COMMISSION STAFF WORKING DOCUMENT The early warning report for Spain 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, Spain, 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  SWD(2023) 183 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Spain           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) 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  planned  policies  in  the  area  of  waste  management,  Spain  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. The gap between the current situation and the 2035 target of 10% 
landfilling of municipal waste is also of concern.  

In 2020, the municipal waste recycling rate reported by  Spain was 36.4% (18.6 percentage points 
below the 2025 target), while the landfill rate was 52.0% (over twice the EU average). The application 
of the new calculation rules4 for municipal waste recycling might result in a lower recycling rate. In 
terms of general trends, the recycling rate improved modestly in the past five years (from 33.9% in 

1An Early Warning report was issued for Spain in 2018 (SWD(2018) 425 final). A total of 8 recommendations  were 
provided.  According  to  the  Spanish  authorities  five  recommendations  therein  are  considered  implemented  and  three 
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.  

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2016 to 36.4% in 2020), while the landfill rate decreased only marginally (by about 2.1 percentage 
points over the last 5 years). 

Limited separate collection of biowaste and too low rates of composting and anaerobic digestion are 
considered the main reasons for this performance.  

The total rate of packaging waste recycling was 69.6% in 2019, which already exceeds the 2025 target 
of 65%; all packaging waste materials have exceeded the recycling targets for 2025, except for paper 
and cardboard, aluminium and plastic. Overall, recycling rates have been slightly increasing over the 
last  few  years  for  all  packaging  materials,  with  the  exception  of  paper  and  cardboard  packaging. 
However, the application of the new calculation rules for the recycling  of packaging waste5 might 
also result in a lower recycling rate (in 2020 the recycling rate for all packaging waste was 68.3%). 

Some of the main challenges in waste management include:  

- 

- 

- 

low rates of capture of recyclables in separate collection (30% for paper and cardboard and 
metals, 20% for plastic and 11% for biowaste); 
low  share  of  the  population  covered  by  high-convenience  separate  collection  services  for 
biowaste and lack of sufficient infrastructure for biowaste treatment; 
too high reliance on landfilling and mechanical biological treatment plants. 

It is  acknowledged that  many  new measures  were included  in  the new  Law 7/2022  on  waste and 
contaminated soil for a circular economy published on 8 April 20226. However, since some measures 
require a longer timeframe before their effects will be fully visible, it is unlikely all 2025 targets can 
be achieved. 

3.  Key recommendations 

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

1.  Support preparing for re-use of municipal waste and re-use systems for packaging 
2.  Further develop waste treatment infrastructure associated with the higher steps of the waste 
hierarchy. Ensure sufficient treatment capacity dedicated to separately collected biowaste. 
3.  Fully  implement  restrictions  on  landfilling  of  all  waste  that  is  suitable  for  recycling,  and 
implement landfilling taxes to incentivise municipalities to improve the effectiveness of waste 
collection and recycling.  

4.  Introduce  enforcement  mechanisms  to  clarify  allocation  of  responsibilities  and  strengthen 
coordination  of  the  regional  and  local  authorities  and  extended  producer  responsibility 
organisations to meet the recycling targets. 

The table below lists all possible actions to  support  Spain’s efforts to  improve its performance in 
waste management. 

4.  Good practices 

5  Implementing Decision (EU) 2019/665. 
6 https://www.boe.es/buscar/act.php?id=BOE-A-2022-5809.   

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The following measures implemented by Spain are considered good practices that contribute to the 
improvement of recycling performance: 

the 

implementation  of  high-performing 

-  Promotion of high-performing recycling schemes (project under the EU Technical Support 
Instrument TSI) – The project aims to improve circular economy at the local level and fosters 
the dissemination of best practices among municipalities to improve recycling, collection and 
treatment systems. Planned activities include the assessment of relevant policy options and 
recycling  schemes, 
recommendations  on 
dissemination of knowledge and expertise, support of local entities and assistance of relevant 
authorities in the implementation of the proposed actions.  
Implementation of Pay-as-you-throw systems – Several municipalities in Spain have ongoing 
projects  with  differentiated  waste  fees  reflecting  the  quantity  of  waste  generation.  For 
instance, Zaldibia (Guipúzcoa) uses a system of different sized waste bins depending on the 
collected fraction7, Esporles (Mallorca) provides a system that charges for additional waste 
bags needed by citizens8, Argentona (Barcelona) applies a pay-per-bag system which allows 
higher charges for residual waste for domestic as well as for commercial waste9 and in the 
province of Castellón, associations of municipalities apply a reduction of the supra-municipal 
charge for collection and waste treatment10for waste brought to civic amenity sites.  

