
environmental model.
Landfilled Residues
Air pollution control residues from waste
incineration facilities consist of a mix of unspent reagents and chemicals
extracted from the flue gas. They are typically treated as hazardous waste and
are usually required to be sent to hazardous waste landfills. Chlorine, sulphur,
heavy metals and dioxins are likely to be concentrated in the air pollution control
residues produced by incinerators. Ironically, the better flue gas cleaning
systems perform, the more likely it becomes that toxic materials are
concentrated in these residues. 
Several recent studies indicate that
long-term impacts of landfilling this hazardous material may be significant. In a Dutch study comparing the costs and benefits of landfill with
those of incineration, the environmental damages associated with air pollution
control residues were considered as the most important externality associated
with treatment in an incineration facility.[41] 
One life-cycle study suggests: 
‘The
evaluation of waste incineration technologies largely depends on the assessment
of heavy metal emissions from landfills and the weighting of the corresponding
impacts at different points in time. Unfortunately, common LCA methods hardly
consider spatial and temporal aspects.’[42]
Using a geochemical model to model some
pollutants, the same study concluded:
‘Landfills
might release heavy metals over very long time periods ranging from a few
thousand years in the case of Cd to more than 100,000 years in the case of Cu.
The dissolved concentrations in the leachate exceed the quality goals set by
the Swiss water protection law (GSchV) by a factor of at least 50.’
We have not included these impacts in our
model due to the limited data associated with their impacts, and the long
timescale over which such impacts might be expected to occur.

3.1.5.9                
Mechanical Biological Treatment

The following types of MBT facility have
been included in the model, reflecting the most commonly used approaches:
Ø 
The stabilisation of the degradable fraction to
reduce impacts from landfilling;
Ø 
Biodrying to produce a fuel subsequently used in
an incinerator;
Ø 
Processes that use AD to treat the biodegradable
element of residual waste; and
Ø 
Processes that only undertake the mechanical
element of the MBT process to recover recyclate from the residual waste, termed
in the model as a Residual MRF facility.
Each type of MBT has different environmental
impacts associated with it. Given the summary nature of this overview the
details will not be summarised here. Instead the reader is referred to the
technical documentation that accompanies the EU waste model. 


3.1.6                    
Employment Module

The aim of the Employment Module is to
derive figures for the rate of employment per tonne of waste managed in
different waste management operations (e.g. collection, landfilling,
incineration, etc.). A graphical overview of the Employment Module is provided
in Figure 3‑9 which shows
how it is linked to the Mass Flow Module outlined above. Employment in waste
management is given in terms of number of full time equivalent (FTE) jobs per
10,000 tonnes of waste processed (also referred to as ‘employment intensity’).
These employment intensity factors are scaled in the model by the quantity of
waste managed in different ways to derive:
Ø 
An estimate of employment in a particular waste
management projection; and
Ø 
An estimate of the net impact on employment from
one scenario compared to another. 
The OECD has previously recognised the
intrinsic difficulties in the analysis and interpretation of employment data in
the waste management industry.[43] An
issue of particular salience relates to the difficulties that arise as a result
of the industry’s heterogeneous nature. This makes direct comparisons between
studies less justifiable. Methodological inconsistencies within the literature
exacerbate this issue, and are discussed further below. In recognition of the
limitations inherent to the existing literature, a survey micro study was also
conducted into employment in waste management facilities.
As shown in Figure 3‑9 this Module takes into
account employment in relation to the following:
Ø 
Reprocessing;
Ø 
Material Recovery Facilities;
Ø 
Anaerobic Digestion;
Ø 
Windrow and In-Vessel Composting;
Ø 
Mechanical Biological Treatment:
Ø 
Landfill and incineration; and
Ø 
Waste Collection.
Figure 3‑9: Overview of the Employment Module
A summary of the research that was
conducted to substantiate the employment intensities for each of the above is
included in the documentation that accompanies the European Reference Model on
Waste. The results of this research are shown in Figure 3‑10 which identifies the
employment intensity values which were used in the model.
Figure 3‑10: Range in Employment Intensities from
Literature Review and Selected Figures for Modelling

3.1.7                     
Costs-Benefit Analysis Results

This component of the model collates the
results coming out of the Environmental Impacts Module and the Financial Costs
Module and presents the information in the form of easy to interpret charts and
graphs. 

