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 Member State, EU environmental policy, application of EU law, carbon neutrality, circular economy, municipal waste, packaging product, prevention of pollution, storage of waste, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.6.2023  COM(2023) 304 final  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           {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} - {SWD(2023) 200 final}  
 
 
1.  INTRODUCTION 

Turning waste into resources is an essential building block of the circular economy. Proper 
implementation of the EU's waste legislation involves the application of the waste hierarchy, 
which  gives  priority  to  preparing  for  re-use  and  recycling  and  puts  landfilling  as  the  least 
preferred  waste  treatment  option.  The  EU’s  targets  for  the  treatment  of  municipal  and 
packaging  waste  have  been  established  in  order  to  ensure  concerted  efforts  in  all  Member 
States to move up the waste hierarchy.  

Improving  performance  in  waste  management  will  speed  up  the  transition  to  a  circular 
economy and contribute  to  the objectives of the  circular economy  action plan for a  cleaner 
and  more  competitive  Europe1  to  double  the  EU  circular  material  use  rate,  significantly 
reduce  total  waste  generation  and  halve  the  amount  of  residual  municipal  waste  by  2030. 
Furthermore, sound waste management is  essential  to  prevent  the  negative impact  of  waste 
generation  on  the  environment  and  health,  and  to  achieve  the  targets  of  the  zero  pollution 
action plan2 on waste and marine litter.  

Increasing  preparing  for  re-use  and  recycling  and  reducing  landfilling  are  key  to  reaching 
climate  neutrality,  increasing  the  security  of  supply  of  raw  materials,  saving  energy,  and 
reducing  EU  dependencies  on  imports  from  third  countries,  while  creating  local  jobs  and 
boosting innovation in new technologies for sustainable products and materials management. 

To  better  reflect  the  EU’s  ambition  to  move  to  a  circular  economy,  in  2018  several 
amendments  to  EU  waste  directives  were  adopted,  including  ambitious  targets  for  the 
preparing for re-use, recycling and landfilling of municipal and for the recycling of packaging 
waste. Municipal waste represents around 10% of the total waste generated in the EU3, but it 
is  one  of  the  most  complex  streams  to  manage  due  to  its  diverse  composition,  the  large 
number of waste producers and  the fragmentation of responsibilities for its  management. A 
large  share  of  municipal  waste  is  composed  of  packaging  waste,  which  has  significant 
circularity potential. 

In order to ensure better, more timely and uniform implementation of these ambitious targets 
and to anticipate any implementation weaknesses, the EU rules adopted in 2018 established a 
system of early warning reports to detect shortcomings and allow action to be taken ahead of 
the  deadlines  for  meeting  the  targets.  Under  these  rules,  the  Commission  is  tasked,  in 
cooperation with the European Environment Agency,  to draw up reports on the progress of 
Member States towards the attainment of the targets.  

This overall report assesses Member States’ likelihood of meeting the 2025 targets set out in 
Article 11(2)(c) of Directive 2008/98/EC on waste (the Waste Framework Directive)4 and in 
Article  6(1)(f)  of  Directive  94/62/EC  on  packaging  and  packaging  waste  (the  Packaging 
Directive5). The targets require Member States to take measures to achieve a minimum of:  

  55% preparing for re-use and recycling of municipal waste,  
  65% recycling of all packaging waste, and  

1 COM(2020) 98 final. 
2 COM(2021) 400 final. 
3 Eurostat 
4 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008L0098-20180705  
5 https://eur-lex.europa.eu/legal-content/en/ALL/?uri=celex%3A31994L0062  

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  material-specific packaging waste recycling targets of 75% for paper and cardboard, 70% 

for glass, 50% for aluminium, 50% for plastic and 25% for wood.  

The  report  also  provides  a  preliminary  assessment  of  the  likelihood  of  Member  States 
meeting the target laid down in Article 5(5) of Directive 1999/31/EC on the landfill of waste 
(the Landfill Directive) to reduce landfilling of municipal waste6 to less than 10% by 2035. 
The report summarises main findings, key recommendations to Member States at risk of not 
achieving  certain  waste  targets,  and  examples  of  best  practices  of  waste  management 
intended to help improve waste recycling performance. It is complemented by staff working 
documents containing country-specific information and recommendations for those Member 
States  at  risk  of  missing  the  2025  preparing  for  re-use  and  recycling  targets  for  municipal 
waste and all packaging waste, which include the following: 

  an estimation of the attainment of the targets by each Member State; 
  a list of Member States at risk of not attaining the targets within the respective deadlines, 
accompanied by appropriate recommendations for the Member States concerned; and 
  examples of best  practices that are used throughout  the EU and could provide guidance 

for making progress towards the targets. 

