Support to Member States in improving hazardous …...PROJECT Support to Member States in improving...

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

mailto:[email protected]

http://www.bipro.de/


ENV/2014/SI2.689463/ETU/A2 3


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

ENV/2014/SI2.689463/ETU/A2 4


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

ENV/2014/SI2.689463/ETU/A2 5


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

ENV/2014/SI2.689463/ETU/A2 6


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

ENV/2014/SI2.689463/ETU/A2 7


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

ENV/2014/SI2.689463/ETU/A2 8


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

ENV/2014/SI2.689463/ETU/A2 9



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

ENV/2014/SI2.689463/ETU/A2 10



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

ENV/2014/SI2.689463/ETU/A2 11


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)

ENV/2014/SI2.689463/ETU/A2 12


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

ENV/2014/SI2.689463/ETU/A2 13


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:

ENV/2014/SI2.689463/ETU/A2 14


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

ENV/2014/SI2.689463/ETU/A2 15


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:



ENV/2014/SI2.689463/ETU/A2 16


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

ENV/2014/SI2.689463/ETU/A2 17


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.

ENV/2014/SI2.689463/ETU/A2 18


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

ENV/2014/SI2.689463/ETU/A2 19


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

ENV/2014/SI2.689463/ETU/A2 20


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:

ENV/2014/SI2.689463/ETU/A2 21


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



ENV/2014/SI2.689463/ETU/A2 22


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:


- 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.


ENV/2014/SI2.689463/ETU/A2 23


− 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


ENV/2014/SI2.689463/ETU/A2 24


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.

ENV/2014/SI2.689463/ETU/A2 25


− 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.

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014D0955

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R1357

ENV/2014/SI2.689463/ETU/A2 26


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.

ENV/2014/SI2.689463/ETU/A2 27


− 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)


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

ENV/2014/SI2.689463/ETU/A2 28


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 ordinance on waste recovery / disposal records

- Further national regulation on implementation

ENV/2014/SI2.689463/ETU/A2 29


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

ENV/2014/SI2.689463/ETU/A2 30


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)?


- 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):

ENV/2014/SI2.689463/ETU/A2 31


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


“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).


- 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].

ENV/2014/SI2.689463/ETU/A2 32


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)



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:

ENV/2014/SI2.689463/ETU/A2 33


(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).

ENV/2014/SI2.689463/ETU/A2 34


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?




ENV/2014/SI2.689463/ETU/A2 35


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

ENV/2014/SI2.689463/ETU/A2 36


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].

ENV/2014/SI2.689463/ETU/A2 37


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

ENV/2014/SI2.689463/ETU/A2 38


(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):

ENV/2014/SI2.689463/ETU/A2 39


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 overestimation 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:

ENV/2014/SI2.689463/ETU/A2 40


− 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


- National statistics


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

http://prtr.ec.europa.eu/WasteTransfer.aspx

ENV/2014/SI2.689463/ETU/A2 41


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.

ENV/2014/SI2.689463/ETU/A2 42


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)


- National Statistics

- E-PTR register (considering information about waste transfers as per country -


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



− 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%).

ENV/2014/SI2.689463/ETU/A2 43


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)




2010 (DK, IT, LT, LU)

- E-PRTR register (considering information about waste transfers as per country -


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 :

ENV/2014/SI2.689463/ETU/A2 44


− Type of waste: W012 (Acid, alkaline or saline wastes)



− 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.


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.


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.


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.

ENV/2014/SI2.689463/ETU/A2 45


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)



- 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 -


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%.


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.


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).

ENV/2014/SI2.689463/ETU/A2 46



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.

ENV/2014/SI2.689463/ETU/A2 47


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

ENV/2014/SI2.689463/ETU/A2 48


- 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

ENV/2014/SI2.689463/ETU/A2 49


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)


- [Prognos 2009] European Atlas of Secondary Raw Materials and [Prognos

2009a] Study of waste streams and secondary materials in the EU


- 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):

