European Commission Brussels
Support to Member States in improving hazardous waste
management based on assessment of Member States' performance
Reference: ENV/2014/SI2.689463/ETU/A2
− FINAL REPORT −
December 2015
In cooperation with
ENV/2014/SI2.689463/ETU/A2 2
European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
CLIENT European Commission
Directorate-General Environment
Unit ENV.A.2
BU9 5/128, B-1049 Brussels, Belgium
Report title Final report
Date December 2015
PROJECT Support to Member States in improving hazardous waste management based
on assessment of Member States' performance (ENV/2014/SI2.689463/ETU/A2)
Service Request under the Multiple Framework Contract with re-opening of
competition “Assistance to the Commission on the assessment of Waste
Management Plans and on compliance monitoring and support of the
implementation of the Waste Framework Directive“ (ENV.C.2/FRA/2013/0023)
CONSULTANT BiPRO GmbH, Munich, Germany
PROGNOS A.G., Berlin, Germany
CONTACT Nicole Seyring / Marie Dollhofer
BiPRO GmbH
Grauertstrasse 12
81545 Munich,
Germany
Telephone +49-89-18979050
Telefax +49-89-18979052
E-mail [email protected] / [email protected]
Website http://www.bipro.de
Disclaimer This report has been prepared for the European Commission in accordance with
the associated contract. It must be stressed that the views expressed in this
report which are not otherwise assigned are those of the authors and are not
necessarily shared by the European Commission.
Note This report is the final report including the results of all project tasks. The
report is accompanied by a screening information document for 18 EU Member
States and a factsheet for 10 EU-Member States. These documents are provided
separately from the present report. An overview of these documents is included
in Annex I. All documents can be downloaded at the following European
Commission website:
http://ec.europa.eu/environment/waste/index.htm
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Content
List of tables .......................................................................................................................... 6
List of figures ......................................................................................................................... 7
Glossary and abbreviations .................................................................................................... 8
Executive summary .............................................................................................................. 11
Background ................................................................................................................. 16
Tasks and structure of the study .................................................................................. 17
Screening of hazardous waste management of 28 EU-MS ............................................ 18
3.1 Screening methodology ......................................................................................................... 18
3.2 Detailed screening results ...................................................................................................... 20
3.2.1 Content of waste management plans (WMPs) / waste prevention programmes (WPPs) ............................ 20
3.2.2 State of compliance with the legal requirements of waste legislation ......................................................... 25
3.2.3 Collection and treatment of hazardous waste .............................................................................................. 34
3.2.4 Available data on generation and management of hazardous waste .......................................................... 46
3.2.5 Enforcement of hazardous waste legislation (inspection, penalties) ........................................................... 50
3.3 Generated amounts and most relevant hazardous waste streams ........................................... 53
3.4 Summary of screening results ................................................................................................. 56
3.4.1 Hazardous waste management performance according to five main categories ........................................ 59
3.4.2 Summary of HW performance assessment for each Member State ............................................................ 63
3.4.3 Grouping of Member States ......................................................................................................................... 70
3.4.4 Proposal for Member States to be included for in-depth assessment ......................................................... 71
Hazardous waste statistics and selection of 10 EU-MS ................................................. 73
4.1 Statistical gap on generation and treatment of hazardous waste ............................................. 73
4.2 Selection of 10 EU-MS for in-depth analysis ............................................................................ 78
In-depth analysis for 10 selected EU-MS ...................................................................... 80
5.1 Method for in-depth analysis of 10 EU-MS .............................................................................. 80
5.2 Hazardous waste management practice in 10 EU-MS .............................................................. 81
5.2.1 Summary of HW management in Bulgaria .................................................................................................... 81
5.2.2 Summary of HW management in Estonia ..................................................................................................... 82
5.2.3 Summary of HW management in Finland ..................................................................................................... 84
5.2.4 Summary of HW management in Germany .................................................................................................. 85
5.2.5 Summary of HW management in Ireland ..................................................................................................... 86
5.2.6 Summary of HW management in Italy .......................................................................................................... 87
5.2.7 Summary of HW management in Latvia ....................................................................................................... 88
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5.2.8 Summary of HW management in Luxembourg ............................................................................................. 89
5.2.9 Summary of HW management in the Netherlands ....................................................................................... 90
5.2.10 Summary of HW management in the United Kingdom ................................................................................ 91
5.3 Particular issues with statistical data ...................................................................................... 93
5.3.1 Particular issues with statistical data in Bulgaria .......................................................................................... 97
5.3.2 Particular issues with statistical data in Estonia ........................................................................................... 99
5.3.3 Particular issues with statistical data in Finland ......................................................................................... 100
5.3.4 Particular issues with statistical data in Germany ...................................................................................... 102
5.3.5 Particular issues with statistical data in Ireland .......................................................................................... 104
5.3.6 Particular issues with statistical data in Italy .............................................................................................. 106
5.3.7 Particular issues with statistical data in Latvia ............................................................................................ 108
5.3.8 Particular issues with statistical data in Luxembourg ................................................................................. 110
5.3.9 Particular issues with statistical data in the Netherlands ........................................................................... 112
5.3.10 Particular issues with statistical data in the United Kingdom ..................................................................... 114
5.4 Particular problems with hazardous waste management ....................................................... 117
5.4.1 Problems as regards HW management planning and treatment capacities............................................... 117
5.4.2 Problems with particular waste streams and technologies ........................................................................ 117
5.4.3 Problems as regards data quality and reporting procedures ...................................................................... 118
5.4.4 Problems as regards HW classification ....................................................................................................... 118
5.4.5 Problems as regards collection, storage and labelling ................................................................................ 121
5.4.6 Problems as regards record keeping ........................................................................................................... 122
5.4.7 Problems as regards permitting practice .................................................................................................... 123
5.4.8 Problems as regards enforcement and inspections .................................................................................... 124
Good HW management practices in the Member States ............................................ 126
6.1 Good examples as regards HW management planning and treatment capacities .................... 126
6.2 Good examples with particular waste streams and technologies ............................................ 127
6.3 Good examples as regards data quality and reporting procedures .......................................... 127
6.4 Good examples as regards HW classification .......................................................................... 129
6.5 Good examples as regards collection, storage and labelling ................................................... 129
6.6 Good examples as regards record keeping ............................................................................. 132
6.7 Good examples as regards permitting practice ....................................................................... 132
6.8 Good examples as regards enforcement and inspections ....................................................... 134
6.9 Good examples as regards cooperation and communication .................................................. 137
Recommendations to improve HW management....................................................... 138
7.1 Recommendation addressing the European Commission ....................................................... 138
7.2 Recommendation addressing Eurostat .................................................................................. 139
7.3 Recommendation addressing the Member States .................................................................. 140
7.3.1 General recommendations for all Member States ..................................................................................... 140
7.3.2 Member State specific recommendations .................................................................................................. 142
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Conclusions ............................................................................................................... 150
Information Sources .................................................................................................. 154
Annex ....................................................................................................................... 179
10.1 Annex I: Overview on MS screening information (18 MS) and MS factsheets (10 MS) .............. 179
10.2 Annex II: Overview on responses by TAC members ................................................................ 181
10.3 Annex III: Overview of conducted expert interviews .............................................................. 182
10.4 Annex IV: Specific problems on HW management in Member States ...................................... 186
10.5 Annex V: Overview on available and screened national and regional WMP ............................ 189
10.6 Annex VI: Overview on available and screened national waste prevention programmes ......... 201
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List of tables
Table 2-1: Overview on project tasks completed during the project ............................................. 17
Table 3-1: Overview of screening criteria on hazardous waste performance ................................ 18
Table 3-2: Overview of most important HW streams as generated in EU-28 MS .......................... 53
Table 4-1: Differences between hazardous waste generation and treatment within EU-28 (Source: Eurostat, 2012, data as of 25.03.2015) ............................................................ 73
Table 4-2: Summarised answers to verify statistical treatment data (screening phase) ................ 75
Table 5-1: Overview on statistical data collection procedures in ten EU MS ................................. 95
Table 5-2: Summary on statistical data, differences and explanations for Bulgaria ....................... 97
Table 5-3: Summary on statistical data, differences and explanations for Estonia ........................ 99
Table 5-4: Summary on statistical data, differences and explanations for Finland ...................... 101
Table 5-5: Summary on statistical data, differences and explanations for Germany ................... 102
Table 5-6: Summary on statistical data, differences and explanations for Ireland ...................... 104
Table 5-7: Summary on statistical data, differences and explanations for Italy ........................... 106
Table 5-8: Summary on statistical data, differences and explanations for Latvia ........................ 108
Table 5-9: Summary on statistical data, differences and explanations for Luxembourg .............. 110
Table 5-10: Summary on statistical data, differences and explanations for the Netherlands........ 113
Table 5-11: Summary on statistical data, differences and explanations for the United Kingdom ....................................................................................................................... 114
Table 6-1: Good practice example from the United Kingdom ...................................................... 126
Table 6-2: Good practice example from France ............................................................................ 128
Table 6-3: Good practice example from Luxembourg .................................................................. 130
Table 6-4: Good practice example from Belgium.......................................................................... 133
Table 6-5: Good practice example from Ireland ........................................................................... 136
Table 6-6: Best practice example from Germany.......................................................................... 137
Table 10-1: Overview on responses by TAC members .................................................................... 181
Table 10-2: Overview of available and screened national and regional WMPs (February 2015) ............................................................................................................................ 189
Table 10-3: Overview of available regional WMPs of Germany (February 2015) ........................... 193
Table 10-4: Overview of available regional WMPs of United Kingdom (February 2015) ............... 197
Table 10-5: Overview of available regional and provincial WMPs of Italy (February 2015) ........... 198
Table 10-6: Overview on available and screened waste prevention programmes (WPPs) ............ 201
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
List of figures
Figure 3-1: Overall scoreboard of the screening results for HW management in the 28 Member States in alphabetical order ............................................................................ 57
Figure 3-2: Overall scoreboard of the screening results for HW management in the 28 Member States in scoring order..................................................................................... 58
Figure 4-1: Differences between HW generation and treatment per waste stream in EU-28 (2012) ............................................................................................................................. 74
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
Glossary and abbreviations
Abbreviation Explanation
ADR European Agreement concerning the International Carriage of Dangerous Goods
by Road
AT Austria
AVV German Federal Waste Catalogue Ordinance
Basel Y-code Waste code used for transfrontier shipment of waste under the Basel Convention
BAT Best Available Technology
BE-Br Belgium - Brussels
BE-Fl Belgium - Flanders
BE-Wa Belgium - Wallonia
BG Bulgaria
cap Capita
CLP Classification, Labelling and Packaging
CSO Central Statistical Office
CY Cyprus
CZ Czech Republic
D code /
D operation
According to WFD: disposal operations
D10 According to WFD: Incineration on land
D11 According to WFD: Incineration at sea
D13 According to WFD: Blending or mixing prior to submission to any of the
operations numbered D 1 to D 12
D14 According to WFD: Repackaging prior to submission to any of the operations
numbered D 1 to D 13
D15 According to WFD: Storage pending any of the operations numbered D 1 to D 14
(excluding temporary storage, pending collection, on the site where the waste is
produced)
D8 According to WFD: Biological treatment not specified elsewhere in this Annex
which results in final compounds or mixtures which are discarded by means of
any of the operations numbered D 1 to D 12
D9 According to WFD: Physico-chemical treatment not specified elsewhere in this
Annex which results in final compounds or mixtures, which are discarded by
means of any of the operations numbered D 1 to D 12 (e.g. evaporation, drying,
calcination, etc.)
DE Germany
Defra Department for Environment Food & Rural Affairs UK
Destatis German Federal Statistical Office
DK Denmark
EA Environment Agency
EC European Commission
EE Estonia
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
Abbreviation Explanation
EEA European Environment Agency
ELV End of life vehicle
ES Spain
ESA Environmental Service Association UK
EU European Union
EU-MS EU Member State
Eurostat Statistical Office of the European Union
EWC European Waste Catalogue
ExEA Bulgarian Executive Environment Agency
EXP Export
FI Finland
FR France
GEN Generation
GR Greece
HP Hazardous property
HR Croatia
HU Hungary
HW Hazardous Waste
IE Ireland
IED Industrial Emissions Directive
IMP Imports
ISO 140001 International Environmental Management Standard
ISO 9001 Quality Management Standard
ISPRA Italian Institute for Environmental Protection and Research
ISTAT Italian National Institute of Statistics
IT Italy
kg Kilogram
KrWG German Law on Life-Cycle Management
kt Kiloton
LAGA German Federal/State Waste Committee
LoW List of Waste
LT Lithuania
LU Luxemburg
LV Latvia
MoE Luxembourg Ministry of the Environment
MS Member State
MSDS Material Safety Data Sheets
MT Malta
MW Megawatt
NACE codes Statistical classification of economic activities
NIS Bulgarian National Statistical Office
NL Netherlands
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
Abbreviation Explanation
OPRA Operational Risk Appraisal
PAH Polycyclic aromatic hydrocarbon
PL Poland
POP Persistent organic pollutants
PT Portugal
R code/
R operation
According to WFD: Recovery operations
R12 According to WFD: Exchange of waste for submission to any of the operations
numbered R 1 to R 11
R13 According to WFD: Storage of waste pending any of the operations numbered R 1
to R 12 (excluding temporary storage, pending collection, on the site where the
waste is produced)
R5 According to WFD: Recycling/reclamation of other inorganic materials
RO Romania
SDK SuperDrecksKëscht (actions of the Ministry for the Sustainable Development and
Infrastructure)
SE Sweden
SI Slovenia
SISTRI System for controlling waste tracking
SK Slovakia
SME Small and medium enterprise
TAC Technical Adaptation Committee
TFS Transfrontier Shipment
TRT Treatment
UBA German Federal Environmental Agency
UK United Kingdom
UK En England
UK Gb Gibraltar
UK NI Northern Ireland
UK Sco Scotland
UK Wa Wales
WDMS Waste Reporting System
WEEE Waste of Electrical and Electronic Equipment
WFD Directive 2008/98/EC on waste (Waste Framework Directive)
WMP Waste Management Plan
WPP Waste Prevention Programme
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Executive summary
In 2012, the 28 Member States of the European Union (EU-MS) produced altogether more than 2.5
billion tonnes of waste whereof 99 million tonnes were hazardous. Although this represents only a
minor share of the total waste production in the EU, hazardous waste (HW) is a priority waste stream
as its properties may cause severe negative impacts on human health and the environment in case it
is improperly managed.
Directive 2008/98/EC on waste1 (Waste Framework Directive or WFD) repealed and incorporated,
inter alia, the previous Directive on Hazardous Waste (Directive 91/689/EEC2), as part of the effort to
simplify and streamline European waste legislation. The WFD sets specific provisions on hazardous
waste management that have to be implemented into national legislation and need to be enforced in
practice. The objective of this study was to assess the national HW management practices in the 28
EU Member States in order to evaluate their performance with the final aim of making
recommendations for improvement. To this end, the following project tasks have been
accomplished:
1. Developing criteria and a methodology for the assessment of Member States' HW
management practices (screening methodology);
2. Screening of national HW management practices against the criteria developed;
3. Analysing waste statistics, including a detailed investigation of the statistical data of ten
Member States with particular focus on a gap identified in the data on the generation and
treatment of HW;
4. Identifying HW management practices and problems with HW management of 10 selected
MS (in-depth analysis for ten selected EU Member States - Bulgaria, Estonia, Finland,
Germany, Latvia, Luxembourg, Ireland, Italy, the Netherlands and the United Kingdom);
5. Presenting HW management best-practice examples;
6. Elaborating a set of general and specific recommendations for improving HW in the Member
States
7. Organising a stakeholders' workshop.
How was the Member States performance assessed?
First, a set of criteria reflecting the main elements and legal requirements on HW stemming from
the Waste Framework Directive has been elaborated. The screening methodology has been sent for
consultation to stakeholders, including to competent authorities from all 28 EU Member States,
European organisations3, hazardous waste associations4, and selected waste management
1 OJ L 312, 22/11/2008, p. 3–30. 2 OJ L 377, 31/12/1991 p. 20-27. 3 European Environmental Agency (EEA), European Environmental Bureau (EEB), Institute for European Environmental Policy (IEEP), Fédération Internationale du Recyclage (FIR), Friends of the Earth Europe, Greenpeace Europe, Improving Implementation of EU Environmental Law (IMPEL)
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companies5. Based on the technical specifications outlined by the European Commission, the
screening criteria included the following elements:
1. Contents of the national waste management plans (WMP) and waste prevention
programmes (WPP) (3 criteria);
2. State of compliance with the legal requirements of waste legislation (including classification,
labelling, record keeping and tracing system, permitting and mixing ban) (7 criteria);
3. HW management collection and treatment infrastructure; capacities and bottlenecks in the
hazardous waste management systems (8 criteria);
4. Available data on the projections of generation and management of HW (2 criteria);
5. Enforcement of HW legislation (including inspection capacity and deterrent measures such
as penalties etc.) (3 criteria).
Thus, in total 23 criteria have been elaborated to assess the hazardous waste management
performance of the EU Member States.
What has been concluded from the screening?
The result of the screening exercise showed that there are differences between the Member States
in implementing the HW requirements of the WFD. However, according to present research there is
no ‘sharp’ demarcation line between the groups of “good” performers and the group of countries
having implementation gaps. Furthermore, as it has emerged from our research, and was also
confirmed by the work of the European Environment Agency, there are major gaps on statistical data
(generation/treatment of hazardous waste) for some Member States, which makes interpretation of
the overall results of the screening exercise difficult. The issue of the statistical gap between the
generation and treatment of hazardous waste was considered a worrying finding. Therefore the
second phase of the study concentrated on analysing and clarifying this finding.
Which Member States have been selected for in-depth assessment?
Ten countries were selected for in-depth assessment, with the main objective to analyse available
information in order to understand and clarify, to the extent possible, the reasons for the statistical
data gap found for certain Member States. These ten countries were:
Five countries with the biggest gaps between reported generated and treated HW (Eurostat data):
Luxembourg (gap estimated as 99%)
Ireland (gap estimated as 96%)
Latvia (gap estimated as 80%)
4 Hazardous Waste Europe (HWE), European Association for co-processing (EUCOPRO), European Union for the Responsible Incineration and Treatment of Special waste (Eurits), European Federation of Waste Management and Environmental Services (FEAD) European Federation of Waste Management and Environmental Services (FNADE), Asociación de Empresas Gestoras de Residuos y Recursos Especiales (ASEGRE) Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e.V (BDE), Croatian Association of Professionals in Nature and Environmental Protection (HUSZPO) 5 REMONDIS, Veolia, SITA
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Italy (gap estimated as 66%)
United Kingdom (gap estimated as 68%)
Five countries with the smallest gap between reported generated and treated HW (Eurostat data):
Estonia (gap estimated as 0%)
Bulgaria (gap estimated as 0%)
Netherlands (gap estimated as 10%)
Finland (gap estimated as 11%)
Germany (gap estimated as 15%)
What was the method for in-depth analysis of 10 EU Member States?
Based on the information collected in the screening phase of the project, the following issues
seemed of particular importance:
1. To make a thorough assessment of the countries' hazardous management practices and
analyse their specific problems in fulfilling the objectives and provisions of the Waste
Framework Directive as regards hazardous waste;
2. In particular, a detailed assessment of the measures for HW collection and storage was
undertaken, which included checking further guidelines, working instructions and assessing
the actual practices (e.g. through interviews). The assessment covered the entire geographic
territory of each Member State;
3. To analyse and explain what are the reasons for the gap between the generation and
treatment of HW. For Estonia (EE) and Bulgaria (BG), where the statistical gap is 0%, a
comprehensive analysis of their actual HW management practices was undertaken,
considering that these countries generate high levels of HW and disposal is almost exclusively
on landfills;
4. To identify the problems of HW management;
5. To identify good practices;
6. To make proposals and recommendations: general recommendations for all Member States
and particular for the selected Member States.
What was the result of assessing the 28 Member States' performance?
Altogether it can be stated that there are no major gaps in the transposition of EU requirements into
national legislation and the declaration of responsibilities and enforcement measures (e.g. penalties).
However, there are differences in the quality and effectiveness of measures taken to support HW
management practice and to allow the authorities to properly follow, control, and manage HW. Also,
the actual performance of the Member States as regards the application of treatment operations in
line with the waste hierarchy varies and could potentially be improved. The following conclusions can
be drawn:
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Good transposition for most of EU requirements on HW with no deficits as regards the
implementation of labelling requirements and the mixing ban into national legislation;
remaining differences for setting derogations of the mixing ban and permitting of HW recovery
installations; large differences as regards record keeping systems, reporting obligations and
support of correct classification. However practice shows that implementation of all obligations
is facing problems for most of the requirements, in particular:
o As regards HW classification several problems are reported, i.e. waste classification system
is not very clear? and leaves room for interpretation; threshold values are not harmonised;
particular waste entries are over-used; there are problems with the assessment of HP 5, 10
and 14; support, helpdesk, guidance in national languages is often not available; definition
of test methods at times scarce; the links between the application of EU List of Waste and
Basel codes often lead to lack of clarity.. Particular waste streams for which classification
problems have been identified are WEEE, excavated oil, contaminated soil, oil containing
liquid waste, solvent, washing liquid and mother liquor, halogenated waste, certain mineral
wastes, clinker ash, waste containing POPs, bio-hazard waste and cytostatic hospital waste.
o The collection of HW waste seems to cause problems for particular waste streams (waste
oils, asbestos waste, contaminated C&D waste, medical waste, WEEE, HW from farms). For
some of these waste streams, the informal sector is involved in some Member States.
Problems regarding storage of HW are reported only for minor cases. As regards correct
labelling of HW waste, problems are reported in particular for small companies and SMEs,
which do not have the sufficient personnel and/or knowledge. Furthermore, different
labelling obligations for different modes of transport are causing problems (EU rules, ADR).
More national guidelines, templates and helpdesks are needed in these cases.
o Problems encountered with permitting practice are the parallel application of old/renewed
and new permits in combination with the fact that facilities hold several permits at the
same time, the addressing of different pieces of environmental legislation in the permit and
thereof insufficient focus on (hazardous) waste management. Additionally, companies
report slow permitting procedures. The mixing ban, well transposed in the MS legislation, is
encountered in practice with illegal activities and difficult control. Moreover, some MS
need to clarify the criteria enabling derogations from the mixing ban.
Different levels of performance regarding the separate collection of WEEE and batteries/
accumulators; large potential for improvement as regards the reliance on landfilling and the
practice of recovery operations for at least ten MS. Furthermore, there are gaps and difficulties
concerning the reliability of HW data in particular concerning the data basis used for reporting to
Eurostat. There are no gaps as regards the inclusion of general requirements on collection and
storage of HW into legislation, even though information from practical implementation shows
that there might be differences regarding implementation on the ground. In this regard, Best
Available Technology (BAT) requirements are either not at all or not sufficiently implemented
for specific waste streams or not adequately described in the permits.
Potential for improvement of the data reporting basis and publically available data on HW. As
regards waste data: The gap between HW generation and treatment in Eurostat statistics range
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
from 0 to 99%. This can be explained mainly by differences in reporting obligations under Eurostat
and national statistics, but also by discrepancies within the Eurostat reporting systems. Common
explanations for the statistical gap are double-counting (e.g. pre-treatment operations), storage
effects, missing information on import/export, reporting errors, application of different waste
codes (e.g. Basel code), change of reporting systems (paper to electronic). Also, the record
keeping obligation is not always well implemented at facility level (i.e. different record keeping
obligations across federal states, lack of user-friendliness) and administration level (e.g.
exemption for record keeping for WEEE and batteries). It seems that Member States applying an
electronic reporting system partly connected to notification and/or consignment notes show
lower gaps and discrepancies in data leading to the position that those reporting systems are
more reliable than others.
Good general enforcement of HW legislation as regards the definition of responsibilities and the
setting of penalties and fines, with differences in the assignment of enforcement
capacities/carried-out inspection activities. Deficiencies of enforcement are often due to the
heavy burden for administration and inspectors and their limited capacities, the overlap of
responsibilities of several authorities and insufficient communication between them, reduced
controls for smaller installations but large number of small and medium sized companies, too low
penalties, significant different level of enforcement actions in federal states and heavy
involvement of brokers and dealers.
All information collected through this study is also synthesised and presented in separate documents
for each Member State, called “screening information” (for 18 MS) and “factsheet” (for 10 MS,
including also further information from the in-depth analysis for those 10 selected MS). All
documents can be downloaded at the following EC website:
http://ec.europa.eu/environment/waste/index.htm
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Background
According to the Treaty of the European Union, the Commission has the task to ensure and oversee
the proper application of EU legislation6. Directive 2008/98/EC on waste7 (Waste Framework
Directive or WFD) sets the basic requirements on waste management including the "polluter pays
principle", the "waste hierarchy" and the need to ensure that waste management is carried out
without endangering human health and the environment. The WFD repealed and incorporated, inter
alia, the previous Directive on Hazardous Waste (Directive 91/689/EEC8), as part of the effort to
simplify and streamline European waste legislation.
In addition to provisions applying to all types of waste, the WFD contains specific provisions related
to the environmentally safe management of hazardous waste, such as
requirements on labelling and identification documents to be accompanied in case of
transferring the waste within a Member State (Article 19),
record keeping (Article 35),
monitoring and control obligations, and the so-called "mixing ban9" (Article 18).
Moreover, permit exemptions that may be granted to hazardous waste installations are more
restrictive (Article 25) than those for installations dealing with other wastes (Article 23). No specific
target has been set by the WFD to reduce the amount of hazardous waste. However, the WFD
provides for an implicit target: all hazardous waste needs to be handled in an environmentally safe
manner.
Whilst the Commission has undertaken a number of studies concerning the implementation of the
WFD's provisions on municipal waste, no recent studies have been realised to assess the
implementation of hazardous waste related provisions. The study ‘Support to Member States in
improving hazardous waste management based on assessment of Member States' performance’
therefore aims at providing an overview of status of implementation in all EU Member States and at
improving hazardous waste management practices of ten selected Member States.
6 Article 17(1) of the Treaty of the European Union: "The Commission shall promote the general interest of the Union and take appropriate initiatives to that end. It shall ensure the application of the Treaties, and of measures adopted by the institutions pursuant to them. It shall oversee the application of Union law under the control of the Court of Justice of the European Union."
7 OJ L 312, 22/11/2008, p. 3–30. 8 OJ L 377, 31/12/1991 p. 20-27. 9 mixing of hazardous waste with other waste, substances or materials, is banned in order to prevent risks for the environment and human health
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Tasks and structure of the study
Between October 2014 and October 2015, the following tasks have been realised during the project:
Table 2-1: Overview on project tasks completed during the project
Task/Deliverable Chapter of this report
Develop criteria and a methodology for the assessment of national waste management practices to the specificities of hazardous waste management (screening methodology)
Chapter 3
Screening of national waste management practices against the criteria developed
Chapter 3
Analysis of waste statistics including the identification of particular issues with statistical data and selecting ten Member States
Chapter 4
Identifying hazardous waste management practice, and problems with HW management of 10 selected MS (in-depth analysis for ten selected EU Member States - Bulgaria, Estonia, Finland, Germany, Latvia, Luxembourg, Ireland, Italy, the Netherlands and the United Kingdom).
Chapter 5
Identify and describe good HW management practice of the 10 selected MS including best-practice examples
Chapter 6
Elaborate a set of general and specific recommendations for improving hazardous waste management in the Member States
Chapter 7
Preparation and organisation of a workshop for Member State officials and stakeholders
Brussels 30 June 2015
This final report includes the results of all tasks. The results of task 1 and 2 (screening methodology
and screening) are summarised in this report, while results for the task 3 are extensively discussed.
For each of the 28 EU Member States (EU-MS), a document containing the country-specific
information has been prepared applying the following method:
In the screening phase, a document for each EU-28 MS has been elaborated including country
specific information on hazardous waste management. Those screening documents are mainly based
on available documents (national legislation, WMP, WPP, implementation reports, statistics) and
have been sent to the members of the Committee for the adaptation to scientific and technical
progress and implementation of the directives on waste established under Article 39 of Directive
2008/98/EC on waste (TAC) for commenting/verification of information.
For the ten selected Member States included in the in-depth analysis undertaken in the second phase
of the project, the screening documents served as a basis to develop factsheets on HW management
(fiches containing detailed information). Sources for the additional information were interviews with
various stakeholders (administration, industry, associations, science, etc.) and further research on
national reports and the internet.
A list of the 18 screening documents and 10 factsheets is included in Annex I/chapter 10.1. All
documents can be downloaded at the following EC website:
http://ec.europa.eu/environment/waste/index.htm.
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Screening of hazardous waste management of 28 EU-MS
3.1 Screening methodology
As a first project step, a methodology has been elaborated in order to screen the hazardous waste
management performance of all EU Member States against a set of criteria reflecting the main
elements and legal requirements on hazardous waste (HW) stemming from the Waste Framework
Directive. Based on the technical specifications outlined by the EC, the screening criteria included the
following elements:
1. contents of the national waste management plans (WMP) and waste prevention
programmes (WPP) (3 criteria);
2. state of compliance with the legal requirements of waste legislation (including classification,
labelling, record keeping and tracing system, permitting and mixing ban) (7 criteria);
3. HW management collection and treatment infrastructure; capacities and bottlenecks in the
hazardous waste management systems (8 criteria);
4. available data on the projections of generation and management of HW (2 criteria);
5. Enforcement of HW legislation (including inspection capacity and deterrent measures such
as penalties etc.) (3 criteria).
Thus, in total 23 criteria have been elaborated to assess the hazardous waste management
performance of the EU Member States, as included in the below table.
Table 3-1: Overview of screening criteria on hazardous waste performance
Content of WMP/WPP
Compliance with legal requirements
Collection and treatment
Data on generation and management
Enforcement
HW in waste management plan(s)
Support of HW classification
Requirements for collection and storage of HW
Existence/ quality of HW generation/ treatment data reported to Eurostat
Responsibilities and inspections
Industrial HW generation in waste management plan(s)
Procedures of HW labelling
Separate collection of WEEE
HW data available to public
Regular inspections and capacities
HW prevention targets in waste prevention programme
Existence of HW record keeping system
Separate collection of batteries and accumulators
Penalties and fines
Requirements for record keeping/ tracking system
Reliance on disposal for HW treated in the MS
Registration/permit procedures
Reliance on disposal for HW treated
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
Content of WMP/WPP
Compliance with legal requirements
Collection and treatment
Data on generation and management
Enforcement
within/exported to other country
Mixing ban Recovery of spent solvents
Derogation from mixing ban
Recovery of acid, alkaline and saline waste
Recovery of used oils
The screening methodology has been sent for consultation to stakeholders, including to competent
authorities from all 28 EU Member States, European organisations10, hazardous waste associations11,
and selected waste management companies12. The methodology and the criteria have been
intensively commented by 20 institutions; these comments have been taken into consideration for
the further development and refinement of the criteria.
The background to the criteria and the rationale behind them are explained in the following sub-
chapters.
In order to screen the performance of HW management in EU-28 Member States, data from publicly
available information sources have been assessed, such as:
• Waste management plans (national plans in all Member States, additionally regional plans in
DE, UK, IT, FR);
• National waste prevention programmes;
• National implementation report on the Waste Framework Directive;
• Member States’ relevant legislation on waste, including ordinances on waste recovery/
disposal records and further national regulations on implementation;
• Eurostat statistics, quality reports on statistics, national statistics;
• Selected interviews to verify information (statistics).
A complete list of the information sources used is included in chapter 8 (Information sources).
10 European Environmental Agency (EEA), European Environmental Bureau (EEB), Institute for European Environmental Policy (IEEP), Fédération Internationale du Recyclage (FIR), Friends of the Earth Europe, Greenpeace Europe, Improving Implementation of EU Environmental Law (IMPEL) 11 Hazardous Waste Europe (HWE), European Association for co-processing (EUCOPRO), European Union for the Responsible Incineration and Treatment of Special waste (Eurits), European Federation of Waste Management and Environmental Services (FEAD) European Federation of Waste Management and Environmental Services (FNADE), Asociación de Empresas Gestoras de Residuos y Recursos Especiales (ASEGRE) Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e.V (BDE), Croatian Association of Professionals in Nature and Environmental Protection (HUSZPO) 12 REMONDIS, Veolia, SITA
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
3.2 Detailed screening results
The following chapter 3.2.1 to 3.2.5 provides a detailed description of the screening criteria that have
been developed in order to evaluate the Member States' performance in the management of HW.
It has to be noted that the results presented for each criterion represent the status quo of screening
prior to the stakeholder consultation that has taken place once the screening was completed. For
verification and comments, the screening information has been sent to the TAC Members. The
replies received are included in chapter 10.2. Where appropriate changes, have been made in the
respective ‘screening information documents’/’factsheets’. However, for methodological reasons
the scoring results have not been changed.
All documents can be downloaded at: http://ec.europa.eu/environment/waste/index.htm.
3.2.1 Content of waste management plans (WMPs) / waste prevention programmes
(WPPs)
Criterion 1.1: Specification on HW in WMP
Background According to Article 28 (1) of the WFD,
“Member States shall ensure that their competent authorities establish, in
accordance with Articles 1, 4, 13 and 16, one or more waste management plans.
Those plans shall, alone or in combination, cover the entire geographical territory of
the Member State concerned”.
Further, according to Article 28 (3) of the WFD,
“The waste management plans shall contain, as appropriate and taking into account
the geographical level and coverage of the planning area, at least the following:
(b) existing waste collection schemes and major disposal and recovery installations,
including any special arrangements for waste oils, hazardous waste or waste
streams addressed by specific Community legislation”.
Therefore, it is assessed whether one or more legally adopted waste management
plan(s) covering the entire geographical territory exist and if these plan(s)
include(s) special arrangements for hazardous waste as required under the WFD.
Rationale Does a valid and adopted waste management plan exist?
Does it include specifications on hazardous waste?
Note: All waste management plans which have not yet been adopted, but for which
finished drafts are available and the schedule for adoption is known, have been
considered (and have been marked with * in the scoring table).
Source - Waste management plan(s) of Member States (see Annex IV)
- For DE and UK, all regional plans have been assessed (see Annex IV)
- For IT, a list of all regional plans has been collected based on information from
the Italian implementation report [IT WFD 2013] and regional websites (see
Annex IV)
- For FR, the overview on regional WMPs was used:
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http://carto.sinoe.org/carto/plans/flash/
- For both IT and FR, a request was made to the MOE to provide an updated list
of WMPs, however this list could not obtained
Results
Twenty-three MS have valid and adopted WMP (four of them close to adoption) which includes
specifications on hazardous waste; two further MS include these specifications in draft WMPs. Three
MS have WMP no valid WMP or the currently adopted WMPs do not cover the entire territory. Two
WMPs do not include specifications on hazardous waste.
Score of 2 for MS where adopted WMPs include specifications on HW (23 MS):
− AT, BG, CZ, DK, EE, ES, FI, HR, HU, LT, LU, LV, MT, NL, PL, PT, SE and SK have valid and
adopted WMPs which include specifications on HW.
− All three BE regions have valid and adopted WMPs including specifications on HW.
− UK has seven regional WMPs; all are adopted and included specifications on HW (see
Table 10-4).
− GR has a draft WMP available which includes specifications on HW.
− The majority of DE federal states have adopted WMPs which includes specifications on HW
generation; draft WMPs not officially adopted are available for Baden-Württemberg and
Mecklenburg-Vorpommern, also including the information on HW (see Table 10-3)
− IE has a draft WMP available for three newly formed waste regions; those drafts are not yet
adopted. However, an officially adopted HW for national Ireland exists including the HW
specifications.
Score of 0 for MS where WMPs are either not adopted or do not include specifications on HW (5
MS):
− CY adopted a new WMP in 2014; the WMP does not contain any information on HW.
− FR has 101 regional WMPs. A detailed overview of all WMP, their current as well as revision
status is available on the French online platform for waste management:
http://carto.sinoe.org/carto/plans/flash/. Following this information, at least some of the
regional plans seem to be outdated.
− For the 21 IT regional WMPs, at least five seem to be outdated; no drafts available (see
Table 10-5).
− The valid WMP for SI only includes municipal waste; however a draft is prepared including
other waste streams and HW scheduled for the end of 2015.
− RO has no WMP adopted; tendering procedure for a new draft started in 2015.
Criterion 1.2: Overview of industrial HW generation included in WMP
Background According to Article 28 (1) of the WFD,
“Member States shall ensure that their competent authorities establish, in
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accordance with Articles 1, 4, 13 and 16, one or more waste management plans.
Those plans shall, alone or in combination, cover the entire geographical territory of
the Member State concerned”.
Further, according to Article 28 (3) of the WFD,
“The waste management plans shall contain, as appropriate and taking into account
the geographical level and coverage of the planning area, at least the following:
(b) existing waste collection schemes and major disposal and recovery installations,
including any special arrangements for waste oils, hazardous waste or waste
streams addressed by specific Community legislation”.
Hazardous waste is produced in households (e.g. paints, batteries and accumulators,
pharmaceuticals); and in industrial processes. For most of EU countries industry
counts for a large amount of hazardous waste. To get an overview of the hazardous
waste generated in a Member State, the WMP should include at least some
information about most significant industrial sectors generating hazardous waste.
Furthermore, the "old" Hazardous Waste Directive (91/689/EEC) included in its
Article 6 an explicit duty for the MS to establish a WMP on Hazardous waste. The
correlation table of Annex V to WFD states that this Article 6 is now Article 28 WFD.
Therefore, it is assessed whether one or more legally adopted waste management
plan(s) covering the entire geographical territory exist and if these plan(s)
include(s) at least a list of major industry sectors and information on hazardous
waste amounts generated by those sectors.
Rationale Does a valid and adopted WMP exist?
Does the WMP include an overview on industrial hazardous waste generation?
Note: All waste management plans which have not yet been adopted, but for which
finished drafts are available and the schedule for adoption is known, have been
considered (and have been marked with * in the scoring table).
Source - Waste management plan(s) of Member States (see Annex IV)
- For DE and UK, all regional plans have been assessed (see Annex IV))
- For IT, a list of all regional plans has been collected based on information from
the Italian implementation report [IT WFD 2013] and regional websites (see
Annex IV)
- For FR, the overview on regional WMPs was used:
http://carto.sinoe.org/carto/plans/flash/
- For both IT and FR, a request was made to the MOE to provide an updated list
of WMPs, however this list could not obtained
Results
16 MS have valid and adopted WMP which include also an overview of industrial hazardous waste.
12 MS have WMP either not in force or without including an overview of industrial HW generation.
Score of 2 for MS where adopted WMP includes an overview of HW generation (15 MS):
AT, DK, EE, HR, LT, LU, LV, MT, PL, PT, SE, SK, have valid and adopted WMP which include an
overview of HW generation.
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
− GR has WMP drafts available which include an overview of industrial HW generation.
− IE has draft WMPs available for three newly established waste regions; those drafts are not
adopted yet, however in addition an officially adopted HW WMP for covering the entire
national territory exists which includes information on generation of industrial HW.
− UK has seven regional WMPs; all have been adopted and include HW generation stemming
from industry (see Table 10-4).
Score of 0 for MS where WMP is either not adopted or it does not include an overview on
industrial HW generation (13 MS):
− The WMPs of BG, CZ, ES, FI, HU, NL do not include information on hazardous industrial waste
generation, or only in a very general way (e.g. including no specifications on amounts).
− None of the WMP established by BE regions include an overview on industrial HW
generation.
− CY adopted a new WMP in 2014; the WMP does not contain any information on HW.
− The Majority of DE Federal States have adopted WMPs which include information on
hazardous industrial waste generation; this is also valid for the draft WMPs of Baden-
Württemberg. No information or very aggregated data (e.g. only amount of industrial HW as
such, not specifying information on streams) on industrial HW are included in the WMPs of
Mecklenburg-Vorpommern, Saxony and Bavaria (see Table 10-3)
− FR has 101 regional WMPs. A detailed overview of all WMPs, their current as well as revision
status is available on the French online platform for waste management:
http://carto.sinoe.org/carto/plans/flash/.According to this information, at least some of the
regional plans seem to be outdated.
− For the 21 IT regional WMPs at least five seem to be outdated; no drafts available (see
Table 10-5).
− The WMP for SI only includes municipal waste; a draft WMP for other waste streams and
also HW is announced for the end of 2015.
− RO has no WMP adopted; tendering procedure for a new draft has started in 2015.
Criterion 1.3: Inclusion of HW and waste prevention targets in WPP
Background Waste prevention is the highest priority in the waste hierarchy and according to
Article 29(1) of the WFD,
“Member States shall establish, in accordance with Articles 1 and 4, waste prevention
programmes not later than 12 December 2013”.
The waste prevention programme shall describe prevention measures.
Additionally Article 29(3) of the WFD states,
“Member States shall determine appropriate specific qualitative or quantitative
benchmarks for waste prevention measures adopted in order to monitor and assess
the progress of the measures and may determine specific qualitative or quantitative
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
targets and indicators (…).”
Therefore, it is assessed whether such programmes exist (as waste prevention
programme, part of waste management plan or other environmental programmes),
and if these programmes include targets on the prevention of hazardous waste.
Rationale Does a valid and adopted waste prevention programme exist?
Does it include information on hazardous waste?
Source - Waste prevention programmes (WPP) of MS (see Annex V)
- WMP of MS (covering waste prevention) (see Annex IV)
- EEA summary on waste prevention programmes:
http://scp.eionet.europa.eu/facts/WPP/
Results
About two thirds of the MS have already established a WPP as a separate programme or integrated it
in their WMP. Most of the WPP do not include quantitative waste prevention targets on HW. Only
three MS have WPP that define qualitative targets on HW. Other MS (6) do not have WPPs
elaborated or adopted. (Table 10-2)
Score of 2 for MS where WPP already exist and includes quantitative waste prevention targets on
HW (3 MS):
− IT include in the WPP a 10 % reduction in the ratio: generated special HW/GDP
− LV includes in its WPP the following quantitative targets:
not more than 50,000 tonnes of total HW generated by 2020
75 % of HW recycled by 2020
not more than 25 % of HW landfilled by 2020
− SE states the following in the WPP:
the content of hazardous substances in materials and products shall be reduced
the knowledge on use and content of hazardous substances in textiles has increased
in the textile sector compared to 2014
by 2020, pre-processors and recyclers of WEEE have access to useful information on
the composition of products and the content of hazardous substances compared to
2014
Score of 1 for MS where WPP (or equivalent) already exist but does not include quantitative waste
prevention targets on HW (20 MS):
− DE, DK, ES, FR, IE, LT, PT and SK have stand-alone WPP. These WPP do not include
quantitative waste prevention targets on HW.
− AT, BG, CZ, EE, FI, HR, HU, LU, MT, NL and PL have included their WPP as an own chapter in
the WMP. These plans do not include quantitative targets on HW.
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
− All UK regions have either drawn up own WPPs or have included the information in the
WMP. None of these plans include quantitative HW prevention targets.
Score of 0 for MS where no WPP (or equivalent) exist (5 MS):
− BE: The Belgian regions of Brussels and Flanders have a WPP established which includes
qualitative targets. However, the Walloon region does not have a WPP available. Thus, since
WPPs are only available for the some parts of the geographical territory of Belgium, BE is
considered not to have a WPP.
− The WPPs of CY, GR, SI and RO are not available or not adopted yet.
3.2.2 State of compliance with the legal requirements of waste legislation
Criterion 2.1: Support of hazardous waste classification
Background According to Article 3(2) of the WFD hazardous waste is defined as:
“waste which displays one or more of the hazardous properties listed in Annex III”.
The assessment whether a waste has to be considered hazardous or non-hazardous
is based on Annex III of the WFD (as mentioned in the definition above) precisely
defining properties of waste which render it hazardous (hazardous properties HP1
to HP15), e.g. “explosive” (HP1), “harmful” (HP5), or “carcinogenic” (HP7). Decision
2000/532/EC on the List of Waste (LoW) fully defines different types of waste by six-
digit entries. The LoW features over 800 entries, each characterised by 6-digit
entries. Many of these entries are marked as hazardous with an asterisk (*), with
the consequence that a legal assumption is made that these waste are considered
hazardous wastes in the sense of Article 3(2) WFD13.
The responsibility for correct classification of waste is in the first place the task of
waste producer / waste holder. Due to the complexity of waste classification, waste
operators often have difficulties to assess whether a waste has to be considered
hazardous or non-hazardous. The classification is subject to supervision of the
competent authorities (Article 17 and 34(1) WFD) and support should be provided
to producers and holders of waste in order to ensure correct classification.
Supportive measures could be guidance, help-desks or procedures where Ministries
provide support/opinions on request of waste producer/holder (e.g. post-text
classification).
Therefore, it is assessed if measures in order support correct waste classification
are provided by the competent authorities.
13 The legislation on waste classification was been recently reviewed with the main purpose to align it to the new chemicals legislation. Commission Decision (EU) No 2014/955/EU of 18 December 2014 amending Decision 2000/532/EC on the list of waste pursuant to Directive 2008/98/EC of the European Parliament and of the Council Text with EEA relevance (OJ L 370, 30.12.2014, p. 44–86 ) and Commission Regulation (EU) No 1357/2014 of 18 December 2014 replacing Annex III to Directive 2008/98/EC of the European Parliament and of the Council on waste and repealing certain Directives (OJ L 365, 19.12.2014, p. 89–96) are applicable as of 15 June 2015.
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
Rationale Are measures implemented to ensure that HW is correctly classified (e.g.
specification on national level, guidelines, internet portal, support/control from
Competent Authorities).
Source - National implementation report on WFD, mainly Qu. 3, 11(2)
- National waste legislation
Results
All Member States include in their national legislation at least basic information on hazardous waste
classification or make the link to current EU waste and chemicals legislation in order to ensure that
classification is in line with EU requirements (all at least score 1). Further, 12 MS have been rated
with score 2 for having provided various supporting tools in order to support correct waste
classification.
Score of 2 for MS including a detailed description of classification procedures within legislation and
providing supportive measures (12 MS):
AT, BG, CZ, DE, FI, HR, IE, NL, PL, PT, SE and UK provide detailed description and supportive
measures (“screening information” including detailed information) like supportive guidance
documents for hazardous waste classification.
− AT supports HW classification with various tools including an explanation of the List of Waste
and an interactive Waste Catalogue that provides exact code and examples of most common
waste streams including HW. Correct classification is also supported during permitting /
registration procedures.
− BG provides support for HW classification if a waste holder has issues defining waste as
hazardous. Sampling reports together with waste samples can be sent to the competent
authority for post-test classification.
− In CZ correct allocation of waste is addressed within the framework of regular training for
employees of municipalities. These employees help waste producers with problems related
to the allocation of waste on site.
− DE supports HW classification through a guidance document (Vollzugshilfe) and additional
information to be found at an online platform for waste classification.
− The Finnish Environment Institute and Statistics Finland have published guidance documents
and give direct guidance to operators on the correct handling and treatment of HW.
− NL has published a guideline on the European List of Waste (Europese afvalstoffenlijst
(EURAL)) that gives additional guidance for waste classification.
− The Polish EPA provides supporting material on the classification of hazardous waste
including a waste catalogue containing information on correct waste classification.
− In PT the National Waste Authority (ANR) provides the general public with a service, clarifying
uncertainties concerning the classification of waste according to the European LoW by
telephone and in writing. In addition the bodies performing audits or inspections deal with
issues related to the correct classification of waste.
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− In SE the EPA has also developed further guidance on correct classification of HW. The
guidance is intended for activities that have an obligation to classify their waste but also for
local authorities that determine if a specific classification is correct or not.
− The UK Environment Agency provides additional supportive materials for the classification of
hazardous waste including a guidance document “Hazardous waste: Interpretation of the
definition and classification of hazardous waste”
Score of 1 for MS including basic information on HW classification within legislation (16 MS)
− For BE, CY, DK, EE, ES, FR, GR, HU, IT, LT, LU, LV, MT, RO, SI and SK supportive measures as
described above could not be identified. Those Member States include general information
on hazardous waste classification according to the List of Waste in the relevant legislation.
For BE it has to be noted that the region of Flanders has prepared a guidance on the
reviewed waste classification legislation.
No MS was awarded a score of 0 (0 MS).
Criterion 2.2: Procedures of hazardous waste labelling
Background According to Article 19 of the WFD
1. Member States shall take the necessary measures to ensure that, in the course of
collection, transport and temporary storage, hazardous waste is packaged and
labelled in accordance with the international and Community standards in force.
2. Whenever hazardous waste is transferred within a Member State, it shall be
accompanied by an identification document, which may be in electronic format,
containing the appropriate data specified in Annex IB to Regulation (EC) No
1013/2006 hazardous waste is defined as:
“waste which displays one or more of the hazardous properties listed in Annex III”.
Labelling of hazardous waste is done according to European and international
standards in force. Additionally national standards might exists, e.g. in case of
transport of HW. It is seen as crucial that labelling requirements are regulated at
national level in order to ensure that same system is applied in one country.
Therefore, it is assessed on what level labelling requirements are described.
Rationale On which level of regulation are provisions for HW labelling stated/described
Source - National implementation report on WFD, Qu. 11(2)
- National waste legislation
Results
All MS include specifications on labelling in their waste laws as foreseen by the WFD. All Ms regulate
labelling on national level, except of Belgium. Therefore 27 MS received a score of 2 and only
Belgium received a score of 1 because of the three regional laws in place. However it has to be noted
that the three regional laws of Belgium are of same quality as the national one with no major
differences in labelling systems. This result is contrary to the information received from some
stakeholders at earlier stages of the project, that there might be regional differences in labelling
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procedures causing to uncertainties amongst authorities and waste actors involved. At least these
differences are not based on legal grounds.