The  work  carried  out  for  the  purposes  of  this  early  warning  report  builds  on  continuous 
support  and  cooperation  between  the  Commission  and  Member  States  on  improving  the 
implementation of EU waste legislation. Following compliance promotion exercises starting 
in  20137,  in  2018  the  European  Commission  issued  a  set  of  reports  on  progress  and 
implementation  challenges  for  several  waste  streams8  that  included  possible  actions  to 
support  Member  States’  efforts  to  improve  their  waste  management  performance9.  In 
addition,  since  2017  the  European  Commission  has  been  regularly  publishing  an 
Environmental  Implementation  Review  (EIR),  a  tool  designed  to  improve  Member  States’ 
implementation of EU environmental laws and policies. The latest EIR was issued in 202210.  

2.  METHODOLOGY 

This report is the result of an extensive  consultation and collaboration among the European 
Commission,  the  European  Environment  Agency,  Eurostat  and  the  Member  States.  The 
assessment was  based on a methodology  developed by the  European  Environment Agency, 
which took as a starting point the waste management data submitted by the Member States to 
Eurostat  in  line  with  reporting  requirements  under  the  waste  directives,  and  considered 
existing  and  planned  policies  at  national  level  and  other  relevant  information.  It  also 
considered the adoption of revised national waste prevention programmes as required by the 
Waste Framework Directive. 
This assessment allowed the European Environment Agency11 to identify the Member States 
likely  to  miss  the  targets.  Its  findings  were  further  discussed  between  the  European 

6 https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A31999L0031  
7 Implementation of the Waste Framework Directive (europa.eu) 
8 COM(2018) 656 final.   
9https://environment.ec.europa.eu/topics/waste-and-recycling/implementation-waste-framework-directive_en    
10https://environment.ec.europa.eu/law-and-governance/environmental-implementation-review_en#country-
reports  
11https://www.eea.europa.eu/publications/many-eu-member-states-are 

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Commission  and  the  Member  State  concerned;  this  enabled  additional  information  to  be 
gathered and led to the finalisation of the report. A call for evidence was used to inform about 
the initiative and gather stakeholder views12. 

This report is based on the latest Eurostat data available at the stage of  its preparation. The 
data  for  reference  year  2020  was  used  for  municipal  waste,  while  for  packaging  waste  the 
data for 2019 was used. Regarding packaging, more recent data for 2020 is now available and 
a  preliminary  assessment  of  its  relevance  to  the  conclusions  of  the  report  is  reflected  in 
Section 5.  

3.  OVERALL FINDINGS   

The  analysis  of  Member  States’  performance  identified  the  general  trends  in  waste 
management and showed the likelihood of achieving waste preparing for re-use and recycling 
targets by 2025. 

The  majority  of  Member  States  have  recently  carried  out  or  are  in  the  process  of 
implementing waste reforms that will result in increased recycling rates in the years leading 
to  2025  and  beyond.  The 
the 
recommendations  issued  in  the  2018  Early  Warning  Report  played  a  relevant  role  in 
achieving progress. However, in some cases delays in their application are affecting national 
recycling performances.  

the  2018  waste  package  and 

implementation  of 

There  are  still  significant  differences  in  waste  management  performance  across  Member 
States. For some countries, the distance from the targets is very large and greater efforts will 
be needed to implement reforms on the ground (e.g. as regards biowaste treatment, separate 
collection,  data  quality,  etc.).  There  is  also  evidence  that  external  factors  influenced 
performance, for instance during the COVID pandemic separate collection in some Member 
States was reduced or halted. There are also indications that the recent spike in energy prices 
is adversely affecting recycling activities.  
Overall, according to the assessment carried out by the European Environment Agency13, the 
majority of Member States are at risk of missing the municipal waste preparing for re-
use and recycling targets for 2025.  

