COMMISSION STAFF WORKING DOCUMENT The early warning report for Finland 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, Finland, 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) 175 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Finland         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) 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} - {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 firmly planned policies in the area of waste, Finland 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.  

For 2020, the municipal waste recycling rate reported by Finland was 41.6%, which is 13.4 percentage points 
below the target of 55%. The upcoming application of the new calculation rules for municipal waste recycling4 
might also result in a lower recycling rate. The recycling rate has remained stable over the past 5 years (from 
2016 to 2020). 28% of Finland’s generated municipal waste undergoes material recycling (dry recyclables), 
and  13%  is  treated  in  anaerobic  digestion  plants  or  composting  plants  (biowaste).  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, implying a strong reliance on this treatment (Finland’s 58% incineration rate for municipal 
waste was about twice the EU average in 2020).  

On packaging waste, Finland reported a recycling rate of 70.6% in 2019, 5.6 percentage points above the 2025 
target for 65% of all packaging waste to be recycled. In 2020 the recycling rates for all waste packaging was 
73.2% (with the application of the new calculation rules5). However, Finland is considered at risk of missing 
the target to recycle 50% of its plastic packaging. Although the recycling rate for plastic packaging waste has 

1 An early-warning report was issued for Finland in 2018 (SWD(2018) 417 final). A total of 12 recommendations were 
provided.  According  to  the  Finish  authorities,  6  of  the  report’s  recommendations  are  considered  implemented  and  6 
partially 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) 
4 Commission Implementing Decision (EU) 2019/1004. 
5 According to Commission Implementing Decision 2019/665. 

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increased by almost 15% during the past 5 years (from 2016 to 2020), the reported recycling rate for plastic 
packaging was only 39.4% in 2020.  

It is acknowledged that Finland has recently put in place several actions to address the situation and achieve 
the targets. Recycling rates for all packaging waste streams show an increase in the period 2015-2019 (before 
dropping in 2020). For municipal waste however, a stagnating recycling rate indicates  that this has not yet 
resulted in measurable effects, since the implementation of measures across the country will take a few years. 
Therefore, improvements are still needed to reach all 2025 targets. Low recycling rates are mainly due to: 

- 

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low capture rates of separately collected recyclables (based on the residual waste composition and the 
amounts of separately collected waste, it is found that the capture rates are particularly low for plastic 
waste and biowaste);  
the fact that waste incineration remains the predominant form of waste treatment in Finland. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Finland’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.  Raise  the  frequency  and/or  convenience  of  separate  collection,  notably  of  plastic  packaging  and 

biowaste.  

3.  Maintain  and  extend  awareness-raising  programmes  that  target  waste  prevention  and  greater 

separation of waste at the source, in particular for plastic packaging and biowaste.  

4.  Implement  economic  instruments  to  direct  recyclables  away  from  waste  incineration  towards  the 

higher steps of the waste hierarchy. 

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

4.  Good practices 

The following measures implemented by Finland are considered good practices that could be replicated and 
that could help Member States to achieve the targets. 

-  Deposit-refund scheme for beverage packaging – The deposit-refund scheme covers a broad spectrum 
of  different  containers  used  for  non-alcoholic  drinks,  alcoholic  drinks,  and  all  main  packaging 
materials  except  for  liquid  packaging  board.  The  great  convenience  of the  scheme  has  led  to  high 
return  rates  (aluminium  cans:  96%;  plastic  bottles:  92 %;  reusable  glass  bottles:  88%;  other  glass 
bottles:  97%).  Although  the  deposit-refund  scheme  is  voluntary  in  Finland,  it  covers  almost  all 
beverage packaging. By joining a deposit system, beverage manufacturers and importers are exempted 
from  the  beverage-packaging  tax  (EUR 0.51  per  litre),  but  still  fulfil  their  extended  producer 
responsibilities. This generates a strong economic incentive for joining the scheme6,7. 

-  System to reuse wooden pallets – Reuse and recycling companies buy used wood pallets, check them, 
sort them, and repair them if needed using robotics. They then sell them to further the reuse of the 
pallet. The incentive for customers to return and reuse pallets is the significantly lower price of renting 
the pallets from providers rather than buying them. The service provider rents out the pallets and takes 
care of their repair and reconditioning. The service covers the entire country8. 

6 https://www.ely-keskus.fi/web/tuottajavastuu/yritykselle. 
7 https://www.palpa.fi/beverage-container-recycling/deposit-refund-system/. 
8 https://www.lt.fi/fi/yritysasiakkaat/palvelut/kierratyspalvelut-ja-jatehuolto/kuormalavapalvelut. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE RECYCLING PERFORMANCE 

Governance 

1)  Set mandatory objectives or indicators for  separate waste collection at the level of the bodies in 
charge of the collection of municipal waste (e.g. municipalities) in order to monitor, enforce and 
achieve higher capture rates. This could be complemented with a system of financial rewards and 
penalties  dependant  on  the  performance  of  the  bodies  on  those  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 

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

Separate collection 

3)  Implement separate collection of biowaste and dry recyclables across the country, including in rural 
areas. This will help to increase the capture rate, quality and convenience of separate collection of 
recyclable waste streams (especially biowaste and plastic packaging waste). 

Waste treatment  

4)  Support preparing for re-use 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 

5)  Maintain and strengthen awareness-raising activities specifically tailored to different target groups 
(e.g.  households,  commercial  waste  generators,  schoolteachers  and  students)  to  increase 
participation in separate collection. These activities are especially important to support the rolling 
out  of  new  separate-collection  services.  Awareness-raising  activities  should  also  have  a  special 
focus on biowaste and home composting.  

Extended producer responsibility and economic instruments 

6)  Implement economic instruments (e.g. taxes, or application of Emission Trading Scheme rules for 
incineration)  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 will reduce dependency on waste incineration. The economic incentive should be designed and 
sufficiently large to be effective and steer waste management up the waste hierarchy. For example, 
it could include a weight-based pay-as-you-throw system for households. 

7)  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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