COMMISSION STAFF WORKING DOCUMENT Additional analysis to complement the impact assessment SWD (2014) 208 supporting the review of EU waste management targets Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste Proposal for a Directive of the European Parliament and of the Council amending Directive 94/62/EC on packaging and packaging waste Proposal for a Directive of the European Parliament and of the Council amending Directive 1999/31/EC on the landfill of waste Proposal for a Directive of the European Parliament and of the Council amending Directives 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and accumulators and waste batteries and accumulators, and 2012/19/EC on waste electrical and electronic equipment
Date: 2015-12-02
Institutions: Directorate-General for Environment, European Commission
Subjects: electricity storage device, environmental impact, packaging product, prevention of pollution, quality of the environment, storage of waste, vehicle, waste, waste disposal, waste recycling

EUROPEAN 
COMMISSION 

Brussels, 2.12.2015  
SWD(2015) 259 final 

COMMISSION STAFF WORKING DOCUMENT 

Additional analysis to complement the impact assessment SWD (2014) 208 supporting 
the review of EU waste management targets 

Accompanying the document 

Proposal for a Directive of the European Parliament and of the Council amending 
Directive 2008/98/EC on waste 

Proposal for a Directive of the European Parliament and of the Council amending 
Directive 94/62/EC on packaging and packaging waste 

Proposal for a Directive of the European Parliament and of the Council amending 
Directive 1999/31/EC on the landfill of waste 

Proposal for a Directive of the European Parliament and of the Council amending 
Directives 2000/53/EC on end-of-life vehicles, 2006/66/EC on batteries and accumulators 
and waste batteries and accumulators, and 2012/19/EC on waste electrical and electronic
equipment 

{COM(2015) 593 final} 
{COM(2015) 594 final} 
{COM(2015) 595 final} 
{COM(2015) 596 final} 

EN 

   EN 

 
 
 
 
  
 
 
 
 
 
 
 
Table of Contents 

1. 

INTRODUCTION....................................................................................................... 2 

1.1.  Purpose of the document ................................................................................... 3 
1.2.  External expertise and consultation of interested parties .................................. 3 

2.  ADDITIONAL POLICY OPTIONS........................................................................... 5 

3.  ANALYSIS OF IMPACTS – METHODOLOGICAL ASPECTS ............................. 9 

4.  COMPARING THE OPTIONS ................................................................................ 10 

4.1.  Costs- benefits analysis ................................................................................... 11 

4.2.  Complementary qualitative assessment .......................................................... 15 

List of Annexes 

Annex 1: Effects of the model update 

Annex 2: Sensitivity Analysis  

Annex 3: Member States specific results for the new target options 

2 

 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION  

1.1. 

Purpose of the document 

The  purpose  of  this  present  document  is  to  present  additional  analytical  elements  which 
supplement the impact assessment on the waste target review presented by the Commission in 
2014 (SWD/2014/0208, further referred to as "the impact assessment").1 

the 

the  withdrawal  of 

legislative  proposal  reviewing 

Following 
targets 
(COM/2014/0397 final) and in light of the first reactions to the previous legislative proposal, 
the Commission decided to analyse the impacts of a number of additional options and variants 
with  the  aim  of  taking  better  into  account  the  different  starting  positions  of  each  Member 
States.  In  particular,  this  complementary  analysis  focuses  on  assessing  options  for  the 
application of a more differentiated approach to target-setting and on quantifying the added-
value of introducing a landfill diversion target in addition to recycling targets. 

the  waste 

This supplementary analysis is exclusively focused on assessing the potential impacts of the 
new  policy  options  and  in  all  other  respects  the  impact  assessment  remains  fully  valid  and 
should be read in conjunction with this document.  

1.2. 

External expertise and consultation of interested parties 

Additional data and information were gathered in order to prepare this supplement.  

Evidence base 

A  consortium  led  by  Eunomia  Research  &  Consulting  was  used  to  gather  the  evidence 
required  to  support  this  complementary  analysis.  The  modelling  tool  used  for  the  impact 
assessment  was  updated  before  being  used  to  analyse  the  new  policy  variants.  Unless 
otherwise specified, the results presented in this document are based on this supporting study 
and from the modelling tool. 2 A summary of the main features of the model is provided in the 
impact assessment itself (Annexes 8 -10).   

Stakeholder consultation  

In  addition  to  the  consultation  already  carried  out  in  the  impact  assessment  (see  Annexes  3 
and  4  of  the  impact  assessment),  the  following  additional  developments  were  taken  into 
consideration:   

•  Member  States  presented  their  preliminary  views  in  Council.  8  meetings  of  the  Working 
Party  on  Environment  were  organised  under  the  Italian  Presidency  between  July  and 
December  2014.  A  first  complete  technical  examination  of  the  2014  proposal  took  place 
and  a  ministerial  debate  was  held  in  October  2014.  Member  States  shared  the  overall 
objective  of  the  proposal,  acknowledging  the  need  to  take  action  by  setting  a  legal 
framework which is able to steer investments in the right direction. However, the overall 
ambition  level  was  considered  too  high  in  the  light  of  the  wide  differences  in  waste 
management performance across the Member States. Some Member States also mentioned 
that  waste  prevention  and  reuse,  which  are  at  the  top  of  the  waste  hierarchy,  were  not 
sufficiently  addressed  in  the  proposal.  Many  called  for  a  greater  focus  on  better  product 
design to promote prevention, reuse and recycling.  

1 European Commission (2014) Impact Assessment Accompanying the Document: Proposal for Reviewing the 

European Waste Management Targets, July 2014, 
http://ec.europa.eu/environment/waste/target_review.htm  

2 Eunomia Research & Consulting (2015) Support to the Waste Targets Review: Analysis of New Policy Options, 
Report for DG Environment of the European Commission 

3 

 
 
 
                                                            
•  Other  more  technical  issues  were  raised  (e.g.  definitions,  calculation  and  reporting 
methods,  how  to  incentivise  re-use,  specific  requirements  for  producer  responsibility 
schemes)  during  the  initial  examination  of  the  proposal,  which  confirmed  key  findings 
from the 2014 Fitness Check3.  In order  to develop  pragmatic solutions on such technical 
issues, the Commission organised additional technical consultations of key stakeholders in 
June 2015 and gathered additional information in September 2015 through  questionnaire 
sent  to  the  Member  States.  A  broader  stakeholder  conference  on  the  circular  economy 
attended by around 700 persons was also organised by the Commission in June 2015.4 A 
specific session on waste management was held on this occasion. 

•  The  report  issued  by  the  European  Parliament  in  July  2015  (EP/  A8-0215/2015)  calling 
notably  for  ambitious  targets  similar  to  the  first  proposal  was  also  taken  into  account  as 
well  as  the  opinion  formulated  by  the  Committee  of  the  Regions  (CDR/4083/2014)  and 
from 
the  European  Economic  and  Social  Committee  (EESC/05002/2014).  More 
specifically  the  European  Parliament  called  on  the  Commission  to  include  in  its  new 
proposal the following elements: 

- 

clear and unambiguous definitions; 

-  developing waste prevention measures; 

- 

- 

- 

- 

- 

- 

setting binding waste reduction targets for municipal, commercial and industrial waste 
to be achieved by 2025; 

clear minimum standards  for extended producer responsibility requirements to ensure 
transparency and cost effectiveness of the extended producer responsibility schemes; 

applying the ‘pay-as-you-throw-principle’ for residual waste combined with mandatory 
separate collection schemes for paper, metal, plastic and glass in order to facilitate the 
high  quality  of  recycling  materials;  introducing  mandatory  separate  collection  for 
biowaste by 2020; 

increasing  recycling/preparation  for  reuse  targets  to  at  least  70  %  of  municipal  solid 
waste  and  80  %  recycling  of  packaging  waste  by  2030,  based  on  a  solid  reporting 
method  preventing  the  reporting  of  discarded  waste  (landfilled  or  incinerated)  as 
recycled  waste,  using  the  same  harmonised  method  for  all  Member  States  with 
externally  verified  statistics;  an  obligation  for  recyclers  to  report  on  the  ‘input‘ 
quantities  of  waste  going  into  the  sorting  plant  as  well  as  on  the  ‘output‘  quantity  of 
recyclates coming out of the recycling plants; 

strictly  limiting  incineration,  with  or  without  energy  recovery,  by  2020,  to  non-
recyclable and non-biodegradable waste; 

a  binding,  gradual  reduction  of  all  landfilling,  implemented  in  coherence  with  the 
requirements for recycling, in three stages (2020, 2025 and 2030), leading to a ban on 
all  landfilling,  except  for  certain  hazardous  waste  and  residual  waste  for  which 
landfilling is the most environmentally sound option; 

- 

encourage Member States to introduce charges on landfilling and incineration. 

In  summary,  there  is  a  large  consensus  between  the  consulted  parties  on  the  need  to 
harmonize the reporting and calculation methods of recycling targets as well as to improve the 
comparability  and  reliability  of  statistics.  Minimum  requirements  for  extended  producer 
responsibility schemes are also seen by many as necessary, even though there are divergences 

3 SWD/2014/0209 final  
4 http://ec.europa.eu/environment/circular-economy/index_en.htm 

4 

 
 
 
                                                            
on  how  exactly  they  should  be  defined.  Diverging  views  have  also  been  expressed  on  the 
level of ambition of the targets.  