3.1.8                    
Distance to Targets

For any model run, this component of the
model calculates the distance that each Member State is from the targets set
out in the following European waste Directives:
Ø 
Landfill Directive Article 5(2) targets;
Ø 
Waste Framework Directive Article 11(2)(a)
target;
Ø 
Packaging and Packaging Waste Directive Article
6(1) targets; and
Ø 
WEEE Directive Article 7(1) target.
The results of these analyses can be very
helpful as reference to identify if the option being modelled will allow the Member State to meet the above targets.  

3.1.9                    
Resource Efficiency Indicators

One intended purpose of the European Waste
Model was to be able to use it to track a number of ‘Resource Efficiency
Indicators’ (REIs) relating to waste and material management in the European
Union. One of the key model output therefore includes a summary of the
following seven REIs:

 Per Inhabitant MSW Generation
     The model can report on waste generated per inhabitant.
     In seeking to ensure that by 2020 waste per inhabitant is in absolute
     decline, a clear issue is that different countries currently have
     different waste generation per inhabitant, and these differences are
     likely to persist, to varying degrees, over coming years. As such, the
     intent ought to be to maintain municipal waste per inhabitant below a
     certain level. However, this approach can be complicated by the fact that
     wastes of varying scope can be included under the definition ‘municipal’. 
 Recycling Rate (dry)
     Where ‘dry’ (i.e. materials other than food waste and garden waste)
     materials are concerned, the recycling rate is a useful indicator of
     performance in respect of resource efficiency. 
 Residual Organic Waste per
     Inhabitant
     Where wet materials are concerned, the
     recycling rate is susceptible to significant influence depending upon the
     approach to collecting waste. For example, where garden wastes are
     separately collected free of charge, in suburban areas, this can increase
     recycling rates significantly, even where some of this material might not
     otherwise have needed to be collected and been managed within the home (so
     would not have arisen as waste). It is be more appropriate, therefore, to
     estimate the quantity of organic waste which is not separately collected
     for composting or anaerobic digestion. This gives an indication of how
     much uncaptured organic waste there is in the residual waste stream, and
     thus indicates the effectiveness of approaches to prevention and source
     separation.
 Residual Waste per Inhabitant
     A measure already considered in certain countries / regions, is the
     quantity of residual waste per inhabitant. The merit of this indicator is
     that it captures the extent to which waste has move into the upper tiers
     of the hierarchy, and no longer requires management as residual waste. To
     the extent that the Roadmap seeks to ensure that only non-recyclable waste
     is incinerated (or, presumably, sent to MBT, or landfilled, etc.), then
     this indicator captures both the recycling efforts and the efforts made in
     respect of waste prevention. It may also be considered also a ‘fair’
     indicator in comparing Member States. 
 Proportion of Waste Landfilled
     Although aligned with the Roadmap’s
     vision, the merits of whether this is a suitable indicator of performance
     are less clear than some of the other indicators included in the model.
     Nevertheless, since it is straightforward to calculate, it is reported
     through the model. 
 GHG Savings Relative to
     Hypothetical Maximum 
     A further interesting measure of resource efficiency is to estimate the
     GHG savings from the management of waste relative to what would be
     achieved if 100% of the dry material was recycled, 100% of the food waste
     was digested, and 100% of the garden waste was composted.[44]
     This gives an indication of how close the existing system is to the
     maximum GHG savings. In calculating this indicator, the modelled impact
     from landfilling needs to assume that all emissions associated with the
     landfilling of waste are assigned to the year in which they are deposited.
     However, in principle, this gives a useful proxy for the ‘resource
     efficiency’ of the waste management system. It may be noted that a similar
     approach has been used in respect of setting recycling rates in Scotland, where a carbon metric is used to calculate recycling rates. 
 Municipal Material Captured for Recycling
     vs Material used in the EU
     It would be of interest to consider the impact of recycling on the
     consumption of raw materials. In principle, although recycling will reduce
     the consumption of raw materials, it might not necessarily do so within
     the EU. Considerable quantities of material are exported for recycling
     either within the EU (intra-EU trade) or to non-EU countries (extra-EU
     trade). Without detailed knowledge and understanding of the flows of
     imports and exports of secondary materials, the extent to which recycling
     reduces the EU’s import dependency is not clear. 

In the absence
of this type of information, therefore, the principle, indicator which could
inform the value of improved waste management is  
“The quantity
of material captured for recycling relative to the quantity of the same
material used in the EU.”
Evidently, this
is somewhat artificial where the model does not include all waste streams. 
Where materials arise principally as industrial wastes, for example, the
proportion of overall demand which could be met by the recycled municipal
waste material is unlikely to be especially high. Nevertheless, as a
comparative indicator (i.e. to assess changes over time or between scenarios),
and to indicate the contribution to total material demand, we include the above
indicator in the model.