ENV/2014/SI2.689463/ETU/A2 50


− 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

http://isoh.cenia.cz/groupisoh/

http://pub.stat.ee/px-web.2001/I_Databas/Environment/01Environmental_pressure/06Generation_of_waste/06Generation_of_waste.asp



http://www.irep.ecologie.gouv.fr/IREP/index.php?adr=http://www.irep.ecologie.gouv.fr/IREP/generic.php?strType=presentation


http://cms.enviroportal.sk/odpady/verejne-informacie.php

http://www.geostore.com/environment-agency/WebStore?xml=environment-agency/xml/ogcDataDownload.xml

http://www.geostore.com/environment-agency/WebStore?xml=environment-agency/xml/ogcDataDownload.xml

http://www.bundesabfallwirtschaftsplan.at/

http://mst.dk/virksomhed-myndighed/affald/tal-for-affald/statistikker-og-isag-dataudtraek/isag-informations-system-for-affald-og-genanvendelse/

http://mst.dk/virksomhed-myndighed/affald/tal-for-affald/statistikker-og-isag-dataudtraek/isag-informations-system-for-affald-og-genanvendelse/

ENV/2014/SI2.689463/ETU/A2 51


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


“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

ENV/2014/SI2.689463/ETU/A2 52


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.

ENV/2014/SI2.689463/ETU/A2 53


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%)


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.

ENV/2014/SI2.689463/ETU/A2 54



[t/2012] [% of EU-28]


3. W013: Used oils (5 kt; 16%)

CZ 1,481,281 1.5% 1. W126: Soils (387 kt; 26%)


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%)


3. W103: Sorting residues (131 kt; 11%)

EE 9,159,140 9.0% 1. W124: Combustion wastes (7,543 kt; 82%)


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%)


FI 1,653,942 1.6% 1. W12B: Other mineral wastes (W122+W123+W125) (746 kt; 45%)



FR 11,303,137 11.2% 1. W126: Soils (2,444 kt; 22%)

2. W081: Discarded vehicles (1,496 kt; 13%)


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%)


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%)

ENV/2014/SI2.689463/ETU/A2 55



[t/2012] [% of EU-28]


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%)


3. W075: Wood wastes (39 kt; 12%)

LV 95,110 0.1% 1. W126: Soils (30 kt; 31%)



MT 29,326 0.0% 1. W081: Discarded vehicles (12 kt; 42%)



NL 4,859,942 4.8% 1. W121: Mineral waste from construction and demolition (1,369 kt; 28%)


3. W127: Dredging spoils (585 kt; 12%)

PL 1,737,024 1.7% 1. W124: Combustion wastes (341 kt; 20%)



PT 544,963 0.5% 1. W02A: Chemical wastes (96 kt; 18%)



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%)



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%)


UK 8,452,496 8.3% 1. W081: Discarded vehicles (1,641 kt; 19%)


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.

ENV/2014/SI2.689463/ETU/A2 56


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.

ENV/2014/SI2.689463/ETU/A2 57


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

ENV/2014/SI2.689463/ETU/A2 58


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

ENV/2014/SI2.689463/ETU/A2 59


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:


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.


ENV/2014/SI2.689463/ETU/A2 60


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.

ENV/2014/SI2.689463/ETU/A2 61


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.

ENV/2014/SI2.689463/ETU/A2 62


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/



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


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.

ENV/2014/SI2.689463/ETU/A2 63


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


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.

ENV/2014/SI2.689463/ETU/A2 64


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

ENV/2014/SI2.689463/ETU/A2 65


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.

ENV/2014/SI2.689463/ETU/A2 66


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

ENV/2014/SI2.689463/ETU/A2 67


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

ENV/2014/SI2.689463/ETU/A2 68


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

ENV/2014/SI2.689463/ETU/A2 69


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

ENV/2014/SI2.689463/ETU/A2 70


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.

ENV/2014/SI2.689463/ETU/A2 71


− 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).

ENV/2014/SI2.689463/ETU/A2 72


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.

ENV/2014/SI2.689463/ETU/A2 73


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.

ENV/2014/SI2.689463/ETU/A2 74


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

http://scp.eionet.europa.eu/Hazardous%20waste%20review_working%20paper_final.pdf

ENV/2014/SI2.689463/ETU/A2 75


− 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


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

ENV/2014/SI2.689463/ETU/A2 76



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 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


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 were provided.

HR Croatian Environment Agency, e-mail dated 16 March, 2015


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


HU Statistics Office Hungary, e-mail dated 18 March, 2015


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.



IE Statistics Office Ireland, e-mail dated 3 March, 2015


Data collection methodology The difference between generation and treatment is explained through methodological reasons (potential double counting).


Additional information provided with reference to the EPA’s National Waste Report for 2012.

LV Statistics Office Latvia, e-mail dated 12 March, 2015


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).

