COMMISSION STAFF WORKING DOCUMENT The early warning report for France 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, France, application of EU law, carbon neutrality, circular economy, municipal waste, packaging product, prevention of pollution, storage of waste, waste recycling

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  EN 

   EUROPEAN COMMISSION  Brussels, 8.6.2023  SWD(2023) 184 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for France         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) 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} - {SWD(2023) 200 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  collected  data  and  existing  policies  in  the  area  of  waste  management,  France  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. France is on track to meet the 2025 target to recycle 65% of all packaging waste. However, 
the country is at risk of not meeting the 2025 target of 50% that applies specifically to plastic packaging. 

France’s recycling rate for municipal waste steadily increased from 42.9% in 2016 to 45.1% in 2018 but has 
been decreasing since then. In 2020, the recycling rate was 42.7%. In addition, new rules for calculating waste 
recycling start to apply3, and this might result in lower recycling rates. The landfilling rate decreased from 
22.4%  in  2016  to  18.1%  in  2020,  getting  closer  to  the  2035  target.  France  has  a  relatively  high  level  of 
incineration of municipal waste: it was 38.1% in 2020, which is higher than the EU average of 27%. 

France is already reporting higher recycling rates for packaging waste than the recycling targets (65.6% in 
2019  vs  the  target  of  65%);  targets  have  also  been  reached  for  most  types  of waste  packaging  (paper  and 
cardboard, metal, wooden and glass packaging). However, the recycling rate for plastic packaging waste is far 
from the 50% target (26.9% in 2019). In addition, applying the new calculation rules for packaging4 might 
result in lower recycling rates (in 2020 the recycling rate for all packaging waste was 60.3%).  

Some of the main challenges facing waste management in the country are listed below. 

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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-  The collection and treatment of municipal biowaste is insufficient. The separate collection of biowaste 
is not common in France; only a small share of the population is covered by a separate collection 
scheme. 

-  The capture of plastic packaging in the separate collection systems is insufficient, introducing deposit-

refund schemes for plastic packaging can increase those capture rates. 

-  Extended producer responsibility (EPR) schemes do not cover commercial plastic packaging waste; 
in addition, in some parts of the country, EPR schemes do not cover all types of plastic packaging 
products. 

France has introduced many new measures that should produce better results in the coming years. However, 
as it usually takes time before the full effects of such measures can be observed, efforts should be intensified 
significantly for all of 2025 targets to be reached. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  France’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.  Improve separating and collecting biowaste at source and ensure there is enough dedicated 

capacity for treating it. 

3.  Implement  a  pay-as-you-throw  system,  which  covers  the  entire  population  and  gives  further 

incentives to the public to separate waste at source. 

4.  Improve and extend separate collection systems, especially for plastic waste, and ensure that all 

types of plastic packaging waste are separately collected. 

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

4.  Good practices 

The following measures implemented by France are considered good practices that could be replicated and 
help Member States in attaining the above-mentioned targets: 

-  A  national  focus  on  Extended  Producer  Responsibility  (EPR)  –  New  EPR  schemes  have  been 
developed  to  promote  recycling  of  new  products  between  2021  and 2025 (professional  packaging, 
construction products or materials from the building sector, toys, sports and leisure equipment, do-it-
yourself  and  gardening  products,  sanitary  textiles,  fishing  gear,  and  cigarette  butts).  Therefore,  25 
product families will be covered by an EPR system by 2025. The governance of EPR sectors is open 
to other parties (besides producers) such as local authorities, environmental protection associations, 
waste prevention and management operators, and the state. 

-  Waste prevention – The 2020 anti-waste law5 introduced several measures on waste prevention. One 
of these measures is funding, financed by producers under EPR schemes, for repairing and reusing 
certain  products  (electrical  and  electronic  equipment,  furniture,  textile  clothing,  etc.).  Funding  is 
reserved for businesses that operate in the social and solidarity economy. In addition, consumers have 
access to a repairability index that lets them to choose electric and electronic appliances that are easier 
to  repair.  Other  measures  include  labelling  products  with  information  on  recycled  content  and 
recyclability. 

5  Loi  n°  2020-105  du  10  février  2020  relative  à  la  lutte  contre  le  gaspillage  et  à  l’économie  circulaire, 
https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759/and 
https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000042169391. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  To  monitor,  enforce  and  achieve  higher  capture  rates,  mandatory  objectives  or  indicators  for 
separate waste collection should be set by the bodies in charge of the collection of municipal waste 
(e.g. municipalities). This could be complemented with a system of financial rewards and penalties 
for  those  entities  depending  on  whether  they  achieve  the  targets  or  not.  The  performance  of 
municipalities  could  also  be  made  available  to  the  general  public  to  raise  awareness  (e.g.  on  a 
website). 

Prevention 

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

Separate collection 

3)  Roll  out  high-convenience  collection  services  to  a  larger  part  of  the  population,  especially  for 
biowaste. A door-to-door collection for biowaste is recommended, particularly in dense urban areas 
where local composting is a challenge. 

4)  Improve the separate collection of plastic waste. In some parts of the country, only specific types of 
plastic packaging waste are currently collected separately. All plastic packaging waste should be 
collected separately throughout the entire country, and the sorting infrastructure should be extended 
in capacity and modernised accordingly. 

Waste treatment  

5)  Develop waste treatment infrastructure associated with the higher steps of the waste hierarchy. Firm 
plans and concrete action are needed, such as further supporting home composting and increasing 
the capacity for treating biowaste to accommodate its separate collection. 

6)  Support preparing for reuse of municipal waste and develop waste-treatment infrastructure in a way 
that focuses on the higher steps of the waste hierarchy. Firm plans and concrete actions are needed, 
such as supplementing centralised biowaste treatment with decentralised composting solutions such 
as home composting and community composting. 

Communication and awareness-raising 

7)  Maintain and reinforce awareness raising activities about waste prevention, littering and separate 
collection. A set of national communication materials should be developed that: (i) are addressed to 
the general public for use at local level; (ii) have clear and consistent messages; and (iii) have a 
particular focus on biowaste, separate collection and sound management of waste. These materials 
should be used in awareness-raising activities on social media and the internet and at civic amenity 
sites. 

Extended producer responsibility and economic instruments 

8)  Expand  the  application  of  the  Pay-as-you-throw  system  to  both  businesses  and  households  to 
achieve higher capture rates for recyclable fractions and reduce residual waste. Local authorities 
could  be  supported  through  guidance  on  how  to  design  incentive  mechanisms  and  create  pilot 
projects to test and refine them. 

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9)  Implement economic instruments (e.g. a landfill tax of a sufficient magnitude) to incentivise waste 
management associated with the higher steps of the waste hierarchy. This will make waste sorting, 
collection  and  recycling  more  effective  and  make  re-use,  preparation  for  re-use  and  recycling 
economically  attractive.  The  economic  incentive  should  be  designed  and  sufficiently  large  to 
develop a ‘steering effect’. 

10) Introduce a Deposit-refund scheme so that more beverage packaging (bottles and cans) is re-used 

and recycled.  

11) Stepping up efforts to establish re-use systems for packaging will bring environmental benefits 

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

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