COMMISSION STAFF WORKING DOCUMENT The early warning report for Sweden 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 identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target
Date: 2023-06-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Sweden, application of EU law, carbon neutrality, circular economy, municipal waste, packaging product, prevention of pollution, storage of waste, waste recycling

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   EUROPEAN COMMISSION  Brussels, 8.6.2023  SWD(2023) 200 final  COMMISSION STAFF WORKING DOCUMENT  The early warning report for Sweden              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  identifying Member States at risk of not meeting the 2025 preparing for re-use and recycling target for municipal waste, the 2025 recycling target for packaging waste and the 2035 municipal waste landfilling reduction target        {COM(2023) 304 final} - {SWD(2023) 175 final} - {SWD(2023) 176 final} - {SWD(2023) 180 final} - {SWD(2023) 181 final} - {SWD(2023) 182 final} - {SWD(2023) 183 final} - {SWD(2023) 184 final} - {SWD(2023) 185 final} - {SWD(2023) 186 final} - {SWD(2023) 187 final} - {SWD(2023) 188 final} - {SWD(2023) 189 final} - {SWD(2023) 195 final} - {SWD(2023) 196 final} - {SWD(2023) 197 final} - {SWD(2023) 198 final} - {SWD(2023) 199 final}  
 
 
1.  Introduction 

The early warning report aims to assist Member States at risk of failing to meet: (i) the 2025 target of 55% for 
the preparing for re-use and the recycling of their municipal waste (this target is set out in Article 11(2)(c) of 
Directive 2008/98/EC); and (ii) the 2025 target of 65% for the recycling of their packaging waste (this target 
is set out in Article 6(1)(f) of Directive 1994/62/EC). It also provides an update on how Member States are 
performing against the 2035 target to send no more than 10% of their municipal waste to landfill (this target 
is set out in Article 5(5) Directive 1999/31/EC).  

This report builds on previous support provided by the Commission to help Member States comply with EU 
law on municipal waste management, including, where relevant, the early warning report from 2018. 

The assessment underpinning the early warning report identified 18 Member States at risk of missing the 2025 
preparing for re-use and recycling target for municipal waste, 10 of which are also at risk of missing the 2025 
recycling target for all packaging waste. 

This assessment is based on a collaborative and transparent process involving the Member States concerned, 
the European Environment Agency1, and an in-depth analysis of the most recent policy developments in the 
Member States. This process also involved extensive consultation with the Member State authorities in charge 
of waste management. The possible actions identified during this process are based on existing best practices 
and aim to help Member States meet the 2025 targets, and as such they focus on policy measures which can 
be  taken  in  the  short  term.  These  actions  should  be  seen  as  complementary  to  those  recommended  in  the 
roadmaps  which  were  drawn  up  as  part  of  preceding  compliance-promotion  activities  and  to  those 
recommended in the Environmental Implementation Review2. 

2.  Key findings 

Based on the analysis of existing and firmly planned policies in the area of waste management,  Sweden is 
considered to be at risk of missing the 2025 target of 55% for the preparing for re-use and the recycling of its 
municipal waste.  

The  recycling  rate  for  municipal  waste  reported  by  Sweden  was relatively  stable  between  2015 and  2019, 
although it fell slightly from its 2016 peak of 48.4% to 46.6 % in 2019. In the same period, the incineration 
rate increased, reaching 53% in 2019. Since 2020, Sweden has applied the new calculation rules for municipal 
waste recycling3, which made the rate drop to 38.3%. This means that Sweden’s recycling rate for municipal 
waste is 16.7 percentage points below the 2025 target of 55%. 

Although hardly any municipal waste is directed to landfills (the landfill rate was less than 1% in 2020), most 
of  it  is  directed  to  incineration  plants,  showing  a  strong  reliance  on  this  treatment.  The  rate  of  waste 
incineration, which increased to about 60% in 2020, is over twice the EU average of 27%.   

For packaging waste, Sweden reported a recycling rate of 63.6% in 2019. However, the packaging recycling 
rates  might  be  lowered  by  the  application  of  the  new  calculation  rules4;  in  2020  the  recycling  rate  for  all 
packaging waste decreased to 60.9%, 4.1 percentage points below the 2025 recycling target for packaging 

1 EEA and ETC/CE (2022). Early Warning Assessment Related to the 2025 Targets for Municipal and Packaging 
Waste (https://www.eea.europa.eu/publications/country-profiles-early-warning-assessments) 
2 European Commission (2022). Environmental Implementation Review 2022. COM/2022/438 final. (https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=comnat%3ACOM_2022_0438_FIN).  
3 Commission Implementing Decision (EU) 2019/1004. 
4 Commission Implementing Decision (EU) 2019/665. 

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waste of 65%. For 2020, all reported recycling rates for specific packaging materials reached or exceeded the 
respective targets to be achieved by 2025, with the exception of plastic and wooden packaging.  