Score of 2 for MS with procedures of hazardous waste labelling at national level (27 MS):
Hazardous waste labelling is regulated on national level in every Member State except from Belgium.
Score of 1 for MS which have regional regulations on hazardous waste labelling in place (1 MS):
The labelling of hazardous waste in Belgium is regulated at regional level and included in laws of
Wallonia, Flanders and in the region of Brussels. In order to score Belgium in a consistent manner,
each of the laws was assessed and a comparison of all three regions was made. The result is that all
three regions had a regional procedure of hazardous waste labelling in place.
None of the MS was awarded a score of 0.
Criterion 2.3: Existence of HW record keeping system
Background According to Article 35(1) of the WFD,
“1. The establishments or undertakings referred to in Article 23(1), the producers of
hazardous waste and the establishments and undertakings which collect or
transport hazardous waste on a professional basis, or act as dealers and brokers of
hazardous waste, shall keep a chronological record of the quantity, nature and
origin of the waste, and, where relevant, the destination, frequency of collection,
mode of transport and treatment method foreseen in respect of the waste, and shall
make that information available, on request, to the competent authorities.”
As Article 35(1) WFD states, the information has to be made available on request.
The competent authorities are not obliged to collect, process and store the data in a
waste register. However such registers are one important measure to ensure
traceability of waste from its generation to its final treatment. Waste registers, if
properly run, can both support permitting procedures and inspections planning.
Further, data from the registry can be retrieved in order to report HW generation
and treatment data, e.g. as to Eurostat – such data being of much better quality
than e.g. from surveys or estimations. A register managed at national level including
the data of the entire territory of a Member States, being regularly processed and
controlled by the authorities, can be seen as one of the most effective measures to
ensure enforcement of EU legislation on hazardous waste.
Therefore, it will be assessed whether a registry for tracing the records of HW is
managed and on what level.
Rationale Does the Member State Authority manage a registry for tracing the records of HW?
Source - National implementation report on WFD, mainly Qu. 11 (2)
- Quality reports on waste statistics 2012
In case no information available in report/no report available:
- National waste legislation
- National ordinance on waste recovery / disposal records
- Further national regulation on implementation
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Results
Results show that a waste register is practice in most of the MS; 21 MS managing such a register on
national level. However there are 4 MS where such a system is covering not the entire territory. In 3
MS, no registry is in place.
Score of 2 for MS with centralised hazardous waste registry (national level) (21 MS):
21 MS were scored 2; there is a national hazardous waste record keeping system in place these are
the MS: AT, BG, CZ, DE, DK, EE, FR, GR, HR, HU, IE, IT, LT, LU, LV, MT, NL, PL, PT, SI and UK.
In case of NL it was assumed that there is a national record keeping system in place since there is the
central online national tracking system (Landelijk Meldpunt Afvalstoffen) for the reporting of
(hazardous) wastes by companies and waste collectors. However, this scoring could not be verified
with competent authority or stakeholders.
Score of 1 for MS with de-centralised (regional level) hazardous waste registry (4 MS):
Four countries were identified that use regional registries for hazardous waste record keeping BE,
ES, FI and SK.
In SK, the Environmental Agency is in charge of waste data collection from waste treatment facilities.
However data on waste produced by industrial activities are collected through the reports on waste
production processed in the Regional Information System of Waste (RISO). Waste producers are
obliged to report data from the records to competent district authorities. Based on this information
it was concluded that a regional waste record keeping system is established in SK. Information could
not be verified / confirmed with competent authorities or stakeholders.
Score of 0 for MS with no hazardous waste registry in place (3 MS):
CY, RO and SE were awarded a score of 0:
− For CY no information on a hazardous waste record keeping system on national or regional
level could be identified. No additional information from the competent authority was
available. Therefore CY was scored 0.
− Information has been identified that RO has planned to establish a national HW registry but
this could not be verified. The MoE did not provide additional information on request yet,
therefore RO was scored 0.
− Through stakeholder consultation [SE SRI 2015] it was confirmed that SE has no registry for
hazardous waste in place. According to the national Ordinance of waste, records have only to
be made available to the competent authority on request. For this reason SE was scored 0.
Criterion 2.4: Requirements for record keeping/ tracking system of HW
Background Article 35(1) of the WFD lays down provisions for record keeping duties related to
transportation of hazardous waste:
“ The establishments or undertakings referred to in Article 23(1), the producers of
hazardous waste and the establishments and undertakings which collect or
transport hazardous waste on a professional basis, or act as dealers and brokers of
hazardous waste, shall keep a chronological record of the quantity, nature and
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origin of the waste, and, where relevant, the destination, frequency of collection,
mode of transport and treatment method foreseen in respect of the waste, and shall
make that information available, on request, to the competent authorities.”
Thereby record keeping duties need to be further distinguished according to
competences granted to supervising authorities. In particular, it is assessed whether
each generation, transfer and treatment of HW has to be recorded and reported
(e.g. holding of consignment note and report to a register) and authorities get
immediate access, or records are required but have to be held only for potential
supervisory purposes. The basic understanding is that a consistent access for
authorities ensures a more efficient and traceable overview on HW management
compared to a periodical control conducted.
Consequently, it is assessed how strict the record keeping duties on HW
management are kept in the respective MS and if they are linked to possible
control procedures.
Rationale Are measures taken to ensure the traceability of HW from generation to final
treatment (i.e. waste record system, consignment notes, and electronic register)?
Source - National implementation report on WFD, mainly Qu. 11 (2)
- Quality reports on waste statistics 2012
- National waste legislation, ordinance on waste recovery / disposal records
Results
16 Member States operate reporting systems where all steps from generation to final treatment of
HW have to be recorded and reported to the competent authority. In 11 Member States, data on
waste generation, transfer or treatment operations are not reported immediately but have to be
kept and presented to authorities on request, e.g. in the course of on-site inspections. Some of those
Member States also require the operator to prepare yearly reports on HW waste data and
management. For one MS the record keeping system remained unclear.
A score of 2 was awarded for MS having a record keeping system in place which covers all steps
from collection to final treatment including control procedures/obligation to transmit data to
competent authority (16 MS):
AT, BE, BG, CY, CZ, DE, DK, EE, FR, HU, IT, LV, PL, PT, SI and SK have national record keeping systems
in place covering all steps from collection of HW to final treatment. The information has to be
reported by waste producers and waste holders to the competent authority immediately or within a
given time-frame. Also in most MS this data has to be kept available for several years. Main
parameters of the records are type, quality, quantity and origin of HW.
A score of 1 was awarded for MS which have the requirement to keep/store data but no reporting
obligation to competent authority (11 MS):
A score of 1 has been awarded to ES, FI, GR, HR, IE, LT, LU, MT, NL, SE and UK because these MS
have hazardous waste record keeping obligation, but data do not have to be reported to the
competent authority. In most cases data have to be kept available for a certain period of time.
A score of 0 was awarded for MS apparently having a record keeping system not covering all steps
or where no answer was available (1 MS):
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RO was awarded a score of 0 because a detailed description on hazardous waste record keeping
systems could not be identified. The competent authority has been approached for clarification, but
no information was made available yet.
Criterion 2.5: Registration/ permit procedure for HW treatment facilities
Background According to Article 23(1) of the WFD,
“Member States shall require any establishment or undertaking intending to carry
out waste treatment to obtain a permit from the competent authority.”
The permitting procedures enable the competent authority to influence the design
and operation conditions on several occasions during permitting procedure. Article
24 of the WFD generally enables MS to grant exemptions for establishments and
undertakings from permit requirements for recovery operations, also including in
hazardous waste recovery operations. The general understanding is that
exemptions for hazardous waste treatment increase the risk of negative impacts on
the environment and human health. Hence, it is assessed whether MS require
permits for HW treatment operations, including recovery operations.
Rationale Are for all establishments / undertakings which carry out HW treatment operations
permits required (i.e. exemptions from permits are not made for HW recovery
facilities).
Source - National implementation report on WFD, mainly Qu. 14 (1)
- National waste legislation, regulation on implementation
- National ordinance on waste recovery /disposal records
Results
In the vast majority of EU Member States establishments / undertakings which carry out HW
treatment recovery operations are not exempted from permitting requirements. However in three
MS, national legislation foresees the possibility to exempt such establishments / undertakings
carrying out HW recovery operations from permit procedure, either allowing simplified permits, or
only requesting registration.
Awarding of a score of 2 for MS which require permits for all establishments/undertakings carrying
out hazardous waste treatment operations (25 MS):
In AT, BE, BG, CY, CZ, DE, EE, ES, FI, FR, GR, HR, HU, IE, LT, LU, LV, MT, NL, PL, PT, RO, SE, SI and SK,
all treatment operations for hazardous waste require an environmental permit also including
recovery facilities
Awarding of a score of 0 for MS which have exemptions for establishments/undertakings carrying
out hazardous waste treatment operations in place (3 MS):
In DK, IT and UK, national legislation foresees the possibility to grant exemptions to
establishments/undertakings which carry out hazardous waste treatment.
In UK for England and Wales there are at least permit exemptions for recovery operations of
HW of WEEE and heating oils listed in schedule 3 of [UK Permit 2010].
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In IT there are exemptions from permits for hazardous waste operations. The possibility of
granting exemptions is specified in Article 214 of Decree No 152/2006 of [IT Act ENV 2010];
this includes simplified procedures for the recovery of certain specific waste streams. Article
214 includes links to Legislative Decree No. 133 May 11, 2005 on incineration: activities of
incineration and energy recovery have access to simplified procedures.
In DK exemptions are possible for the recovery of all kind of waste (including HW). A number
of smaller waste treatment plant recovery facilities are not subject to approval under the
Environmental Protection Act, i.e. small recycling centres, small scrap yards and sludge
storage plants, and small biogas or composting plants.
Criterion 2.6: Legal transposition of ban on the mixing of HW
Background According to Article 18 (1) of the WFD;
“Member States shall take the necessary measures to ensure that hazardous waste
is not mixed, either with other categories of hazardous waste or with other waste,
substances or materials. Mixing shall include the dilution of hazardous substances.
A mixing ban establishes the basis for separate treatment of hazardous waste.
Mixing of hazardous waste can hamper recovery or at least may limit the results of
recovery and consequently increase potential environmental impacts. A mixing ban
imposed at national level is more effective than on regional level.
Therefore, it is assessed if the mixing ban is required by legislation.
Rationale Is the mixing ban required in legislation?
Source - National implementation report on WFD, mainly Qu.11 (3)
In case no information available in report/no report available:
- National waste legislation, regulation on implementation
Results
All EU MS have implemented the mixing ban of hazardous waste in national legislation. Nearly all
laws make clear that hazardous waste must not be mixed with waste, substances / materials with
other properties; the prohibition of mixing also includes the dilution of hazardous waste.
Awarding of a score of 2 for MS that have implemented the mixing ban for HW at national level (27
MS):
27 EU MS except BE have implemented the ban of hazardous waste mixing in national legislation.
Score of 1 for MS that legally implemented mixing ban for HW on regional level (1 MS):
In BE the mixing ban of hazardous waste is implemented in regional legislation for all three regions
(Brussels, Flanders and Wallonia).
Criterion 2.7: Derogation for mixing ban
Background In addition to the general mixing ban Article 18 (2) of the WFD states that,
“By way of derogation from paragraph 1, Member States may allow mixing provided
that:
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(a) the mixing operation is carried out by an establishment or undertaking which has
obtained a permit in accordance with Article 23;
(b) the provisions of Article 13 are complied with and the adverse impact of the
waste management on human health and the environment is not increased; and
(c) the mixing operation conforms to best available techniques.
(3) Subject to technical and economic feasibility criteria, where hazardous waste has
been mixed in a manner contrary to paragraph 1, separation shall be carried out
where possible and necessary in order to comply with Article 13.”
Any derogation from the mixing ban implies risks for comprehensive and effective
reuse, recovery and/or increases potential impacts on health and environment.
Nevertheless, criteria for derogations need to be defined due to technical reasons.
For instance, usage of waste as secondary raw material may require mixing to
ensure proper reactions within the recovery processes or to condition the waste
fraction.
A general ban for derogations may therefore lead to undesirable effects and
hamper efficient reuse/ recovery. Further, if criteria are not defined, decision is left
to authorities at lower administrative levels; this may lead to inconsistent decisions
within issued permits. Such criteria could refer e.g. to Best Available Technologies
(BAT), each HW stream which shall be mixed are permitted for the facility, no
additional harm to human health and the environment, etc.
Therefore it is assessed, whether criteria for allowing derogation from the mixing
ban are set in legislation.
Rationale Does national (regional) legislation define appropriate criteria in order to make
derogations from the mixing ban (allowing for mixing of hazardous waste).
Source - National implementation report on WFD, Qu.11 (3)
- Waste management plans (WMP) of MS (only WMPs officially adopted and in
force)
- Other sources to be defined
Results
The results of criteria 2.8 “Derogation for mixing ban” are strongly linked to the findings of criteria
2.7 “Legal transposition of ban on the mixing of HW”. The vast majority of the MS which have
implemented the HW mixing ban in national legislation have also defined criteria for the derogation.
However five countries do not include such criteria in national legislation.
Awarding of score of 2 for MS which have set appropriate criteria for the derogation from the
mixing ban or do not allow any derogation (23 MS):
The MS AT, BE, BG, CY, CZ, DE, DK, EE, ES, FI, FR, HR, HU, IT, LT, LU, LV, MT, PT, RO, SE, SI and UK all
have defined appropriate criteria for the derogation of the mixing ban of hazardous waste. Most of
these countries do not allow mixing of hazardous waste at all or have at least included the criteria for
derogation as set in the WFD 2008/98/EC Art. 18(2).
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Some countries define criteria for mixing that go beyond the ones defined in the WFD, e.g. also
including the requirement that all waste streams to be mixed have to be permitted as single streams
in the receiving facility.
Awarding of score of 0 for MS that have no specification/criteria on derogation set in law (5 MS):
Member States which were awarded a score of 0 have no information or criteria on derogation from
the mixing ban included in legislation but allow the mixing of hazardous waste in exceptional cases.
These countries are GR, IE, NL, PL and SK.
GR allows exceptions from the mixing ban for HW recovery included in permits, but no
criteria defined in law.
In the case of IE the national legislation states that derogations from the mixing ban can be
granted by the Irish EPA but the criteria for such derogations are not specified.
NL allow the mixing of HW under an environmental permit, however criteria for allowance
are not defined in the legislation.
In PL the mixing is allowed in the waste law under Art.21 [PL Act on waste 2012], but only the
following broad criterion is set: “if mixing hazardous waste helps to improve the security of
processing mixed waste generated”.
Also in SK the mixing of hazardous waste may be carried out if it is needed for increasing the
safety during waste recovery or disposal and if such is compliant with the granted permit.
But no criteria for the mixing are defined in legislation.
3.2.3 Collection and treatment of hazardous waste
Criterion 3.1: Requirements for collection and storage of HW
Background Article 17 and 19 of the WFD on controls and labelling also includes that MS shall
take necessary measures to ensure that the
“collection, transport and temporary storage, hazardous waste is packaged and
labelled in accordance with the international and Community standards in force”
and that
“production, collection and transportation of hazardous waste, as well as its storage
and treatment, are carried out in conditions providing protection for the
environment and human health (…).”
Thus, at MS level, it should be clearly defined what the requirements are in order to
ensure separate collection and safe storage on all steps of HW management. It is
necessary to include the requirement into national legislation but also to specify the
requirements in accompanying documents, explaining in detail the collection and
storage requirements to be applied for HW.
Rationale Are measures introduced to specify the separate collection and storage of HW?
Source - National implementation report on WFD, mainly Qu. 11 (1)
In case no information available in report/no report available:
- National waste legislation, regulation on implementation
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Results
All Member States include at least the basic requirements as mentioned in the WFD. All MS include
at least one or several of the following conditions in the national legislation that:
− HW is to be collected and kept separately and transferred to a waste collector/treatment
facility permitted/registered for this activity;
− the safe storage of waste needs to be ensured / HW is to be stored in a way that protects the
environment and the human health;
− waste must only be transferred to a licensed collector/to a licensed treatment facility.
Some MS additionally impose further requirements for collection and storage, e.g. separate
collection of Construction & Demolition Waste is specified. However within this screening report, a
thorough investigation as to which MS includes/provides such specific measures has not been
conducted. Therefore the scoring results for this criterion have not been included in the scoring
table.
It can be confirmed, however that all Member States at least included the general requirements on
collection and storage as specified in the WFD.
Criterion 3.2: Performance of separate collection of WEEE
Background Electrical and electronic equipment (EEE) sector is developing very fast and its
products are omnipresent in the daily life. The ever-increasing quantity of waste
electrical and electronic equipment (WEEE) has become a serious social problem
and threat to the environment. EEE often includes hazardous substances, which
pose high risks to the environment and human health. Proper management of WEEE
is thus an important issue. In this context, separate collection is a precondition for
ensuring specific treatment, including recycling, of WEEE. Therefore Directive
2012/19/EU (The WEEE Directive) includes ambitious targets for the collection of
WEEE.
According to Article 7 of the WEEE Directive: From 2016, the minimum collection
rate shall be 45 % calculated on the basis of the total weight of WEEE collected in
accordance with Articles 5 and 6 in a given year in the Member State concerned,
expressed as a percentage of the average weight of EEE placed on the market in the
three preceding years in that Member State (…). Therefore, the collection rate of
WEEE of the Member States is assessed.
Rationale What is the rate (%) for separate collection of WEEE in the MS (collection rates
calculated as share of WEEE collected compared to EEE put on the market)?
28 MS will be ordered descending (highest % first)
Source - Eurostat statistics on Waste Electrical and Electronic Equipment (WEEE)
(env_waselee), latest data from 2012 (Cyprus 2010)
Results
Based on the assessment of the Eurostat data, a comparison between the performances of separate
collection of WEEE within the 28 MS was made. The scoring was solely based on the reported data
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for the year 2012; the only exception is CY where only data for 2010 were available. The collection
performance of WEEE was calculated as share of WEEE collected compared to EEE placed on the
market. The average separate collection rate of WEEE within the 28 EU MS was 39 %. According to
the data, 9 MS are already reaching the collection target for 2016.
MS that were awarded a score of 2 for having the highest WEEE separate collection rate (9 MS):
AT, BG, DK, HU, IE, IT, LT, SE and SK had a collection rate between 47 and 77% in 2012; these MS are
already fulfilling the 2016 target.
MS that were scored 1 for having a medium rate of separate WEEE collection (9 MS):
BE, DE, EE, FI, HR, LU, NL, PL and UK in 2012 had a collection rate between 35 and 45 %; all MS are
fulfilling or are close to fulfilling the target for 2016.
MS scored with 0 due to the lowest WEEE separate collection rate (10 MS):
CY, CZ, ES, FR, GR, LV, MT, PT, RO and SI had a collection rate between 14 and 34 % in 2012 (CY
2010).
Criterion 3.3: Performance of separate collection of batteries and accumulators
Background Batteries and accumulators contain hazardous substances which may pose negative
impacts on the environment when becoming waste. Directive 2006/66/EC on
batteries and accumulators and waste batteries and accumulators ("The Batteries
Directive") therefore requires that in order to protect the environment, waste
batteries and accumulators should be collected separately. The Directive also sets
collection targets.
According to Article 10 (2) of the Directive on batteries and accumulators:
“Member States shall achieve the following minimum collection rates: (a) 25 % by 26
September 2012; (b) 45 % by 26 September 2016”, calculated on the basis of
average annual sales in preceding years. Therefore, the collection rate of batteries
and accumulators of the MS is assessed.
Rationale What is the rate (%) for separate collection of batteries and accumulators in the MS
(share of collected batteries/ accumulators compared to what was put on the
market)?
28 MS will be ordered descending (highest % first)
Source - Eurostat statistics on Sales and collection of portable batteries and
accumulators (env_waspb), latest data from 2013
- Other information sources, if not available at Eurostat (WMPs, Implementation
report on batteries, [EC Bio 2014]
Results
Based on the assessment of the most recent Eurostat data (2012), a comparison between the
performance of the 28 MS in terms of separate collection of batteries and accumulators was made.
For CY, ES, IT, NL, RO and UK information has been retrieved from Implementation reports on the
Batteries Directive (2012). For DK the data was extracted from the WMP (data of 2011), for GR from
[EC BIO 2014].
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The collection performance of batteries/accumulators was calculated as share of collected
batteries/accumulators compared to batteries/accumulators placed on the market. The overall
average separate collection rate of batteries/accumulators in the 28 EU MS was 40 %.
Not all data for all 28 EU MS was available. As concerns data on collected batteries/accumulators and
the amount of put on the market, 2013 data was available on Eurostat for the following countries:
AT, BE, BG, CZ, DE, EE, FI, FR, HU, IE, LT, LU, LV, MT, PL, PT, SE, SI and SK (19 MS); the average
collection rate of 40% was calculated according to this data.
MS which were awarded a score of 2 for having the highest batteries/accumulators separate
collection rate (9 MS):
AT, BE, DE, DK, LU, MT, NL, SE and SK in 2012 have a collection rate between 42 and 64 %; over-
fulfilling, fulfilling ore close to fulfilling the target of 2016.
MS which were awarded a score of 1 for having a medium rate of separate batteries/ accumulators
collection (9 MS):
BG, EE, ES, FI, FR, HU, IE, LT and SI have a collection rate between 31 and 41%.
MS scored with 0 due to the lowest batteries/ accumulators separate collection rate (10 MS):
CY, CZ, GR, HR, IT, LV, PL, PT, RO and UK have a rate between 10 and 30 %.
Criterion 3.4: Reliance on disposal for HW treated in the Member State
Background According to Article 1 and 4 of the WFD,
“This Directive lays down measures to protect the environment and human health by
preventing or reducing the adverse impacts of the generation and management of
waste and by reducing overall impacts of resource use and improving the efficiency
of such use.”
“The following waste hierarchy shall apply as a priority order in waste prevention
and management legislation and policy:
(a) prevention;
(b) preparing for re-use;
(c) recycling;
(d) other recovery, e.g. energy recovery; and
(e) disposal.
...Member States shall take into account the general environmental protection
principles of precaution and sustainability, technical feasibility and economic
viability, protection of resources as well as the overall environmental, human health,
economic and social impacts, in accordance with Articles 1 and 13.”
and the justification of the WFD
“Hazardous waste should be regulated under strict specifications in order to prevent
or limit, as far as possible, the potential negative effects on the environment and on
human health due to inappropriate management.”
Many substances present in HW need a final disposal in order to persistently
remove them from the material cycle. However depositing HW onto or into Land
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(D1, D5, D12) should be the least favourite treatment option, since in terms of the
immobilisation of contaminants, these operations do not represent the best
available practice. In accordance with the WFD, MS should not only rely on this last
treatment option of the waste hierarchy.
Therefore, the rate of depositing HW into or onto land is assessed.
Rationale What is the rate for depositing HW onto or into land (D1, D5, D12) treated in the
Member State?
Source - Eurostat statistics on HW treatment latest data available, 2012
For plausibility checks:
- National statistics
- Quality Reports on Waste Statistics for all EU-28 Member States as of 2012 or
2010 (DK, IT, LT, LU)
- Clarification requests to responsible authorities for the submission of statistical
data to Eurostat for all MS
Eurostat data is available only for the amount of hazardous waste treated within a Member State,
referring to the amount generated in the country minus exports of waste to other countries plus
imports of waste to the country.
Eurostat data from 2012 were used for the assessment including the following statistics:
− Type of waste: TOTAL_HH
− Amount of waste treated: TOTAL
− Treatment option for total the amount: TRT
− Type of waste disposed: DSP_L
The disposal rate is calculated based on the total amount of hazardous waste disposed of (excluding
backfilling) compared to the total amount of hazardous waste treated within the Member State
(including imports, excluding exports). The statistical data for treatment operations submitted to
Eurostat are excluding pre-treatment facilities (Annex II of the European Waste Statistics Regulation).
Results
The rate of hazardous waste disposed of (excluding backfilling) within the MS (generation in MS
minus export plus import) is between 0 % and 100 % based on the figures provided by Eurostat for
the year 2012. The average disposal rate for all hazardous waste treated in the EU-28 amounted to
approximately 48 %, taking into consideration the limitations of the data provided as mentioned
below.
Awarding of score of 2 for MS with lowest disposal rates (< 20%) (9 MS):
AT, CZ, GR, HR, LV, MT, PL, PT, RO and SI are the MS with the lowest disposal rates (below 20%) with
regard to the amount treated within the country.
Awarding of score of 1 for MS with medium disposal rates (between 20 and 40%) (11 MS):
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CY, DE, ES, FR, IE, IT, LT, LU, NL and UK have – compared to other MS – medium rates of disposed
hazardous waste (between 23% and 39%). In LU and MT, all waste has been shipped.
Score of 0 for MS with highest disposal rates (>40%) (8 MS):
BE, BG, DK, EE, FI, HU, SE and SK show high disposal rates of hazardous waste (between 41% and
100%).
Clarification on data uncertainties
There are some uncertainties about the results, mainly due to remaining data gaps when comparing
Eurostat data for generation, for treatment and for waste shipment (import and export). Potential
reasons might be:
− The Member States apply different data collection methodologies (on the waste producer
side compared to waste treatment side). The analysis has shown that for the majority of
Member States statistical data are collected at the side of waste production (waste
producer). Hence, in many cases only the first step of the treatment route is known. In the
case this first step is defined as a 'sorting facility' or an 'other pre-treatment facility' which
are not included in Annex II of the European Waste Statistics Regulation this may lead to data
gaps in reporting to Eurostat (reason “Annex II”).
− Additionally a certain amount of hazardous waste is treated in on-site facilities of the waste
producer (in particular valid for certain industrial wastes). Again, these amounts are often
not recorded and not reported to Eurostat (reason “on-site”).
− A potential amount might be stored temporarily or – what cannot be excluded – also
disposed of illegally.
Taking these limitations into account, the calculations and scoring results refer solely to HW amounts
treated in off-site facilities; this is the amount visible in the Eurostat statistics. As a consequence, the
calculations may lead to either an over- estimation or an under-estimation of the disposal share,
particularly for Member States with large waste amounts treated.
In order to try to clarify the difference, statistical authorities have been approached, in order to
confirm data or explain inconsistencies.
Answers were provided by 13 MS. In general, the assumptions of data uncertainties mentioned
above were confirmed. Selected Statistical Offices were able to provide additional data. However,
there remain some uncertainties. Therefore have run an additional sensitivity analysis (please see
below). This is further summarised in the Table 4-2 in chapter 4.1.
Sensitivity analysis
As explained above, for a number of MS a significant difference exists between the amounts of HW
generated and HW treated (generation minus exports plus imports). The data differences however
cannot be explained completely and doubts about data quality and consistency remain.
To avoid misleading total scoring for the single Member States, the project team proposed the
following procedure:
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− Regarding the statistical criteria 3.4, 3.5, 3.6, 3.7 and 3.8, for all Member States, a sensitivity
analysis was conducted for the result obtained per criterion. The outcome of the sensitivity
analysis was that the performance of the Member States slightly changed. However, the MS
performing below-average prior to the analysis, in particular the ones with lowest score,
remained below average after the sensitivity analysis.
− The overall results of the sensitivity analysis for criteria 3.4 to 3.8 are as follows:
RO, CY, GR, SI, BE, ES, IT, FR and FI remain below the average of all Member States;
accordingly the result has not changed but only the order/ranking within this group;
HU, MT, SE and NL are above the average when not counting the criteria on HW
treatment (criteria 3.4 to 3.8).
Criterion 3.5: Reliance on disposal for HW treated within/ exported to another country
Background The same background as for Criterion 3.4 applies.
In addition to that: where reliance on disposal for HW treated within the MS
(defined as HW generated in the MS minus export + import) is assessed, under this
criterion the reliance on disposal of HW including the exports to other MS will be
assessed. This shall ensure that all HW falling under the responsibility of a MS –
including their HW exported to other countries – is considered.
Rationale What is the rate for depositing HW onto or into land (D1, D5, D12) treated within
the Member States or exported to another country? 28 MS will be ordered
descending (lowest % first)
Source - Eurostat statistics on HW treatment latest data available, 2012
For plausibility checks:
- National statistics
- Quality Reports on Waste Statistics for all EU-28 Member States as of 2012 or
2010 (DK, IT, LT, LU)
- Selected Interviews (OVAM, Statistical Office Ireland)
- E-PRTR Register (considering information about waste transfers as per country -
http://prtr.ec.europa.eu/WasteTransfer.aspx)
For the assessment of criterion 3.5 the following data were used:
1. Results of the analysis for criterion 3.4 (What is the rate for depositing HW onto or into land
(D1, D5, D12) treated within the Member State)
2. Volumes of waste exported to another country: the data used was taken from the Eurostat
Waste shipment statistics of 2012. The data on waste shipments per Member State had to be
analysed based on the following aspects in order to obtain the correct amount of HW treated
− Basis for classification: Is the waste shipped classified as hazardous or non-hazardous
• Within the classification of waste shipped additional assessments had to be made for
waste amounts that had been classified as UNKNOWN. For these amounts of waste not
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classified, the data available within Eurostat under “Category Of Waste” and “Raw data -
Waste stream” were analysed and classified.
• When it was unclear whether HW amounts reported were recovered (R) or disposed (D),
it was assumed that amounts were disposed. The disposal rate was calculated based on
the total amount of hazardous waste disposed of (excluding backfilling) within the
country, plus the total amount of hazardous waste exported for disposal compared to the
total amount of hazardous waste treated within the Member State (including imports,
excluding exports) plus the total amount of hazardous waste exported. The result was
used for the identification of the 9 MS with lowest disposal rate, 9 MS with medium
disposal rate and 10 MS with highest disposal rate.
Results
Score for 2 for the MS with lowest disposal rates (8 MS):
AT, CY, CZ, GR, LV, PL, PT and RO are the nine MS with the lowest calculated disposal rate based on
available statistical data.
Score of 1 for the MS with medium disposal rates (10 MS):
DE, ES, FR, HR, IE, LT, LU, MT, NL, and SI are the 9 MS with – compared to other MS – medium rates
of hazardous waste disposal based on available statistical data. For LU and MT, all waste has been
shipped.
Score of 0 for the MS with highest disposal rates (10 MS):
BE, BG, DK, EE, FI, HU, IT, SE, SK and UK show highest disposal rates of hazardous waste based on
available statistical data.
Considerations on data uncertainties
For criterion 3.5 the same data uncertainties have been considered as for criterion 3.4. As criterion
3.5 is directly related to criterion 3.4 using the same data basis the same approach to overcome the
uncertainties have been applied (sensitivity analysis, request to experts for clarification).
Criterion 3.6: HW recovery for spent solvents
Background The same general background as the last two criteria applies.
This criterion focuses on the particular HW stream of spent solvents. In terms of
their environmental and human health risk, spent solvents are one of the important
HW streams. Due to the possibility of distillation, spent solvents are in general well
suited for recycling. The amount of spent solvents generated in the EU MS is about
3.2 million tonnes. In most MS, the amount of spent solvents is below 10% of the
generated total amount of HW; spent solvents count for approximately 3% of the
total amount of HW in the European Union.
Therefore a high rate of spent solvents recovered (excluding energy recovery) is an
indication of a well-functioning HW management infrastructure.
Therefore, the rate of recovery (excluding energy recovery) for spent solvents is
assessed.
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Rationale Which percentage of spent solvents treated in or shipped to the Member State is
recovered (excluding energy recovery)*?).
Source - Eurostat statistics on HW treatment, waste code W011; treatment option
RCV_NE
(2012, for DK, IE, IT, LT, RO 2010)
For plausibility checks:
- National Statistics
- E-PTR register (considering information about waste transfers as per country -
http://prtr.ec.europa.eu/WasteTransfer.aspx)
Eurostat data available for the reliance on hazardous waste recovery for spent solvents are available
for the amount of solvents treated in the country. Volumes treated in the country refer to national
volumes generated minus exports plus imports.
For the assessment, data for 2012 were used, except for DK, IE, IT, LT and RO. As no 2012 detailed
data were available for these Member States, 2010 figures were used.
For the calculation the following data were used:
− Type of waste: W011
− Amount of waste treated: TOTAL
− Treatment option for total the amount: TRT
− Type of waste recovered: RCV_NE
The recovery rate is calculated based on the total amount of spent solvents recovered (excluding
energy recovery) compared to the total amount of spent solvents treated in the Member State
(including imports, excluding exports).
Results
The rate of spent solvents treated or shipped to the Member State which is recovered (excluding
energy recovery) range from zero to hundred percent based on the figures provided by Eurostat. The
average recovery rate for all spent solvents treated within the EU-28 amounts to approximately 40%,
taking into consideration the above-mentioned limitations of the data provided by Eurostat.
Score of 2 for MS with highest recovery rates (9 MS):
CY, ES, GR, HR, IT, LV, PT, RO and UK are the countries with the highest recovery rates (above 75%)
with regard to the amount treated in the country.
Score of 1 for MS with medium recovery rates (5 MS):
BG, LU, MT, PL and SK are 5 countries with medium rates of recovered spent solvents (between 51%
and 68%). For LU and MT all spent solvents are exported for recovery.
Score of 0 for MS with lowest recovery rates (14 MS):
AT, BE, CZ, DE, DK, EE, FI, FR, HU, IE, LT, NL, SE and SI show low rates of spent solvents recovery
(between 0% and 48%).
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Remarks on data uncertainties
Having a closer look at the scoring results, it has to be noted that for amounts of HW exported for
treatment to another Member State, sometimes data on recovery is not available at Eurostat. It can
be assumed that these amounts of waste exported are recovered – instead of disposed, which is not
permissible - but there is no data evidence for this assumption. However, for methodological
reasons, these exported amounts, for which no treatment data evidence exists, have been
considered as recovered instead of disposed.. Therefore, it has to be taken into account, that
Member States which export a large amount of HW for treatment could benefit of this methodology
since all exported amounts are counted as recovered and not as disposed.
The same approach to overcome the uncertainties have been applied (sensitivity analysis, request to
experts for clarification) as described for criterion 3.4.
Criterion 3.7: HW recovery for acid, alkaline or saline wastes
Background The same general background as for Criterion 3.4 applies. However this criterion
focuses on the particular HW stream of acids, alkaline or saline wastes. In terms of
their environmental and human health risk, acids and alkaline wastes in particular,
but also saline wastes are some of the important HW and in general well suited for
recycling. The generated amount of acids, alkaline or saline wastes in the EU is
about 3.6 Million tonnes (4 % of the total amount of HW). In most MS the amount is
below or around 10 % of the total generated HW amount. Therefore, a high rate of
acids, alkaline or saline wastes recovered (excluding energy recovery) is an
indication for a well-functioning HW management infrastructure.
Therefore, the rate of recovery (excluding energy recovery) for acids, alkaline or
saline wastes is assessed.
Rationale Which percentage of acid, alkaline or saline wastes treated in or shipped to the
Member State is recovered (excluding energy recovery and backfilling)?
Source - Eurostat statistics on HW treatment (latest year available; waste code W012;
treatment option RCV_NE)
For plausibility checks:
- National Statistics
- Quality Reports on Waste Statistics for all EU-28 Member States as of 2012 or
2010 (DK, IT, LT, LU)
- E-PRTR register (considering information about waste transfers as per country -
http://prtr.ec.europa.eu/WasteTransfer.aspx)
Eurostat data for the reliance on hazardous waste recovery for acid, alkaline or saline wastes are
available for the amount of acid, alkaline or saline wastes treated within the country. Volumes
treated within the country refer to national volumes generated minus exports plus imports.
For the assessment 2012 data were used, except for DK, IE, IT, LT where 2010 data have been used.
For the calculation, the following Eurostat reference codes data were used :
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− Type of waste: W012 (Acid, alkaline or saline wastes)
− Amount of waste treated: TOTAL
− Treatment option for total the amount: TRT
− Type of waste recovered: RCV_NE
The recovery rate is calculated as the total amount of acid, alkaline or saline wastes recovered
(excluding energy recovery) compared to the total amount of acid, alkaline or saline wastes treated
within the Member State (including imports, excluding exports).
Results
The rate of acid, alkaline or saline wastes treated or shipped to the Member State which is recovered
(excluding energy recovery) amounted to between zero and hundred percent based on the figures
provided by Eurostat. The average recovery rate for all acid, alkaline or saline wastes treated within
the EU-28 amounts to approximately 88%, taking into consideration the above-mentioned limitations
of the Eurostat data.
Score of 2 for MS with highest recovery rates (16 MS):
AT, BG, CY, CZ, DE, EE, GR, HR, HU, IT, LT, NL, PL, PT, SI and UK are the MS with the highest recovery
rates (above 80%) with regard to the amount treated in the country.
Score of 1 for MS with medium recovery rates (9 MS):
BE, ES, FI, FR, IE, LU, MT, RO and SK are MS with medium rates of recovered acid, alkaline or saline
wastes (between 52% and 71%). For IE, LU and MT all acid, alkaline or saline wastes were exported
(with no further information which treatment applied, therefore score 1).
Awarding of score of 0 for MS with lowest recovery rates (3 MS):
DK, LV, and SE show very low rates of acid, alkaline or saline wastes recovery.
Remarks on data uncertainties
Given the low amount of acid, alkaline or saline wastes treated in certain Member States compared
to the amount generated, some uncertainties remain, as mentioned above. This may lead to
inaccurate results mainly for AT (only 6% of generated volumes treated), EE (2%), HR (19%), SI (6%).
The same approach to overcome the uncertainties has been applied (sensitivity analysis, request to
experts for clarification) as described for criterion 3.4.
Criterion 3.8: HW recovery for used oils
Background The same general background as for Criterion 3.4 applies. This criterion focuses on
the particular HW stream of used oils. The generated amount of used oils in the EU
MS is about 4.9 million tons (5 % of the total amount of HW). In most MS, the
amount of used oils is below or around 10 % of the generated total amount. In
terms of their environmental (especially water) and human health risk, used oils are
one of the important HW and in general well suited for recycling.
Therefore, the percentage of recovery (recycling) of HW is an indication for a
functioning HW management infrastructure.
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Rationale Which percentage of used oils treated in or shipped to the Member State is
recovered (excluding energy recovery)?
Source - Eurostat statistics on HW treatment (latest year available; waste code W013;
treatment option RCV_NE)
For plausibility checks:
- National Statistics
- Quality Reports on Waste Statistics for EU-28 Member States for 2012 or 2010
(DK, IT, LT, LU)
- E-PRTR register (considering information about waste transfers as per country -
http://prtr.ec.europa.eu/WasteTransfer.aspx)
Eurostat data available for the reliance on hazardous waste recovery for waste oils are available for
the amount of waste oils treated in the country. Volumes treated in the country refer to national
volumes generated minus exports plus imports.
For the assessment 2012 data were used, except for DK, IE, IT, LT and RO where data for 2010 have
been used.
For the calculation the following Eurostat reference codes data were used:
Type of waste: W013
Amount of waste treated: TOTAL
Treatment option for total the amount: TRT
Type of waste recovered: RCV_NE
The recovery rate is calculated with the total amount of waste oils recovered (excluding energy
recovery) compared to the total amount of waste oils treated within the Member State (including
imports, excluding exports).
Results
The rate of waste oils treated or shipped to the Member State for recovery (excluding energy
recovery) lies to between 0% and 100% based on the figures provided by Eurostat. The average
recovery rate in EU-28 amounts to approximately 79%.
Score of 2 for MS with highest recovery rates (13 MS):
BE, BG, CY, DE, EE, ES, FI, GR, IE, LT, LV, PL and PT are the 13 MS with the highest recovery rates
(above 75%) with regard to the amount treated within the country.
Score of 1 for MS with medium recovery rates (6 MS):
DK, HU, IT, LU, SE and SK are the 6 MS medium rates of used oils (between 52% and 73%). For LU all
waste were exported (with no further information which treatment applied, therefore score 1).
Score of 0 for MS with lowest recovery rates (9 MS):
AT, CZ, FR, HR, MT, NL, RO, SI and UK show low rates of used oil recovery (between 0% and 46%).
For MT the actual rate is unknown, as used oils are reported under mixed code (13 07 03* code
according to European List of Waste).
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Remarks on data uncertainties
The same inconsistencies as described for criteria 3.4 and the same validation procedure apply.
Additionally, for CZ some uncertainties remain. Compared to 2010 the share of used oils recovered in
CZ decreased from 79% to 46% (8.948 t to 2.827 t). The reason is not obvious, a possible explanation
would be e.g. potential storage effect due to unplanned shut downs. Such effects would impact the
scoring significantly.
3.2.4 Available data on generation and management of hazardous waste
Criterion 4.1: Existence and quality of HW generation/treatment data reported to Eurostat
Background According to Article 3 of Regulation (EC) No 2150/2002 on waste statistics,
“Member States shall, whilst complying with conditions as to quality and accuracy to
be defined in accordance with the procedure referred to in Article 7(2), acquire data
necessary for the specification of the characteristics listed in Annexes I and II by
means either of:
- surveys,
- administrative or other sources, such as the reporting obligations under
Community legislation on waste management,
- statistical estimation procedures on the basis of samples or waste-related
estimators, or
- a combination of these means.”
In practice, HW generation and treatment data resulting from information of waste
tracking systems (waste record system, consignment notes, and electronic registers)
in place in the Member States are usually more precise and of better quality than
data based on reporting obligations.
Hence, the data basis for HW generation and treatment data reported to Eurostat
is assessed for each Member State.
Rationale What is the basis for HW generation and treatment data reported to Eurostat?
Source - Eurostat statistics on HW generation (latest year available)
- Quality reports from Eurostat (2012, for DK, IT, LT, LU 2010)
Results
Tracking systems for HW deem high effort for both the competent authorities and the stakeholders
involved in HW generation, collection, transport and treatment. However, such systems allow a very
good traceability of waste from generation to its final treatment, and produce waste generation and
treatment data reflecting real amounts.
Six EU Member States have implemented such complex waste tracking systems. HW generation data
stemming from those tracking systems are reported to Eurostat. Five EU Member States base their
HW generation data reported to Eurostat on reporting obligations set by EU legislation. 17 Member
States base their reporting of generated HW amounts on estimations, sampling and surveys.
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Score of 2 for MS using waste tracking systems as data basis (6 MS):
AT, BG, DE, HR, IT and NL apply tracking systems for HW getting the score 2, with following
specifications:
- AT: EDM traceability register (www.edm.gv.at)
- BG: Register via ExEA (Executive Environmental Agency)
- DE: consignment notes ("Begleitscheinverfahren")
- HR: mainly EPR (Environmental Pollution Register - waste producer based > 50 kg)
- IT: MUD declarations, SISTRI (Waste Traceability Control System)
- NL: Transport register
Score of 1 for MS following reporting obligation (6 MS):
Reporting obligations under Community legislation on waste management are the basis for reporting
HW generation data for DK, EE, LT, LU, MT and SK; receiving the score of 1.
- DK: reports from the waste handlers on collected waste
- EE: waste permit system including reporting obligation, Waste Data Management System
operated by Environmental Agency plus estimations mainly for enterprises less 10 employees
- LT: reporting obligation by waste generation and treatment companies; > 200 kg/year of HW
- LU: reporting obligation
- MT: WasteServ and MEPA; data from legally operating waste generators are requested
- SK: obligation to submit data when producing > 50 kg of HW
Score of 0 for MS using estimations, waste survey and sampling as a data basis (16 MS):
BE, CY, CZ, ES, FI, FR, GR, HU, IE, LV, PL, PT, RO, SE, SI and UK
- BE: for Flanders and Brussels Environmental permit database and reporting obligation; for
Wallonia survey/estimations
- CY: sample survey, applicable only for licensed treatment, not possible to determine on
treatment
- CZ: sample survey (List of treatment facilities)
- ES: RT Survey plus model based estimations; Licensed Waste Managers including reporting
obligation
- FI: VAHTI Administrative register (enterprises, permits) plus survey and other sources
- FR: administrative sources plus survey
- GR : ELSTAT, different registers plus additional survey
- HU : 100% sample survey (HW > 200 kg)
- PL: IWMS data collection system; survey based
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- PT: sample survey, model based
- SE: survey based, partly environmental reports only
- SI: survey based (ODP, ODP-Z, OPD-P); for HW > 5 kg, for treatment survey based for waste
recovery and disposal (ODP-P); for waste brought to landfill sites (KO-U)
- UK: administrative and survey data
- IE, LV, RO : survey based
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Criterion 4.2: Hazardous waste data available to public
Background According to Article 7 of the WFD,
“(1) The measures designed to amend non-essential elements of this Directive
relating to the updating of the list of waste established by Decision 2000/532/EC
shall be adopted in accordance with the regulatory procedure with scrutiny referred
to in Article 39(2). The list of waste shall include hazardous waste and shall take into
account the origin and composition of the waste and, where necessary, the limit
values of concentration of hazardous substances. The list of waste shall be binding
as regards determination of the waste which is to be considered as hazardous waste.
...”
“(7) The Commission shall ensure that the list of waste and any review of this list
adhere, as appropriate, to principles of clarity, comprehensibility and accessibility for
users, particularly small and medium-sized enterprises (SMEs)”.
Detailed information about waste streams (six digit code or similar detailed national
classification) are the basis for the correct classification and identification of
treatment opportunities and thus allowing to identify recovery options according to
the EU waste hierarchy. Aggregated data are also meaningful, mainly with regard to
the origin, but leave room regarding the assessment of specific parameters of each
type of waste. A detailed publicly available data basis is of substantial public interest
due to the potential impacts of hazardous waste management on health and
environment. Furthermore, it allows for waste stream specific analysis and its
potential treatment options by market players. This could form the basis for
investment decisions by waste treatment companies i.e. recovery/recycling
facilities.
Therefore, the level of detail of HW data available to public is assessed.
Rationale To what level of detail are figures on HW management publicly available (Note:
National classification systems will be considered similar to LoW).
Source - National implementation report on WFD, mainly Question 11(2)
In case no information available in report/no report available:
- [Prognos 2009] European Atlas of Secondary Raw Materials and [Prognos
2009a] Study of waste streams and secondary materials in the EU
- National waste legislation
- National waste statistics, publicly available
Results
Based on publically available information provided in reports, web pages and databases provided by
official institutions (Statistical offices, Environmental Agencies, Ministries of Environment,…) for 6 MS
a score of 2 was awarded (data on HW available with full 6 digit-code according to List of Waste). 4
MS were awarded a score of 1 (such data available for certain regions). For the majority of 18 MS
only aggregated data (e.g. to the level of 2 digits) is available; they have been awarded a score of ‘0’.
Score of 2 for MS making available to the public HW information using a six digit code according to
LoW or using a detailed national classification system (6 MS):
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− CZ available in the annual yearbook and at Waste Management Information System (ISOH),
http://isoh.cenia.cz/groupisoh/
− DE available in German Statistical Office (DESTATIS), publication of Expert Series 19
− EE published at available in Estonian Statistical Office, http://pub.stat.ee/px-
web.2001/I_Databas/Environment/01Environmental_pressure/06Generation_of_waste/06G
eneration_of_waste.asp
− FR listed in French Pollution Register,
http://www.irep.ecologie.gouv.fr/IREP/index.php?adr=http://www.irep.ecologie.gouv.fr/IRE
P/generic.php?strType=presentation
− SK available at ENVIROPORTAL, http://cms.enviroportal.sk/odpady/verejne-informacie.php
− UK published at Environmental Agency, http://www.geostore.com/environment-
agency/WebStore?xml=environment-agency/xml/ogcDataDownload.xml
Score of 1 for those MS making partly available to the public HW information using six digit codes
according to LoW (4 MS):
− 6-digit codes data on HW is partly available for AT based on ÖNORM classification within the
'Status report on waste management in Austria' (Die Bestandsaufnahme der Abfallwirtschaft
in Österreich) 2013", http://www.bundesabfallwirtschaftsplan.at/.
− For DK 6-digit codes data is partly available via ISAG / ADS until 2009,
http://mst.dk/virksomhed-myndighed/affald/tal-for-affald/statistikker-og-isag-
dataudtraek/isag-informations-system-for-affald-og-genanvendelse/
− For ES 6-digit codes data on HW is available for some regions.
− The IE national WMP on hazardous waste includes a detailed list of HW data; however is
partly aggregated and not very often updated (WMP revision every 6 years); latest available
data is for 2011.
Score of 0 for MS with only aggregated data publicly available (18 MS):
For the remaining 18 MS a score of 0 was awarded, as data on HW management are publicly
available only on an aggregated level comparable to the reporting to Eurostat. These MS are BE, BG,
CY, FI, GR, HR, HU, IT, LT, LU, LV, MT, NL, PL, PT, RO, SE and SI.
3.2.5 Enforcement of hazardous waste legislation (inspection, penalties)
Criterion 5.1: Responsibilities and inspections
Background A basic condition for proper waste management in line with Article 13 of the WFD is
a clear assignment of responsibilities to all involved actors, such as authorities,
waste producers, waste collectors, etc. Article 15 of the WFD enables the MS to
allocate responsibilities among involved actors:
“Member States shall take the necessary measures to ensure that any original waste producer or other holder carries out the treatment of waste himself or has the treatment handled by a dealer or an establishment or undertaking which carries out
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waste treatment operations or arranged by a private or public waste collector in accordance with Articles 4 and 13.” However, Article 15(2) enables the MS to specify conditions of responsibility as long as proper handling of hazardous waste is guaranteed along the whole treatment chain.
As regards inspections, several actors could be involved, e.g. regional authorities,
inspectorates, police, environmental protection authorities and others. It is crucial
that responsibilities are clearly defined amongst those institutions and amongst the
different regional levels of a Member State.
Therefore, it is assessed whether responsibilities for HW requirements are clearly
defined in the MS.
