COMMISSION STAFF WORKING DOCUMENT The early warning report for Finland 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: EU environmental policy, Finland, application of EU law, circular economy, environmental law, environmental protection, pollution control, prevention of pollution, waste, waste management

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  EN 

   EUROPEAN COMMISSION  Brussels, 24.9.2018 SWD(2018) 417 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Finland 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) 414 final} - {SWD(2018) 415 final} - {SWD(2018) 416 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,  Finland’s  municipal  waste  recycling  rate  (including  composting)  reported  to 
Eurostat  was  42 %.  Its  incineration  rate  was  55 %,  while  its  landfilling  rate  was  only  3 %. 
Based  on  an  analysis  of  existing  and  firmly  planned  policies  in  the  area  of  waste 
management,  and  despite  a  fairly  good  performance  in  the  past  few  years,  Finland  is  still 
considered at risk of missing the 2020 target of 50 % preparation for re-use/recycling target 
for municipal waste. 

The  assessment4  that  underpins  the  early  warning  report  concludes  that,  despite  the 
introduction of economic instruments such as a landfill tax, extended producer responsibility 
(EPR) and a high level of awareness among the public, Finland has been stagnating at a fairly 
high  level  but  below  the  50 %  objective.  This  is  considered  to  be  linked  to  fairly  generous 
flexibilities in the obligation to ensure separate collection of dry recyclables and bio-waste, 
and to frequent regulatory changes in recent years that have created uncertainty and led to a 
lack  of  investment.  A  degree  of  inefficiency  in  the  organisation  of  the  EPR  schemes  also 
slows down progress. 

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

1 http://ec.europa.eu/environment/waste/framework/support_implementation.htm 
2 Finland was not part of this exercise and therefore no country-specific roadmap was issued for Finland. 
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: Finland.’ 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Incentives for municipalities / extended producer responsibility 

1)  Introduction of mandatory recycling targets for municipalities in line with the national 

50 % target, and shift of some responsibility back to the municipalities by: 
a.  setting  recycling  or  residual  waste  targets  at  the  municipal  level,  with  fines  for 

failure to meet the targets;  

b.  updating the waste information system, as required;  
c.  revising the Waste Act to redefine the responsibilities of the producer responsibility 
organisations (PROs) and municipalities, to ensure that their services are combined, 
or  coordinated,  and  that  municipalities  have  the  powers  to  make  the  necessary 
system improvements. 

2)  Introduction  of  mandatory 

tri-party  contractual  arrangements  between  PROs, 
municipalities  and  collection  companies  to  drive  cooperation  and  efficiency  savings 
across all levels of waste services, in order to reduce fragmentation. 

Economic instruments 

3)  Setting the cost of disposal at a sufficiently high level to incentivise provision of high 
quality recycling services to the public and use of these services. This could be achieved 
by: 

a.  implementing an incineration tax; 
b.  ensuring  PROs  pay  municipalities  for  any  revenues  obtained  from  the  sale  of 

recyclables; 

c.  creating a mechanism (using surveys of residual waste) to ensure PROs pay an 
additional  fee  for  the  management  of  packaging  in  residual  waste  to  the 
municipalities collecting such waste; 

d.  implementing  country-wide  pay-as-you-throw  systems,  varying  their  approach 
(with regard to volume, weight, etc.) depending on the local circumstances. 

Separate collection 

4)  Extension of the existing obligations to sort recyclables and bio-waste from households 
to cover buildings with any number of flats (without a de-minimis); equal application of 
the  obligations  to  buildings  with  multiple  flats  in  built-up  areas  and  individual 
households  in  suburban  and  rural  areas.  Highly  rural  areas  may  need  some  form  of 
exemption. 

5)  Increasing the roll-out of door-to-door collection. 

6)  Introduction of obligations for businesses to sort their food wastes, plastic, metals, and 

paper/card. 

7)  Development of national minimum service standards for waste collection to specify, for 
example, the type and volume of containers, frequency of collection and type of vehicle 
used,  taking  into  account  the  type  of  housing  stock,  how  rural  the  area  is,  typical 
climate, etc. 

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Technical support to municipalities 

8)  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. 

Communication and awareness-raising programmes 

9)  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. 

Longer-term strategic measures 

10) Reduction of fragmentation of responsibilities for managing waste streams to make the 

sector as a whole – not just partitions of the sector – more efficient. 

11) Analysis  of  the  cost  and  performance  implications  of  taking  a  ‘free-market’  approach 

and considering moving away from this approach if it is found to be costly. 

12) Consideration  of  a  longer-term  strategy  and  vision  for  the  waste  sector,  and 
implementation of a single package of changes to cover a 10- to 15-year period, rather 
than following a more piecemeal approach to improving legislation and practice in the 
sector. 

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