COMMISSION STAFF WORKING DOCUMENT The early warning report for Estonia 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, Estonia, 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) 180 final  COMMISSION STAFF WORKING DOCUMENT The early warning report for Estonia          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) 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) 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 of existing policies in the area of waste management, Estonia is at 
risk of missing the 2025 target of 55% for the preparing for re-use and the recycling of its municipal waste. 

In  2019,  municipal  waste  generation  in  Estonia  (369 kg/person)  was  significantly  below  the  EU  average 
(504 kg/person).  However,  packaging  waste  generation  was  only  slightly  below  the  EU  average 
(158 kg/person  vs  174 kg/person).  This  low  figure  may  be  an  indication  that  some  quantities  of  generated 
municipal waste are not reported. 

In 2020, Estonia’s recycling rate for municipal waste was 28.9% (which is about 26 percentage points below 
the 2025 target). Only a very small share is used for composting (3% in 2020). The situation is of concern 
primarily due to trends in municipal waste recycling, which did not show significant progress in 5 years (from 
28.1%  in  2016 to  28.9% in  2020).  In  2020  Estonia’s  landfill rate  was  14.7%, which is  lower  than the  EU 
average. This is mainly because a high share of waste is used for energy recovery (43% in 2020) rather than 
being recycled.  

There is an overcapacity of mechanical biological treatment plants and waste incineration facilities for energy 
recovery,  which  has  helped  to  divert  waste  from  landfilling,  but  keeps  municipal  recycling  at  a  low  rate. 

1 An early warning report was issued for Estonia in 2018 (SWD(2018) 416 final), which contained 10 recommendations. 
According to Estonian authorities, 1 of the recommendations is considered to be implemented, 5 partially implemented 
and 4 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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Concerning biowaste, Estonia suffers from an inadequate separate collection system and uneven capacity in 
the different regions for treating this key waste stream. 

In 2019, the recycling rate for all packaging reached 66.2%, which already exceeds the 2025 target (65%); in 
2020, the recycling rate further increased to 71.4%. This is partly due a deposit-refund scheme for beverage 
packaging that has been place since 2005. 

Significant additional improvements are needed to bring Estonian waste management in line with the EU’s 
waste hierarchy. Some of the main challenges facing waste management in the country include: 

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overcapacity of residual waste treatment facilities (mechanical biological treatment and waste-to-
energy facilities), leading to lock-in effects and reduced incentives to improve separate collection 
and recycling; 
low separate collection and treatment rates for household biowaste; 
limited economic incentives to households for separate collection (e.g. pay-as-you-throw is 
implemented in different ways) and no mandatory separate collection targets for municipalities; 

-  data quality issues related to discrepancies between local and national reporting. 

3.  Key recommendations 

Among  the  measures  deemed  necessary  to  support  Estonia’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.  Consider making municipalities and larger territorial units responsible for meeting mandatory targets 
for separate collection. This could be complemented with financial rewards for those municipalities 
that achieve the targets and/or financial penalties for those that do not achieve them. 

3.  Consider introducing a tax on incinerating mixed municipal waste. 
4.  Provide clear guidance to municipalities on using pay-as-you-throw schemes, which are designed to 

give strong incentives to the public to separate waste for collection. 

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

4.  Good practices 

The following measures implemented by Estonia are considered good practices that could be replicated and 
that could help Member States achieve the above-mentioned targets. 

Real-time digital data collection system – A new waste data collection and traceability system will be launched 
in 20254. The system will let companies directly send waste data sets electronically to national government 
authorities. This will reduce the administrative burden on businesses and could support enforcement through 
more  reliable  checks  on  waste  management  data.  It  is  also  expected  to  support  enforcement  and  policy 
development at  ministry level.  The system will also make it easier to communicate on waste management 
performance to the general public. 

National  study on key  waste management issues and solutions – Following the  2018 early warning report, 
Estonia  applied  for  and  received  financial  support  from  the  EU`s  structural  reform  support  programme  to 
conduct a comprehensive analysis of its waste management system. The project was carried out by the World 
Bank in 2020-2021, and the results are now serving as a blueprint for policy action.  

4 https://www.realtimeeconomy-bsr.eu/. 

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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 municipalities could also be made available to the general public to raise 
awareness (e.g. on a website). 

2)  Consider allowing municipalities to collect at least part of the waste management tax proceeds. 
The funds could be used to organise effective separate collection systems for different waste 
streams, set up civic amenity sites and clean litter.  

3)  Address  data  quality  issues  by  aligning  municipal  and  national  reporting  and  improving  how 

recycling rates are calculated.  

Prevention 

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

5)  Swiftly revise the Waste Prevention Programme as part of the Waste Management Plan, to ensure 
an efficient and updated waste prevention strategy. Foster coordination between the central and 
the local government to advance on waste prevention. Properly monitor implementation of waste 
prevention measures and ensure sufficient budget is allocated for such measures. 

Separate collection 

6)  Improve  separate  collection  of  waste,  in  particular  of  biowaste.  Adopt  minimum  collection 

frequencies for residual waste and biowaste to ensure hygiene and sanitary standards. 

Waste treatment  

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. 

8)  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  the 
capacity to treat biowaste to fully cover generated biowaste. Measures could include providing more 
effective incentives to private operators to set up new biowaste treatment plants and introducing 
public-private partnerships and financial support through EU funding. 

Communication and awareness-raising 

9)  Carry out awareness-raising campaigns specifically tailored to different target groups (e.g. 

households, commercial waste generators, schoolteachers and students) to increase participation in 
separate collection. A set of national communication materials should be developed that: (i) are 
addressed to the general public, farmers, and pupils for use at local level; (ii) have clear and 
consistent messages; and (iii) have a particular focus on biowaste, home composting and sound 
management of waste (e.g. sorting). 

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Extended producer responsibility and economic instruments 

10) To achieve high capture rates of recyclable waste, draw up clear guidance for municipalities on pay-
as-you-throw schemes and on designing incentive mechanisms that strongly encourage the public 
to sort their waste.  

11) Implement economic instruments (e.g. taxes on incineration of a sufficient magnitude or applying 
Emissions Trading Scheme rules on 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’. 

12) 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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