The results of the consultations were taken into account to improve the legislative proposal on 
some  key  technical  aspects  and  to  fine  tune  the  main  options  and  their  variants  to  be 
considered in more detail in this supplement.  

2. 

ADDITIONAL POLICY OPTIONS  

Three options were described and analysed in the original impact assessment (see page 44). 
Options  1  "Ensuring  full  implementation"  and  2  "Simplification,  improved  monitoring, 
dissemination of best practices" are not discussed in this supplementary analysis.  

As  shown  in  Figure  1  below,  additional  analysis  (in  the  form  of  two  additional  sub-options 
and  a  number  of  variants  under  each  of  them)  was  only  conducted  under  Option  3  (i.e. 
Upgrade EU targets).  

First, two new main Options (Options 3.8 and 3.9) were introduced to assess the impacts of 
alternative target-setting approaches: 

•  Under  Option  3.8  ("progression  rates"),  each  Member  State  is  set  to  achieve  the 
proposed  EU-wide  targets  by  following  a  customised  compliance  path  developed  on 
the basis of common average progression rates and taking as a point of departure their 
current performance levels.  

•  Under  Option  3.9  ("time  derogations"),  all  Member  States  are  set  to  achieve  the 
proposed  EU-wide  targets  by  the  same  deadlines,  but  a  number  of  Member  States 
would have the possibility to request a time  derogation of maximum 5 years in  case 
they prove to be unable to meet them and where they comply with certain conditions. 

Both  Options  allow  for  a  differentiated  approach  taking  into  the  Member  States'  current 
performance, but do so in two different ways and to a different extent.   

Second, for both Options 3.8 and 3.9, a number of "variants" were tested. These included a 
"moderate"  and  a  "high"  set  of  sub-options  assessing  the  impacts  of  variations  in  the  final 
recycling  rate  to  be  achieved  by  the  Member  States.  Under  the  "moderate"  variant  the  final 
recycling rates are 65% for municipal waste and 75% for packaging waste. Under the "high" 
variant the final recycling rate are 70% for municipal waste and 80% for packaging waste.  

Additional variants on the introduction of a landfill diversion target on top of recycling targets 
were  also  tested  for  each  of  the  Options.  In  order  to  better  understand  the  relationship  and 
possible  synergies/overlaps  between  recycling  targets  and  action  on  landfilling,  the  analysis 
has  thus  attempted  to  single  out  the  incremental  impacts  of  introducing  a  landfill  diversion 
target.  For  both  Options,  these  variants  were  designed  using  same  type  of  differentiation 
applied for the recycling targets. 

Finally,  it  should  be  noted  that  for  packaging  waste,  which  also  covers  industrial  and 
commercial sources, the application of a differentiated approach – whether progressive rates 
or  time  derogations  -  was  not  considered  as  a  viable  option.  This  is  because  for  packaging 
waste the differences across Member States are less pronounced (see the impact assessment, 
page 21), while the risk of creating distortions on the internal market is higher.  

To  ensure  consistency  between  the  municipal  waste  and  the  packaging  targets,  each  variant 
under Options 3.8 and 3.9 includes recycling targets for packaging waste as set out in Table 1 
below (similar to Option 3.2 in the impact assessment – see Table 7, page 52 of the impact 
assessment).   

5 

 
 
 
 
 Packaging waste 

‘Moderate’ Targets 

‘High’ Targets 

Option 3.8(a) and Option 3.9(a) 

Option 3.8(b) and Option 3.9(b) 

2020 

2025 

Overall recycling/reuse 

Plastics 
Non-ferrous metal 5 

Ferrous metal 

Glass 

Paper/Cardboard 

Wood 

55% 

40% 

65% 

65% 

65% 

80% 

45% 

65% 

55% 

75% 

75% 

75% 

85% 

60% 

2030 

75% 

Review 

85% 

85% 

85% 

85% 

75% 

2020 

2025 

60% 

45% 

70% 

70% 

70% 

85% 

50% 

70% 

60% 

80% 

80% 

80% 

90% 

65% 

2030 

80% 

Review 

90% 

90% 

90% 

90% 

80% 

Table 1: Proposed recycling targets for packaging waste – moderate and high variants 

Option 3.8 – Progression rates  

Under  this  option,  the  principle  of  differentiation  is  implemented  for  each  Member  State 
through  the  application  of  annual  average  progression  rates.  Specific  targets  for  2025,  2030 
and in some cases 2035 are calculated for each individual Member State by applying common 
average  annual  progression  rates  between  2  and  3  percentage  points  −  starting  from  a 
predefined baseline year (i.e. 2013)6 − until a pre-set target recycling rate is reached (i.e. 65% 
or 70)7.   

The average annual progression rates applied were determined on the basis of an analysis of 
Member  States'  performances  over  the  past  15  years8.  This  shows  that  an  annual  average 
increase  between  2  and  3  percentage  points  is  feasible  and  was  achieved  by  a  number  of 
Member States in the past, as already explained in the impact assessment (p 51).      

Two alternative variants have been developed and tested:  

•  a 'moderate' variant - Option 3.8 (a) – which assumes an average annual progression rate of 

2.5 percentage point until a recycling rate of  65% is achieved;  and  

•  a  'high'  variant  –  Option  3.8  (b)  which  assumes  an  average  annual  progression  rate  of  3 
percentage  points  until  a  recycling  rate  of  50%  is  achieved  and  an  average  annual 
progression rate  of 2 percentage points until a final recycling rate of 70% is reached.  

Option 3.8(c) has been developed in order to assess the added value of introducing a landfill 
diversion for MSW on top of recycling targets. Under this variant, landfill reduction targets 
for 2025, 2030 and in some cases 2035 are calculated for each individual Member States by 

5 Compared to the impact assessment a minor correction has been inserted to ensure the same progression rate 

between ferrous and non-ferrous metals which will ease the monitoring/implementation of the target 

6 EUROSTAT data on MSW for 2013 being  the most recent dataset available    
7  Eurostat  (2015)  Municipal  Waste  [env_wasmun],  Date  Accessed:  23  June  2015,  Downloaded  from: 

http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_wasmun&lang=en 

8  "Managing municipal solid waste – a review of the achievements in 32 European countries" EEA report N° 2, 

EEA 2013  

6 

 
 
 
 
 
 
                                                            
applying an average landfill reduction rate of 4 percentage points starting from a predefined 
baseline year (i.e. 2013) until a final reduction to 10% is reached.  

Option 3 – Upgrade EU targets (options assessed in the initial impact assessment)  

• 

• 

• 

• 
• 
• 

• 

Option 3.1 – Increase the recycling/reuse target for municipal waste  

Low: 60% reuse/recycling target by 2030; 50% by 2025 with only one method   

o 
o  High: 70% reuse/recycling target by 2030; 60% by 2025 with one method   

Option 3.2 – Increase the packaging waste targets 

Basis: top  Member States results in 2010 combined with stakeholder signals   

o 
o  Variant: target for nonferrous metals  

Option 3.3 – Limiting landfilling to residual waste  

o 

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 
Option 3.5 – same as option 3.4 with different deadlines for different groups of countries  
Option 3.6 -  same as option 3.4 with more stringent deadline for all Member States  with the possibility of time 
derogation   
Option 3.7 – same as option 3.4 with landfill ban on  all similar waste 

New Options included in this supplementary analysis 
Option 3.8 – Progression Rates  

a)  Moderate: 65%  reuse/recycling target for MSW combined with 75% recycling/reuse target for packaging waste 

by 2030 

b)  High: 70%  reuse/recycling final target for MSW combined with 80% recycling/reuse target for packaging waste 

by 2030 

c)  Option 3.8 (a) +  landfill reduction target for  municipal waste of maximum 10% with Member States specific 

deadlines 

Option 3.9 –Time derogations applicable to Member States at risk of non-compliance 
a)  Moderate: 65% reuse/recycling target by 2030 for MSW with possibility of a 5 year time-derogations for7 

Member States  combined with 75% recycling/reuse target for Packaging waste. 

b)  High: 70%  reuse/recycling target by 2030 for MSW with possibility of a 5 year time-derogations  for 7 Member 

States combined with 80% recycling/reuse target for Packaging waste  

c)  Option 3.9 (a) +  Landfill reduction target for municipal waste (maximum 10% by 2030) with possibility of a 5 

year time-derogations  for 9 Member States  

d)  Option 3.9 (b)+ Landfill reduction on municipal waste  with possibility of a 5 year time-derogations for  9 

Member States S (maximum 5% by 2030) 

Figure 1: Summary of the Options and variants considered under Option 3 

As explained in the impact assessment, experience shows that reduction rates of 4 percentage 
points  per  year  seem  to  be  reasonable  as  such  progress  has  either  been  achieved  or  even 
exceeded in several Member States over recent years.  

