COMMISSION STAFF WORKING DOCUMENT The early warning report for Estonia 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, Estonia, 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) 416 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Estonia 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) 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; 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, Estonia’s municipal waste recycling rate (including composting) reported to Eurostat 
was  28 %,  while  its  landfilling  rate  was  10 %.  Based  on  an  analysis  of  existing  and  firmly 
planned policies in the area of waste management, Estonia is considered at risk of missing the 
2020 target of 50 % preparation for re-use/recycling of municipal waste. 

The  assessment4  that  underpins  the  early  warning  report  concludes  that  there  are  some 
structural  problems  in  Estonia  leading  to  slow  progress  in  recycling.  These  structural 
problems  include  regulatory  barriers  that  cause  uncertainty  (for  example,  the  fact  that 
municipalities can choose  between tendering for  the market and competition in the market) 
and  the  lack  of  effective  instruments  in  place  to  force  municipalities  to  comply  with  the 
recycling  targets.  Separate  collection  is  not  yet  being  carried  out  efficiently,  the  extended 
producer  responsibility  (EPR)  schemes  for  packaging  are  not  sufficiently  integrated  with 
municipal collection services, and there are insufficient incentives for households to separate 
waste. Moreover, there is no incineration tax to shift waste disposal towards recycling. 

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

1 http://ec.europa.eu/environment/waste/framework/support_implementation_1st_phase.htm 
2 Roadmap for Estonia: http://ec.europa.eu/environment/waste/framework/pdf/EE_Roadmap_FINAL.pdf 
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: Estonia.’. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Economic incentives 

1)  Setting  mandatory  targets  at  municipal  level  either  for  recycling  or  potentially  for 
residual  waste  (depending  on  the  availability  of  data)  with  financial  penalties  for 
municipalities that fail to meet the targets. 

2)  Removing regulatory uncertainty around the potential ways in which municipalities can 
operate  waste  services.  This  would  help  the  municipalities  implement  waste  recycling 
targets.  Different  solutions  will  be  required  in  the  ‘free  market’  approach  where 
households  can  choose  the  waste  collection  company,  and  in  the  ‘tender-based’ 
approach  where  all  households  within  one  municipality  are  served  by  one  contractor 
selected via tender. 

3)  Implementation of a residual waste tax to increase costs of disposal and provide a clear 
economic  incentive  to  introduce  recycling  services.  The  tax  should  include  landfill, 
incineration  and  any  other  mixed  waste  treatment  activity  in  order  to  support  re-use, 
preparation for re-use, recycling and composting of separately collected bio-waste. 

Extended producer responsibility 

4)  Clear  distribution  of  responsibilities  for  the  management  of  packaging  waste  between 
municipalities  and  producer  responsibility  organisations  (PROs).  The  contractual 
arrangements  between  them  should  allow  the  municipalities  to  influence  decisions 
regarding the packaging collection systems’ performance (which is the responsibility of 
the PROs). 

5)  Ensuring the fees paid by producers cover the full cost of collection of packaging waste. 
This  will  provide  the  price  signal  to  those  running  the  collection  service  to  increase 
recycling  performance,  and  thus  avoid  taxes  on  residual  waste  (implemented  in  line 
with action 3). 

Separate collection 

6)  Further  implementation  of  pay-as-you-throw  through  national  legislation.  Research 
studies  and  trials  should  be  carried  out  to  ensure  the  most  effective  schemes  are 
designed and operated. 

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. 

8)  Setting  up  civic  amenity  sites  (using  national/EU  funds),  starting  in  municipalities 
where  the  collection  service  is  most  advanced  (for  example,  where  door-to-door 
separate collection is becoming well established) to maximise the likely effectiveness of 
the sites. This would also allow best practices to be identified and used as a model for 
other municipalities. 

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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. 

Technical support to municipalities 

10) 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. 

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