Consultation on the Review of the European Waste Management
Targets
Personal Details
In what capacity are you responding to this
consultation? -single choice reply-(compulsory)

As a representative of a public authority

-

Member State, regional

or local competent authority

Name -open reply-(compulsory)

Surname -open reply-(compulsory)
Email address -open repIy-(compulsory
Please provide the full name of the public
authority/body for which you are responding.

Dutch Government

-open reply-(compulsory)
.

In what country are you based? -single choice reply- Netherlands

[mPulsorY)

jHow many inhabitants are covered by your
[ganisation? -open reply-(cornpulsory)

16000000

Your contribution will be published on the official 1 give permission for my feedback to be published as t is
website of the Targets Review Project and on
Your Voice in Europe. Please use the
dropdown list below to indicate if you want your
contribution to remain anonymous.
See Personal Data to view the Comrnission’s
guidelines regarding how your personal data is
protected. Your data is subject to the following
specific privacy statement:
“Received contributions, together with the
identity of the contributor, will be published on
the Internet, unless the contributor objects to
publication of the personal data on the grounds
that such publication would harm his or her
legitimate interests. In this case the contribution
may be published in anonymous form.
Otherwise the contribution will not be published
nor will, in principle, its content be taken into
account”
-single choice reply-(cornpulsory)

Waste Framework Directive
Do you want to respond to the questions 0fl the
Waste Framework Directive? 1f you select ‘No” you

Yes

can move on to the next section of the consultation
which deals with the Landfill Directive. 1f you select
“Yes” the questions relating to the Waste Framework
Directive will open up below.
-single choice reply-(compulsory)
Are there any issues related to the targets in the Waste Framework Directive which you feel are important and should be
added to those isted above? 1f so, please describe up to three additional issues in the text boxes below (please ensure
that you only enter one clearly defined issue per box). Please note that these issues should be associated with the
existing targets. not with other issues related to the general state of waste management.
First issue: -open reply-loptional)
Lacking and/or vague definitions in the directives lead to different interpretations, and consequently to varying enforcement and licensing
in different Member States. This influences international trade and the level playing field. Examples of unclear definitions are “household
waste”, “municipal waste” and “similar waste”. Avoid these detinitions or define them in a very dear manner.

Second issue: -open reply- Îiu
Monitoring, validation, calculation and reporting is carried Out differently in Member States.

Third issue: -open reply-D;[
In reviewing targets it is important to weigh benefits of setting ambitious targets and keep involved the Member States that face
difficulties complying those targets. As long as several Member States are far from achieving targets, setting more ambitious targets
might not be effective.

Suggestions for Revision
1. Establish a single target and calculation

3 = moderately good idea, may be worth further consideration

method based only on the quantity of municipal
waste collected. This would require that a
consistent definition of municipal waste is used
in all Member States. -single choice reply-(optionall
2. Extend the existing targets to include other
3 = moderately good idea, may be worth further consideration
specific waste streams beyond paper, metal,
plastic and glass (for example, wood, food
waste, textiles, and other materials in municipal
waste). -single choice reply

3. Establish a single target and calculation
5 = very good idea, definitely deserves further consideration
method based only on the quantity of household
waste collected. This would require that a
consistent definition of household waste is used
in all Member States. -single choice reply- Lviiall

4. Adjust the targets so that biowaste is also

3 = moderately good idea, may be worth further consideration

included -single choice reply- r

5. Set targets which reflect environmental
weightings for materials (for example, through
reference to greenhouse gas savings achieved
through recycling). -single choice reply

4

6. lmprove monitoring and validation of the

5 = very good idea, definitely deserves further consideration

reports submitted by Member States so that the
consistency and reliability of data can be

vaIidated. -single choice reply-c;
(7. Introduce requirements on businesses to sort :3 = moderately good idea, may be worlh further consideration
;a range of waste materials for recycling and
composting / anaerobic digestion. -single choice
reply- f•r1al)

8. The 70% recycling target should not include

5 = very good idea, definitely deserves further consideration

backfilling. -single choice reply- cr

9. Provide dear definitions of recycling and
material recovery, and how these should be
calculated for the C&D waste stream. -single

5 = very good idea, definitely deserves further consideration

choice reply-

10. Mandate sorting of wastes at C&D sites with 4
a special attention to hazardous waste. -single
choice reply

1 1. Require facilities which sort ‘mixed C&D
wastes to achieve a high level of recycling of
the input materials. -single choice reply

4

Are there any other proposals in addition to the above that you feel deserve serieus consideration? 1f so, please describe up to three
additional solutions in the text boxes below (as in the list above, please ensure that you only enter one clearly defined solution per box).
Please only include options which you strongly favour.
First solution:
-open reply
Clarify definitions to avoid ditferent interpretations. Clarify responsibilities of different actors to ensure a level playing field.

