International Review of Waste Management Policy - Department of ...

International Review of Waste
Management Policy:
Annexes to Main Report
Authors:
Eunomia (UK), Tobin Consulting Engineers (Ireland),
Öko-Institute (Germany), Arcadis (Belgium), Scuola
Agraria del Parco di Monza (Italy), TBU Engineering
(Austria), Eunomia New Zealand (New Zealand)
29 th September 2009

Report for:
Mr. Michael Layde, Department of the Environment, Heritage and Local Government, Ireland
Prepared by:
Dr Dominic Hogg, Dr Adrian Gibbs, Ann Ballinger, Andrew Coulthurst, Tim Elliott, Dr Debbie
Fletcher, Simon Russell, Chris Sherrington, Sam Taylor (Eunomia), Duncan Wilson (Eunomia
New Zealand), Sean Finlay, Damien Grehan, Mairead Hogan, Pat O’Neill (Tobin), Martin
Steiner (TBU), Andreas Hermann, Matthias Buchert (Oko Institut), Ilse Laureysens, Mike van
Acoyleyn (Arcadis), Enzo Favoino and Valentina Caimi (Scuola Agraria del Parco di Monza)
Approved by:
………………………………………………….
Joe Papineschi
(Director)
Contact Details
Eunomia Research & Consulting Ltd
62 Queen Square
Bristol
BS1 4JZ
United Kingdom
Tel: +44 (0)117 9450100
Fax: +44 (0)8717 142942
Web: www.eunomia.co.uk
Acknowledgements
We are grateful to the Steering Group for this project and to those who contributed to the
Consultative Group meetings. Several organisations also made submissions in writing and we
are very grateful to them for the time spent doing so, and the insights provided.
Disclaimer
Eunomia Research & Consulting has taken due care in the preparation of this document to
ensure that all facts and analysis presented are as accurate as possible within the scope of
the project. However Eunomia makes no warranty, express or implied, with respect to the use
of any information disclosed in this document, or assumes any liabilities with respect to the
use of, or damage resulting in any way from the use of any information disclosed in this
document.
International Review of Waste Policy: Annexes

29/09/09

Contents
WASTE WASTE POLICIES POLICIES POLICIES – EXISTING EXISTING FRAMEWORK FRAMEWORK AND AND SOME SOME THEORETICAL THEORETICAL CONSIDERATIONS
CONSIDERATIONS.......
CONSIDERATIONS ....... 1
i
1.0 Waste Policies – a Review of the Existing Framework .....................................................2
2.0 Policy Instruments for Waste Management....................................................................31
KEY KEY KEY INSTITUTIONAL INSTITUTIONAL INSTITUTIONAL ISSUES ISSUES................................
ISSUES ISSUES................................
................................................................
................................ ................................
................................................................
................................ ................................
......................................
................................ ...... ......42 ...... 42 42
3.0 Competition in the Market for Waste Collection.............................................................44
4.0 The Role of Local Authorities............................................................................................63
5.0 Governance Structures / Responsibilities for Delivery of National Strategy ................74
POLICIES POLICIES POLICIES FOR FOR FOR MUNICIPAL MUNICIPAL MUNICIPAL WASTE WASTE................................
WASTE WASTE................................
................................................................
................................ ................................
.............................................................
................................ .............................
.............................84
............................. 84 84
6.0 Review of Irish Policy on Prevention and Recycling........................................................85
7.0 Pay-By-Use - Ireland ....................................................................................................... 103
8.0 Pay-by-use - International .............................................................................................. 118
9.0 Pay-by-use – Germany ................................................................................................... 159
10.0 Pay-by-use – Flanders, Belgium................................................................................. 176
11.0 Landfill Levy - Ireland.................................................................................................. 185
12.0 Producer Responsibility, Packaging - Ireland............................................................ 199
13.0 Producer Responsibility, Packaging - International.................................................. 229
14.0 Producer Responsibility, Packaging - Germany ........................................................ 253
15.0 Producer Responsibility – Flanders, Belgium........................................................... 263
16.0 Deposit Refund Systems - International ................................................................... 297
17.0 Deposit Refund Scheme - Germany .......................................................................... 340
18.0 National Waste Prevention Programme - Ireland ..................................................... 350
19.0 Producer Responsibility, WEEE - Ireland................................................................... 362
20.0 Producer Responsibility, WEEE - International ......................................................... 376
21.0 Producer Responsibility, WEEE - Germany................................................................ 406
22.0 Producer Responsibility, ELVs - Ireland..................................................................... 417
23.0 Producer Responsibility, ELVs - International........................................................... 431
24.0 Producer Responsibility, Batteries - Ireland.............................................................. 448
25.0 Producer Responsibility, Batteries - International.................................................... 457
26.0 Producer Responsibility, Batteries - Germany .......................................................... 478
27.0 Plastic Bag Levy - Ireland ........................................................................................... 487
28.0 Packaging Taxes - International................................................................................. 498
29.0 Tyre Charge - International......................................................................................... 508
30.0 Product Taxes - Belgium............................................................................................. 515
31.0 Plastic Bag Bans – International ............................................................................... 525
International Review of Waste Policy: Annexes

