COMMISSION STAFF WORKING DOCUMENT The early warning report for Portugal 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, Portugal, 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) 197 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Portugal         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) 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, Portugal is 
considered to be at risk of missing: (i) the 2025 target of 55% for the preparation for re-use and the recycling 
of  its  municipal  waste;  and  (ii)  the  2025 targets  for  some  packaging  waste  streams.  The  distance  between 
Portugal’s current landfilling rate and the 2035 target to landfill no more than 10% of its municipal waste is 
also of concern. 

In 2020, the recycling rate for municipal waste reported by Portugal was 26.5% (which is almost 30 percentage 
points  below  the  2025  target),  while  the  landfill  rate  was  47.5%  (about  twice  the  EU  average).  General 
recycling trends in Portugal are also of concern: the recycling rate decreased by 4.4 percentage points from 
30.9% to 26.5% in the 5 years from 2016 to 2020, while in the same period there was no significant decline in 
the landfill rate.  

Portugal’s excessively low composting and digesting rates are considered a key reason for this performance. 
While it is estimated that Portugal generated 1.7 million tonnes of biowaste in 2019, the treatment capacity in 
the country is less than 80% of the total generated municipal biowaste, and there is a lack of treatment facilities 
for separately collected biowaste. The amount of municipal waste sent to landfill remains too high, and 45% 

1  An  early-warning  report  was  issued  for  Portugal  in  2018  (SWD(2018)  422  final).  In  total,  the  report  made  eight 
recommendations. According to the Portuguese authorities, 1 of the recommendations is considered implemented, 5 as 
partially implemented, and 2 have not been addressed. 
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  Semester  2022.  Country  Report  for  Portugal.  A  Country  Specific  Recommendation  (CSR-3)  has  been 
addressed to Portugal on waste management and circular economy. 

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of biodegradable waste is still landfilled. There is therefore an urgent need to improve the separate collection 
and treatment of biowaste in Portugal. 

The recycling rate for all packaging waste in 2019 was 62.8%, which is very close to the 2025 target of 65%. 
Therefore, Portugal is likely to meet its 2025 target for all packaging waste. However, Portugal is at risk of not 
meeting the material-based recycling targets for specific streams such as ferrous metals, aluminium, glass, and 
plastic packaging. In addition, the new calculation rules4 for packaging-waste recycling might result in a lower 
recycling rate. In 2020 the recycling rate for all packaging waste decreased to 59.8%. Both plastic waste and 
metal waste have low separate-collection rates even though the collection services in Portugal for these waste 
streams  are  very  convenient.  In  addition,  data  on  the  separate  collection  of  ferrous  metals  and  aluminium 
packaging are not yet available, so estimates for these waste streams are uncertain. An extended-producer-
responsibility scheme exists for all main packaging fractions, but industrial waste is not yet covered by this 
scheme.  

Significant improvements are therefore needed to bring waste management in Portugal in line with the EU 
waste hierarchy. There are already plans in place to improve almost all aspects, for example to: (i) increase 
biowaste treatment capacity; (ii) increase the mandatory separate collection of waste; (iii) implement a pay-
as-you-throw system; and (iv) and set up a deposit-refund scheme for beverage packaging made of plastic, 
ferrous metals and aluminium. It is therefore expected that more progress will be achieved in the coming years. 
However, since some measures will require more time before their effects will be fully visible, efforts should 
be stepped up significantly in order to reach all 2025 targets. 

Some of the main challenges in waste management include:  

- 

- 
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the lack of sufficient infrastructure for  the separate collection and treatment of biowaste and  some 
packaging streams; 
the lack of high-convenience collection services for some waste streams in many parts of Portugal; 
heavy  reliance  on  landfilling  and  low  capture  rates  of  recyclable  waste  in  the  separate  collection 
system. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Portugal’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.  Improve separate collection of recyclables and different packaging waste fractions (household and 

non-household waste). Make the separate collection of biowaste more convenient. 

3.  Implement  and  strengthen  economic  instruments  to  encourage  good  waste  management.  For 
example  (i)  implement  a  mandatory  pay-as-you-throw  system;  (ii)  implement  a  deposit-refund 
scheme; and (iii) increase the landfill tax.  