- 

7 https://www.sasieta.eus/espanol/municipios?herria=19 
8 https://esporles.cat/ca/residus-recollida-i-gestio. 
9 https://residus.gencat.cat/web/.content/home/lagencia/publicacions/prevencio/guia_pxg_en.pdf. 
10 
https://bop.dipcas.es/PortalBOP/obtenerPdfAnuncio.do?idAnuncio=124482. 

https://bop.dipcas.es/PortalBOP/obtenerPdfAnuncio.do?idAnuncio=124589.   

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Fully implement restrictions on landfilling of all waste that is suitable for recycling. In this context 
it should undertake a study to identify barriers to the implementation of the landfill ban and assess 
the possible impact of the new landfill tax on illegal waste dumping. 

2)  Introduce additional incentives and enforcement mechanisms to reinforce the responsibilities and 
coordination  of  the  regional  and  local  authorities  and  extended  producer  responsibility 
organisations. Regions and local authorities could implement systems to monitor the behaviour of 
citizens  (and  businesses)  as  regards  separate  waste  collection  and  make  the  collected  data  on 
regional/municipal performance publicly available. 

3)  To  monitor,  enforce  and  achieve  higher  capture  rates,  mandatory  objectives  or  indicators  for 
separate waste collection should be set by the bodies in charge of the collection of municipal waste 
(e.g. municipalities). This could be complemented with tax rebates for bodies that meet the targets 
and/or budget restrictions for those that do not meet them. The performance of municipalities could 
also be made available to the general public to raise awareness (e.g. on a website). 

Prevention 

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

5)  Swiftly revise the Waste Management Plan integrating the Waste Prevention Programme. Establish 
clear guidelines for timeframe harmonisation among Spanish regions.  Ensure proper monitoring of 
the  implementation  of  waste  prevention  measures  and  sufficient  budget  allocation.  Foster 
coordination  between central  government level and  local  level in reaching  EU  waste  prevention 
objectives. 

Separate Collection 

6)  Further expand high-convenience collection services to a larger part of the population, especially 
for biowaste. Implementation of a separate collection scheme for biowaste is in progress. However, 
the degree of application of this scheme in the regions/municipalities is only specified to a limited 
extent. The  improvement  of  data  availability  on  the share of  municipalities  covered by  separate 
biowaste collection schemes is under way and should be further stepped up. 

Waste treatment  

7)  Further  develop  waste-treatment  infrastructure  associated  with  the  higher  steps  of  the  waste 
hierarchy. Ensure sufficient treatment capacity dedicated to separately collected biowaste. In Spain, 
treatment capacities are expected to increase since earmarked funds have been distributed to the 
regions according to defined criteria. To monitor progress and improve the coordination of capacity 
needs  across  regions,  it  is  recommended  that  quantitative  information  be  collected  on  existing, 
planned or projected capacities for the treatment of separately collected biowaste. It is proposed that 
regions  use  the  revenues  from  landfill  and  incineration  tax  to  finance  actions  to  improve  waste 
management. 

8)  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. 

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Communication and Awareness Rising 

9)   Carry  out  awareness-raising  activities  specifically  tailored  to  different  target  groups  to  enhance 
participation in separate collection. Develop a set of national communication materials addressed 
to different target groups (e.g. households and commercial waste generators, schoolteachers and 
students,  tourists)  with  clear  and  consistent  messages  and  publish  good  practices  for  separate 
collection, biowaste and home composting. These materials should be used as part of awareness-
raising activities via e.g. leaflets, social media and internet, and should be made available at civic 
amenity sites. Consider preparing communication materials in English as well as in Spanish to help 
tourists contribute to waste separation.   

Extended producer responsibility and economic instruments 

10) Accelerate the implementation 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  the  design  of  incentive  mechanisms  and  through  the 
introduction of or learnings from pilot projects. 

11) 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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