ENV/2014/SI2.689463/ETU/A2 77



Data collection methodology Around 61,894 t of hazardous waste are stored on-site.


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


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 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


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.



PT Statistics Office Portugal, e-mail dated 18 March, 2015


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


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 information was provided to the report “Avfall i Sverige 2012”

ENV/2014/SI2.689463/ETU/A2 78



SI Statistics Office Slovenia, e-mail dated 17 March, 2015


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 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


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%)

ENV/2014/SI2.689463/ETU/A2 79


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.

ENV/2014/SI2.689463/ETU/A2 80


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.

ENV/2014/SI2.689463/ETU/A2 93


− 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

ENV/2014/SI2.689463/ETU/A2 94


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).

ENV/2014/SI2.689463/ETU/A2 95


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

ENV/2014/SI2.689463/ETU/A2 96


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.


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.


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);


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:

ENV/2014/SI2.689463/ETU/A2 97


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

ENV/2014/SI2.689463/ETU/A2 98


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

ENV/2014/SI2.689463/ETU/A2 99


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


Statistical gap


Treatment

(excluding Annex

2 WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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

ENV/2014/SI2.689463/ETU/A2 100


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.


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.


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.



- 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.

ENV/2014/SI2.689463/ETU/A2 101


Table 5-4: Summary on statistical data, differences and explanations for Finland


Statistical

gap at

Eurostat data

Generation

Treatment

(excluding Annex

2 WStatR)

Export Imports Difference (Gap)

(GEN - EXP + IMP) - TRT


estimated

Eurostat,


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


Data

comparison

Eurostat FI Stat 2015



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

ENV/2014/SI2.689463/ETU/A2 102


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.


- 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


Statistical gap


Treatment

(excluding Annex

2 WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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

ENV/2014/SI2.689463/ETU/A2 103


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).


Data

comparison

Eurostat German Statistical Office (Destatis)



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

ENV/2014/SI2.689463/ETU/A2 104


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).



- 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


Statistical gap


Treatment

(excluding

Annex 2

WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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

ENV/2014/SI2.689463/ETU/A2 105


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.


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.


- 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%).

ENV/2014/SI2.689463/ETU/A2 106


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


Statistical gap


Treatment

(excluding Annex

2 WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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

http://ec.europa.eu/eurostat/documents/3859598/5915865/KS-RA-10-011-EN.PDF/39cda22f-3449-4cf6-98a6-280193bf770

http://ec.europa.eu/eurostat/documents/3859598/5915865/KS-RA-10-011-EN.PDF/39cda22f-3449-4cf6-98a6-280193bf770

ENV/2014/SI2.689463/ETU/A2 107



Data

comparison

Eurostat IT ISPRA



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.


− 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

ENV/2014/SI2.689463/ETU/A2 108


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


Statistical

gap at

Eurostat data

Generation

Treatment

(excluding

Annex 2 WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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

http://parissrv.lvgmc.lv/#viewType=home_view

http://www.lvgmc.lv/lapas/vide/atkritumi/atkritumu-statistikas-apkopojumi/atkritumu-statistikas-apkopojumi?id=1713&nid=380

http://www.lvgmc.lv/lapas/vide/atkritumi/atkritumu-statistikas-apkopojumi/atkritumu-statistikas-apkopojumi?id=1713&nid=380

http://data.csb.gov.lv/pxweb/en/vide/vide__ikgad__vide/VI0040.px/table/tableViewLayout1/?rxid=a79839fe-11ba-4ecd-8cc3-4035692c5fc8

http://data.csb.gov.lv/pxweb/en/vide/vide__ikgad__vide/VI0040.px/table/tableViewLayout1/?rxid=a79839fe-11ba-4ecd-8cc3-4035692c5fc8

ENV/2014/SI2.689463/ETU/A2 109



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

ENV/2014/SI2.689463/ETU/A2 110


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.


− 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


Statistical

gap at

Eurostat data

Generation

Treatment

(excluding Annex

2 WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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.

ENV/2014/SI2.689463/ETU/A2 111


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


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

ENV/2014/SI2.689463/ETU/A2 112


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.


− 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

http://statline.cbs.nl/Statweb/dome/?TH=5560&LA=en

ENV/2014/SI2.689463/ETU/A2 113


Table 5-10: Summary on statistical data, differences and explanations for the Netherlands


Statistical gap

at Eurostat

data

Generation

Treatment

(excluding

Annex 2

WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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


Data

comparison

. Eurostat 2010 [NL RIJK 2013b]**

HW generation 4,485 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:

ENV/2014/SI2.689463/ETU/A2 114


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.