Rationale Are responsibilities for enforcement of HW requirements clearly defined?
Source - National implementation report on WFD, Question 17
Results
Responsibilities for enforcement of HW requirements are described in all MS. Usually the authorities
for implementation and enforcement are specified in the national waste law. As regards control
authorities, there is in some cases a distinction made amongst authorities depending on the type of a
facility (e.g. large facilities at national or regional level, small facilities at municipal level). The level of
detail used to describe the allocated responsibilities differs between the MS; however there is no
justification for a distinction during awarding of the score.
Score of 2 for MS where responsibilities of enforcement are clearly defined (28 MS):
All 28 MS declare responsibilities of enforcement of hazardous waste information.
Criterion 5.2: Regular inspections and inspection capacities
Background According to Article 34(1) of the WFD,
“Establishments or undertakings which carry out waste treatment operations, establishments or undertakings which collect or transport waste on a professional basis, brokers and dealers, and establishments or undertakings which produce hazardous waste shall be subject to appropriate periodic inspections by the competent authorities.”
In order to fulfil these requirements, Member States need to ensure sufficient
administrative and technical capacities at the level of respective authorities. In
addition to general inspections, Article 34(2) of the WFD requires capacity to cover
inspections of “origin, nature, quantity and destination of the waste collected and
transported.”
Therefore, it is assessed if a system of regular inspections is foreseen and if it
describes schedules/inspections plans/capacities in order to carry out inspections.
Rationale Is an inspection capacity assigned for the control of permits, transports and
undertakings (including regular on-site inspections, controls of labelling
obligations)?
Source - National implementation report on WFD, Question 17
- National information sources
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Results
The objective was to assess if MS have in place a system for regular inspections and if there is
sufficient capacity to cover inspections in the manner prescribed by WFD. In particular, it was
assessed if MS have prescribed details related to scheduling of regular inspections and the level of
detail of inspections; and if MS have sufficient administrative and technical capacity to carry out
inspections. 15 MS have in place a system of regular inspections and have declared capacities. For 13
MS, only rather vague information on their inspection systems could be identified.
Score of 2 for MS where the system of regular inspections is described and inspection capacities
are declared (15 MS):
AT, CY, CZ, DE, ES, FI, FR, HU, IE, LV, PL, SE, SI, SK and UK describe the inspection system in place in
detail, and indicate details on inspection capacities.
Score of 1 for MS where the system of inspections is explained to a less detailed extent (13 MS):
BE, BG, DK, EE, GR, HR, IT, LT, LU, MT, NL, PT and RO include only vague information on the system
of regular inspections.
Criterion 5.3: Penalties and Fines
Background In order to enforce EU waste legislation and ensure a prohibition of abandonment,
dumping or uncontrolled waste management, Article 36 of the WFD requires MS,
to
“lay down provisions on the penalties applicable to infringements of the provisions
of this Directive and shall take all measures necessary to ensure that they are
implemented. The penalties shall be effective, proportionate and dissuasive.”
Therefore, a clearly defined scale of penalties should be laid down in national
legislation, which is assessed within this criterion.
Rationale Is a system of penalties and fines defined in national legislation; are examples
available?
Source - National implementation report on WFD, Qu. 18
Results
A system of penalties and fines is laid down by all MS legislation. The level of detail of the system
varies as some MS provide a full description of their system of penalties and fines.
Score of 2 for MS where a system of penalties and fines is defined in national legislation (28 MS):
All 28 MS declare a system of penalties and fines defined in national legislation.
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3.3 Generated amounts and most relevant hazardous waste streams
As additional information, hazardous waste generation in terms of amounts has been summarised. In
2012, hazardous waste generation was estimated to be more than 100 million tonnes in EU-28
[Eurostat 2012]. The following MS generate the largest amounts of HW:
− DE about 21.9 M tonnes (about 22% of EU-28 generation14),
− BG about 13.4 M tonnes (about 13% of EU-28 generation),
− FR about 11.3 M tonnes (about 11% of EU-28 generation), and
− EE 9.1 M tonnes and UK 8.6 M tonnes (each about 9% of EU-28 generation).
The main HW streams are mostly mineral waste fractions, e.g. other mineral wastes (W12B15, 17%),
soils (W126, 9%), combustion wastes (W124, 11%), and mineral waste from construction and
demolition (W121, 8%) (Eurostat terminology applied).
Focussing on non-mineral HW streams, the majority of these was generated by chemical and
pharmaceutical industry: chemical wastes (W02A, almost 14%), used oils (W013, 4%), spent solvents
(W011, 3%) and acid, alkaline or saline wastes (W012, 3%).
Further relevant amounts originate from discarded vehicles (W081) amounting to 7% of all HW
generated.
The shares of the most relevant waste streams differ between the MS as summarised in the following
table. Please note that, depending on the project progress, data are based on data available at
Eurostat as per 25.03.2015. For selected MS later updates are available. The general trend, of course,
has not changed.
Table 3-2: Overview of most important HW streams as generated in EU-28 MS
MS Total amount of HW generated (Eurostat)
[t/2012] [% of EU-28]
Top 3 HW streams as per MS [Eurostat-code: Name (amount in t; % of total per country)]
AT 1,065,888 1.1% 1. W128_13: Mineral wastes from waste treatment and stabilised wastes (201 kt; 19%)
2. W02A: Chemical wastes (175 kt; 16%)
3. W124: Combustion wastes (134 kt; 13%)
BE 4,257,755 4.2% 1. W02A: Chemical wastes (638 kt; 15%)
2. W05: Health care and biological wastes (540 kt; 13%)
3. W126: Soils (472 kt; 11%)
BG 13,407,042 13.2% 1. W12B: Other mineral wastes (W122+W123+W125) (13,268 kt; 99%)
2. W124: Combustion wastes (75 kt; 1%)
3. W032: Industrial effluent sludges (16 kt; 0%)
CY 31,288 0.0% 1. W081: Discarded vehicles (14 kt; 44%)
2. W12B: Other mineral wastes (W122+W123+W125) (5 kt; 17%)
14 The shares within the EU-28 is an estimation only, as for selected MS detailed data are available only for 2010. 15 According to Waste Statistic Regulation, Regulation (EC) No 2150/2002, OJ L 332, 09/12/2002, p. 1–36.
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MS Total amount of HW generated (Eurostat)
[t/2012] [% of EU-28]
Top 3 HW streams as per MS [Eurostat-code: Name (amount in t; % of total per country)]
3. W013: Used oils (5 kt; 16%)
CZ 1,481,281 1.5% 1. W126: Soils (387 kt; 26%)
2. W02A: Chemical wastes (214 kt; 14%)
3. W121: Mineral waste from construction and demolition (154 kt; 10%)
DE 21,983,895 21.7% 1. W121: Mineral waste from construction and demolition (4,438 kt; 20%)
2. W02A: Chemical wastes (2,701 kt; 12%)
3. W128_13: Mineral wastes from waste treatment and stabilised wastes (2,608 kt; 12%)
DK 1,192,750 1.2% 1. W126: Soils (473 kt; 40%)
2. W121: Mineral waste from construction and demolition (202 kt; 17%)
3. W103: Sorting residues (131 kt; 11%)
EE 9,159,140 9.0% 1. W124: Combustion wastes (7,543 kt; 82%)
2. W02A: Chemical wastes (1,518 kt; 17%)
3. W033: Sludges and liquid wastes from waste treatment (20 kt; 0%)
ES 3,113,947 3.1% 1. W02A: Chemical wastes (675 kt; 22%)
2. W012: Acid, alkaline or saline wastes (422 kt; 14%)
3. W124: Combustion wastes (325 kt; 10%)
FI 1,653,942 1.6% 1. W12B: Other mineral wastes (W122+W123+W125) (746 kt; 45%)
2. W121: Mineral waste from construction and demolition (210 kt; 13%)
3. W012: Acid, alkaline or saline wastes (194 kt; 12%)
FR 11,303,137 11.2% 1. W126: Soils (2,444 kt; 22%)
2. W081: Discarded vehicles (1,496 kt; 13%)
3. W02A: Chemical wastes (1,408 kt; 12%)
GR 297,370 0.3% 1. W081: Discarded vehicles (77 kt; 26%)
2. W013: Used oils (51 kt; 17%)
3. W0841: Batteries and accumulators wastes (48 kt; 16%)
HR 122,541 0.1% 1. W081: Discarded vehicles (31 kt; 25%)
2. W08A: Discarded equipment (except discarded vehicles and batteries and accumulators waste) (W08 except W081, W0841) (15 kt; 13%)
3. W02A: Chemical wastes (15 kt; 12%)
HU 700,246 0.7% 1. W02A: Chemical wastes (146 kt; 21%)
2. W126: Soils (111 kt; 16%)
3. W128_13: Mineral wastes from waste treatment and stabilised wastes (91 kt; 13%)
IE 1,972,204** 1.9% 1. W02A: Chemical wastes (775 kt; 39%)
2. W011: Spent solvents (606 kt; 31%)
3. W126: Soils (204 kt; 10%)
IT 9,474,449 9.4% 1. W02A: Chemical wastes (1,496 kt; 16%)
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
MS Total amount of HW generated (Eurostat)
[t/2012] [% of EU-28]
Top 3 HW streams as per MS [Eurostat-code: Name (amount in t; % of total per country)]
2. W128_13: Mineral wastes from waste treatment and stabilised wastes (1,367 kt; 14%)
3. W032: Industrial effluent sludges (1,293 kt; 14%)
LT 136,786 0.1% 1. W02A: Chemical wastes (36 kt; 26%)
2. W081: Discarded vehicles (25 kt; 18%)
3. W0841: Batteries and accumulators wastes (17 kt; 13%)
LU 315,082 0.3% 1. W126: Soils (159 kt; 51%)
2. W124: Combustion wastes (44 kt; 14%)
3. W075: Wood wastes (39 kt; 12%)
LV 95,110 0.1% 1. W126: Soils (30 kt; 31%)
2. W081: Discarded vehicles (10 kt; 11%)
3. W02A: Chemical wastes (9 kt; 9%)
MT 29,326 0.0% 1. W081: Discarded vehicles (12 kt; 42%)
2. W02A: Chemical wastes (10 kt; 34%)
3. W124: Combustion wastes (2 kt; 5%)
NL 4,859,942 4.8% 1. W121: Mineral waste from construction and demolition (1,369 kt; 28%)
2. W02A: Chemical wastes (1,151 kt; 24%)
3. W127: Dredging spoils (585 kt; 12%)
PL 1,737,024 1.7% 1. W124: Combustion wastes (341 kt; 20%)
2. W02A: Chemical wastes (302 kt; 17%)
3. W012: Acid, alkaline or saline wastes (235 kt; 14%)
PT 544,963 0.5% 1. W02A: Chemical wastes (96 kt; 18%)
2. W032: Industrial effluent sludges (82 kt; 15%)
3. W081: Discarded vehicles (68 kt; 13%)
RO 670,590 0.7% 1. W032: Industrial effluent sludges (169 kt; 25%)
2. W12B: Other mineral wastes (W122+W123+W125) (89 kt; 13%)
3. W013: Used oils (78 kt; 12%)
SE 2,752,657 2.7% 1. W126: Soils (872 kt; 32%)
2. W02A: Chemical wastes (363 kt; 13%)
3. W081: Discarded vehicles (281 kt; 10%)
SI 136,953 0.1% 1. W02A: Chemical wastes (21 kt; 16%)
2. W103: Sorting residues (19 kt; 14%)
3. W011: Spent solvents (19 kt; 14%)
SK 370,223 0.4% 1. W02A: Chemical wastes (66 kt; 18%)
2. W033: Sludges and liquid wastes from waste treatment (58 kt; 16%)
3. W032: Industrial effluent sludges (44 kt; 12%)
UK 8,452,496 8.3% 1. W081: Discarded vehicles (1,641 kt; 19%)
2. W02A: Chemical wastes (1,449 kt; 17%)
3. W124: Combustion wastes (986 kt; 12%) * The shares within the EU-28 are an estimation only, as for selected MS detailed data are available only for 2010. ** Data available for 2010 only.
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European Commission Final report Support to Member States in improving HW management based on assessment of Member States' performance
3.4 Summary of screening results
The following two tables provide the overview of the screening results including the score each
Member State has obtained per criterion. The first figure lists the Member States in an alphabetical
order and the second one shows the sorted result of scoring with decreasing performance for the 28
Member States.
It has to be noted that the results presented for each criterion represent the status quo of
screening prior to the stakeholder consultation that has taken place once the screening was
completed. If changes had to be made based on comments obtained by TAC Members this has
been made within the respective ‘screening information’/ ‘factsheets’ of the Member State.
However, for methodological reasons, the scoring results have not been changed.
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Figure 3-1: Overall scoreboard of the screening results for HW management in the 28 Member States in alphabetical order
Overall
score
Average
score
MS /
Criterion1.1 1.2 1.3 2.1 2.2 2.3 2.4 2.5 2.6 2.7 3.2 3.3 3.4 3.5 3.6 3.7 3.8 4.1 4.2 5.1 5.2 5.3
38 1,81 AT 2 2 1 2 2 2 2 2 2 2 2 2 2 2 0 2 0 2 1 2 2 2
23 1,10 BE 2 0 0 1 1 1 2 2 1 2 1 2 0 0 0 1 2 0 0 2 1 2
32 1,52 BG 2 0 1 2 2 2 2 2 2 2 2 1 0 0 1 2 2 2 0 2 1 2
26 1,24 CY 0 0 0 1 2 0 2 2 2 2 0 0 1 2 2 2 2 0 0 2 2 2
31 1,48 CZ 2 0 1 2 2 2 2 2 2 2 0 0 2 2 0 2 0 0 2 2 2 2
36 1,71 DE 2 0 1 2 2 2 2 2 2 2 1 2 1 1 0 2 2 2 2 2 2 2
28 1,33 DK 2 2 1 1 2 2 2 0 2 2 2 2 0 0 0 0 1 1 1 2 1 2
32 1,52 EE 2 2 1 1 2 2 2 2 2 2 1 1 0 0 0 2 2 1 2 2 1 2
29 1,38 ES 2 0 1 1 2 1 1 2 2 2 0 1 1 1 2 1 2 0 1 2 2 2
26 1,24 FI 2 0 1 2 2 1 1 2 2 2 1 1 0 0 0 1 2 0 0 2 2 2
26 1,24 FR 0 0 1 1 2 2 2 2 2 2 0 1 1 1 0 1 0 0 2 2 2 2
29 1,38 GR 2 2 0 1 2 2 1 2 2 0 0 0 2 2 2 2 2 0 0 2 1 2
33 1,57 HR 2 2 1 2 2 2 1 2 2 2 1 0 2 1 2 2 0 2 0 2 1 2
28 1,33 HU 2 0 1 1 2 2 2 2 2 2 2 1 0 0 0 2 1 0 0 2 2 2
31 1,48 IE 2 2 1 2 2 2 1 2 2 0 2 1 1 1 0 1 2 0 1 2 2 2
28 1,33 IT 0 0 2 1 2 2 2 0 2 2 2 0 1 0 2 2 1 2 0 2 1 2
32 1,52 LT 2 2 1 1 2 2 1 2 2 2 2 1 1 1 0 2 2 1 0 2 1 2
31 1,48 LU 2 2 1 1 2 2 1 2 2 2 1 2 1 1 1 1 1 1 0 2 1 2
33 1,57 LV 2 2 2 1 2 2 2 2 2 2 0 0 2 2 2 0 2 0 0 2 2 2
29 1,38 MT 2 2 1 1 2 2 1 2 2 2 0 2 1 1 1 1 0 1 0 2 1 2
28 1,33 NL 2 0 1 2 2 2 1 2 2 0 1 2 1 1 0 2 0 2 0 2 1 2
33 1,57 PL 2 2 1 2 2 2 2 2 2 0 1 0 2 2 1 2 2 0 0 2 2 2
34 1,62 PT 2 2 1 2 2 2 2 2 2 2 0 0 2 2 2 2 2 0 0 2 1 2
21 1,00 RO 0 0 0 1 2 0 0 2 2 2 0 0 2 2 2 1 0 0 0 2 1 2
28 1,33 SE 2 2 2 2 2 0 1 2 2 2 2 2 0 0 0 0 1 0 0 2 2 2
25 1,19 SI 0 0 0 1 2 2 2 2 2 2 0 1 2 1 0 2 0 0 0 2 2 2
31 1,48 SK 2 2 1 1 2 1 2 2 2 0 2 2 0 0 1 1 1 1 2 2 2 2
30 1,43 UK 2 2 1 2 2 2 1 0 2 2 1 0 1 0 2 2 0 0 2 2 2 2
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Figure 3-2: Overall scoreboard of the screening results for HW management in the 28 Member States in scoring order
Overall
score
Average
score
MS /
Criterion 1.1 1.2 1.3 2.1 2.2 2.3 2.4 2.5 2.6 2.7 3.2 3.3 3.4 3.5 3.6 3.7 3.8 4.1 4.2 5.1 5.2 5.3
38 1,73 AT 2 2 1 2 2 2 2 2 2 2 2 2 2 2 0 2 0 2 1 2 2 2
36 1,64 DE 2 0 1 2 2 2 2 2 2 2 1 2 1 1 0 2 2 2 2 2 2 2
34 1,55 PT 2 2 1 2 2 2 2 2 2 2 0 0 2 2 2 2 2 0 0 2 1 2
33 1,50 PL 2 2 1 2 2 2 2 2 2 0 1 0 2 2 1 2 2 0 0 2 2 2
33 1,50 LV 2 2 2 1 2 2 2 2 2 2 0 0 2 2 2 0 2 0 0 2 2 2
33 1,50 HR 2 2 1 2 2 2 1 2 2 2 1 0 2 1 2 2 0 2 0 2 1 2
32 1,45 EE 2 2 1 1 2 2 2 2 2 2 1 1 0 0 0 2 2 1 2 2 1 2
32 1,45 BG 2 0 1 2 2 2 2 2 2 2 2 1 0 0 1 2 2 2 0 2 1 2
32 1,45 LT 2 2 1 1 2 2 1 2 2 2 2 1 1 1 0 2 2 1 0 2 1 2
31 1,41 LU 2 2 1 1 2 2 1 2 2 2 1 2 1 1 1 1 1 1 0 2 1 2
31 1,41 SK 2 2 1 1 2 1 2 2 2 0 2 2 0 0 1 1 1 1 2 2 2 2
31 1,41 CZ 2 0 1 2 2 2 2 2 2 2 0 0 2 2 0 2 0 0 2 2 2 2
31 1,41 IE 2 2 1 2 2 2 1 2 2 0 2 1 1 1 0 1 2 0 1 2 2 2
30 1,36 UK 2 2 1 2 2 2 1 0 2 2 1 0 1 0 2 2 0 0 2 2 2 2
29 1,32 MT 2 2 1 1 2 2 1 2 2 2 0 2 1 1 1 1 0 1 0 2 1 2
29 1,32 GR 2 2 0 1 2 2 1 2 2 0 0 0 2 2 2 2 2 0 0 2 1 2
29 1,32 ES 2 0 1 1 2 1 1 2 2 2 0 1 1 1 2 1 2 0 1 2 2 2
28 1,27 SE 2 2 2 2 2 0 1 2 2 2 2 2 0 0 0 0 1 0 0 2 2 2
28 1,27 NL 2 0 1 2 2 2 1 2 2 0 1 2 1 1 0 2 0 2 0 2 1 2
28 1,27 HU 2 0 1 1 2 2 2 2 2 2 2 1 0 0 0 2 1 0 0 2 2 2
28 1,27 IT 0 0 2 1 2 2 2 0 2 2 2 0 1 0 2 2 1 2 0 2 1 2
28 1,27 DK 2 2 1 1 2 2 2 0 2 2 2 2 0 0 0 0 1 1 1 2 1 2
26 1,18 FR 0 0 1 1 2 2 2 2 2 2 0 1 1 1 0 1 0 0 2 2 2 2
26 1,18 CY 0 0 0 1 2 0 2 2 2 2 0 0 1 2 2 2 2 0 0 2 2 2
26 1,18 FI 2 0 1 2 2 1 1 2 2 2 1 1 0 0 0 1 2 0 0 2 2 2
25 1,14 SI 0 0 0 1 2 2 2 2 2 2 0 1 2 1 0 2 0 0 0 2 2 2
23 1,05 BE 2 0 0 1 1 1 2 2 1 2 1 2 0 0 0 1 2 0 0 2 1 2
21 0,95 RO 0 0 0 1 2 0 0 2 2 2 0 0 2 2 2 1 0 0 0 2 1 2
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3.4.1 Hazardous waste management performance according to five main categories
The results of the performance screening exercise are summarised in the following texts following
the five main elements assessed. All information has been collected also in separate documents for
each Member State, called “screening information” (for 18 MS) and “factsheet” (for 10 MS, including
also further information from the in-depth analysis for those 10 selected MS). These documents are
accompanying this report; an overview list is available in Annex I/chapter 10.1. All documents can be
downloaded at the following EC website:
http://ec.europa.eu/environment/waste/index.htm
Content of waste management plans (WMPs) / waste prevention programmes (WPPs)
As regards the content of the Waste Management Plans: The vast majority of Member States’ WMP
include specifications on hazardous waste (e.g. specifications on collection, handling, storing, main
hazardous waste streams, amounts, etc.). Approximately half of the Member States provide data on
industrial hazardous waste in their plans, at least giving an overview on the main sectors. Two MS
only cover municipal waste within their current planning (SI, CY); one MS does not have a WMP
available at all (RO) and two MS do not cover the whole national territory with their large number of
regional WMPs (IT and FR).
As regards Waste Prevention Programmes, only three of the MS include quantitative targets in
order to reduce the hazardous waste generation in future (IT, LV, SE); the vast majority of MS
include, if at all, qualitative targets. Two MS do not include targets on HW at all (FI, RO) and three MS
have no WPP adopted (BE-Wallonia, GR, RO).
State of compliance with the legal requirements of waste legislation
The state of compliance with the legal requirements set in the WFD is reasonably good in most
Member States. In particular, the obligations on HW labelling and mixing ban are implemented at
national level in all MS (BE includes the obligations in three regional regulations). Both for labelling of
HW and for the ban of mixing of HW, problems in practice are reported by stakeholders; however, as
far as legal transposition is concerned no deficits could be identified.
As regards the requirement on record keeping, it can be considered that most of the MS have a good
level of implementation. However, differences in implementation are made as regards the record
practice, covering national or only some regional levels and requiring the involved actors to record
and report data timely to the Competent Authority in order to allow back-tracking and control. Four
MS do not operate a central register (BE, ES, FI, SK) and for further three no register is in place, or no
information available (CY, RO, SE). 16 MS require HW operators and involved actors to report data to
In conclusion the status of waste management planning can be stated as conform to the WFD’s
requirements for most of the Member States. Nearly half of the MS additionally include data on
hazardous industrial waste generation. As regards waste prevention, the reduction of hazardous
waste is described qualitatively in most of the Member States, whilst quantitative targets are still
an exception.
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Competent Authority at all steps of management, transport and treatment; 11 MS include only the
obligation to keep the records and to make them available on request. For RO no obligation could be
assessed.
Looking at the permitting procedures, only three MS include the possibility to release HW recovery
facilities from full permitting procedures (DK, IT, UK); all other MS do not include derogations for
such operations.
As concerns the derogations from the mixing ban, the majority of MS do not include such
derogations or set appropriate criteria. Five MS (GR, IE, NL, PL, SK) however do include the possibility
to derogate from the mixing ban within the permit. However, common criteria in national legislation
could not be found.
As regards the classification of HW, all MS implemented the requirements set in WFD (i.e. make link
to the European List of Waste and chemicals legislation). However only 12 MS provide additional
material to ensure and support correct classification (guidance, website, support measures by
competent authorities, etc.).
Collection and treatment of hazardous waste
With respect to the requirements for separate collection and storage, it can be concluded that all
MS include the general requirements laid down in the WFD. Some MS go beyond and explain what
the conditions for collection/storage are or provide supporting measures (guidance, websites, etc.).
Based on the information sources screened for this criterion (national implementation reports and
national waste legislation) it was not possible to assess sufficiently the differences between the
requirements in all Member States because information was partly included in extra documents. As
an example the Environment Agency in the UK provides an additional guidance document for storing
and sorting that goes beyond information and requirements included in national legislation. These
supportive measures could not be assessed for all Member States within the scope of this project.
WEEE and batteries/accumulators are the main sources of HW stemming from households. As
regards the separate collection of WEEE, eight MS are already reaching or over-achieving the 45%
target of 2016 (AT, BE, HU, IE, IT, LT, SE, SK). For the collection of batteries and accumulators, six MS
(AT, BE, LU, DK, SE, SK) reach or over-achieve the target of 2016. On the other hand, there are still
MS where significant efforts have to be made in order to reach the targets, or where the fulfilment is
unlikely. Regarding the 45% target for WEEE FR, LV, GR, ES, RO, MT and CY are below 30% in 2012,
The implementation of EU requirements on hazardous waste is satisfactory for most
requirements. No deficits as regards legal transposition could be identified for HW labelling and
mixing ban. Some MS show discrepancies in the legal transposition on derogations given on the
mixing ban and for permitting procedures of HW recovery facilities. Large differences between
MS were assessed in terms of the record keeping system in place, and reporting obligations for
the operators. Supporting measures in order to ensure correct classification of HW are available
only in a few MS.
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while for batteries and accumulators in 2013 GR, HR, UK, CY and RO did not meet the 25% target and
will unlikely meet the 45% target in 2016.
When looking at the waste hierarchy as implemented in practice, major deficits remain. About one
third of the MS is relying on disposal operations (depositing HW onto or into land (D1, D5, D1216)) to
a large extent (more than 40% of overall HW treated in such D operations). Also when looking at the
three major HW streams (spent solvents, used oils, acid, alkaline or saline wastes) there is potential
for more recovery operations (excluding energy recovery) for at least 12 MS.
It has to be noted that there are concerns related to the reliability of statistical data even after
performing quality controls and plausibility checks of that data. This is further detailed in the report.
In order to remove the open uncertainties, the responsible experts for statistics in the MS have been
requested to confirm the data or explain uncertainties and data gaps.
Available data on generation and management of hazardous waste
Data availability and data basis for reporting to Eurostat differs in the MS. Only six MS (AT, BG, DE,
HR, IT, NL) base their reporting to Eurostat on an existing tracking system (registry); such a system
ensures high preciseness and good data quality. Other six MS base their reporting to Eurostat on
data retrieved from reporting obligations (BE Fl; BE Br, DK, EE, LU, LT, SK). 16 Member States use
survey and sample as a basis for HW data on generation and/or treatment, thus being one source of
inconsistencies of Eurostat data. As regards the data published with open access to public and
stakeholders, only six MS (CZ, DE, EE, FR, SK, UK) publish data according to a six digit code (List of
Waste); AT, DK, ES and IE have this data partly available (e.g. covering certain regions).
16 As defined in the Waste Framework Directive (Annex I): D1=Deposit into or on to land (e.g. landfill, etc.), D5= Specially
engineered landfill (e.g. placement into lined discrete cells which are capped and isolated from one another and the environment, etc.), D12= Permanent storage (e.g. emplacement of containers in a mine, etc.).
Requirements for collection and storage are implemented in all MS at least as general requirements
in national legislation. The separate collection of WEEE and batteries/accumulators is at different
levels in the MS, with a few MS reaching/overachieving the 2016 targets, whilst other MS struggle
to reach the targets. As regards (statistical) performance of actual treatment of HW considering the
waste hierarchy, there is large potential for improvement. It has to been noted that it is difficult to
verify and interpret results based on Eurostat data.
As regards quality and availability of data on hazardous waste there is potential for improvement
as the majority of MS use surveys and samples as a basis to report data to Eurostat, instead of data
reported, and only some MS publish data on the basis of the six digit code in order to allow
stakeholders and public to see and follow-up on such data.
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Enforcement of hazardous waste legislation
As concerns the enforcement of HW legislation, the structures for a thorough enforcement are set
and declared (in the implementation reports sent by MS on the basis of Article 37 of WFD). All MS
clearly define the responsibilities for enforcement of HW requirements and all MS have systems of
penalties and fines defined in national legislation, including examples of such fines and penalties. 15
MS sufficiently describe in the Implementation Reports on WFD the system of regular inspection, the
general inspection capacity available or/and number of inspections performed/planned. This does
not mean that there are no differences and gaps in actual implementation
The performance of EU-28 MS as regard hazardous waste management can be summarised as:
1. Good status of waste management planning, including HW specifications in most of the Member
States’ WMPs and data on industrial hazardous waste for about half of the plans; setting at least
qualitative targets for the reduction of HW in waste prevention programmes (WPP), however
only some include quantitative targets for the prevention of hazardous waste.
2. Good implementation for most of EU requirements on HW with no deficits as regards the
implementation of labelling requirements and the mixing ban into national legislation; remaining
differences for setting derogations of the mixing ban and permitting of HW recovery installations;
large differences as regards record keeping systems, reporting obligations and support of correct
classification.
3. Different levels of performance regarding the separate collection of WEEE and batteries/
accumulators; large potential for improvement as regards the reliance on landfilling and the
practice of recovery operations for at least ten MS. Furthermore, there are gaps and difficulties
concerning the reliability of HW data, in particular concerning the data basis used for reporting
to Eurostat. There are no gaps as regards the inclusion of general requirements on collection and
storage of HW into legislation, even though information from practical implementation shows
that there might be differences regarding implementation on the ground.
The basis for a full enforcement of HW legislation seems to be laid in most MS: responsibilities
are defined, penalties and fines declared by all MS, and enforcement/inspection capacities
assigned by the majority of MS. This does not mean that there are no differences and gaps in
actual implementation. As an example in the Czech Republic detailed information on the
number of inspections per year per type of facility is available; in 2012 around 75 inspectors
conducted 2,100 inspections on landfills, incinerators, waste collection centres etc. This
information, including the results of the inspections, is made available to the public on an
annual basis. For most Member States on the other hand, solely the information on the general
conditions for inspections, e.g. inspection of IEEP facility every 3 years, is available in the
legislation. If inspections plans, number of conducted results and findings of the inspections
are not publically available it cannot be assessed if legal requirements are enforced in the
Member States. However, the basis for carrying out inspection and enforcement procedures is
set for the majority of MS in national legislation.
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4. Potential for improvement of the data reporting basis and publically available data on HW.
5. Good general enforcement of HW legislation as regards the definition of responsibilities and the
setting of penalties and fines, with differences in the assignment of enforcement
capacities/carried-out inspection activities.
The result of the screening exercise showed that there are differences between the Member States
in implementing the requirements of the WFD for hazardous waste. However, according to present
research there is no ‘sharp’ demarcation line between the groups of “good” performers and the
group of countries having implementation gaps. Furthermore, as detailed in Chapter 4 and 5.3 it has
emerged from our research, confirmed also by the European Environment Agency work, that there
are major gaps on statistical data (generation/treatment of hazardous waste) for some Member
States, which makes interpretation of the overall results of the screening exercise difficult. The issue
of the statistical gap between the generation and treatment of hazardous waste was considered a
worrying finding. Therefore the second phase of the study concentrated on analysing and clarifying
this finding.
3.4.2 Summary of HW performance assessment for each Member State
Member States are listed in order of scoring (see also Figure 3-2):
AT (overall score of 38) shows an excellent overall HW performance including good
transposition of legal requirements as regards hazardous waste, performance of treatment
technologies and enforcement on the ground. Therefore AT reached the highest scoring for
almost all criteria. The criterion on waste prevention was scored with 1 as AT includes no
quantitative targets in order to reduce HW production in the current WPP. HW data for AT is
only partially available according to full six-digit-codes based on ÖNORM (scored 1).
Furthermore, both the rate of solvents sent to recovery operations (excluding energy recovery)
and the recovery rate of used oils are comparatively low (both criteria scored 0).
The same is valid for DE (overall score of 36); overall legal requirements, actual treatment and
enforcement on the ground are rated as above average; the majority of the criteria have been
rated with 2. As regards waste management planning, although extensive data is provided in
national statistics, two of the 16 regional waste management plans do not provide an overview
of the most significant hazardous industrial waste streams, and therefore this criterion has
been rated as 0. Furthermore, the national WPP does not include quantitative targets for the
reduction of HW. As regards treatment applied for HW, the rate of solvents sent to recovery
operations (excluding energy recovery) is below 75% (scored 0). According to Eurostat data, DE
Altogether it can be stated that there are no major gaps in the transposition of EU
requirements into national legislation and the declaration of responsibilities and enforcement
measures (e.g. penalties). However, there are differences in the realisation of measures to
support HW management practice and to allow the authorities to properly follow, control, and
manage HW. Also, the actual performance as regards the application of treatment operations
in line with the waste hierarchy is at different status with potential for improvement.
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still relies on the disposal of HW (depositing into/onto land) both including exports and
excluding imports (both criteria scored 1). Lastly, the rate for the separate collection of WEEE
is only average (scored 1).
PT (overall score of 34) has very good results regarding compliance with the legal
requirements of European HW legislation; all criteria have been scored 2. In addition, the
Waste Management Plan includes specification on HW as well as an overview on industrial HW
generation. As regards waste prevention targets for HW, no quantitative targets are set in the
WPP (scored 1). Despite the very good overall score, some criteria of HW waste management
were below average. The separate collection of WEEE (34%) and batteries (28%) are clearly
below the average collection rate of the other Member States. Furthermore, the available data
on generation and management of HW is insufficient because data reported to Eurostat is
based only on a sample survey and in general HW is not publicly available on an aggregated
level (scored 0).
With the exception of the derogation from the mixing ban, PL (overall score of 33) has a very
good state of compliance with legal requirements of HW legislation in regard to classification,
labelling, record keeping, and permit procedure (all scored 2). According to the Polish waste
law (Art. 21), the mixing of HW is allowed if mixing helps to improve the security of processing
mixed waste generated is set in the law (scored 0). In addition, the Waste Management Plan
includes specification on HW as well as an overview on industrial HW generation. In regards to
waste prevention targets for HW, no quantitative targets are set in the WPP (scored 1).
Furthermore, Poland has very low rates for the disposal of HW. The reporting is based on
sample surveys rather than on real data reported within e.g. a registry and HW data is only
available to public on an aggregated level (both scored 0). The enforcement of HW legislation
includes inspection responsibilities and capacities as well as deterrent measures including
penalties and fines; all three criteria have been scored 2.
LV (overall score of 33) has excellent transposition of HW legislation; all three criteria have
been scored with 2. Inspection responsibilities and capacities for inspections as well as
penalties for infringements are clearly defined in legislation or information is available. Also,
core requirements of HW management have been transposed into national legislation like
procedures of labelling, registration and permit procedures, mixing ban of HW and
derogations. WMP include specifications on HW and lists the most important HW industrial
waste streams. There are significant performance gaps in the quality of HW data and its
availability to the public. As one out of only three countries, LV includes quantitative targets as
regards the prevention of HW in the current WPP. Another deficit is the performance of
separate collection of WEEE (28%) and batteries (26%) which were both very low compared to
the other Member States (Average WEEE: 39%, Batteries: 40%). According to HW treatment
date, LV is performing well, except for the acid, alkaline and saline waste, where recovery rate
(excluding energy recovery) is reported as zero.
The situation in HR (overall score of 33) is comparable to LT. HW management planning is
consistent and includes industrial HW and the specifications on HW. HW legislation is well
transposed into national law. The enforcement of HW legislation is supported through clear
responsibilities and fines / penalties for infringements. However, there are performance gaps
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in the separate collection of batteries and accumulators (19%) as well as in the recovery of
used oils (below 50%), and therefore both scored 0. Furthermore, the availability of HW data
for public use is not sufficient because only aggregated data is made available. Actual
performance as regards the separate collection of WEEE and the rate for depositing HW onto
or into land treated in the Member States or exported to another country was average (both
scored 1).
EE (overall score of 32) scored 2 for thirteen criteria including specification of HW and
industrial HW amounts in WMP, the transposition of all legal requirements on labelling, record
keeping, permitting and the mixing ban, and most criteria on enforcement and the availability
of HW data to the public. In regards to waste prevention targets for HW, no quantitative
targets are set in the WPP (scored 1). Average performance (scored 1) was assigned to HW
classification and separate collection rates of WEEE and batteries. Low scores have been given
for heavy reliance on disposal of HW onto or into land and the HW recovery rate for spent
solvents (below 50%).
The case of BG (overall score of 32) is similar to the situation in EE in regard to the
transposition of legal requirements: all criteria for labelling, classification, record keeping,
mixing ban and its derogation have been scored with 2. In Bulgaria there are issues with the
performance in the field of HW management. The recently legally adopted Waste
Management Plan, which also contains the Waste Prevention Programme, does neither
include detailed information on the amounts of industrial HW nor quantitative targets for HW
reduction. Concerning technical performance based on statistical data, there are deficits in the
rate for depositing HW onto or into land (scored 0). The rate for recovery of spent solvents
(excluding energy recovery) is below 50 % (score 1).
LT (overall score of 32) shows good transposition of legal requirements of HW management,
and a good level of enforcement and of HW management planning. In regard to waste
prevention targets for HW, no quantitative targets are set in the WPP (scored 1). LT attained
average performance in the support of HW classification since no supportive measures are
conducted (scored 1); the requirements for the record keeping system were scored average
since there is no obligation to report HW data to a competent authority. Performance gaps
have been identified for the HW recovery of spent solvents since the rate is below 50% and
data on HW is only available on an aggregated level to the public (scored 0). Further, LT is fairly
reliant on depositing HW into/onto land. However, responsibilities for inspections, as well as
penalties and fines, are clearly defined leading to good enforcement of HW legislation.
LU (overall score of 31) scored 2 for HW management planning, the enforcement of HW
legislation in the country as well as for compliance with legal requirements for HW
management. As most of the MS, LU does not include quantitative targets on HW in the WPP.
However, additional support for HW classification and reporting obligations of HW data to the
competent authority were average and have been scored 1. Average performance was also
assigned to the separate collection rate of WEEE and the HW data reporting since it is not
based on a waste tracking system. For all criteria as regards HW treatment (criteria 3.4 to 3.8),
LU has received the score of 1, as LU is mainly depending on waste export.
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The situation in SK (overall score of 31) is very good when it comes to transposition of HW
legislation (all criteria scored 2), the separate collection rate for WEEE and batteries, HW
management planning and record keeping obligations. In regard to waste prevention targets
for HW, no quantitative targets are set in the WPP (scored 1). Average statistical data
performance was assessed in the field of HW recovery of used oils, acid, alkaline or saline
wastes and spent solvents (scored 1). Slovakia does not provide additional support for HW
classification in the form of a guidance document. Based on reported Eurostat data, significant
amounts of HW are still landfilled since the rate for depositing HW onto or into land is still high
(score 0). Furthermore, criteria for the derogation of the HW mixing ban are not clearly
defined in legislation, hereafter the mixing may be carried out if it is needed to increase safety
during waste recovery or disposal. This may be defined within a granted permit by setting
conditions on case to case basis (scored 0).
CZ (overall score of 31) has very good performance in the fields of HW legislation transposition
and enforcement including inspection responsibilities, inspection capacities and
penalties/fines for infringements as well as compliance with legal requirements of European
waste legislation; all criteria being scored with 2. However, there are performance deficits for
the separate collection rate of WEEE (32%) and batteries (30%) where the rate is below the
average. Furthermore, the rate for recovery of used oils and spent solvents is relatively low in
comparison to other MS, both being below 50%. Although the Waste Management Plan
includes specifications on HW, the amounts for industrial HW are not included. In addition, no
quantitative targets are set for HW reduction in the Waste Prevention Programme.
IE (overall score of 31) has in general a very good overall score in waste management planning
and prevention; most of the core requirements of the WFD transposed into national laws.
However, the requirements for record keeping (tracking system) of HW do not contain a
reporting obligation to the competent authority. Further, derogations of the HW mixing ban
can be given by EPA; however criteria to further specify in what cases exemptions are possible,
are not defined in the law (scored 0). Concerning the data on HW management, IE has good
results in separate collection of WEEE and in treatment practice of used oils. Collection rate of
batteries, reliance on disposal into/onto land and treatment of acid, alkaline or saline waste
has been scored 1, while recovery rate for spent solvents is below average (score 0). Also,
there are deficits in the existence and quality data reported to Eurostat for HW generation
(scored 0).
UK (overall score of 30) is one of the few countries that has permit exemptions for the
recovery of HW; some recovery operations for WEEE and heating oil in England and Wales do
not require a permit (scored 0). However, UK has also reached the highest score for thirteen
criteria including HW management planning, classification and labelling of HW, the existence
of a national record keeping system, and the mixing ban for HW as well as derogation from it.
The criteria considering inclusion of quantitative targets for HW reduction in waste prevention,
the separate collection rate for WEEE and the missing reporting obligation for HW to the
competent authority were scored with 1. As regards enforcement of HW legislation, UK has
the highest possible performance being scored 2 for each criterion. Low performance has been
assessed in particularly as regards battery collection and for HW treatment options applied for
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HW in general (reliant on disposal operations) and for used oils.
MT (overall score of 29) performs well as regards waste management planning and the
transposition of legal requirements and enforcement (scored 2 for most criteria). A score of 1
was assigned for covering HW in the WPP, for including information on HW classification (but
not providing any additional support on this), for record keeping systems and guidance for
reporting obligations and the system of inspections. As regards collection of WEEE, MT has the
second lowest collection rate (15%); however the collection rate target for
batteries/accumulators for 2016 is nearly fulfilled. As regards treatment, reliance on
depositing operations (when also counting exports) are average (scored 1) as is the recovery
rate for spent solvents and acid, alkaline or saline waste. This is however due to the fact that
MT is heavily relying on export; thus, a judgement on how those wastes are treated could not
be made. Exceptionally, for the treatment of waste oils, a score of 0 has been given, as it could
not be identified what is the fate of this waste stream which is reported under different code
than foreseen in the LoW. HW data reported to Eurostat is survey based and is publically
available in aggregated form in the WMP.
The performance of GR (overall score of 29) is very good as regards the HW management
planning, HW labelling, existence of a national record keeping system, the permit procedures
for HW treatment and the implementation of the mixing ban as well as the enforcement of
HW legislation. Further, following statistical data, Greece is performing well as regards the
applied treatment options for HW in general and the three HW streams under assessment (all
score 2). Greece has, however, no support for HW classification available and there is no
obligation for reporting HW data to the competent authority (both scored 1). The Greek Waste
Prevention Programme is not yet legally adopted; even though a draft is available, it was not
considered due to lack of legal transposition. Deficits were found in the separate collection
rate of WEEE and batteries that is below average. Furthermore, GR scored 0 for exemptions
for HW recovery that may be allowed in permits although the criteria for this are not included
in legislation. Furthermore, HW data is not available to the public as full-digit code data and
data reported to Eurostat originates from different data sources and is based on sample
surveys.
ES (overall score of 29) has an average performance of HW management. Ten out of twenty-
two criteria were scored 2 including enforcement of HW legislation through inspections and
penalties/fines for infringements, HW labelling, permits for HW treatment and the
implementation of the mixing ban. ES received average scoring (score 1) for support of HW
classification, regional record keeping system and HW reporting obligations as well as for most
of the statistical treatment performance. For the treatment applied for spent solvents and
used oils score 2 is applied. Spain has deficits in waste management planning since industrial
HW is not included in the WMP and data reported for HW generation and treatment is based
on surveys (both scored 0). In addition, the separate collection rate for WEEE was low
compared to other Member States (28%).
SE (overall score of 28) attained the highest score possible for the criteria on planning and
prevention, being one of the few countries including quantitative targets. Furthermore, all
criteria on enforcement and separate collection (WEEE and batteries/accumulators) were
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scored 2, as were most of the criteria on legal transposition. However, Sweden has
performance gaps as regards implementing reporting obligations (score 1) and managing a HW
registry (scored 0, and is one of three countries which does not have a register). Sweden
reached a relatively low score mainly because of the HW treatment data reported to Eurostat
with high reliance on disposal onto/into land both including/excluding imports/exports and
because of recovery rates for the three HW streams assessed (score 0) except of waste oils
(score 1). Furthermore, the HW data is based on sample surveys and data is only available to
the public in aggregated form (both scored 0).
NL (overall score of 28) also complies with the legal requirements, being scored 2 for most of
those criteria. However, only average performance was scored as regards data records, the
requirement to keep and store HW data, and reporting obligations for operator (scored 1). The
same is valid for criteria for setting derogations on the mixing ban (scored 0). Further deficits
are assessed in data availability (no data for HW industrial waste, even though more than 80
sector plans exists, data not available to full-digit code to the public). Potential for
improvements is possible, when looking at the Eurostat data as regards collection of WEEE and
reliance on depositing into/onto land (score 1) and as regards applied recovery technologies
for spent solvents and used oils (score 0).
HU (overall score of 28) fully complies with the legal requirements of the WFD and states good
enforcement practice, getting the highest score for all specified categories except for the
criterion on classification (no guidance material available). As regards waste management
planning, HU does not include data on industrial HW in the WMP and no quantitative targets
are specified in WMP. The main reason for a relatively low overall score is the poor quality and
availability of data (survey based data and not publically available) and low performance for
HW treatment, its reliance on landfilling, and the low recovery rate of spent solvents (all
scored 0). While collection rate of WEEE is one of the highest, the rate for
batteries/accumulators is average.
The situation in IT (overall score of 28) scored near average performance. IT shows
considerable improvement potential for the application of treatment technologies moving up
the waste hierarchy (high reliance on landfilling, low recovery rates for spent solvents), waste
data quality and availability, and waste management planning. Italy shows deficits as regards
waste management; the planning is delegated to the regional level, including 21 regional
WMPs and not all of them are updated. Italy scored 2 for twelve criteria including HW
labelling, existence of a national record keeping system and HW reporting obligation,
implementation of the mixing ban and definition of criteria for derogation. In addition,
enforcement of HW legislation is well implemented, inspection capacities and activities
however are declared only very general.
DK (overall score of 28) obtained the highest scoring for twelve criteria in particular as regards
the enforcement of HW legislation, responsibilities for inspections, penalties and fines for
infringements, HW management planning, separate collection rate of WEEE and batteries as
well as compliance with requirements of HW legislation (labelling, record keeping, mixing ban
and its derogation). There are however performance gaps in particular for the depositing rate
of HW onto or into land and for recovery rate (excluding energy recover) for all three particular
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HW streams under assessment. Furthermore, Denmark is one of the three Member States that
has permit exemptions for the recovery of HW in place as no distinction is made in legislation
between hazardous and non-hazardous waste (scored 0).
FR (overall score of 26) scored 2 for ten criteria including the implementation on all legal
requirements on labelling, record keeping, permitting and the mixing ban, all criteria on
enforcement and the availability of HW data to the public. However deficits were identified for
the following criteria (scored 0): France delegates the waste management planning to the
regional level, including 101 regional WMPs; not all of them are updated according to the
official national overview. Furthermore, the WEEE recovery rate is below average. Based on
reported Eurostat data, the recovery rate for spent solvents and used oils is below average.
The reporting is based on administrative information sources and surveys, rather than on real
data (e.g. reported within a registry). The criteria on waste prevention, collection of batteries
and accumulators, reliance on landfill and recovery rate for acid, alkaline or saline waste were
all scored with 1.
CY (overall score of 26) attained the highest scores possible for legal transposition and
enforcement structures. However, no guidance material supporting the correct classification of
HW could be found (scored 1). Furthermore, it seems that CY is one of three countries not
managing a HW registry (scored 0). Potential for improvements are seen in waste
management planning (HW is not included at all in planning) and the WPP (not adopted yet).
Recovery rates of the three HW streams assessed were all scored 2, the collection rates for
WEEE and batteries/accumulators (being 13/14 %) were all scored as 0.
FI (overall score of 26) received good scores for enforcement and legal transposition, except
for record keeping and back-tracking system (both scored 1). FI does not provide data on
hazardous industrial waste in its WMP and does not specify quantitative targets in its WPP.
Data reported to Eurostat is partly based on surveys rather than reported data and data is
available only in aggregated form to the public (scored 0). As regards collection and treatment:
collection rates on WEEE and batteries/ accumulators are average as are the recovery rates for
acid, alkaline and saline waste (all scored 1). Reliance on disposal operations (excluding
incineration) is estimated as being high and the recovery rate for spent solvents is below 40%
(all scored 0).
SI (overall score of 25) attained the highest scores possible for all criteria on legal
transposition on labelling, record keeping, permitting and the mixing ban and all criteria on
enforcement. Additionally, reliance on landfill is low and the recovery rate of acid, alkaline or
saline waste is above 40% (both scored 2). Deficits are found in all other statistical criteria: the
collection rate of batteries and accumulators, being average in EU comparison, and the
reliance on landfills (including exports) were both scored 1. Recovery rate for spent solvents
and used oils have been scored 0. Furthermore, HW data is not available to the public as full-
digit code data and data reported to Eurostat is survey based and the national waste
management planning only includes municipal waste (inclusion of hazardous and other waste
streams is planned for the end of 2015.)
BE (overall score of 23) is the only country where the majority of criteria on legal requirements
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are not scored with 2. This is attributed to Belgium’s federal structure which has three waste
laws (labelling and the mixing ban are regulated on a regional level). As regards planning, three
WMP are in place and all three include specifications on HW (scored 2) but do not include data
on industrial HW (scored 0). Furthermore, the WPP of Wallonia region has not yet been
adopted. As regards HW data: data is partly based on surveys (Wallonia) and data is only
available in aggregated form to the public (all three regions). As regards actual treatment
performance: the WEEE collection rate is average as is the recovery rate for acid, alkaline and
saline waste (both scored 1). A score of 0 was assigned to disposal operations (both
including/excluding import/export) and to the recovery rate of spent solvents. As regards
enforcement, although structures are set and responsibilities declared, the system of
inspection is not clearly specified. In Belgium, problems occur in particular in the region of
Wallonia, where the data basis and planning is poor. This has been confirmed with the
Ministry.
