COMMISSION STAFF WORKING DOCUMENT The early warning report for Ireland 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, Ireland, 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) 181 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Ireland             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) 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 

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 2018. 

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 Agency1, 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 Review2. 

2.  Key findings 

Based  on  an  analysis  of  collected  data  and  existing  policies  in  the  area  of  waste  management,  Ireland  is 
considered  at  risk  of  missing  the  2025  target  of  55%  for  the  preparing  for  re-use  and  the  recycling  of  its 
municipal waste. Ireland is on track to meet the 2025 target to recycle 65% of all packaging waste. However, 
the country is at risk of not meeting the 2025 target of 50% that applies specifically to plastic packaging. 

The incineration rate was 46% in 2019 – almost twice the EU average of 26%. With a landfilling rate of 15.3% 
in 2019, Ireland was not considered at risk of not meeting the 2035 target for municipal waste landfilling (less 
than 10%). It is to be noted however that according to the data for 2020, the incineration rate fell to 31.8% and 
the landfilling rate increased  to 22.5%, which indicates the need to step up efforts to divert waste towards 
recycling.  

Ireland’s recycling rate of municipal waste decreased by slightly more than 3 percentage points between 2016 
and 2018, from 40.7% to 37.6%. Despite a decrease in composting/digestion of 0.7 percentage points from 
9.6% to 8.9% between 2019 and 2020, the recycling rate increased by 3 percentage points to 40.4% in 2020 
and is therefore slightly below the 2016 rate. 

1 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) 
2 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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In 2019, Ireland’s recycling rates were already higher than the targets for all packaging materials except plastic 
packaging. The recycling rate for plastic packaging waste declined by 2.2 percentage points between 2015 and 
2019. With a current recycling rate of 27.5%, the distance to meeting the target for plastic packaging waste is 
22.5  percentage  points,  even  after  applying  the  new  calculation  rules3.  In  2020,  the  recycling  rate  for  all 
packaging materials was 62.4%. 

The main factors hindering progress of Ireland towards the targets include: 

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low  capture  rates  of  recyclable  waste  in  the  separate  collection  system,  in  particular  from  plastic 
packaging; 

lack of sufficient infrastructure for the separate collection and treatment of biowaste; 

limited economic instruments to incentivise waste management associated with the higher steps of the 
waste hierarchy. 

Firm plans are already in place for some of these issues, e.g. separate collection and treatment of biowaste and 
a tax on waste incineration. Additional progress is therefore expected once these measures yield results. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Ireland’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 municipal biowaste to increase capture rates, prioritising door-to-door 

collection and promoting high quality bio-waste to maximise potential for recovery. 

3.  Further develop waste treatment infrastructure associated with the higher steps of the waste hierarchy, 

including increasing the capacity for treating biowaste and supporting home composting. 

4.  Implement  economic  instruments,  such  as  incineration  taxes,  to  incentivise  recycling  and  reduce 

dependency on waste incineration. 

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

4.  Good practices 

The following measures implemented by Ireland are considered good practices that can contribute to better 
performance in recycling. 

-  Major role of producer responsibility organisations in awareness-raising and communication – To be 
authorised  to  operate,  producer  responsibility  organisations  must  carry  out  national  education 
programmes  and  awareness-raising  activities  specific  to  their  respective  waste  streams.  These 
campaigns  must  run  across  all  existing  and  emerging  media  platforms,  and  their  effectiveness  is 
continuously monitored. The organisations are also encouraged to work together on these campaigns. 

- 

2022-2023 Circular economy communication campaign – A national circular economy education and 
awareness campaign4 across print, radio and social media has been launched to present the concept of 
circular  economy  to  the  general  public.  This  includes  presenting  ‘Circular  Heroes’,  which  are 

3 Commission Implementing Decision (EU) 2019/1004. 
4 Irish Environmental Protection Agency: It’s time to get circular. 

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individuals, businesses and organisations who will illustrate the circular economy in practical terms 
through their own stories. The campaign is to be followed by more targeted campaigns focusing on 
specific demographics, material streams and economic activities. 

OVERVIEW OF POSSIBLE ACTIONS TO IMPROVE PERFORMANCE 

Governance 

1)  Set mandatory indicators and targets for 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  dependant  on  the  performance  of  the  bodies  against  the  targets.  Information  on  the 
performance of those bodies could also be made available to the general public to raise awareness 
(e.g. on a website).  

Prevention 

2)  Take measures to increase re-use and to prevent the generation of non-recyclable municipal waste 
3)  Swiftly revise the national waste prevention programme. Foster coordination between the central 

and the local government on waste prevention. Properly monitor implementation of waste 
prevention measures and ensure sufficient budget is allocated to them. 

Separate collection 

4)  Increase biowaste capture rates by focusing on door-to-door separate collection of municipal 

biowaste. Promote separation in a clean biowaste stream to avoid contamination and to maximise 
the potential value of biowaste.  

5)  To increase capture rates of plastic packaging waste from households, assess whether additional 
types  of  plastic  waste  can be  separately  collected.  Soft  plastics  have  recently  been  added  to  the 
separately collected stream, and this could also be possible for other types of plastic waste. 

Waste treatment  

6)  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. 

7)  Conduct a clear mapping of the current national capacity for treating biowaste and adjust it to match 
upcoming needs. This will ensure that with the planned increase of separate collection for biowaste, 
it can be adequately recycled.  

Communication and awareness-raising 

8)  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. 

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Extended producer responsibility and economic instruments 

9)  Implement economic instruments (e.g. incineration taxes of a sufficient magnitude or applying 
emissions trading schemes rules for incineration) to incentivise waste management associated 
with the higher steps of the waste hierarchy. This will help to make re-use, preparation for re-use 
and recycling economically attractive and reduce dependency on waste incineration. The 
economic incentive should be designed and sufficiently large to develop a ‘steering effect’. 

10) Implement a deposit-refund scheme for all types of PET5 bottles up to 3 litres in size and aluminium 

beverage cans. 

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. 

5 Polyethylene terephthalate. 

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