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32.0 Levy on Waste Paints - International......................................................................... 529
33.0 Circular WPPR 17/08 - Ireland .................................................................................. 533
34.0 Minimum Recycling Standards (Household Waste) - International......................... 543
35.0 Minimum Recycling Standards (Commercial and Industrial Waste) - International
564
36.0 Product Standards: Biowaste Treatment Products - International.......................... 570
37.0 Animal By–Products Regulations – Ireland .............................................................. 588
38.0 Policies For Dealing With Junk Mail........................................................................... 598
CONSTRUCTION CONSTRUCTION CONSTRUCTION AND AND AND DEMOLITION DEMOLITION DEMOLITION WASTE WASTE................................
WASTE WASTE................................
................................................................
................................ ................................
.............................................
................................ ............. .............604
............. 604 604
39.0 Review of Irish Policy, Construction & Demolition Waste ........................................ 605
40.0 National Construction and Demolition Waste Council - Ireland .............................. 608
41.0 Landfill Levy - Ireland.................................................................................................. 616
42.0 C & D Waste Management Plan Guidelines - Ireland............................................... 626
43.0 Site Waste Management Plans - International ......................................................... 632
44.0 Waste Facility Permit Regulations - Ireland .............................................................. 644
45.0 Demolition Protocol - UK ............................................................................................ 650
46.0 Tax on Aggregates - International .............................................................................. 653
47.0 Product Standards for Aggregates - International .................................................... 667
48.0 Minimum Recycling Standards (Construction and Demolition Waste) - International
673
49.0 Incentives Affecting Construction and Demolition Waste - Belgium ....................... 690
50.0 Minimum Recycling Standards (Construction and Demolition Waste) - Germany. 691
POLICIES POLICIES FOR FOR RESIDUAL RESIDUAL WASTE WASTE ................................
................................................................
................................
................................
............................................................
................................ ............................
............................693
............................ 693
51.0 The Landfill Directive – Current Situation................................................................. 694
52.0 Policies Aimed at Discouraging Disposal .................................................................. 727
53.0 Landfill Ban (German Case Study)............................................................................. 794
54.0 Waste Levies and Bans (Belgium-Flanders Case Study) ......................................... 800
55.0 Landfill Allowance Schemes (UK) .............................................................................. 808
56.0 Proposed Policy Changes ........................................................................................... 824
OTHER OTHER POLICIES POLICIES................................
POLICIES POLICIES................................
................................................................
................................ ................................
................................................................
................................ ................................
......................................................
................................ ......................
......................845
...................... 845 845
57.0 Green Public Procurement ......................................................................................... 846
58.0 Ireland and the UNECE / Stockholm Conventions ................................................... 862
TARGET TARGET SETTING SETTING................................
SETTING SETTING................................
................................................................
................................ ................................
................................................................
................................ ................................
.....................................................
................................ .....................
.....................867
..................... 867
59.0 Target Setting.............................................................................................................. 868
GRANT GRANT GRANT FUNDING FUNDING................................
................................................................
................................ ................................
................................................................
................................ ................................
.....................................................
................................ .....................
.....................901
..................... 901
60.0 Grant Funding ............................................................................................................. 902
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TECHNICAL TECHNICAL ANNEXES ANNEXES................................
ANNEXES ANNEXES................................
................................................................
................................ ................................
................................................................
................................ ................................
.............................................
................................ ............. ............. 930 930
930
iii
61.0 Appraisal of Residual Waste Treatment Options...................................................... 931
62.0 Life-cycle Assessment of Residual Waste Treatment Technologies ....................... 964
63.0 Externalities of Waste Management Options ........................................................... 978
64.0 Costs of Household Waste Collection .....................................................................1033
International Review of Waste Policy: Annexes

Glossary of Acronyms
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ABP Belgian Pharmaceutical Association
ADF Advanced disposal fee
AOO Netherlands Waste Management Council
ARF Advance recycling fees
AVGI Belgian Pharmaceutical Industry Association
B2C Business to consumer
B2B Business to business
BAT Best available techniques
BDMV Belgian Direct Marketing Association
BEBAT Belgian producer responsibility organisation for batteries
BMW Biodegradable municipal waste
BPF Belgian Petrol Federation
BVDU Belgian Association of Publishers
C&D Construction and demolition (wastes)
C&I Commercial and industrial (wastes)
CA sites/CAS Civic Amenity Sites
CARE Carpet America Recovery Effort
CCMA City and County Managers Association
CEN European Committee for Standardisation
CIF Construction Industry Federation
CLRTAP Convention on Long-range Transboundary Air Pollution
COP4 Fourth Conference of the Parties
CPI Consumer Price Index
CPT Core Prevention Team
Cre Composting Association Ireland
CRT Cathode ray tube
DAFF Department for Agriculture, Fisheries and Forestry
DIFTAR Differentiated tariffs (pay-by-use)
DfE Design for the Environment
DGRNE-OWD Wallonian Directorate General for Natural Resources and
Environment - Wallonian Office for Waste
DoEHLG Department of Environment, Heritage and Local Government
DPG Deutsche Pfandsystem GmbH

v
DSD Duales System Deutschland
DVC Differential and variable charging (pay-by-use)
DVR Differential and variable rate charging (pay-by-use)
EEA European Environment Agency
EfW Energy from waste
ELVs End of life vehicles
EMAS Eco-management and Audit Scheme
EPA Environmental Protection Agency
EPR Extended producer responsibility
ESRI Economic and Social Research Institute
EWC European Waste Catalogue
FEBELAUTO Belgian confederation gathering the different groupings of the
Belgian automotive sector
FEBELGEN Generic pharmaceutical organisation
FEBELGRA Federation of the Belgian printing and communication industry
FEDIS Belgian federation of distributors
GDP Gross Domestic Product
GHG Greenhouse Gas
HCB Hexachlorobenzene
Hhld Household
IBEC The Irish Business and Employers Confederation
ISO 14001 Environmental management systems
IWMA Irish Waste Management Association
JCPRA Japan Containers and Packaging Recycling Association
JRC Joint Research Centre (European Commission)
LA Local authority
LAB Association Belgium
LCA Life cycle assessment
MBO Milieubeleidsovereenkomst-environmental policy agreements
with producers
MBT Mechanical biological treatment
MDG Market Development Group
MPC Marginal private costs
MRF Materials recovery facility
MS (EU) Member State
MSC Marginal social costs
International Review of Waste Policy: Annexes

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MSW Municipal solid waste
NAVETEX National Association of Textile Retailers
NBWS National biodegradable waste strategy
NGO Non-governmental organization
NFIW National Association of Informative Magazines
NIR Near infrared
NVGV National Organisation of Pharmaceutical Wholesalers
Octa BDE’ Octa-brominated diphenyl ether
OECD Organisation for Economic Co-operation and Development
OEE Office of Environmental Enforcement
OFBMW Organic fraction of biodegradable municipal waste
OPHACO Belgian Association of Pharmaceutical Cooperatives
OVAM The Public Flemish Waste Agency
PAHs Polycyclic aromatic hydrocarbons
PAYT Pay-as-you-throw (pay-by-use)
PBU Pay-by-use
PBUC Pay by use charge
PCBs Polychlorinated biphenyls
Penta BDE’ Penta brominated diphenyl ether
PERN Packaging export recovery note
PET Polyethylene terephthalate
PMD Plastiek, Metaal en Drankverpakkingen (packaging made of
plastic, metal and drinks cartons)
PPP Public private partnership
POPs Persistent organic pollutants
PRN Packaging recovery note
PRO Producer responsibility organisation
R&D Research and development
RBRC Rechargeable Battery Recycling Corporation
RECUPEL Flemish producer responsibility organisation dealing with waste
electrical and electronic equipment
RECYBAT Flemish producer responsibility organisation dealing with
accumulators.
RIA Regulatory impact assessment
RPS Repak payment system
RWMPs Regional waste management plans

