COMMISSION STAFF WORKING DOCUMENT The early warning report for Croatia Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of EU waste legislation, including the early warning report for Member States at risk of missing the 2020 preparation for re-use/recycling target on municipal waste
Date: 2018-09-24
Institutions: Directorate-General for Environment, European Commission
Subjects: Croatia, EU environmental policy, application of EU law, circular economy, environmental law, environmental protection, pollution control, prevention of pollution, waste, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.9.2018 SWD(2018) 414 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Croatia Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of EU waste legislation, including the early warning report for Member States at risk of missing the 2020 preparation for re-use/recycling target on municipal waste {COM(2018) 656 final} - {SWD(2018) 413 final} - {SWD(2018) 415 final} - {SWD(2018) 416 final} - {SWD(2018) 417 final} - {SWD(2018) 418 final} - {SWD(2018) 419 final} - {SWD(2018) 420 final} - {SWD(2018) 421 final} - {SWD(2018) 422 final} - {SWD(2018) 423 final} - {SWD(2018) 424 final} - {SWD(2018) 425 final} - {SWD(2018) 426 final}  
 
 
1.  Introduction 

This early warning report is part of the Commission's overall implementation report and aims 
to assist Member States at risk of failing to meet the 2020 target of 50 % preparation for re-
use/recycling of municipal waste set out in Article 11(2)(a) of Directive 2008/98/EC. It builds 
on  previous  support  provided  by  the  Commission  to  help Member  States  comply1  with  EU 
law in the area of municipal waste management. This resulted in country-specific roadmaps2 
being drawn up for the relevant Member States.  

The  assessment  underpinning  the  early  warning  report  is  based  on  a  collaborative  and 
transparent process involving the Member States concerned and an in-depth analysis of their 
most  recent  policy  developments.  This  also  involved  extensive  consultation  with  the 
authorities in charge of waste management.  

The possible actions identified during this process are based on the existing best practices and 
aim  to  help  Member  States  in  meeting  the  2020  municipal  waste  preparation  for  re-
use/recycling target; they therefore focus on policy measures that can be taken forward in the 
short  term.  These  actions  should  be  seen  as  complementary  to  those  recommended  in  the 
roadmaps that were drawn up as part of the preceding compliance promotion activities and to 
the recommendations made in the Environmental Implementation Review3 

2.  Key findings 

In 2016, the recycling rate (including composting) reported to Eurostat was 21 %. The rate of 
municipal waste landfilling was 77 %, making it among the highest in the EU. Based on an 
analysis of existing and firmly planned policies in the area of waste management, Croatia is 
considered at risk of failing to meet the 2020 target of 50 % preparation for re-use/recycling 
for municipal waste. 

The assessment4 that underpins the early warning report concludes that: 

 

the separate collection of recyclables, including bio-waste, is not yet being carried out 
effectively; 

  economic incentives for citizens and municipalities are yet to be implemented; 
 

the extended producer responsibility schemes in Croatia do not fully cover the costs 
of separate collection; and 

  more investment is needed in projects higher up the waste hierarchy that go  beyond 

the treatment of residual waste. 

The table below lists possible actions to support Croatia's efforts to improve its performance 
in waste management. 

1 http://ec.europa.eu/environment/waste/framework/support_implementation.htm 
2 Roadmap for Croatia 
http://ec.europa.eu/environment/waste/framework/pdf/facsheets%20and%20roadmaps/Roadmap_Croatia.p
df 
3 http://ec.europa.eu/environment/eir/country-reports/index2_en.htm 
4 Eunomia Research & Consulting et al. (2018) ‘Study to identify Member States at risk of non-compliance with 
the 2020 target of the Waste Framework Directive and to follow-up phase 1 and 2 of the compliance 
promotion exercise. The early warning report: Croatia.’. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Data reporting 

1)  Systematic audits on companies providing data on the amounts of packaging placed on 
the market (producers or producer responsibility organisations — PROs) to ensure that 
it is in line with the data on municipal waste. Reconciliation of differences between the 
municipal waste and packaging waste datasets. 

2)  Monitoring more closely the amounts of waste landfilled at those landfills which are 

still without weighbridges. 

3)  Statistically representative compositional analysis of municipal waste. 

Extended producer responsibility 

4)  Improvements to the functioning of the EPR by either: 

– specifying in detail a minimum level of collection service (see action 6) that producers 
are required to fund for the local self-government units (LSGUs) so that there is a focus 
on quality collection services, including door-to-door collection wherever appropriate; 
or 

– restructuring the existing approach by making producers set up their own not-for-
profit PRO, which would be tasked with collecting the fees from producers and 
distributing them to LSGUs, while ensuring these fees are not more than necessary for 
the service. 

5)  In both options outlined in point 4, increases to the fees paid by producers or PROs to 

ensure that they cover the full costs of the collection service. 

Separate collection 

6)  Development of a more prescriptive collection service standard for implementation by 

LSGUs to ensure a high level of recycling, emphasising door-to-door separate 
collection, and ensuring a more rapid spread of door-to-door service throughout Croatia.  

Regulation and incentives for local authorities 

7)  Consideration of review of fines for LSGUs that fail to meet the targets - currently the 

fines are too low and most likely below the costs of achieving the targets while potential 
increases of fines to a more punitive level over several years would be more effective. 

8)  Implementation of measures to ensure that those LSGUs that were already achieving 

high rates of recycling in 2015 are not penalised. 

9)  Ensuring the definition of residual waste clearly indicates that residual waste is defined 
as all mixed municipal waste, minus any materials which are sorted from mixed waste 
for recycling. This is important since the target for LSGUs is linked to the amount of 
residual waste generated 

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Pay-as-you-throw schemes 

10) Development of guidelines with technical and organisational details with a view to 

speeding up the implementation of such schemes throughout the country.  

Communication and awareness-raising 

11) Development of a set of national communications materials addressed to the public for 
use at local level, with clear and consistent messages. These materials should be used as 
part of awareness-raising campaigns, in leaflets, and at civic amenity sites (green 
points). 

Technical support to municipalities 

12) Development  of  a  system  at  national  level  that  provides  technical  support  for 

municipalities, specifically in the following areas: 

a.  choosing collection services;  
b.  service procurement; 
c.  service management; 
d.  communication campaigns; 

coupled with active sharing of good ideas and practices that can improve efficiency in terms 
of cost reduction and improvement in performance. 

Use of EU funds 

13) Review of spending priorities / fund allocation from EU funds to align the relevant 
operational programme for cohesion policy funds with the 2017 national waste 
management plan and waste prevention programme. Current allocation remains too 
heavily focused on residual waste treatment infrastructure to be provided at the regional 
waste management centres instead of support for separate collection of dry recyclables 
and of bio-waste. 

14) Prioritising funding of ‘whole system’ changes while avoiding funding of ad hoc 

projects - ensuring a more structural approach that improves the whole system, rather 
than just some components of a good system. 

15) Awarding  funding on the condition that the LSGUs commit to implementing high 

quality collection services in line with the minimum service standards (see action 6), so 
that the funding is oriented towards delivering results and sub-standard and 
underperforming systems do not get funded. 

Regional approach to waste management 

16) Consideration of a regional approach to achieving the targets. Differences in their 

current performance (due to geography, tourism) suggest the regions may require quite 
specific operational considerations to be taken into account to improve waste 
management. 

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