COMMISSION STAFF WORKING DOCUMENT The Early Warning report for Poland 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 compliance with Article 11(2)a of Directive 2008/98/EC
Date: 2019-01-17
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Poland, 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, 17.1.2019 SWD(2018) 426 final/ 2  This document corrects document SWD(2018) 426 final of 24.09.2018  Corrections to the list of possible actions.  The text shall read as follows: COMMISSION STAFF WORKING DOCUMENT The Early Warning report for Poland 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 compliance with Article 11(2)a of Directive 2008/98/EC {COM(2018) 656 final} - {SWD(2018) 413 final} - {SWD(2018) 414 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}  
 
 
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 of the 'Early Warning report for Poland' 

In 2016, Poland’s municipal waste recycling rate (including composting) reported to Eurostat 
was  44 %,  while  the  landfilling  rate  was  37 %.  However,  for  compliance  with  the  target 
Poland  chose  to  report4  the  recycling  rate  of  four  fractions  of  municipal  waste  —  paper, 
plastic,  metal  and  glass  –  which  was  27  %  in  2015.  Based  on  an  analysis  of  existing  and 
firmly  planned  policies  in  the  area  of  waste  management,  and  on  Poland’s  performance  to 
date,  Poland  is  considered  at  risk  of  missing  the  2020  target  of  50  %  preparation  for  re-
use/recycling for municipal waste. 

The assessment5 that underpins the early warning report concludes that  

the separate collection of recyclables is not yet being carried out effectively; 

 
  economic incentives for households to separate waste are lacking; 
 

the  extended  producer  responsibility  (EPR)  schemes  in  Poland  do  not  operate 
efficiently; and 

  some  reservations  on  the  quality  of  waste  data  undermine  the  reliability  of  the  high 

recycling rates reported to Eurostat. 

1 http://ec.europa.eu/environment/waste/framework/support_implementation_1st_phase.htm 
2 Roadmap for Poland: http://ec.europa.eu/environment/waste/framework/pdf/PL_Roadmap_FINAL.pdf 
3 http://ec.europa.eu/environment/eir/country-reports/index2_en.htm 
4 In line with Commission Decision 2011/753/EU, Member States may choose a different method than the one 
used by Eurostat to calculate their recycling rates and track compliance with the 2020 target of 50 % recycling 
of municipal waste. 
5 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: Poland.’ 

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

OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Extended Producer Responsibility for packaging waste 

1)  Improvements  to  the  EPR  system  for  packaging  and  alignment  with  the  general 
minimum requirements in the revised Waste Framework Directive, while ensuring, 
specifically  that  producers  provide  better  cost  coverage,  including  the  cost  of 
dealing with unrecycled packaging disposed of by households as residual waste. 
2)  Improvements to the quality of data reported on packaging placed on the market. 

Financial incentives for regional enforcement of municipal targets 

3)  As  the  annual  recycling  target  for  municipalities  increases  to  50 %  in  2020,  the 
number of municipalities failing to meet it is likely to increase. Guidance from the 
Ministry  of  Environment  on  the  consistent  application  of  fines  for  failing  to  meet 
the target would be beneficial to ensure they act as the required deterrent. 

Technical support to municipalities 

4)  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. 

5)  Research 

into  best  practices  and  monitoring  (e.g. 

through  a  survey)  of 
municipalities’  implementation  of  the  sorting  obligation,  getting  their  feedback  on 
challenges and barriers and developing tools to support them. 

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