vii
SNIFFER Scotland and Northern Ireland Forum for Environmental Research
UUPP International Federation of Periodical Press
UN-ECE United Nations Economic Commission for Europe
WEEE Waste electrical and electronic equipment
WFD Waste framework directive
WFL Waste facility levy
WID Waste incineration directive
WRAP Waste and Resources Action Programme (UK)
VALORLUB Belgian producer responsibility organisation dealing with waste
oils
VDV Association of food retailers
VEGRAB Federation of printing companies
VLACO The Flemish organisation for promoting composting and compost
use
VLAREA Flemish regulation for waste
VFG Vegetable, fruit and garden (biowaste)
VROM The Netherlands Ministry of Housing, Spatial Planning and the
Environment
VUKPP Federation of Catholic Periodical Press
International Review of Waste Policy: Annexes

WASTE POLICIES – EXISTING FRAMEWORK AND
SOME THEORETICAL CONSIDERATIONS
1
International Review of Waste Policy: Annexes

1.0 Waste Policies – a Review of the Existing
Framework
Irish waste management has made enormous strides over the past decade. The
statistics tell a story of impressive improvements in performance in many areas,
whilst some of the improvements are not so readily revealed though appeal to
statistics alone (for example, with regard to the effects of closing down old ‘dumps’
which posed a threat to the environment).
The changes which Ireland has made have been, to a considerable degree, motivated
by policies emanating from Europe. Much focus tends to fall upon the so-called
Producer Responsibility Directives in this regard, yet the impact of changes to the
operation and regulation of landfills has also been significant. This has increased the
costs of disposal, and thereby increased the benefits associated with avoiding
disposal (through prevention, re-use, recycling and alternative treatments). Recycling,
in particular, is likely to have been incentivised by the escalation in landfill gate fees.
In this Annex, we outline what we believe to be the salient issues in respect of
European waste policy and legislation as it affects Ireland. It would not be possible to
look at each and every aspect of each piece of policy. The overview is unashamedly
forward-looking. It looks to the future with a view to understanding the challenges
ahead, rather than seeking to dwell on past achievements.
1.1 The Priority Status of Waste Prevention
As is well known, waste prevention lies at the top of the waste management
hierarchy. The status of waste prevention in this respect has been reinforced by the
revised Waste Framework Directive (WFD) under Article 4: 1
2
29/09/09
“1. 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.
2. When applying the waste hierarchy referred to in paragraph 1, Member
States shall take measures to encourage the options that deliver the best
overall environmental outcome. This may require specific waste streams
1 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.

3
departing from the hierarchy where this is justified by life-cycle thinking on the
overall impacts of the generation and management of such waste.
Member States shall ensure that the development of waste legislation and
policy is a fully transparent process, observing existing national rules about
the consultation and involvement of citizens and stakeholders.
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.”
The above suggests that other than where life-cycle thinking suggests otherwise,
prevention and preparing for re-use should be considered priority areas for waste
management policy in future. Indeed, the WFD sets out a requirement for Member
States to develop Waste Prevention Programmes under Articles 29 to 31: 2
“Article Article 29
Waste prevention programmes
1. Member States shall establish, in accordance with Articles 1 and 4, 4, 4, waste
prevention programmes not later than [five years and 20 days after
publication of the WFD in the Official Journal].
Such programmes shall be integrated either into the waste management
plans provided for in Article 28 or into other environmental policy
programmes, as appropriate, or shall function as separate programmes. If any
such programme is integrated into the waste management plan or into other
programmes, the waste prevention measures shall be clearly identified.
2. The programmes provided for in paragraph 1 shall set out the waste
prevention objectives Member States shall describe the existing prevention
measures and evaluate the usefulness of the examples of measures indicated
in Annex IV or other appropriate measures.
The aim of such objectives and measures shall be to break the link between
economic growth and the environmental impacts associated with the
generation of waste.
3. 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 targets and indicators, other than those referred to
in paragraph 4, for the same purpose.
4. Indicators for waste prevention measures may be adopted in accordance
with the procedure referred to in Article 39 (3).
2 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.
International Review of Waste Policy: Annexes

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5. The Commission shall create create create a a a system system system for for for sharing sharing sharing information information on on best best
practice practice regarding regarding waste waste pre prevention pre pre vention and and develop guidelines in order to assist
the Member States in the preparation of the Programmes. 3
Article Article 30
30
Evaluation and review of plans and programmes
1. 1. Member States shall ensure that the waste management plans and waste
prevention programmes are evaluated at least every sixth year and revised as
appropriate and, where relevant, in accordance with Articles 9 and 11 .
2. The European Environment Agency is invited to include in its annual report
a review of progress in the completion and implementation of waste
prevention programmes.
Article Article 31
31
Public participation
Member States shall ensure that relevant stakeholders and authorities and
the general public have the opportunity to participate in the elaboration of the
waste management plans and waste prevention programmes, and have
access to them once elaborated, in accordance with Directive 2003/35/EC
or, if relevant, Directive 2001/42/EC of the European Parliament and of the
Council of 27 June 2001 on the assessment of the effects of certain plans
and programmes on the environment. They shall place the plans and
programmes on a publicly available website.”
The measures referred to in Article 29 as being set out in Annex IV are shown in Box 1
below. 4
Box 1: Annex IV of the WFD
Examples of waste prevention measures referred to in Article 29
Measures that can affect the framework conditions related to the generation of waste
1. The use of planning measures, or other economic instruments promoting the efficient use of resources.
2. The promotion of research and development into the area of achieving cleaner and less wasteful products
and technologies and the dissemination and use of the results of such research and development.
3. The development of effective and meaningful indicators of the environmental pressures associated with
the generation of waste aimed at contributing to the prevention of waste generation at all levels, from product
comparisons at Community level through action by local authorities to national measures.
Measures that can affect the design and production and distribution phase
4. The promotion of eco-design (the systematic integration of environmental aspects into product design with
the aim to improve the environmental performance of the product throughout its whole life cycle).
5. The provision of information on waste prevention techniques with a view to facilitating the implementation
of best available techniques by industry.
6. Organise training of competent authorities as regards the insertion of waste prevention requirements in
permits under this Directive and Directive 96/61/EC.
3 The European Commission has already initiated the process of developing these Guidelines.
4 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.