More  specifically,  with  regard  to  the  target  of  55%  preparing  for  re-use  and  recycling  of 
municipal waste and 65% recycling of all packaging waste to be achieved by 2025:  

  9  Member  States  are  on  track  to  meet  both  targets  –  Austria,  Belgium,  Czechia, 

Denmark, Germany, Italy, Luxembourg, the Netherlands and Slovenia; 

  8 Member States are at risk of missing the municipal waste target only, but not at 
risk  for  the  target  on  all  packaging  waste  –  Estonia,  Finland,  France,  Ireland,  Latvia, 
Portugal, Spain and Sweden; 

  10  Member  States  are  at  risk  of  missing  both  the  targets  for  municipal  and  all 
packaging  waste  for  2025  –  Bulgaria,  Croatia,  Cyprus,  Greece,  Hungary,  Lithuania, 
Malta, Poland, Romania and Slovakia. 

12https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13511-Early-Warning-Report-on-
Waste_en  
13https://www.eea.europa.eu/publications/many-eu-member-states-are  

3 

 
 
 
                                                           
This  early  warning  report  is  accompanied  by  staff  working  documents  for  Member  States 
considered at risk of missing at least one of these two headline targets (55% preparing for re-
use and recycling target for municipal waste and 65% recycling target for all packaging waste 
to be achieved by 2025); this corresponds to the second and third groups of Member States 
listed above14. All Member States at risk of missing the target for all packaging waste are also 
at risk of missing the municipal waste target.  

It  should  be  noted  that  achieving  high  performance  in  re-use,  preparing  for  re-use  and 
recycling  of  waste  requires  continuous  efforts  both  in  Member  States  that  have  been 
identified  at  risk  of  missing  2025  targets  and  in  those  for  which  the  assessment  has  shown 
likelihood  to  achieve  them  although  they  still  have  some  distance  to  cover.  As  ensuring 
proper waste management in line with the waste hierarchy  often faces new challenges, also 
those  countries  that  have  reached  preparing  for  re-use  and  recycling  rates  above  the  2025 
targets  in  2019  and  2020  need  to  pursue  policies  to  maintain  and  further  improve 
performance levels, including in the context of the application of the new calculation rules for 
recycling.  Further  efforts  should  be  made  to  achieve  material  specific  recycling  targets  for 
packaging, in particular for plastic packaging.     

                                           Reference data: ©ESRI 

Member states not at risk for both targets  

Member States at risk for the municipal waste preparing for re-use and recycling target but not at risk for 
the all packaging waste recycling target  

Member states at risk for both targets 

Outside coverage 

14 The assessment of the risks of missing the targets takes into account data and information available until April 
2022. 

4 

 
 
 
 
 
 
 
 
 
 
                                                           
Figure 1: Prospects for EU Member States of meeting the preparing for re-use and recycling 
targets for municipal waste and packaging waste (Source: European Environment Agency15 ) 

4.  MUNICIPAL WASTE   

In  2020,  Europeans  generated  on  average  521  kg  of  municipal  waste  per  person,  49%  of 
which was prepared for re-use or recycled while around 23% was landfilled16. The amount of 
waste generated has been slowly increasing in recent years. 

Legal  obligations  on  the  management  of  municipal  waste  are  laid  down  in  the  Waste 
Framework Directive. In advance of meeting the 55% target for the preparing for re-use and 
recycling of municipal waste17 to be achieved by 2025, Member States are required to meet a 
50%  target  by  202018.  The  Directive  also  includes  longer-term  ambitious  targets:  60%  by 
2030  and  65%  by  203519,  as  well  as  other  requirements  such  as  implementing  separate 
collection  of  waste  and  adopting  national  waste  management  plans  and  waste  prevention 
programmes. 

Based  on  the  assessment  carried  out  by  the  European  Environment  Agency  and  on  an  in-
depth  review  of  Member  States’  recycling  performance  and  waste  policies20,  18  Member 
States have been identified as being at risk of missing the target of 55% preparing for re-
use  and  recycling  of  municipal  waste  by  2025:  Bulgaria,  Croatia,  Cyprus,  Estonia, 
Finland, France, Greece, Hungary, Ireland, Latvia, Lithuania, Malta, Poland, Portugal, 
Romania, Slovakia, Spain and Sweden.  