− 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


Statistical gap


Treatment

(excluding Annex

2 WStatR)

Export Imports

Difference (Gap)

(GEN - EXP + IMP) -

TRT


estimated

Eurostat,


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

ENV/2014/SI2.689463/ETU/A2 115


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.


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.

ENV/2014/SI2.689463/ETU/A2 116


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).


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.


− 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

ENV/2014/SI2.689463/ETU/A2 117


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

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’

ENV/2014/SI2.689463/ETU/A2 129


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

http://stoffen-info.nl/

ENV/2014/SI2.689463/ETU/A2 130


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

http://www.legilux.public.lu/rgl/2005/A/0696/1.pdf

ENV/2014/SI2.689463/ETU/A2 131


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).

ENV/2014/SI2.689463/ETU/A2 132


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).

ENV/2014/SI2.689463/ETU/A2 133


− 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

ENV/2014/SI2.689463/ETU/A2 134


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

ENV/2014/SI2.689463/ETU/A2 135


− 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).

ENV/2014/SI2.689463/ETU/A2 136


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.

ENV/2014/SI2.689463/ETU/A2 137


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/

ENV/2014/SI2.689463/ETU/A2 138


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

ENV/2014/SI2.689463/ETU/A2 139


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.

ENV/2014/SI2.689463/ETU/A2 140


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.

ENV/2014/SI2.689463/ETU/A2 141


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.

ENV/2014/SI2.689463/ETU/A2 142


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

ENV/2014/SI2.689463/ETU/A2 143


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.

ENV/2014/SI2.689463/ETU/A2 144


− 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,

ENV/2014/SI2.689463/ETU/A2 145


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

ENV/2014/SI2.689463/ETU/A2 146


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.

ENV/2014/SI2.689463/ETU/A2 147


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

ENV/2014/SI2.689463/ETU/A2 148


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.

ENV/2014/SI2.689463/ETU/A2 150


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.

ENV/2014/SI2.689463/ETU/A2 151


Different levels of performance regarding the separate collection of WEEE and batteries/



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


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


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.

ENV/2014/SI2.689463/ETU/A2 152


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.

ENV/2014/SI2.689463/ETU/A2 153


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.

ENV/2014/SI2.689463/ETU/A2 154


Information Sources

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[Assessment GR WMP 2014] European Commission - Detailed evaluation report for assessing GR WMP, carried out by BiPRO, 2014

[Assessment LT WMP 2014] European Commission - Detailed evaluation report for assessing LT WMP, carried out by BiPRO, 2014

[Assessment PT WMP 2014] European Commission - Detailed evaluation report for assessing PT WMP, carried out

by BiPRO, 2014

[Assessment SI MWMP 2014] European Commission - Detailed evaluation report for assessing SI MWMP, carried out by BiPRO, 2014

[Assessment SK WMP 2014] European Commission - Detailed evaluation report for assessing SK WMP, carried out by BiPRO, 2014

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[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

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/405120/LIT_9910.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/405120/LIT_9910.pdf

https://www.gov.uk/topic/environmental-management/waste

https://www.gov.uk/how-to-classify-different-types-of-waste

https://www.gov.uk/government/publications/waste-classification-technical-guidance

https://www.gov.uk/government/publications/waste-classification-technical-guidance

https://www.gov.uk/government/statistical-data-sets/env23-uk-waste-data-and-management

https://www.gov.uk/government/statistical-data-sets/env23-uk-waste-data-and-management

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/401400/Digest_of_waste_England_2015_-_final.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/401400/Digest_of_waste_England_2015_-_final.pdf

https://www.gov.uk/managing-your-waste-an-overview/storage

http://scp.eionet.europa.eu/facts/WPP/england


http://webarchive.nationalarchives.gov.uk/20140328084622/http:/cdn.environment-agency.gov.uk/geho0611btuv-e-e.pdf

http://webarchive.nationalarchives.gov.uk/20140328084622/http:/cdn.environment-agency.gov.uk/geho0611btuv-e-e.pdf

http://www.360environmental.co.uk/legislation/waste_legislation/hazardous_waste/

http://www.360environmental.co.uk/legislation/waste_legislation/hazardous_waste/

http://www.legislation.gov.uk/uksi/2005/894/note/made

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265810/pb14100-waste-management-plan-20131213.pdf