7. The inclusion of measures to prevent waste production at installations not falling under Directive 96/61/EC.
Where appropriate, such measures could include waste prevention assessments or plans.
8. The use of awareness campaigns or the provision of financial, decision making or other support to
businesses. Such measures are likely to be particularly effective where they are aimed at, and adapted to,
small and medium sized enterprises and work through established business networks.
9. The use of voluntary agreements, consumer/producer panels or sectoral negotiations in order that the
relevant businesses or industrial sectors set their own waste prevention plans or objectives or correct
wasteful products or packaging.
10. The promotion of creditable environmental management systems, including EMAS and ISO 14001.
Measures that can affect the consumption and use phase
11. Economic instruments such as incentives for clean purchases or the institution of an obligatory payment
by consumers for a given article or element of packaging that would otherwise be provided free of charge.
12. The use of awareness campaigns and information provision directed at the general public or a specific
set of consumers.
13. The promotion of creditable eco-labels.
14. Agreements with industry, such as the use of product panels such as those being carried out within the
framework of Integrated Product Policies or with retailers on the availability of waste prevention information
and products with a lower environmental impact.
15. In the context of public and corporate procurement, the integration of environmental and waste
prevention criteria into calls for tenders and contracts, in line with the Handbook on environmental public
procurement published by the Commission on 29 October 2004.
16. The promotion of the reuse and/or repair of appropriate discarded products or of their components,
notably through the use of educational, economic, logistic or other measures such as support to or
establishment of accredited repair and reuse-centres and networks especially in densely populated regions.
It is clear from the above – the position of waste prevention in the hierarchy, and the
need to develop waste prevention programmes, both flowing from the revised WFD –
that waste prevention is beginning to attract growing attention as an area that needs
to be tackled by policy makers. The concept of ‘decoupling’ the level of activity in the
economy from the level of waste being generated is a prominent one, and reflects
concerns that economic growth is not yet on what might be considered to be a
sustainable trajectory. To this end, the WFD includes provision, under Article 9, for
decoupling objectives to be set: 5
5
“The Commission shall, following the consultation of stakeholders, submit to
the European Parliament and the Council the following reports accompanied,
if appropriate, by proposals for measures required in support of the prevention
activities and the implementation of the waste prevention programmes
referred to in Article 29 covering:
a) by the end of 2011 an interim report on the evolution of waste generation
and the scope of waste prevention;
(aa) by the end of 2011 the formulation of a product eco-design policy
addressing both the generation of waste and the presence of hazardous
substances in waste, with a view to promoting technologies focusing on
durable, re-usable and recyclable products;
5 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.
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29/09/09
b) by by by the the the end end end of of of 2014 2014 2014 the the the setting setting setting of of of waste waste waste prev prevention prev prevention
ention and and and decoupling decoupling
decoupling
objectives objectives for for 2020, 2020, based based on on on best best available available practices practices including, including, including, if if necessary,
necessary,
a a revision revision of of the the indicators indicators referred referred to to in in Article Article 29(4) 29(4); 29(4)
c) by the end of 2011 the formulation of an action plan for further support
measures at European level seeking in particular to change the current
consumption patterns.”
Evidently, if Irish policy and strategy development is to be future-proofed, the issue of
waste prevention and decoupling waste generation from economic growth needs to
be considered.
1.2 Definitions
The definition of ‘prevention’ has been a matter of some debate. The OECD defines
waste prevention as covering the top three elements of the standard waste hierarchy,
describing these as: 6
� Strict Strict Strict avoidance avoidance avoidance - the complete prevention of waste generation by virtual
elimination of hazardous substances or by reducing material or energy
intensity in production, consumption, and distribution.
� Reduction Reduction Reduction at at source source - minimising use of toxic or harmful substances and/or
minimising material or energy consumption.
� Product Product Product re re-use re use use - the multiple use of a product in its original form, for its original
purpose or for an alternative, with or without reconditioning.
Other studies expand on this definition to include the following examples: 7
“Household waste prevention is minimising the quantity (weight and volume)
and hazardousness of household-derived waste generated in a defined
community for collection by any party.
The following activities are included:
Avoidance;
Avoidance;
for example by eliminating hazardous components and substances, by
not purchasing unnecessary goods, by buying services or experiences
rather than goods, by using refill systems and by preventing delivery of
unwanted mail.
Reduction;
Reduction;
for example by buying less hazardous goods, by purchasing less heavily
packaged goods and goods that are lighter, more compact and more
durable.
6 OECD (2000) Strategic Waste Prevention: OECD Reference Manual, Paris: OECD
7 Enviros and Momenta (2005) Towards a UK Framework for Household Waste Prevention, Phase 1
Report for the National Resources & Waste Forum.

7
Reuse; Reuse;
Reuse;
for example domestic reuse of containers, donation of goods to
charities, refurbishment and reuse of goods (not-for-profit or
commercially), home and community composting.”
Centralised composting and energy recovery were excluded, but home composting
was included.
These definitions might be considered, for the purposes of developing Irish policy, to
have been superseded by what has now been agreed in the new Waste Framework
Directive (WFD). Article 3 sets out the following Definitions of relevance to ‘waste
prevention’: 8
"‘Prevention’ means measures taken before a substance, material or product
has become waste, that reduce:
(a) the quantity of waste, including through the re-use of products or the
extension of life-span of products;
(b) the adverse impacts of the generated waste on the environment and
human health; or
(c) the content of harmful substances in materials and products;”
Since prevention includes re-use:
"‘Re-use’ means any operation by which products or components that are not
waste are used again for the same purpose for which they were conceived;
‘Preparing for re-use’ means checking, cleaning or repairing recovery
operations, by which products or components of products that have become
waste are prepared so that they will be re-used without any other preprocessing;”
Given that Ireland will have to align its legislation with these requirements, it seems
only logical to use the definitions set out in the revised WFD.
It is, of course, important to note that a reduction in waste collected by a local
authority does not necessarily imply that ‘waste prevention’ has occurred to an
equivalent degree (for example, where waste is dumped or burnt illegally).
One of the previous debates within the context of waste prevention related to how
one should consider measures which reduce the hazardousness of waste through
increasing the quantity of waste (for example, using vitrification, or stabilisation in
cement). The Commission’s definition appears to address this by including the clause
‘measures taken before a substance, material or product has become waste’ In other
words, measures which reduce hazardousness after a waste has been generated
would not be considered ‘waste prevention’.
8 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.
International Review of Waste Policy: Annexes

