COMMISSION STAFF WORKING DOCUMENT The early warning report for Croatia 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: Croatia, EU environmental policy, 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) 185 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Croatia          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) 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  the  analysis  of  collected  data  and  existing  policies  in  the  area  of  waste  management,  Croatia  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 and the 2025 target to recycle 65% of packaging waste. Despite the significant decrease of 
the landfilling rate, the distance to the 2035 target to landfill 10% of municipal waste is also of concern. 

Croatia’s  recycling  rate  of  municipal  waste  significantly  increased  from  21%  in  2016  to  34.4%  in  2020 
(applying  new  calculation  rules  would  lower  the  2020  rate  to  30%).  Despite  a  significant  decrease  in  the 
landfilling rate (from 76.7% in 2016 to 55.7% in 2020), Croatia continues to rely heavily on landfilling. 

The total recycling rate for packaging waste decreased from 60.1% in 2015 to 48.9% in 2019. This decrease 
seems related to certain issues in the quality of the data collection that have only been partially addressed. In 
2020 the recycling rate for all packaging waste increased to 54.2%. The recycling targets to be reached by 
2025 for specific packaging materials have only been reached for paper and cardboard packaging. However, 
recycling rates are more than 15% below the specific targets for all other packaging (i.e. plastic, wood, metals 
and glass). 

1 An early warning report was issued for Croatia in 2018 (SWD(2018) 421 final). A total of 16 recommendations were 
provided. According to the Croatian authorities, 10 of the recommendations are considered as being implemented, four 
partially implemented and two 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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Some of the main challenges facing waste management in the country include: 

- 

a possible underestimation of the amount of packaging waste generated (it was less than half the EU 
average in 2019:  74 kg/person vs 177 kg/person); this is likely due to underreporting of packaging 
placed on the market, leading to underestimating the effective recycling rate and affecting extended 
producer responsibilities; 

-  weak enforcement mechanisms and a lack of coordination between various administrative levels in 

- 

the implementation of waste management according to the principles of waste hierarchy; 
significant reliance on landfilling, including of biowaste: Croatia reported that 79% of biodegradable 
waste was landfilled in 2020. 

Croatia has recently seen a significant increase in the recycling rate of municipal waste and has put in place 
many measures and made major investments. This is all expected to help the country make additional progress 
in the coming years. However, efforts should be stepped up significantly in order to reach all 2025 targets, and 
the distance to the 2035 target on landfill needs further attention. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Croatia’s  efforts  to  improve  its  performance  in  waste 
management, three main recommendations are listed below. 

1. 
2. 

3. 
4. 

Support preparing for re-use of municipal waste and re-use systems for packaging 
Impose restrictions on the landfilling of all waste that is suitable for recycling and introduce 
taxes  on  landfilling.  This  will  incentivise  municipalities  to  be  more  effective  in  sorting, 
collecting, and recycling waste. 
Address the data quality issues concerning packaging waste generated. 
Further develop waste treatment infrastructure associated with the higher steps of the waste 
hierarchy (such as increasing capacity for treating biowaste and supporting home composting). 

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

4.  Good practices 

The  following  measures  implemented  by  Croatia  are  considered  good  practices  contributing  to  the 
improvement of its recycling performance. 

-  Biowaste treatment capacity boosted through EU funding –EU funds were allocated to Croatia through 
the 2014-2022 operational programme for competitiveness and cohesion for nine composting plants. 
In addition, under the 2021-2026 national recovery and resilience plan, a new open call was published 
in May 2022 for building new composting plants. 

-  Facilitate sound waste management – An online platform, ‘Burza otpada’4, enables companies list the 
available waste that they want to dispose of. It acts as a centre for the supply and demand of all types 
of  waste.  The  waste  listed  on  this  platform  must  meet  technological  criteria  required  for  certain 
categories of waste. 

4 https://digitalnakomora.hr/e-gospodarske-informacije/burza-otpada/centar-informacija/o-burzi-otpada. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Address  data  quality  issues  on  generated  packaging  waste  as  a  priority.  Creating  a  register  of 
producers with extended responsibility and  imposing penalties are expected to  help improve  the 
data quality (although not before 2024). However, additional action is needed to achieve coherence 
between municipal waste and packaging waste data sets. 

2)  Set mandatory objectives or indicators on separate waste collection to be achieved by 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 for those entities depending on whether they achieve the targets or not. Information on the 
performance of municipalities could also be made available to the general public to raise awareness 
(e.g. on a website). 

Prevention 

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

4)  Swiftly  adopt  the  waste  prevention  programme,  which  is  part  of  the  2023-2028  national  waste 
management  plan.  The  country  should  foster  coordination  between  the  central  and  the  local 
government  to  achieve  EU  waste  prevention  objectives.  Croatia  should  also  properly  monitor 
implementation of waste prevention measures and ensure sufficient budget is allocated to them. 

Separate collection 

5)  Roll  out  high-convenience  collection  services  to  a  larger  part  of  the  population,  especially  for 
biowaste.  Additional  improvements  are  necessary  to  achieve  and  maintain  a  high  quality  of 
separately collected biowaste. 

Waste treatment  

6)  Develop waste treatment infrastructure associated with the higher steps of the waste hierarchy. Firm 
plans and concrete action are needed, such as supporting home composting and increasing capacity 
for treating biowaste to fully cover all generated biowaste. Extending treatment plants has already 
started or is planned, although the total capacity which would be reached is still not considered to 
be sufficient. 

7)  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 

8)  Carry  out  awareness-raising  activities  specifically  tailored  to  different  target  groups  (e.g. 
households,  commercial  waste  generators,  schoolteachers,  students  and  tourists)  to  increase 
participation  in  separate  collection.  A  set  of  national  communication  materials  addressed  to  the 
public for use at local level, with clear and consistent messages can be developed. These materials 
should be used as part of awareness-raising activities on social media and the internet and at civic 

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amenity sites. Communication materials (e.g. leaflets) could be made available in English to help 
tourists contribute to separate collection of waste. 

Extended producer responsibility and economic instruments 

9)   Implement economic instruments (e.g. raising landfill taxes to a sufficient magnitude) to incentivise 
waste management associated with the higher steps of the waste hierarchy. This will make re-use, 
preparation for re-use and recycling economically attractive and reduce dependency on landfilling. 
The economic incentive should be designed and sufficiently large to develop a ‘steering effect’. The 
most effective landfill taxes are considered to be those that increase over time in correlation with 
specific targets. 

10)  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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