Option 3.9 – Time derogations 

Under this option, differentiation is implemented by setting common EU targets for 2025 and 
2030  while  envisaging  the  possibility  of  granting  time  derogations  to  those  Member  States 
that are the furthest behind with regards to recycling of municipal waste.   

In order to assess the possible impacts of this option, it has been necessary to identify those 
Member  States  that  may  request  time  derogations  for  the  2025  and  2030  targets.  For  the 
modelling  of  this  option,  it  was  therefore  assumed  that  Member  States  recycling  less  than 

7 

 
 
 
 
 
 
 
 
 
 
20% of their municipal waste in 20139 would be granted such derogations, thus meeting the 
common EU targets five years later than all other Member States.  

In order to ensure that Member States applying for derogation take the necessary steps to meet 
the  targets  on  time,  it  is  proposed  to  link  the  possibility  for  a  Member  State  to  obtain  time 
derogations with the adoption of a compliance plan, taking into consideration best practices 
applied in the most advanced Member States.  

As listed in Figure 1, two alternative options have been developed based on different degrees 
of ambition: 

•  a 'moderate' variant - Option 3.9(a) – which combines a 65% recycling rate for municipal 

waste by 2030 and  ‘moderate’ targets for packaging waste.  

•  a 'high' variant – Option 3.9(b) – which combines a 70% recycling rate for municipal waste 

by 2030 and the ‘high’ targets  packaging waste derogation 

Under both variants, 7 Member States would be eligible for a 5-year time derogation for the 
MSW recycling targets. 

Options  3.9  (c)  and  (d)  both  allow  for  the  added  value  of  additional  measures  aiming  at 
limiting landfilling being assessed. In Options 3.9 (c), a maximum diversion target of 10% by 
no later than 2030 was applied while in Option 3.9 (d) this maximum has been decreased to 
5%. Under both these variants, common EU landfill reduction targets for 2025 and 2030 were 
set, but combined with a regime of time-derogations for those Member States that heavily rely 
on  landfilling  of  their  municipal waste. For the modelling of these  variants, it was assumed 
that Member States landfilling more than 65% of their waste in 2013 10 would be granted such 
derogations, thus achieving the common EU targets five years later.  

9 Estonia, Greece, Croatia, Latvia, Malta, Romania and Slovakia 
10 Cyprus, Czech Republic, Greece, Croatia, Latvia, Malta, Romania and Slovakia 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
3. 

ANALYSIS OF IMPACTS – METHODOLOGICAL ASPECTS 

Model Update 

The analysis of impacts of the new variants described in this supplement is based on the same 
methodology applied described in the impact assessment (see Section 5). Nevertheless, since 
the impact assessment was finalised, improvements and updates have been introduced in the 
model  used  to  calculate  the  cost  and  benefits  of  the  different  scenarios.  The  modelling  tool 
used for assessing  the  costs  and benefits of the policy options in the impact assessment has 
been updated in a number of ways.11 The main changes that have been introduced include: 

•  All costs have been updated from 2013 to 2015 prices and the deflators used were switched 

from EU 28 deflators to country specific deflators; 

•  Given  that  many  of  the  new  policy  variants  extend  out  to  2035  the  Net  Present  Value 
(NPV) reported for the new target variants has been extended out by five years to allow the 
options to be compared on an equal footing (in the impact assessment the NPV covered the 
period 2014 to 2030 as none of the options extended beyond this point);  

•  Labour  cost  ratios  and  employment  intensity  factors  were  updated  in  light  of  new 

information that has become available over the last two years;   

•  Material  revenues  derived  from  the  sale  of  dry  recyclables  were  updated  to  account  for 

changes in commodity markets for secondary materials;   

•  The  approach  to  assessing  the  costs  of  civic  amenity  sites  has  been  improved  and  the 
collection module has been improved to more accurately account for, among other things, 
differences in approaches to collecting waste from houses vs flats/high rise buildings with 
multiple occupants;      

•  More realistic potential capture rates for packaging in MSW were applied which had two 
effects. Firstly, the household collection costs went up due to less revenue being generated 
from  the  captured  material,  and  secondly,  more  material  had  to  be  captured  from  non-
MSW sources, again, increasing the costs of the meeting the targets;  

•  The packaging waste data was updated from 2011 to Eurostat’s latest publication for 2012;   

As an illustration of the possible effects of the updates provided to the model, the impacts of 
these adjustments in the case of Option 3.1 – high and Option 3.7 (identified as the preferred 
Option in the initial impact assessment) were calculated. The results are summarised in Annex 
1 and from these results it can be concluded that the updated model produces results which 
are similar and consistent with the initial impact assessment. Expanding the time period by 5 
years (up to 2035) will amplify the initial results due to the high expected value of benefits to 
society in the period 2030-2035(see Annex 1).   

Sensitivity Analysis  

11  Eunomia  Research  &  Consulting  (2015)  Support  to  the  Waste  Targets  Review:  Analysis  of  New  Policy 

Options, Report for DG Environment of the European Commission. 

9 

 
 
 
 
 
                                                            
As detailed in Annex 2, sensitivity analysis has been carried out on the main input parameters 
used in the model. In summary the results are sensitive to some input parameters including the 
efficiency  of  the  collection  system  (such  as  the  introduction  of  measures  to  promote 
prevention and recycling like pay-as thrown schemes), material losses and revenues, valuation 
of GHG and the cost of capital. From the sensitivity tests conducted it appears that, although 
the model is clearly more sensitive to changes in some input assumptions than to others, the 
overall  narrative  and  conclusions  do  not  change  significantly  at  EU  28  level  and  over  the 
period 2015-2035.  

Calculation methods and reporting  

As  explained  in  the  impact  assessment,  the  existing  possibility  of  using  4  calculations 
methods for the 2020 recycling target for municipal waste will be maintained mainly for legal 
certainty reasons and to minimize any short-term disruption to the waste management plans 
adopted by many Member States. 

However, for all new targets (applicable by 2025 and 2030) only one calculation method will 
be allowed (i.e. calculation method 4). All calculations carried out in the impact assessment as 
well as in this supplement are based on data reported by Member States to Eurostat and the 
OECD using a single calculation method that broadly corresponds to the Method 4 under the 
existing implementing rules. 12  

As in the impact assessment, all calculations have been carried out on the basis of the input to 
the  final  recycling  process:  for  each  material  and  for  each  collection  system  (door-to-door 
separate collection, civil amenities centers, bring systems, etc.) specific losses rates have been 
applied to discount losses occurring between the collection and the input to the final recycling 
process. 13 

In  line  with  the  impact  assessment  guidelines,  calculations  have  been  made  assuming  full 
implementation  of  existing  legislation  –  particularly  for  what  relates  to  the  existing  landfill 
diversion  target  for  municipal  biodegradable  waste  and  the  existing  recycling  targets  for 
packaging  and  municipal  waste  (see  page  21  of  the  Impact  Assessment  for  more  detailed 
explanations). As regards the 2020 recycling targets for municipal waste, the estimates fully 
take into account Member States' choices in terms of calculation method and their impacts on 
actual performance (see page 34 of the Impact Assessment).  

4. 

COMPARING THE OPTIONS 

In this section, the relative impacts of the new variants and options are compared. As in the 
impact  assessment,  the  options  and  their  variants  are  first  compared  on  the  basis  of  the 
quantified data available through the model (e.g. costs and benefits, impacts on employment, 
contribution  to  greenhouse  gas  and  marine  litter  reduction).  Impacts  that  are  not  monetised  
within the model will also be discussed.  

Subsequently,  and  to  complement  the  cost-benefit  analysis,    a  qualitative  assesment  on  the 
relative contribution of each option and their variants to the attaintment of the main objectives 
as defined in the impact asessment is carried out.  

12 Commission Decisions  COM/2011/753/EC and COM 2005/270/EC: 
13 This is in line with existing rules requiring Member States to report recycled quantities when they reach the 
final/effective  recycling  step.  However,  according  to  existing  rules,  reporting  at  the  level  of  separate 
collection (for municipal waste) or at the output of sorting facility (for packaging and municipal waste) 
is tolerated as long as there are no 'significant' losses (see impact assessment page 36).   

10 

 
 
 
                                                            
 
4.1. 

Costs- benefits analysis 

Table  2  and  Figure  2  (see  below)  show  the  net  social  costs  of  each  option 
compared  to  the  full  implementation  scenario  presented  in  the  impact 
assessment. 