Considering Member States’ distance from the 2025 target and their specific challenges and 
situation,  key  country-specific  recommendations  to  improve  preparing  for  re-use  and 
recycling  rates  have  been  identified.  This  has  been  done  through  a  process  that  closely 
engaged the national authorities.  If implemented swiftly by national  and local authorities in 
cooperation  with  the  waste  management  industry,  these  suggested  measures  could 
significantly  accelerate  the  improvement  of  recycling  performance.  The  staff  working 
documents  accompanying  this  report  outline  these  possible  actions  for  each  Member  State 
considered  at  risk.  Key  common  priorities  and  related  challenges  are  provided  in  the 
following box. 

It  may  be  reasonably  assumed  that  this  assessment  also  provides  a  strong  indication  of 
Member States’ risk of missing the preparing for re-use and recycling target for 2030 of 60% 
if  no  additional  efforts  are  made,  including  swifter  implementation  of  adopted  policies  and 
reforms. 

15 https://www.eea.europa.eu/publications/many-eu-member-states-are  
16 Eurostat 
17 Article 11(2)(a) of Directive 2008/98/EC. 
18  Member  States  may  choose  among  four  methods  to  calculate  the  target  for  2020,  allowing  to  apply  it  to 
certain streams or to all municipal waste; the targets for 2025, 2030 and 2035 apply to all municipal waste. 
19 Article 11(2)(c) to (e) of Directive 2008/98/EC. 
20https://www.eea.europa.eu/publications/many-eu-member-states-are 

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Box 1: Municipal waste 

  The  majority  of  Member  States  have  carried  out  or  are  in  the  process  of 
implementing  waste  reforms  that  will  result  in  a  more  circular  approach  and 
increased preparing for re-use and recycling rates in the years leading to 2025 and 
beyond. However, in some cases delays in their application  are adversely affecting 
their performance. The challenges posed by the COVID pandemic and the energy 
crisis  may  require  specific  actions  to  avoid  delayed  implementation  of  national 
waste reforms.    

  Biowaste  is  the  most  important  waste  stream  for  which  action  is  needed,  since  it 
constitutes  on  average  34%  of  municipal  waste.  Focus  should  be  given  to 
introducing  or  expanding  effective  capacity  for  the  separate  collection  and 
treatment  of  biowaste.  Sound  biowaste  management  could  enable  the  use  of 
biowaste as a fertiliser and soil improver and for the production of biogas21.  It can 
provide  significant  contributions  to  climate  goals  and  can  help  achieve  EU 
objectives  for  energy  and  critical  raw  materials  security  by  replacing  mined 
mineral fertilisers while enhancing soil health. 

  High capture  rates  and quality of separate collection are  essential  preconditions  of 
preparing  for  re-use  and  recycling;  this  could  be  more  effectively  achieved  via 
targets for the mandatory separate collection of waste at municipal level. Their 
use  should  be  based  on  incentives  and  accountability  (for  instance,  a  system  of 
financial rewards and penalties depending on the performance on those targets could 
be introduced). 

  Measures  are  needed  to  encourage  households  to  sort  waste,  including  higher 

collection frequency for separated streams than for mixed waste. 

  Member  States  are  not  using  the  full  spectrum  of  economic  measures  to  reduce 
landfilling and incineration (such as landfill and incineration taxes) and to enhance 
waste  treatment  associated  with  the  higher  steps  of  the  waste  hierarchy,  such  as 
preparing  for  re-use  and  recycling  (for  instance,  pay-as-you-throw  and  deposit-
return schemes). 

  Member States need to close the investment gap including through the effective use 
improving 

infrastructure  that  supports 

of  EU  funds 
prevention, re-use and recycling performance. 

to  develop  waste 

  Member States  should take measures on the  prevention of non-recyclable waste. 
Some  Member  States  have  not  yet  revised  their  national  waste  prevention 
programmes. The revision is expected to be completed by 2023. 

  Awareness-raising  activities  are  essential  to  enhance  citizens’  participation  in 
better  waste  management.  They  can  be  tailored  to  different  target  groups  (such  as 
households, students, or tourists). 