4.  Further  develop  waste-treatment  infrastructure  associated  with  the  higher  steps  of  the  waste 
hierarchy (such as increasing treatment capacity for biowaste, supporting home-composting, and 
ensuring the pre-treatment of waste that goes to landfill).  

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

4 Commission Implementing Decision (EU) 2019/665. 

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4.  Good practices 

The  following  measures  implemented  by  Portugal  are  considered  good  practices  that  help  to  improve  its 
recycling performance and could be replicated and that could help other Member States achieve the above-
mentioned targets. 

-  Packaging taxes and a ban on free carrier bags – In Portugal, single-use packaging for take-away and 
home-delivery  meals  are  covered  by  a  packaging  tax.  A  tax  of  EUR  0.30  per  single-use  package 
applies from 1 July 2022 for packaging made of plastic or made of multi-material with plastic, and 
from 1 January 2023 for packaging made of aluminium or made of multi-material aluminium. Portugal 
plans to extend the existing tax to single-use packaging of any material and not just those made of 
plastic or aluminium. Since July 2021, there has been a ban on distributing free carrier bags made of 
any material and of any thickness, in order to avoid the placing on the market of superfluous packaging. 
-  Home  and  community  composting  –  In  northern  Portugal  a  home-composting  project  has  been 
developed  in  the  municipalities  in  collaboration  with  Lipor5,  an  association  of  municipalities  that 
focuses on waste management. In 2020, 15 818 composting devices were distributed and 6 343 tonnes 
of biowaste were locally composted. 

5 https://www.lipor.pt/en/awareness/home-and-community-composting/composting-2/.  

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OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Address  data-quality  issues  on  generated  packaging  waste.  In  particular,  improve  the  electronic 
system for reporting the quantities of packaging placed on the market. This could be achieved by 
introducing  new  requirements  (e.g.  identifying  packaging  waste  types  with  their  respective 
registration  number,  or  mandatory  audits  for  packaging  producers),  improving  monitoring,  and 
increasing enforcement.  

2)  Set mandatory objectives or indicators for  separate waste collection at the level of the bodies in 
charge of collecting and managing municipal waste 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 strategic plan for municipal waste, integrating it into the country’s 

waste-prevention programme. Foster coordination between central and peripheral/insular areas to 
ensure uniform implementation of waste-prevention measures across the whole country. Properly 
monitor the application of the waste-prevention measures and set aside sufficient budgetary 
resources for this monitoring. 

Separate collection 

5)  Improve  the  high-convenience  collection  services  and  roll  these  services  out  across  the  whole 
country so that they are accessible to the whole population. These services should cover the different 
packaging waste fractions (household and non-household waste) and especially biowaste.  Home 
and community composting should be promoted, especially in rural areas. The specific challenges 
posed on separate collection by tourism should be duly taken into account.  

Waste treatment  

6)  Support  the  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 treatment capacity for biowaste to fully cover 
the generated biowaste.  

7)  Improve the waste management infrastructure to ensure that municipal waste is pre-treated before 
being  landfilled.  Swift  action  should  also  be  taken  to  ensure  the  closure  and  rehabilitation  of 
substandard landfills to comply with EU requirements.  

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 should be developed 
that: (i) are addressed to the public for use at local level; and (ii) have clear and consistent messages. 
These materials should be used as part of awareness-raising activities in leaflets, on social media, 

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on the internet, and at civic amenity sites. Portugal should also consider creating communication 
materials in  English to  help  tourists  contribute  to  waste  separation.  Two  of the  focuses  of  these 
materials should be the newly introduced requirement to separately collect biowaste and guidelines 
for home and community composting. 

Extended producer responsibility and economic instruments 

9)  Implement economic instruments (e.g. raising landfill taxes to a sufficient magnitude more quickly) 
to incentivise waste management focused on 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. 

10) Consider  implementing  a  pay-as-you-throw  system  for  both  businesses  and  households  to  both 
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 and how to introduce – 
and learn from – pilot projects. 

11) Accelerate the implementation of the planned deposit-refund scheme with a view to it contributing 

to recycling performance in 2025. 

12) 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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