Options 

Financial 
Costs 

External 
Costs 

Net 
Social 
Costs 

Employment 

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term 
Prices 

1,000 FTEs in 
2035 

Option 3.8 
Option 3.8(a) - moderate 
Option 3.8(b) – high  
Option 3.8(c) - high equal to (a) with 
landfill (max 10%) 
Option 3.9 
Option 3.9(a) - moderate 
Option 3.9(b) – high   
Option 3.9(c) – equal to (a) with 
landfill (max 10%) 
Option 3.9(d) – equal to (b) with 
landfill (max 5%) 

-11.0 
-14.9 

-5.1 

-8.6 
-10.2 

-4.9 

-25.7 
-31.1 

-36.7 
-46.1 

-27.8 

-32.9 

-18.0 
-22.7 

-26.7 
-32.9 

-19.6 

-24.5 

-4.0 

-25.8 

-29.7 

140 
177 

136 

144 
178 

140 

176 

Reduction in 
Greenhouse Gas 
Emissions 

Million 
Tonnes 
CO2 eq 
in 2035 

Million 
Tonnes 
CO2 eq, 
2015 to 
2035 

-40.1 
-48.0 

-44.1 

-41.0 
-48.5 

-45.1 

-543 
-655 

-613 

-424 
-523 

-477 

-55.3 

-617 

Table 2: Comparison of key indicators for each of the new target variants listed in Figure 1 

Notes: 

1.  Financial costs are direct costs linked with the implementation of the targets (more separate collection, 

more revenues from the sales of materials, savings from less residual waste collection and treatment) while 
external costs represent the costs (or benefits if negative) to be paid (or gained in case of negative external 
costs) by third parties due to the implementation of the targets (reduced emissions of GHG and air 
pollutants).  Negative costs represent a benefit to society. 
 All scenarios compared against the Full Implementation. 

2. 
3.  Net social costs = financial costs + external costs. 
4.  Employment figures represent direct employment only (no multiplier effects have been included). 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 2: Comparing the net social costs across the EU28 for each of the new target variants listed in Figure 1 

The results of the cost/benefit analysis show that all the new options assessed can result in a 
net-benefit  for  society  at  the  EU  level.  However,  there  are  differences  between  the  options 
and their variants as summarised below:   

On the approach to target-setting 

•  Overall, the "progression rates" approach – that is the variants included under Option 3.8 – 
shows  higher  benefits  for  society  over  the  period  2015-2035  compared  to  the  time 
derogation  approach  under  option  3.9.  This  is  chiefly  explained  by  the  fact  that  under 
Option  3.8  those  Member  States  that  in  2013  already  recycled  more  than  35%  of  their 
municipal  waste  would  have  to  achieve  the  final  EU  target  before  2030.  It  is  this  early 
achievement of the targets by a group of eleven mid- and high performing countries14 that 
significantly increases the discounted flow of benefits from Option 3.8: the bulk of savings 
arising  from  more  recycling  and  less  residual  waste  collection  and  treatment  is  captured 
earlier in these 11 Member States compared to Option 3.9. And this fully compensates for 
later  achievement  by  a  group  of  under-performing  countries,  which  overall  generate  less 
waste, both per capita and in absolute terms.   

•  However, it can be seen from Figure 2 that as of 2030, the yearly benefits for society are 
very similar between Option 3.8 and 3.9. This shows that in the longer-term, both options 
lead to positive outcomes that are close in magnitude. It should also be noted that some of 
the potential benefits of Option 3.9 might have been underestimated as it has been assumed 
that all Member States will have a linear progression until 2030 and the attainment of the 
proposed  EU  targets.  It  nevertheless  appears  that  some  Member  States  have  already 

14 AT, BE, DK, FR, DE, IT, LU, NL, SL, SE and UK would have to meet the recycling target by 2025 although 
7 others MS would have to meet the same target 10 years later (see Annex 1, table A1 and A2) 

12 

 
 
 
 
 
                                                            
planned  to  meet  the  envisaged  EU  targets  earlier  15  and  this  was  not  taken  into  account 
when Option 3.9 was modelled.     

On the final recycling rates  

•  Higher MSW and packaging waste recycling targets are associated with greater financial 
savings and environmental benefits. For instance, the modelling suggests that by increasing 
the MSW recycling target from 65% to 70% and the overall packaging target from 75% to 
80% (moving from Option 3.9(a) to 3.9(b)), €6.2  billion of additional benefits for society 
are realised. Pronounced improvements in the benefits are likewise realised when moving 
from Option 3.8(a) to 3.8(b) (€9.4 billion). 

•  As  already  indicated  in  the  impact  assessment,  the  analysis  shows  a  general  tendency 
according to which the higher the final recycling rates, the greater the overall benefits for 
society.  In  all  the  scenarios  going  beyond  full  implementation  of  the  current  targets,  the 
model  in  fact  predicts  that  the  costs  of  additional  improvements  in  separate  collection, 
sorting  and  recycling  will  consistently  be  outweighed  by  the  revenues  from  the  sale  of 
secondary  raw  materials  and  the  savings  generated  by  reducing  the  amount  of  residual 
waste to be treated (i.e. landfilled or incinerated).  

•  Finally, the main barriers explaining why some Member States struggle to achieve higher 
recycling  rates  despite  of  clear  advantages  in  terms  of  cost-savings  and  environmental 
benefits are detailed in the impact assessment (section 2.5 and particularly 2.5.1).  

On the added value of a landfill reduction target 

•  The  inclusion  of  a  landfill  reduction  target  on  top  of  the  MSW  and  packaging  waste 
recycling  packages  lead  to  reduced  benefits  at  society  level  even  though  these  benefits 
remain  overall  positive.  For  example,  Option  3.9(c)  sees  the  benefits  at  society  level 
reduced  by  €  2.5  billion  over  the  period  2015 -2035  relative  to  Option  3.9(a):  the  only 
difference between these two variants is a restriction on landfilling of MSW to 10% of the 
total in the case of option 3.9(c).  

The  main  reason  for  this  is  that  the  environmental  benefits  generated  by  a  switch  from 
landfill to other  residual waste treatments are  not  sufficiently high to  compensate for the 
financial costs of such a switch. Indeed, a landfill reduction target would force any residual 
waste  out  of  landfill  into  more  expensive  residual  waste  treatment  options,  such  as 
incineration or mechanical biological treatment. This explains why for many countries, and 
the  EU28  as  a  whole,  the  addition  of  a  landfill  diversion  target  would  be  slightly  more 
costly than the options which do not include it.  

•  However, it should be noted that some important environmental benefits linked to landfill 
reduction measures (e.g. leachates and water pollution, effects of odours and bio-aerosols 
as  well  other  nuisances,  impacts  on  landscape  and  financial  inconveniences  linked  with 
living  in  the  vicinity  of  waste  treatment  facilities)  cannot  be  monetised  and  are  therefore 
not  factored  in  the  cost-benefit  analysis.  This  is  mainly  due  to  the  absence  of  proper 
methods to quantify such impacts. As explained in the impact assessment (page 30) social 
acceptance remains a key issue and this is particularly valid in the case of landfilling even 
though it might also be valid in case of incineration in some Member States. For all these 
reasons,  the  benefits  of  the  options  aiming  at  reducing  landfilling  are  likely  to  be  under 
estimated. 

15 Recently adopted waste management plans in FR, AT, BE, NL for instance include a target around or above 

65% recycling by 2025 

13 

 
 
 
                                                            
•  In  addition,  as  it  is  the  rule  in  any  cost  benefit  analysis,  landfill  charges  and  support 
measures  for  energy  (e.g.  benefits  resulting  from  substituting  fossil  fuel  by  fuel  derived 
from non-recyclable waste) are excluded from the analysis. The actual financial cost to be 
paid  by  the  operators  in  each  Member  State  will  be  affected  by  the  level  of  taxes  and 
subsidies as it is clearly shown in Figure 4 of the initial impact assessment (page 27).  

Job creation and GHG  

•  In  terms  of  job  creation,  Options  3.8(b),  3.9(b),  and  3.9(d)  are  promising  with  over  170 
thousand Full Time Equivalent (FTE) jobs likely to be created by 2035, with most of these 
jobs  being  created  in  the  recycling  industry.  This  is  direct  employment  only  with  no 
provision for multiplier effects (which would increase the employment generation figures). 
The  employment  intensities  –  FTEs  per  tonne  processed  –  associated  with  recycling  and 
preparation for reuse are typically much higher than those for residual waste treatment and 
disposal. Thus, Member States which need to implement the largest improvements in their 
waste  management  systems  could  potentially  derive  the  greatest  benefit  in  terms  of  job 
creation.  

Results per Member State  

Detailed results per Member Sate for the main options are provided in Annex 3. From these 
Tables, it can be concluded that: 

•  Nearly all the new options and variants assessed are estimated to bring benefits at society 
level for all Member States with the exception of  Options, i.e. 3.8 (c), 3.9 (c) and 3.9 (d) 
where four Member States are expected to face limited costs at society level(see Annex 3);  

•  Direct  saving  (negative  financial  costs)  are  expected  for  most  options  and  most  Member 
States;  nevertheless  slight  increases  in  financial  costs  are  expected  particularly  in  those 
Member  States  still  landfilling  residual  municipal  waste  under  the  full  implementation 
scenario.  For  these  Member  States  a  higher  proportion  of  waste  will  be  directly  diverted 
from (low cost)16 landfilling  to  recycling meaning that the scope for savings  (due  to less 
residual waste treatment by incineration or MBT) is reduced in these circumstances; other 
factors  like  labour  costs,  prices  of  electricity,  type  of  housing  in  relation  to  collection 
systems etc. also influences the relative position of each Member State;  

•  Moving  towards  higher  recycling  rates  is  estimated  to  provide  higher  benefits  at  society 

level for all Member States; 

•  Options including landfill reduction are expected to reduce social benefits in those Member 
States  still  relying  on  landfilling  for  their  residual  waste  treatment,  knowing  that,  as 
explained above, some key benefits were not monetised;  

•  These conclusions are amplified for larger countries due to a scaling factor: the amount of 
waste  whose  fate  is  changing  result  in  larger  changes  in  cost  and  benefits  particularly  in 
those MS expected to be just at 50% recycling by 2020 (FR, UK, SP, IT),  and;  

•  Higher job creation and GHG emission reduction can be expected in those Member States 
which need to implement the largest improvements in their waste management system. 