Second solution: -open reply
Uniform monitoring, validation, calculation, reporting and enforcement.
Third solution: -open reply-:
Remove the exclusion of hazardous waste from the calculation method for the target of C&D waste.

Landtili Directive
Do you want to respond to the questions on the
Landfill Directive? 1f you select “No’ you can move en
to the next section of the consultation which deals
with the Packaging and Packaging Waste Directive. 1f
you select “Yes” the questions relating to the Landfill
Directive will open up below.
-single choice reply-(compulsory)

Key Issues
Are there any issues related to the targets in the Landfill Directive which you feel are important and should be added to
those listed above? It so, please describe up to three additional issues in the text boxes below (please ensure that you
only enter one clearly defined issue per box). Please note that these issues should be associated with the existing targets,
not with other issues related to the general state of waste management.
First issue: -open reply
Targets should be set ter household and industrial waste instead of municipal waste.

Second issue: -open reply

Third issue: -open reply-

‘al)

Suggestions for Revision
1. Revise the targets so that they are set in such 2
a way that they do not penalise countries whose
economies are growing faster after starting from
a lower base. -single choice reply-ootcDrL

2. Establishagal obligation for reporng
municipal waste’ and enforcing the use of a
single definition of the term by all Member

moderately good idea, may be worth further consideration

States. -single choice repIy-:ii

3. Standardise the approach to performance
measurement and progress reporting. -single

5

very good idea, definitely deserves further consideration

1choice reply

4.In Member States where no data exists for
2
1995, a more recent baseline year should be set
with targets adjusted accordingly. -single choice

15. Clarify when treated waste should be

5 = very good idea, definitely deserves further consideration

considered no longer biodegradable’ from the
perspective of the Landfill Directive. -single choice
reply- i W)

6. Further tighten existing targets (eg. move
3 = moderately good idea, may be worth further consideration
progressively towards zero biodegradable
municipal waste sent to landfiii). -single choice reply
(oPt!Onal)

7. Progressively include all biodegradable
wastes (not just biodegradable wastes of
municipal origin) within targets similar to the

15 = very good idea, definitely deserves further consideration

existing ones. -single choice reply

8. Introduce targets for the progressive
reduction in the quantity of residual waste
irrespective of how it is subsequently managed
(whether it is sentto incineration, MBT or
landfill, or any other residual waste

2

managernentrnethod).-siglechoice reply-

9.Definepre-treatment’ in an unambiguous
5 = very good idea, definitely deserves furlher consideration
landfilling
waste
that
that
the
ban
on
so
!manner
is not pre-treated is applied equally across all
icountries. -single choice reply
Are there any issues related to the targets in the Landt ilI Directive which you feel are important and should be added to those listed
above? 1f so, please describe up to three additional issues in the text boxes below (please ensure that you only enter one clearly

defined issue per box). Please note that these issues should be associated with the existing targets, not with other issues related to the
general state of waste management.
First solution:
-open reply-

1)

In reviewing targets t is important to weigh benefits of setting ambitlous targets and keep involved the Member States that face
difficulties complying those targets. As long as several Member States are far from achieving targets, setting more ambitious targets
-

might not be effective.
Second solution: -open reply-cl
Suggestion 2: we support the uniform reporting, however, targets should be set for household and industrial waste instead of municipal
waste.
Third solution: -open reply-t

Packaging and Packaging Waste Directive
Do you want to respond to the questions on the Yes

Packaging and Packaging Waste Directive? 1f
you select “No” you can move on to the next
section of the consultation which deals with the
Roadmap to a Resource Efficient Europe. 1f you
select Yes” the questions relating to the
Packaging and Packaging Waste Directive will
open up below. -single choice reply-(compulsory)

Key Issues
Are there any issues related to the existing targets which you feel are important and should be added to those listed
above? It so, please describe up to three additional issues in the text boxes below (please ensure that you only enter one
clearly defined issue per box). Please note that these issues should be associated with the existing targets, not with other
issues related to the general state of, for example, markets for recycled packaging waste.
First issue: -open reply
Enforcement differs among Member States.
Second issue: -open reply
The option in the Packaging Directive to calculate the recycling percentages as laid down in Commission Decision 2005/270/EC, by
using the amount placed on the market (art. 2, sub 2, last phrase) is not in line with the calculation methods offered in the WED.
Third issue: -open reply
Lacking of any adoption of bioplastic packaging.