1.3 Waste Prevention Policy – Links to Measurement of Success
Our experience of assessing waste prevention policy is that the almost universally
agreed ‘priority status’ given to waste prevention, reflected in its place at the top of
the waste hierarchy, is not reflected in the way policy has been developed. Most of
the influential policies that are addressed to ‘waste’ are not designed to address
waste prevention directly. Rather, they seek to reduce the quantity of waste disposed,
or increase its recycling, and sometimes, its recovery. This experience is reinforced in
the review of policy undertaken within this report. As regards policies, waste
prevention has not been given the status it deserves. This may be a reflection of the
fact that waste policy is influenced by those associated with the management of
waste. Waste prevention is clearly an activity that diminishes the activity of those
involved in ‘managing waste’.
The negotiations around the WFD itself included debates around waste prevention
targets and whether they should be set in the WFD. Notwithstanding the clear
agreement on the place of waste prevention at the top of the hierarchy, policy
makers’ commitment to establishing targets for this is clearly somewhat weak. The
usual argument, rarely challenged (and hence, even more rarely requiring a sensible
defence) is that waste prevention is ‘not measurable’ because one is seeking to
measure ‘something which is no longer there’.
This absence of imagination and creativity in the quest to understand how one might
measure waste prevention perhaps explains, in part, the absence of relevant policies
themselves. There is an urgent need, therefore, for more cool-headed and creative
thinking about:
8
1. Indicators for measuring success of a programme of waste prevention; and
2. Means to evaluate the contribution of specific measures.
In the case of the former, some discussion is provided below. In the case of the latter,
it seems entirely likely that the approach has to be tailored to fit the policy. Otherwise,
similar rules and guidelines apply as for any ex post assessment of any policy. Just
because a policy refers to ‘waste prevention’, this does not mean that the only way to
evaluate its effectiveness is to measure ‘what is no longer there’. As with all ex post
evaluations, the real issue relates to devising a mechanism to evaluate the policy
against a relevant counterfactual scenario. ‘What is no longer there’ is then estimated
‘by subtraction’ using the situation as it now stands, and the situation as it would
have been without the policy in place.
1.3.1 Measuring Decoupling
Prevention policies are typically responses to observed pressures, and require
indicators to measure the success of the policy in terms of the response. There are
different strategies open to understand the impact of the policy. However, what is
essential is to understand the link between changes in waste quantities /
hazardousness of waste and the policy itself.
Decoupling means that the link between economic growth and the growth of the
environmental problem (or pressure) is broken. According to the OECD “relative
decoupling” means that the economy grows faster than the environmental problem,
29/09/09

ut both grow. “Absolute decoupling” means that the economy grows and the
environmental problem declines. “Negative decoupling” implies that the
environmental problem grows faster than the economy (in other words, there is no
decoupling).
The goal of prevention ought to be to achieve absolute decoupling, and to achieve a
reduction in environmental pressure so as to ensure that future environmental quality
is safeguarded, and environmental stocks are effectively managed for the long-term.
The latter is not so easy to define. Hence, an important indicator will inevitably be the
assessment of the degree of decoupling, because of the attention paid in Article 9,
Article 29 (see above) and in the preamble (para 40) of the new WFD (see above).
Point 3 of Annex IV refers to pressure related indicators (see Box 1).
One formulation of a decoupling indicator r(t) for a given year t vis-à-vis a given
reference year t0 is as follows: 9
m(
t)
m(
t0)
r ( t)
=
a(
t)
a(
t )
9
0
where m(t) describes the environmental pressure in year t and a(t) describes the
economic variable in year t (and similarly for time t= t0). In circumstances where the
economic indicator is increasing, positive decoupling can be said to occur when the
decoupling indicator is less than one. Absolute decoupling occurs when the
numerator is less than one even where the economic indicator is greater than one.
There is no decoupling when the indicator equals one. When the decoupling indicator
is greater than one, then where the denominator is greater than one, there is negative
decoupling. These rules have to be reconsidered in the context where the economy is
in decline.
In order to take into account the uncertainty factor in the estimations, a hypothesis
test is needed when trying to determine whether or not there is decoupling. The
uncertainty on the data for an individual production year can be relatively high, which
complicates the estimate of decoupling. For that reason, the numerator and the
denominator in the equation can be replaced by the inclination of a regression line,
which offers greater reliability and robustness than the estimate for a separate year. 10
This methodology has been applied on Flemish data on waste production. Figure 1-1
shows, as an example the decoupling indicator for the total production of industrial
waste compared to the GDP for the periods: 1996-2000, 1997-2001, 1998-2002,
1999-2003, 2000-2004, 2001-2005. 11
9 Mike Van Acoleyen (2004) Indicators for Waste Prevention - Development of a Methodology for, and
Testing of OECD Indicators, OVAM: Mechelen.
10 J. Van Dijck (2004) Hypothese testen van indicatoren voor het afvalstofbeleid, Probabilitas,
Heverlee.
11 OVAM (2008) Bedrijfsafvalstoffen: Cijfers en Trends voor Productie, Verwerking, Invoer en Uitvoer,.
International Review of Waste Policy: Annexes

For each indicator decoupling was calculated by comparing the regression of the
pressure indicator (in this case waste production) with the economic indicator (in this
case GDP) over the same period. Confidence intervals have been added to see if the
indicator really is statistically sound above zero, which was the case until 2001. From
2002 onwards, positive decoupling cannot with statistical certainty be proved for the
Flemish region.
Figure 1-1: Decoupling Indicator for Industrial Waste in Flanders
In principle, the above formulation might be a little simplistic and a more general form
might be:
r =
10
( ∂m
) ∂t
( ∂a
)
29/09/09
∂t
This effectively compares the rate at which the pressure variable is changing over
time relative to the rate of change in the economic variable.
The somewhat hackneyed view that waste prevention ‘cannot be measured’ can be
seen to be little more than an excuse not to act, or not to evaluate policies which,
after all, are the ones which ought to be given the highest priority, both because of
their potential to reduce the waste of ‘other factors of production’ (solid wastes are
often a symptom of other forms of waste), and because of their likely positive impact
in terms of the environment and sustainable development. Finally, waste prevention
measures frequently give rise to cost savings to businesses and consumers,
suggesting that policy is failing to move these actors to a situation where waste is
considered to be a variable cost in the production process.