16 landfill taxes are not taken into account in the cost/benefits analysis (see section 5 of the impact assessment for 

more details) 

14 

 
 
 
                                                            
4.2. 

Complementary qualitative assessment 

In  this  section  a  more  qualitative  comparison  of  the  options  and  variants  is  carried  out  by 
assessing  their  relative  contribution  to  each  objective  identified  in  section  3  of  the  impact 
assessment - (1) simplification, (2) better monitoring/implementation, (3) dissemination best 
practices,  (4)  level  of  ambition  in  terms  of  resource  efficiency  –  and  their  potential 
performance in terms of coherence and efficiency.  

On the approach to target setting  

•  Options  3.8  and  3.9  are  very  similar  in  terms  of  simplification  and  improved  monitoring 
and  implementation  (Objectives  1  and  2).  Option  3.8  might  appear  as  more  complex  as 
each Member State would have a different target. Nevertheless, both Options have already 
been  applied  in  other  similar  legislations  of  similar  nature.  Both  approaches  provide 
recognition of the Member States' different starting points even though Option 3.8 is more 
country-specific.  

•  In  terms  of  implementation,  both  Options  have  their  own  advantages:  Option  3.8  might 
lead  to  improved  results  as  all  targets  would  be  country  specific  (Objective  2).  A  more 
tailor-made approach, setting firm but realistic milestones, could be effective in improving 
implementation.  

Allowing  Member  States  to  postpone  for  5  years  the  deadline  for  attaining  the  targets 
through the use of derogations might incentive these Member States to not take on time the 
measure  necessary  to  improve  their  waste  management  systems.  Nevertheless,  under 
option 3.9, this issue could be mitigated through a use of a conditionality mechanisms and 
additional safety-net requirements. In fact, one of the main advantages of Option 3.9 could 
be its potential for promotion of best practices which corresponds to Objective 3 and this 
could  help  to  improve  implementation.  As  mentioned  above,  time-derogations  could  be 
limited  to  some  Member  States  and  could  be  combined,  as  in  the  2014  proposal,  with  a 
conditionality mechanism where Member States requiring time derogation would have to 
prepare and submit to the Commission a compliance plan including an assessment of best 
increase 
practices  or  equivalent  measures.  Even 
administrative  burden,  it  would  be  limited  those  Member  States  where  it  makes  sense 
(maximum  of  7  Member  States),  also  bearing  in  mind  that  the  dissemination  of  best 
practices could help avoiding potential infringement procedures.  

this  approach  would 

though 

•  In the medium-term (before 2030), the contribution to the creation of a circular economy 
and  to  resource  efficiency  (objective  4)  at  the  EU28  level  is  higher  under  Option  3.8.  In 
fact,  more  raw  materials  and  resources  would  be  recycled  over  the  first  10  years  under 
Option 3.8 than under Option 3.9, which only the majority of Member States reaching the 
final MSW targets in 2030. Option 3.8 instead assumes that at least 11 Member States − 
which include the most economically developed and the largest waste producers in the EU 
− would meet the final recycling target on MSW well before 2030. Early achievement by 
this  group  of  countries  could  also  play  a  decisive  role  in  advancing  recycling  across  the 
whole  EU,  in  particular  by  creating  a  critical  mass  for  the  development  of  a  robust 
European market for secondary raw materials.  In the long-run (i.e. as of 2030), however, it 
should be noted that both options have comparable performances, leading to the same level 
of yearly societal benefits.  

On the final recycling rates  

•  As regards recycling targets, options which include higher reuse/recycling targets perform 
better  in  terms  of  resource  efficiency  and  level  of  ambition  of  the  package.  However, 

15 

 
 
 
 
opting  today  for  moderate  target-level  could  allow  taking  better  account  of  some  of  the 
uncertainties  underlined  by  the  sensitivity  analysis,  in  particular  regarding  waste 
prevention.  

•  Against this background, one possibility would be to opt for one of the "moderate" variants 
for  municipal  and  packaging  waste  recycling  and  re-assess  the  target  through  a  review 
clause,  at  later  stage  (i.e.  between  2020  and  2025)  with  the  view  to  move  towards  the 
higher targets, in line with the higher variants tested. This could also allow ensuring more 
coherence, taking into consideration future potential synergies with actions on the "rest of 
the circle". For instance, measures on products (e.g. to improve recyclability for instance of 
the plastics) or consumer policy can help ensure that the model's underlying assumptions 
materialise so that society gets the highest benefit from increasing recycling rates. 

On the added value of a landfill reduction target 

•  Under  both  options,  variants  with  only  recycling  targets  and  no  additional  landfilling 
targets  might  raise  some  questions  in  terms  of  simplification  as  the  co-existence  of 
multiple  EU  targets  on  municipal  waste  activities  could  limit  the  flexibility  that  national 
governments and economic actors have during implementation.  

•  Yet, the options combining recycling/reuse with landfilling targets could perform better in 
terms  of  coherence.  There  are  clear  synergies  between  a  gradual  increase  of  the 
reuse/recycling  rates  and  a  parallel  decrease  in  the  rate  of  landfilling.  Fixing  clear  long 
term targets for recycling and landfilling would give the necessary legal certainty to waste 
operators  –  whether  private  or  public  –  to  unblock  potential  investments.  Member  States  
still  landfilling  significant  amounts  of  their  waste  would  be  pushed  to  replace  landfilling 
directly  by  other  waste  management  practices  aligned  with  the  first  steps  of  the  waste 
hierarchy (prevention, re-use and recycling).  

•  At  the  same  time,  giving  adequate  lead  time  to  reduce  landfilling  could  limit  the  risk  of 
creating over capacities of residual waste treatment, as it has been the case in some more 
advanced Member States.   

•  Experience shows that Member States having effectively achieved high levels of recycling 
and  re-use  are  those  where  measures  to  limit  landfilling  are  the  most  developed  (via 
specific  bans  and/or  fiscal  policies  to  discourage  landfilling  together  with  incentives  for 
recycling).  Maintaining  landfilling  cheap  and  easy  represents  a  clear  barrier  for  the 
development separate collection and recycling (see impact assessment page 26/27).  

•  Reducing landfilling would contribute directly to Objective 4 (level of ambition, resource 
efficiency)  –  landfilling  represents  the  worst  waste  management  option  of  the  waste 
hierarchy as all potential resources are lost when landfilled. In that sense landfilling should 
be  progressively  phased  out  in  line  with  the  objectives  of  the  7th  Environmental  Action 
Program  proposed  by  the  Commission  and  endorsed  by  the  Council  and  the  Parliament. 
Leaving  the  possibility  for  the  Member  States  to  landfill  between  30  and  35  %  of  their 
municipal solid waste would be in contradiction with the objective of the Commission to 
promote circular economy.       

In  conclusion,  all  Options  and  their  variants  contribute  to  the  attainment  of  the  objectives 
detailed  in  the  Impact  Assessment.  In  the  context  of  this  analytical  note  it  has  only  been 
possible  to  identify  the  main  contributions  of  each  Option  and  variants  to  the  objectives 
without ranking these Options and variants between them.   

16 

 
 
 
Annex 1: Effects of the model updates in the case of Options 3.1 and 3.7 

The following table compares the results between those generated for the impact assessment 
and those generated using the updated model in the case of one Option (Option 3.1 – high). 
The comparison is intended to provide an indication of the extent to which the model outputs 
have changed as a result of the further development and enhancement of the modelling tool.  

The Table aims to isolate the impact that the changes listed above have had on the model from 
those  that  have  occurred  as  a  result  of  inflating  the  prices  to  2015  real  terms  prices  and 
adjusting the period over which NPV is calculated to 2015 to 2035. 

When comparing the NPV figures for the period 2014 to 2030 it can be seen that the financial 
costs are virtually unchanged, while the external benefits have increased by about €2.5 billion 
(the external costs have fallen from -€8.5 to -€11 billi on, with negative costs representing a 
benefit  to  society).  This  change  includes  the  fact  that  the  prices  have  all  been  inflated  from 
2013 to 2015 real terms prices. As a result of the changes to the financial and external costs 
the net social cost shows greater benefits to society, but the shift has been relatively slight. It 
can be concluded that the updated model produces results which are consistent with the initial 
impact assessment.  