21 https://www.eea.europa.eu/publications/biowaste-in-europe 

6 

 
 
 
                                                           
5.  PACKAGING WASTE 

In  2020,  the  total  packaging  waste  generated  in  the  EU  amounted  to  around  79.6  million 
tonnes22. The average overall packaging recycling rate in the EU has steadily increased from 
2005  to  2016  (67.6%  in  2016)  whereas  a  slight  decrease  has  been  observed  from  2016  to 
2020  (64%  in  2020)23.  Furthermore,  between  2013  and  2020  the  amount  of  generated 
packaging waste grew by 15% across the EU, suggesting that more work on waste prevention 
is needed.  

Legal  obligations  on  the  management  of  packaging  waste  are  laid  down  in  the  Packaging 
Directive. These include a recycling target of 65% for all packaging waste to be achieved by 
2025  and  material-specific  targets  for  paper  and  cardboard,  glass,  aluminium,  plastic  and 
wood. Member States are allowed to  meet  up to  5 percent  of the targets  by subtracting the 
share of reusable sales packaging placed on the market for the first time and re-used as part of 
a system to re-use packaging, and as regards wooden packaging, to take fully into account of 
repair for re-use. The Directive also includes longer-term ambitious recycling targets: 70% by 
2030  for  all  packaging  and  also  material-specific  targets  for  paper  and  cardboard,  glass, 
aluminium, plastic and wood24.  
Overall,  according  to  the  assessment  carried  out  by  the  European  Environment  Agency25, 
10 Member States have been identified as at risk of missing the target of 65% recycling 
of  packaging  waste  by  2025:  Bulgaria,  Croatia,  Cyprus,  Greece,  Hungary,  Lithuania, 
Malta, Poland, Romania, Slovakia. 

Furthermore,  several  Member  States  are  considered  to  be  at  risk  of  missing  one  or  more 
material-specific targets, with plastic being the most critical material:  

Plastics 

Glass 

Austria, Bulgaria, Croatia, Cyprus, Denmark, Finland, France, 
Greece,  Hungary,  Ireland,  Italy,  Latvia,  Luxembourg,  Malta, 
Poland, Portugal, Romania, Slovakia and Spain 

Bulgaria, Croatia, Cyprus, Greece, Hungary, Lithuania, Malta, 
Poland, Portugal and Romania 

Aluminium 

Croatia,  Cyprus,  Czechia,  Greece,  Malta,  Portugal,  Romania, 
Slovakia and Spain 

Ferrous metal 

Croatia, Denmark, Malta, Portugal and Romania 

Paper and cardboard  Croatia, Malta, Slovakia and Spain 

Wood 

Croatia and Malta 

The assessment identified some inconsistencies in packaging data reported by some Member 
States, indicating that the amounts of packaging put on the market may be underreported. In 
addition,  the  new  recycling  performance  calculation  requires  Member  States  to  apply  as  of 
2020, as annual reporting of packaging waste generation and recycling is expected to result in 

22 Eurostat  
23 Eurostat 
24 Article 6(1), points (h) and (i) of Directive 94/62/EC. 
25https://www.eea.europa.eu/publications/many-eu-member-states-are 

7 

 
 
 
 
                                                           
lower  reported  recycling  rates  by  a  few  percentage  points26.  At  the  same  time,  in  case 
Member States  take measures to  ensure that  re-use systems  expand, they will have to  meet 
lower recycling targets.  

A  preliminary  review  of  data  on  packaging  waste  for  reference  year  2020  collected  by 
Eurostat  indicated  that  the  assessment  of  Member  States  at  risk  of  not  meeting  the  targets 
remains  valid.  An  overall  slight  reduction  in  the recycling  rates  can  be  observed  (however, 
Member  States  showed  very  different  patterns,  with  the  performance  of  some  increasing 
while  that  of  others  decreased).    In  addition,  at  this  stage  it  is  not  yet  possible  to  clearly 
attribute the changes to specific reasons due to several factors being at play, in particular the 
application  of  the  new  calculation  method  for  recycling  performance  and  the  effects  of  the 
COVID pandemic. 

The staff working documents accompanying this report outline possible actions that could be 
carried out to significantly reduce the risk of the waste packaging targets not being met. Some 
of the relevant common priorities identified in Box 1 above are also relevant for packaging. 
Specific challenges and priorities in relation to packaging are set out in Box 2 below. 

26 Directives (EU) 2018/850 and 2018/851introduced new calculation rules requiring recycling to be measured 
at the point of packaging waste entering a recycling operation. The previous rules, reflected in the statistics up to 
2019 and for some Member States for 2020, allow for all separately collected waste to be reported as recycled. 