https://www.gov.uk/government/publications/waste-prevention-programme-for-england

https://www.gov.uk/government/publications/waste-prevention-programme-for-england

http://europa.eu/rapid/press-release_MEMO-15-4871_en.htm

http://www.gibraltarlaws.gov.gi/articles/1950-07o.pdf

ENV/2014/SI2.689463/ETU/A2 177


[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

https://www.gibraltar.gov.gi/images/stories/PDF/pressoffice/pressreleases/2013/838.1-2013.pdf


https://www.gov.uk/government/collections/national-operator-waste-returns

http://www.hse.gov.uk/pubns/priced/hsg71.pdf

http://www.legislation.gov.uk/nisr/2005/300/contents/made

http://www.arc21.org.uk/download/1/arc21%20Waste%20Management%20Plan%20Oct%202014.pdf

http://www.arc21.org.uk/download/1/arc21%20Waste%20Management%20Plan%20Oct%202014.pdf

http://www.northwestwaste.org.uk/wp-content/uploads/2010/12/NWRWMG_Waste_Management_Plan.pdf


http://swamp2008.org.uk/wp-content/uploads/2009/06/IBR0450-SWaMP-WMP-Full-Copy-Final.pdf


http://www.doeni.gov.uk/index/protect_the_environment/waste/rethink_waste.htm

http://www.doeni.gov.uk/index/protect_the_environment/waste/rethink_waste.htm


http://scp.eionet.europa.eu/facts/WPP/scotland


http://www.legislation.gov.uk/ssi/2011/226/contents/made%202011

http://www.legislation.gov.uk/ssi/2011/228/contents/made

http://www.scotland.gov.uk/Topics/Environment/waste-and-pollution/Waste-1/wastestrategy


http://www.scotland.gov.uk/Resource/0043/00435308.pdf

ENV/2014/SI2.689463/ETU/A2 178


[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

http://scp.eionet.europa.eu/facts/WPP/wales

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


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/110310municipalwasteplan1en.pdf

http://wales.gov.uk/docs/desh/publications/131203waste-prevention-programme-document-en.pdf


http://www.un.org/esa/dsd/dsd_aofw_ni/ni_pdfs/NationalReports/belgium/WasteManagement.pdf

http://www.un.org/esa/dsd/dsd_aofw_ni/ni_pdfs/NationalReports/belgium/WasteManagement.pdf

https://www.retsinformation.dk/Forms/R0710.aspx?id=144615

https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp

ENV/2014/SI2.689463/ETU/A2 179


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

ENV/2014/SI2.689463/ETU/A2 180


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.

ENV/2014/SI2.689463/ETU/A2 181


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

ENV/2014/SI2.689463/ETU/A2 182


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


[EE MoEa 2015]

Environment Agency Matti Viisimaa


[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


[EE INSP 2015]

National Audit Office Tuuli Rasso

Krista Jansen

Viire Viss


[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]

http://www.kcm2000.bg/activity/production/

http://www.kcm2000.bg/activity/production/

ENV/2014/SI2.689463/ETU/A2 183



Germany

Federal Environment Agency (Umweltbundesamt)

Dr. Joachim Wuttke

01.06.15 Commented Factsheet

[DE UBA 2015]


Bernd Engelmann 10.06.15 Phone interview

[DE UBA 2015]


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


[DE BRD NRW 2015]

BDE - Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e.V., Fachbereich 4: Sonderabfallwirtschaft

Sandra Giern


[DE BDE 2015]

AGS – Arbeitsgemeinschaft der Sonderabfall-Entsorgungs-Gesellschaften der Länder

Dr. Olaf Kropp (SAM)


[DE AGS 2015]

BDSAV e.V. – Bundesverband Deutscher Sonderabfallverbrennungsanlagen e.V. (EURITS)

Horst Suchomel

Andreas Neuss


Information by mail

[DE BDSAV 2015]

ITAD German Association of Waste-to-Energy Plants

Carsten Spohn


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


Commented Factsheet

Provided good practice examples

[IE Indaver 2015]

Irish Environmental Protection Jonathan Derham 22.07.15 Phone interview

ENV/2014/SI2.689463/ETU/A2 184



Agency (EPA) Jane Keneally, Joe Reilly

Commented Factsheet


[IE EPA & Environ 2015]