RO (overall score of 21) attained the highest scores possible for nine criteria in particular as
regards the transposition of EU requirements into legislation and reported enforcement
procedures; however no particular inspection capacities are declared. Major implementation
gaps remain as regards waste management planning (no current WMP in place), the
availability of data on hazardous waste (only aggregated statistics, no waste registry in place,
reporting based on survey) and procedures on record keeping and the tracking of waste.
Actual performance as regards WEEE/battery collection and recovery rates of used oils is
below average (all scored 0). Score for the reliance of landfilling of HW however is 2; also
recovery rate for spent solvent is reported to Eurostat as comparably high.
3.4.3 Grouping of Member States
The maximum score possible for the 22 criteria included in the scoring is 44. The highest score
reached by a MS is 38 (AT), the lowest 21 (RO). The average score for the EU-28 MS is 30.
Based on this, the MS can be grouped into two groups:
− Group 1: MS performing at least average or above average, and
− Group 2: MS lying below average.
Following this approach the following 14 MS are assigned to group 1 (average and above average
performance):
AT, DE, PT, PL, LV, HR, EE, BG, LT, LU, SK, CZ, IE and UK. Scoring within this group varies between 30
and 38 points.
Similarities of this group include:
− A WMP is in place including specifications of HW. In most cases, data on industrial HW
streams are specified.
− A WPP is in place including HW at least qualitatively.
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− Legal requirements on classification, labelling, record keeping, permitting and mixing ban are
in general well implemented with few low scorings for the MS; no similarities in the criteria
with low scores.
− Enforcement structures and measures are defined well. In half of these MS, inspection
capacities and procedures are specified in more detail in the WFD implementation report.
Differences in this group include:
− Scoring for the collection rates of WEEE and batteries/accumulators and the treatment of
HW both in general and for the three HW streams assessed vary widely.
− The data basis for Eurostat reporting and the quality and availability of public data scored
vary widely.
14 MS are assigned to group 2 (below average performance):
MT, GR, ES, SE, NL, HU, IT, DK, FR, CY, FI, SI, BE and RO. Scoring within this group varies between 21
and 29 points.
Similarities of this group include:
− The legal requirements on classification, labelling, record keeping, permitting and mixing ban
are in general well implemented with some punctual low scorings.
− The data basis for Eurostat reporting and the quality and availability of public data scored 0
in most of the cases.
− Enforcement structures and measures are defined well. In half of these MS, inspection
capacities and procedures are specified in more detail in the WFD implementation report.
− Most of the Member States of this group show gaps in waste management planning, not
including information on either specifications on HW or industrial HW, or both. Exceptions
are GR, SE and MT which include these types of information.
Differences in this group are:
− The WPP is not in place for five countries of this group.
− The scoring for the collection rates of WEEE and batteries/accumulators and treatment of
HW both in general and for the three HW streams under assessment vary widely.
It has to be noted, that no ‘sharp’ demarcation line can between drawn between the groups. In
general the scoring shows little ‘sharp’ results and little variations. The actual scoring result should
be understood as an indication of results, rather than actual points received by a MS.
3.4.4 Proposal for Member States to be included for in-depth assessment
The proposal for selecting the EU MS for in-depth assessment in the second part of this project is
based on:
− the screening results,
− the significance of the country as regards the amounts of HW produced (chapter 3.3), and
− the problems announced by stakeholders from practice (chapter 0).
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Based on this information we proposed to include the following countries in the second study part:
− RO: received a below average score with considerable gaps compared to other MS;
− BE: received a below average score (mainly because of statistical data and data
quality/availability and federal structure) and is amongst the ten biggest HW producer (8th on
the list); for BE in particular problems occur in the region of Wallonia, where the data basis in
planning is poor;
− SI and/or CY received a below average score and are an example of a smaller EU country (not
producing considerable amounts on HW on EU level (amongst 10 MS with lowest amount);
− FR: produces considerable amounts of HW (3rd on the list) and showed below average
performance of actual treatment technologies and gaps in waste management planning;
− FI and/or SE and/or NL had good implementation of all legal requirements, however received
low scores in actual treatment statistics and data quality/availability and are considerable
producers of HW (NL being 7th, SE 11th and FI 14th on the list);
− MT or GR scored close to average performance and show different problems in HW
management and transposition of law; however they generate lower amounts of HW
compared to other MS (below 1 Mt/year);
− HU or DK scored close to average performance and had in particular low scoring for actual
treatment;
− ES and/or IT both scored near average performance. Both countries show considerable
improvement potential for the application of treatment technologies moving up the waste
hierarchy, HW data quality and availability, and HW management planning. Furthermore, IT
and ES are both producing considerable amounts of HW (IT 6th and ES 9th on the list) and a
list of problems is reported from stakeholders;
− UK has average performance according to scoring, however when looking at actual
treatment performance there is potential for improvement. For UK, a list of potential
problems have been reported by stakeholders mainly stating that state of the art
technologies for recycling are not supported enough, that the UK is still reliant on disposal
operations, and a list of other implementation problems. Furthermore, UK is one of the main
generators of HW (5th on the list).
It should be noted that DK, HU, MT, SE and NL are above the average when excluding the criteria
on HW treatment (criteria 3.4 to 3.8), those being the criteria imposing some uncertainties and
inconsistencies (see Criterion 3.4: Reliance on disposal for HW treated in the Member State).
The final selection was made in close cooperation with the European Commission. The
selection process is described in chapter 4.
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Hazardous waste statistics and selection of 10 EU-MS
4.1 Statistical gap on generation and treatment of hazardous waste
Eurostat data seem to suggest that there is a gap between the amounts of hazardous waste
generated and treated for most of the Member States, as indicated in the following table.
Table 4-1: Differences between hazardous waste generation and treatment within EU-28 (Source: Eurostat, 2012, data as of 25.03.2015)17
MS
Generation
(GEN) t/2012
Eurostat
Treatment
(TRT) t/2012
Eurostat
Export*
(EXP) t/2012
Eurostat est.
Import*
(IMP) t/2012
Eurostat est.
Diference
(GEN - EXP + t / 2012
calculated
(Gap) IMP) – TRT %/2012 calculated
AT 1,065,888 338,860 269,697 125,789 583,121 63%
BE 4,257,755 2,059,944 596,913 508,073 2,108,971 51%
BG 13,407,042 13,389,620 2,083 30,039 45,378 0%
CY 31,288 24,201 4,997 0 2,090 8%
CZ 1,481,281 753,402 10,153 23,243 740,969 50%
DE 21,983,895 21,098,397 334,327 3,077,329 3,628,500 15%
DK 1,192,750 977,663 96,798 245,835 364,124 27%
EE 9,159,139 9,131,275 3,331 17,957 42,490 0%
ES 3,113,947 2,420,583 56,939 290,769 927,194 28%
FI 1,653,942 1,411,308 95,455 20,459 167,638 11%
FR 11,303,137 8,841,003 100,137 228,969 2,590,966 23%
GR 297,370 108,104 21,519 6,133 173,880 62%
HR 122,541 73,404 19,120 0 30,017 29%
HU 700,246 376,811 19,128 0 304,307 45%
IE 1,972,204 69,111 132,069 6,625 1,777,649 96%
IT 9,474,449 3,258,267 237,810 369,251 6,347,624 66%
LT 136,785 70,246 19,220 8,515 55,834 44%
LU 315,082 1,992 0 0 313,090 99%
LV 95,114 41,749 8,424 125,339 170,280 80%
MT 29,326 501 14,308 0 14,517 97%
NL 4,859,942 4,456,188 788,476 870,338 485,616 10%
PL 1,737,024 1,434,985 13,373 78,112 366,778 20%
PT 544,963 193,394 2,760 9,314 358,123 65%
RO 670,590 521,195 0 0 149,395 22%
SE 2,752,657 1,123,393 242,772 208,991 1,595,483 59%
SI 133,334 75,111 54,650 33,762 37,335 33%
SK 370,223 199,393 4,987 10,765 176,608 47%
UK 8,452,496 2,672,513 160,556 75,100 5,694,528 68%
Countries with large gap on reported generated and treated HW
Countries with low/no gap on reported generated and treated HW
*as some amounts in the import/export statistics are provided for a group of hazardous and non-hazardous waste, a slight overestimation might occur.
17 Given the project progress, based on data available at Eurostat as per 25.03.2015 and before clarification requests to the MS. For selected MS later updates are available.
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At European level, the calculated average gap between the amount of hazardous waste generated
and treated is 28% (up to 29 million tonnes).
An EEA18 study prepared in parallel to this study (draft), confirms this: In 2012, the gap between the
amounts of hazardous waste generated and treated was 26 million tonnes (EU wide), equivalent to
about 26% of the total generated amount of hazardous waste.
The EEA draft study tries to map how large the gap between reported and generated/treated
hazardous waste is in the Member States. The document comes to the conclusion that in particular
for chemical wastes, discarded vehicles, used oils and combustion wastes large gaps occur (see figure
below).
Figure 4-1: Differences between HW generation and treatment per waste stream in EU-28 (2012)
Source: [EEA 2015]: Hazardous waste review in the EU-28, Iceland, Norway, Switzerland and Turkey. Generation and
Treatment. Prepared by the ETC/SCP and ETC/WMGE. February 2015, DRAFT NOT PUBLISHED YET, p.30
The uncertainties as detected by the EEA study may have different reasons. In a first step, the
following assumptions have been made (which have subsequently been verified with the selected MS
in a second step):
18 [EEA 2015]: Hazardous waste review in the EU-28, Iceland, Norway, Switzerland and Turkey. Generation and Treatment. Prepared by the ETC/SCP and ETC/WMGE. June 2015, http://scp.eionet.europa.eu/Hazardous%20waste%20review_working%20paper_final.pdf
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− The Member States apply different data collection methodologies (on the waste producer
side compared to waste treatment side). The analysis has shown that for the majority of
Member States statistical data are collected at the side of waste production (waste producer).
Hence, in many cases only the first step of the treatment route is known. In the case this first
step is defined as a 'sorting facility' or an 'other pre-treatment facility' which are not included
in Annex II of the European Waste Statistics Regulation, this may lead to data gaps in reporting
to Eurostat (reason “Annex II”).
− Additionally, a certain amount of hazardous waste is treated in on-site facilities of the waste
producer (in particularly valid for certain industrial wastes). Again, these amounts are often
not recorded and not reported to Eurostat (reason “on-site”).
− Differences between the amount of waste generated and waste treated occur also due to pre-
treatment activities, changing hazardous into non-hazardous waste or reducing the amount of
HW by separation of hazardous from non-hazardous fractions, drying etc.
− A potential amount might be stored temporarily or – what cannot be excluded – also disposed
of illegally.
Taking these limitations into account, the figures visible in the Eurostat statistics refer solely to HW
amounts treated in off-site facilities. As a consequence, the calculations may lead to an over- or
underestimation of the disposal share, in particular for Member States with large waste amounts
treated.
As described in chapter 3.2.3 (Criterion 3.4: Reliance on disposal for HW treated in the Member
State, Statistics Offices have been approached, in order to confirm data or explain inconsistencies.
Answers were provided by 13 MS (some of them including new statistical data). In general, the
assumptions of data uncertainties mentioned above were confirmed. The main topics are
summarised in the following table.
Table 4-2: Summarised answers to verify statistical treatment data (screening phase)
MS Summarised answer
BE Statistics Office Belgium, e-mail dated 3 March, 2015
Reasons for the difference between generation and treatment mentioned:
Data collection methodology Methodological specification due to the specific situation in the three regions (Flanders, Brussels, Wallonia) with the main problem that data from Wallonia are not available at all and thus estimated only based on data for Flanders.
Additional data / information:
No additional data provided.
CZ Statistics Office Czech Republic (CZ), e-mail dated 27 February, 2015
Reasons for the difference between generation and treatment mentioned:
Data collection methodology Main reasons for the difference between generation and treatment are: (i) HW is classified as temporary storage and (ii) imports and exports are not reported.
Data classification
According to the Czech legislation three operations of waste treatment are permissible. Besides recovery (R-codes) and disposal (D-codes) operations, other treatment methods (N-codes) are possible, e.g. N1 for use of waste for landscaping, N11 for use of waste for the deposit
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MS Summarised answer
reclamation or N12 for deposits of waste as technological materials to make landfills safe. (Quality Report 2012, Annex I – Method of waste treatment).
These specific Czech N-codes are not reported to Eurostat.
Additional data / information:
Additional information was given for spent solvents (not recovered in CZ), acid, alkaline and saline waste (recovered but confidential data), used oils (not recovered in CZ).
GR Statistics Office Greece, e-mail dated 16 March, 2015
Reasons for the difference between generation and treatment mentioned:
Data collection methodology As data reporting reasons were mentioned mainly double counting of secondary waste from dismantling WEEE, ELV and used tyres – 3,352 t), exports (22,154 t), temporary storage (assumption: 86,934 t) and finally also different methodological approaches.
Impact of pre-treatment operations Main reason for the difference between generation and treatment is classification as pre-treatment operations leading to a change in classification of the waste from hazardous to non-hazardous (mainly ELV – 76,826 t).
Additional data / information:
Additional data were provided.
HR Croatian Environment Agency, e-mail dated 16 March, 2015
Reasons for the difference between generation and treatment mentioned:
Reporting obligation Main reasons for the difference between generation and treatment are classification as treatment operations excluded from reporting (Annex II).
Data collection methodology Minor shares temporarily stored and not part of the statistics.
Additional data / information
No additional data provided.
HU Statistics Office Hungary, e-mail dated 18 March, 2015
Reasons for the difference between generation and treatment mentioned:
Data collection methodology Main reasons for the difference between generation and treatment are classification as import/export effects and shares temporarily stored.
Impact of pre-treatment operations Changes of hazardous nature during pre-treatment was mentioned as potential reason for the difference between amounts generated and treated.
Additional data / information:
No additional data provided.
IE Statistics Office Ireland, e-mail dated 3 March, 2015
Reasons for the difference between generation and treatment mentioned:
Data collection methodology The difference between generation and treatment is explained through methodological reasons (potential double counting).
Additional data / information:
Additional information provided with reference to the EPA’s National Waste Report for 2012.
LV Statistics Office Latvia, e-mail dated 12 March, 2015
Reasons for the difference between generation and treatment mentioned:
Reporting obligation Main reasons for the difference between generation and treatment is classification as treatment operations excluded from reporting (Annex II) amounting to 14,900 (R12 procedure).
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MS Summarised answer
Data collection methodology Around 61,894 t of hazardous waste are stored on-site.
Additional data / information:
Additional information was given for spent solvents (collected and exported), acid, alkaline and saline waste (collected and exported), used oils (burned and recovered)
Exports in 2012 amounted to 12,279 t (compared to 8,424 published in the import-export statistics by Eurostat; reasons for the difference were not explained).
MT Statistics Office Malta, e-mail dated 13 March, 2015
Reasons for the difference between generation and treatment mentioned:
Reporting obligation Main reasons for the difference between generation and treatment are classification as treatment operations excluded from reporting (Annex II), temporary storage.
Impact of pre-treatment operations Additional reasons are mainly dismantling of discarded vehicles, WEEE and batteries into hazardous parts and non-hazardous parts. Non-hazardous parts, which comprise the bulk of the weight, are recorded under non-hazardous waste exports in the TFS register
Additional data / information:
Additional information was given for spent solvents (export for recovery overseas), acid, alkaline and saline waste (partly exported), used oils (exported for recovery). In the case of waste oils it should be noted that waste oils, bilges and waste fuels that are exported for recovery are classified altogether under LoW code 13 07 03* (Other fuels including mixtures).
PL Central Statistics Office Poland, e-mail dated 17 March, 2015
Reasons for the difference between generation and treatment mentioned:
Reporting obligation Main reasons for the difference between generation and treatment are classification as treatment operations excluded from reporting (Annex II)
Impact of pre-treatment operations Changes following pre-treatment may lead to changes in waste type and classification from hazardous waste to non-hazardous waste.
Additional data / information:
No additional data provided.
PT Statistics Office Portugal, e-mail dated 18 March, 2015
Reasons for the difference between generation and treatment mentioned:
Reporting obligation Main reasons for the difference between generation and treatment are classification as treatment operations excluded from reporting (Annex II) summing up to 351,563 t in 2012 and referring to treatment and disposal operations D8+D9, D11+D13+D14+D15 and R12+R13.
Additional data / information
Additional data provided on the amount excluded from reporting to Eurostat.
SE Swedish Environmental Agency, e-mail dated 13 March, 2015
Reasons for the difference between generation and treatment mentioned:
Data collection methodology One of the problems is that different methods are used to estimate generated and treated waste in Sweden. Reasons for the difference between generated and treated waste amounts are that the resulting waste volumes may be overestimated, and that HW is exported abroad for treatment. In addition, not all HW are transported to a waste treatment facility. Also some amounts might not have been recorded when treated on-site.
Additional data / information:
Additional information was provided to the report “Avfall i Sverige 2012”
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MS Summarised answer
SI Statistics Office Slovenia, e-mail dated 17 March, 2015
Reasons for the difference between generation and treatment mentioned:
Data reporting Main reasons for the difference between generation and treatment is classification as temporary storage. The amount was classified with 4,759 t.
Additional data / information:
Additional information provided on exported amounts of spent solvents, acid, alkaline or saline waste and used oils
SK Statistics Office Slovakia, e-mail dated 16 March, 2015
Reasons for the difference between generation and treatment mentioned:
Main reasons for the difference between generation and treatment are classification as treatment operations excluded from reporting (Annex II) summing up to 170,831 t for the operations D8, D9, D15, R12 and R13. The total amount treated thus refers to the total amount generated.
4.2 Selection of 10 EU-MS for in-depth analysis
As described in chapter 3.4, the results of the screening exercise showed that there are indeed
differences in the level of implementation of the hazardous waste requirements of the WFD by
Member States. However, the results did not allow selecting ten Member States on the basis of
“low” performance meaning that there is no ‘sharp’ demarcation line between the groups of “good”
performers and the group of countries having implementation gaps. Furthermore, the most worrying
finding of the screening exercise was that there is a large gap between HW generation and treatment
as reported under Eurostat and that national waste data in many cases differ to the Eurostat data.
In this context, it was considered that the clarification of the gap called for further analysis and
explanation and was opportune to use this ongoing study for further investigation.
Therefore the ten countries that were selected for the in-depth assessment were:
Five countries with the biggest gaps between reported generated and treated HW (Eurostat data):
Luxembourg (gap estimated as 99%)
Ireland (gap estimated as 96%)
Latvia (gap estimated as 80%)
Italy (gap estimated as 66%)
United Kingdom (gap estimated as 68%)
Five countries with the smallest gap between reported generated and treated HW (Eurostat data):
Estonia (gap estimated as 0%)
Bulgaria (gap estimated as 0%)
Netherlands (gap estimated as 10%)
Finland (gap estimated as 11%)
Germany (gap estimated as 15%)
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In addition to the in-depth analysis of particular problems with HW management in these ten EU
Member States, the second phase of the project focused on the identification and analysis of good
and bad practices in the 10 MS, with clear overall recommendations for improvement.
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In-depth analysis for 10 selected EU-MS
5.1 Method for in-depth analysis of 10 EU-MS
Based on the information collected in the screening phase of the project, the following issues
seemed of particular importance:
1. To make a thorough assessment of the countries' hazardous management practices and
analyse their specific problems in fulfilling the objectives and provisions of the Waste
Framework Directive as regards hazardous waste;
2. In particular, a detailed assessment of the measures for HW collection and storage is
necessary, which would include checking further guidelines, working instructions and
assessing the actual practice (e.g. through interviews). The assessment shall cover the entire
geographic territory of each Member State;
3. To analyse and explain what are the reasons for the gap between the generation and
treatment of HW. For Estonia (EE) and Bulgaria (BG), where the statistical gap is 0%, a
comprehensive analysis of their actual HW management practices shall be made, considering
that they generate high levels of HW and disposal is almost exclusively on landfills;
4. To identify the problems of HW management;
5. To identify good practices;
6. To make proposals and recommendations: general recommendations for all Member States
and particular for the selected Member States.
Finally, a clear overall conclusion on HW management practices (rather than country specific
roadmaps) should be presented and actions to undertake in order to improve should be identified.
The analysis for the ten Member States is based on expert interviews and additional desk research.
Interviews with relevant stakeholders:
The first step in this process was to identify relevant stakeholders. Interviews, in person, by
telephone or by e-mail have been conducted with the stakeholders identified. The aims of the
interviews were to collect more information, to assess the quality of already collected information
(via desk research, summarised in the draft factsheet) and to obtain additional information.
In most cases, a draft version of the factsheet has been provided to the interviewee before the
interview, together with a list of information requested. The interviews were not formally
structured, but lead by the demand for data and information in the given case.
As part of the screening phase, one document for each Member State has been prepared including
the information collected while preparing the screening report (‘screening information‘). This
document served as basis for the elaboration of the more detailed ‘factsheet’ for the ten selected
MS.
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The purpose of the study was also to present the different views on the issue of HW management in
a Member state, including those of:
authorities of different administrative levels; e.g. authorities for registration, permitting,
data collection and follow up, enforcement and inspections usually the Ministries of
Environment, Environmental Agencies, Environmental Board, Inspectorates of
national/federal state level;
authorities involved in data collection and reporting, i.e. national statistical offices;
practitioners involved in HW management, i.e. large companies or waste associations
representing the companies;
institutes and institutions involved in HW management, e.g. by providing guidelines and
standards.
About five to ten extensive interviews have been realised per country, including several reviewing
phases of the factsheet. For some MS (in particular Luxembourg where only very few stakeholders
are involved in the HW management), less interviews have been conducted.
A complete list of the interviews realised in the MS, including the name of institutions and contacts is
included in Annex III/chapter 10.3.
Desk research
The expert interviews have been complemented by further desk research at national level, including
documents either provided by the interviewed experts or collected via additional search (official
websites, guidance, etc.). The desk search included:
Follow-up on information collected during screening phase (i.e. criteria with discrepancies)
literature, further studies on HW (e.g. major HW streams, amounts, treatment applied,
reports about exports…) and statistical data if available.
Identify data and information gaps focusing on 1) waste generation and treatment in the
country and 2) obligation/practice of HW collection and storage.
The primary sources for the desk research include websites and data basis from administrative
bodies and statistical offices.
5.2 Hazardous waste management practice in 10 EU-MS
5.2.1 Summary of HW management in Bulgaria
The amount of generated HW in Bulgaria (BG) in 2012 is reported as 13,407 kt in absolute terms and
1,830 kg/cap in relative terms. Excluding HW from the mining sector, the numbers are approximately
159 kt and 22 kg/cap respectively. Waste streams from the mining sector account for 99% of the
total generation. This explains the fact that the HW generation per inhabitant is approximately eight-
times higher than the EU average (200 kg/inhabitant). The major share of other HW generated stems
from thermal processes, waste from surface chemical treatment and coating and industrial sludges.
The amount of HW treated in Bulgaria in 2012 is reported as approximately 13,390 kt in absolute
terms. Based on the aforementioned statistics on HW generation and treatment, a 0% statistical gap
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between HW generation and treatment was calculated for Bulgaria. Τhe reason for the non-existent
statistical gap is the high share of the mining waste stream on the total HW generation. By
excluding mineral wastes and consulting the national statistics, we reached the conclusion that there
is a gap of 63% between HW generation and treatment. A detailed explanation and critical analysis
of this statistical gap is provided in chapter 5.3.1.
In general, requirements from the WFD on HW are implemented in national law including:
− Waste classification is performed according to regulations without problems.
− HW labelling is done in accordance with the EU requirements.
− Persons carrying out operations with HW provide consignment notes and annual reports to
the Executive Environment Agency (ExEA). Currently, record keeping is done based on a
paper system, but it is planned to establish an electronic information system that will be
operational on February 2016. It is anticipated that data quality will be improved.
− The procedure of issuing a permit for carrying out waste management operations is laid
down in the Waste Management Act. Regional Inspectorates of Environment and Water
(RIEW) control the compliance with the waste treatment requirements and the
implementation of conditions as laid down in the permits.
− The mixing ban of HW with other waste is implemented and any derogations in practice are
mentioned in the respective IPPC permit.
− In general, collection and storage are performed according to legislation. Guidance on these,
including ADR transportation, can be provided by the HW collection companies.
− Site inspections are performed at least annually, including inspections of HW management
practices. A more regular and strict inspection on waste generation sites would contribute
to the compliance with requirements and enforcement of legislation.
In general, authority representatives do not see major problems in HW management in Bulgaria.
However there are some particular challenges, e.g. in the fields of elaborating a dedicated strategy
for HW, the reduction of the mining waste stream, and improvement of data control.
All detailed information and information sources are included in the factsheet for Bulgaria.
5.2.2 Summary of HW management in Estonia
The amount of generated HW in Estonia (EE) in 2012 is reported as 9,159 kt in absolute terms and
6,911 kg/cap in relative terms. This high amount is mainly due to HW from oil-shale sector (the oil-
shale processing sector accounts for some 85% of Estonia's total electricity production and the
country is the largest oil-shale producer in the EU). Excluding HW from oil-shale sector the numbers
are approximately 233 kt and 174 kg/cap respectively.
Waste streams from the oil-shale processing sector (mainly oil shale ash and semi-coke) are
therefore unique for Estonia and account for more than 95% of the total generation. This explains
the fact that the average generation exceeds significantly the EU average. The major share of the
remaining generated HW regard cement clinker dust, oily waste, and soil polluted with hazardous
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substances. The amount of treated HW in Estonia in 2012 is reported as approximately 9,131 kt in
absolute terms.
Based on the aforementioned statistics on HW generation and treatment, a 0% statistical gap was
calculated. Τhe reason for this is the high level electronic reporting system used in Estonia. A
detailed explanation of this statistical gap is provided in chapter 5.3.2.
In general, requirements from the WFD are implemented in national law including the following key
features:
− Estonian classification system follows the LoW coding system with the addition of eight digit
coding for a few types of waste (e.g. for metal types, WEEE, and ELV) and additional codes for
oil shale wastes. A guidance document (from 2006) is available; Environmental Board or
Inspectorate provides support on request.
− Labelling is well implemented; no problems are reported. Labelling is checked during on-site
inspections.
− As regards record keeping: There are three reporting instruments: (i) The waste reporting
system (WDMS) is part of the Environmental Register and is the management system for data
from waste reports. Wide access is given to authorities to introduce, verify and use data. In
addition there is (ii) an Environmental Permit Information, Consignment Note Database and
(iii) an annual report database. The latter two will be linked to each other in near future.
− Permits are granted by the Environmental Board. There are two types of permit - permit for
HW management (‘license’) and standard environmental permit.
− The mixing of HW with other HW or any other substances or materials is permitted if
account is taken of best available technology (BAT). No cases are known for mixing with the
purpose of re-classification.
− Collection companies have to be authorised by public authorities and need to have a
responsible person for waste handling, who has to prove expertise and knowledge on HW
handling.
− During inspection, storage containers and packaging, as well as correct labelling (not only
before transportation) are checked; it is also controlled if the personnel is adequately
informed.
− Inspections are based on an inspection plan based on risk analysis. Usually, annual inspections
are performed.
Authority representatives do not see major problems in HW management in Estonia. However,
there are some particular challenges, e.g. in the field of i) establishing clear and measurable goals
and target levels for HW, so as to increase recovery and reduce disposal, ii) further investigate
options for HW management from oil shale production, iii) increase collection of asbestos and waste
oil.
All detailed information and information sources are included in the factsheet for Estonia.
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5.2.3 Summary of HW management in Finland
Reported HW data for Finland (FI) amounts to generated HW in 2012 of 1,654 kt in absolute terms,
referring to 306 kg/cap in relative terms. The main fractions of HW generated are mineral waste,
both from construction and demolition and other sources, and acid, alkaline or saline wastes,
together representing approximately 70% of total HW generated. In Finland the treated amount of
HW in 2012 is reported to be 1,411 kt in absolute terms. Data published by the Finland Statistics
Office for 2012 indicates 1,042 kt of HW generated which is a large difference to Eurostat data (612
kt). The data reported by Statistics Finland for HW treatment amounts to 1,361 kt and only differs
slightly from data published by Eurostat.
Based on the statistical data published by Eurostat for HW generation (1,654 kt) and treatment
within Finland (1,411 kt) there remains a statistical gap of 168 kt (11%) which is considered to be
comparably low. Reasons for the statistical gap can be explained by methodological reasons of
double counting and excluding pre-treatment facilities from reporting obligation to Eurostat, and loss
of hazardous status during intermediate treatment. A detailed explanation and critical analysis of this
statistical gap is provided in chapter 5.3.3.
Finland has implemented all requirements from the WFD into national law, as follows:
− Classification procedures are in accordance to European law, several guidelines and a
helpdesk are established. Guidelines have been updated to meet Commission Regulation
1357/2014.
− Labelling is in accordance with international and EU standards (CLP). Guidelines are provided.
− Records have to be kept for 6 years and transmitted to permitting authority (Centres for
Economic Development, Transport and the Environment (ELY) or municipality).
− Permits are given by ELY centres or municipality and checked individually.
− A mixing ban is in place. Derogations for special activities are given if they are in accordance
with best available technology (BAT).
− Collectors have to make a notification to the waste management register that is kept by the
local environmental authorities. There is a publicly available web-based overview of collection
points for municipal HW.
− All facilities that treat HW professionally or on industrial scale need an environmental permit
in Finland. This includes waste storage (if defined as operations R13 and D15).
− Inspections are carried out by ELY centres. According to type of facility on-site inspection is
carried out every year to every four years.
Industry and authority representatives see particular challenges in HW management in Finland:
− Improvement of record keeping and data analysis is required since only companies with a
permit have a reporting obligation to competent authority. Data on HW generation and
treatment are still mainly survey based.
− Clear definitions of test methods to be used in waste classification are required to avoid
misleading interpretations.
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− High rate for depositing HW onto or into land mainly for hazardous mineral waste and
hazardous household waste is seen critical.
All detailed information and information sources are included in the factsheet for Finland.
5.2.4 Summary of HW management in Germany
The amount of generated HW in Germany (DE) in 2012 is reported as approximately 21,984 kt in
absolute terms and 274 kg/cap in relative terms. The major share of generated HW thereby can be
allocated to construction and demolition waste (wherein bituminous mixtures containing coal tar
hold a major share), chemical wastes and waste from waste treatment facilities. The amount of
treated HW in Germany in 2012 is reported as approximately 21,098 kt in absolute terms.
Based on the aforementioned statistics on HW generation and treatment, a statistical gap of
approximately 3,683 kt (15%) can be calculated. Reasons for the statistical gap are that 1) Eurostat
statistics on HW generation contain exported amounts but no imported amounts, whereas HW
treatment contains imported amounts but no exported amounts and Eurostat statistics on HW
treatment do not contain certain recovery/disposal operations (e.g. R 12, R13, D8, D9, D11, see also
requirements from Annex II to the Waste Statistics Regulation). A detailed explanation and critical
analysis of this statistical gap is provided in chapter 5.3.4.
Main responsibilities are within the regions (‘Länder’ / federal states). In general, all requirements
from the WFD are implemented in national law including the following:
− Classification of waste as ‘hazardous’ takes place in Germany on the basis of the Federal Waste
Catalogue Ordinance. Guidance and support is provided.
− Specifications of labelling are included in laws, ordinances and technical rules which are well
implemented and used.
− Record keeping is done via a central electronically based waste registry coordinated on behalf of
the Federal States by the Central Coordination Point Waste. Back-tracking of all steps of HW is
ensured through a complex procedure of keeping records (‘Nachweisverfahren’).
− Permits for HW facilities are granted based on Federal Imission Control Act; no exemptions from
permits are made for treatment operations.
− The mixing ban is implemented and controlled within the ex-ante controls (prior to permitting; is
part of permit granting conditions) and by regular site-visits during operation period. Exemptions
are based on criteria set by German government; however this option has not been used.
− Collection of waste needs to be permitted; the commercial collection of HW from households
thereby is forbidden.
− Requirements for the entrance areas of storage points, laid down in guidelines from authorities
have proven to be effective and are generally well implemented.
− The responsibility for inspections is determined at Länder level. The administrative capacity for
inspection issues has been decisively increased in the last few years. Controls for facilities covered
by the Industrial Emissions Directive (IED) are performed 1-3 times per year. Waste transports are
controlled multiple times per year. Additionally regular and case specific controls are conducted.
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Industry and authority representatives do not see major problems in HW management in Germany,
however there are some particular challenges, e.g. in the field of classification (‘overusage’ of certain
entries from LoW chapter 19), record keeping system (‘tracking possibilities for Federal State
authorities), permits (‘old permits’ and missing traceability), mixing ban (criteria for derogations) and
inspections (inspection capacity and publication of the results).
All detailed information and information sources are included in the factsheet for Germany.
5.2.5 Summary of HW management in Ireland
The amount of generated HW in Ireland (IE) in 2012 is reported as 1,972 kt in absolute terms and
430 kg/cap in relative terms according to data reported to Eurostat. It has to be noted that amounts
reported to Eurostat differ significantly from national HW statistics due to a reporting mistake.
Based on national statistics for 2012 the actual amounts are 283.5 kt in absolute terms and 61.9
kg/cap being approximately six-times lower than Eurostat data. The major shares of HW generated
can be allocated to the following categories: spent solvents (31%), oil waste (mineral oil) (13%) and
equipment (electrical, electronic, mechanical) (8%). The amount of treated HW in Ireland in 2012
according to national statistics is 130 kt compared to 69 kt reported to Eurostat in absolute terms.
Based on Eurostat statistics on HW generation and treatment, a statistical gap of approximately
1,832 to 1,847 kt (93-94%) can be calculated which is considered to be very high compared to other
EU Member States. Reasons for the statistical gap are as aforementioned reporting mistakes to
Eurostat where kg amounts were reported as tonnes. If the statistical gap is recalculated based on
data from national statistics the result for the statistical gap is 16,1 kt (5.7%). This amount is
considered as comparably low. A detailed explanation and critical analysis of this statistical gap is
provided in chapter 5.3.5.
HW management is mostly under national responsibility, the only exceptions are permits for small
scale and low risk facilities that can be issued by local authorities and inspections for which waste
enforcement teams are established in each region. In general, most requirements from the WFD are
implemented in national law including the following specific requirements:
− The EU waste classification system is adopted and the EPA has published extensive guidance,
developed a tool and worksheets to facilitate understanding of the LoW.
− Specifications of labelling are included in laws which are well implemented. In general the
responsibility for the labelling of HW obliges the holder of the material.
− An electronic record keeping system for every HW movement is established in Ireland. The Waste
Regulation Management System is operated and managed by the National TransFrontier Shipments
Office. The tracking system uses Waste Transfer Forms that make every HW shipment or transfer
traceable.
− Everyone involved in HW management needs a permit. The National Waste Collection Permit
Office keeps record and grants all permits for waste collectors, and an electronic register is
publically available.
− The mixing of HW can only be conducted if granted by the EPA. Very strict rules and criteria are
defined and imposed, but no criteria for derogation are defined in law.
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− Based on national legislation any person who proposes to collect waste (including HW) for the
purposes of reward is required to hold a Waste Collection Permit.
− The EPA grants permits for HW storage they do impose certain conditions, in general all HW
treatment facilities also have a permit for HW storage.
− As aforementioned, local authorities are in charge of conducting inspections; all information on
inspections performed is included in the regional WMPs. The EPA requires minimum criteria for
inspections and a number of inspections that have to be performed.
According to industry and authorities representatives no major problems in HW management occur
in Ireland. Nevertheless, there are some minor problems regarding collection of HW stemming from
households and farms, this is mainly a problem of collection coverage. Another minor problem is
related to the different labelling obligations under the WSR and the ADR where it is not always clear
to HW holders which label is correct.
All detailed information and information sources are included in the Ireland factsheet.
5.2.6 Summary of HW management in Italy
The amount of generated HW in Italy (IT) in 2012 is reported as approximately 9,400 kt in absolute
terms and 160 kg/cap in relative terms. There are significant regional differences and production
takes place mainly in North Italy. Italy belongs to the top five EU MS in HW generation. The major
waste streams produced are chemical wastes, mineral wastes from waste treatment and stabilised
waste and industrial effluent sludge, accounting together for 44% of total amount generated. This is
in line with national data.
There is a significant statistical data gap between HW generation and treatment data published by
Eurostat (7,344 kt generated vs. 3,258 kt treated). The main reason identified is the reporting
obligation (excluding several disposal operations in reporting). Other sources of variation are the
statistics on import and export, based on Basel-Y-code classification. However, between the HW
generation and treatment amounts remains a statistical gap, which could not be clarified and thus
leaving room for uncertainties regarding HW storage. A detailed explanation and critical analysis of
this statistical gap is provided in chapter 5.3.6.
HW management is under the responsibility of the regions. EU HW related legislation is in general
translated into national legislation. The key requirements are implemented as follows:
− EU legislation was implemented into national legislation in general. Responsibilities are mainly
with the regions. Waste management planning is partly outdated.
− Classification procedures are established by Article 184 of the Consolidated Act on the
Environment. However, there seems to be uncertainty about which laws to follow (Law 28 of 2012
vs. Annex VI of Directive 67/548/EC). There are no guidelines / helpdesks or other (see
chapter 5.4.4).
− No helpdesks / guidelines or other support measures exist as regards correct labelling. Common
practice is using the United Kingdom guidelines WM3 (see [UK EA HW 2015]).
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− As regards record keeping procedures: Records are sent to Italy's Institute for Environmental
Protection and Research (ISPRA), which performs necessary checks. However, there are
complications in the implementation of the new electronic SISTRI record system.
− Permits are granted by ISPRA after an application at the competent regional authority. Permitting
procedures take between four and six years.
− The mixing of HW with other substances is forbidden. Derogations are granted on the basis of
special activities (R12, ...). Mixing has to be conform with BAT.
− Collection companies have to be authorised by public authorities and are included on specific list
(‘Albo gestori ambientali’).
− Storage can take place for three months at generator, if substances are separated by LoW code.
Other operators can store if they have the proper permissions. Storage is not very common in Italy.
− On-site inspections are mostly occasional; document controls are more frequent. Collection is
controlled by more than five responsible authorities. Most penalties are given out for erroneous
filling out of documents.
The technical status of most of HW treatment facilities is up to date.
Still, there remain considerable differences between the regions. Potential for improvement still
exists for the practical implementation: some of the regional waste plans are outdated, the
advanced concept of the record keeping system SISTRI is still faced with technical teething troubles,
and stakeholders complain a lack of support and communication by competent authorities and long
waiting times for permits. Challenges remain with HW treatment, as the majority (69%) of the
treated amounts is still landfilled. Additionally there is a lack of clear regulation and implementation
of the acceptance criteria for depositing HW.
All detailed information and information sources are included in the Italy factsheet.
5.2.7 Summary of HW management in Latvia
The amount of generated HW in Latvia (LV) in 2012 is reported as 95 kt in absolute terms and 47
kg/cap in relative terms according to Eurostat, the reported amounts seem to be low. The major HW
streams generated included: i) 10 02 07* solid wastes from gas treatment, ii) 17 05 03*
contaminated soil, iii) 16 07 08* wastes containing oil, iv) 13 04 and 13 05 bilge oils and oily water [LV
MoEPRDb 2015].
Based on the aforementioned statistics on HW generation and treatment, a 48% statistical gap was
calculated for Latvia. According to national statistics the statistical gap amounts to 43%. Τhe reason
for the statistical gap was explained by the competent authority due to i) pre-treatment of HW
leading to different classification, ii) temporary storage of HW at enterprises and iii) missing reports
from some HW recovery companies. A detailed explanation and critical analysis of this statistical gap
is provided in chapter 5.3.7.
In general, requirements from the WFD are implemented in national law. The main provisions are
transposed as follows:
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− The Latvian classification system follows the LoW coding system. Guidance is available on the
website of LEGMC and can be also provided by other competent authorities upon request.
Some difficulties can be encountered with mirror codes.
− Labelling is well implemented, guidance can be provided by authorities upon request, as well
as from the waste collection companies.
− An electronic record keeping system is in place in Latvia, covering all steps from generation
to final treatment. Although the electronic system is easy to operate and practical, especially
compared to paper forms, its functionality could be improved.
− Permits are granted by the State Environmental Service (SES). There are permits for i) A and B
category polluting activities, and ii) collection, transportation, transfer, sorting or storage of
waste (both publicly available on the SES website)
− The mixing ban of HW with other waste is implemented and no derogation from it is
provided.
− Requirements for collection and storage of HW are set in the permit. In terms of in case of
hazardous medical waste the State Environmental Service and Health Inspection is
responsible for controls on proper collection and storage.
− Site Inspections are performed at least annually, including HW management practices. A
more regular and strict inspection of waste generation sites would contribute to compliance
enforcement.
Authority representatives do not see major problems in HW management in Latvia. However there
are some particular challenges, e.g. in the field of i) establishing clear and measurable goals and
target levels for HW in the NWMP, so as to increase recovery and reduce disposal, ii) improve data
collection, iii) Focus on waste oils and contaminated C&D waste streams.
All detailed information and information sources are included in the Latvia factsheet.
5.2.8 Summary of HW management in Luxembourg
The amount of generated HW in Luxembourg (LU) in 2012 is reported as approximately 315 kt in
absolute terms and 600 kg/cap in relative terms. This amount per capita is very high compared to
other EU Member States (200 kg per inhabitant). This amount of HW per inhabitant can be explained
by the rehabilitation of a large contaminated site. The major share of generated HW thereby can be
allocated to contaminated soils (51%), combustion waste (14%) and wood waste (12%).
The amount of treated HW in Luxembourg in 2012 is reported as approximately 2 kt in absolute
terms. [Eurostat WASTRT 2012]. As data indicates almost no HW treatment takes place in
Luxembourg due to the too low amounts of HW produced to operate a HW treatment facility. HW
treated in Luxembourg undergoes the following treatment operations: recovery other than energy
recovery – except backfilling, incineration/disposal (D10) and incineration/energy recovery (R10). A
detailed explanation and critical analysis of this statistical gap is provided in chapter 5.3.8.
In Luxembourg all requirements stemming from the WFD regarding HW are implemented in national
law as follows:
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− Classification of waste as ‘hazardous’ in Luxembourg is done based on the European LoW.
Certain wastes can be regarded as hazardous by the competent authority even if they are not
according to the LoW. Guidance and support is provided by the competent authority including
sample testing
− Labelling requirements are in line with European legislation. Correct labelling is controlled by
the authority.
− Record keeping is done via a waste register that has to be kept by HW producers on paper.
This system is currently being changed into a mandatory electronic system –from 2017 on-
that will allow online reporting. Companies involved in HW collection, treatment and storage
have to report annually HW data.
− Permits for HW facilities involved at any stage of HW management are required. Depending
on risk and type of operation different permits are required.
− Derogations from the mixing ban are included in the national legislation if certain criteria
(e.g. BAT), however in practice no cases of mixing HW are currently allowed.
− The collection of HW underlies a permit obligation. A daily updated online database is
available where all collection permits according to LoW codes can be searched.
− Luxembourg only has 2 storing facilities. Temporary storage in small companies has well
improved in the last years due to the support provided.
− Periodic inspections are conducted by the competent authority for HW treatment operations,
collection and transport of HW, production of HW. New requirements for inspections have
been implemented recently introducing an integrated system for HW management
enforcement. Information on inspections and results is publicly available.
All detailed information and information sources are included in the Luxembourg factsheet.
5.2.9 Summary of HW management in the Netherlands
In the Netherlands (NL), the amount of generated HW in 2012 is reported as approximately 4,860 kt
in absolute terms (approximately 290 kg/cap in relative terms). Compared to other EU Member
States the Netherlands has a high HW generation in absolute and relative terms, since the average in
the EU is of 200 kg/cap. Most of the HW was produced in the construction sector with 2,557 kt
(53%), followed by waste water and waste treatment (12%) and services (11%).
The three biggest HW streams in 2012 amount together to 64% of the total amount of HW
generated, these streams are mineral waste from construction and demolition (1,369 kt), chemical
waste (1,151 kt) and dredging spoils (585 kt). The Netherlands have high treatment capacities;
therefore in 2012 a total of 4,456 kt of HW was treated within the country, which amounts to 92% of
the amount of HW generated in the same year.
Based on these statistics on HW generation (4,860 kt) and treatment (4,456 kt) as well as amounts of
HW exported (788 kt) and imported (870 kt) in 2012, a statistical gap of approximately 10% can be
calculated, which is considered to be comparably low. Possible reasons for the data gap could be 1)
difference between data reported to Eurostat and data publicly available and 2) immanent reasons,
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e.g. wet vs. dry, loss of weight by pre-treatment activities (drying), other codification used for
treatment technologies, on-site treatments etc. However, a final clarification from competent
authorities was not possible. A detailed explanation and critical analysis of this statistical gap is
provided in chapter 5.3.9.
HW management in the Netherlands is under national responsibility. The key requirements of the
HW related European legislation are implemented as follows:
− Classification is in accordance to European law, several guidelines and helpdesk are provided.
− The HW generator has the obligation to label the waste, hazardous as well as non-hazardous waste
and to fill out the Material Safety Data Sheet (MSDS), also called Veiligheidsinformatieblad. The
Dutch Waste Management Association has published labelling templates for 24 substances on
their website.
− The Netherlands has in place a central national electronic tracking system (Landelijk Meldpunt
Afvalstoffen) for reporting HW transports by companies and waste collectors. But there is no
reporting obligation to competent authority and the electronic register does not cover all steps of
HW management.
− Permits are granted for collectors, transporters, dealers and brokers of waste by the National and
International Road Transport Organisation (NIWO). The list of permits can be accessed online (VIHB
list). The Human Environment and Transport Inspectorate grants licenses for the collection of used
oils and minor HW, such as laboratory chemicals. Permits for landfills and other HW treatment
facilities need to contain an evaluation of the BAT.
− Netherlands has implemented the mixing ban of HW. Derogations for special activities are given if
they are in accordance with BAT. In general mixing is regarded as treatment (R12 or D13) and
necessary environmental permits are required.
− Collection and transport of HW can only be carried out by companies having a specific VIHB permit
that is granted by the NIWO. Controls of permits are infrequent and only conducted every 5 years.
− Storage guidelines for hazardous substances have been published by the ministry.
− Inspection is carried out by the Human Environment and Transport Inspectorate (ILT),
together with enforcing bodies such as the police. ILT carries out inspections on
transport. The enforcement on storage lies in the hands of provinces. Inspections are
carried out on a regular basis and planned both on-site visits and document controls are
performed. Companies in line with legal requirements and having a management quality
system are controlled less frequently.
All detailed information and information sources are included in the Netherlands factsheet.
5.2.10 Summary of HW management in the United Kingdom
The amount of generated HW in the UK in 2012 is reported as approximately 8,452 kt in absolute
terms and 133 kg/cap in relative terms. These figures have been updated in July 2015 due to a recent
revision of figures from Wales. The current amount of HW generation is reported to be 7,631 kt (120
kg/cap). The major share of generated HW thereby can be allocated to discarded vehicles, chemical
wastes and combustion wastes. The amount of treated HW in the UK in 2012 is reported as
approximately 2,673 kt in absolute terms.
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Based on the aforementioned statistics on HW generation (8,452 kt) and treatment (2,673 kt), a
statistical gap of approximately 5,682 kt (67%) can be calculated which is considered to be
comparably high. Reasons for the statistical gap are that Eurostat statistics contain ‘secondary’ waste
which is double counted and thus is excluded in the UK’s official statistics which reports 5,931 kt as
generated HW. Additional evidence exists that at least 1,620 kt of HW lost its hazardous status during
intermediate treatment (i.e. after capture by generation template but before capture by the
treatment template). The reasons for the remaining gap of approximately 1,535 kt to 1,541 kt
(~26%) cannot be explained definitely as waste generation and final treatment are measured in
different ways which may lead to discrepancies. A detailed explanation and critical analysis of this
statistical gap is provided in chapter 5.3.10.
Main responsibilities are with the UK Competent Authorities (Environment Agency in England,
Natural Resources Wales, Scottish Environmental Protection Agency and Northern Ireland
Environment Agency). In general, all requirements from the WFD are implemented in national law
including the following:
− Classification of waste as ‘hazardous’ takes place in the UK on the basis of the List of
Waste Regulations 2005. Guidance and support is well provided. Particular issues
regarding misclassifications exist.
− Specifications of labelling are well implemented and used.
− Record keeping is based on a system where waste operators have to submit quarterly
reports to the authorities. Movements of waste are tracked by using a consignment note
system.
− HW treatment facilities and other operators need an environmental permit. Also waste
producers (producing over 500 kg of hazardous waste) have to register their premises.
The registration system currently shall be aligned with the reporting system. Exemptions
from permitting, e.g. for small waste oils burners exist and are discussed critically.
− The mixing ban is implemented and controlled within the ex-ante controls (prior to
permitting; permit conditions) and by regular site-visits during operation period.
− Collection and storage of waste needs to be permitted. Sufficient guidance exists.
− The responsibility for inspections relies with the UK Competent Authorities (Environment
Agency in England, Natural Resources Wales, Scottish Environmental Protection Agency
and Northern Ireland Environment Agency). Inspections are conducted regularly based
on the environmental risk of the permitted site according the OPRA system
(‘Environmental Permitting Regulations Operational Risk Appraisal’).
Industry and authority representatives see particular challenges in HW management in the UK:
− Difficulties appear in classification of waste. However, it is discussed if these
classifications occur on a case-by-case basis due to the complex system or if these are a
systematic and deliberate issue.