8 

 
 
 
                                                           
Box 2: Packaging waste 

  Continuous  improvements  in  separate  collection  remain  essential  to  improve 
recycling performance. Separate collection improvements can be best achieved by a 
combination  of  a  high  share  of  the  population  being  covered  by  high-convenience 
separate  collection  systems,  the  application  of  deposit-return  schemes,  the 
introduction  of  separate  collection  bins  in  public  and  commercial  areas,  and 
awareness raising. 

  The  majority  of  Member  States  struggle  to  meet  the  target  on  plastic  packaging. 
This  can  be  addressed  by  improving  separate  collection  systems  for  plastic,  and 
increasing plastic sorting and treatment capacities. 

  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.  

  Member  States 

that  perform  weaker 

terms  of  recycling  often  have 
inconsistencies in packaging data. This indicates that the amount of packaging put 
on the market may be underreported, with the result that statistics are inaccurate and 
that  producers  may  not  bear  their  full  extended  responsibility  for  financing  waste 
collection, sorting and recycling. 

in 

  The impact of improvements in waste-management practices and infrastructure may 
be  distorted  in  the  reported  data  by  the  application  of  the  new  calculation  rules 
applicable  as  of  2020.  The  impact  of  the  new  calculation  rules  cannot  be  fully 
assessed  yet,  but  reported  data  by  some  Member  States  for  2020  indicate  a 
decreasing effect of few percentage points.  

6.  LANDFILLING 

Landfilling  is  the  least  preferable  waste  treatment  option.  The  Landfill  Directive27    obliges 
Member States to reduce the landfilling of municipal waste to a maximum of 10% by 2035 
and introduces a ban on the landfilling of separately collected waste, including biodegradable 
waste. 

While  amounts  of  landfilled  municipal  waste  fell  steadily  in  the  EU  as  a  whole  until  2016 
(dropping  by  18%  during  the  2013-2016  period28),  the  trend  from  2017  to  2020  was  not 
linear, with around 53.5 million tonnes of municipal waste landfilled in 2020. Furthermore, 
the  average  landfilling  rate  for  municipal  waste  in  the  EU  still  stood  at  23%  in  2020. 
However,  significant  differences  across  the  EU  persist:  in  2020  eight  Member  States  still 
landfilled over 50% of municipal waste, with three of them reporting rates above 70%.  

27 Art. 5(5) of Directive 2018/850 
28 Eurostat. 

9 

 
 
 
                                                           
A total of 13 Member States are still far from the target of a maximum of 10% of landfilling 
of municipal waste to be reached by 203529: Bulgaria, Croatia, Cyprus, Czechia, Greece, 
Hungary, Latvia, Malta, Poland, Portugal, Romania, Slovakia and Spain.  

The  distance  to  the  target  deserves  further  attention  and  requires  the  implementation  of 
corrective measures, even if more time is needed to establish with more certainty the risk of 
missing the targets. 
A study carried out  for the Commission30 also found that 15 Member States were not  fully 
meeting the obligation laid down in the Directive31 to treat waste before landfilling. 

Despite considerable improvements since the adoption of the Landfill Directive and closures 
of non-compliant landfills across the EU, the number of landfills that are not in line with the 
requirements of the Waste Framework and Landfill Directives remains a matter of concern. 
At the end of 2021, 1995 illegal or substandard landfills were still operating and had to be 
rehabilitated or adapted to EU standards32. 

7.  BEST PRACTICES 

Member  States  share  common  challenges  in  waste  management  and  many  solutions  have 
been already found and applied. The wide sharing of such solutions is considered a priority. 
This  report  aims  to  identify  a  few  best  practices  in  municipal  waste  and  packaging  waste 
management  from  each  Member  State,  providing  an  overview  of  successful  initiatives  and 
measures that could be replicated in other countries and could help Member States attain the 
targets.  

The best practices collected address a wide range of subjects in waste management, such as 
governance, separate collection, including in remote areas, public-private partnerships, re-use 
and  prevention  of  waste,  waste 
treatment,  communication  and  awareness  raising, 
implementation  of  economic  instruments,  and  effective  extended  producer  responsibility 
schemes.  