1.4 Waste Recycling and Composting / Anaerobic Digestion
The WFD defines ‘recycling’ as follows: 12
11
"recycling" means any recovery operation by which waste materials are
reprocessed into products, materials or substances whether for the original or
other purposes. It includes the reprocessing of organic material but does not
include energy recovery and the reprocessing into materials that are to be
used as fuels or for backfilling operations.
As such, for the purposes of this report, we consider recycling to include the
composting and anaerobic digestion of waste where this leads to the production of a
useful output.
Article 4(1), which sets out the waste hierarchy, places recycling below ‘prevention’
and ‘preparing for re-use’, but above ‘other recovery’. Article 4(2) suggests that other
than where life-cycle thinking suggests otherwise, recycling should be encouraged
more strongly than either ‘other recovery’ or ‘disposal’, but not at the expense of
‘prevention’ and ‘preparing for re-use’.
Article 10 states that:
1. Member States shall take the necessary measures to ensure that waste
undergoes recovery operations, in accordance with Articles 4 and 13.
2. Where necessary to comply with paragraph 1 and to facilitate or improve
recovery, waste shall be collected separately if technically, environmentally
and economically practicable and shall not be mixed with other waste or other
material with different properties.
Whereas this does not establish any specific targets, Article 11, on Re-use and
Recycling, states that:
1. Member States shall take measures as appropriate to promote the re-use
of products and preparing for re-use activities, notably through encouraging
the establishment and support of re-use and repair networks, the use of
economic instruments, procurement criteria, quantitative objectives or other
measures.
Member States shall take measures to promote high quality recycling and to
this end they shall set up separate collection of waste where technically,
environmentally and economically practicable and appropriate to meet the
necessary quality standards for the relevant recycling sectors.
Subject to Article 10(2), by 2015 separate collection shall be set up for at
least the following: paper, metal, plastic and glass.
2. In order to comply with the objectives of this Directive, and to move towards
a European recycling society with a high level of resource efficiency, Member
12 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.
International Review of Waste Policy: Annexes

12
29/09/09
States shall take the necessary measures designed to achieve the following
targets:
a) by 2020 the preparing for re-use and the recycling of waste materials such as at
least paper, metal, plastic and glass from households and possibly from other
origins as far as these waste streams are similar to waste from households,
shall be increased to a minimum of overall 50% by weight;
b) by 2020 the preparing for re-use, recycling and other material recovery,
including backfilling operations using waste to substitute other materials, of
non-hazardous construction and demolition waste excluding naturally occurring
material defined in category 17 05 04 in the European Waste Catalogue (EWC)
shall be increased to a minimum of 70% by weight.
3. The Commission shall, in accordance with the regulatory procedure with
scrutiny referred to in Article 39(2) of this Directive, establish detailed rules on
the application and calculation methods for verifying compliance with the
targets set out in paragraph 2 of this Article, considering Regulation (EC) No
2150/2002 of the European Parliament and of the Council of 25 November
2002 on waste statistics. These can include transition periods for Member
States with less than 5% recycling in either category in 2008.
4. By 31 December 2014 at the latest, the Commission shall examine the
measures and the targets referred to in paragraph 2 with a view to, if
necessary, reinforcing the targets and consider setting targets for other waste
streams. The report of the Commission, accompanied by a proposal if
appropriate, shall be sent to the European Parliament and the Council. In its
report the Commission shall take into account the relevant environmental,
economic and social impacts of setting the targets.
5. Every three years, in accordance with Article 37, Member States shall
report to the Commission on their record with regard to meeting the targets. If
targets are not met, this report shall include the reasons for failure and the
actions the Member State intends to take to meet the targets.
Eunomia, as leaders in this study, is involved in work referred to under paragraph 3
above. This is being led by the Oko Institut. For the time being, the Commission has
issued, in response to a request to the United Kingdom, clarification of paragraph 2
above (which is far from being unambiguous). The Commission stated: 13
It is also the Commission services' understanding that the 50% target applies
to the totality of at least four material waste streams including paper, plastics,
glass and metals originating from households and possibly other sources, and
does not apply individually to each of these waste streams. By "the totality" of
wastes we understand the amount of both separately collected and mixed
13 Response from Commisioner, DG Environment, to letter from Roy Hathaway, Defra, dated 31 July
2008.

13
waste from these sources. Member States can add more material waste
streams from household or similar wastes to this target (e.g. biowaste) in
which case the 50% target would apply to the totality of all waste streams
included. I would also like to draw your attention to Article 11(3) of the draft
revised Waste Framework Directive which specifies that any eventual
modalities related to the application and calculation methods for verifying
compliance with the targets need to be elaborated by the Commission and the
Member States in comitology.
The most recent EPA report suggests that recycling rates for the four materials under
consideration paper, metal, plastic, glass, was such that the target would be met for
each of metals, paper and glass, but not plastic (see Table 1-1). The target would be
met if one aggregated the figures for all 4 materials.
The picture is quite different if one looks only at household waste (see Table 1-2).
Here, the 50% target is not met for the materials in combination. The target is just
exceeded for paper, it is easily exceeded for glass, but in respect of plastics and
metals, the performance is below what is suggested.
Pending the agreement of rules described in para 3 above, Ireland would appear to
be already meeting targets for municipal waste, though the hierarchy and Article 10
should still be followed, subject to life-cycle thinking suggesting otherwise. Hence, the
target under the Waste Framework Directive should be considered a bare minimum,
and in any case, it may yet be supplemented by a requirement to separate biowaste
at source.
Table 1-1: Recycling Performance for 4 Key WFD Materials, Municipal Waste
Managed Managed
Managed Landfilled Landfilled
Landfilled Recycled
Recycled Recycled
Recycled
(tonnes)
(tonnes) (tonnes)
(tonnes) (tonnes)
(tonnes) (%)
(%)
Metals 133,500 50,000 83,499 62.5%
Paper 914,069 384,245 529,824 58.0%
Plastic 288,760 223,755 65,005 22.5%
Glass 182,554 48,075 134,479 73.7%
Total 1,518,883 706,075 812,807 53.5%
Source: EPA (2009) National Waste Report 2007, Wexford: EPA.
Table 1-2: Recycling Performance for 4 Key WFD Materials, Household Waste
Managed Managed
Managed Landfilled
Landfilled Recycled
Recycled Recycled
Recycled
(tonnes)
(tonnes) (tonnes) (tonnes)
(tonnes) (tonnes) (tonnes)
(tonnes) (%)
(%)
Metals 48,021 35,577 12,444 25.9%
Paper 385,074 187,350 197,724 51.3%
Plastic 195,881 153,662 42,219 21.6%
Glass 131,300 38,759 92,540 70.5%
Total 760,276 415,348 344,927 45.4%
Source: EPA (2009) National Waste Report 2007, Wexford: EPA.
International Review of Waste Policy: Annexes