− Additionally, enforcing the waste hierarchy is considered. An especially contentious
issue is how to prioritise reuse and recycling operations over other recovery operations
which although lower down the hierarchy but are legal options.
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− The integration of the registration duties for premises of HW producers and the
reporting duties for waste movements is seen critical by industry as the traceability of
HW management might worsen.
− The exemption of small waste oil burners from national permitting procedures is seen
critical by industry and was already addressed by the European Commission.
All detailed information and information sources are included in the UK factsheet.
5.3 Particular issues with statistical data
In several EU Member States, there is obviously a discrepancy
either between reported Eurostat data and national statistics as regards HW generation and
treatment, or/and
between data of the reported HW generation and treatment (in Eurostat or/and national
statistics).
Partly, the investigation in the ten selected Member States focused on these statistical discrepancies.
To this end, national statistics have been collected and were compared to Eurostat statistics in order
to investigate if there are differences in data and what are the possible reasons for those differences.
The analysis also follows the question if occurring gaps between HW generation and treatment data
(meaning that reporting treatment data is lower than the reported HW generation) can be fully
explained or if the gap or part of it cannot be explained (with the consequence that e.g. not all HW
generated is correctly treated or treatment has not been reported). Further, it has been assessed on
what information the statistics is based on (e.g. register, reporting obligations, estimations …) and
thus how reliable data basis might be.
The situation in the ten analysed Member States can be summarised as follows:
− For Bulgaria and Estonia there was no relevant gap between HW generation and treatment
under Eurostat (gap = 0%). In the case of Estonia the reporting system − high level electronic
reporting with full description of waste shipments and LoW codes that are linked and
transformed automatically to Eurostat codes − is considered as providing highly reliable
datasets. HW generation and treatment data match quite well, also for national statistic. In
the case of Bulgaria the high amount of mineral waste accounting for 99% of total HW
production is included in Eurostat but excluded in national statistics. Therefore Eurostat data
is more than 100 times higher. This also has the effect that information on other HW streams
is ‘hidden’. In fact, recovery rate for other HW streams than mineral waste is quite
reasonable, but also when subtracting mineral wastes there is a gap between HW generation
and treatment of approximately 64%. This gap could not be fully clarified.
− In the Netherlands, Finland and Germany, the statistical gap from generation and treatment
based on Eurostat data is comparably low (10%, 11% and 15% respectively). For the
Netherlands the statistical gap could not be clarified. Based on national statistics, Finland is
the only country that has a negative statistical gap between HW generation and treatment of
-13%. The reasons for data discrepancies, as well as for the data gap, could not yet be
clarified with the competent authority. Differences for Germany can mainly be explained
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through reporting differences from national and Eurostat statistics, either by methodological
or by technological reasons like drying of waste.
− Latvia has a statistical gap below but close to 50% in both calculations using national (43%)
and Eurostat data (48%). The originally calculated Eurostat statistical gap had to be corrected
for Latvia due to data mistakes. The originally calculated import amounts for 2012 of 125.3kt
based on Eurostat were corrected to minimum 1.9 kt up to maximum 6.2 kt imported HW
(including max. potential within mixed groups). The reason for this was the fact that the
waste code 19 12 10 was marked in the original table originating from Eurostat in column
“Raw data - Waste stream” with “*” as symbol for a HW code and thus summed up by an
automatic formula to the total amount of HW imported.
− After extensive clarification of HW data for the United Kingdom the original statistical gap of
67% according to Eurostat data could be estimated to 26% in reality according to national
data. There are several reasons for the data discrepancies leading to larger gap of 67% that
are explained below and in the factsheet. Nevertheless, the remaining gap of 26% could not
be fully clarified.
− In Italy, the gap between HW generation and treatment is more than 60% high. Reasons for
the gap are manifold examples are the different reporting obligation for HW treatment and
exports. However, when taking these reasons into consideration, a share of the gap could
not be fully clarified.
− For Ireland Eurostat statistics for HW generation and treatment do not fit together at all and
there appears a gap of about 95%. The data gap for the reporting period 2012 in the
preliminary datasets submitted to Eurostat in early 2015 can be explained by the fact that
some enterprises reported HW data in kg and not in t, but these amounts have been
reported as tonnes to Eurostat. This is the main reason for the nonconformity of Eurostat
data with nationally published HW data. Taking national statistics into consideration
(including data on treatment, export and import on HW), the gap between HW generation
and treatment is only 6%.
− For Luxembourg, even after the investigation the extremely high statistical gap of 99%
remains. The reason is that HW imports and exports could not be definitely clarified due to
the fact that HW shipments have been reported according to Basel-Y-code that includes
hazardous and non-hazardous amounts. The statistical gap could not be fully clarified.
The main reasons for discrepancies of Eurostat and national HW data investigated are:
1. In-company HW amounts / HW treated on-site are not covered by the record keeping system
(DE, IT, LV, NL).
2. Uncertainties in reporting (BG, UK, LV) and obvious mistakes in reporting (IE)
3. Eurostat statistics on HW treatment excluded from the reporting obligation certain recovery/
disposal operations (D8, D9, D11, D13, D14, D15, R12 and R13 are leading to a statistical gap,
see also requirements from Annex II to the Waste Statistics Regulation) (DE, IT, also mentioned
by other MS).
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4. Temporary storage – HW generation in one year, HW treatment in next year, e.g. in case of
large amounts of contaminated soils (BG, also mentioned by EE and IT).
5. Import/Export statistics refer exclusively to Basel-Y-code classification, there are no additional
information to LoW codes available (IT, LU).
6. Double-counting of HW generated, in particular for waste amounts sent to transfer stations and
for pre-treatment (e.g. 19 code) and waste stemming from other treatment sites (UK, FI, NL).
7. Pre-treatment activities or flows of HW to re-processors under D15 or other codes are not
reported to Eurostat (BG, FI).
8. Amounts in national statistics are calculated based on ‘fresh weight’ whereas data for certain
sludges (especially from LoW chapters 3 and 12) in Eurostat is based on ‘dry weight’ (DE).
9. National statistics is based on diverting classification code (IT).
The statistical data collection procedure also focused on the investigation of the possible connection
between remaining data discrepancies and the information basis used to elaborate statistics. The
following reporting procedures/data bases are used to establish HW data sets:
Table 5-1: Overview on statistical data collection procedures in ten EU MS
EU-MS
Statistical data collection procedure Investigated data discrepancies
BG Identification cards and record books with annual reporting; reporting is on paper. It is planned to upgrade to an electronic system operational by Feb. 2016 in order to improve data quality.
None in Eurostat. Large difference compared to national statistics (excluding of mineral wastes); high amount of mineral waste in Eurostat ‘masks’ gap of HW generation/ treatment for other HW streams.
Partly no explanation for gaps
EE High level electronic reporting with full description of waste shipments and LoW codes that are linked and transformed automatically to Eurostat codes
None
FI Finland uses a de-centralised (regional) record keeping system for HW tracing. Only partly reporting obligation to competent authority for companies needing an environmental permit for their activities
11% in Eurostat. Large discrepancies between Eurostat and national data. Deviating amounts for HW from waste water and waste treatment and basic metal industry.
No explanation for data gap
DE Waste statistics in general from surveying waste treatment facilities according German Environmental Statistics Law (‘Umweltstatistikgesetz’). Electronic record keeping directly linked to statistical collection procedure for HW generation (consignment notes), minimises the need for estimations, import/export data available
15% in Eurostat, differences in national and Eurostat data occur (as explained in the section on DE), Partly no explanation for gaps
IE An electronic record keeping system for every HW movement is established. The tracking system uses Waste Transfer Forms (WTFs) that are tracking documents which must be used whenever HW is
Huge data discrepancies compared to national statistics based on a reporting mistake (kg vs. t).
However, partly no explanation for HW
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EU-MS
Statistical data collection procedure Investigated data discrepancies
shipped or transferred within the State. export and treatment data.
IT 1) Paper-based record keeping, annual reporting 2) Digital record keeping (SISTRI), some remaining problems with system, systems not covering export/import data
66% in Eurostat, differences in national and Eurostat data occur (as explained in the section on IT); Partly no explanation for gaps
LV HW data is prepared based on reports submitted by companies in annual statistical report that need to be to submitted to State Environmental Service for control.
Data gaps for treatment and generation can partly be explained due to methodological reasons.
National data for reference year 2012 was not available.
LU HW registers have to be kept by producers and have
to be made available upon request. This register is
not electronic. Companies involved in HW
collection, treatment and storage have to report
annually their HW data (Excel format); this system is
being changed into an electronic online reporting
that will be mandatory in 2017
Large discrepancies between Eurostat and national data on HW generation (33%) and no treatment data available on national level.
Partly no explanation for gaps
NL The HW data reported to Eurostat is based on
national transport register data collected. There is
a central national electronic tracking system
established, there is no reporting obligation to the
competent authority for HW and no electronic
register covering all steps of HW management.
11% in Eurostat. Reasons for data discrepancies could be explained by several reasons.
Partly no explanation for gaps
UK Quarterly reports by operators with permit
In 2014: change from notification/reporting system
with pre-notification procedure ‘back to’ simple
reporting system, data quality might have decreased
68% in Eurostat, differences in national and Eurostat data occur (as explained in the section on UK);
Partly no explanation for gaps
From the information collected as regards data discrepancies and statistics procedure system applied
in the countries, the following assumptions could be drawn (at least for the 10 MS assessed):
Member States operating an electronic reporting system partly connected to notification
and/or consignment notes have a smaller statistical gap or, if there is a gap, it can be fully
explained
For Member States relying on other reporting systems (quarterly, annually) and/or paper
reporting, and having no reporting obligation, the data discrepancies remain and cannot
fully be explained.
To wrap up the investigations on statistics the following points are describing the situation:
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1. The gap between HW generation and treatment in Eurostat statistics range from 0 to 99%. The
gaps can be explained mainly by differences in reporting obligations under Eurostat and national
statistics but also by discrepancies within the Eurostat reporting systems.
2. It seems that Member States applying an electronic reporting system partly connected to
notification and/or consignment notes show lower gaps and discrepancies in data leading to the
position that those reporting systems are more reliable than others.
3. In some Member States (smaller) gaps in statistics remain, even when taking into account all
reasons explaining the differences of data; it can be concluded that there is poor reporting for
HW actions and no full record/control of those actions.
The following chapter describes the situation as regards statistical issues in the analysed Member
States. All information is included and fully cited in the MS factsheets (separate documents, list in
Annex I/Chapter 10.1).
5.3.1 Particular issues with statistical data in Bulgaria
Statistical data collection procedures in Bulgaria are carried out by the Executive Environment
Agency (ExEA). Persons or companies carrying out operations with HW are obliged to provide
information. All persons along the chain, from the waste producer to the recipient for final recovery
or disposal, are required to complete identification cards upon request. Record books contain a
chronological record of the quantity, nature and origin of the waste and, where required, the
destination, frequency of collection, mode of transport and treatment methods foreseen. Operators
etc. have to provide an annual report containing this data. Record keeping is on paper, but it is
planned to upgrade record keeping to an electronic information system operational by February
2016. It is anticipated that data quality will be improved.
The ExEA is responsible for issuing IED permits and collects HW transfer notes, annual reports and
any data regarding waste activities. After data verification, ExEA sends it to the National Statistical
Office for further processing according to methodology and eventually reporting to Eurostat. There
are data quality procedures for verification by both authorities. Further, all data collected is
summarised by the Bulgarian Environmental Agency by means of Excel tables, which are published
once a year in not-aggregated form.
Table 5-2: Summary on statistical data, differences and explanations for Bulgaria
Eurostat data (2012)
Statistical gap
at Eurostat data Generation
(GEN)
Treatment
(excluding Annex
2 WStatR) (TRT)
Export
(EXP)
Imports
(IMP)
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
13,407 kt 13,389 kt 2kt 30 kt 45 kt 0%
Explanation for
gap
Reason for 0% data gap:
Eurostat data includes ‘Other mineral wastes’ (W12B) accounting for 99%. Generated
mining waste is typically disposed directly in tailing ponds next to operating quarry or is
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used for backfilling. As HW is produced and treated at the same site and both is reported by
one operator, data is matching to a high extent. However, the high amount of mineral waste
compared to other HW sources is ‘hiding’ the data of other HW streams and possible gaps
(see below).
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
Eurostat [BG NIS 2015B]
HW generation 13,407 kt 158 kt
HW treatment 13,390 kt 59 kt
Generation
HW generation The amount of generated HW in official Eurostat data in 2012 is 13,407 kt; the Bulgarian
National Statistical Office (NIS) report for the same year 158 kt generated HW.
Data difference NIS about 100 times less than Eurostat
Explanation Eurostat data includes ‘Other mineral wastes’ (W12B) accounting for 13,268 kt or 99% of
total HW generation. When excluding the fraction of mineral waste from Eurostat data, HW
amounts to 139 kt leaving a difference of 20 kt higher than reporting in national statistics.
Mining waste is outside the scope of the WFD (Article 2(2) (d)), however Eurostat has not
cleared so far whether it should be included in the reports or not. BG, EE and one more
country have decided to include this source in the statistics.
Treatment
HW treatment As regards HW treatment: The amount reported under Eurostat is 13,390 kt 2012 and in
Bulgarian Statistics 59 kt.
Data difference NIS more than 100 times less than Eurostat
Explanation As there are enormous quantities of mining waste compared to any other HW source,
disposal of this stream “masks” any other numbers also gaps and treatment data.
When excluding mineral wastes from the statistics:
1) When taking total HW generation (excluding mineral wastes) as a basis, 158 kt were
generated; 59 kt were treated – this leaves a gap of 63%
2) Also when looking at the three major waste streams (used oil, Industrial effluent
sludges, combustion waste) data from national statistics from 2012, 142 kt of were
generated and 46 kt is reported as treated HW, leaving a gap of 96 kt (gap of 67%).
3) There are some data discrepancies between the National Plan 2014-2020 and the
NIS reports, for example HW generation for 2012, recovered quantities of waste oil
exceed collected quantities, collected, recovered and disposed quantities from WEEE
do not fit
4) There is a constant decrease of reported HW generation (excluding mineral waste)
between the years 2008 and 2012 (see table below), The reason for the significant
drop between 2010 and 2011 has been the reclassification of waste resulting from
one enterprise with economic activity "Metallurgy and manufacture of metal
products, except machinery and equipment"
5) The possibility that a certain percentage of generated HW goes unreported cannot be
excluded
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Possible reasons for the gap are:
1) significant temporary storage of HW
2) poor reporting and/or
3) pre-treatment activities or flows of HW to re-processors under D15 or other codes are
not reported to Eurostat
The possibility that a certain percentage of generated HW is not reported cannot be
excluded.
HW
import/export
There are no significant exports; about 2.1 kt are exported in 2012 (industrial sludge,
solidified lead slag, mixed materials containing hazardous substances, expired medicines
(mainly to RO, HU, NL) (mainly D10 and R5). This is conform with Eurostat (2 kt).
The total imported HW in 2012 was 30 kt, mainly lead -acid batteries, pyrite stubs (mainly
from DE); all imported for R operations. This is conform with Eurostat (30 kt).
Data difference None
Investigated data discrepancies
- By excluding mineral wastes and consulting the national statistics, it can be concluded that there is a gap
of 63% between HW generation and treatment
- Large difference to national statistics (excluding of mineral wastes); high amount of mineral waste in Eurostat ‘masks’ gap of HW generation/ treatment for other HW streams.
- Partly no explanation for gaps
5.3.2 Particular issues with statistical data in Estonia
Estonia uses a high level electronic reporting system with full description showing accurately the
waste flow (Consignment Note Database) in order to avoid discrepancies with waste codes or gaps.
Further, annual reporting is required by operators holding an environmental permit. The tracking of
HW is possible both via consignment notes and annual reports. Information basis for elaborating the
statistic is the waste permit system including reporting obligation, EA Waste Data Management
System plus estimations mainly for enterprises less than ten employees. The Ministry plans to link
the Consignment Note Database to the Annual Report Database in the near future.
The Estonian Environmental Agency provides waste management information and manages a portal
intended for the use by officials, industry, and general public. Also information about waste
shipments (quantity and waste type) are published.
Table 5-3: Summary on statistical data, differences and explanations for Estonia
Eurostat data (2012)
Statistical gap
at Eurostat data Generation
Treatment
(excluding Annex
2 WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
9,159 kt 9,131 kt 3 kt 17 kt 42 kt 0%
Explanation for
gap
Reason for zero gap:
1) Estonia uses a high level electronic reporting system with full description of the waste
shipment. It includes data from waste generation point to intermediate treatment
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companies to final treatment point (regardless from the number of companies
involved). In this way it avoids controversies with codes or gaps.
2) In the waste database, LoW codes are linked and transformed automatically to
Eurostat codes, prior to reporting.
3) Temporary storage could account for a possible gap (in other countries, not in Estonia).
For example there have been few old contaminated sites from the Soviet-era in Estonia
and large amounts of contaminated soil can be produced from a single restoration
project. These amounts are subject to temporary storage and treated within the next
years.
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
Eurostat Estonian Environmental Agency Statistics
HW generation 9,159 kt 9,233 kt
HW treatment 9,131 kt 9,131 kt
Generation
HW generation The amount of generated HW in official Eurostat data in 2012 is 9,159 kt; the
Environmental Agency Statistics reports for the same year 9,233 kt generated HW.
Data difference EE statistic 74 kt higher than Eurostat.
Treatment
HW treatment As regards HW treatment: The amount reported under Eurostat and Environmental Agency
statistics is for both datasets 9,131 kt in 2012.
Data difference None
HW
import/export
Imports of HW are reported to 18 kt and exports of HW are reported to 3 kt in 2012. This is
in line with reported Eurostat data.
Data difference None
Investigated data discrepancies
- Based on the aforementioned statistics on HW generation and treatment, a 0% statistical gap was calculated.
- Τhe reason for this is the high level electronic reporting system used in Estonia.
5.3.3 Particular issues with statistical data in Finland
Based on the statistical data published by Eurostat for HW generation (1,654 kt) and treatment
within Finland (1,411 kt) there remains a statistical gap of 168 kt (11%) which is considered to be
comparably low. Reasons for the statistical gap can be explained by methodological reasons of
double counting and excluding pretreatment facilities from reporting obligation to Eurostat, loss of
hazardous status during intermediate treatment.
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Table 5-4: Summary on statistical data, differences and explanations for Finland
Eurostat data (2012)
Statistical
gap at
Eurostat data
Generation
Treatment
(excluding Annex
2 WStatR)
Export Imports Difference (Gap)
(GEN - EXP + IMP) - TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
1,654 kt 1,411 kt 95 kt 20 kt 168 kt 11%
Explanation
for gap
− Potential reasons for the statistical gap can be explained by methodological reasons, e.g.
double counting, excluding pre-treatment facilities from reporting obligation to Eurostat
as well as loss of hazardous status during intermediate treatment.
− Further reasons for the discrepancies between Eurostat data and national statistics could
not be clarified. The 11% data gap remains
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
Eurostat FI Stat 2015
HW generation 1,654 kt 1,052 kt
HW treatment 1,411 kt 1,361 kt
Generation
HW
generation
The amount of generated HW in official Eurostat data in 2012 is 1,654 kt; the Statistics
Finland reports for the same year 1,052 kt generated HW.
Data
difference
FI Stat 602 kt less than Eurostat
Explanation − As regards HW generated there are significant differences between Eurostat and Statistics
Finland.
− Reasons for the different generation data are mainly:
1) deviating amounts for HW from waste water and waste treatment in national statistics
and Eurostat. These amounts are not included in the data provided in Statistics Finland.
2) difference in the amounts of HW generated by basic metal industry. In total terms
national statistics indicates lower generation data in the basic metal industry.
Treatment
HW
treatment
As regards HW treatment: The amount reported under Eurostat is 1,411 kt for 2012.
Whereas Statistics Finland reports 1,361 kt.
Data
difference
Statistics Finland reports 50 kt less than Eurostat
Explanation According to Statistics Finland 1,361 kt of HW were treated. These figures are nearly in line
with data published by Eurostat (1,411 kt). Around three third of HW was landfilled. These
were mainly mineral fractions, but also 46% of HW generated by households. [FI Stat 2015]
Other reasons could not be clearly explained.
HW
import/export
There are no separate detailed data on import and exports of HW publicly available by
Statistics Finland on national level. The Monitoring Report 2014 publishes only aggregated
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figures. Therefore, a comparison of national and Eurostat data could not be conducted [FI
WMP MR 2014]. The Finnish Environment Institute (SYKE) is the competent authority in
relation to transfrontier shipments of waste.
Imports of HW are reported to 20 kt and exports of HW are reported to 95 kt in 2012
according to Eurostat.
Data
difference
n.a.
Investigated data discrepancies
- Large discrepancies between Eurostat and national data. Deviating amounts for HW from waste water and waste treatment and basic metal industry.
- No explanation for data gap
- Based on the statistical data published by Eurostat for HW generation (1,654 kt) and treatment within Finland (1,411 kt) there remains a statistical gap of 168 kt (11%)
5.3.4 Particular issues with statistical data in Germany
Statistical data collection procedures in Germany are based on surveys at waste treatment facilities
and thus focus on wastes arriving at treatment facilities. There are also statistics available for HW
generation that are directly linked to the electronic record keeping system which minimises the need
for estimations. In the case of HW, both data sources show differences regarding the amounts for
HW generation. The different statistics are further explained in the German factsheet (see list in
Annex I/chapter 10.1). In general, statistical data in Germany is plausible.
Also national statistics on import and export of HW is plausible since data collection is not performed
via questionnaires once a year but based on submitted consignment notes (‘Begleitscheine’). Hence
data is very recent and transparent. The German statistics also include amounts of HW break down
on Federal State level. Destatis (German Statistical Office) is regularly publishing data on waste
generation including HW; this information is available to the public in form of a report. Differences
between Eurostat and national data is summarised in the following table. Following the
argumentation, differences and also the gap of generation and treatment (according to Eurostat) can
mainly be reported with difference reporting obligations (see below).
Table 5-5: Summary on statistical data, differences and explanations for Germany
Eurostat data (2012)
Statistical gap
at Eurostat data Generation
Treatment
(excluding Annex
2 WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
21,984 kt 21,098 kt 334 kt 3,077 kt 3,628 kt 15%
Explanation for
gap
- Eurostat statistics on HW treatment do not contain certain recovery/disposal
operations (e.g. R 12, R13, D 8, D 9, D 11, see also requirements from Annex II to the
Waste Statistics Regulation).
- Reason for gap: In Germany, sufficient disposal capacities are available and the
disposal infrastructure is often dominated by larger companies that need to follow the
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regulations, e.g. due to image reasons. Additionally, the duty to assign a person in
charge for waste (‘Abfallbeauftragter’) for larger industries is seen as a helpful tool.
Additionally, the treatment and disposal infrastructure usually rely on highly developed
technology solutions but are still cost-efficient. As a consequence, there is no
substantial competition for the treatment of certain waste streams which decreases
the amount of exported HW (exempt from occasional shipments to MS close to the
German border to reduce transportation cost).
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
Eurostat German Statistical Office (Destatis)
HW generation 21,984 kt 23,686 kt
HW treatment 21,098 kt 26,121 kt
Generation
HW generation The amount of generated HW in official Eurostat data in 2012 is 21,984 kt; the German
Statistical Office (Destatis) reports for the same year 23,686 kt generated HW based on
surveys at waste treatment facilities following the German Environmental Statistics Law
(‘Umweltstatistikgesetz’).
Referring to data generated from the assessment of consignment notes, Destatis reports
21,963 kt as HW generation, which is 1,723 kt less than the amounts reported based on
surveys. There are several reasons for these differences between the aforementioned data
from two different sources provided in the German Factsheet. However, some uncertainties
remain.
Data difference Destatis 1,702 kt more than Eurostat
Explanation The difference between the two datasets can be explained due to the reason that amounts
in Destatis are calculated based on ‘fresh weight’ whereas data for certain sludges
(especially from LoW chapters 3 and 12) in Eurostat is based on ‘dry weight’.
In addition, both Destatis and Eurostat data might underestimate the actual generation of
HW, at least in one federal state (North-Rhine-Westphalia) as in-company HW amounts not
covered by the record keeping system.
Treatment
HW treatment As regards HW treatment, the amount reported under Eurostat is 21,098 kt for 2012
whereas Destatis reports 26,686 kt (as input to landfills, incinerators, chemical-physical
treatment facilities, etc.).
Data difference Destatis 5,023 kt more than Eurostat
Explanation The difference in treated HW amounts between Destatis and Eurostat can be explained
mainly because Eurostat data on treatment does not contain certain recovery / disposal
operations (e.g. R12, R 13, D 8, D 9, D 11, see Annex III to the Waste Statistics Regulation)
which are included in the data from Destatis. Additionally, some waste treatment processes
might partly be double-counted in data from Destatis, as HW amounts which are treated
sequentially by more than one treatment facility will be counted twice or more.
HW
import/export
When considering the share of HW according the Federal Waste Catalogue Ordinance
(‘AVV’) (LoW) from the overall waste shipments underlying the duty for notification,
imported HW amounts to approximately 3,077 kt to Germany (data from UBA). Whereas
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335 kt of HW are exported from Germany (data from UBA). Both amounts are basically in
line with the reported amount of Eurostat (3,077 kt import, 334 kt export).
Data difference None
Investigated data discrepancies
- A statistical gap of 15% according to Eurostat data remains.
- Differences in national and Eurostat data occur (as explained in the section on DE),
- However partly no explanation for gap
5.3.5 Particular issues with statistical data in Ireland
Statistical data collection procedures in Ireland are based on surveys. An electronic record keeping
system called Waste Regulation Management System (WRMS) is established for every HW
movement and is operated and managed by the National TransFrontier Shipments Office (TFS).
Dublin City Council (National TFS Office) the sole authority for the administration of HW movements
within Ireland. The tracking system uses Waste Transfer Forms (WTFs) that are tracking documents
which must be used whenever HW is shipped or transferred within the State. The WTF
administration system requires consignors to purchase and fill in forms online.
The recording obligation applies to everyone involved in waste management e.g. waste producer,
waste holder, consignee, notifier, carrier, and is well established in Ireland. No problems with the
record keeping obligation are known. Penalties are issued by the authorities for non-reported HW
movements.
Problems with data reporting to Eurostat have occurred in Ireland. The Central Statistical Office
(CSO) had responsibility for compiling the waste generation dataset for Waste Statistics Regulation
reporting (2012 calendar year), through combining EPA data (modelling and administrative data)
with the CSO enterprise survey data and scaling up to national data per NACE economic sector. For
2012 data reporting, CSO conducted a waste generation survey of a number of enterprises on the
business register. These survey data are an important data source for the waste generation dataset.
Under the Statistics Act 1993, CSO are precluded from sharing the enterprise survey data with EPA,
although EPA would like to bring their waste validation expertise to the review of the data. EPA
would also like to review the dataset prior to submission to Eurostat in future, to avoid gross errors
in reporting and the ensuing work in answering queries on the data.
Table 5-6: Summary on statistical data, differences and explanations for Ireland
Eurostat data (2012)
Statistical gap
at Eurostat data Generation
Treatment
(excluding
Annex 2
WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
1,972 kt 69 kt 132-147 kt 6.6 kt 1,832 kt - 1,847 kt 93%/
94%
Explanation for As mentioned above in Ireland the Central Statistical Office (CSO) has the responsibility of
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gap reporting HW data to Eurostat. The data gap for the reporting period 2012 in the
preliminary datasets submitted to Eurostat in early 2015 can be explained by the fact that
some enterprises reported HW data in kg and not in t, but these amounts have been
reported as tonnes to Eurostat. This is the main reason for the nonconformity of Eurostat
data with nationally published HW data.
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
[Eurostat WASGEN 2012] [IE EPA 2015]*
HW generation 1,972 kt 283.5 kt**
HW treatment 69 kt 130 kt
* preliminary data provided by EPA waste statistics team Aug 2015 for 2012
** This figure includes 10.3kt of secondary hazardous waste arising as required to be
reported under the WStatR methodology
Generation
HW generation The amount of generated HW in official Eurostat data in 2012 is 1,972 kt; the Irish EPA
provided a preliminary HW generation amount of 283.5 kt for the same year.
Data difference Significant discrepancy between the amounts of HW reported to Eurostat for 2012
compared to the amount published on national level. Eurostat data is nearly seven times
higher than national data.
Explanation The difference in the HW generation amounts for 2012 can be explained by the fact that
some companies did report HW data in kg and not in t, but these amounts have been
reported as tonnes to Eurostat.
Treatment
HW treatment As regards HW treatment: The amount reported under Eurostat is 69 kt for 2012. Whereas
[IE EPA 2015] reports 130 kt.
Data difference National statistics report 61 kt more than Eurostat
Explanation The difference between data reported to Eurostat and national data is because Waste
Statistics Regulation asks for information on HW undergoing final treatment in the State,
while Ireland reports on final treatment and non-final treatment of HW
HW
import/export
According to Eurostat HW amounts exported in 2012 from Ireland amounted to 132 kt - 147
kt national data indicates 144 kt (amber list waste that may contain non-hazardous waste).
Therefore HW export data seems to be plausible and fit to the data of HW generation. HW
imports in 2012 are reported to be in both statistics 6.6 kt. Taking the HW generation and
import/export data into consideration a gap between HW generation and treatment
(including import/export) would calculate to about 6%.
Data difference n.a.
Investigated data discrepancies
- Reasons for the statistical gap of 93-94% are reporting mistakes to Eurostat where kg amounts were reported as tonnes.
- If the statistical gap is recalculated based on data from national statistics the result for the statistical gap is 16,1 kt (5.7%).
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5.3.6 Particular issues with statistical data in Italy
HW statistics are prepared by ISPRA on the basis of the MUD declarations (‘Modello Unico di
Dichiarazione ambientale’) (paper reporting) and the SISTRI reporting system (Waste Traceability
Control System) (digital system). Any person involved in HW management are obliged to keep a
register and submit data annual notification to the Chambers of Commerce competent for the
region. This data is used to produce statistics. Further, the electronic Waste Tracking System (SISTRI)
established in the Campania region in 2011 and now implemented nation-wide at the initiative of the
Ministry of Environment, Land and Sea. With this system data can be reported electronically. Import
and export data are not covered by the system. There remain some problems with the application.
There are annual detailed reports on industrial waste, differentiated by hazardous and non-
hazardous, published by ISPRA. The level of detail refers to classification ( LoW-groups and waste
streams as per Eurostat groups), origin (branches), regions (for generation and treatment), treatment
options (waste streams as per R and D code on regional level). Treatment data is also available by
regions.
Table 5-7: Summary on statistical data, differences and explanations for Italy
Eurostat data (2012)
Statistical gap
at Eurostat data Generation
Treatment
(excluding Annex
2 WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
9,474 kt 3,258 kt 238kt 369 kt 6,348 kt 66%
Explanation for
gap
Reason for relatively large gap:
1) The main reason identified is the reporting obligation. According to the ‘Manual on
waste Statistics’ published by Eurostat19 the disposal and treatment options D8, D9,
D11, D13, D14, D15, R12 and R13 are excluded from the reporting obligation leading to
a statistical gap of up to approximately 4,200 kt compared to nationally published data
by ISPRA.
2) Another source of variations are the import and export statistics, based on Basel-Y-
code classification (see below).
3) Further reasons could be explained by waste amounts that are internally (on-site)
treated and statistically not clearly explained temporarily stored amounts.
4)
19 [Eurostat 2010] : Manual on waste statistics - A handbook for data collection on waste generation and treatment, http://ec.europa.eu/eurostat/documents/3859598/5915865/KS-RA-10-011-EN.PDF/39cda22f-3449-4cf6-98a6-280193bf770
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Comparison of national and Eurostat data and explanations (2012)
Data
comparison
Eurostat IT ISPRA
HW generation 9,474 kt 9,372 kt
HW treatment 3,258 kt 7,344 kt
Generation
HW generation The amount of generated HW in official Eurostat data in 2012 is 9,474 kt; the Italian ISPRA
reports similar amounts (9,372 kt).
Data difference ISPRA reports 102 kt less than Eurostat.
Explanation ISPRA is reporting for some waste streams different amounts than Eurostat, i.e. chemical
wastes (1,486 kt ISPRA instead of 1,496 kt Eurostat) and industrial effluent sludges (1,327 kt
instead 1,293 kt) slightly higher amounts are reported than under Eurostat.
Differences could not be explained.
Treatment
HW treatment As regards HW treatment: The amount reported under Eurostat is 3,258 kt in 2012 and
7,344 kt under ISPRA reporting.
Data difference ISPRA reports 4,086 kt more than Eurostat
Explanation In addition to the above mentioned reasons: According to the current understanding, data
on waste generation are collected on LoW basis. According to ISPRA 8,197 kt of HW
generated are based on the MUD (‘Modello Unico di Dichiarazione ambientale’) reporting
system; 1,162 kt are ELV and nearly 12 kt are HW due to ISTAT (Italian National Institute of
Statistics) activities.
Due to different methodological approaches data are not directly comparable.
HW
import/export
As regards export of waste ISPRA reports 1,380 kt (using Basel-Y-code) compared to 237 kt
reported by Eurostat. Converting this amount to LoW hazardous codes this would fit to
Eurostat reporting.
For import ISPRA reports in 2012 107 kt, Eurostat reports 369 kt. Data sources for the
amount of HW imported published by ISPRA are not yet clear, Eurostat reports a higher
amount. So far it was not possible to clarify this issue.
Data difference Export: None (if converted to LoW code), Import: ISPRA 262 kt lower than Eurostat
Explanation − Data for exports published by ISPRA are based on the definition of hazardous based on
Basel-Y-code (Y1-Y45). Taking into consideration the classification according to the
LoW, where entries to be considered as HW are annotated with an *, the amount of
HW exported would be lower. It has to be noted, that also selected amounts classified
as non-hazardous based on Basel would have to be considered as hazardous based on
LoW. Data sources for the amount of HW imported published by ISPRA are not clear.
Eurostat reports a higher amount. It was not possible to clarify this issue.
Investigated data discrepancies
− There is a significant statistical data gap of 66% that remains. The main reason identified is the reporting
obligation (excluding several disposal operations in reporting).
− However, when taking these reasons into consideration, a share of the gap could not be fully clarified
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5.3.7 Particular issues with statistical data in Latvia
In Latvia statistical data on HW management is prepared based on reports submitted by companies.
Companies generating or treating HW are required to prepare an annual statistical report on
management of waste and to submit it to State Environmental Service for checking. Data on waste
management are treated and prepared by the State Limited company “Latvian Environmental,
Geological and Meteorological Centre”. HW data is publically available at different levels a) public
access to HW reporting data base20; b) summaries on annual waste statistics reports21 as well as c)
aggregated data is available at the Central Statistics Database22.
The companies HW records are usually a printed list with waste (including info on amount, weight,
chemical properties) that is currently stored on site. This document upon request has to be
presented to the environmental inspection. A separate waste transportation accounting system has
been developed for registration of HW transports within Latvia. This system is used by HW
management companies, state institutions and competent authorities.
There are mixed opinions and impressions regarding the operation and functioning of the
electronic system in practice. On the one hand side it has been reported that it is easy to operate
and practical, especially compared to paper forms. Consignment notes can be printed as pdf files. On
the other hand side, the technical performance of the electronic system could be improved. It
would be necessary to simplify its use, because data has to be inserted in three different state web
base programs and these data are not comparable. Statistical reports should be linked to the
electronic system which is not done at the moment. In general the data entry system should be
improved to be more user-friendly data entry system.
Table 5-8: Summary on statistical data, differences and explanations for Latvia
Eurostat data (2012)
Statistical
gap at
Eurostat data
Generation
Treatment
(excluding
Annex 2 WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
95 kt 42kt 10 kt* 2.7 kt* 45.7 kt 48%
* average amounts based on imports 1.9 kt to 6.2 kt, and exports 8 kt to 12 kt
Explanation
for gap
The difference between amounts of HW generated and treated was explained by the
authorities as follows:
1) pre-treatment of HW leading to different classification,
2) temporary storage of HW at enterprises and
3) missing reports from some HW recovery companies. Especially, pre-treatment of
bilge water from navigation in port facilities leads to high volumes of purified
water.
20 http://parissrv.lvgmc.lv/#viewType=home_view 21 http://www.lvgmc.lv/lapas/vide/atkritumi/atkritumu-statistikas-apkopojumi/atkritumu-statistikas-apkopojumi?id=1713&nid=380 22 http://data.csb.gov.lv/pxweb/en/vide/vide__ikgad__vide/VI0040.px/table/tableViewLayout1/?rxid=a79839fe-11ba-4ecd-8cc3-4035692c5fc8
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Comparison of national and Eurostat data and explanations (2012)
Data
comparison
HW generation
(absolute)
[Eurostat WASGEN 2012] [LV MoEPRDb 2015]
95 kt 91.5 kt*
HW treatment
(absolute)
[Eurostat WASTRT 2012] [LV MoEPRDb 2015]
42 kt 51.7 kt*
*Data source from 2015, data for 2012
Generation
HW
generation
The amount of generated HW in official Eurostat data in 2012 is 95 kt; the Latvian MoEPRD
reports a smaller amount of 91.5 kt in absolute terms.
Data
difference
MoEPRD reports 3.5 kt less than Eurostat.
Explanation According to the National annual waste statistics report HW generation data were as follows
in 2012 in Latvia:
Year Generated by reporting enterprises, kt Collected, kt
2012 41.04 91.49
There is an obvious data inconsistency as data on HW collected amounts is higher than data
on HW generated. The reasons are:
i) bilge water (13 04 03) is reported as collected but not as generated, as it is not
produced in Latvia and
ii) Category C companies are not obliged to submit annual reports and do not account
for HW generation; any small quantities from this source are reported as collected
by the respective collection company.
Treatment
HW
treatment
As regards HW treatment: The amount reported under Eurostat is 42 kt in 2012 and 51.7 kt
under Latvian MoEPRD reporting.
Data
difference
Latvian national statistics reports 9.7 kt more HW generation than Eurostat.
Explanation According to the National annual waste statistics report HW generation data were as follows
in 2012 in Latvia:
Year Recovered (R1-R13), kt Disposed (D1-D15), kt Total (kt)
2012 47.43 4.25 56.7
The difference between treated HW amounts was explained by the authorities as follows:
1) pre-treatment of HW leading to different classification,
2) temporary storage of HW at enterprises and
3) missing reports from some HW recovery companies. Especially, pre-treatment of bilge
water from navigation in port facilities leads to high volumes of purified water.
HW The originally calculated HW amounts based on Eurostat for imports in 2012 were 125 kt
and exports 8 kt. National data for 2011 included in the Latvian WMP indicated largely
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import/export deviating amounts of exports 14.9 kt and imports 3 kt.
Data
difference
Not directly comparable due to different reporting periods. However, for imports there is an
immense difference of 122 kt less according to national statistics. Exports seem comparable.
Explanation Compared to previous calculations for Latvia a correction of the calculated import
amounts for 2012 based on Eurostat from 125.3 kt to min. 1.9 kt up to max. 6.2 kt
(including max. potential within mixed groups) had to be made. The reason for this was the
fact, that the waste code 19 12 10 was marked the original table originating from Eurostat
in column “Raw data - Waste stream” with “*” as symbol for a HW code and thus summed
up by an automatic formula to the total amount of HW imported. The original data in this
column were used mainly to be able to allocate mixed waste fractions to the HW potential
imported / exported based on the identification of single waste codes within a “mixed
group”.
Based on this new calculation of HW imports the significant difference of the amounts
reported nationally and according to Eurostat could be clarified. Data now seems to be
plausible.
Investigated data discrepancies
− Data gaps for treatment and generation can partly be explained due to methodological reasons.
− Latvia has a statistical gap below but close to 50% in both calculations using national (43%) and Eurostat
data (48%) that remains
5.3.8 Particular issues with statistical data in Luxembourg
In Luxemburg HW statistics are prepared by the Environment Agency (Administration de
l’Environnement – AEV) on the basis of the reporting obligation. HW data has to be collected by the
producer and they must keep a register that has to be made available to the AEV if required. This
register is not electronic. One priority in Luxembourg is the transparency of HW data, for this reason
all companies involved in the framework of the SuperDrecksKëscht submit their data to them via an
electronic tool. This data are transmitted to the AEV on demand.
In general, companies involved in HW collection, treatment and storage have to report annually
their HW data to the AEV in an Excel format. This system is currently under revision and is being
changed into an electronic online reporting that will be mandatory in 2017.
Table 5-9: Summary on statistical data, differences and explanations for Luxembourg
Eurostat data (2012)
Statistical
gap at
Eurostat data
Generation
Treatment
(excluding Annex
2 WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
315 kt 2 kt n.a. n.a. 313 kt 99%
Explanation
for gap
Including the information on import and export of 0 kt for both, the gap between
statistical data from Eurostat on HW generation and treatment amounts to 99% in
Luxemburg. It has to be noted, that this very high data gap is mainly based on the missing
information on HW imported and exported that was not included into calculation.
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Nearly all HW is exported for treatment and it can be assumed that the actual data gap is
largely below 99% [LU Environment Agency 2015].
No further explanation on the statistical gap could be provided by the competent
authority
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
HW generation (absolute) [Eurostat WASGEN 2012] [LU Stat 2013]
315 kt 420 kt*
HW treatment (absolute) [Eurostat WASTRT 2012] [LU Stat 2013]
2 kt n.a.
Generation
HW
generation
The amount of generated HW in official Eurostat data in 2012 is 315 kt; the Luxembourgian
national statistics reports amounts of 420 kt.
Data
difference
[LU Stat 2013] reports 105 kt more than Eurostat.
Explanation National HW data contains amounts of the following waste types: Clinical waste, Waste
medicines and pharmaceuticals, Waste mineral oils, Oil mixtures, Waste containing PCBs
and / or PCTs and / or PBBs, Wastes from the production and use of inks, dyes, pigments,
paints, lacquers, varnishes, Wastes from the production and use of resins, latex, plasticizers,
glues and adhesives, Wastes from the production and use of photographic chemicals and
materials, Wastes from metals and plastics surface treatment, Residues of waste disposal
operations, contaminated soils, Filter dust containing non-ferrous
Differences could not be explained.
Treatment
HW
treatment
As regards HW treatment: The amount reported under Eurostat is 2 kt in 2012 national
data is not available.
Data
difference
n.a.
Explanation n.a..
HW
import/export
Eurostat data for HW imports and exports is not available on the LoW code level for 2012
[Eurostat WShip 2012]. According to the competent authority HW data has been reported
to Eurostat according to Basel-Y-code level.
National data on waste exported and imported is available, though this data is only for
waste that has to be notified. It can only be assumed that a large amount of these wastes is
hazardous.
- Amounts of waste requiring notification exported in 2012 amounted to 697 kt
- Amounts of waste requiring notification imported in 2012 amounted to 14 kt
Data
difference
n.a.
Explanation Data according to the Basel Convention on the Control of Transboundary Movements of
Hazardous Wastes and their Disposal has been reported to Eurostat according to Y-code
but category of waste according to the List of Waste codes has not been included in
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reporting. For this reasons correct amount of HW imported and exported cannot be
defined, as Basel-Y-codes includes all amounts for which a notification is required, this can
be both, hazardous and non-hazardous waste.
Investigated data discrepancies
− The extremely high statistical gap of 99% remains.
− The reason is that HW imports and exports could not be definitely clarified
− The statistical gap could not be fully explained
5.3.9 Particular issues with statistical data in the Netherlands
In the Netherlands the Ministry of Environment annually publishes aggregated data on HW at
Statistics Netherlands (StatLine) that is available to the public.23 The HW generation and treatment
data reported to Eurostat is based on national transport register data collected. There is a central
national electronic tracking system established at the National Waste Notification Bureau (Landelijk
Meldpunt Afvalstoffen) for reporting HW transports by companies and waste collectors. However, in
general there is no reporting obligation to the competent authority for HW as well as no electronic
register covering all steps of HW management.
National data on HW generation for 2012 is not publicly available. The public database
Afvalmonitor provides data until 2010 on an aggregated level for the origin and treatment options
applied. Data on HW is only available for selected treatment options, not giving a complete picture of
the generation situation in the Netherlands. A general overview on HW generation is publicly
available for the time period from 2006 – 2010. According to national statistics in 2010 3,819 kt of
HW were generated, of these 38% (1,452 kt) was generated by construction and demolition
activities. Regarding HW treatment data for the Netherlands, national statistics and statistical
evaluations provide some indication with regard to HW landfilled (460 kt) and incinerated (66 kt),
but do not give a complete picture of the treatment situation, even if data are available via the
national tracing system. Comparing data for 2010 in total 415 kt of HW was landfilled, 1,966 kt
recycled and 1,130 kt incinerated with or without energy recovery. The same situation is given for
national data on HW imports and exports. Permits of Dutch waste shipment notifications are public
on company level, but the database module provides quantitative data only for the notified amount,
but not for the actual values imported or exported, thus data are only available based on Eurostat
data.
23 http://statline.cbs.nl/Statweb/dome/?TH=5560&LA=en
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Table 5-10: Summary on statistical data, differences and explanations for the Netherlands
Eurostat data (2012)
Statistical gap
at Eurostat
data
Generation
Treatment
(excluding
Annex 2
WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
4,860 kt 4,456 kt 788 kt 870 kt 486 kt 10%
Explanation
for gap
− Based on the reporting obligations in the Netherlands it seems that a complete
overview of HW data should be available in general, but is not publically available. The
calculated gap of up to 10% in 2012 can be explainable by immanent reasons (e.g. wet
vs. dry, loss of weight by pre-treatment activities (drying), other codification used for
treatment technologies, on-site treatments etc.)
− Also, the gap seems to be based on the difference between data reported and data
publicly available.
− Further reasons might be in different codification for treatment techniques, which are
not related directly to the European R/D-codes.
− A final clarification of the reasons for the data gap could not be conducted
Comparison of national and Eurostat data and explanations (2010)
Data
comparison
. Eurostat 2010 [NL RIJK 2013b]**
HW generation 4,485 kt 3,819 kt *
HW treatment 3,798 kt 3,819 kt
* excluding dredging spoils (baggerspecie), amounting according to Eurostat 267 kt in 2010
** Data from 2010, only source from 2013
Generation
HW
generation
The amount of generated HW in official Eurostat data in 2010 is 4,485 kt; the national
statistics reports for the same year reports 3,819 kt generated HW excluding dredging
spoils, amounting according to Eurostat 267 kt in 2010
Data
difference
National statistics from the Netherlands report 399 kt less than Eurostat in 2010 (including
the amount of 267 kt of dredging spoils)
Explanation No explanation could be found or clarified.
Treatment
HW treatment As regards HW treatment: The amount reported under Eurostat for 2010 is 3,798 kt and in
national statistics it is 3,819 kt.
Data
difference
The data difference amounts to 21 kt more HW treated in 2010 according to national
statistics.
Explanation No explanation could be found or clarified.
HW
import/export
According to Eurostat data HW exports and imports in 2012 were:
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Export (Eurostat, estimated) Imports (Eurostat, estimated)
788 kt 870 kt
No comparison possible due to missing national data on imports/exports (data only partly
publically available)
Data
difference
n.a.
Explanation Since national data on generation and treatment of HW is only available for 2010, Eurostat
was checked for HW import/export data in 2010. But for 2010, data are available at
Eurostat only on the Basel-Y-code level. A distinction between hazardous and non-
hazardous waste based on LoW codes is thus not possible.
Investigated data discrepancies
− Based on Eurostat statistics a statistical gap of approximately 10% can be calculated
− Mostly no explanation for gaps
5.3.10 Particular issues with statistical data in the United Kingdom
In UK all environmental data are collected and processed by UK Competent Authorities. Operators
with an environmental permit have to complete documents to the Competent Authority including
information on the waste they have received or removed from their site. Reporting is done
quarterly. The Competent Authority uses this information to compile national waste statistics.
In practice, there was a change in the notification/ reporting system for HW in the UK in the last
years. In the former system waste producers had to pre-notify a waste movement at the authority
which had to confirm the transport beforehand. Within this system the authorities had an excellent
overview on waste transports but the system caused a high administrative burden, both on industry
and authority level. The current system is administered at industrial level and the authority is not
involved in pre-notifications. Waste producer and waste treatment companies have to report
quarterly their waste movements. The authority collects a fee for each waste movement.
Detailed data on waste amounts (6-digit level) is available at the UK Competent Authorities
providing MS-Access data bases for each year including information on amounts, location of
generation and destination and treatment operation according to LoW classification. Further
aggregated HW data is available for industry sectors according to the NACE codes.
Table 5-11: Summary on statistical data, differences and explanations for the United Kingdom
Eurostat data (2012)
Statistical gap
at Eurostat data Generation
Treatment
(excluding Annex
2 WStatR)
Export Imports
Difference (Gap)
(GEN - EXP + IMP) -
TRT
Eurostat Eurostat Eurostat,
estimated
Eurostat,
estimated calculated calculated
8,452
(7,631)* 2,673 173-174 70-77
5,676 – 5,682
(4,854 – 4,862)*
67%
(64%)*
*updated data from July 2015
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Explanation for
gap
Reason for relatively large gap:
Official (national) statistics report 5,931 kt of HW generated in 2012 for UK, which deviates
from the reporting by Eurostat. The difference can be explained by significant double-
counting of ‘secondary’ waste (2,250 kt) in the statistics by Eurostat (see section below).
Due to a recent revision of the Welsh figures, the Eurostat data on HW generation in the UK
was updated in July 2015. The before reported number of 8,452 kt was changed to 7,631 kt.
The difference can be allocated to revised amounts of ‘secondary’ (double-counted) waste
and does not affect the officially reported 5,931 kt of generated HW in the UK in 2012.