 

[1] Eunomia Research & Consulting and Copenhagen Resource Institute
(in development) Development of a Modelling Tool on Waste Generation and
Management, Report for the European Commission DG Environment, www.wastemodel.eu
[2] Arcadis & Eunomia (2010) Assessment of the Options to
Improve the Management of Bio-waste in the EU, Report for the European
Commission http://ec.europa.eu/environment/waste/compost/developments.htm

[3] ETC/SCP (2011) Projections of Municipal Waste Management and
Greenhouse Gases, Prepared by Bakas et al., 89 pp. Copenhagen, Denmark http://scp.eionet.europa.eu/publications/2011WP4

[4] The following Member States were visited: Bulgaria, Croatia, Cyprus, Czech Republic, Estonia, Finland, France, Greece, Hungary, Italy, Latvia, Lithuania, Malta, Poland, Portugal, Romania, Slovakia, Spain, and Sweden.
[5] European Commission (2013) Waste Management Model, www.wastemodel.eu 
[6] EEA (2013) Managing municipal solid waste - a review of
achievements in 32 European countries http://www.eea.europa.eu/publications/managing-municipal-solid-waste

[7] ETC / EEA (2012b) Revision of the MSW Generation Projection
Equations Based on Additional Data Points for 2009 and 2010, Prepared by
Andersen, F. M. et al. in 2012
[8] Eunomia Research & Consulting and Copenhagen Resource Institute
(in development) Development of a Modelling Tool on Waste Generation and
Management, Report for the European Commission DG Environment, www.wastemodel.eu 
[9] ETC/SCP (2009) Europe as a Recycling Society - Present Recycling
Levels of Municipal Waste and Construction & Demolition Waste in the EU,
Prepared by Christian Fischer and Mads Werge, Working Paper No 2/2009
[10] The following AD energy recovery schemes are included in the model:
electricity only; combined heat & power (CHP); gas to grid; and gas to
vehicle fuel.
[11] Grosso M, Biganzoli L and Rigamonti L (2011) A Quantitative
Estimate of Potential Aluminium Recovery from Incineration Bottom Ashes, Resources,
Conservation and Recycling, Vol. 55, pp. 1178-1184
[12] Prices taken as 2012 figures, accepting that financial years have
different start and end points. An approximation is taken where data comes from
countries like the UK where the financial year runs from April to end March (in
this case UK 2012/13 prices are taken in the model as 2012 prices).
[13] European Commission (2009) Impact Assessment Guidelines, 15
January 2009, SEC (2009) 92. 
[14] European Central bank Website (Accessed 11/6/2013), , Monetary
Policy > Strategy > Definition of price stability http://www.ecb.int/mopo/strategy/pricestab/html/index.en.html

[15] ETC/SCP (2012) Overview of the Use of Landfill Taxes in Europe,
prepared by Christian Fischer, Mathias Lehner and David Lindsay McKinnon of the
Copenhagen Resource Institute, April 2012 http://scp.eionet.europa.eu/publications/WP2012_1/wp/WP2012_1

[16] Rising to €63.00 in 2015
[17] Rising to €14 from 2013
[18] Ignasi Puig Ventosa (2011) Landfill and Waste Incineration
Taxes: The Spanish Case, Presentation at Brussels 25th October 2011, ec.europa.eu/environment/waste/pdf/strategy/5.%20Landfill%20and%20incineration%20taxes%20in%20Spain%20Ignasi%20Puig%20%282%29.pdf 