As regards the WFD 70% target for re-use, recycling and recovery for construction and
demolition waste, the latest EPA report indicates that Ireland is already achieving this
target. Some caveats are necessary here, however, not least since the EPA Report
highlights problems with the data. This is likely to be true in cases other than Ireland,
and the challenge for many Member States will be to obtain quality data as to their
current performance, not to mention that in the future.
It will be clear that the above targets relate in the main to dry materials. The WFD also
highlights the significance of the biowaste stream in Article 22, which states:
14
29/09/09
Member States shall take measures, as appropriate, and in accordance with
Articles 4 and 13, to encourage:
a) the separate collection of bio-waste with a view to the composting
and digestion of bio-waste;
b) the treatment of bio-waste in a way that fulfils a high level of
environmental protection;
c) the use of environmentally safe materials produced from bio-waste.
The Commission shall carry out an assessment on the management of biowaste
with a view to submitting a proposal if appropriate.
The assessment shall examine the opportunity of setting minimum
requirements for bio-waste management and quality criteria for compost and
digestate from bio-waste, in order to guarantee a high level of protection for
human health and the environment.
In respect of the Commission’s above commitment, the Commission has already
issued a Green Paper on the Management of Biowaste in the European Union. This
asks a number of questions pertinent to the management of biowaste, and ends with
the statement that: 14
In late 2009, the Commission intends to present its analysis of the responses
received together with, if appropriate, its proposals and/or initiatives for an EU
strategy on the management of bio-waste.
Ireland’s performance in respect of biowaste is far worse than on many of the dry
recyclables. The latest EPA Report suggests that less than one tenth of the estimated
918 thousand tonnes of organic waste was recovered. This stream has been the
focus of much recent activity in the policy area. Circular WPPR 17/08 on the
Implementation of Segregated ‘Brown Bin’ Collection for Biowaste and Home
Composting was issued on 31 July 2008 to all City and County Managers. This affects
the provision of separate collection services to households. More recently,
consultation has been launched on a new Statutory Instrument, the Waste
14 Commission of the European Communities (2008) Green Paper on the Management of Biowaste in
the European Union, COM(2008) 811 Final, Brussels, 3.12.08 (available at http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0811:FIN:EN:PDF).

Management (Food Waste) Regulations. This would effectively mandate the separate
collection of food waste from waste producers, as defined under the instrument.
Another important feature of the WFD, which is pertinent to the recycling of biowaste,
is Article 6, which concerns the matter of whether, and if so, when, waste might cease
to be treated as such (the ‘end of waste’ issues). The Article states: 15
15
1. Certain specified waste shall cease to be waste within the meaning of point
(1) of Article 3 when it has undergone a recovery, , , including including recycling, recycling,
operation and complies with specific criteria to be developed in accordance
with the following conditions:
a) the substance or object is commonly used for specific purposes purposes purposes ;
b) a market or demand exists for such a substance or object;
c) the substance or object fulfils the technical requirements for the
specific purposes purposes and meets the existing legislation and standards
applicable to products; and
d) the use of the substance or object will not lead to overall adverse
environmental or human health impacts.
The criteria shall include limit values for pollutants where necessary and and shall
shall
take take into into account account account any any any possible possible advers adverse advers e environmental environmental environmental effects effects effects of of the
the
substance substance substance or or object object. object
2. The measures relating to the adoption of such criteria and specifying the
waste, designed to amend non-essential elements of this Directive, by
supplementing it, shall be adopted in accordance with the regulatory
procedure with scrutiny referred to in Article 39 (2). End End-of End of of-waste of waste specific
specific
criteria criteria should should be be be considered, considered, among among others, others, at at least least for for aggregates, aggregates, paper,
paper,
glass, glass, glass, metal, metal, metal, tyres tyres and textiles.
3. Waste which ceases to be waste in accordance with paragraphs 1 and 2,
shall also cease to be waste for the purpose of the recovery and recycling
targets set out in Directives 94/62/EC, 2000/53/EC, 2002/96/EC and
2006/66/EC and other relevant Community legislation when the recycling or or
recovery recovery requirements requirements oof
o f that legislation are are met met. met
4. Where criteria have not been set at Community level under the procedure
set out in paragraphs 1 and 2, Member States may decide case by case
whether certain waste has ceased to be waste taking into account the
applicable case law. They shall notify the Commission of such decisions in
accordance with Directive 98/34/EC of the European Parliament and of the
Council of 22 June 1998 laying down a procedure for the provision of
information in the field of technical standards and regulations and of rules on
Information Society services where so required by that Directive.
15 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.
International Review of Waste Policy: Annexes

The Joint Research Centre (JRC) of the European Commission has been leading pilot
studies on end-of-waste criteria for aggregates and for biowaste. A report has been
published on the JRC website concerning the study. 16
As far as recycling is concerned, the WFD effectively underpins the Producer
Responsibility Directives already in place. These are:
16
� European Parliament and Council Directive 94/62/EC of 20 December 1994
on packaging and packaging waste 17;
� Directive 2000/53/EC of the European Parliament and of the Council of
18 September 2000 on end-of life vehicles; 18
� Directive 2002/96/EC of the European Parliament and of the Council of 27
January 2003 on waste electrical and electronic equipment
(WEEE); 19http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-
//EP//TEXT+TA+P6-TA-2008-0282+0+DOC+XML+V0//EN&language=EN -
def_2_14#def_2_14 and
� Directive 2006/66/EC of the European Parliament and of the Council of
6 September 2006 on batteries and accumulators and waste batteries and
accumulators. 20
Article 8 of the WFD, on Extended Producer Responsibility, allows Member States
considerable freedom to develop measures to encourage producers to take
responsibility for their products. The ambition of Member State measures is certainly
not restricted to those products already covered by EU Directives. The Article seems
designed to allow Member States to develop their own initiatives in this regard (as
some have done already – see Annex 15.0): 21
29/09/09
1. In order to strengthen the prevention, re-use, recycling and recovery of
waste, Member States may take legislative or non-legislative measures to
ensure that any natural or legal person who professionally develops,
manufactures, processes, treats, sells or imports products (producer of the
product) has extended producer responsibility.
16 JRC (2009) End of Waste Criteria, JRC Scientific and Technical Reports,
http://susproc.jrc.ec.europa.eu/activities/waste/documents/Endofwastecriteriafinal.pdf
17 OJ L 365, 31.12.1994, p. 10. Directive as last amended by Directive 2005/20/EC (OJ L 70,
16.3.2005, p. 17).
18 OJ L 269, 21.10.2000, p. 34. Directive as last amended by Directive 2008/33/EC of the European
Parliament and of the Council (OJ L 81, 20.3.2008, p. 62 ).
19 OJ L 37, 13.2.2003, p. 24. Directive as last amended by Directive 2008/34/EC (OJ L 81,
20.3.2008, p. 65).
20 OJ L 266, 26.9.2006, p. 1. Directive as last amended by Directive 2008/12/EC (OJ L 76,
19.3.2008, p. 39).
21 Directive 2008/98/EC of the European Parliament and the Council of 19 November 2008 on Waste
and Repealing Certain Directives.