Referring to this ‘secondary’ waste, the UK views this all to be double counted waste
because it is waste removed from treatment sites (i.e. waste resulting from waste
treatment operations such as shredder residues). The UK authority mentions that this waste
has definitely already been captured elsewhere in the UK’s generation estimate and
Eurostat fully acknowledges the present double-counting without reasoning why the double
counted waste amounts are included in the data published by Eurostat.
According to Defra, there is also additional evidence that in 2012, at least 1,620 kt of HW
lost its hazardous status during intermediate treatment (i.e. after capture by the
generation template but before capture by the treatment template). This intermediate
treatment explains a large amount of the remaining gap between reported figures for HW
generation and final treatment.
The reasons for the remaining gap of approximately 1,535 kt – 1,541 kt (~26%) cannot be
precisely explained. According to Defra, waste generation and final waste treatment are
measured in different ways and waste generation comes from a lot of sources. This allows
for differences in reporting statistics. More investigations would be needed to determine if
there is a true gap and what the causes are.
Comparison of national and Eurostat data and explanations (2012)
Data
comparison
HW
generation
(absolute)
[Eurostat WASGEN 2012] [UK EA Stat 2014] [UK EA Stat
2015]
8,452 kt (March 2015)
7,631 kt (July 2015)
5,931 kt
HW treatment
(absolute)
[Eurostat WASTRT 2012] [UK EA Stat 2014] [UK EA Stat
2015]
2,673 kt 2,673 kt
Generation
HW generation The amount of generated HW in official Eurostat data in 2012 is 8,452 kt (or respectively as
updated 7,631 kt); the UK EA Statistics reports for the same year 5,931 kt generated HW.
Data difference UK EA Statistic reports 2,521 kt (or respectively 1,700 kt) less than Eurostat
Explanation The difference between the two datasets can be explained due to double-counting of
‘secondary waste (as already indicated above). The double counting is as a result of the data
which Eurostat insists on including in the waste generation estimates but which is removed
from the UK’s estimates. This relates to 1,870 kt (waste from waste sites) and 650 kt
(wholesale of waste and scrap) - a total of 2,520 kt. Subtracting this figure from the 8,452 kt
indicated on Eurostat would leave a generation total of 5,931 kt for 2012.
Due to a recent revision of the Welsh figures, the Eurostat data on HW generation in the UK
was updated in July 2015. The before reported number of 8,452 kt was changed to 7,631 kt.
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The difference can be allocated to revised amounts of ‘secondary’ (double-counted) waste
and does not affect the officially reported 5,931 kt of generated HW in the UK in 2012.
In terms of practice, the UK waste generation statistics brings together a large number of
processes, some of which draw on EA permitted facility data and some from other
sources. Although the UK does not have any formal measures of uncertainty, according
DEFRA the level of uncertainty is fairly high.
Treatment
HW treatment As regards HW treatment: The amount reported under Eurostat and UK EA STAT for both
datasets is 2,673 kt in 2012.
Data difference None.
However as explained above, there remains a statistical gap between HW generation and
treatment of approximately 1,535 kt – 1,541 kt (~26%).
Explanation Waste treatment is mostly based on permitted site returns for which there is good quality
data as the returns are mandatory. Some estimations are made for waste treated under
exemption, but these are subject to extreme levels of uncertainty because the whole
purpose of exempt activities is that they do not require the operator to return any details of
what they have done (or even if they are still active), so there is almost no information to
work with. Identifying final treatment is not easy and the UK accepts that the method used
here is not perfect. Waste received by transfer stations and other operations assumed not
to be final treatment are excluded, but this classification relies on generalisations so it will
only be approximated.
In this connection, there is also a concern that the regulator does not have sufficient
oversight (see earlier points under ‘record keeping’) to provide a mass balance of HW, that
is to ensure that all HW is correctly recycled or destroyed by incinerations.
HW
import/export
The used figures for imports (70-77 kt) and exports (173-174 kt) are estimated from
[Eurostat WShip 2012] and contain waste amounts considered hazardous according the List
of Waste (excluding e.g. wastes underlying the notification duties from the Basel
Convention which hare not hazardous according the LoW).
Data difference None
Explanation UK’s reported amounts to Eurostat on waste shipments according to the WSR are estimated
to be plausible. There are no statements to the contrary. It has to be noted, that reported
shipment data refer to notified amounts according to Basel requirements. Notified LoW
codes are not necessarily hazardous. For the purpose of this analysis only the hazardous
LoW codes were considered, leading to a significant lower amount compared to the total
reported shipped volumes.
Investigated data discrepancies
− The remaining gap of approximately 1,535 kt to 1,541 kt (~26%) cannot be explained definitely
− Waste generation and final treatment are measured in different ways which may lead to discrepancies
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5.4 Particular problems with hazardous waste management
The particular problems with HW management have been summarised and allocated according to
different thematic categories in order to include information across countries accordingly. This
provides an overview on major problems across the ten Member States that were assessed in depth.
All information is also included in the factsheets (Annex I/Chapter 10.1).
5.4.1 Problems as regards HW management planning and treatment capacities
− The National Waste Management Plan does not focus on HW; a dedicated strategy for HW by
analysing economic sector or important streams, using additional sources of information (BG)
− The National Waste Management Plan does not establish clear and measurable goals and
target levels for HW, so as to increase recovery and reduce disposal (EE, LV).
− Particular and important HW streams are not covered by Waste Management Plans (EE, oil
shale).
− HW management planning solely delegated to regional level with many regions involved and
no sufficient communication/coordination between regions resulting in different quality of HW
management planning and outdated plans (IT).
− Significant regional differences in waste generation and differences in waste treatment
operations applied; hindering uniform capacity planning (IT, North-Central-South).
− Heavier bureaucratic burden for waste companies in other MS, because of different
requirements at regions and several involved authorities in Italy to be applied by companies
operating on national/international level (IT).
5.4.2 Problems with particular waste streams and technologies
− Particular issue of oil shale production (high amounts, low recovery alternatives) remain (EE).
− Best Available Technology (BAT) requirements are not existent or not sufficient for specific
waste streams, as for oil shale (EE).
− Some cases identified where BAT were not adequately described in permit or environmental
monitoring was not sufficient (EE).
− Priority to increase collection of asbestos and waste oil (EE).
− Installations are planned/set-up but not operated; state-owned HW landfill is at present
without operator (tender was cancelled) (EE).
− High rate for depositing HW onto or into land for hazardous mineral waste and hazardous
household waste (FI).
− Difficulties in enforcing the waste hierarchy; issue is how to prioritise reuse and recycling
operations over other recovery operations which although lower down the hierarchy are
perfectly legal options (UK).
− Cases where HW is rather going to low cost treatment options rather than to BAT solutions,
reference to BAT (and thus the reference to the waste hierarchy) is not adequately reflected
in the implementation of HW management, e.g. in permitting procedures; this aspect
hampers investments in expensive new HW treatment technologies (UK).
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− State of the art technologies may be undermined by cheaper, albeit quite legal alternatives.
Investments in certain technologies, e.g. plasma technologies, are the premise of the private
sector which takes its steer from the Government’s HW strategy (UK).
5.4.3 Problems as regards data quality and reporting procedures
− There are some data discrepancies identified between the national WMP and National
Statistical Office (NIS) reports (BG)
− Pre-treatment is counted as treatment (EE).
− Differences in the amounts stored among two consecutive years (EE).
− HW reported as by-product, where in reality it exceeded limit values (in particular clinker ash
given to farmers) (EE).
− National data on waste exported and imported is available, though this data is only for waste
that has to be notified; correct amounts of HW imported and exported are not available (LU).
− Data collection in general is poor and should be improved (LV).
− EPA and Central Statistical Office (CSO) collaborate to compile data on waste generation. A
waste generation survey of enterprises has been conducted by CSO, this survey data
submitted to Eurostat included errors in reporting. The HW dataset reported to Eurostat for
2012 was not correct (IE).
− Formatting issues with annual reports by industry to the EPA, these can make completing the
annual report and other regular reports time consuming, e.g. regular changes of the template
that makes obtaining and compiling data time consuming, duplication of information between
the various different reports e.g. E-PRTR, ADR, Waste Treatment survey, the online interface
does not allow automatic entries (copy/paste) (IE).
− Appliance of different waste codes systems for import/export data (Basel-Y-code instead of
LoW code), hampering data comparison (IT, LU).
− Problems with the change of reporting system, from paper reporting to electronic reporting
system (IT).
− Electronic system not including tracking of waste shipments; hence no data on import/export
included (IT).
− Data on HW generation and treatment reported through the national reporting system
is complete but not publically available; most of the HW data is only available until 2010
(NL).
− HW data reporting via the National Waste Notification Bureau (LMA) uses different
codification for their treatment techniques, which are not exactly related to the European
recovery and disposal codes. It is difficult to directly transpose information accordingly (NL).
5.4.4 Problems as regards HW classification
− Entries of the waste classification system are not very distinct and can be interpreted widely
which may foster wrong classification (DE, UK).
− In some cases the waste is not classified solely on its properties but according to permits and
capabilities of the waste treatment facility which shall receive the waste due to its
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economically viable prices compared to other treatment options; in particular this is true for
waste of the same material but from a different source (DE).
− Regarding LoW mirror entries 17 03 01* and 17 03 02 the decisive criterion whether the waste
is classified as hazardous is the PAH content, but the threshold values are not harmonized
which causes a HW classification issues in the Federal States (DE).
− ‘Over usage’ of particular waste entries, only a limited amount of entries are used for huge
waste amounts, i.e. LoW chapter 19 − often the waste is not further allocated to a specific
entry according its origin or type but entries are used where cost-efficient market structures
are existent (e.g. currently LoW entries 19 12 11* and 19 02 04* dealing with mixed waste
fractions from waste management facilities are favoured due to the fact that they usually are
sent to incineration) (DE).
− Uncertainties exist due to the adaption of waste classification to the CLP Regulation. In
particular the new requirements for Hazardous Property (HP) 10 (concentration limits for lead
compounds) may have significant impacts that more wastes have to be classified as hazardous
and are directed to underground storage. Additionally it could lead to a contact ban for
workers due to health and safety regulations (DE).
− In the case of HP 5, the new provisions could also cause more wastes to be classified as
hazardous, especially in the case of construction and demolition waste (DE).
− Connected to classification, further guidance is needed as regards end-of-waste criteria and
definition of ‘by-product’ (EE).
− Uncertainties with HP 14 (EE); problems with parallel classification systems (CLP for chemicals,
Dangerous Substances Directive and Dangerous Products Directive for waste); to avoid a dual
classification system, industry already adapted classification of HW to CLP before the authority
forced them to do, which leads to misclassifications especially regarding HP14; missing
legislative framework for the assessment of HP 14 still is an intense problem (UK).
− There seems to be uncertainty about which laws to follow for the assessment of HP14. The
Law 28 of 2012 clearly declares to use the criteria of ADR (transport regulation) for the
classification of waste being technically feasible and with reproducible analytical results for the
assessment of H14 whereas the National State Council wrote that this cannot be used
anymore for classification of waste in order to assess HP14. Instead Regulation (UE) n.
1357/2014 should be used which refers to Annex VI of Directive 67/548/EC (IT)
− There are no guidelines / helpdesks or other (IT)
− No official helpdesk is available for HW classification support; several state institutions that
are able to give advice regarding HW classification: e.g. State Environmental Service (LV).
− At present, bilge water amounts from international navigation is not reported to national
authorities and some guideline with similar experience would be welcome (LV).
− European criteria for waste classification are based on substances and compounds (as in CLP
Regulation), analytical results for wastes are usually in elemental form, and same elements can
form vast variety of different compounds, depending on conditions. Thus it is not clear which
hazards and limit values apply to a certain waste. (FI).
− National test methods to be used in waste classification have not been clearly defined,
reference is made to the tests of chemicals legislation (see above) however, it should be
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defined which tests are to be used in cases where there are several test methods available
(CEN tests for wastes, UN ADR tests, tests of chemicals legislation) (FI).
− Applying two different systems at national and European level as regards HW legislation
concerning classification of waste and classification for transboundary movements of HW
(Basel-Y-codes and/or LoW) connected to missing guidance/advice with consequence that
companies apply different classification systems (IT); IT and LU are following the Basel codes
reporting and data is collected with Basel codes at company level (while some other EU MS
collect data as LoW code at facility level and then ‘transform’ them to Basel codes, which they
then report.
− Occurrence of accidental or deliberate misclassification of HW by HW producers (UK).
Classification of particular waste streams that causes problems:
− WEEE; classification as hazardous as soon as one part is hazardous. (DE)
− Excavated soil; different approaches for each Federal State, missing standards on HP 14 (DE),
mirror entries, such as contaminated soils (EE).
− In general the classification of mirror entries is problematic in some cases (LV).
− Solvents, washing liquids and mother liquor; missing threshold values to enable a definite
classification as aqueous, halogenated or other solvent (DE).
− Classification with regard to halogenated waste may differ due to different analytical
techniques (NL).
− Certain mineral wastes, e.g. slags from household waste incineration; classification as
hazardous or as non-hazardous as potentially hazardous substances might be bound in the slag
matrix (DE).
− HW reported as by-product, where in reality it exceeded limit values (in particular clinker ash
given to farmers) (EE).
− Waste containing POPs (EE).
− Oil containing liquid wastes (LV).
− Classification of bio-hazardous waste (e.g. in hospitals) is unclear and the information related
to it is very difficult to find. Detailed instructions on classification with “biohazard”-symbol is
needed (FI).
− Cytostatic hospital waste was often declared as infectious, although it should have been
declared as toxic. Inspections of 35 hospitals have shown that cytostatic hospital waste was
often declared as infectious, although it should have been declared as toxic (NL).
− Certain LoW entries are ambiguous (FI):
There can be an absolute waste entry as well as a mirror entry for certain wastes (for ex.
17 01 01-03 vs. 17 01 06*/17 01 07).
Wastes with same composition can have an absolute non-hazardous waste entry in one
section of the waste list while in other section the same waste falls under a mirror entry
(for ex. ELV plastics with POP-BFR:s 16 01 19 vs. WEEE plastics with POP-BFR:s 16 02
15*).
The level of detail in the LoW for different economic sectors is very different
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Certain wastes are missing altogether from the LoW (for example production waste
from manufacturing organic insulation materials for buildings, such as pulp wool
containing boric acid and borax).
The LoW entries are not totally up-to-date with the current production practices (for
example production of bio-fuels; anaerobic digestion).
Particularly critical is the LoW code for packaging waste (15 01 00 group of code) (IT).
5.4.5 Problems as regards collection, storage and labelling
Problems as regards collection are:
− A part of the collected waste oil is not captured by the official sector and is led to non-
permitted activities; to avoid: a guide has been prepared for waste oil generators to inform on
the danger of unauthorized disposal and the damage from non-compliant incineration (BG).
− Collection of particular waste streams (asbestos and waste oil) is not sufficient/has to be
improved; informal sector involved (EE).
− Coverage as well as enforcement of provisions on waste oils and contaminated C&D waste
could be improved (LV).
− There is probably an informal sector involved in waste oil as it has a commercial value (LV).
− Waste streams generated in small quantities but from scattered sources (waste oils and
medical waste) from small medical centres are difficult to be captured; the same is the case
with some HW quantities contained in construction waste (LV).
− WEEE, parts that is more valuable (e.g. metal) are often disposed of as scrap metal and not as
WEEE; in order to ensure that equipment is taken to waste handlers and collection points as
complete, no waste handler may accept components of WEEE, incomplete WEEE, and WEEE
that is classified as HW (EE).
− Issue of unreported HW due to a lack of collection facilities for HW from a diverse range of
sources, mostly small scale, including households, small businesses and farms. Also, minor
problems with household HW that is not correctly sorted out and ends up in the residual bin
(IE).
− Currently no formal system for collection of farm HW (IE).
− Collection is controlled by too many authorities (more than five in Italy), thus making
coordination and planning difficult (IT).
− Companies need license to engage in HW collection, controls are infrequent (NL)
− Non-confirming packaging of collected wastes occurs regularly (UK).
Problems as regards storage are:
− Little storage space available. Due to the resulting high price for storage, it is often cheaper to
treat HW abroad (IT).
− Storage of HW at production sites does not require an environmental permit if the
operation itself does not require a permit. In this case it is possible to store HW without
being controlled by the authorities and without having an environmental permit (FI).
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Problems as regards labelling are:
− Companies, which do not have a person assigned specifically to deal with waste management
issues, might have problems with correct labelling; consultancy assistance must be asked for
(BG).
− SMEs partly assign HW the wrong entry due to missing knowledge and also label the waste
incorrectly; although guidance documents are provided, they are partly not considered by
SMEs with the consequence that sometimes waste disposal facilities need to change the
received waste’s classification (and labelling) before treatment (DE).
− In some cases there are uncertainties how to label containers which contained hazardous
waste and were recently emptied (DE).
− Difficulties occur between the different labelling requirements for different modes of transport
and the composition of the waste. Waste classification prior to labelling (IT).
− Two labelling procedures are used in parallel (EU rules for labelling substances and ADR) (IT).
− Missing national guidelines and helpdesks for classification (IT).
− Missing labelling templates for certain waste streams (provided for 24 hazardous substances
by Waste Management Association, however missing for other waste streams) (NL).
− HW producers are obliged to fill out Material Safety Data Sheet (MSDS), however in practice,
the HW generators do not always fill out a MSDS. In general the MSDS is only delivered to the
customer for major waste flows. For other waste flows, waste management companies need
to use the information on composition to check the MSDS on the internet to obtain
information on harmful components. Therefore they have to make an own evaluation. (NL)
− Wrong labelling might occur on a case-by-case basis especially in SMEs, e.g. sometimes the
drums (‘container’) used for waste movements are re-used and therefore still show the old
label. Waste treatment operators then have to assess the waste again in an acceptance testing
(UK).
5.4.6 Problems as regards record keeping
− Waste producers and waste treatment facilities sometimes face challenges with correct
record keeping depending on their personal capacity and infrastructure, e.g. in the case of
civic amenity sites without a weighing possibility and trained staff (DE).
− For countries with obligations at Federal State level: duties for signatures are organised
differently across Federal States, e.g. when has to be signed and who has to sign; a
harmonisation amongst Federal States is favoured by the industry (DE).
− Difficulties with back-tracking of waste transports amongst Federal State level: data is
collected at national level (e.g. Central Coordination Point Waste) but only coordinates
information, while data is kept in databases on level of the Federal State; in case there are
national waste transports with several interim processes (e.g. interim storage, pre-treatment,
recovery, etc.) across several Federal States, consignment note and waste treatment proof
only cover the transport between two processes (DE).
− Problematic are the exemptions of the record keeping duties for WEEE and batteries (DE).
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− Detailed record keeping regulation, but only companies with a permit have a reporting
obligation to competent authority (FI)
− Lack of user-friendliness of applied (new) electronic record keeping system, potential for
improvement (IT, LV).
− Doubts as concerns the correct application of Article 18 (waste to be accompanied by certain
information) of WSR (IT).
− Change of record keeping system results in decreasing overview of authority and data quality –
change from pre-notification of waste movement with confirmation of authority to quarterly
reporting (after movement); decrease of control possibilities and data quality (UK).
− Duty to notify premises is planned to be removed in order to reduce duplicate reporting
obligations (on the one hand the registration of premises and on the other hand the quarterly
reporting of HW movements); some industrial stakeholders fear that there is the possibility of
loss of traceability and accountability of the HW producer; authorities however state that an
updated registration system will be built around the current quarterly reporting system which
will maintain the current level of traceability whilst reducing unnecessary burdens for the
waste producers with regards to the duplicate reporting structure. The lack of traceability due
to the removal of the notification of premises may also influence permitting practices (UK).
5.4.7 Problems as regards permitting practice
− Problems with old/new permits in parallel: several facilities have permits stemming from
former national waste legislation; as facilities have changed over time (technological
adaptions), permits were adapted or respectively additional permits granted on top of the
initial permit − sometimes it is problematic for authorities to control these permits, since there
is no holistic version of the most recent permit version but a variety (20 to 30) of permits and
permit adaptions; in addition, it is challenging for facility operators to identify which legal
requirements have to be fulfilled related to their current state of the permit. (DE)
− Non conformity of different environmental legislation: The baseline report in the frame of the
Germany BImSchG (Federal Immission Control Act) permitting does usually not cover waste
related issues; authorities are not informed about the baseline situation regarding waste in
the respective facility. (DE)
− Permitting procedure can be slow due to a lack of capacity at the competent authorities (IE).
− Very long permitting procedures between four and six years, hampering investment and the
establishment of new (recovery) technologies and leading to high export rates (IT).
− Public opinion is critical, leading to permits being only granted with stricter limits compared to
national and European legislation; difficult to obtain approval/permit for a HW treatment
facility, authorities provide little information to public in order to disseminate fears (IT).
− Criteria applied in public tender for HW treatment are primarily focussed on the cheapest
offer, leading to exports in technically lower equipped facilities (IT).
− Waste oil incinerators with a thermal throughput below 0.5 MW, which are commonly used in
workshops and garages to burn waste oils to generate heat, are not covered as technical
installation under the Waste Incineration Directive and are exempted from permit procedures,
this hampering recovery of waste oil (UK).
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− Permits for HW treatment plants are not always easily accessible to the public (NL).
As regards the implementation of the mixing ban:
− Mixing ban allows derogations for specific activities if in accordance with BAT and with
environmental permit, but several cases of illegal activity, penalties have been given (NL).
− Mixing ban is in place, but mainly the control system is difficult to implement systematically
due the large number of small and medium sized companies. Also there is different local
interpretation and application of the mixing ban (IT). Contaminated land sites do not need
permit; hence are relatively uncontrolled; in practice, contaminated soils hazardous and non-
hazardous can be mixed to give a non-hazardous output; this is very difficult to enforce (UK).
− In the frame of the current reporting system (see ‘Record keeping’), there might be cases
where waste treatment operators bulk up HW in a way that one drum (‘container’) of HW is
combined with other drums containing non-HW; this system of dilution cannot be traced easily
by the authorities in the reporting new system (UK).
− Not all articles dealing with mixing rules in the WFD are transposed and reclassified, in terms
of enforcement of the mixing rules there is a lack of traceability on plants that pre-mix waste
that are difficult to verify (DE).
5.4.8 Problems as regards enforcement and inspections
− There is a heavy administrative burden on the inspection authorities having an adverse effect
to the quality of checks (BG).
− Inspections are done routinely for IPPC companies, but due to work load, less frequently for
the non-IPPC companies (BG).
− Huge amount of annual reports and transfer of records into National Information System
(40,000 reports by 8,000 companies yearly) have been submitted, checked and recorded. This
is a heavy administrative burden posed on the inspection authorities, however the situation is
expected to improve with introduction of the Electronic Information System (BG).
− Penalties imposed in reality for non-compliance with environmental permits are much lower
than the maximum rates (EE).
− High number of authorities involved in inspections; in Italy collection is controlled by more
than five responsible authorities, thus making coordination and planning difficult (IT).
− Inspections are in place, regulation is very strict, but comprehensive implementation is limited
by the large number of small and medium sized companies (IT).
− No sufficient rules for inspections; on-site inspections often take the form of occasional
control during collection and are not regular; document controls are more frequent - penalties
are rather given for documentation errors such as mistakes when filling out forms rather than
for mistake in waste management operations. (IT).
− Insufficient communication between authorities and companies; authorities are not aware of
problems that companies face (IT).
− Significant regional differences in implementation of HW management are existent hampering
uniform planning and enforcement of waste management (IT, North-Central/South).
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− A lot of activities are carried out by brokers and dealers without own treatment capacities,
partly only dealing with transport; waste producer is not always in direct contact with the
treatment/disposal facility − this might be a further reason for differences between legal
regulation and practical implementation (IT).
− The integration of the registration duties for premises of HW producers and the reporting
duties for waste movements are seen critical by industry as the traceability of HW
management might worsen (UK).
− Enforcement powers against ‘sham’ treatment are not sufficiently robust, meaning that the
legislation is satisfactorily implemented but the implementation on the ground, e.g. the
promotion of high treatment standards in industry, leaves room for improvement (UK).
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Good HW management practices in the Member States
The focus of this chapter remains on the ten Member States included in the in-depth assessment on
HW management undertaken in Chapter 5.
6.1 Good examples as regards HW management planning and
treatment capacities
− Development of detailed waste stream specific plans, that include specific targets and
management principles for HW (in the case of the NL 83 sectorial plans, for specific non-
hazardous and HW streams)
− Good cooperation with mainly neighbouring countries and reaping the benefits of the
European market for the environmental sound treatment of HW. The standards in
neighbouring countries are at the same high level and make cooperation possible. (IE/UK, NL)
− HW prevention is included in a national plan and is also brought to operator/facility level;
e.g. in Luxembourg the action “SuperDrecksKëscht fir Betriber” is an instrument used in HW
prevention and is intended to provide tailored waste prevention advice to enterprises (LU).
− The Waste Prevention and Management Plan is an instrument that every company has to enclose when applying for an operating permit for classified establishments (LU).
− Producers/ collectors have to justify in their consignment notes whether the waste hierarchy
was reflected when choosing the further treatment of the waste (UK).
Table 6-1: Good practice example from the United Kingdom
‘Support for actors in waste management with a guidance framework’
→ Competent Authorities in UK provide a holistic support framework
Hotlines to report environmental incidents or to seek advice from waste specialists available
Support for different waste streams and for all aspects of waste management available online
Guidance framework consists of general information, step-by-step explanations, FAQs, etc.
Information is tailored to all actors in waste management and refers to regional differences in UK
In the UK, a holistic support framework is provided for all involved actors (e.g. waste producers,
waste treatment operators) in waste management.
The official website of UK’s government provides a separate section dedicated to environmental
management. Within the subsection ‘Waste’24 the respective governmental departments provide an
extensive overview on different aspects in general waste management. The provided information is
divided in different sections ranging from introductory guides to basic information on inter alia
(hazardous) waste, waste movements, permits, licences, storage, treatment, end-of-waste and
24 https://www.gov.uk/topic/environmental-management/waste
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disposal. Additionally, information on separate waste streams such as batteries, WEEE, Packaging,
waste water, radioactive waste and clinical waste is given.
Each available section is further structured along the main aspects and contains the most important
definitions, step-by-step explanations and answers to frequently asked questions. In many cases
also a phone hotline is provided for direct communication with the respective UK Competent
Authority to seek further advice (e.g. regarding classification of waste) or to report environmental
incidents (e.g. fly tipping, littering, etc.). The technical guidance document (WM3) on the
classification and assessment of waste should be separately mentioned in this context as it is seen as
a helpful tool from actors in waste management inside and outside the UK.
The online provided information is also tailored for the use of those actors involved in day-by-day
waste management processes and recognizes the regional differences for England, Scotland, Wales
and Northern Ireland.
6.2 Good examples with particular waste streams and technologies
− Certain HW incinerators are equipped with energy recovery installations, hence, pollutants
are phased out of the recycling circle while concurrently energy is generated (DE).
− Waste legislation is largely based on EU legislation, but in some cases includes stricter
standards and limits than those applied in the EU (FI).
− Landfilling of suitable asbestos waste in non-hazardous landfills is permitted (Council Decision
2003/33/EC) however, no limits are specified. The Irish EPA has therefore published a
Guidance note on Landfilling of Asbestos that sets out a discussion basis and guidance in
relation to the classification of landfills accepting asbestos waste (IE).
6.3 Good examples as regards data quality and reporting procedures
− Waste databases provide transparent information on waste composition, generation and
treatment (e.g. AIDA in North-Rhine-Westphalia and database on HW statistics, Bavaria) (DE).
− Waste data is easily accessible and available to public including e.g. generation and
treatment, origin (branches), regions (for generation and treatment), treatment options
(waste streams as per R and D code on regional level) and/or including information on export
and import of HW (EE, IT, NL).
− Introduction of an electronic waste registration system; recently established (IT).
− Development of good practice guidance for registration of HW, electronically available (NL).
− Well established electronic record keeping system for every HW movements within the
State, recording obligation applies to everyone involved in HW management. Penalties are
issued for not reporting HW movements (IE).
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− An electronic record keeping system is in place, covering all steps from generation to final
treatment. Although the electronic system is easy to operate and practical, especially
compared to paper forms, its functionality can be improved (NL).
− Yearly waste reports have to be submitted to the EPA. Since the revision and simplification of
the reporting format data reporting has been improved and is straighter forward. There are
some minor issues with annual reports to the EPA that relate to formatting (IE).
Table 6-2: Good practice example from France
‘Shared responsibility in waste management’
Article 15 of the WFD regulates the responsibility for waste management.
In a ‘shared responsibility regime’, the waste producer shares responsibility for the ultimate fate of the waste even though the waste might be managed by intermediate actors. This may foster self-regulation of the industry.
The responsibilities for actors in waste management as they are laid down in French waste legislation are seen as ‘good example’ from industrial HW management stakeholders.
Article 15 of Directive 2008/98/EC regulates responsibility for waste management: “Member States
may specify the conditions of responsibility and decide in which cases the original producer is to
retain responsibility for the whole treatment chain or in which cases the responsibility of the producer
and the holder can be shared or delegated among the actors of the treatment chain.”
Member States may further define in their legislation the shared responsibility regime among actors,
where the waste producer still shares responsibility for the ultimate fate of the waste although the
waste might be managed by intermediate actors. This fosters self-regulation of the industry, as the
initial producer and all the downstream holders are responsible for the good treatment of the waste.
So the producer rather delivers the waste to waste management companies in which they trust.
Hence, it is very common for waste producers to commission audits regarding proper waste
management. As a consequence, the shared responsibility regime may strengthen an
environmentally sound treatment of waste. By contrast, if the waste producer can shift the entire
responsibility to further actors, this may foster treatment activities with lower quality standards
connected to lower prices.
In the case of France, the producer is responsible for the waste until the final treatment, even if
there are intermediate actors (e.g. traders, dealers) (see Article L541-225). Additionally, the producer
is responsible for the compliance of the chosen treatment with the waste hierarchy (Article L541-2-
1). The control of the waste management chain is followed via a consignment note covering all
movements from the initial waste producer to the final operator of the treatment. Penalties are laid
down, on the one hand for the producer (Article L541-3) and on the other hand for all other actors
involved in the management chain of the waste (Article L541-4), if the treatment is not achieved
correctly. Additional duties for the producer are to provide necessary information to the
downstream holders of the waste (Article L541-7-1) and to provide information and justification for
the chosen treatment option to the competent authorities (Article L541-9).
25 Articles of Table 6-2 are taken from : French environmental legal code ‘Code de l’environnement’
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6.4 Good examples as regards HW classification
− Classification of wastes as ‘hazardous’ is supported by national documents/ordinances;
guidance. Helpdesk or support post-classification is in place (BG, DE, UK, LU, NL).
− Quick legal implementation of international standards on classification, e.g. the regulation for
the separation of and keeping separated of HWs (Regeling scheiden en gescheiden houden van
gevaarlijke afvalstoffen26) established in 2001 already included the EWC which had only been
published in 2000 (NL).
− A national laboratory is available to conduct waste classification analysis, i.e. in cases where
classification is on the borderline and the owners have to refer to Material Safety Data Sheets
(MSDS) or conduct a laboratory analysis prior to classification decision (EE).
− Extensive support for HW classification is provided; waste holders obtain additional support
from the EPA and local authorities when correct classification of HW is difficult (IE).
− Improvement of knowledge and the participation of most companies in the SuperDrecksKëscht
with significant decrease of cases of re-classification (LU).
− Classification helpdesk available online (http://stoffen-info.nl/) provided by the Ministry of
Infrastructures and Environment that is responsible for the content of the helpdesk (NL).
− Problems of misclassification are detected by targeted controls (i.e. in NL control of 35
hospitals and misclassification of cytostatic hospital (infectious instead of toxic) (NL).
− Problems of misclassification are addressed by the regulatory authorities are trying to address
with the help of Environmental Service Association (ESA) and the waste management industry,
principally by providing more information to HW producers (UK).
6.5 Good examples as regards collection, storage and labelling
− Every company which has permit for HW management has a responsible person for waste
handling with proven knowledge and expertise (EE).
− Pilot project to determine the nature and extent of on-farm stockpiling of HW. The project
entailed the operation of six bring-centres for farm HW. The aim was to facilitate the
collection, recovery and disposal of HW from farms; quantify and characterise farm HW
(including de-registered pesticides), and research the need for a national farm HW collection
scheme (IE).
− Extensive guidance documents on relevant aspects for HW management (e.g. on permitting,
classification, transport, recycling, mixing, consignment notes and others) are accessible for all
actors in waste management on the website of the Environment Agency (UK).
− Specific support especially for small and medium enterprises in HW management is assured,
companies are supported and controlled at every step of HW management (LU, see box).
26 http://wetten.overheid.nl/BWBR0009515/geldigheidsdatum_05-02-2015#Artikel1a, accessed February 2015
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Table 6-3: Good practice example from Luxembourg
‘The involvement of organisation/institutions in HW management’
→ HW management is managed to a large extend by SuperDrecksKëscht (SDK)
→ Supports especially households and small business
→ Provides label ‘SuperDrecksKëscht® fir Betriber’
→ Runs information and awareness campaigns and provides training
HW in Luxembourg is managed to a large extend by SuperDrecksKëscht (SDK), established in 1985. In
2005 SDK got a legal basis by the concerning the functioning27. The action is organised by the
Ministry of the Environment (MoE) and includes the following tasks to be conducted by private
operators:
− the management of problematic waste from households;
− assisting and advising businesses and institutions in the public and private sectors to certify the
ecological waste management in these companies and establishments;
− promoting ecological waste management through actions of publicity and awareness;
− organising the collection of small quantities of waste from businesses and establishments in the
public and private sectors;
− storage, appropriate treatment and conditioning of problematic waste
The SDK is an integral concept for HW management that helps especially households and small
business to improve HW handling and correct disposal. Due to the fact that there are very few large
companies producing large HW amounts in LU (e.g. DuPont) and that they have their own integrated
HW management system SDK, rather focuses on SMEs (generally craft enterprises and garages). The
service of the SDK comprises correct HW classification and labelling, storage as well as authorised
waste collectors for these HW. In addition, where possible, less toxic and harmful substitutes for
used hazardous substances are recommended. Over 4,000 companies are participating in the SDK
which represents around 50% of the actively working population in LU.
The label ‘SuperDrecksKëscht® fir Betriber’ is a certification mark for environmentally sound waste
management. It is certified according to ISO 14024 and recognises companies and institutions from
the private and public sector that implemented the concept[LU Environment Agency 2015]. The
framework agreement to obtain the SDK label foresees audits including site-visits once a year in the
first five years and afterwards once every two years. During the audits, the improvement or
potential for improvement are documented and improvement strategies are elaborated together
with the companies.
LU has a good HW management originating from households currently 5.5 kg per inhabitant are
collected [LU Environment Agency 2015]. In terms of quantities 5,000 t/year of HW are collected
from households. A waste sorting analysis conducted in 2014 has shown that only 1% of the residual
27 Law of the 25 March 2005, http://www.legilux.public.lu/rgl/2005/A/0696/1.pdf
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waste is hazardous. This 1% mainly consists of three fractions, namely paints and varnishes, aerosols
and old medicine. It has to be noted that in LU all aerosols are considered as hazardous. The SDK
informs households, schools and the public in general through information campaigns, awareness
raising events as well as through education. Since recently the SDK has been attributed the
competency of train the waste management experts for companies, this does not only focus on HW
but it is a part of it [LU SDK 2015].
Good examples as regards collection are:
− A Green Innovation Award has been awarded in 2014 for a scheme on mobile collection of
household hazardous waste. This scheme entailed a dedicated phone line, collection from
addresses on certain dates and minimal costs from the municipalities (BG).
− HW collectors are required to hold a waste collection permit that is issued by a national
authority, an online register is implemented where permitted waste collector can be searched
(IE, LU, NL); daily updated in the case of LU.
− Controls of collection permits issued are carried out by the authorities every 5 years, but the
companies are in charge of verifying validity of their permit (NL).
− Publicly available web-based overview of collection points for municipal HW (FI).
− Several training and awareness campaigns (FI).
Good examples as regards storage are:
− Requirements for the entrance areas of storage points, laid down in guidelines from
authorities have proven to be effective and are generally well implemented (DE).
− BAT Guidance for the storage, repacking and blending of waste and HW (BAT Guidance Note
on Best Available Techniques for the Waste Sector: Waste Transfer and Materials Recovery) in
order to improve storage (IE).
− The ministry has published storage guidelines for hazardous substances (NL).
− Dual duties regarding storage of HW exist; at first following the regulations and guidelines of
the Environmental Agency and secondly following the ‘Health and Safety Executive’ which
provides guidance e.g. on the storage of flammable liquids or chemicals (UK).
Good examples as regards labelling are:
− Labelling templates are provided by a Waste Management Association for 24 hazardous
substances (NL).
− Guidance on labelling is provided by the authorities on request (LV).
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6.6 Good examples as regards record keeping
− An electronic record keeping system is in place in, covering all steps from generation to final
treatment; also the producer or manager of HW must ensure the registration of HW in a
special logbook in printed or electronic form (LV).
− Operation of electronic record keeping system combining different information and wide
access is given to authorities to introduce, verify and use data (DE, EE), in the case of BG for
IPPC permits and companies performing HW activities (BG).
− An efficient tracking and reporting system by the National Waste Notification Bureau
(Landelijk Meldpunt Afvalstoffen- LMA) is in place. [NL LMA 2015], however the electronic
record keeping system does not cover all steps of HW management. Also, data is not publically
available (NL).
− Existence of supervision of national tracking system; in case of the Netherlands The executive
Agency of the MoE ‘Rijkswaterstaat’ supervises the online national tracking system (Landelijk
Meldpunt Afvalstoffen) for reporting of wastes by companies (NL).
− Waste reporting system is part of the Environmental Register and is the management system
for data from waste reports (EE).
− Combination of different information in record keeping system, i.e. from environmental
permits, consignment notes and annual report database (latter two will be linked to each
other in near future) (EE) and is linked already (DE), ensuring back-tracking of all steps from
generation to treatment.
− All data about permitting and record keeping are collected and coordinated at national level,
although permitting is the obligation at Federal State level (DE, IT, UK).Within record keeping
system LoW are automatically transformed to Eurostat codes (EE).
6.7 Good examples as regards permitting practice
− The Helpdesk of the Ministry for Infrastructure and the Environment “InfoMill” organises for
operators and other involved actors workshops and trainings for permitting, such as the
Environmental Licensing Bill (Wabo) (NL).
− Permits are granted for collectors, transporters, dealers and brokers of waste by the National
and International Road Transport Organisation (Nationale en Internationale Wegvervoer
Organisatie –NIWO). The list of permits can be accessed online (VIHB list) (NL).
− Permits for landfills and other facilities for the treatment of HW are required to contain an
evaluation of the Best Available Technology (BAT) (in the Netherlands since 2013) (NL).
As regards good practice for the implementation of the mixing ban:
− Mixing ban is implemented and controlled within the ex-ante controls (prior to permitting;
permit conditions) and by regular site-visits during the operation period, exemptions are based
on criteria set by the government (however this options has not been used) (DE, UK).
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− Criteria for granting derogations from mixing ban are laid down in national legislation (AT, BE-
Flanders) or legislation contains a provision to include such criteria into legislation (DE).
− Exemptions of the mixing ban are clearly laid down in legislation (Decision) (NL), including:
o process noted under “Licensing in practice” (Including BAT decision) [NL WMP 2014]
o landfilling of equal HW types is not perceived as mixing; which types of wastes are
permitted to be landfilled together is laid down in the Decision on landfills and landfill
bans (Besluit stortplaatsen en stortverboden afvalstoffen -Bssa); it is forbidden to mix
HW in order to meet the acceptance criteria for the landfilling of waste
o mixing of HW is allowed for the manufacture of fuels used in cement kilns and other
incineration processes
o for all other instances mixing is regarded as a treatment (R12 or D13) and the necessary
environmental permits are required by companies to conduct mixing operations
o some specific limits are set up for waste mixed with the purpose to be treated by R1 and
D8/D9.
o all proposed mixing activities are reviewed against the existing Waste Plan taking into
account the LoW code of the waste; specific composition of the HW to be mixed is not
taken into account
Table 6-4: Good practice example from Belgium
‘Applicable and controllable legal implementation of the mixing ban’
Article 18 of the WFD lays down a ban on the mixing of hazardous waste
The non-binding guidance document on the WFD further clarifies and defines mixing and dilution
The mixing ban as implemented in Flemish waste legislation further substantiates Article 18 of the WFD
Clarification of the mixing ban regarding waste treatment, shipment, collection and handling in Flemish legislation as good example
The ban on the mixing of hazardous waste is laid down in Article 18 of the WFD and not further
clarified. The guidance document28 on the WFD further explains this article e.g. by providing
definitions for ‘mixing’, ’blending’ and ‘diluting’. However, the definitions and clarifications provided
in the guidance are not legally binding.
Industrial stakeholders have the concern that in case Article 18 of the WFD is generally translated
into national legislation without including further explanations (e.g. as provided by the non-binding
guidance on the WFD), the mixing/dilution ban may be not sufficiently applicable and controllable.
28 http://ec.europa.eu/environment/waste/framework/guidance.htm
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As a result, unclear permits on mixing and blending activities may be granted.
By contrast the implementation of the mixing ban in the Flemish waste legislation is seen as a good
example. The Flemish Materials Decree29 (2012) transposes the WFD and mentions the mixing ban
in Article 30 §3:
“The natural persons or entities who treat waste, cannot mix hazardous waste with other categories
of hazardous waste, nor with other waste, substances or materials. Dilution of hazardous substances
is also understood as mixing.”
The Materials Decree is practically implemented in the VLAREMA legislation30 from 2012. Article
4.4.2. further explains the mixing ban:
“It is forbidden to mix a waste with one or more materials with the aim to lower the concentration of
one or more components present in the waste in order to:
1° use a disposal method for the diluted waste which is not allowed for the non-diluted waste;
2° recover a waste which normally should be disposed of;
3° to use or transform a waste or intended raw material, in a raw material, for which the waste
or intended raw material does not qualify”
VLAREMA further clarifies the mixing/ dilution ban not only on treatment level, but also regarding
waste shipment, collection and handling of waste, including loading and unloading (see Article
6.1.1.1. 3° VLAREMA).
6.8 Good examples as regards enforcement and inspections
− Combination of different inspection obligations (IED, Seveso, etc.) to reduce administrative
burdens is welcomed by authorities and industry and should be further extended (DE).
− Combination of different authorities performing inspections together, i.e. inspectorate and
enforcing bodies such as police (NL).
− Realisation of independent audits for national performance on HW (in the case of Estonia:
one for HW arising from the oil-shale sector and one for the remaining HW by the National
Audit Office, indicating an independent accreditation and serious approach for identifying
areas for improvements) and follow-up meetings with Audit office and Ministry (EE).
− During inspection, storage containers and packaging, as well as correct labelling (not only
before transportation) are checked; also personnel if they are adequately informed (EE).
− Inspections are based on an inspection plan based on risk analysis (EE, UK); usually annual
inspections are performed, consignment notes, annual reports and permits are analysed prior
to inspection (EE).
29 https://navigator.emis.vito.be/mijn-navigator?woId=41855 30 https://navigator.emis.vito.be/mijn-navigator?woId=43991
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− Inspections are planned on the basis of the age of equipment, frequency of production
accidents, seasonal nature of the entity’s business, location of the entity (e.g., nature
protection zone, residential area, safeguard zone), regular complaints received, high level of
pollution produced by the entity, change of the operator, monitoring activity revealing that
the pollution limit is exceeded systematically, etc.) (LV).
− New requirements for inspections have been implemented recently introducing an
integrated system for HW management enforcement. Information on inspections and results
is publicly available (LU).
− New law including obligation for special training and education for inspectors for HW [LU].
− HW transport trucks are also regularly inspected on the borders in cooperation with other
authorities (EE).
− There are penalties for fly-tipping / illegal dumping and there is a 24h call phone, where they
can identify crimes in cooperation with the police (EE)
− Good inspection routines with clearly defined responsibilities. Planning of inspections is
based on the guidance of the Ministry of the Environment. Each regional ELY-Centre has
drawn up a plan for environmental inspections and issues an annual report summarising if the
targets of the environmental inspections plan have been achieved. The facilities are divided
into four categories based on their environmental effects and the frequency of the
inspections is defined according to the category (FI).
− Inspections are based on a National Strategic Plan; annual reports are being published and
are publically available. Planned inspections are carried out on a regular basis. Companies in
line with legal requirements and having a management quality assurance system are
controlled less frequently. (NL).
− Declarations on illegal practices can be made online 24/7 on the website of the inspectorate
(NL).
− In case of infringements a five step intervention policy exists, ranging from warning to
penalties and police reports with penal prosecution (NL).
− Site Inspections are performed at least annually, including HW management practises. (LV).
− Approximately four to five inspections per year are performed on-site per waste treatment
operator; each inspection focusses on special elements, such as traceability of kept records,
emission control, correct storage of waste, mechanical integrity of the process, etc.; after the
inspection, there are flow charts for the authority to select the enforcement policy.
According to the inspection results, there are several options such as ‘stop treatment
operations immediately’ or ‘issue advice to improve situation’ (UK).
− Authorities are fairly active in tackling waste crime, performing regular document and on-site
controls (UK, NL).
− Regarding the ‘duty of care’ regular internal audits are established. The same applies for ISO
9001 and 140001 certified facilities (majority of ESA facilities); under the permitting system all
waste facilities must have a management system preferably certified (i.e. ISO 14001) (UK).
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Table 6-5: Good practice example from Ireland
‘Improvement of waste legislation enforcement’
Minimum criteria and number of inspections to be accomplished by local authorities
All inspections to be conducted are laid down in an annual inspection plan. Additional information on inspections performed is included in the regional WMPs
All Prosecutions and penalties (searchable by year) for breaches of licences conditions can be found online
Environment Fund whose revenues were utilised for the enforcement of the provisions of any enactment relating to waste management, prevention of litter or protection of the environment and the maintenance of a network of local authority waste enforcement staff.
The Waste Management (Amendment) Act, 2001 provided for the establishment of an Environment
Fund, to be managed and controlled by the Minister for the Environment, Community and Local
Government. Revenues from the levies on plastic shopping bags and the landfill of waste are paid
into the Fund, which may be utilised for a range of purposes. Activities eligible for financial assistance
include for the enforcement of the provisions of any enactment relating to waste management,
prevention of litter or protection of the environment. The Government Waste Management Policy
Statement Delivering Change: Preventing and Recycling Waste (2002) pledged that Revenues
generated would be used to support appropriate waste management and environmental protection
initiatives which could not previously be undertaken because of resource limitations.
A key component of the agreed programme of measures in response to CJEU Case C-494/01 was a
commitment to fund the maintenance of a network of local authority waste enforcement staff. To
date since the CJEU judgement on the case €70m has been spent on the recruitment and continued
employment of 120 additional enforcement officers at a 100% rate of funding, resulting in a greatly
enhanced response on the ground with targeted exercises, road blocks and other waste enforcement
activities. A review group established in 2013 identified the existing strengths and weaknesses of
enforcement in Ireland and made recommendations for the future. A number of measures were
introduced to further enhance how waste legislation is enforced in Ireland. A core objective in this
initiative is to bring greater consistency of approach to the application of waste legislation and its
enforcement at local, regional and national levels.
To this end, the establishment of a lead enforcement authority in each of the three waste
management planning regions was recommended. Each of these new Lead Regional Waste
Enforcement Authorities would have responsibility for coordinating waste enforcement actions
within regions, setting priorities and common objectives for waste enforcement, ensuring consistent
enforcement of waste legislation across the three existing waste management planning regions while
still leaving local authority personnel as first responders on the ground to specific breaches of waste
legislation. Additional enforcement staff will be recruited by the lead authorities. While reduced
levels of revenue are available from the Environment Fund due to the success of the landfill and
plastic shopping bag levies funding commitments can only be given on a year by year basis. Financial
support for waste enforcement will increase to an overall waste enforcement grant of €8M in 2016.
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6.9 Good examples as regards cooperation and communication
− Good information flow between authorities and companies, the authorities are well aware
of problems in the private sector (FI).
− Cooperation with neighbouring (industrial) countries that have same high level standards to
reap the benefits of the European market for the environmental sound treatment of HW (NL).
− Involvement in IMPEL network and bilateral agreements on cooperation mainly with Belgium,
Germany and UK, but also with China. This cooperation network helps countries to agree on
common procedures or parameters regarding inter alia the implementation of EU waste
legislation (NL).
− National organisation with regional representatives to exchange information, knowledge and
experiences on HW (DE, see box).
Table 6-6: Best practice example from Germany
‘Interlinkage of regional authorities on national level’
German federal working group for waste (‘Bund/Laender-Arbeitsgemeinschaft Abfall (LAGA))’
National organisation with regional representatives
General aim to secure a homogenous enforcement of waste legislation across German Federal States
The so-called ‘Bund/Länder-Arbeitsgemeinschaft Abfall (LAGA)’31 is a federal working group for
waste in Germany. The working group was established in 1963 with the aim to secure a homogenous
enforcement of waste legislation in Germany.
To reach this aim, information and experience are regularly exchanged and discussed between the
national (German Environmental Ministry) and regional level (Environmental Authorities of Federal
States). Additionally, a close cooperation between the LAGA and relevant associations as well as
other German institutions is ensured. In order to further develop laws and to represent Germany at
the European and international level, the LAGA develops positions and suggestions. Regarding
practical issues of waste management within the Federal States, the LAGA elaborates instruction/
information sheets and guidelines on aspects of waste management as e.g. waste classification,
sampling or on general treatment of waste streams.