[19] Eurostat (2012) Energy Statistics Database (data are for 2012 S2,
industrial consumers) available at
http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=nrg_pc_205&lang=en
Accessed 12/6/12
[20] Directive 2009/28/EC. Available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:EN:PDF
[21] The model separately considers both composting and anaerobic
digestion processes.
[22] Eunomia Research & Consulting and Copenhagen Resource Institute
(in development) Development of a Modelling Tool on Waste Generation and
Management, Report for the European Commission DG Environment, www.wastemodel.eu 
[23] The methodology used is summarised in: European Environment Agency
(2011) Revealing the Costs of Air Pollution from Industrial Facilities in
Europe, EEA Technical Report No 15/2011, November 2011
[24] IPCC (2007) Synthesis Report
[25] Eunomia Research & Consulting and Copenhagen Resource Institute
(in development) Development of a Modelling Tool on Waste Generation and
Management, Report for the European Commission DG Environment, www.wastemodel.eu 
[26] In addition to the impacts shown in the table, there will also be
some avoided heavy metal burdens not shown in the table, but these typically
have a relatively minor impact in comparison to those shown in the table
[27] A literature review outlining the rationale for using these figures
has been produced as part of the modelling project.
[28] Relevant information can be found in Comext and Market Access
Databases (see http://epp.eurostat.ec.europa.eu/newxtweb/
and http://madb.europa.eu/madb/indexPubli.htm
). Other sources: Ecorys / Danish Technical Institute / Cambridge Econometrics
/ CES ifo / Idea Consult (2008) Study on the Competitiveness of the European
Steel Sector: Within the Framework of Sectoral Competitiveness Studies
ENTR/06/054, Final Report for DG Enterprise and Industry, August 2008; Plastics
Europe (2010) Plastics – the Facts 2010: An Analysis of European Plastics
Production, Demand and Recovery for 2009; CEPI (2013) Key Statistics: European
Pulp and Paper Industry 2012
[29] Dimitris P. Komilis and Robert K. Ham (2004) Life-Cycle Inventory
of Municipal Solid Waste and Yard Waste Windrow Composting in the United States, Journal of Environmental Engineering, Vol. 130, No. 11, November 1, 2004,
p.1394
[30] Amlinger F, Peyr S and Cuhls C (2008) Greenhouse Gas Emissions from
Composting and Mechanical Biological Treatment, Waste Management and Research,
26, pp47-60
[31] Environment Agency (2000) Life Cycle Inventory Development for
Waste Management Operations: Composting and Anaerobic Digestion, R&D
Project Record P1/392/4
[32] ETC/EEA (2009). Waste model developed internally by the European
Topic Centre for the EEA for internal use. Supporting Documentation for the
model: ETC/SCP (2011). Projections of Municipal Waste Management and Greenhouse
Gases. Prepared by Bakas et al., 89 pp. Copenhagen, Denmark.
[33] IPCC (2006). 2006 IPCC Guidelines for National Greenhouse Gas
Inventories Volume 5 Waste. 
[34] Excel model available from IPCC (2006). 2006 IPCC Guidelines for
National Greenhouse Gas Inventories Volume 5 Waste. 
[35] Some countries in their reporting claim that higher methane
extraction rates are attainable; however given the uncertainties associated
with modelling these impacts a more conservative approach has been taken
[36] Komex (2002) Investigation of the Composition and Emissions of
Trace Components in Landfill Gas, R&D Technical Report P1-438/TR for the
Environment Agency, Bristol
[37] Eunomia (2007) Emissions of Nitrous Oxide from Waste Treatment
Processes, Report to WRAP, July 2007
[38] European Commission (2006) Integrated Pollution Prevention and
Control: Reference Document on Incineration, August 2006
[39] Riemann I (2006) CEWEP Energy Report (Status 2001-2004): Results of
Specific Data for Energy, Efficiency Rates and Coefficients, Plant Efficiency
Factors and NCV of 97 European W-t-E Plants and Determination of the Main Energy
Results, updated July 2006; VITO (2000) Vergelijking van Verwerkingsscenario’s
voor Restfractie van HHA en Niet-specifiek Categorie II Bedrijfsafval, Final
Report
[40] Grosso M, Biganzoli L and Rigamonti L (2011) A Quantitative
Estimate of Potential Aluminium Recovery from Incineration Bottom Ashes, Resources,
Conservation and Recycling, 55, pp1178-1184
[41] Dijkgraaf E and Vollebergh H (2004) Burn or Bury? A Social Cost
Comparison of Final Waste Disposal Methods, Ecological Economics, 50: pp233-247
[42] Hellweg S (2000) Time- and Site-Dependent Life-Cycle Assessment of
Thermal Waste Treatment Processes, Dissertation submitted to the Swiss Federal
Institute of Technology
[43] OECD (1996) The Global
Environmental Goods and Services Industry, Paris, OECD.
[44] We note that 100% recycling of all materials might not be
considered possible, but this does serve to highlight the closeness to a
hypothetical maximum without entering into discussion regarding what ‘maximum
rates’ of recycling might be (noting also that views on ‘maximum rates’ seem to
be increasing over time).