Model Version / Model 
Variations 

First IA Model 
NPV 2014 to 2030, € Billion, 
2013 Prices 
Updated Model 
NPV 2015 to 2030, € Billion, 
2015 Prices 

Updated Model 
NPV 2015 to 2035, € Billion, 
2015 Prices 

Notes: 

Financial 
Costs 

External 
Costs 

Net Social 
Costs1 

Net Present Value3 

-8.4 

-8.5 

-16.9 

-5.5 

-10.6 

-16.1 

Employ-
ment2 
1,000 
FTEs 

In 2030: 
138 

In 2030: 
135 

Reduction in Greenhouse 
Gas Emissions 

Million Tonnes CO2 eq 

In 2030:  -39 

In 2030:  -38 

2014 to 
2030:  -214 

2014 to 
2030: -232 

-10.1 

-20.2 

-30.4 

In 2035: 
139 

In 2035:  -39 

2014 to 
2035: -386 

1.  Net social costs = financial costs + external costs. 
2.  Employment figures represent direct employment only (no multiplier effects have been included). 
3.  Negative costs represent a benefit to society.  

Table A4: Option 3.1- high – differences between the previous and updated version of the model 

Extending  the  calculation  of  NPV  out  to  2035  significantly  alters  the  final  results.  This  is 
because NPV measures the flow of costs over time. In line with the European Commission’s 
approach to impact assessments, a discount rate of 4% per annum was used again as part of 
this  additional  analysis.  Despite  the  fact  that  future  costs  and  benefits  are  discounted,  the 
addition of an extra five years of costs and benefits significantly alters the final, aggregated 
NPV figure.  

This  is  clearly  shown  in  Figure  2  where  the  area  under  the  graph  provides  a  hypothetical 
example of the flow of money over time. Triangle ‘A’ shows the flow of costs between 2020 
and  2030,  whereas  the  flow  of  costs  between  2020  and  2035  will  include  the  entire  area 
shown by ‘A’ and ‘B’. This provides an illustration of why extending NPV to 2035 has such a 
marked impact on the results, even after the effects of discounting are taken into account.   

17 

 
 
 
 
    
 
Figure A1: Net Present Value (NPV) measures the flow of costs over time which is represented by the area under 
the graph 

Option 3.7 was considered the 'preferred' Option in the initial impact assessment. In this case, 
the updated results show a bigger change compared to those calculated for Option 3.1- High 
(see Table below). This is particularly true for the financial costs, where the net benefits have 
decreased from -€10.7 billion in 201 3 real term prices to -€0.1 b illion in 2015 real term prices. 
The  reduction  in  the  calculated  external  benefits  has  been  less  marked,  these  falling  from  -
€18.3 billion in 2013 real terms prices to  -€16.6 billion in 2015 real terms prices.  

Unlike  Option  3.1-high,  which  is  restricted  to  a  MSW  recycling  target,  Option  3.7  includes 
both packaging waste recycling targets and a landfill diversion target, which covers MSW as 
well as the landfilling of other ‘similar’ wastes. It has been shown above that changes to the 
Municipal Waste Model has caused the financial costs of Option 3.1-high to increase by €2.9 
billion. This, therefore, explains part of the reduction in costs recorded in relation to Option 
3.7.  The  remaining  €7.8  billion  increase  in  fi nancial  costs  occurs  due  to  additional 
improvements to the Packaging Waste and Landfill Diversion parts of the model as detailed in 
section 3.       

18 

 
 
 
 
  
 
 
 
 
 
Model Version / Model 
Variations 

Option 3.7 

First IA Model 
NPV 2014 to 2030, € Billion, 
2013 Prices 
Updated Model 
NPV 2015 to 2030, € Billion, 
2015 Prices 
Updated Model 
NPV 2015 to 2035, € Billion, 
2015 Prices 

Notes: 

Financial 
Costs 

External 
Costs 

Net Social 
Costs1 

Net Present Value3 

Employ-
ment2 
1,000 
FTEs 

Reduction in Greenhouse 
Gas Emissions 

Million Tonnes CO2 eq 

-10.7 

-18.3 

-29.0 

- 

In 2030: -62 

-0.1 

-16.6 

-16.7 

-0.7 

-31.1 

-31.8 

In 2030: 
186 

In 2035: 
199

In 2030: -62   

In 2035:  -66 

2014 to 
2030: -443 

2015 to 
2030: -419 

2015 to 
2035: -739 

Net social costs = financial costs + external costs 

Employment figures represent direct employment only (no multiplier effects have been included) 

Negative costs represent a benefit to society.  

19 

 
 
 
 
 
 
 
 
 
 
Annex 2: Sensitivity Analysis 

Option  3.9(c)  was  used  for  the  purpose  of  assessing  the  degree  to  which  the  model  outputs 
change when the values of a number of assumptions are flexed to their likely upper and lower 
limits.  In  summary,  when  calculating  the  impact  of  Option  3.9(c)  the  results  are  mainly 
sensitive  to:  waste  prevention  effects  resulting  from  introducing  pay-as-you-throw  (PAYT) 
schemes;  material  losses  between  the  point  of  collecting  recyclables  and  their  final 
reprocessing; material revenues received from the sale of dry recyclables; the monetised value 
placed on greenhouse gas; and weighted average cost of capital.  

It can be seen from Figure A2 below, for example, that altering the assumed waste prevention 
impact generated by transitioning to PAYT – which is the most influencing input parameter - 
will either cause a net difference – in terms of net present value (NPV) – of between + €1.1 
billion (+ 4% of the total NPV) of minus €4.7  billion (- 15% of the total NPV) in 2015 real 
term prices (NPV period covers 2015 to 2035).  

It  is  clear  that  from  the  sensitivity  tests  conducted  as  part  of  the  analysis  that,  although  the 
model  is  clearly  more  sensitive  to  changes  in  some  input  assumptions  than  to  others,  the 
overall  narrative  and  conclusions  do  not  change  significantly.  It  is  therefore  safe  to  assume 
that although the numbers may vary slightly if different input assumptions are used the overall 
conclusion that is being drawn will not change. 

.      

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NPV 2015-2035 (billion EUR, 2015 Real Terms Prices)

-€30

-€28

-€26

-€24

-€22

-€20

-€18

Waste Prevention Effects per Household - PAYT

-€29.53

-€23.60

Material Losses: Combined

-€24.71

-€19.78

Material Revenues - Plastics (EUR)

-€25.35

-€22.15

Monetised value placed on GHG emissions (variance)

-€26.20

-€23.27

Material Revenues - Paper & Card (EUR)

-€25.13

-€23.06

Weighted Average Cost of Capital - Infrastructure

-€25.25

-€24.08

Material Revenues - Textiles (EUR)

-€24.94

-€23.82

Marginal Electricity Grid mix - minimum % renewables

-€25.68

-€24.71

Material Revenues - Aluminium (EUR)

-€24.89

-€23.99

Energy Prices - Direct Revenue for Supplying
Electricity to Grid (EUR per kWh)

-€24.92

-€24.19

Material Revenues - Steel (EUR)

-€24.86

-€24.13

Labour Costs

-€25.03

-€24.55

Landfill gas capture rates

-€24.97

-€24.54

Global warming potential of methane

-€25.05

-€24.71

Waste Prevention Effects per Household - Food Waste
Collection

-€24.89

-€24.76

Energy Prices - Heat price (EUR per kWh)

-€24.78

-€24.69

Weighted Average Cost of Capital - Vehicles

-€24.76

-€24.67

Collection System Efficiencies (variance)

-€23.97

-€23.89

Material Revenues - Glass (EUR)

-€24.73

-€24.66

NPV based on the 
central estimates 
and the difference 
between full 
implementation 
and Scenario 3.9 
(c): €24.5 billion 

NPV with variable below baseline value

NPV with variable above baseline value

Figure A2: Variance in social cost of waste management in the EU28, Option 3.9(c) compared to full 
implementation (NPV over 2015 – 2035 in 2015 real term prices) 

21 

 
 
 
 
 
 
 
 
 
 
 
Annex 3 – Member States specific results for the new target options 

Financial 
Costs 

External 
Costs 

Net Social 
Costs2 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term Prices 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

-0.36 
0.11 
-0.01 
-0.08 
-0.09 
-0.32 
-0.23 
-0.01 
-0.30 
-2.75 
-1.03 
-0.26 
-0.09 
-0.22 
-5.62 
-0.01 
-0.06 
-0.02 
0.01 
-0.81 
0.06 
-0.06 
0.45 
-0.01 
-0.01 
0.26 
-0.42 
0.84 
-11.0 

-0.49 
-0.52 
-0.14 
-0.18 
-0.06 
-0.39 
-0.11 
-0.03 
-0.09 
-8.30 
-1.06 
-0.30 
-0.66 
-0.28 
-5.44 
-0.05 
-0.13 
-0.02 
-0.01 
-0.55 
-0.51 
-0.52 
-0.51 
-0.17 
-0.08 
-0.93 
-0.11 
-3.99 
-25.7 