Department of the Environment

Brendan O'Neill

Darren Byrne


Commented Factsheet


[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


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


[IT MAS 2015]

Latvia

Ministry of Environmental Protection and Regional Development

Ilze Donina

Rudite Vesere


[LV MoE 2015]

State Environmental Service Daina Kaleja

Dace Ugule

Inga Senavska


[LV MoE 2015]

State Ltd "Latvian Environment, Geology and Meteorology Centre" (LEGMC)

Intars Cakars


[LV MoE 2015]

Ragn Sells (collection and sorting of HW company)

Diana Afonina


[LV RAGN 2015]

BAO (collection and sorting of HW company)

Maris Kalnins


[LV BAO 2015]

Luxembourg

Environment Agency – waste division (Administration de l’environnement – Division des déchets)

Rober Schmitt

Frank Thewes


Commented Factsheet

[LU Environment Agency 2015]

SuperDrecksKetsch Carlo Guetti

Thomas Hoffmann


Commented Factsheet

[LU SDK 2015]

The Netherlands

ENV/2014/SI2.689463/ETU/A2 185



Reym B.V. Nick Kappen


[NL REY 2015]

Dutch Waste Management Association

Unico van Kooten


[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


[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].

ENV/2014/SI2.689463/ETU/A2 186


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.

ENV/2014/SI2.689463/ETU/A2 187


− 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.

ENV/2014/SI2.689463/ETU/A2 188


− 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.

ENV/2014/SI2.689463/ETU/A2 189


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.)


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




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





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

http://www.mzp.cz/C1257458002F0DC7/cz/news_141222_Vlada_schvalila_POH/$FILE/POH%20CR%20352%202014%20narizeni%20vlady%20sb0141-2014.pdf

ENV/2014/SI2.689463/ETU/A2 190


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)


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)


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)


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)_

https://helda.helsinki.fi/bitstream/handle/10138/38022/FE_14_2009.pdf?sequence=1

http://www.ym.fi/sv-FI/Miljo/Avfall/Den_riksomfattande_avfallsplanen


http://www.fzoeu.hr/hrv/pdf/waste_management_plan.pdf



http://www.epa.ie/pubs/reports/waste/haz/NHWM_Plan.pdf

http://southernwasteregion.ie/node?qt-homepage_tabs=4#qt-homepage_tabs








ENV/2014/SI2.689463/ETU/A2 191


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:


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)


Annex: http://www.mko.gov.si/fileadmin/mko.gov.si/pageuploads/zakonodaja/varstvo_okolja/operativni_programi/op_komunalni_odpadki_priloge.pdf


http://www.lap2.nl/sectorplannen.asp

https://www.mos.gov.pl/kategoria/3340_krajowy_plan_gospodarki_odpadami_2014/


http://www.apambiente.pt/_zdata/DESTAQUES/2014/Portaria_PlanoEstrategico_PERSU2020_final.pdf

http://www.apambiente.pt/_zdata/DESTAQUES/2014/Portaria_PlanoEstrategico_PERSU2020_final.pdf


http://www.apambiente.pt/_zdata/Politicas/Residuos/Planeamento/PERH/PERH_2011_2016.pdf

http://www.apambiente.pt/_zdata/Politicas/Residuos/Planeamento/PERH/PERH_2011_2016.pdf



ENV/2014/SI2.689463/ETU/A2 192


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/priloha_01.pdf (Annex 1)




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)



http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_01.pdf




http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_05_06.pdf

http://www.minzp.sk/files/oblasti/odpady-a-obaly/poh/poh2011-2015/priloha_05_06.pdf

ENV/2014/SI2.689463/ETU/A2 193


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






https://um.baden-wuerttemberg.de/fileadmin/redaktion/m-um/intern/Dateien/Dokumente/2_Presse_und_Service/Publikationen/Umwelt/Abfallwirtschaftsplan_Teilplan_gefaehrliche_Abfaelle.pdf
















ENV/2014/SI2.689463/ETU/A2 194




HW



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





ENV/2014/SI2.689463/ETU/A2 195




HW



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

http://dict.leo.org/ende/index_de.html#/search=Rhineland-Palatinate&searchLoc=0&resultOrder=basic&multiwordShowSingle=on









ENV/2014/SI2.689463/ETU/A2 196




HW



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



ENV/2014/SI2.689463/ETU/A2 197


Table 10-4: Overview of available regional WMPs of United Kingdom (February 2015)