Low recycling rates are mainly due to: 

- 

- 

- 

low capture rates of paper, cardboard, plastic and biowaste in the separate collection system, and, 
generally, low density of the ‘bring point’ system for waste collection; 
lack  of  support  mechanisms  to  ensure  the  separate  collection  of  municipal  waste  fractions  from 
businesses; 
the fact that waste incineration remains the predominant form of waste treatment in Sweden. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Sweden’s  efforts  to  improve  its  performance  in  waste 
management, three main recommendations are listed below. 

1.  Support preparing for re-use of municipal waste and re-use systems for packaging. 
2.  Develop  waste  treatment  infrastructure  associated  with  the  higher  steps  of  the  waste  hierarchy  to 

reduce reliance on incineration, including for the recycling of plastic packaging. 

3.  Improve separate collection services for waste fractions separated at source – in particular packaging 

and biowaste – to ensure high capture rates across the country.  

4.  Introduce support mechanisms to ensure the separate collection of recyclable municipal waste from 

businesses. 

The table below lists some possible actions to support Sweden’s efforts to improve its performance in waste 
management. 

4.  Good practices 

The  following  measures  implemented  by  Sweden  are  considered  good  practices  that  help  to  improve  its 
recycling performance. 

-  Landfilling  bans  for  certain  waste  types  –  The  Swedish  ban  on  landfilling5  of  combustible  waste 
(introduced in 2002) and organic waste (introduced in 2005) has led to a low landfill rate, with less 
than 1% of municipal waste landfilled in 2021.  

-  Co-funding  programmes  for  biogas  plants  –  According  to  the  Swedish  government6,  many  biogas 
plants  based  on  anaerobic  digestion  have  been  built  with  the  support  of  co-funding  programmes 
between municipalities and the private sector. These programmes lead to: (i) greater collection of food 
waste  from  businesses  and  households,  thus  providing  feedstock  to  the  digesters;  and  (ii)  the 
construction of treatment facilities close to the system for collecting food waste. Biogas is used as fuel 
in local transport and waste collection vehicles. 

-  Local incentives for waste prevention – The municipality of Gothenburg introduced specific measures 
for reducing waste generation within the municipality’s own activities. One measure includes a target 
to reduce the waste generation per a full-time employee by 40% between 2020 and 2030, while others 
target  the  prevention  of  specific  waste  types  such  as  food  waste,  electronic  waste  and  single-use 
products7. This has resulted both in less waste and in lower costs for the municipality itself and for 
households. The measures have been carried out in cooperation with staff working within retirement 
homes, schools, pre-schools, offices, public-meal establishments, and apartment buildings. The work 

5 Förordning (2001:512) om deponering av avfall. 
6 Local investments supported by the Swedish EPA. 
7 Waste Managaement Plan of Gothenburg Municipality.  

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has been successful and has inspired other municipalities to implement the same model as the one 
developed in Gothenburg. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE RECYCLING PERFORMANCE 

Governance 

1)  Introduce support mechanisms (such as municipal guidance for companies) to ensure the separate 
collection of recyclable municipal solid waste from businesses in order to increase the capture rates 
of fractions separated at source.  

2)  In  order  to  achieve  both  high  capture  rates  and  high  quality  in  collected  waste,  set  mandatory 
objectives or indicators for separate waste collection for municipalities or other bodies (e.g. private 
waste operators in charge of the separate collection). This could be complemented by economic or 
other incentive mechanisms which would reward or penalise bodies according to their performance. 
Information on the performance of the local collection system could also be made available to the 
general public to raise awareness (e.g. on a website).  

Prevention 

3)  Take measures to increase re-use and to prevent the generation of non-recyclable municipal waste. 

Separate collection 

4)  Increase  the  capture  rates  of  separately  collected  municipal  waste  by  fully  implementing  high-
convenience door-to-door collection for recyclable waste types. Consider swifter implementation 
of the legislation on mandatory separate collection of biowaste. 

Waste treatment  

5)  Support  preparing  for re-use  of  municipal  waste and develop  waste treatment  infrastructure  that 
focuses on the higher steps of the waste hierarchy to reduce reliance on incineration, including for 
the recycling of plastic packaging.  

Communication and awareness-raising 

6)  Maintain and strengthen awareness-raising activities specifically tailored to different target groups 
(e.g. households, commercial waste generators, rural and urban areas, teachers, and pupils) to 
increase participation in separate collection, and in particular when rolling out new separate 
collection services.  

Extended producer responsibility and economic instruments 

7)  Use economic instruments to incentivise waste management associated with the higher steps of the 
waste hierarchy. This will help to make reuse, preparation for reuse and recycling economically 
attractive and reduce dependency on landfilling. The economic incentive should be designed and 
sufficiently large to be effective and steer waste management up the waste hierarchy. 

8)  Stepping up efforts to establish reuse systems for packaging will bring environmental benefits and 

help Member States in complying with the EU packaging recycling targets. 

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