8.  CONCLUSIONS 

EU  waste  legislation  has  been  driving  considerable  improvements  in  waste  management, 
contributing to the EU circularity and zero pollution goals. However, full implementation of 
that legislation is crucial if the EU is to fully reap the environmental and economic benefits of 
a  cleaner  and  more  circular  economy  and  compete  in  a  world  of  increasingly  scarce 
resources.  Further  efforts  are  also  essential  in  the  light  of  the  substantial  increase  in 
packaging  waste,  the  limited  decrease  in  total  waste  generation  (by  4%  between  2010  and 
2020), the pollution caused by marine plastic litter, and a relatively stable trend for residual 

29 https://www.eea.europa.eu/publications/many-eu-member-states-are 
30  Milieu  (2017),  ‘Study  to  assess  the  implementation  by  the  EU  Member  States  of  certain  provisions  of 
Directive 1999/31/EC on the landfill of waste’. 
31 Article 6(a) of the Landfill Directive. 
32 This figure is based on the number of illegal or substandard landfills which are subject to ongoing 
infringement procedures. 

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municipal  waste,  all  of  which  put  at  risk  the  achievement  of  the  zero  pollution  targets  by 
203033.   

The Commission’s early warning reports on waste and other compliance promotion activities 
point to continuous progress in Member States, albeit at different levels of performance. For 
the  EU  as  a  whole,  the  average  rate  of  municipal  waste  preparing  for  re-use  and  recycling 
increased  over  2010-2020,  albeit  slowly  (from  37%  to  some  47%),  while  landfilling  has 
significantly  decreased,  from  31%  to  some  23%.  However,  serious  gaps,  delays  and 
challenges have also been identified and have to be swiftly addressed. 

Good  progress  is  possible  if  the  Member  States  concerned  take  action  to  implement  the 
measures  identified  in  this  report  and  in  the  accompanying  country-specific  staff  working 
documents. Action must include a clear focus on biowaste and packaging waste. Improving 
waste management performance entails boosting separate collection, which is key to ensure 
the quality of waste and enable its recycling. In parallel, there is a pressing need to increase 
preparing for re-use and further develop waste treatment capacities for sorting and recycling 
in order to advance to the higher steps of the waste hierarchy.  

Other  important  measures  required  concern  the  improvement  of  data  quality,  ensuring 
effective  enforcement  of  the  rules,  and  deploying  enhanced  economic  instruments,  such  as 
landfill  and 
efficient  extended  producer  responsibility  schemes  and  fit-for-purpose 
incineration taxes. These  are  all  essential to  fully  reap  the benefits  of the circular economy 
and comply with EU waste legislation. 

The  Commission  will  continue  to  support  Member  States  in  their  implementation  efforts. 
This  includes  technical  assistance,  including  through  the  Environmental  Implementation 
Review34, European Semester country recommendations35, guidance on separate collection36, 
exchange  of  best  practices37,  reforms  and  investments  under  the  Recovery  and  Resilience 
Facility,  and  financial  support  from  other  EU  funds,  such  as  the  Cohesion  Policy  Funds 
(European Regional Development Fund and Cohesion Fund). Furthermore, the Commission 
has been launching other initiatives which contribute to a more circular economy and to less 
waste generated, such as the proposals for new regulations on packaging and packing waste 
and  on  ecodesign  for  sustainable  products,  and  the  revision  of  the  Industrial  Emissions 
Directive.  

Lastly,  recognising  the  wide  differences  in  waste  management  situations,  the  EU  rules  on 
waste  give  some  Member  States  the  possibility  to  postpone  compliance  beyond  the  target 
years, under specific conditions. This option should be considered with care, since delays in 
the adoption of the necessary reforms will also delay environmental and economic benefits of 
the  circular  economy,  including  actions  to  reduce  pressure  on  natural  resources  and 
dependencies on imports. 

33 https://environment.ec.europa.eu/strategy/zero-pollution-action-plan/zero-pollution-targets_en 
34 http://ec.europa.eu/environment/eir/index_en.htm 
35https://commission.europa.eu/publications/2022-european-semester-country-specific-recommendations-
commission-recommendations_en 
36 e.g. Guidance for separate collection of municipal waste https://data.europa.eu/doi/10.2779/691513 
37 TAIEX-EIR Peer2Peer - http://ec.europa.eu/environment/eir/p2p/index_en.htm 

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