Suggestions for Revision
1. The methodology for calculating recycling rates

5 = very good idea, definitely deserves further consideration

should be standardised so that data (and hence
performance levels) are comparable across Member
States.
-single choice reply

2. Remove from the Packaging Directive the target
for packaging waste from municipal sources and

‘2

include it into the Waste Framework Directive to
ensure full consistency with the existing target on
municipal waste recycling.
-single choice reply3. Bring the recycling targets for different materials

2

closer together to ensure a more level playing field.
-single choice reply

4. Incorporate “weightings’ for materials
recycled based on environmental benefits
derived from recycling the material. -single choice

4

5. The targets for some packaging materials
5 = very good idea, definitely deserves further consideration
could be subdivided into subcategories; for
example, metals could be divided into
(non-ferrous and ferrous metals. The same could
apply for plastic; for example, separate targets
could be set for PET, LDPE, and HDPE. -single
choice reply

Setspecifictargets for recycng of packaging 13 = moderately good idea, may beworthfurtherconderaflon
waste from households to encourage further
recycling of household packaging. -single choice
reply-(optional)

7. Remove from the Directive the maximum limit 5 = very good idea, detinitely deserves further consideration
of 80% that stipulates how much packaging
waste a Member State is allowed to recycle.
-single choice reply-D

8. Introduce a target for prevention of packaging 1 = poor idea, not worth consideration
waste (the development of waste prevention
targets is covered in a broader manner in a later
section of this consultation). -single choice reply
(optionaij

9. Adjust the definitions for reuse and recycling
in the Packaging Directive to be consistent with
those contained in the Waste Framework

5 = very good idea, definitely deserves further consideration

Directive. -single choice reply

10. Expand the recycling target to include reuse, 4
by allowing the reuse of packaging to be
credited to the recycling target. -single choice reply
(optional)

11. Introduce targets for reuse for commercial

4

transit packaging. -single choice reply-ri

12. Introduce targets for reuse for all packaging. 3 = moderately good idea, may be worth further consideration
-single choice reply

Are there any other proposals ifi additiofi to the above that you feel deserve serious consideration? 1f so, please describe up to three
additioflal solutiofis ifi the text boxes below (as ifi the list above, please ensure that you only enter one clearly defined solutiofi per box).
Please only include options which you strongly favour.

First solution:
-open reply-’ ‘u’ni
Next to the environmental pressure of packaging, take aiso care of the product-packaging combination (eg. more packaging could lead
to less food waste due to postponed expiration date).
Second solution: -open reply-optional
lntroduce European quality standards to ensure a level playing field.
Third solution: -open reply
Formulate a vision en bioplastics, based on a dear del1nition of bioplastics.
The Commission is keen to encourage higher rates

75%

of recycling. It recognises, however, the need to
maintain the quality of recycled material so that it can
be used profitably and with losses kept to a minimum
between the collection and recycling stages. Keeping
in mmd the need to maintain quality, please select
from the dropdown lists below the highest level of
recycling that you believe could reasonably be
achieved for each of the materials. Below you will be
asked the year by which you believe these targets
could realistically be achieved (i.e. between 2020 and
2025).
Paper and Cardboard:
-single choice reply-op ‘t!.
Glass -single choice reply-t•

Metals -single choice reply-

ional)

90%
85%

Plastic: -single choice reply-

50%

Wood: -single choice reply-tt.

45%

AHPackaging -single choice rep’-itDÈ

70%

Other Material (please specify below) -single

50%

(choice reply-’:’

1f you have entered a recycling rate for Other
Material above, please state what material this

Beverage carton

isfor-openreply-’ Ph

Paper and Cardboard -single choice reply- .i»

2022

Fiss -single choice reply-’c’’’

2022

Metals -single choice reply-’

2022

Plastic -single choice reply-’t!n.