The LAGA is a national organisation where representatives from the regional Federal States
(environmental authorities/ ministries of the 16 Federal States) and from the National Environmental
Ministry work together equally. Currently, the LAGA is further organised along three committees
(Product Responsibility, Waste Law and Waste Engineering).
This approach is especially favourable in case that (hazardous) waste management is administered
and enforced on regional level whereas the waste legislation is valid on national level.
31 http://www.laga-online.de/
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Recommendations to improve HW management
7.1 Recommendation addressing the European Commission
Check and improve European List of Waste (LoW), in order to:
− adjust the level of detail for different economic sectors;
− add additional codes (e.g. production waste from manufacturing organic insulation materials
for buildings, such as pulp wool containing boric acid and borax);
− update LoW codes with current production practices (e.g. production of bio-fuels; anaerobic
digestion);
− avoid over-usage of 99-codes.
Adapt/clarify the provisions in the Waste Framework Directive as regards:
− Art. 18, the mixing ban, i.e. specify under which conditions derogations from the mixing ban
are allowed (e.g. by setting criteria referring to Best Available Technologies (BAT), each HW
stream which shall be mixed are permitted for the facility, further clear criteria);
− Art. 35, record keeping, i.e. tighten the obligation to make information available on request
for hazardous waste to a reporting obligation;
− Art. 23, permitting, i.e. specify under which conditions exceptions for landfilling hazardous
waste should be permitted. Derogations should be possible only on case (waste stream) by
case basis;
− Art. 23, permitting, alternatively Art. 34, inspections, i.e. specify, that in the permits for
treatment facilities mixing hazardous waste it shall be clearly defined which particular
treatment operations and waste codes are permitted for mixing;
− Art. 23, permitting, alternatively Art. 34, inspections, i.e. include the obligation that the
requirements set for hazardous waste incinerators have to be respected also for municipal
waste incinerators treating hazardous waste.
Announce, spread and translate official EU guidance to Member States:
− The EC is providing several very useful guidance documents explaining the interpretation and
best practice to obligations on hazardous waste (i.e. the guidance on WFD and the
forthcoming guidance on the classification of HW); stakeholders32 stated that such guidance
should be more announced and distributed to the level of actual stakeholders (regional
authorities, operators); this includes the availability of such guidance in MS languages.
32 EC stakeholder workshop on HW guidance, June 2015 & Eurits general assembly, November 2015
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7.2 Recommendation addressing Eurostat
Check and improve the European List of Waste (LoW) with impact on the differentiation between
hazardous and non-hazardous waste for Eurostat classification:
− to avoid that waste with same composition can have an absolute non-hazardous waste code in
one group of the LoW (e.g. ELV plastics with POP-BFR:s allocated to code 16 01 19), while the
same waste is counted a hazardous waste in another group (e.g. WEEE plastics with POP-BFR:s).
Reporting obligation by Member States:
Generation
− request for clarification, whether exported volumes are included in the reported amounts (Data
Quality Reports);
− request for clarification, whether volumes generated on-site are included in the reported
amounts (Data Quality Reports).
Treatment
− request for clarification, whether imported volumes are included in the reported amounts (Data
Quality Reports);
− request for clarification, whether volumes generated on-site are included in the reported
amounts (Data Quality Reports);
− include treatment operations currently excluded from reporting (Annex II) as separate treatment
option and include data in the publicly available data sets;
− request for the amount temporarily stored and include data in the publicly available data set.
Import / Exports
− improve the Joint questionnaire for transboundary shipment according to Basel for the EU
Member States with regard to the inclusion of LoW codes in order to distinguish between
hazardous and non-hazardous or at least to add the information on hazardous / non-hazardous
− additional classification according to EWC or Eurostat classification to be able to clearly identify
the amount of notified hazardous waste movements (Part II: Annual Reporting, Section A, Tables
6, 7, 8a, 8b);
Data verification
− request for information if there is a data gap between national data and data reported to Eurostat
and the reasons for this difference;
− add the requirement to explain data gaps between generation and treatment above a certain
percentage (e.g. > 10% to 15%);
− demand missing or incomplete information in Quality reports;
− improve verification procedures for the Eurostat table on transboundary movements.
Data availability to the public (Eurostat):
− improve access to Data Quality Reports or develop a publicly accessible summarized table on key
issues regarding data quality giving comparable information for the member states.
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7.3 Recommendation addressing the Member States
7.3.1 General recommendations for all Member States
General recommendations:
− Support SMEs since they often lack necessary knowledge and expertise in HW management;
− Intensify support for operators to ensure correct labelling , in particular for small and
medium sized enterprises; there seem to be only a few good examples on labelling practices;
− Elaborate and disseminate practical guidance on the management of hazardous waste for
specific sectors (e.g. certain industry, commercial, farming) including information on
prevention, collection, labelling.
Recommendation addressing Waste Management Planning Authorities:
− Include HW as a fix element in national/regional waste management planning either in a
separate plan on HW or within the strategic waste management plan of the country region;
− Identify the major HW streams, generators, transport and treatment routes and develop a
programme to tackle problems/problematic waste streams with measures if identified;
− Include in the waste management plans measures to increase recovery for HW if suitable;
− Include planning on HW collection infrastructure, also including ways of collection hazardous
household waste – connect to available infrastructure;
− Elaborate or support waste characterisation studies to outline hazardous waste content of
waste arising from smaller sources (e.g. households and small business) ;
− Coordinate HW management planning on national level, as regional level might be
insufficient to cover the issue for specific waste streams.
Recommendation as regards hazardous waste prevention:
− Generation of hazardous waste (per capita) remained more or less stable in the last years and
the prevention of hazardous waste does not seem on the political agenda for most of the MS
Thus: promote hazardous waste prevention, cleaner technology and better compliance with
regulation and include HW including targets and indicators in waste prevention programmes;
− Target the main sectors of the HW generators in your country and engage with construction,
chemical, health, agricultural and other prior generators of HW;
− Include the issue of HW in the national waste prevention programmes and develop
indicators to reduce hazardousness of waste and amount of waste generation also by e.g.
developing measures on eco-design and circular economy, e.g. for specific material streams
including the expertise and proposal of the concerned industry;
− Include issues on hazardous products in green public procurement procedures and indicators.
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Recommendation addressing the inspectorates and enforcement bodies:
− Use inspections/site-visits as help and improvement chance when problems occur for the first
time rather than direct infringement;
− Also focus on HW operations that do not require an environmental permit, e.g. temporary
storage or treatment operations, and on SMEs;
− A more regular and strict inspection on waste generation sites (it was expressed that this
would contribute to improving enforcement).
Recommendation as regards classification and labelling:
− Support and control the correct classification of HW and provide advice on test methods to be
applied, i.e. laboratory testing. Provide a helpdesk for classification difficulties;
− Reclassify HW if there is doubt of correct classification;
− Give advice on different labelling obligations and control correct labelling during site visits
(GHS/CLP, ADR);
− Provide more material, training and support for correct labelling, as correct labelling remains
a challenge and not many good practice was identified.
Recommendation as regards collection and storage:
− Control collection permits regularly and do not issue unlimited permits;
− Monitor the collection of hazardous waste in order to avoid illegal activities/involvement of
informal sector – create a publically available online register including a list of registered
collectors and update list regularly;
− Support the collection of smaller HW quantities (household, SMEs, farms);
− Give guidance on correct storage, e.g. during site visits.
Recommendation as regards permits and HW mixing ban:
− Require the reference to BAT technologies in the permit of a treatment facility.
− Control the mixing ban within the ex-ante controls (prior to permitting; permit conditions)
and by regular site-visits during the operation period.
Recommendation as regards record keeping and data:
− Enforce data reporting obligation also for imports/exports of waste, if possible issue penalties
for non-reporting of HW;
− Improve record keeping and introduce electronic systems, where not yet available;
− Improve technical performance of electronic record keeping system; where necessary simplify
the use, make it user-friendly;
− Link record keeping systems to statistical reporting procedures.
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Recommendation as regards cooperation with other regions/between Member States:
− Provide access to data basis for neighbouring regions/member states, e.g. the controlling
authority of the region/state ‘A’ can get access to the database of region/state ‘B’ when waste
collectors are controlled in Federal State ‘A’ but the carrier’s permission was issued in Federal
State ‘B’.
7.3.2 Member State specific recommendations
This chapter makes Member State specific recommendations to those that fall under one of these
two conditions:
1. Member States that have been covered by the in depth assessment but where after the
detailed investigation a statistical gap above 20% remains that could not be clarified or
explained. This condition applies to Bulgaria, Italy, Latvia, Luxemburg and the United
Kingdom.
2. Member States that were not covered by the in-depth assessment having a calculated
statistical gap above 45% as presented in chapter 4.1. Member States falling under this
condition are Austria, Belgium, Czech Republic, Greece, Malta, Portugal, Sweden and
Slovakia.
This reasons for this selection are that on the one hand side, it can be concluded, that Member
States that have a remaining, not fully explainable statistical gap above 20% should improve HW
management; on the other hand, due to the many reasons that have been identified for the
statistical gaps investigated (see chapter 5.3), it can be assumed that Member States that have
statistical gaps above 45% without further investigation have HW management issues that could be
improved based on recommendations provided. In addition, some Member State recommendations
are based on HW management problems that were identified during the stakeholder consultation
(see chapter 0, Annex IV).
The Member States recommendations are sorted in alphabetical order.
Austria
Austria has not been selected as one of the ten Member States for the in-depth assessment.
However considering the statistical gap of 63 % calculated between HW generated and treated in the
State and the information collected through the stakeholder consultation the following
recommendations can be made:
− Improve the infrastructure for recovery of spent solvents and used oils. Spent solvent are
currently not recovered (excluding energy recovery) within Austria. The same is valid for used
oils.
− Data have to be reported by all Austrian waste management companies electronically (legal
obligation). Although the Electronical Data Management (EDM)-System was introduced many
years ago, no reliable statistics exist – especially concerning hazardous waste. Austrian
industry is reporting datasets, but public authorities are not able to present current statistics
(see also chapter 0). In order to improve transparency and traceability of HW, figures
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following the six digit code according to the European List of Waste should be published by
the competent authority.
Belgium
Due to its federal structure, Belgium is a Member State where the political competencies lie with the
regions (Flanders, Wallonia and Brussels) which leads to several differences regarding waste
management performance. Also, the statistical gap for HW treatment and generation data of 51% is
relatively high. The following recommendations can be made for improvement:
− Harmonise the criteria for the derogation of the mixing ban: Regarding compliance with legal
requirements, the labelling of HW should be aligned in the three regions. Even though the
mixing ban is implemented in all three regions, the criteria for possible derogations vary and
this may lead to a lack of harmonised application of the ban..
− The content and topicality of the Waste Management Plans are not comparable, e.g. the
WMP of Wallonia is from 1998 contains data from 1995. The WMP from Flanders and Brussels
region do not cover industrial HW being one of the major sources of HW, and only the
Brussels region includes HW prevention targets and measures. The WMPs and WPPs of
Wallonia and Flanders should be updated or revised in order to consider HW management
and prevention.
− In general, problems occur in particular in the region of Wallonia, where the data basis and
planning is poor. While Flanders and Brussels have a reporting obligation for HW generation
and treatment data, in Wallonia amounts reported to Eurostat are mainly based on surveys
and estimations. In addition, data is only available in aggregated form to the public in all three
regions. Therefore, the traceability of HW should be improved in Wallonia by introducing an
obligatory tracking system. HW data reporting according to the six-digit code should be
published by all three regions.
− HW treatment data shows that performance in Belgium is below average, especially for HW
deposited onto or into land (D1, D5, D12) and spent solvents treated in or shipped to the
Member State recovered (excluding energy recovery) and should be improved.
− Only Flanders provides support for HW classification through a specific handbook, which is
only available in Flemish. Because the two other regions do not provide supportive measures
the recommendation would be to translate the handbook into French.
Bulgaria
Bulgaria was covered in the in-depth assessment of ten Member States which showed that the
statistical gap of 0% according to Eurostat data is not correct and that the actual statistical gap
amounts to around 63% when excluding the high amount of mineral waste (see chapter 0). Because
this statistical gap could not be explained or clarified the following recommendations can be made:
− Exclude mineral waste amounts from the HW data reported to Eurostat in order to improve
the picture of real HW amounts treated and generated in Bulgaria.
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− Include HW into the scope of the National Waste Management Plan, including a detailed
overview of industrial HW generation. In addition, align HW data included in WMP with data
from National Statistical Office (NIS) reports in order to resolve data discrepancies.
− Improve (hazardous) waste management knowledge within the companies, to raise the
number of staff assigned specifically to deal with waste management issues, thus preventing
problems with HW labelling.
− Reduce the heavy administrative burden on the inspection authorities, in order to prevent
improperly conducted quality of checks and inspections. This especially applies to the
infrequent inspections of non-IPPC facilities.
− The rate for depositing HW onto or into land (D1, D5, D12) treated within the Member State is
100% and should be lowered in favour of recovery operations.
− Figures on HW management are publicly available only on an aggregated level at National
Statistical Institute; this should be changed by publishing data on a six-digit code following the
LoW classification.
Czech Republic
The Czech Republic has shown a very good overall HW performance in the screening phase.
However, the HW statistical gap between generation and treatment data is comparably high (50%).
For this reason the following recommendations apply:
− The HW management planning could be improved due to the fact that the Waste
Management Plan and the Waste Prevention Programme from 2014 include specifications on
HW but the amounts of industrial HW generated are not included. Industrial HW amounts per
waste stream should be included in the WMP.
− The separate collection rates of WEEE (32%) and batteries (30%) are both below the EU-28
average and need to be improved.
− For HW treatment operations especially the recovery (excluding energy recovery) of spent
solvents (7%) and used oils (46%) in the Czech Republic or shipped to the Member State
should be raised because they were both below average.
− Currently, HW generation and treatment data reported to Eurostat is collected on the basis of
sample surveys. The collection of HW data via an obligatory and electronic reporting system
would improve the data quality and reliability in the Czech Republic.
Greece
Altogether Greece has an average performance in HW management based on the screening
conducted. Moreover, based on the statistical gap of 62% calculated the following improvements can
be suggested:
− Cases of mixing different categories of HW or hazardous with non-HW waste are explicitly
foreseen in the environmental permits issued by the competent authorities for HW recovery
operations. However, the national law does not define criteria for these mixing operations,
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e.g. application of best available technology. Criteria should be included in the legislation or in
the permits themselves.
− Move on from HW data collection that is currently based on different registers and uses
additional surveys for HW generation and treatment data, in order to improve the data
quality and reliability. In addition the public has only access to aggregated HW data; it can be
recommended to make data available according to the six-digit code following the LoW.
− The separate collection performance of WEEE (28%) and batteries (24%) are both below the
EU-28 average and need to be increased.
Italy
Italy was covered within the in-depth assessment of ten Member States which showed that the
statistical gap of 66% according to Eurostat data could not be clarified. This finding should be further
investigated and clarified. Based on the statistical gap and the problems in HW management
identified (see chapter 0) recommendations to improve the situation are:
− Italy shows deficits as regards waste management in terms of the planning due to the fact
that it is delegated to the regional level including 21 regional WMPs (some of them outdated).
The communication/coordination between regions should be improved to prevent different
quality of HW management planning and significant regional differences in waste treatment
operations applied; hindering uniform capacity planning.
− Requirements vary between regions and several layers of authorities are involved. That
overall hinders proper HW management and includes high bureaucratic burden for Italian
waste companies. Alignment between regions is necessary.
− HW waste data from companies are collected and then reported to Eurostat based on Basel
codes which makes the distinction between hazardous and non-hazardous wastes not always
possible. Like done by other EU-MS, it would be an improvement if Italy would collect waste
data based on LoW codes at the facility level and then change the classification for reporting
to Basel codes.
− Italy does not provide any support for the classification of HW in the form of guidelines or
helpdesks. This often leads to misclassification which also tends to lead to incorrect labelling
of HW. The situation would be improved if classification support would be provided to smaller
companies that do not have in-house waste management experts, mostly SMEs.
− Regarding the enforcement of waste legislation: the communication between the inspection
authorities and the companies should be improved so that current issues in HW management
are considered. Also, the inspectors should rather focus on incorrect treatment operations
than on document controls during inspections.
− The separate collection performance for batteries and accumulators (27.1%) is below the EU-
28 average and should be increased in order to reach the collection targets in 2016.
− Although Italy maintains an electronic register for waste data, this is not publically available.
Some regional WMP include aggregated waste data, however this information is not regularly
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updated. HW data should be made publically available in order to improve traceability and
transparency.
Latvia
Although the statistical gap on HW generation and treatment in Latvia based on Eurostat data was
corrected through the in-depth assessment (from 48% to 43% according to national statistics); it
cannot be fully explained. The main reason seem to be pre-treatment of HW leading to different
classification, temporary storage of HW at enterprises and missing reports from some HW recovery
companies. However, the following recommendations can be made:
− The National Waste Management Plan should establish clear and measurable goals and target
levels for HW, so as to increase recovery and reduce disposal. This especially counts for acid,
alkaline or saline wastes where the percentage treated in Latvia or shipped to other Member
States for recovery (excluding energy recovery and backfilling) is very low.
− In general data collection in Latvia is poor because it is survey based and should be improved
by introducing an obligatory, preferably electronic, reporting system that allows the tracking
of all HW movements.
− Latvia should establish an official helpdesk for HW classification and labelling support. At the
moment several state institutions provide support with the interpretation and explanation of
legislation acts regarding labelling and classification, e.g. Latvian Environmental, Geological
and Meteorological Centre (LEGMC); however information is spread amongst those
institutions.
− The separate collection performance for WEEE (28%) and batteries (25.8%) are both below
the EU-28 average and should be increased in order to reach the collection targets in 2016.
Also the collection schemes for waste oils and contaminated C&D waste should be revised.
Especially for waste oils a proper private or public collection system should be established
since there is probably an informal sector established due to the value of the waste.
Luxemburg
Luxemburg is the smallest Member State covered by the in-depth analysis but having a high amount
of HW generation by citizens compared to other MS (600 kg/cap vs.200 kg/cap average in EU-28).
This is mostly due to the rehabilitation of a large contaminated site. Nonetheless even after the in-
depth assessment the statistical gap of 99% between HW generation and treatment data could not
be clarified. The following recommendations can be made:
− Data collection on HW data shipments (imports and exports) should be based on LoW
codification and not only on Basel Y-code classification. This does not only apply to data
reported to Eurostat but also to data held by national registries.
− Currently the system for HW reporting is being changed to an electronic and mandatory
online reporting system which should improve data availability and HW traceability. It is
important that this system is based on LoW codes.
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Malta
Malta has the second highest statistical gap between HW amounts generated and treated amounting
to 97%. In combination with the average scoring within the screening part of the project, the
following specific recommendations can be given:
− Although MT has recently adopted a Waste Prevention Plan of Malta (2014), this does not
include HW; no overall objectives, quantitative targets, measures on prevention and
indicators related to HW are included. It would be an improvement to include HW in waste
prevention planning.
− Malta does not provide HW classification support to HW holders and/or producers that goes
beyond the classification requirements set out in European legislation. In order to support
correct classification of waste as hazardous supportive measures should be implemented.
− Malta was ranked second-last with regard to the separate collection rate of WEEE amounting
to only 15% in 2012. In the same year, the collection rate for WEEE was 2.84 kg/inhabitant
(based on 421,364 no. of inhabitants). If the collection rate of 45% in 2016 is to be met,
significant improvements in the separate collection infrastructure need to be implemented.
− The Waste Management Plan contains aggregated data of HW generated, which is however
not timely information because the WMP is revised every 6 years. The National Statistics
Office publishes data on solid waste management in Malta every year in January; aggregated
information on HW which is managed in pre-treatment and final treatment facilities in Malta
is provided. Nevertheless, it is recommended to make HW data publically available based a
six-digit code.
Portugal
Although Portugal was scored third best in the screening conducted the relatively high statistical gap
of 65% and HW management problems identified (see Portuguese ‘screening information’) lead to
the following recommendations:
− The Portuguese legislation implemented the ban on the mixing of HW including possible
derogations if certain criteria are met. Especially an authorisation has to be obtained by the
respective licensing authority for the mixing operation. However, the mixing rules are not
explicitly included in the permits. To assure correct HW mixing that complies with the
defined criteria the requirements for the mixing operation should be included in the permit.
− The Waste Management Plan (2014) does include specifications on HW as well as an
overview on recent industrial HW generation amounts from 2012. But as regards waste
prevention targets for HW, no quantitative targets are set in the WPP and should be included
in the next revision (current application period is from 2010-2016).
− The separate collection performance of Portugal for WEEE (34%) and batteries (28.1%) are
both below the EU-28 average and should be increased in order to reach the collection
targets in 2016.
− Data inconsistencies could occur due to the fact that the available data on generation and
management of HW reported to Eurostat is based only on a sample survey and is model
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based. HW data on generation and treatment should be based on an obligatory reporting
system that should be preferably electronic.
Slovakia
The screening showed an overall good HW management situation in Slovakia but the statistical gap
calculated amounts to 47% leaving space for improvement. Recommendations are:
− No supportive measures for correct HW classification to HW holders and/or producers that
go beyond the classification requirements set out in European legislation are provided. In
order to support correct classification of waste as hazardous supportive measures should be
implemented.
− The rate for depositing HW onto or into land (D1, D5, D12) treated within the Member State
is high compared to EU average. The amount of HW disposed of should be reduced by
promoting recovery operations.
− In Slovakia, criteria for the derogation of the HW mixing ban are not clearly defined in
legislation, hereafter the mixing may be carried out if it is needed to increase safety during
waste recovery or disposal. This may be defined within a granted permit by setting
conditions on case to case basis. Specific criteria should be included in the waste act and in
the permit itself in order to insure proper HW management during mixing operations.
Sweden
Based on the screening conducted Sweden has overall good HW planning and prevention, being one
of the few countries including particular quantitative targets. Still the statistical gap for HW treated
and generated is comparably high (59%). The following recommendations are raised:
− Sweden has no reporting obligation for HW movements and no national or regional record
keeping system is established. This is a major potential source for data inconsistencies and
traceability deficits. It is recommended to establish a national record keeping system for HW
that is based on reporting obligations independently from authorities’ requests.
− The rate for disposal operations is high and the percentage of recovery operations
particularly for spent solvents and acid, alkaline or saline wastes is low. Recovery operations
for HW should be fostered and treatment capacities increased.
− The enforcement could be improved. In Sweden mostly the municipalities are in charge of
the inspections, missing adequate capacities and knowledge. Personnel should be trained
within the municipalities in order to have adequate know-how especially as regards
technically difficult questions of correct HW classification.
United Kingdom
The United Kingdom was included in the in-depth analysis of ten Member States which revealed that
the statistical gap between HW generation and treatment could be decreased to approximately 26%,
mainly due to double-counting effects. However, the remaining gap cannot be explained. Apart from
statistical issues, the UK in summary has to decrease the amount of low-standard treatment of HW
and move up the waste hierarchy, the occurrence of wrong classification, labelling and packaging of
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HW and a record keeping system which is not fully transparent. Hence, the specific
recommendations are:
− Promote the waste hierarchy for the overall management of HW to avoid 'sham treatment'
and foster high-standard treatment, e.g. by referencing to BAT in permits and further
defining the mixing ban in the legislation and in the derogations from the mixing ban granted
in the individual permits.
− Enforce the implemented legislation on hazardous waste to support investments from
industry in BAT technologies. Especially enforce the mixing ban by including definitions of
e.g. mixing, blending and diluting into legislation. The aim should be to achieve a clear and
controllable definition of the mixing ban that can be included in the inspection plans (in line
with the explanations on the mixing ban given at the related 'waste' website of the UK
government).
− Include small waste oil incinerators in the permitting procedures.
− Promote the usage of the WM3 guidance document for operators in industry (see [UK EA HW
2015]) and especially address SMEs, e.g. with capacity building events, helpdesks and a
further dissemination of the available summary guidance particularly aiming at SMEs.
− Support the correct classification, labelling and packaging of HW by maintaining the general
helpdesk on waste classification and expanding it to labelling and packaging. Consider
including a dedicated section on labelling and packaging of HW in the WM3 guidance
document.
− Change the record keeping system to an electronic version in order to withdraw statistical
data directly from this system. Even though the former system of pre-notifying waste
movements was abandoned, an electronic record keeping system should be introduced
where waste movements have to be reported online and also the registries are kept online
to allow continuous access (and thus control possibility) for the authority.
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Conclusions
The following conclusions can be drawn from the EC study on hazardous waste management:
Good status of waste management planning, including HW specifications in most of the
Member States’ WMPs and data on industrial hazardous waste for about half of the plans;
setting at least qualitative targets for the reduction of HW in waste prevention programmes
(WPP); however, only some include quantitative targets for the prevention of hazardous waste.
Potential for the improvement of waste management planning is seen in including all important
HW streams, establishing clear and measureable goals and target levels for HW, avoiding
complete delegation to regional (or even lower administrative level) and aligning regional
differences in HW management planning.
Good implementation for most of EU requirements on HW with no deficits as regards the
implementation of labelling requirements and the mixing ban into national legislation;
remaining differences for setting derogations of the mixing ban and permitting of HW recovery
installations; large differences as regards record keeping systems, reporting obligations and
support of correct classification. However practice shows that implementation of all obligations
is facing problems for most of the requirements, in particular:
o As regards HW classification several problems are reported, i.e. that waste classification
system is not very distinct and leaves room for interpretation, threshold values are not
harmonised, ‘over-usage’ of particular waste entries, problems with HP 5, 10 and 14,
missing support, helpdesk, guidance in national languages, missing definition of test
methods, interferences between LoW and Basel coding. Particular waste streams with
problems in classification are WEEE, excavated oil, contaminated soil, oil containing liquid
waste, solvent, washing liquid and mother liquor, halogenated waste, certain mineral
wastes, clinker ash, waste containing POPs, bio-hazard waste and cytostatic hospital waste.
o The collection of HW waste seems to cause problems for particular waste streams (waste
oils, asbestos waste, contaminated C&D waste, medical waste, WEEE, HW from farms. For
some of these waste streams, the informal sector is involved in some MS. Problems
regarding storage of HW are reported only for minor cases. As regards correct labelling of
HW waste, problems are reported in particular for small companies and SMEs, which do not
have the sufficient personnel and/or knowledge. Further, different labelling obligations for
different modes of transport are causing problems (EU rules, ADR). More national
guidelines, templates and helpdesks are needed in these cases.
o Problems encountered with permitting practice are the parallel application of old/renewed
and new permits in combination with the fact that facilities hold several permits at the
same time, the addressing of different pieces of environmental legislation in the permit and
thereof insufficient focus on (hazardous) waste management. Additionally, companies
report slow permitting procedures. The mixing ban, well transposed in the MS legislation, is
encountered in practice with illegal activities and difficult control. Further, some MS need
to clarify the criteria enabling derogations from the mixing ban.
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Different levels of performance regarding the separate collection of WEEE and batteries/
accumulators; large potential for improvement as regards the reliance on landfilling and the
practice of recovery operations for at least ten MS. Furthermore, there are gaps and difficulties
concerning the reliability of HW data in particular concerning the data basis used for reporting to
Eurostat. There are no gaps as regards the inclusion of general requirements on collection and
storage of HW into legislation, even though information from practical implementation shows
that there might be differences regarding implementation on the ground. In this regard Best
Available Technology (BAT) requirements are not existent or not sufficient for specific waste
streams or not adequately described in the permits.
Potential for improvement of the data reporting basis and publically available data on HW. As
regards waste data: The gap between HW generation and treatment in Eurostat statistics range
from 0 to 99%. They can be explained mainly by differences in reporting obligations under
Eurostat and national statistics but also by discrepancies within the Eurostat reporting systems.
Common explanations for the statistical gap are double-counting (e.g. pre-treatment operations),
storage effects, missing information on import/export, reporting errors, application of different
waste codes (e.g. Basel code), change of reporting systems (paper to electronic). Also the record
keeping faces problems on facility level (i.e. different record keeping obligations across Federal
States, lack of user-friendliness) and administration level (e.g. exemption for record keeping for
WEEE and batteries). It seems that Member States applying an electronic reporting system partly
connected to notification and/or consignment notes show lower gaps and discrepancies in data
leading to the position that those reporting systems are more reliable than others. In some
Member States (smaller) gaps in statistics remain, even when taking into account all reasons
explaining the differences of data which leads to the position that there is at least poorer
reporting for HW actions and no full record/control of those actions.
Good general enforcement of HW legislation as regards the definition of responsibilities and the
setting of penalties and fines, with differences in the assignment of enforcement
capacities/carried-out inspection activities. However deficiencies of enforcement are due to the
heavy burden for administration and inspectors and their limited capacities, the interference of
responsibilities of several authorities and insufficient communication between them, reduced
controls for smaller installations but large number of small and medium sized companies, too low
penalties, significant different level of enforcement actions in Federal States and heavy
involvement of brokers and dealers.
The requirements for hazardous waste as laid down in the Waste Framework Directive are
usually transposed into national/regional law; however, there is a discrepancy of the
transposition of the requirements and the practice. One example is the mixing ban (including
the dilution of HW): the legislation is clear, however it is stated from several stakeholders, that
a control system is difficult to implement systematically and that the practice of mixing cannot
be traced easily, even when a thorough record system is applied. Further in some countries
there are regional differences in the interpretation and application of this obligation.
Also the actual performance as regards the application of treatment operations moving up the
waste hierarchy is at different status with potential for improvement.
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For a follow-up study, it is proposed to include the following Member States:
Romania received a below average score with considerable gaps compared to other MS. It
seems that EU requirements are in generally well transposed. However, Romania shows
deficits in terms of (hazardous) waste management planning, data availability and quality as
well as practical application and enforcement of waste legislation.
Belgium problems mainly relate to statistical data (data quality/availability) and the federal
structure. The country is one of the ten biggest HW producer (8th on the list) and has a
relatively high data gap (according to Eurostat 51%). For BE in particular problems occur in
the region of Wallonia, where the data basis regarding planning is poor.
France produces considerable amounts of HW (3rd on the list) and showed below average
performance of actual treatment technologies and gaps in waste management planning.
Deficits were identified for the following criteria (scored 0): France delegates the waste
management planning to the regional level, including 101 regional WMPs; not all of them are
updated according to the official national overview. Furthermore, the WEEE recovery rate is
below average. Based on reported Eurostat data, the recovery rate for spent solvents and
used oils is below average. The reporting is based on administrative information sources and
surveys rather than on real data (e.g. reported within a registry). The criteria on waste
prevention, collection of batteries and accumulators, reliance on landfill and recovery rate
for acid, alkaline or saline waste were all scored with 1.
Spain is showing a considerable improvement potential for the application of treatment
technologies moving up the waste hierarchy, HW data quality and availability, and HW
management planning. Spain is producing considerable amounts of HW (9th on the list) and a
list of problems of implementation of HW legislation on the grounds is reported from
stakeholders.
Sweden well implemented all legal requirements, however received low scores in actual
treatment statistics and data quality/availability. The country is a considerable producer of
HW (10th on the top HW producer in Europe). Further Sweden has according to Eurostat data
a gap of 59% between HW generation and treatment.
Poland is also producing considerable amounts of HW (11th in the list). The compliance with
legal requirements is assessed as being good, however some open issues are detected as
regards HW data reporting and quality of such data. Further, the actual waste management
planning is partly delegated to regional levels, thus manifold authorities being involved in
permitting and inspection procedures, which in general causes a potential for non-uniform
implementation and enforcement of the requirements.
Slovenia and/or Cyprus received a below average score and are an example for smaller EU
countries not producing considerable amounts of HW on EU level. In the first screening, both
countries showed particular deficits in available guidance material supporting the correct
classification of HW, waste reporting and data quality as well as waste management planning
and applied treatment operations.
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Hungary and/or Denmark scored close to average performance and had in particular a low
scoring for actual treatment. Both MS have been assessed in the first screening as
transposing well the legal requirements. However regarding the applied treatment
operations, disposal holds a considerably high share. For Hungary also HW data availability
and quality seems to be low. The statistical gap for HW generation and treatment for
Hungary is 45% according to Eurostat.
With this proposal for further MS assessments, the overall list of assessed and to be assessed
MS includes:
The 11 largest HW producer in the EU.
All MS with a statistical gap (according to Eurostat) of above 65%
All MS where different (federal) levels are involved in HW management and planning.
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[SE SRI 2015] FEAD Stakeholder consultation concerning HW management in MS, information provided by Mr. Carl Hagberg - STENA METALL (SRI), 5 February 2015 and 23 February 2015
[SE SWM 2014] Avfall Sverige - Swedish Waste Management, 2014, http://www.avfallsverige.se/fileadmin/uploads/Rapporter/sah_2014_Eng_141001.pdf, accessed February 2015
[SE TAC 2015] Swedish Environmental Protection Agency, document comment by Henrik Sandström, 01.09.2015
[SE WFD 2015] Original Member State Implementation Report. 2010-12. Waste Framework Directive
[SE WMP 2013] From waste management to resource efficiency - Sweden's Waste Plan 2012–2017 (“Från avfallshantering till resurshushållning. Sveriges avfallsplan”) http://www.naturvardsverket.se/Nerladdningssida/?fileType=pdf&downloadUrl=/Documents/publikationer6400/978-91-620-6560-7.pdf, accessed January 2015
[SE WPP 2014] Tillsammans vinner vi på ett giftfritt och resurseffektivt samhälle - Sveriges program för att förebygga avfall (2014-2017], http://www.naturvardsverket.se/Miljoarbete-i-samhallet/Miljoarbete-i-Sverige/Uppdelat-efter-omrade/Avfall/Avfallsforebyggande-program/, accessed January 2015
[SI MWMP 2012] Operational Programme for the management of municipal waste, http://www.mko.gov.si/fileadmin/mko.gov.si/pageuploads/zakonodaja/varstvo_okolja/operativni_programi/op_komunalni_odpadki.pdf
[SI MWMP Annex 2012] Annex: http://www.mko.gov.si/fileadmin/mko.gov.si/pageuploads/zakonodaja/varstvo_okolja/operativni_programi/op_komunalni_odpadki_priloge.pdf
[SI TAC 2015] Ministry of the Environment and Spatial Planning, document comment by Lucija Jukic-Sorsak, 04.09.2015
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[SI WFD 2013] Original Member State Implementation Report. 2010-12. Waste Framework Directive (Delivery date: September 2013)
[SK Act 79/2015] Act No. 79/2015 Coll. on wastes and on a change and amendment of certain other acts (Zákon č. 79/2015 Z. z. o odpadoch a o zmene a doplnení niektorých zákonov), effective since 01.01.2016, https://www.slov-lex.sk/pravne-predpisy/SK/ZZ/2015/79/20170101#clanok-1, accessed September 2015, in Slovak
[SK EEA 2014] Slovakia - Waste prevention programme, http://scp.eionet.europa.eu/facts/WPP/slovakia, accessed January 2015
[SK MoE 2015] Organizational regulations of the Ministry of Environment of the Slovak Republic 2015, http://www.minzp.sk/files/o-nas/mzp-sr/organizacny-poriadok/organizacny-poriadok-uplne-znenie.pdf, accessed August 2015
[SK TAC 2015] Ministry of Environment, document comment by Viera Špalková, 04.09.2015
[SK Waste Statistics 2012] Statistical Office of the Slovak Republic, Quality Report on Waste Statistics 2012, http://www.sazp.sk/public/index/open_file.php?file=Komisia/Spravy/Odpady/rok2012/Slovak_Quality_Report_2012_SK.pdf, accessed February 2015
[SK WFD 2013] Original Member State Implementation Report. 2010-12. Waste Framework Directive (Delivery date: September 2013)
[SK WMP 2011] Waste management plan of the Slovak Republic for 2011-2015, http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/poh-sr-2011-2015.pdf, accessed January 2015
[SK WMP Annexes 2011] Annex 1: http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_01.pdf accessed January 2015
Annex 2: http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_02.pdf accessed January 2015
Annex 3: http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_03.pdf accessed January 2015
Annex 4: http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_04.pdf, accessed January 2015
Annex 5 and 6: http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_05_06.pdf, accessed January 2015
[SK WMP 2016] Waste management plan of the Slovak Republic for 2016 – 2020 (Program odpadového hospodárstva Slovenskej republiky na roky 2016 – 2020), currently unavailable
[SK WPP 2014] Waste Prevention Program of the Slovak Republic for the period 2014-2018 (Program predchádzania vzniku odpadu SR na roky), http://www.minzp.sk/sekcie/temy-oblasti/odpady-obaly/program-predchadzania-vzniku-odpadu/, accessed January 2015
[UK Chemicals 2009] Chemicals (Hazardous Information and Packaging for Supply) Regulations 2009 http://www.legislation.gov.uk/uksi/2009/716/contents/made, accessed January 2015
[UK Dangerous goods 2009] Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009, http://www.legislation.gov.uk/title/the%20carriage%20of%20dangerous%20goods?page=1, accessed January 2015
[UK DEFRA 2015] Information provided by E-mail and via phone interview by Olu Ogunbadejo, Sarah Steeds, Robin Karfoot and Jane Stratford from DEFRA, 23 June 2015
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[UK EA Env 2014] Environmental permitting charging scheme & guidance, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/405120/LIT_9910.pdf, accessed February 2015
[UK EA Guidance 2015] Environment Agency – Environmental Management: Waste, https://www.gov.uk/topic/environmental-management/waste, accessed July 2015
[UK EA HW 2015] HW classification support/guidance (WM3) from the UK Environment Agency, https://www.gov.uk/how-to-classify-different-types-of-waste, and https://www.gov.uk/government/publications/waste-classification-technical-guidance, accessed July 2015
[UK EA Stat 2014] ENV23 - UK statistics on waste, https://www.gov.uk/government/statistical-data-sets/env23-uk-waste-data-and-management, accessed February 2015
[UK EA Stat 2015] Defra: Digest of Waste and Resource Statistics – 2015 Edition, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/401400/Digest_of_waste_England_2015_-_final.pdf, accessed February 2015
[UK EA Storing 2015] Sorting and storage support/guidance from the UK Environment Agency, https://www.gov.uk/managing-your-waste-an-overview/storage, accessed February 2015
[UK EN EEA 2014] EEA summary WPP England, http://scp.eionet.europa.eu/facts/WPP/england, accessed January 2015
[UK En LoW 2005] List of Wastes (England) Regulations 2005, http://www.legislation.gov.uk/uksi/2005/895/contents/made, accessed January 2015
[UK En Wa Guidance Record 2011] Guidance – HWR05 Record keeping A guide to the Hazardous Waste Regulations, http://webarchive.nationalarchives.gov.uk/20140328084622/http://cdn.environment-agency.gov.uk/geho0611btuv-e-e.pdf and http://www.360environmental.co.uk/legislation/waste_legislation/hazardous_waste/, accessed January 2015
[UK En Wa HW 2005] Hazardous Waste (England and Wales) Regulations 2005, http://www.legislation.gov.uk/uksi/2005/894/note/made, accessed January 2015
[UK En WMP 2013] Waste Management Plan for England, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265810/pb14100-waste-management-plan-20131213.pdf, accessed January 2015
[UK EN WPP 2013] Prevention is better than cure – The role of waste prevention in moving to a more resource efficient economy, https://www.gov.uk/government/publications/waste-prevention-programme-for-england, accessed January 2015
[UK ESA 2015a] FEAD Stakeholder consultation concerning HW management in the Member States, information provided by Roy Hathaway – Environmental Service Association (ESA), 05. February and 23 February 2015
[UK ESA 2015b] Information provided by E-mail and via phone interview by Mr Gene Wilson from ESA, 24 June 2015
[UK EU Press 2015] European Commission: Press Release Database – April infringements package: main decisions, http://europa.eu/rapid/press-release_MEMO-15-4871_en.htm, accessed July 2015
[UK Gb 1950-07] The Public Health Act, http://www.gibraltarlaws.gov.gi/articles/1950-07o.pdf, accessed January 2015
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[UK Gb WMP 2013] Gibraltar waste management plan, https://www.gibraltar.gov.gi/images/stories/PDF/pressoffice/pressreleases/2013/838.1-2013.pdf, accessed January 2015
[UK Gov 2015] Environmental management – collection, National operator waste returns, https://www.gov.uk/government/collections/national-operator-waste-returns, accessed January 2015
[UK HSE 2015] Health and Safety Executive: Chemical warehousing – The storage of packaged dangerous substances, http://www.hse.gov.uk/pubns/priced/hsg71.pdf, accessed August 2015
[UK Ni HW 2005] Hazardous Waste Regulations (Northern Ireland) 2005, http://www.legislation.gov.uk/nisr/2005/300/contents/made, accessed January 2015
[UK Ni WMP Arc 2014] Arc 21 region: Waste Management Plan, http://www.arc21.org.uk/download/1/arc21%20Waste%20Management%20Plan%20Oct%202014.pdf, accessed January 2015
[UK Ni WMP North 2015] North West Region: A review of the waste management plan 2006-2020, http://www.northwestwaste.org.uk/wp-content/uploads/2010/12/NWRWMG_Waste_Management_Plan.pdf, accessed January 2015
[UK Ni WMP South 2014] Southern region: Waste Management Plan, http://swamp2008.org.uk/wp-content/uploads/2009/06/IBR0450-SWaMP-WMP-Full-Copy-Final.pdf, accessed January 2015
[UK NI WPP 2014] Waste Prevention Programme for Northern Ireland, http://www.doeni.gov.uk/index/protect_the_environment/waste/rethink_waste.htm, accessed January 2015
[UK Permit 2010] The Environmental Permitting (England and Wales) Regulations 2010; http://www.legislation.gov.uk/uksi/2010/675/contents/made; accessed January 2015
[UK Sco EEA 2014] EEA summary WPP Scotland, http://scp.eionet.europa.eu/facts/WPP/scotland , accessed January 2015
[UK Sco SW 1996] The Special Waste Regulations 1996, http://www.legislation.gov.uk/uksi/1996/972/contents/made, accessed January 2015
[UK Sco Waste 2011] Waste (Scotland) Regulations 2011, http://www.legislation.gov.uk/ssi/2011/226/contents/made 2011, accessed January 2015
[UK Sco WML 2011] Waste Management Licensing (Scotland) Regulations 2011,
http://www.legislation.gov.uk/ssi/2011/228/contents/made, accessed January 2015
[UK Sco WMP 2010] Scotland’s zero waste plan, http://www.scotland.gov.uk/Topics/Environment/waste-and-pollution/Waste-1/wastestrategy, accessed January 2015
[UK SCO WPP 2013] Zero Waste: Safeguarding Scotland´s Resources: Blueprint for a more resource efficient and circular economy, http://www.scotland.gov.uk/Resource/0043/00435308.pdf, accessed January 2015
[UK TRADEBE EURITS 2015] Information provided by E-mail and via phone interview by Mr Andrew Crowther from TRADEBE and Mr Mike Hale from EURITS, 01 July 2015
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[UK Wa EEA 2014] EEA summary WPP Wales, http://scp.eionet.europa.eu/facts/WPP/wales, accessed January 2015
[UK Wa WMP C&D 2012] Construction and demolition sector plan, http://wales.gov.uk/docs/desh/publications/130301construction-demolition-waste-plan-en.pdf, accessed January 2015
[UK Wa WMP C&I 2013] Commercial and industrial sector plan, http://wales.gov.uk/docs/desh/consultation/130513-industrial-commercial-sector-plan-en.pdf, accessed January 2015
[UK Wa WMP CIM 2012] Collections, Infrastructure and Markets Sector Plan , http://wales.gov.uk/docs/desh/publications/120713wastecimsectorplanen.pdf, accessed January 2015
[UK Wa WMP Food 2011] Food, manufacture, service and retail sector plan, http://wales.gov.uk/docs/desh/consultation/110322wastefoodplanen.pdf, accessed January 2015
[UK Wa WMP MSP 2011] Municipal Sector Plan, http://wales.gov.uk/docs/desh/publications/110310municipalwasteplan1en.pdf, accessed January 2015
[UK WA WPP 2013] Towards Zero Waste. One Wales: One Planet. The Waste Prevention Programme for Wales, http://wales.gov.uk/docs/desh/publications/131203waste-prevention-programme-document-en.pdf, accessed January 2015
[UK WFD 2013] Original Member State Implementation Report. 2010-12. Waste Framework Directive (Delivery date: September 2013)
[UN Report 2015] UN National Reports on Waste Management, http://www.un.org/esa/dsd/dsd_aofw_ni/ni_pdfs/NationalReports/belgium/WasteManagement.pdf, accessed February 2015
[Waste Data System 2012] Order No. 1306 on Waste Data System, https://www.retsinformation.dk/Forms/R0710.aspx?id=144615
[WStatR 2012] WStatR quality reports 2012 https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp, accessed January 2015
[WStatR 2012b] Manual on waste statistics. A handbook for data collection on waste generation and
treatment, Eurostat, edition 2010
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Annex
10.1 Annex I: Overview on MS screening information (18 MS) and MS
factsheets (10 MS)
Within the first project steps a screening information has been prepared for all 28 EU Member
States including information on hazardous waste legislation, planning and procedures based on
available documents (waste management plans, national legislation, implementation reports, ...). For
verification and commenting, the screening information has been sent to the TAC Members on
waste.
For the ten selected Member States included in the in-depth analysis this screening information
document has been extended to a full factsheet on hazardous waste management practice.
Information source for this detailed information are expert interviews with various stakeholders
(administration, industry, associations, science, etc.) and further reports and websites on national
level. All information are cited in both types of documents; including the expert interviews
conducted.
The screening information (18 MS) and factsheets (10 MS) are provided in extra documents applying
the following shortcuts (bold grey are the MS with full factsheets):
No MS or Region Title
1 Austria AT Screening information HW
2a Belgium - Brussels BE Br Screening information
2b Belgium - Flanders BE Fl Screening information
2c Belgium - Wallonia BE Wa Screening information
3 Bulgaria BG Factsheet HW
4 Cyprus CY Screening information
5 Czech Republic CZ Screening information
6 Germany DE Factsheet HW
7 Denmark DK Screening information
8 Estonia EE Factsheet HW
9 Spain ES Screening information*
10 Finland FI Factsheet HW
11 France FR Screening information
12 Greece GR Screening information
13 Croatia HR Screening information
14 Hungary HU Screening information
15 Ireland IE Factsheet HW
16 Italy IT Factsheet HW
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No MS or Region Title
17 Lithuania LT Screening information
18 Luxembourg LU Factsheet HW
19 Latvia LV Factsheet HW
20 Malta MT Screening information
21 The Netherlands NL Factsheet HW
22 Poland PL Screening information
23 Portugal PT Screening information
24 Romania RO Screening information
25 Sweden SE Screening information
26 Slovenia SI Screening information
27 Slovakia SK Screening information
28 United Kingdom UK Factsheet HW
*Note: Spain has not been selected as one of the ten EU Member States for the further in-depth
analysis in the scope of this project. Nevertheless some stakeholders expressed views about HW
management in Spain. In particular the Hazardous waste association in Spain (ASEGRE) delivered
information. The Spain screening information includes therefore the view of this stakeholder
applying a similar structure for announced problems as in this report. This extra information is
marked and cited; however it could not be reviewed or validated by authorities or other stakeholders
within this project as not being part of the selected Member States.
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10.2 Annex II: Overview on responses by TAC members
Within the first project steps a screening information has been prepared for all 28 EU Member
States including information on hazardous waste legislation, planning and procedures based on
available documents (national legislation, WMP, WPP, implementation reports, statistics). For
verification and commenting, the screening information has been sent to the TAC Members on waste
for all Member States which have not been selected for the in-depth analysis. The following table
includes an overview of which TAC members responded and commented the screening information
on hazardous waste management practice. The information has been considered for the final version
of the screening information and is cited in the document with the shortcut [MS TAC 2015].
Table 10-1: Overview on responses by TAC members
MS Reply date Contact Person
AT 17.07.2015
01.09.2015
Ulrich Kremser,
Federal Ministry of Agriculture, Forestry, Environment and Water Management
BE 27.07.2015
15.09.2015
Nicolas Scherrier, Bruxelles Environnement
Evi Rossi, OVAM, Public Waste Agency of Flanders
BG Covered in in-depth assessment of 10 MS
CY n.a. n.a.
CZ 04.09.2015
11.09.2015
Jaromir Manhart, Ministry of the Environment
DE Covered in in-depth assessment of 10 MS
DK 14.09.2015 Lene Brun, Danish Environmental Protection Agency
EE Covered in in-depth assessment of 10 MS
ES n.a. n.a.
FI Covered in in-depth assessment of 10 MS
FR n.a. n.a.
GR n.a. n.a.
HR n.a. n.a.
HU n.a. n.a.
IE Covered in in-depth assessment of 10 MS
IT Covered in in-depth assessment of 10 MS
LT 08.09.15 Juozas Jezukevičius, Ministry of the Environment
LU Covered in in-depth assessment of 10 MS
LV Covered in in-depth assessment of 10 MS
MT 03.09.2015 Darren Cordina, MEPA, Malta Environment and Planning Authority
NL Covered in in-depth assessment of 10 MS
PL n.a. n.a.
PT 04.09.2015 Ana Cristina Carrola, Portugues Environmental Agency
RO n.a. n.a.
