COMMISSION STAFF WORKING DOCUMENT The early warning report for Slovakia 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, Slovakia, 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) 198 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Slovakia            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) 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. 

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 the analysis of collected data and existing policies in the area of waste management,  Slovakia is 
considered to be at risk of missing the 2025 target of 55% for the preparation for re-use and the recycling of 
its municipal waste. While Slovakia has reported levels above the 2025 target to recycle 65% of its packaging 
waste, data quality issues have raised concerns about its actual performance. The distance between Slovakia’s 
current landfilling rate and its 2035 target to landfill no more than 10% of its municipal waste is also of concern. 

Municipal  waste  generation  in  Slovakia  in  2020  (421 kg/person  per  year)  was  below  the  EU  average 
(505 kg/person per year). In particular, packaging waste generated in 2018 was also well below the EU average 
(105 kg/person vs 174 kg/person). This low figure may be an indication that significant quantities of packaging 
placed on the market, the amount of which is used for generated packaging waste, are not reported. 

The recycling rate for municipal waste in Slovakia has increased by almost 20 percentage points in the last 5 
years and reached 42.2% in 2020. However, this increase appears to be more driven by changes in statistical 
reporting than by improved recycling performance. Despite a significant decrease in the landfilling rate in the 
period 2016-2020 (from 65.4% to 49.7 %), Slovakia continues to rely heavily on landfilling (49.7% of waste 
was landfilled in 2020, more than twice the EU average). 

Slovakia’s excessively low capture rate of biowaste (only 36% of generated biowaste was captured in 2020) 
is considered a key factor in limiting the country’s current performance in waste management. Slovakia does 
not have enough capacity to treat all its biowaste, especially given plans to separately collect a greater share 

1 An early-warning report was issued for Slovakia in 2018 (SWD(2018) 421 final). In total, 19 recommendations were 
drafted within the assessment. According to the Slovak authorities, 6 of the report’s recommendations are considered 
implemented, 8 partially implemented, and 5 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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of biowaste as of 2023. The country also still has no legally binding national quality standards for compost 
and no quality management system for compost produced from separately collected biowaste. 

In 2019, the recycling rate for all packaging waste reached 67.5%, which was above the 2025 target of 65%. 
However,  there  are  data  quality  issues  with  regard  to  packaging  waste.  For  instance,  there  is  a  notable 
discrepancy between the relatively low recycling rate for municipal waste and the very high recycling rates for 
packaging waste. The datasets on municipal waste and packaging waste appear inconsistent, given that a large 
share  of  packaging  waste  is  generated  by  households  and  is  thus  part  of  municipal  waste.  In  addition,  the 
upcoming application of new calculation rules4 for packaging waste recycling might result in a lower recycling 
rate. In 2020 the recycling rate for all packaging waste increased to 70.8%; however, the new calculation rules 
were not applied. 

Significant  improvements  are  needed  to  bring  waste  management  in  Slovakia  in  line  with  the  EU  waste 
hierarchy. Some of the main challenges facing waste management in the country include: 

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the lack of economic incentives for householders to separate their recyclable waste at source (in two 
thirds of all municipalities in Slovakia, management fees for collected waste cover only a fraction of 
the actual costs of collecting the waste); 
inefficient and fragmented collection and treatment of municipal waste which does not benefit from 
economies of scale (this is in part due to the great number of municipalities in Slovakia; around 
3 000 in total); 
data quality issues related to the reporting and calculation of national recycling rates, in particular for 
packaging waste. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support Slovakia’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 reduce the dependency on landfilling by increasing landfill taxes, addressing the issue of illegal 

landfilling, and supporting the separate collection and treatment of biowaste. 

3.  Further implement and expand the pay-as-you-throw system for both businesses and households.  
4.  Improve the system for managing the quality of data on packaging waste in order to build coherent 

and verifiable data sets. 

The table below lists further actions recommended to support Slovakia’s efforts to improve its performance in 
waste management. 

4.  Good practice 

The  following  measure  implemented  by  Slovakia  is  considered  an  example  of  good  practice  that  helps  to 
improve its recycling performance. 

-  Study to improve packaging data quality – The Slovak Environment Agency, which is responsible for 
reporting data to Eurostat, has submitted a project proposal under Eurostat’s grant call on ‘Statistics 
for the European Green Deal’. Under the proposed project, a thorough analysis of available databases 
would be conducted, comparing existing data and estimating the share of ‘free riders’ among plastic 
packaging  producers.  This  study  is  expected  to  significantly  improve  the  quality  of  Slovakia’s 
packaging data. 

4 Commission Implementing Decision 2019/665. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  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 a system of financial rewards and penalties 
dependant on the performance on such 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).  

2)  Address data-quality issues, especially those related to waste generated from packaging placed on 
the market and associated recycled quantities.  Fully apply the criteria provided  in the document 
Guidance for the compilation and reporting of data on packaging and packaging waste according 
to Decision 2005/270/EC. Carry out independent, third-party audits of data compiled by producers 
and producer-responsibility organisations.  

3)  Close and rehabilitate substandard landfills and take action against illegal landfills and fly tipping. 
Increase the enforcement capacity in order to inspect, check and discourage uncontrolled dumping. 

Prevention 

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

waste. 

5)  Promote  and  support  sustainable  consumption  models.  Slovakia’s  waste  prevention  programme 
could  be  complemented  with  specific  mandatory  measures,  such  as  eco-design  criteria,  to  make 
products  more  durable.  It  should  allocate  sufficient  budget  to  the  implementation  of  the  waste 
prevention  measures.  Slovakia  should  also  foster  coordination  between  the  central  and the local 
government to achieve the EU’s waste prevention objectives.  

Separate collection 

6)  Develop,  enforce  and  monitor  minimum  national  service  standards  for separate  waste  collection 
(including  of  biowaste).  This  could  include  specifying,  for  example:  (i)  the  type  and  volume  of 
containers; (ii) the minimum and maximum frequency of collections; and (iii) the types of vehicle 
that may be used for collections. These standards should take into account the type of housing stock, 
climate, seasonality, etc. It should ensure that the necessary infrastructure for separate collection is 
put in place. 

Waste treatment  

7)  Support preparing for re-use of municipal waste and  develop waste treatment infrastructure 
associated with the higher steps of the waste hierarchy. Firm plans and concrete actions are needed, 
such  as  supporting  home  composting  and  increasing  the  efficiency  of  treatment  capacity  for 
biowaste in order to fully cover generated biowaste. This should be accompanied by the introduction 
of  national  quality  standards  to  produce  high-quality  compost/digestate.  The  standards  could  be 
developed in dialogue with the farming community. 

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Communication and awareness raising 

8)  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 the separate collection of waste. A set of national communication materials should 
be developed that: (i) are addressed to the general public, farmers, and pupils for use at local level; 
(ii)  have  clear  and  consistent  messages;  and  (iii)  have  a  particular  focus  on  biowaste,  home 
composting and the sound management of waste (e.g. sorting). 

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Extended producer responsibility and economic instruments 

9)  Expand the application of the 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. 

10) Use  economic  instruments  (e.g.  raising  landfill  taxes  to  a  sufficiently  high  level;  they  currently 
range between EUR 11 and EUR 33 per tonne of municipal waste) 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. 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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