HW



NORTHERN IRELAND

Southern Region

Southern Waste Management Partnership (SWaMP2008): Waste Management Plan, March 2014 (2012-2020)


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)


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)






X X X

ENGLAND Waste Management Plan for England

(December 2013)


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.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




http://wales.gov.uk/consultations/environmentandcountryside/foodsectorplan/?lang=en

http://wales.gov.uk/topics/environmentcountryside/epq/waste_recycling/publication/canddsectorplan/?lang=en

http://wales.gov.uk/consultations/environmentandcountryside/industrial-commercial-sector-plan/?lang=en











http://www.sepa.org.uk/waste/waste_data/idoc.ashx?docid=a9309ef9-0240-4338-a2a2-f446b325cade&version=-1

http://www.sepa.org.uk/waste/idoc.ashx?docid=917cf403-8114-42a7-a859-78db1911bad7&version=-1





ENV/2014/SI2.689463/ETU/A2 198


Table 10-5: Overview of available regional and provincial WMPs of Italy (February 2015)



hazardous waste?


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


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


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


MARCHE Regional Waste Plan, adopted 02/02/2015) Piano regionale per la Gestione dei Rifiuti

http://www.ambiente.regione.marche.it/ambiente/rifiuti.aspx


http://www.regione.abruzzo.it/xambiente/docs/nuovoPRGR/all.1RelazionePiano.pdf

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






http://burc.regione.campania.it/eBurcWeb/publicContent/archivio/archivio.iface

http://burc.regione.campania.it/eBurcWeb/publicContent/archivio/archivio.iface

http://www.regione.campania.it/it/tematiche/rifiuti/piano-regionale-di-gestione-dei-rifiuti-speciali?page=1

http://www.regione.campania.it/it/tematiche/rifiuti/piano-regionale-di-gestione-dei-rifiuti-speciali?page=1

http://bur.regione.fvg.it/newbur/visionaBUR?bnum=2012/01/13/4

http://bur.regione.fvg.it/newbur/visionaBUR?bnum=2012/01/13/4










ENV/2014/SI2.689463/ETU/A2 199




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







http://www.provincia.brindisi.it/dmdocuments/ambiente/Piano_Reg_Gest_Rifiuti/RIF_21_PRGRU_PARTE_I.pdf

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

http://www.regione.puglia.it/index.php?page=curp&id=4772&opz=display

http://www.sardegnaambiente.it/documenti/18_183_20090115125209.pdf

http://www.sardegnaambiente.it/documenti/18_183_20090115125209.pdf





ENV/2014/SI2.689463/ETU/A2 200




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


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


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.

http://www.appa.provincia.tn.it/binary/pat_appa/Piano_smaltimento_rifiuti/piano_rifiuti_speciali.1276242653.pdf

http://www.provincia.bz.it/agenzia-ambiente/rifiuti/piani-gestione-rifiuti.asp

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

http://www.provincia.bz.it/agenzia-ambiente/download/Piano_gestione_rifiuti_pericolosi.pdf







ENV/2014/SI2.689463/ETU/A2 201


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)


FI WPP is included in WMP

FR National Waste Prevention Programme 2014-2020 (Programme national

de prévention des déchets 2014-2020)


http://mim.dk/media/mim/67848/Ressourcestrategi_UK_web.pdf



ENV/2014/SI2.689463/ETU/A2 202



GR NATIONAL WASTE PREVENTION PLAN (ΕΘΝΙΚΟ ΣΤΡΑΤΗΓΙΚΟ ΣΧΕΔΙΟ ΠΡΟΛΗΨΗΣ ΔΗΜΙΟΥΡΓΙΑΣ ΑΠΟΒΛΗΤΩΝ)

WPP under development. Adoption was planned for 2014.


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)


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)


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. ?






http://www3.lrs.lt/pls/inter3/dokpaieska.showdoc_l?p_id=458655&p_tr2=2






ENV/2014/SI2.689463/ETU/A2 203



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”)


UK - Wales Towards Zero Waste. One Wales: One Planet. The Waste Prevention Programme for Wales (2013-)


Sources: [EC BiPRO 2014, EEA 2014, consultation of stakeholders] (February 2015)



http://www.doeni.gov.uk/waste_prevention_programme_for_ni_2014-2.pdf




ENV/2014/SI2.689463/ETU/A2 204


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