-0.85 
-0.42 
-0.15 
-0.27 
-0.15 
-0.72 
-0.33 
-0.04 
-0.39 
-11.05 
-2.09 
-0.56 
-0.75 
-0.50 
-11.05 
-0.06 
-0.19 
-0.05 
0.00 
-1.36 
-0.45 
-0.59 
-0.06 
-0.19 
-0.09 
-0.68 
-0.53 
-3.15 
-36.71 

2.05 
2.10 
0.36 
3.06 
0.25 
1.34 
1.07 
0.34 
0.81 
27.57 
9.81 
1.47 
2.51 
1.71 
20.41 
0.38 
0.55 
0.09 
0.08 
2.58 
13.01 
4.35 
1.88 
0.80 
0.16 
12.22 
0.68 
28.78 
140 

-0.75 
-0.55 
-0.29 
-0.47 
-0.17 
-0.78 
-0.12 
-0.12 
-0.10 
-9.77 
-2.53 
-0.78 
-1.12 
-0.75 
-7.57 
-0.11 
-0.24 
-0.03 
-0.05 
-0.65 
-1.54 
-1.17 
-1.66 
-0.47 
-0.10 
-2.19 
-0.25 
-5.82 
-40.1 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-11.69 
-7.37 
-3.55 
-4.31 
-2.01 
-8.80 
-1.50 
-1.13 
-1.18 
-144.21 
-31.01 
-8.10 
-14.85 
-9.73 
-110.91 
-1.41 
-3.22 
-0.31 
-0.47 
-9.65 
-18.43 
-14.40 
-13.87 
-3.67 
-1.54 
-26.63 
-3.41 
-86.06 
-543.4 

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A5:  Financial, External and Net social costs for Option 3.8 (a)  

22 

 
 
 
 
 
 
 
 
 
Financial 
Costs 

External 
Costs 

Net Social 
Costs2 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term Prices 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

-0.55 
0.03 
-0.01 
-0.10 
-0.10 
-0.45 
-0.37 
-0.02 
-0.34 
-3.10 
-2.19 
-0.34 
-0.11 
-0.30 
-6.30 
-0.01 
-0.07 
-0.04 
0.01 
-1.23 
0.06 
-0.15 
0.55 
-0.01 
-0.01 
0.49 
-0.54 
0.27 
-14.9 

-0.62 
-0.62 
-0.17 
-0.21 
-0.08 
-0.46 
-0.13 
-0.04 
-0.11 
-9.37 
-2.04 
-0.38 
-0.77 
-0.34 
-6.21 
-0.06 
-0.15 
-0.03 
-0.02 
-0.77 
-0.63 
-0.63 
-0.67 
-0.23 
-0.10 
-1.18 
-0.16 
-4.93 
-31.1 

-1.18 
-0.59 
-0.18 
-0.31 
-0.18 
-0.91 
-0.50 
-0.06 
-0.46 
-12.47 
-4.23 
-0.73 
-0.88 
-0.64 
-12.50 
-0.07 
-0.22 
-0.07 
-0.01 
-2.00 
-0.57 
-0.78 
-0.13 
-0.24 
-0.12 
-0.69 
-0.70 
-4.66 
-46.1 

2.61 
2.90 
0.47 
3.75 
0.28 
1.70 
1.46 
0.38 
1.08 
33.26 
13.25 
1.71 
2.89 
2.42 
25.15 
0.45 
0.66 
0.13 
0.09 
3.56 
15.53 
5.19 
2.13 
0.92 
0.21 
15.19 
0.98 
38.41 
177 

-0.95 
-0.68 
-0.39 
-0.55 
-0.19 
-0.91 
-0.16 
-0.14 
-0.13 
-11.00 
-3.48 
-0.90 
-1.26 
-0.90 
-8.80 
-0.13 
-0.29 
-0.03 
-0.05 
-0.90 
-1.75 
-1.31 
-1.84 
-0.53 
-0.13 
-2.77 
-0.36 
-7.50 
-48.0 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-14.43 
-9.22 
-4.39 
-4.96 
-2.36 
-10.41 
-2.10 
-1.45 
-1.66 
-162.67 
-46.25 
-10.15 
-17.10 
-11.87 
-126.70 
-1.64 
-3.89 
-0.43 
-0.51 
-13.51 
-21.70 
-16.49 
-17.80 
-4.79 
-1.96 
-33.08 
-4.96 
-108.68 
-655.2 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A6:  Member State Specific Results for Option 3.8(b) 

23 

 
 
 
 
 
 
Financial 
Costs 

External 
Costs 

Net Social 
Costs2 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term Prices 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

-0.36 
0.11 
0.27 
0.00 
-0.10 
-0.33 
-0.23 
0.09 
-0.13 
-1.76 
-1.03 
-0.08 
0.14 
-0.22 
-5.08 
0.00 
0.06 
-0.02 
0.00 
-0.81 
0.40 
0.11 
0.91 
0.02 
0.16 
1.04 
-0.42 
2.16 
-5.1 

-0.49 
-0.52 
-0.26 
-0.21 
-0.08 
-0.39 
-0.11 
-0.06 
-0.20 
-8.29 
-1.06 
-0.43 
-0.74 
-0.28 
-6.14 
-0.06 
-0.17 
-0.02 
-0.01 
-0.55 
-0.67 
-0.57 
-0.56 
-0.19 
-0.29 
-0.98 
-0.11 
-4.34 
-27.8 

-0.85 
-0.42 
0.01 
-0.21 
-0.18 
-0.72 
-0.33 
0.03 
-0.33 
-10.05 
-2.09 
-0.50 
-0.59 
-0.50 
-11.22 
-0.06 
-0.10 
-0.05 
-0.01 
-1.36 
-0.27 
-0.46 
0.34 
-0.17 
-0.13 
0.07 
-0.53 
-2.18 
-32.9 

2.05 
2.10 
0.32 
3.01 
0.22 
1.34 
1.07 
0.33 
0.81 
27.38 
9.81 
1.08 
2.58 
1.71 
19.25 
0.39 
0.59 
0.09 
0.06 
2.58 
12.71 
4.20 
1.37 
0.76 
0.12 
11.16 
0.68 
28.13 
136 

-0.75 
-0.55 
-0.50 
-0.42 
-0.22 
-0.73 
-0.12 
-0.15 
-0.20 
-9.83 
-2.53 
-1.10 
-1.13 
-0.75 
-8.20 
-0.14 
-0.32 
-0.03 
-0.04 
-0.65 
-1.74 
-1.29 
-1.74 
-0.42 
-0.22 
-3.15 
-0.25 
-6.96 
-44.1 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-11.69 
-7.37 
-6.14 
-3.93 
-2.51 
-8.61 
-1.50 
-2.29 
-4.55 
-147.71 
-31.01 
-12.47 
-15.21 
-9.73 
-122.17 
-1.75 
-4.40 
-0.31 
-0.43 
-9.65 
-21.50 
-16.73 
-15.58 
-3.96 
-3.95 
-37.49 
-3.41 
-107.25 
-613.3 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A7:  Member State Specific Results for Option 3.8(c) 

24 

 
 
 
 
 
Financial 
Costs 

External 
Costs 

Net Social 
Costs2 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term Prices 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

-0.04 
0.23 
-0.01 
-0.08 
-0.08 
-0.28 
-0.14 
-0.01 
-0.28 
-1.89 
-0.53 
-0.20 
-0.05 
-0.16 
-3.96 
0.00 
-0.02 
-0.01 
0.01 
-0.47 
-0.49 
-0.76 
0.44 
-0.01 
-0.01 
0.46 
-0.35 
0.03 
-8.6 

-0.26 
-0.28 
-0.11 
-0.15 
-0.06 
-0.41 
-0.06 
-0.03 
-0.07 
-5.95 
-0.58 
-0.23 
-0.58 
-0.20 
-3.68 
-0.04 
-0.11 
-0.01 
-0.01 
-0.27 
-0.42 
-0.45 
-0.55 
-0.18 
-0.05 
-0.77 
-0.07 
-2.41 
-18.0 

-0.30 
-0.05 
-0.12 
-0.23 
-0.15 
-0.69 
-0.20 
-0.03 
-0.36 
-7.84 
-1.11 
-0.43 
-0.63 
-0.35 
-7.64 
-0.04 
-0.13 
-0.03 
-0.01 
-0.74 
-0.92 
-1.20 
-0.10 
-0.19 
-0.06 
-0.31 
-0.42 
-2.37 
-26.7 

2.25 
2.14 
0.35 
3.07 
0.25 
1.34 
1.18 
0.34 
0.81 
27.82 
10.98 
1.47 
2.52 
1.73 
21.00 
0.38 
0.56 
0.10 
0.08 
2.72 
13.04 
4.38 
1.88 
0.80 
0.16 
12.28 
0.82 
29.43 
144 

