COMMISSION STAFF WORKING DOCUMENT The early warning report for Malta 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, Malta, 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) 195 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Malta             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) 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 20181. 

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 Agency2, 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 Review3. 

2.  Key findings 

Based on an analysis of existing and planned policies in the area of waste management, Malta is considered to 
be at risk of missing: (i) the 2025 target of 55% for the preparing for re-use and the recycling of its municipal 
waste; and (ii) the 2025 target to recycle 65% of its packaging waste. There is also a large gap between the 
percentage of municipal waste currently sent to landfill and the 2035 target that no more than 10% of municipal 
waste should be landfilled. 

In 2020, the municipal waste recycling rate (including composting) reported by Malta to Eurostat was 10.5%, 
while the landfill rate was 82.5% (over three times the EU average). In addition, Malta is also lagging behind 
when it comes to: (i) the recycling target for all packaging waste (only 40% of which is recycled compared 
with an EU target of 65 %); and (ii) recycling targets for most material-specific packaging-waste streams (such 
as plastics, metals and glass).  General recycling trends in Malta are also of concern: the recycling rate for 
municipal waste has decreased slightly in recent years, falling by 2.2 percentage points between 2016 and 2020 
from 12.7% to 10.5%. The recycling rate for packaging waste has also fallen, by 3.4 percentage points from 
37.1% to 33.7% between 2015 and 2019; in 2020 the recycling rate for all packaging waste increased to 40%. 

1 An early-warning report was issued for Malta in 2018 (SWD(2018) 421 final). A total of 17 recommendations were 
provided. According to the Maltese authorities, 6 of the report’s recommendations are considered as being 
implemented, 10 partially implemented, and 1 not implemented. 
2 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) 
3  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) 

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The percentage of municipal waste sent to landfill increased by 7.8 percentage points between 2016 and 2020 
from 74.7% to 82.5%.  

Some of the main challenges in waste management include: 

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low capture rates of recyclable waste in the separate collection system (40% for dry recyclables and 
34% for biowaste). The high touristic activity in Malta – approximately 2.5 million tourists per year – 
presents specific challenges to increasing the capture rates; 
insufficient infrastructure for recycling of waste instead of landfilling (i.e. insufficient sorting-plant 
capacity for separately collected waste and for commingled dry recyclables); 
limited  use  of  compost  (i.e.  compost  is  used  for  landscaping  and  landfill  remediation  instead  of 
recycling for agricultural purposes). 

It is acknowledged that several actions have been recently put in place by Malta to reverse the current situation 
and achieve the targets4. However, this has not yet resulted in measurable effects. Significant improvements 
are needed to bring Maltese waste-management practices into line with the EU’s waste hierarchy.  

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Malta’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.  Further invest in infrastructure for separate collection, sorting and recycling. 
3.  Implement a pay-as-you-throw system for both businesses and households.  
4.  Ensure that compost and digestate from biowaste treatment plants are used for land improvement and 

fertilising. 

The table below lists a number of possible actions to support Malta’s efforts to improve its performance in 
waste management. 

4.  Good practices 

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

-  Campaigns to raise awareness of sound waste management – Several campaigns have been conducted 
to raise awareness among the general public of waste prevention, source separation, waste collection, 
and  the fight  against  littering.  These  campaigns  included  the  creation  of  materials  for  schools  and 
pupils such as comics on waste management (see Ecohive kids5). 

-  Development of an integrated waste management infrastructure – Malta has developed a new waste 
management infrastructure in a highly integrated manner. It did this by adding to existing treatment 
capacity and building brand-new treatment capacity for activities such as waste incineration, material 
recovery, biowaste processing, etc. This approach will make it possible to achieve economies of scale 
and significant synergies for waste management (see Ecohive project6).  

4 Malta has started to plan and commission several additional treatment plants, and is also working to improve the 
collection systems for dry recyclables and biowaste. Echohive (https://www.ecohive.com.mt/). 
5 https://www.ecohive.com.mt/kids.  
6 https://www.ecohive.com.mt/# 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Clearly identify the authorities and entities responsible (at national, regional, and waste-operator 
level) for achieving the target of 55% for the preparing for re-use and the recycling of municipal 
waste. 

2)  Set mandatory objectives or indicators for  separate waste collection at the level of the  bodies in 
charge of collecting municipal waste (e.g. municipalities) in order to monitor, enforce and achieve 
higher capture rates. This could be complemented with performance-bound financial rewards and 
penalties  dependant  on  the  achievement  of  the  targets.  Information  on  the  performance  of 
municipalities  could  also  be  made  available  to  the  general  public  to  raise  awareness  (e.g.  by 
publishing on a website). 

Prevention 

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

4)  Ensure proper monitoring of the implementation of waste prevention measures, including through 
appropriate  qualitative  or  quantitative  indicators  and  targets  and  sufficient  resources  for  this 
monitoring. Promote coordination between the central and the local government to achieve the EU’s 
waste-prevention objectives. 

Separate collection 

5)  Improve the convenience of separate collection systems and require businesses to have their waste 
streams collected separately to increase capture rates for dry recyclables and biowaste and reduce 
landfilling. Malta should aim to double its capture rate and improve the purity of its waste fractions. 
The challenges posed by tourism to separate collection should also be duly considered.  

Waste treatment  

6)  Support  preparing  for re-use  of  municipal  waste and  develop  waste treatment  infrastructure  that 
focuses on the higher steps of the waste hierarchy. Build sufficient sorting capacity and ensure that 
the sorted waste is of sufficiently high quality to be accepted by recycling plants. This will ensure 
that pre-sorted waste is destined for recycling and reduce landfilling and incineration; extension of 
the treatment plants is foreseen. 

7)  Compost and digestate from biowaste treatment plants should be used for land improvement and as 
fertiliser.  To  ensure  production  of  high-quality  compost/digestate  across  the  country,  national 
standards  for  the  quality  of  compost/digestate  should  be  implemented  by  means  of  a  quality-
management system. To ensure acceptability among the users of this digestate (such as the farming 
community), the relevant parties should be involved in developing these standards. 

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Communication and awareness raising 

8)  Maintain and strengthen activities to raise awareness of waste prevention, littering and separate 

collection (especially in areas related to tourism, such as hotels and restaurants). Develop a set of 
national communication materials addressed to different target groups (e.g. households, 
commercial waste generators, schoolteachers, and students) for use at local level, with clear and 
consistent messages. These materials should be used as part of awareness-raising activities, in 
leaflets, on social media, on the internet, and at civic amenity sites. 

Extended producer responsibility and economic instruments 

9)  Set up a pay-as-you-throw system for both businesses and households to attain higher capture 
rates for recyclable fractions and reduce residual waste. Local authorities could be supported 
through guidance on how to design the incentive mechanisms and how to introduce and learn 
from pilot projects. 

10) Implement economic instruments (e.g. raising landfill taxes to a sufficiently high level and 

introducing an incineration tax) to incentivise waste management associated with the higher steps 
of the waste hierarchy. This will help to make reuse, preparing for reuse and recycling 
economically attractive, and reduce dependency on landfilling. The economic incentives should 
be sufficiently large and designed to be effective and steer waste management up the waste 
hierarchy. Landfill taxes that increase over time in correlation to specific targets are considered 
the most effective. 

11) 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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