2022

INood -single choice reply-

2022

All Packaging -single choice reply- DMunal)

2022

Other material (as defined above) -single choice

2022

reply- ptional)

Consultation Regarding the Aspirations of the Roadmap to a Resource Efficient
Europe
Waste Prevention
Do you agree with the principle that there should be

Yes

targets for waste prevention?
-single choice reply-(compulsory)
Do you think there is a case for setting prevention targets on specific waste streams/materials/products? 1f so, which waste
streams/materials/products do you feel should be covered by new targets and why? Please provide an answer for each material/waste
stream in the free text boxes below.
Waste Stream /Material/Product A:
-open reply
Yes, there is a case for setting prevention targets, however, only on specific waste streams and provided that the targets can be realized,
monitored and enforced. Setting relative targets could be a possibility. However, further research is needed to investigate how these
targets should be set.
Waste Stream /Material/Product ‘B’: -open reply-loptional)

Waste Stream /Material/Product ‘C: -open reply-

Waste Stream /Material/Product D: -open reply

1. In line with the proposal in the Roadmap, a
requirement that waste generated per capita is

3 = moderately good idea, may be worth further consideration

.2. Targets for decoupling of municipal waste
4
from economic growth in line with Article 9(c) of
the Waste Framework Directive. For example,
the difference between the annual change in
municipaI waste per capita (X%) and the annual
change in GDP per capita (Y%) should
jdemonstrate a decoupling tendency such that
)over comparable (eg. four year) periods, the
value of (Y X) is increasing in value. -single
—

choicerepIy- :r

3. Consistent reporting of household waste
arisings across Member States would act to

4

produce a level playing field for setting absolute
itargets on waste prevention (e.g. no greater
[than X kg per household per year). The targets
could exhibit a declining trend over time. -single
choice reply
14. New requirements could be set on Member

2

States to incrementally increase the number of
prevention measures in place, and the overall
1
coverage of these measures. For example, the
number of househoids who have signed up to
say no” to unwanted mail, or the number of
househoids covered by measures to reduce
food wastage. -single choice reply- ;r
----

5. Introduce requirements for progressive
coverage of househoids by pay-as-you throw

3 = moderately good idea, may be worth further consideration

schemes. -single choice reply

Preparation for Reuse
Do you agree with the principle that there should Yes
be separate targets for preparation for reuse?
-single choice reply-icompulsory)

Do you think there is a case for targets for preparation for reuse on specific waste streams/materials/products? It so, which waste
streams/materials/products do you feel should be covered by a target, and how should the target be specified? Please provide an
answer for each material/waste stream in the free text boxes below.
Waste Stream /Material/Product ‘A’:
-open reply
In the question above we mean: “No”, however, to mention the following exception we had to dick “Yes” in the drop down box. Car
wrecks could be a suitable waste stream for targets on preparation for reuse. However, this is only a small stream.
Waste Stream /Material/Product ‘B’:
-open reply

Waste Stream /Material/Product ‘C’:
-open reply-,al)

Waste Stream /Material/Product ‘D’:
-open reply

Recychng Rates
Do you agree with the view that recydling rates

Yes

should be increased and/or be made to include more
materials/waste streams?
-single choice reply-)compulsory)

Household Waste -single choice reply- :ional)

65%

Municipal Waste -single choice reply-

65%

65%
Industrial Waste -single choice reply-

80%

Construction & Demolition Waste -single choice

90% or more

reply

hiorder to take into account the large
differences between Member States’ current
recycIing levels, would you agree that an
approach which sets targets relative to the
existing situation in each Member State (for
instance ncrease of recycling rates by X% per

No

year) is appropriate? -single choice reply-

So far only municipal waste and construction and demolition waste are covered by specific recycling targets in the Waste Framework
Directive, whilst other Directives cover packaging, WEEE, ELVs and batteries. Do you think there is a case for setting recycling targets
on waste streams/materials/products that are not already covered by targets in existing Directives? 1f 50, which waste
streams/materials/products do you feel should be covered by new targets and why?
Waste Stream /Material/Product ‘A’:
-open reply
Textile. Recycling of textile would be beneficial because manufacturing of textile entails major environmental pressure while it is still
discarded after use.
Waste Stream /Material/Product ‘B:
-open reply

Waste Stream /Material/Product ‘C’:
-open reply

Waste Stream /Material/Product ‘D’:
-open reply-vLc:f

Limiting Incineration of Waste Which Might Otherwise be Recycled
Do you agree with the view that a maximum level
should be set for the amount of waste that can be
incinerated for different waste streams (e.g.
household waste and/or commercial waste)?
-single choice reply-l compulsory)

Landf iii
1. Landfilling should be limited to residues from
a specified range (to be determined) of waste
treatment operations. -single choice reply[JandfiIIin should be limited to a certain

No

percentage of waste generated (for nstance
5%) from a part icular date. -single choice reply