-0.78 
-0.57 
-0.29 
-0.47 
-0.17 
-0.87 
-0.15 
-0.12 
-0.10 
-9.74 
-2.84 
-0.78 
-1.12 
-0.75 
-7.57 
-0.11 
-0.26 
-0.03 
-0.05 
-0.68 
-1.53 
-1.25 
-1.66 
-0.47 
-0.11 
-2.20 
-0.30 
-6.01 
-41.0 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-7.41 
-5.99 
-2.80 
-3.60 
-1.96 
-9.56 
-1.69 
-1.01 
-0.90 
-114.76 
-25.04 
-6.24 
-12.88 
-7.24 
-79.74 
-1.08 
-3.00 
-0.25 
-0.40 
-5.39 
-14.98 
-12.02 
-14.63 
-3.80 
-1.04 
-22.72 
-2.47 
-61.79 
-424.4 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A8:  Member State Specific Results for Option 3.9(a) 

25 

 
 
 
 
 
 
Financial 
Costs 

External 
Costs 

Net Social 
Costs2 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term Prices 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

-0.20 
0.24 
-0.01 
-0.09 
-0.10 
-0.38 
-0.20 
-0.01 
-0.33 
-1.91 
-0.79 
-0.25 
-0.10 
-0.22 
-4.48 
0.00 
-0.03 
-0.02 
0.00 
-0.86 
-0.51 
-0.81 
0.42 
-0.03 
-0.01 
0.58 
-0.45 
0.37 
-10.2 

-0.39 
-0.40 
-0.16 
-0.18 
-0.07 
-0.48 
-0.09 
-0.03 
-0.10 
-6.99 
-1.08 
-0.28 
-0.66 
-0.26 
-4.38 
-0.05 
-0.13 
-0.02 
-0.01 
-0.44 
-0.52 
-0.54 
-0.64 
-0.21 
-0.07 
-1.07 
-0.11 
-3.35 
-22.7 

-0.59 
-0.16 
-0.17 
-0.27 
-0.17 
-0.86 
-0.29 
-0.04 
-0.43 
-8.90 
-1.87 
-0.53 
-0.76 
-0.47 
-8.86 
-0.05 
-0.16 
-0.04 
-0.01 
-1.30 
-1.03 
-1.35 
-0.22 
-0.24 
-0.08 
-0.49 
-0.56 
-2.98 
-32.9 

2.73 
2.90 
0.47 
3.76 
0.29 
1.70 
1.46 
0.38 
1.08 
33.31 
14.12 
1.71 
2.89 
2.44 
25.52 
0.45 
0.66 
0.13 
0.09 
3.67 
15.54 
5.21 
2.14 
0.92 
0.21 
15.19 
1.05 
37.97 
178 

-0.97 
-0.69 
-0.39 
-0.55 
-0.19 
-1.01 
-0.17 
-0.14 
-0.13 
-10.99 
-3.66 
-0.90 
-1.25 
-0.90 
-8.80 
-0.13 
-0.29 
-0.03 
-0.05 
-0.93 
-1.75 
-1.40 
-1.85 
-0.54 
-0.14 
-2.77 
-0.39 
-7.48 
-48.5 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-10.46 
-7.80 
-4.06 
-4.38 
-2.25 
-11.36 
-2.04 
-1.22 
-1.33 
-132.41 
-33.50 
-7.53 
-14.51 
-9.31 
-94.36 
-1.35 
-3.44 
-0.35 
-0.46 
-9.06 
-17.97 
-14.17 
-16.82 
-4.44 
-1.44 
-30.43 
-3.91 
-82.41 
-522.8 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A9:   Member State Specific Results for Option 3.9(b) 

26 

 
 
 
 
 
 
 
Financial 
Costs 

External 
Costs 

Net Social 
Costs2 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term Prices 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

-0.04 
0.23 
0.29 
0.01 
-0.10 
-0.28 
-0.14 
0.02 
-0.27 
-1.50 
-0.53 
-0.03 
0.09 
-0.16 
-3.53 
0.01 
0.06 
-0.01 
0.00 
-0.47 
-0.45 
-0.71 
0.82 
0.01 
0.07 
1.21 
-0.35 
0.83 
-4.9 

-0.26 
-0.28 
-0.24 
-0.18 
-0.08 
-0.41 
-0.06 
-0.04 
-0.09 
-6.02 
-0.58 
-0.35 
-0.63 
-0.20 
-4.12 
-0.05 
-0.14 
-0.01 
-0.01 
-0.27 
-0.49 
-0.47 
-0.58 
-0.19 
-0.15 
-0.80 
-0.07 
-2.82 
-19.6 

-0.30 
-0.05 
0.05 
-0.17 
-0.18 
-0.69 
-0.20 
-0.01 
-0.36 
-7.53 
-1.11 
-0.38 
-0.54 
-0.35 
-7.65 
-0.04 
-0.08 
-0.03 
-0.01 
-0.74 
-0.94 
-1.18 
0.24 
-0.18 
-0.08 
0.41 
-0.42 
-1.99 
-24.5 

2.25 
2.14 
0.31 
3.03 
0.22 
1.34 
1.18 
0.34 
0.81 
27.84 
10.98 
1.08 
2.57 
1.73 
19.32 
0.39 
0.59 
0.10 
0.06 
2.72 
13.06 
4.40 
1.37 
0.81 
0.13 
11.14 
0.82 
29.60 
140 

-0.78 
-0.57 
-0.50 
-0.42 
-0.22 
-0.87 
-0.15 
-0.15 
-0.21 
-9.97 
-2.84 
-1.10 
-1.13 
-0.75 
-8.23 
-0.14 
-0.32 
-0.03 
-0.04 
-0.68 
-1.60 
-1.33 
-1.74 
-0.49 
-0.22 
-3.14 
-0.30 
-7.15 
-45.1 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-7.41 
-5.99 
-5.60 
-3.24 
-2.49 
-9.56 
-1.69 
-1.47 
-1.48 
-117.77 
-25.04 
-10.67 
-13.11 
-7.24 
-88.79 
-1.49 
-3.77 
-0.25 
-0.37 
-5.39 
-16.02 
-12.98 
-15.74 
-4.02 
-2.30 
-32.89 
-2.47 
-77.72 
-476.9 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A10: Member State Specific Results for Option 3.9(c) 

27 

 
 
 
 
 
 
 
 
 
Net Social 
External 
Financial 
Costs2 
Costs 
Costs 
Net Present Value, 2015 to 2035, 
Billion EUR, 2015 Real Term 
Prices 
-0.39 
-0.40 

-0.59 
-0.16 

-0.20 
0.24 

0.31 

0.01 

-0.11 
-0.35 

-0.20 

0.03 

-0.25 

-0.86 
-0.79 

0.02 

0.06 

-0.27 
-3.62 

0.06 

0.06 

-0.02 

0.00 
-0.86 

-0.51 

-0.71 

0.87 
0.01 

0.07 

1.65 

-0.45 
1.83 
-4.0 

-0.30 

-0.22 

-0.10 
-0.51 

-0.09 

-0.05 

-0.16 

-7.15 
-1.08 

-0.47 

-0.71 

-0.24 
-5.22 

-0.05 

-0.14 

-0.02 

-0.01 
-0.44 

-0.77 

-0.59 

-0.73 
-0.23 

-0.18 

-1.30 

-0.11 
-4.09 
-25.8 

0.01 

-0.21 

-0.20 
-0.86 

-0.29 

-0.02 

-0.41 

-8.01 
-1.87 

-0.44 

-0.65 

-0.51 
-8.84 

0.01 

-0.09 

-0.04 

-0.01 
-1.30 

-1.28 

-1.30 

0.14 
-0.22 

-0.11 

0.34 

-0.56 
-2.26 
-29.7 

Employment3 

Reduction in Greenhouse Gas 
Emissions 

1,000 FTEs in 
2035 

Million Tonnes 
CO2 eq in 2035 

2.73 
2.90 

0.44 

3.73 

0.27 
1.70 

1.46 

0.39 

1.08 

33.35 
14.12 

1.41 

2.94 

2.45 
24.58 

0.42 

0.63 

0.13 

0.08 
3.67 

15.58 

5.25 

1.72 
0.93 

0.19 

14.45 

1.05 
38.22 
176 

-0.97 
-0.69 

-0.60 

-0.51 

-0.25 
-1.07 

-0.17 

-0.18 

-0.33 

-11.42 
-3.66 

-1.30 

-1.26 

-0.94 
-9.96 

-0.16 

-0.32 

-0.04 

-0.05 
-0.93 

-1.98 

-1.57 

-2.03 
-0.58 

-0.25 

-4.23 

-0.39 
-9.50 
-55.3 

Million Tonnes 
CO2 eq, 2015 to 
2035 
-10.46 
-7.80 

-7.13 

-4.15 

-2.94 
-12.00 

-2.04 

-1.81 

-3.30 

-139.68 
-33.50 

-13.65 

-14.72 

-9.03 
-112.07 

-1.71 

-3.80 

-0.35 

-0.49 
-9.06 

-21.39 

-16.10 

-19.31 
-4.91 

-2.82 

-47.68 

-3.91 
-111.25 
-617.1 

Member State 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 
EU28 
Notes:  

1.  Negative costs represent a benefit to society. All scenarios compared against the Full Implementation. 
2.  Net social costs = financial costs + external costs. 
3.  Employment figures represent direct employment only (no multiplier effects have been included). 

Table A11:  Member State Specific Results for Option 3.9(d) 

28