COMMISSION STAFF WORKING DOCUMENT The early warning report for Poland 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, Poland, 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) 196 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Poland        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) 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 the data collected and existing policies in the area of waste management, Poland is 
considered to be at risk of missing: (i) the 2025 target of 55% for the preparing for re-use and the recycling of 
its municipal waste ; and (ii) the 2025 target to recycle 65% of its packaging waste. The gap between Poland’s 
current  landfilling  rate  and  the  2035  target  to  landfill  no  more  than  10%  of  its  municipal  waste  is  also  of 
concern. 

The  overall  municipal  waste  recycling  rate  in  Poland  remained  rather  stable  between  2016  and  2019, 
respectively  at  34.8 and  36%.  In  2020  the  municipal  waste recycling  rate  reported  by  Poland  increased to 
38.7%, however it is still 16.3 percentage points below the 2025 target of 55%. The application of the EU’s 
new calculation rules for municipal waste recycling4 might result in a lower recycling rate. The amount of 
municipal waste sent to landfill remains too high (in 2020, the landfill rate was 39.8%). 

The overall recycling rate for packaging waste slightly decreased in recent years, falling by 3.6 percentage 
points  from  2015  to  2019.  The  reported  recycling  rate  for  all  packaging  waste  in  2019  was  55.5%, 
9.5 percentage points below the 2025 target. Plastic is the packaging waste stream of most concern as plastic 

1 An early warning report was issued for Poland in 2018 (SWD(2018) 426 final). A total of six recommendations were 
provided. In the annex to the Early Warning Assessment related to the 2025 Targets for Municipal and Packaging Waste 
are listed 5 of 6 recommendations. According to the Polish authorities, 4 of the report’s recommendations are considered 
as being implemented, and 1 as 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) 
4 Commission Implementing Decision (EU) 2019/1004. 

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packaging was recycling was 18.5 percentage points below the 50% recycling target. The packaging-recycling 
rates might also be reduced by the future application of the new calculation rules5.  

Poland has recently put in place several measures to address the situation and achieve the mentioned targets. 
However, this has not yet resulted in measurable effects, and efforts should be stepped up significantly in order 
to reach all 2025 targets. Current recycling performance in the country is impacted by: 

- 

- 
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low capture rates of biowaste in the separate collection system combined with insufficient recycling 
capacity for separately collected biowaste;  
landfilling and incineration remaining the predominant forms of waste treatment in Poland; 
need to increase the capture rate of packaging waste in the separate collection system, in particular of 
challenging  fractions  like  plastic;  introducing  a  mandatory  deposit-refund  schemes  can  increase 
capture rates. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Poland’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 develop waste treatment infrastructure associated with the higher steps of the waste hierarchy 

(such as increasing treatment capacity for biowaste and supporting home composting). 

3.  Increase the efficiency of separate-collection systems and swiftly implement a national deposit-refund 
scheme for beverage packaging (including by promoting multi-use systems among local bottlers).  
4.  Extend a pay-as-you-throw system to all households, and fully introduce the cost-coverage rules as 

part of extended producer responsibility for packaging.  

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

4.  Good practices 

The  following  measures  implemented  by  Poland  are  considered  good  practices  that  help  to  improve  its 
recycling performance. 

- 

Identification  of  individual  households  producing  waste  –  In  2021,  regulations6  were  introduced 
enabling the identification of the individual households producing waste, via labelling of containers 
or bags intended for the collection of municipal waste. This helped the country to meet its obligations 
on  separate  waste  collection,  in  particular  in  multi-apartment  blocks  (e.g.  by  identifying  separate 
accounts for individual households). 

-  Supporting  home  composting  –  To  support  home  composting,  in  20197  a  partial  exemption  to  the 
waste  fee  was  introduced  for  property  owners  who  compost  their  waste  at  home.  This  not  only 
encourages home composting, it also makes it possible to better monitor this composting, because to 
obtain this exemption, home-composting must be reported by households to the municipality. 

5 Commission Implementing Decision 2019/665. 
6 Journal of Laws of 2021, item 1648, https://dziennikustaw.gov.pl/DU/rok/2021/pozycja/1648. 
7 Journal of Laws of 2019, item 1579, as amended, https://dziennikustaw.gov.pl/DU/rok/2019/pozycja/1579. 

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE RECYCLING PERFORMANCE 

Governance 

1)  Closely monitor the efficiency of separate-collection systems being rolled-out across the country. 
Monitoring should focus on capture rates and the quality of the recyclables. Improve data-collection 
methodologies across different national entities involved in waste statistics to ensure the consistency 
and accuracy of data reported to Eurostat. 

2)  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  performance-bound 
financial rewards and penalties dependant on the achievement of the 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 

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

4)  Swiftly  adopt  the  national  waste-management  plan  (KPGO  2022-2028),  integrating  the  waste 
prevention  programme.  Also  promote  coordination  between  central  government  and  local 
government to achieve the EU’s waste-prevention objectives. Closely monitor the implementation 
of waste prevention measures, and set aside sufficient budgetary resources for this monitoring. 

Separate collection 

5)  Improve the effectiveness of the existing door-to-door separate collection system and monitor its 
implementation. Particular attention should be paid to: (i) the newly introduced obligation to collect 
biowaste  and  compliance with  this  obligation  by  municipalities  and  waste  generators  across  the 
country;  and  (ii)  plastic  packaging  which  poses  the  most  challenges  in  terms  of  recycling 
performance.  

Waste treatment  

6)  Support preparing for reuse of municipal waste and further 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  treatment  capacity  for  biowaste  in  order to 
fully cover the generated biowaste (via new treatment plants and the transformation/modernisation 
of  existing  mechanical-biological  treatment  plants).  Also  consider  introducing  a  quality-
management system for compost from biowaste to build trust in compost quality among compost 
users. 

Communication and awareness raising 

7)  Maintain and reinforce awareness raising activities about waste prevention, littering and separate 
collection. A set of national communication materials should be developed that: (i) are addressed to 
the general public for use at local level; (ii) have clear and consistent messages; and (iii) have a 
particular focus on biowaste, separate collection and sound management of waste. These materials 
should be used in awareness-raising activities on social media and the internet and at civic amenity 
sites. 

Extended producer responsibility and economic instruments 

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8)  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. 

9)  Swiftly implement the planned mandatory deposit-refund system for recycling and promote multi-

use systems among local bottlers to increase reuse and closed-loop recycling.  

10) Implement economic instruments to incentivise waste management focused on the higher steps of 
the waste hierarchy. Reconsider the tax exemption for waste that is landfilled after having been 
treated  in  mechanical-biological  treatment  plants  and  waste-incineration  taxes. This  will  help  to 
make reuse, preparation for reuse, and recycling economically attractive and reduce dependency on 
landfilling. The economic incentives 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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