SE 01.09.2015 Henrik Sandstrom, Swedish Environmental Protection Agency
SI 04.09.2015 Lucija Jukic-Sorsak, Ministry of the Environment and Spatial Planning
SK 04.09.2015 Viera Špalková, Ministry of Environment
UK Covered in in-depth assessment of 10 MS
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10.3 Annex III: Overview of conducted expert interviews
Name of institution Contact (Name/E-mail/Phone) Date Information provided / Shortcut for citation
Bulgaria
Ministry of Environment
and Water
Diana Baleva Galya Kostova Slaveya Stoyanova
17.6.15 Personal interview [BG MoEWb 2015]
Executive Environment Agency
Rositsa Karamfilova
18.6.15 Personal interview
[BG ExEEA 2015]
National Statistical Institute Petar Petrov 18.6.15 Personal interview
[BG NIS 2015A]
NADIN - WEEE Recycling
Company
Ivaylo Traykov
18.6.15 Personal interview & site visit
[BG Nadin 2015]
BALBOK - HW Collection
and Treatment
Ralitza Anguelova
17.6.15 Personal interview & site visit
[BG Balbok 2015]
Lubrica - Waste oil
regeneration plant
Radina Kostadinova
24.6.15 E-mail with commented Factsheet
[BG Lubrica 2015]
KCM - Ore mining and metals production
Tsonka Markova
26.6.15 E-mail with commented Factsheet
[BG KCM 2015]
Estonia
Ministry of the Environment Mari-Liis Ummik
Peter Eek
15.07.15 Personal interview
[EE MoEa 2015]
Environment Agency Matti Viisimaa
15.07.15 Personal interview
[EE MoEa 2015]
Information by mail
[EE EAc 2015]
Environmental Board Taimar Ala 15.07.15 Personal interview
[EE MoEa 2015]
Environmental Inspectorate Kristel Lopsik
Rene Rajasalu
16.07.15 Personal interview
[EE INSP 2015]
National Audit Office Tuuli Rasso
Krista Jansen
Viire Viss
16.07.15 Personal interview
[EE NAOa 2015]
Finland
Turku University of Applied Sciences
Nea Metsänranta & Henna Knuutila
10.06.15 Commented Factsheet
The Finnish Environment Insitute
Eevaleena Häkkinen
24.02.15
03.06.15
Information by mail
Commented Factsheet
[FI MoE 2015a]
[FI MoE 2015b]
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Name of institution Contact (Name/E-mail/Phone) Date Information provided / Shortcut for citation
Germany
Federal Environment Agency (Umweltbundesamt)
Dr. Joachim Wuttke
01.06.15 Commented Factsheet
[DE UBA 2015]
Federal Environment Agency (Umweltbundesamt)
Bernd Engelmann 10.06.15 Phone interview
[DE UBA 2015]
Federal Environment Agency (Umweltbundesamt)
Harald Junker 10.06.15 Phone interview
[DE UBA 2015]
German Federal Statistical Office
(Statistisches Bundesamt)
Ms Roß 12.06.15 Phone interview
[DE Destatis 2015a]
German Federal Statistical Office
(Statistisches Bundesamt)
Brigitte Apel 14.08.15 Information by mail
[DE Destatis 2015b]
Environmental Agency of North Rhine Westfalia (LANUV)
Michael Oberdörfer
10.06.15 Phone interview
Commented Factsheet
[DE LANUV NRW 2015]
IMPEL - Cluster i: Improving Implementation of EU Environmental Law (Permitting, Inspection, Enforcement and Smarter Regulation)
Thomas Ormond
Horst Buether
28.05.15 Information by mail
[DE RPDA Hessen 2015]
Regional Authority Düsseldorf – Expert of record keeping system
Hartmut Laabs
10.06.15 Phone interview
[DE BRD NRW 2015]
BDE - Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e.V., Fachbereich 4: Sonderabfallwirtschaft
Sandra Giern
24.06.15 Phone interview
[DE BDE 2015]
AGS – Arbeitsgemeinschaft der Sonderabfall-Entsorgungs-Gesellschaften der Länder
Dr. Olaf Kropp (SAM)
08.06.15 Phone interview
[DE AGS 2015]
BDSAV e.V. – Bundesverband Deutscher Sonderabfallverbrennungsanlagen e.V. (EURITS)
Horst Suchomel
Andreas Neuss
08.07.15 Phone interview
Information by mail
[DE BDSAV 2015]
ITAD German Association of Waste-to-Energy Plants
Carsten Spohn
07.07.15 Phone interview
Information by mail
[DE ITAD 2015]
Ireland
Limerick, Regional Waste Co-ordinator, Southern Waste Region
Phillipa King
24 06.15 Phone interview
Commented Factsheet
[IE Limerick 2015]
Indaver Ireland ltd. (hazardous waste management company)
Claire Downey
Reese Hasselby
02.07.15 Phone interview
Commented Factsheet
Provided good practice examples
[IE Indaver 2015]
Irish Environmental Protection Jonathan Derham 22.07.15 Phone interview
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Name of institution Contact (Name/E-mail/Phone) Date Information provided / Shortcut for citation
Agency (EPA) Jane Keneally, Joe Reilly
Commented Factsheet
Provided good practice examples
[IE EPA & Environ 2015]
Department of the Environment
Brendan O'Neill
Darren Byrne
22.07.15 Phone interview
Commented Factsheet
Provided good practice examples
[IE EPA & Environ 2015]
Italy
A2A Ambiente spa Claudia Mensi 17.06.2015 Commented Factsheet
[IT A2A 2015]
Italian Ministry of Environment Sagnotti Giulia 18.03.2015 Information by mail
[IT MoE 2015]
FISE ASSOAMBIENTE
Elisabetta Perotta
27.02.2015
15.06.2015
Information by mail
Commented Factsheet
[IT FISE 2015A]
[IT FISE 2015B]
REMONDIS Industrie Service GmbH Vertrieb International
Dr. Ludwig Ramacher
02.07.2015 Phone interview
Information by mail
[IT REM 2015]
Company German expert 17.07.2015 Phone interview
[IT EXP 2015]
University of Udine and IEFE, Bocconi University, Milano
Antonio Massarutto
03.08.2015 Phone interview
[IT MAS 2015]
Latvia
Ministry of Environmental Protection and Regional Development
Ilze Donina
Rudite Vesere
13.07.15 Personal interview
[LV MoE 2015]
State Environmental Service Daina Kaleja
Dace Ugule
Inga Senavska
13.07.15 Personal interview
[LV MoE 2015]
State Ltd "Latvian Environment, Geology and Meteorology Centre" (LEGMC)
Intars Cakars
13.07.15 Personal interview
[LV MoE 2015]
Ragn Sells (collection and sorting of HW company)
Diana Afonina
13.07.15 Personal interview
[LV RAGN 2015]
BAO (collection and sorting of HW company)
Maris Kalnins
14.07.15 Personal interview
[LV BAO 2015]
Luxembourg
Environment Agency – waste division (Administration de l’environnement – Division des déchets)
Rober Schmitt
Frank Thewes
06.07.15 Phone interview
Commented Factsheet
[LU Environment Agency 2015]
SuperDrecksKetsch Carlo Guetti
Thomas Hoffmann
30.06.15 Phone interview
Commented Factsheet
[LU SDK 2015]
The Netherlands
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Name of institution Contact (Name/E-mail/Phone) Date Information provided / Shortcut for citation
Reym B.V. Nick Kappen
17.06.15 Phone interview
[NL REY 2015]
Dutch Waste Management Association
Unico van Kooten
11.09.15 Phone interview
[NL DWMA 2015]
Indaver B.V. Bart Clerinx
24.08.15 Information by mail
[NL IND 2015]
United Kingdom
Department fort Environment, Food and Rural Affairs (Defra)
Olu Ogunbadejo
Sarah Steeds
Robin Karfoot
Final review undertaken by:
Jane Stratford
Stephen Cowperthwaite
23.06.15
13.08.15
20.08.15
Phone interview
Information by mail
Commented Factsheet
[UK DEFRA 2015]
Environment Agency UK
On behalf of Scotland, Wales and Northern Ireland Environment Agency
Bob McIntyre
07.08./15 Comments submitted to DEFRA, DEFRA response includes views of the national environmental agencies, Included in
[UK DEFRA 2015]
ESA – Environmental Services Association
Roy Hathaway
Phone interview
[UK ESA 2015a]
Services Association Gene Wilson
24.06.15 Phone interview
[UK ESA 2015b]
Tradebe Andrew Crowther
01.07.15
04.08.15
Phone interview
[UK TRADEBE EURITS 2015]
EURITS Mike Hale 04.08.15 Phone interview
[UK TRADEBE EURITS 2015]
Note: Spain has not been selected for in-depth analysis. However extensive comments have been
received by ASEGRE (Hazardous waste association Spain, Luis Palimo, E-mail 14.07.15) about the HW
management practice in Spain. This information is included in the Spain screening information
document and cited as [ES ASEGRE 2015a].
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10.4 Annex IV: Specific problems on HW management in Member States
The project team has researched specific problems within the MS by means of interviews with
concerned stakeholders which are involved in the practice of HW management in different MS.
Namely, the European Federation on Waste Management and Environmental Services (FEAD) has
been supportive contacting their Members and asking for identification of specific problems as
regards legal and practical implementation of HW requirements. The following answers have been
provided:
Austria [AT FEAD 2015]:
− Austria did not implement the European List of Waste (LoW) into national legislation. Austria
is working with its own (national) list of waste, called „Abfallverzeichnisverordnung“(based
on the former ÖNORM S 2100 „Abfallkatalog“). No legally binding „assignment catalogue“ is
existing, which would give legal certainty to Austrian waste management companies, when
they have to align an Austrian Waste code to a code number of the European List of Waste.
− In the daily practice of managing hazardous waste Austrian industry is confronted with the
fact that some types of waste have to be classified as „hazardous“ inside Austria, but as
„non-hazardous“ outside of Austria in other EU MS and vice versa. In terms of waste
shipment procedures this circumstance might create big problems or even can cause an
„illegal shipment“.
− In terms of classification of hazardous waste, Austrian „HP-criteria“ do not fully comply with
the hazardous properties as listed in Annex III of the Waste Framework Directive.
− Data have to be reported by all Austrian waste management companies electronically (legal
obligation). Although the Electronical Data Management (EDM)-System was introduced
many years ago, no reliable statistics exist – especially concerning hazardous waste. Austrian
industry is reporting hundreds of thousands datasets per year, but public authorities are not
able to present any actual statistics.
Spain [ES ASEGRE 2015]:
− Regarding the list of problems in Spain, it is a mix of all, but specially enforcement and
legislation compliance.
− Legislation compliance and enforcement: Different implementation criteria in the country.
Competent bodies for enforcement are Regional Governments.
− Classification: Inadequate or different classification, an example are empty agrochemical
containers, the classification of that waste is: 02 01 08* - agrochemical waste containing
dangerous substances or 15 01 10* - packaging containing residues of or contaminated by
dangerous substances, but in some regions some streams of that waste can be classified:
non-hazardous as 15 01 01 paper and cardboard, 15 01 02 plastics, 15 01 04 metal, 15 01 06
mixed.
− HW reporting: Data is not reliable data because of inconsistencies between regional
electronic traceability systems.
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− Enforcement: Lack of control on classification, lack of traceability and insufficient
inspections. Lack of traceability and control in other streams (non-HW) with direct impact to
HW, because HW are classified as non-HW and illegally treated or illegally landfilled.
− Consequences: HW are illegally mixed with other streams, for example domestic,
construction and demolition waste and deposit in landfills for that wastes and HW are
illegally treated in facilities not authorised, as is the case of HW waters declassified or
diluted to non-HW and treated in Urban Water Treatment Plants or bio-methanisation
plants. Other cases are refrigerators with fluorinated gases or electric transformers
contaminated with PCB treated in big shredders.
− Other important information: Brokers. This is a new actor introduced by WFD, defined as
“any undertaking arranging the recovery or disposal of waste on behalf of others, including
such brokers who do not take physical possession of the waste”. Brokers present a risk to the
proper HW management. Waste manager with facility has a deposit and a facility to defend
its investment. Broker only responds with deposit, in many cases insufficient to guaranty the
proper management, so require a much more intense control and inspection from public
bodies.
− We think most of these problems would be solved if the producer retained responsibility
for the whole treatment chain, as stated by WFD 15.2. “Without prejudice to Regulation (EC)
No 1013/2006, Member States may specify the conditions of responsibility and decide in
which cases the original producer is to retain responsibility for the whole treatment chain or
in which cases the responsibility of the producer and the holder can be shared or delegated
among the actors of the treatment chain”. The consequence of the existing system in Spain −
responsibility is delegated among the actors of the treatment chain − is that producers are
only interested in the price of the service, but not in the quality or security of the treatment.
So the market (legal and illegal treatments) leads to a lowering of the prices to levels which
do not guaranty the treatment security.
United Kingdom [UK ESA 2015]:
− Legal compliance: The legislation and policy/strategy documents in the UK are generally
satisfactory, but ESA members’ concern is with the lack of implementation on the ground
and the fact that HW may be going to low cost or even “sham” treatment options rather
than the BAT solutions which are more expensive. The Environment Agency does not
proactively implement BAT and waste hierarchy in the UK, although it does try to address
instances of waste crime (see below).
− Classification of hazardous waste: There is a problem of accidental or deliberate
misclassification of HW by HW producers in the UK which the regulatory authorities are
trying to address with the help of ESA and the waste management industry, principally by
providing more information to HW producers. More needs to be done on this.
− HW reporting: It is acknowledged by all sides that the data reporting on hazardous waste in
the UK is by no means perfect. ESA members have called for the introduction of a new
system of electronic consignment notes for HW.
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− Permitting, registration, exemption: At present all HW producers have to register their
premises with the Environment Agency but there are plans to possibly scrap this
requirement under the UK’s “red tape” review. ESA members are concerned about the
possible loss of traceability and accountability of the HW producer if this happens.
− Enforcement (inspection etc.): As already mentioned the UK authorities are fairly active in
tackling waste crime, but they are less active in promoting higher standards within the
industry, for example by not taking action to phase out hazardous waste landfill for certain
types of HW where more state-of-the-art BAT treatments already exist. This means there is
little incentive for ESA members to invest in expensive new HW technology in the future.
Sweden [SE SRI 2015]:
− Our overall opinion about the implementation of the legislation and the waste management
regarding hazardous waste in Sweden is that it works well.
− Enforcement: The one area where there is a potential for improvement is the enforcement.
It is mostly the municipalities that are in charge of the inspections and we often find that
they do not have the resources or the knowledge to deal with the often technically difficult
questions of classification. We feel that this can result in an uneven playing field.
Italy [IT FISE 2015]:
− Classification: In Italy the most important problems in HW legislation are about classification.
For some hazardous properties (H4 - H8 - H14) there have been many problems in making
specific technical regulations. These problems derive from the difficulties to apply CLP rules
to waste. Today these problems are being relevant. It's necessary to have from EU specific
rule for HP 14 (hopefully before 1 June 2015). Without specific European rule for HP14 the
waste classification for HP14 should be suspended or should be declared that HP14 is not
applicable to waste in general. The last change in our legislation (Law 116/2014) declared
that when a mirror code is to be define for a waste, than we have to consider the worst case
“always”…no mention about “applying knowledge of the process/activity that produced the
waste”. As this is now the situation, we will have an increase of hazardous waste from now
until the 1st of June when the new European regulation will be in force. So is very important
to have also guidelines about the correct classification of waste, as in UK; best will be to have
it at a European level.
− Permit procedures: Deriving from above, of course we have also great difficulties in permits
release for treatment plants. It takes long time and sometime it is not affordable at an
economical point of view; it is better, also for authorities, the solution of having export of
hazardous waste to other countries (especially Germany, Holland and Austria).
− Traceability: SISTRI system is in place and is applicable to every producer/holder of HW (any
quantity) but this system can trace just from point A (producer) to point B (holder) like a GPS;
if the holder is, as an example, a mixing treatment plant than the rest of the traceability is
paper documents (register), based on the permit of the plant.
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10.5 Annex V: Overview on available and screened national and regional WMP
Table 10-2: Overview of available and screened national and regional WMPs (February 2015)
MS or Region
WMP Link
AT Federal Waste Management Plan (2011-2017)
(BAWP – Bundesabfallwirtschaftsplan)
http://www.bundesabfallwirtschaftsplan.at
BE - Flanders
Implementation Plan for Environmentally Responsible Household Waste Management (2008-2015) (Uitvoeringsplan Milieuverantwoord Beheer van Huishoudelijke Afvalstoffen)
http://www.ovam.be/sites/default/files/Uitvoeringsplan%20milieuverantwoord%20beheer%20huishoudelijke%20afvalstoffen.pdf
BE - Wallonia
Waste Plan Wallonia (Horizon 2010) (Le Plan Wallon des Déchets) http://environnement.wallonie.be/rapports/owd/pwd/index.htm
BE - Brussels
Waste Prevention and Management Plan (since 2010) http://www.bruxellesenvironnement.be/uploadedFiles/Contenu_du_site/Professionnels/Formations_et_s%C3%A9minaires/Conf%C3%A9rence_Pre-waste_2011_(actes)/w-brusselsenvironment-wasteplanEN.pdf
BG National Waste Management Plan (2014-2020) (Национален план за управление на отпадъците за периода 2014-2020 г.)
http://www.moew.government.bg/files/file/Waste/NACIONALEN_PLAN/_/NPUO_2014-2020.pdf
CY Management Plan for Domestic and Similar Type Wastes 2014- (draft status) (Σχέδιο Διαχείρισης για τα Οικιακά και Παρομοίου Τύπου Απόβλητα)
http://www.moa.gov.cy/moa/environment/environment.nsf/All/D1CF07F7EB83735EC2257A9100270099/$file/TelikoSxedio.pdf
CZ Waste Management Plan of the Czech Republic for the Period 2015 – 2024 (in force since 01/01/15) (Plán odpadového hospodářství České republiky na období 2015 - 2024)
http://portal.cenia.cz/eiasea/detail/SEA_MZP183K
(http://www.mzp.cz/C1257458002F0DC7/cz/news_141222_Vlada_schvalila_POH/$FILE/POH%20CR%20352%202014%20narizeni%20vlady%20sb0141-2014.pdf (government regulation))
DE no national WMP, 16 regional WMPs (see list in below)
DK Denmark without Waste - Resource plan for waste management 2013-2018
(Danmark uden affald - Ressourceplan for affaldshåndtering)
http://www2.mst.dk/Udgiv/publikationer/2014/05/978-87-93178-55-7.pdf
EE National Waste Management Plan 2014-2020 (Riigi Jäätmekava) http://www.envir.ee/et/eesmargid-tegevused/jaatmed/riigi-jaatmekava-2014-2020
ES Integrated Waste National Plan 2008-2015
(Plan Nacional Integrado de Residuos)
http://www.boe.es/boe/dias/2009/02/26/pdfs/BOE-A-2009-3243.pdf
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MS or Region
WMP Link
FI Towards a Recycling Society – The National Waste Plan for 2016 (2007-2016) (two interim reports in 2012 and 2014, WMP applies until end of 2016) (Valtakunnallinen jätesuunnitelma vuoteen)
English summary:
https://helda.helsinki.fi/bitstream/handle/10138/38022/FE_14_2009.pdf?sequence=1
Overview (including link to interim reports):
http://www.ym.fi/sv-FI/Miljo/Avfall/Den_riksomfattande_avfallsplanen
FR no national WMP, ~ 100 regional WMPs, no updated list of WMP could be provided by Ministry of Environment
GR Revision of National Waste Management Plan (2014-2020) (draft status, ongoing public consultation, finished by March/April 2015)
(Αναθεώρηση Εθνικού Σχεδιασμού Διαχείρισης Αποβλήτων)
http://www.ypeka.gr/Default.aspx?tabid=238&language=el-GR
HR Waste Management Plan in the Republic of Croatia for the Period from 2007 to 2015
http://www.fzoeu.hr/hrv/pdf/waste_management_plan.pdf
HU National Waste Management Plan 2014-2020
(Országos Hulladékgazdálkodási Terv)
http://videkstrategia.kormany.hu/download/c/96/90000/Orszagos%20Hulladekgazdalkodasi%20Terv%202014-2020.pdf
IE 1) National Hazardous Waste Management Plan (2014-2020)
Revision of three regional WMP (former 10) (draft status)
2) Southern draft Regional Waste Management Plan 2015-2021
3) Eastern-Midlands draft Regional Waste Management Plan 2015-2021
4) Connacht-Ulster draft Regional Waste Management Plan 2015-2021
1) http://www.epa.ie/pubs/reports/waste/haz/NHWM_Plan.pdf
2) http://southernwasteregion.ie/node?qt-homepage_tabs=4#qt-homepage_tabs
3) http://emwr.ie/wp-content/uploads/2014/11/Final_Draft_Plan_Part_1_2_3EMR_A04_low.pdf
4) http://www.curwmo.ie/Draft_Waste_Plan_for_Connacht_Ulster_Region/
IT no national WMP, 19 regions, 2 autonomous provinces (21 regional/provinces plans) (see list below, input provided by Ministry of Environment)
LT National Waste Management Plan for period 2014-2020
(VALSTYBINIS ATLIEKŲ TVARKYMO 2014-2020 METŲ PLANAS)
http://www3.lrs.lt/pls/inter3/dokpaieska.showdoc_l?p_id=470278
LU General Waste Management Plan 2010-2016
(Plan général de gestion des Déchets)
http://www.environnement.public.lu/dechets/dossiers/pggd/pggd_plan_general.pdf
LV National Waste Management Plan for the period of 2013-2020
(Atkritumu apsaimniekošanas valsts plans 2013.–2020.gadam)
http://polsis.mk.gov.lv/LoadAtt/file9833.doc
MT Waste Management plan for the Maltese islands , A Resource Management Approach, 2014 - 2020
http://msdec.gov.mt/en/Document%20Repository/Waste%20Management%20Plan%202014%20-%202020%20-%20Final%20Document.pdf
NL National Waste Management Plan 2009-2021 http://www.lap2.nl/sn_documents/downloads/01%20Beleidskader/Beleidskader(ttw2)_
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MS or Region
WMP Link
(Landelijk afvalbeheerplan)
In addition: 84 "sector plans" on specific waste streams
00_compleet.pdf
Overview (specific waste streams):
http://www.lap2.nl/sectorplannen.asp
PL National Waste Management Plan 2014 (valid until 31.12.2016)
(Krajowy plan gospodarki odpadami)
https://www.mos.gov.pl/kategoria/3340_krajowy_plan_gospodarki_odpadami_2014/
PT 1) National Waste Management Plan (PNGR) 2014-2020 (last version available from November 2014, waiting to be published)
(Plano Nacional de Gestão de Resíduos)
2) Strategic Plan for Municipal Waste 2020
(Plano Estratégico para os Resíduos Urbanos (PERSU) 2020)
3) Strategic plan for industrial waste management 2000-2015 (Plano Estratégico de Gestão de Resíduos Industriais PESGRI)
4) Strategic plan for healthcare waste 2011-2016 (Plano Estratégico dos Resíduos Hospitalares PERH)
1) http://www.apambiente.pt/index.php?ref=16&subref=84&sub2ref=108&sub3ref=1095
2)http://www.apambiente.pt/_zdata/DESTAQUES/2014/Portaria_PlanoEstrategico_PERSU2020_final.pdf
3) http://www.apambiente.pt/_zdata/Politicas/Residuos/Planeamento/PESGRI/PESGRI.zip
4) http://www.apambiente.pt/_zdata/Politicas/Residuos/Planeamento/PERH/PERH_2011_2016.pdf
RO National Waste Management Plan (2004-2009), Issued: October 2004. No revision or new draft WMP available.
SE From waste handling to resource handling. Swedish Waste Planning 2012-2017 (Från avfallshantering till resurshushållning. Sveriges avfallsplan)
English version:
http://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-6560-7.pdf
Swedish version:
http://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-6502-7.pdf
SI 1) Operational Programme for the management of municipal waste with emphasis on attaining targets from Directives 2008/98/EC, 94/62/EC and 1999/31/EC, Number 35402-2/2013/7 (published 2013) (covering municipal waste only)
(Operativni program ravnanja s komunalnimi odpadki s poudarkom na doseganju okoljskih ciljev iz Direktive 2008/98/ES, Direktive 94/62/ES in Direktive 1999/31/ES, Številka: 35402-2/2013/7)
http://www.mko.gov.si/fileadmin/mko.gov.si/pageuploads/zakonodaja/varstvo_okolja/operativni_programi/op_komunalni_odpadki.pdf
Annex: http://www.mko.gov.si/fileadmin/mko.gov.si/pageuploads/zakonodaja/varstvo_okolja/operativni_programi/op_komunalni_odpadki_priloge.pdf
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MS or Region
WMP Link
Please note: Slovenia is in the process of preparing WMP which will cover the whole state area and define all waste streams (including hazardous waste). Following the Government's program WMP will be adopted latest by the end of 2015.
SK Waste management plan of the Slovak Republic for 2011-2015
(Program odpadového hospodárstva Slovenskej republiky na roky 2011– 2015)
http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/poh-sr-2011-2015.pdf
http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_01.pdf (Annex 1)
http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_02.pdf (Annex 2)
http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_03.pdf (Annex 3)
http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_04.pdf (Annex 4)
http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_05_06.pdf (Annex 5, 6)
UK no national WMP, 5 regions (England, Gibraltar, Northern Ireland, Scotland, Wales) (see list below)
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Table 10-3: Overview of available regional WMPs of Germany (February 2015)
Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
HW
Does it include an overview on
industrial HW generation
BADEN-WURTTEM-
BERG
Waste Management Plan Baden-Wuerttemberg – Municipal Waste, Draft 14.11.2014, stakeholder consultation completed, WMP available in March 2015
Abfallwirtschaftsplan Baden-Württemberg – Teilplan Siedlungsabfälle (2015)
Waste Management Plan Baden-Wuerttemberg – Sector plan hazardous Waste, (2012)
Abfallwirtschaftsplan Baden-Württemberg – Teilplan gefährliche Abfälle, (2012)
https://um.baden-wuerttemberg.de/de/umwelt/abfall-und-kreislaufwirtschaft/rahmenplanung-und-abfallbilanzen/entwurf-des-teilplans-siedlungsabfaelle-stand-29042013/
https://um.baden-wuerttemberg.de/fileadmin//redaktion/m-um/intern/Dateien/Dokumente/2_Presse_und_Service/Publikationen/Umwelt/Abfallwirtschaftsplan_Teilplan_gefaehrliche_Abfaelle.pdf
X X X
BAVARIA
Regulation on Waste Management Plan of Bavaria
Verordnung über den Abfallwirtschaftsplan Bayern (AbfPV)1), (17. Dezember 2014)
http://www.gesetze-bayern.de/jportal/?quelle=jlink&docid=jlr-AbfPlanVBY2014rahmen&psml=bsbayprod.psml&max=true&aiz=true
X X very general
BERLIN
Waste Management Plan Berlin – Sector plan municipal waste (2011-2020)
Abfallwirtschaftsplan Berlin 2010 – Teilplan Sieldungsabfälle (2011-2020)
Waste Management Plan Berlin – Sector plan hazardous waste (2010-2020)
Abfallwirtschaftsplan Berlin 2010 – Teilplan gefährliche Abfälle (2010-2020)
http://www.stadtentwicklung.berlin.de/umwelt/abfall/wirtschaftsplan/download/AWP_Siedlungsabfaelle_2011.pdf
http://www.stadtentwicklung.berlin.de/umwelt/abfall/wirtschaftsplan/download/AWP_Gefaehrliche_Abfaelle2010.pdf
X X X
BRANDEN-BURG
Waste Management Plan for Brandenburg (2012)
Abfallwirtschaftsplan des Landes Brandenburg (2012)
Sectorial Plan for hazardous waste (2005); integrated into WMP from 2012
Teilplan gefährlich Abfälle (2005)
http://www.mlul.brandenburg.de/cms/media.php/lbm1.a.3310.de/awp2012.pdf
http://www.mlul.brandenburg.de/cms/media.php/lbm1.a.3310.de/awpsond05.pdf
X X X
BREMEN Waste Management Plan for Bremen (2006-2015)
Abfallwirtschaftsplan für das Land Bremen (2006–2015)
http://www.umwelt.bremen.de/sixcms/media.php/13/AWP%202007.pdf
X X X
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Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
HW
Does it include an overview on
industrial HW generation
HAMBURG
Waste Management Plan Hamburg – Municipal waste (2007)
Abfallwirtschaftsplan Hamburg- Siedlungsabfälle (2007)
Hamburg Waste Management Plan hazardous waste (2011)
Hamburg - Abfallwirtschaftsplan gefährliche (2011)
http://www.hamburg.de/contentblob/137022/data/awp-hausmuell.pdf
http://www.hamburg.de/contentblob/2755040/data/awp-gefaehrliche-abfaelle-2011.pdf
X X X
HESSE
Waste Management Plan Hesse – Municipal and industrial waste (2010)
Abfallwirtschaftsplan Hessen – Siedlungsabfälle und industrielle Abfälle (2010)
https://umweltministerium.hessen.de/sites/default/files/HMUELV/abfallwirtschaftsplan_siedlungabfaelle_und_industrielle_abfaelle.pdf
X X X
MECKLEN-BURG-VOR-POMMERN
Abfallwirtschaftsplan Mecklenburg- Vorpommern (2008, updated 2014)
Waste Management Plan Mecklenburg- Vorpommern
http://www.regierung-mv.de/cms2/Regierungsportal_prod/Regierungsportal/de/wm/Themen/Abfallwirtschaft/Abfallwirtschaftsplan/index.jsp?publikid=2260
X X very general
LOWER SAXONY
Waste Management Plan – Municipal and non-hazardous waste (2011 – 2017)
Abfallwirtschaftsplan Niedersachsen - Teilplan Siedlungsabfälle und nicht gefährliche Abfälle (2011-2017)
Waste Management Plan – Hazardous waste (2011-2017)
Abfallwirtschaftsplan Niedersachsen Teilplan Sonderabfall (gefährlicher Abfall).
Both plans at:
http://www.umwelt.niedersachsen.de/portal/live.php?navigation_id=27689&article_id=94709&_psmand=10
X X X
NORTH-RHINE WESPHALIA
Waste Management Plan NORTH-RHINE WESPHALIA – Sector Plan municipal waste (2014) , Draft 14.11.2014, stakeholder consultation completed, WMP available in March 2015
Abfallwirtschaftsplan Nordrhein-Westfalen, Teilplan Sieldungsabfäle (2014)
Waste Management Plan North-Rhine Wesphalia – Sector Plan hazardous waste (2007; update report in 2014 with result that no need to revise WMP on hazardous waste)
Abfallwirtschaftsplan Nordrhein-Westfalen
Teilplan Sonderabfälle (gefährliche Abfälle)
http://www.wirev.org/fileadmin/wir-nrw/abfallwirtschaftsplan_nrw_entwurf.pdf
http://www.umwelt.nrw.de/fileadmin/redaktion/abfallwirtschaftsplan.pdf
X X X
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Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
HW
Does it include an overview on
industrial HW generation
RHINELAND-PALATINATE
Waste Management Plan Rhineland-Palatinate – Municipal waste (2013 – 2019)
Abfallwirtschaftsplan Rheinland-Pfalz, Teilplan Sieldungsabfälle (2013 – 2019)
Waste Management Plan Rhineland-Palatinate– Hazardous waste (2013)
Abfallwirtschaftsplan Rheinland-Pfalz, Teilplan Sonderabfallwirtschaft (2013)
http://www.mwkel.rlp.de/File/AWP-Rheinland-Pfalz-2013-Endversion-pdf
http://www.mwkel.rlp.de/File/Sonderabfallplan-November-2013-pdf
X X X
SAARLAND
Waste Management Plan Saarland – Municipal waste (2010
Abfallwirtschaftsplan Saarland, Teilplan Sieldungsabfälle (2010) 2019)
Waste Management Plan Saarland – Sector Plan industrial waste (2008-2017)
Abfallwirtschaftsplan Saarland – Teilplan Abfälle aus Industrie und Gewerbe
http://www.saarland.de/dokumente/res_umwelt/AWP_2010_Endfassung.pdf
http://www.saarland.de/dokumente/thema_abfall/AWP__Mai2008.pdf
X X X
SAXONY
Waste Management Plan for Saxony – update 2009
Abfallwirtschaftsplan für den Freistaat Sachsen- Fortschreibung 2009
https://publikationen.sachsen.de/bdb/artikel/11727 X X very general
SAXONY-ANHALT
Waste Management Plan of Saxony-Anhalt - Sector plan municipal waste (2011-2015)
Abfallwirtschaftsplan - Teilpläne für Siedlungsabfälle (2011-2015)
Waste Management Plan of Saxony-Anhalt – Sector plan for hazardous waste (2011-2015)
Abfallwirtschaftsplan – Teilplan gefährliche Abfälle (2011-2015)
http://www.lvwa.sachsen-anhalt.de/fileadmin/Bibliothek/Politik_und_Verwaltung/LVWA/LVwA/Dokumente/landwirtschaftumwelt/401/abfall/gefaehrlicheAbfaelle.pdf
X X X
SCHLESWIG-HOLSTEIN
Waste Management Plan of Schleswig-Holstein – Sector plan municipal waste (2014-2023), Draft 4.2.2014
Abfallwirtschaftsplan Schleswig-Holstein – Teilplan Siedlungsabfälle (2014 – 2023),
http://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/Startseite/LatenteThemen/PDF/Entwurf_AWP__blob=publicationFile.pdf
X X X
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Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
HW
Does it include an overview on
industrial HW generation
Waste Management Plan Schleswig-Holstein – Sector plan industrial and commercial waste (2015), Draft version from 06.11.2014, consultation until March 2015
Abfallwirtschaftsplan Schleswig-Holstein
-Teilplan Abfälle aus dem industriellen und gewerblichen Bereich
http://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/Abfall/04_Abfallwirtschaftsplaene/045_Oeffentlichkeitsbeteiligung/PDF/Entwurf_Abfallwirtschaftsplan__blob=publicationFile.pdf
THURINGIA Waste Management Plan of Thuringia (2011 – 2017)
Abfallwirtschaftsplan Thüringen
http://www.thueringen.de/imperia/md/content/tmlnu/themen/abfall/lawp.pdf
X X X
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Table 10-4: Overview of available regional WMPs of United Kingdom (February 2015)
Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
HW
Does it include an overview on
industrial HW generation
NORTHERN IRELAND
Southern Region
Southern Waste Management Partnership (SWaMP2008): Waste Management Plan, March 2014 (2012-2020)
http://swamp2008.org.uk/wp-content/uploads/2009/06/IBR0450-SWaMP-WMP-Full-Copy-Final.pdf
X X X
NORTHERN IRELAND
ARC21
Waste management plan (October 2014) http://www.arc21.org.uk/download/1/arc21%20Waste%20Management%20Plan%20Oct%202014.pdf
X X X
NORTHERN IRELAND
North West
A REVIEW OF THE WASTE MANAGEMENT PLAN
2006-2020, DOENI Determined (January 2015)
http://www.northwestwaste.org.uk/wp-content/uploads/2010/12/NWRWMG_Waste_Management_Plan.pdf
X X X
WALES
Municipal Sector Plan (MSP) Part 1 (March 2011)
Collections, Infrastructure and Markets Sector Plan (CIM) (July 2012)
Food, manufacture, service and retail sector plan (2011)
Construction and demolition sector plan (2012)
Commercial and industrial sector plan (2013)
http://wales.gov.uk/docs/desh/publications/110310municipalwasteplan1en.pdf
http://wales.gov.uk/docs/desh/publications/120713wastecimsectorplanen.pdf
http://wales.gov.uk/docs/desh/consultation/110322wastefoodplanen.pdf
http://wales.gov.uk/docs/desh/publications/130301construction-demolition-waste-plan-en.pdf
http://wales.gov.uk/docs/desh/consultation/130513-industrial-commercial-sector-plan-en.pdf
X X X
ENGLAND Waste Management Plan for England
(December 2013)
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265810/pb14100-waste-management-plan-20131213.pdf
X X X
SCOTLAND
Scotland’s zero waste plan (2010)
Waste Data Digest 12: Key facts and trends (2010)
Waste from all sources: waste data tables 2012
http://www.scotland.gov.uk/Topics/Environment/waste-and-pollution/Waste-1/wastestrategy
http://www.sepa.org.uk/waste/waste_data/waste_data_digest.aspx
http://www.sepa.org.uk/waste/waste_data.aspx
X X X
GIBRALTAR Gibraltar waste management plan 2013 https://www.gibraltar.gov.gi/images/stories/PDF/pres
soffice/pressreleases/2013/838.1-2013.pdf X X X
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Table 10-5: Overview of available regional and provincial WMPs of Italy (February 2015)
Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
hazardous waste?
Does it include an overview on
industrial hazardous waste
generation
ABRUZZO
Regional Waste Management Plan (2007), supplement 29.12.2011 Piano Regionale di Gestione dei Rifiuti (2007) New waste management plan in preparation (second link)
http://www.regione.abruzzo.it/xambiente/docs/nuovoPRGR/all.1RelazionePiano.pdf http://www.regione.abruzzo.it/xambiente/index.asp?modello=nuovoPRGR&servizio=LL&stileDiv=sequence&template=default&b=gestRifi10
X (MoE) X (MoE) X (MoE)
BASILICATA Regional Law No 28 of 24 November 2008; however no WMP available New draft announced for end 2016
Outdated
CALABRIA Waste Management Plan of Calabria (2007) Piano Gestione Rifiuti 2007 Regione Calabria (2007)
http://www.regione.calabria.it/ambiente/allegati/raccoltadifferenziata/documentazione/piano_regionale_dei_rifiuti.pdf
Outdated
CAMPANIA
Waste Management Plan of Campania (2012) Piano Regionale per la Gestione dei Rifiuti Urbani della Regione Campania (2011)
http://burc.regione.campania.it/eBurcWeb/publicContent/archivio/archivio.iface (Bulletin 5 of 24.1.2012) http://www.regione.campania.it/it/tematiche/rifiuti/piano-regionale-di-gestione-dei-rifiuti-speciali?page=1
X X (MoE) X (MoE)
EMILIA-ROMAGNA
Regional Waste Management Plan (2014-2020), adopted February 2014 Piano Regionale di Gestione dei Rifiuti
http://ambiente.regione.emilia-romagna.it/rifiuti/temi/piani-e-programmi/piani-e-programmi-1
X X X
FRIULI-VENEZIA GIULIA
New plan adopted 31/12/12 Official Bulletin No 10 of 14 March 2012, Ordinary Series No 15
http://bur.regione.fvg.it/newbur/visionaBUR?bnum=2012/01/13/4 X (MoE) X (MoE) X (MoE)
LAZIO Waste Management Plan of Lazio (2012) Piano di Gestione dei Rifiuti della Regione Lazio (2012)
http://www.regione.lazio.it/binary/rl_main/tbl_documenti/RIF_DCR_12_18_01_2012.pdf
X (MoE) X (MoE) X (MoE)
LIGURIA Regional Management Plan (adopted 27/12/2013) Piano regionale di gestione dei rifiuti e delle bonifiche (2013)
http://www.ambienteinliguria.it/eco3/DTS_GENERALE/20140113/1_Sezione_RU.pdf
X (MoE) X (MoE) X (MoE)
LOMBARDY Regional Waste Programme (2014 -2020), adopted 20/06/2014 Programma regionale di gestione dei rifiuti
http://www.reti.regione.lombardia.it/cs/Satellite?c=Redazionale_P&childpagename=DG_Reti%2FDetail&cid=1213595689750&pagename=DG_RSSWrapper
X (MoE) X (MoE) X (MoE)
MARCHE Regional Waste Plan, adopted 02/02/2015) Piano regionale per la Gestione dei Rifiuti
http://www.ambiente.regione.marche.it/ambiente/rifiuti.aspx
X (MoE) X (MoE) X (MoE)
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Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
hazardous waste?
Does it include an overview on
industrial hazardous waste
generation
MOLISE
Waste Management Plan of the Region Molise(2003) Piano di Gestione dei rifiuti della Regione Molise New plan document from 2013 including SEA for new WMP
http://www.regione.molise.it/web/Assessorati/autorit%C3%A0_ambiente.nsf/0/C4645CCF71DD6473C125744E003B616C?OpenDocument
Outdated
PIEDMONT
Waste Management Plan of the Region Piemont, 2009 – Process of updating since 2011 Piano Regionale di Gestione dei Rifiuti Urbani e dei Fanghi di depurazione
http://www.regione.piemonte.it/ambiente/rifiuti/rifiuti_urbani.htm
Outdated
APULIA
PRGUR – Regional Waste Management Plan for Municipal waste, February 2013 PRGUR – Piano Regionale Gestione dei Rifiuti Urbani PRGUR – Regional Waste Management Plan for „industrial“ waste, 2009
http://www.provincia.brindisi.it/dmdocuments/ambiente/Piano_Reg_Gest_Rifiuti/RIF_21_PRGRU_PARTE_I.pdf http://www.regione.puglia.it/index.php?page=curp&id=4772&opz=display
X
X (MoE) X (MoE)
SARDINIA
Regional Waste Management Plan – Sector plan for Municipal Waste (2008) Piano Regionale di Gestione dei Rifiuti sezione Rifiuti Urbani (2008) Regional Waste Management Plan – Sector plan for Hazardous Waste (21.12.2012) Piano Regionale Di Gestione Dei Rifiuti Speciali
http://www.sardegnaambiente.it/documenti/18_183_20090115125209.pdf http://www.sardegnaambiente.it/documenti/18_330_20130122105848.pdf
X
X X
SICILY
Waste Management Plan for Solid Municipal Waste, approved August 2012, SEA published May 2014 Piano Di Gestione Dei Rifiuti Solidi Urbani
http://pti.regione.sicilia.it/portal/page/portal/PIR_PORTALE/PIR_LaStrutturaRegionale/PIR_AssEnergia/PIR_Dipartimentodellacquaedeirifiuti/PIR_PianoGestioneIntegratadeiRifiuti/Piano_di_gestione_03_07_2012.pdf
Outdated (MoE)
TUSCANY
Regional Waste Management and Contaminated Site Remediation Plan “Prevention, Recycling and Recovery” (2014-2020), adopted 18.11.2014 Piano regionale di gestione dei rifiuti e bonifica dei siti inquinati “Prevenzione, Riciclo e Recupero”
http://www.regione.toscana.it/-/piano-regionale-di-gestione-dei-rifiuti-e-bonifica-dei-siti-inquinati
X X X
TRENTINO
Provincial plan of Trentino for municipal wate (2006), there might be an update/new WMP from 2013, not published Piano provinciale sdmi altimento rifiuti Provincial plan of Trentino for industrial waste of 2010
http://www.appa.provincia.tn.it/pianificazione/Piano_smaltimento_rifiuti
X (MoE) X (MoE) X (MoE)
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Region WMP (Title and time frame) Link Does a valid and adopted WMP exists?
Does it include specification on
hazardous waste?
Does it include an overview on
industrial hazardous waste
generation
(2004) Piano provinciale di smaltimento dei rifiuti pericolosi
BOLZANO
Waste management plan (2000) Piano gestione rifuti Waste Management Plan for hazardous waste Piano provincial per la gestione dei rifiuti peligroso (2006)
http://www.provincia.bz.it/agenzia-ambiente/rifiuti/piani-gestione-rifiuti.asp http://www.provincia.bz.it/agenzia-ambiente/download/Piano_gestione_rifiuti_pericolosi.pdf
X (MoE) X (MoE) X (MoE)
UMBRIA Regional Waste Management Plan (2009) Piano Regionale di Gestione dei Rifiuti
http://www.ambiente.regione.umbria.it/MEDIACENTER/FE/CategoriaMedia.aspx?idc=148
X X (MoE) X (MoE)
VALLE D’AOSTA
Waste Management Plan 2003, update-procedure since 2014 Piano gestione rifuiuti 2003 updating procedure since 2014
http://www.regione.vda.it/territorio/ambiente/rifiuti/piano_gestione_rifiuti/default_i.asp
X (MoE) X (MoE) X (MoE)
VENETO Regional Plan for Urban and Hazardous Waste (22.32013) Piano Regionale Per La Gestione Dei Rifiuti Urbani e Speciale
http://www.regione.veneto.it/web/ambiente-e-territorio/piano-gestione-rifiuti
X X (MoE)) X (MoE)
*The Ministry of Environment has commented the list of regional WMPs in Italy. Comments from Ministry are marked with (MoE); information could not been
cross-checked.
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10.6 Annex VI: Overview on available and screened national waste prevention programmes
Table 10-6: Overview on available and screened waste prevention programmes (WPPs)
MS or Region WPP Link
AT WPP is included in WMP (Chapter 6, pp. 207–239) (2011-2017)
BE - Flanders Under development
BE - Wallonia Drafted in 2012 and currently under political discussion
BE - Brussels WPP is included in WMP (Main part of the Waste Management Plan) (2010-intermediate duration)
BG WPP is included in WMP
CY Public consultations were finalised on 23 December 2013. Adoption is
expected in 2014.
CZ WPP is included in WMP
DE Waste Prevention Programme of the federal government including the federal states (Abfallvermeidungsprogramm des Bundes unter Beteiligung der Länder)3
http://www.bmu.de/fileadmin/Daten_BMU/Download_PDF/Wasser_Abfall_Boden/Abfallwirtschaft/abfallvermeidungsprogramm_bf.pdf
DK Denmark without Waste - Resources Strategy for Waste Management
2013-2018
http://mim.dk/media/mim/67848/Ressourcestrategi_UK_web.pdf?
EE Waste prevention programme (2011-2017) included in WMP Annex 3 (Jäätmetekke vältimise programm)
https://www.osale.ee/konsultatsioonid/files/consult/256_Lisa%203%20Jaatmetekke%20valtimise%20programm.pdf
ES State Programme for Waste Prevention 2014-2020
(Programa Estatal de Prevencion de Residuos)
http://www.magrama.gob.es/imagenes/es/Programa%20de%20prevencion%20aprobado%20actualizado%20ANFABRA%2011%2002%202014_tcm7-310254.pdf
FI WPP is included in WMP
FR National Waste Prevention Programme 2014-2020 (Programme national
de prévention des déchets 2014-2020)
http://www.developpement-durable.gouv.fr/IMG/pdf/Programme_national_prevention_dechets_2014-2020.pdf
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MS or Region WPP Link
GR NATIONAL WASTE PREVENTION PLAN (ΕΘΝΙΚΟ ΣΤΡΑΤΗΓΙΚΟ ΣΧΕΔΙΟ ΠΡΟΛΗΨΗΣ ΔΗΜΙΟΥΡΓΙΑΣ ΑΠΟΒΛΗΤΩΝ)
WPP under development. Adoption was planned for 2014.
http://www.ypeka.gr/Default.aspx?tabid=238&language=el-GR
HR New WPP will be included in WMP 2015-2021
HU WPP is included in WMP
IE Towards a Resource Efficient Ireland- A National Strategy to 2020 incorporating Ireland’s National Waste Prevention Programme
http://www.epa.ie/pubs/reports/waste/prevention/TowardsAResourceEfficientIreland.pdf
IT Programma Nazionale di Prevenzione dei Rifiuti (National Waste Prevention Programme 2013-2020)
http://www.minambiente.it/sites/default/files/archivio/normativa/dm_07_10_2013_programma.pdf
LT Lithuanian National Waste Prevention Programme 2014-2020
(VALSTYBINĖ ATLIEKŲ PREVENCIJOS PROGRAMA)
http://www3.lrs.lt/pls/inter3/dokpaieska.showdoc_l?p_id=458655&p_tr2=2
LU WPP is included in WMP
LV WPP is included in WMP
MT WPP is included in WMP
NL National Waste Prevention Programme 2014 (Afvalpreventieprogramma Nederland 2014)
http://www.lap2.nl/sn_documents/downloads/07%20Afvalpreventieprogramma/Afvalpreventieprogramma%20NL%20final%202013.pdf
PL WPP included in WMP
PT Urban Waste Prevention Program (Programa de Prevenção de Resíduos Urbanos e 2010-2016)
http://www.apambiente.pt/index.php?ref=16&subref=84&sub2ref=106&sub3ref=268
RO Romania will start a project to develop a waste prevention programme in
2014
?
SE Swedish Waste prevention programme 2014 – 2017 (Tillsammans vinner vi på ett giftfritt och resurseffektivt samhälle - Sveriges program för att förebygga avfall 2014-2017)
http://www.naturvardsverket.se/upload/miljoarbete-i-samhallet/miljoarbete-i-sverige/avfall/avfallsforebyggande-programmet/avfallsforebyggande-programmet-giftfritt-resurseffektivt-samhalle.pdf
SI WPP is under development. Adoption was planned for 2014. ?
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MS or Region WPP Link
SK Waste Prevention Program of the Slovak Republic for the period 2014-2018
(Program predchádzania vzniku odpadu SR na roky)
http://www.minzp.sk/files/sekcia-enviromentalneho-hodnotenia-riadenia/odpady-a-obaly/registre-a-zoznamy/ppvo-vlastnymaterial.pdf
UK - England Prevention is better than cure – The role of waste prevention in moving to a more resource efficient economy (2013)
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265022/pb14091-waste-prevention-20131211.pdf
UK - Gibraltar WPP is included in WMP
UK - Northern Ireland
THE WASTE PREVENTION PROGRAMME FOR NORTHERN IRELAND – THE ROAD TO ZERO WASTE (2014)
http://www.doeni.gov.uk/waste_prevention_programme_for_ni_2014-2.pdf
UK - Scotland Safeguarding Scotland's Resources - Blueprint for a More Resource Efficient and Circular Economy (2013) (programme is part of the “Zero waste agenda”)
http://www.scotland.gov.uk/Resource/0043/00435308.pdf
UK - Wales Towards Zero Waste. One Wales: One Planet. The Waste Prevention Programme for Wales (2013-)
http://wales.gov.uk/docs/desh/publications/131203waste-prevention-programme-document-en.pdf
Sources: [EC BiPRO 2014, EEA 2014, consultation of stakeholders] (February 2015)
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