13. Landflhling of recyclable/compostable waste

5 = very good idea, definitely deserves further consideration

(to be defined) should be banned. -single choice
reply

4. Landtilling of waste that is combustible should 5 = very good idea, definitely deserves further consideration
be banned. -single choice reply-:ul)

5.LandfUHng of wasteshoubebanned f [th
not been pre-treated to a level where the
potential to lead to methane emissions from
Iandfills has been virtually eliminated. -single
Ichoice reply-

5=verygood idea, definitely deservesfurtherconsiderahon

lonall

Are there any other proposals in addition to the above that you feel deserve serious consideration? 1f so, please describe up to three
additional solutions in the text boxes below (as in the list above, please ensure that you only enter one clearly defined solution per box).
Please only include options which you strongly favour.
First solution:
-open reply
Suggestion 2 proposes to limit Iandfill to a certain percentage of waste generated, however. a distinction should be made between
different waste streams.
Second solution:
-open reply

Third solution:
-open reply

In order to take into account the large differences
No
between Member States current levels of landfilling.
1 would you agree that an approach which sets targets
that take account of the existing situation in each
Member State is appropriate (for instance by fixing a
landfilling reduction percentage per year)?
-single choice reply

Targets as a Tool in Waste Legislation
Do you believe the Commission should go

Yes

further than simply setting targets for Member

States to achieve? 1f you select “No” there are
no more questions and you can submit your
response by clicking on the button below. -single

1 choice reply-(compuIsory
Suggestions for Change
1. Develop guidance on the implementation of
effective producer responsibility schemes to

Yes

improve the transparency of the systems as well
as their cost effectiveness. -single choice reply
loptonaI)

2. Develop guidance on the proper
implementation of the waste hierarchy. -single

Yes

choice reply

3. Ensure a closer monitoring by the
Yes
Commission of progress accomplished by
Member States in applying the waste hierarchy.
For those Member States moving too slowly to
meet the legally binding targets, develop
mechanisms to ensure that key instruments
such as a combination of economic and legal
instruments (landfill/incineration taxes/bans,
EPR schemes, incentives for municipalities and
citizens, etc.) are applied. -single choice reply
optional)

4. Develop criteria for municipalities to
No
implement services of a minimum standard to
enable sorting of a range of waste materials for
recycIing and composting / anaerobic digestion.
-single choice reply-

5H mp rove the con sten cy of the def in hio ns ‘Yes
used in the legislation and ensure proper
imonitoring by improved data collection and
systematic reliability and validity checks of data
reported. -single choice reply

Are there any other proposals in addition to the above that you feel deserve serious consideration? 1f so, please describe up to three
additional solutions in the text boxes below (as in the list above, please ensure that you only enter one clearly defined solution per box).
Please only include options which you strongly favour.
First solution:
-open reply- optional)
:1) Link waste policy to industry policy (eg. create jobs in re-use and recycling, discuss sustainability and recycling when negotiating
trade agreements, set requirements regarding recycling and re-use on new products). 2) Stimulate Member States to promote the waste
hierarchy by legal instruments (bans) and tinancial instruments (subsidies and tax schemes).

1 Second solution:
-open reply- optional)
3) Promote knowledge exchange, e.g. by exchanging best practices, a databank. establish contacts between entrepreneurs in different
Member States. 4) Promote changing roles of producer and consumer e.g. lease. 5) Promote sustainable procurement of Member

1 States’ public authorities.
Third solution:
-open reply- optionafl
6) Ensure coherent reporting and enforcement within EU. 7) Establish a European body that takes care ot harmonized implementation of
the directives.

General Comments

Would you like to add any general comments? 1f so, please use the space provided below.
-open reply
1) Unclear definitions also influence the answering of this consultation. Eg. our rating in questions on biowaste and backfilling depend on
interpretation of these definitions. 2) In paragraph 3 Recycling rates (questions on the Roadmap to a Resource Efficient Europe), the
percentages mentioned are ambitious and unlikely to be achieved easily by all Member States. 3) The directives, Roadmap and
• consultation focus on targets for government and businesses. while the consumer has a major influence on the quality and quantity of
waste arising, through, for example. consumer acceptance and commitment to waste separation. 4) The review should assess where the
current waste directives. and other related legislation, prevent resource efficiency (circular economy). Eg. consider how to deal with the
negative impact REACH authorization may have on the recycling activities and ambitions in Europe. 5) Consider subsidiarity. 6) Ensure
opportunities for new and innovative technologies. 7) Problems appear related to Essential Requirements of packaging. However, this is
out of the scope of this consultation and therefore these issues are not mentioned here.