17
Such measures may include an acceptance of returned products and of the
waste that remains after those products have been used, as well as the
subsequent management of the waste and financial responsibility for such
activities. These measures may include the obligation to provide publicly
available information as to the extent to which the product is re-usable and
recyclable.
2. Member States may take appropriate measures to encourage the design of
products in order to reduce their environmental impacts and the generation of
waste in the course of the production and subsequent use of products, and in
order to ensure that the recovery and disposal of products that have become
waste take place in accordance with Articles 4 and 13.
Such measures may encourage, inter alia, the development, production and
marketing of products that are suitable for multiple use, that are technically
durable and that are, after having become waste, suitable for proper and safe
recovery and environmentally compatible disposal.
When applying extended producer responsibility, Member States shall take
into account the technical feasibility and economic viability and the overall
environmental, human health and social impacts, respecting the need to
ensure the proper functioning of the internal market.
4. The extended producer responsibility shall be applied without prejudice to
the responsibility for waste management as provided for in Article 15 (1) and
without prejudice to existing waste stream specific and product specific
legislation.
Article 14 (2), on Costs, bears some relation to Extended Producer Responsibility. It
states that:
2. Member States may decide that the costs of waste management are to be
borne partly or wholly by the producer of the product from which the waste
came and that the distributors of such product may share these costs.
If one takes this principle to its limit, and if one also bears in mind the preamble to
the WFD (which, at Para 26 reiterates the status of the polluter pays principle as ‘a
guiding principle at the European and International levels’), then where Article 14(1),
states:
1. In accordance with the polluter-pays principle, the costs of waste
management shall be borne by the original waste producer or by the current
or previous waste holders
one might reasonably interpret the logic to be that where extended producer
responsibility systems are implemented, producers / distributors should bear all costs
related to extended producer responsibility, ensuring that as far as possible,
consumers of products – the ultimate causes of the pollution – pay.
1.4.1 The Producer Responsibility Directives
The key producer responsibility Directives were listed above. The intention, in what
follows, is not to describe each Directive in detail, but to highlight the key issues
facing Ireland in each of these.
International Review of Waste Policy: Annexes

1.4.1.1 Packaging and Packaging Waste
Directive 94/62/EC of 20 December 1994 on packaging and packaging waste , and
its amendments suggests that Member States must introduce systems for the return
and/or collection of used packaging to attain specific targets. The targets were recast
so that Member States must achieve the following targets:
18
� by no later than 31 December 2008, between 55 and 80% by weight of
packaging waste to be recycled;
� no later than 31 December 2008 the following targets for materials contained
in packaging waste must be attained: 60% by weight for glass, paper and
board; 50% by weight for metals; 22.5% by weight for plastics and 15% by
weight for wood; and
� by no later than 31 December 2008, at least 60% by weight of packaging
waste to be recovered or incinerated at waste incineration plants with energy
recovery;
The Directive also lays down essential requirements with which countries should
comply regarding the composition and the reusable and recoverable nature of
packaging and packaging waste. The Commission has been critical of the way in
which Member States have implemented the essential requirements aspect of the
Directive: 22
29/09/09
Although there seems to be some decoupling of packaging waste generation
from GDP growth, in almost all Member States the absolute quantity of
packaging waste is increasing. Prevention measures such as enforcement
systems for the essential requirements, packaging prevention plans and
strong producer responsibility systems might have had some effect on the
reduction of packaging generation. However, the overall patterns of packaging
waste generation are not significantly different between the Member States
applying different prevention tools and the Member States applying none of
these tools.
It has made clear its determination is to promote the development of European
standards relating to these essential requirements and has suggested that provisions
concerning proof of conformity with national standards should be applied
immediately.
1.4.1.2 End of Life Vehicles
Directive 2000/53/EC on end-of life vehicles seeks to make waste prevention its
priority objective. It stipulates that vehicle manufacturers and material and
equipment manufacturers must:
22 Commission of the European Communities (2006) Report from the Commission to the Council and
the European Parliament on the Implementation of Directive 94/62/EC on Packaging and Packaging
Waste and its Impact on the Environment, as well as Functioning of the Internal Market, COM (2006)
767 Final, 6 th December 2006.

19
� endeavour to reduce the use of hazardous substances when designing
vehicles;
� design and produce vehicles which facilitate the dismantling, re-use, recovery
and recycling of end-of-life vehicles;
� increase the use of recycled materials in vehicle manufacture;
� ensure that components of vehicles placed on the market after 1 July 2003 do
not contain mercury, hexavalent chromium, cadmium or lead, except in the
applications listed in Annex II. The Council or the Commission may amend the
Annex where scientific and technical progress make it possible to avoid using
these substances.
The Directive also introduces provisions on the collection of all end-of-life vehicles
(Article 5). Member States must set up collection systems for end-of-life vehicles and
for used parts. They must also ensure that all vehicles are transferred to authorised
treatment facilities, and set up a system of deregistration upon presentation of a
certificate of destruction. Such certificates are to be issued when the vehicle is
transferred, free of charge, to a treatment facility.
The last holder of an end-of-life vehicle may dispose of it free of charge ("free takeback"
principle). Producers must meet all, or a significant proportion of, the cost of
this measure.
The storage and treatment of end-of-life vehicles is also subject to strict control, in
accordance with the requirements of Directive 75/442/EEC replaced by Directive
2006/12/EC and of Annex I to the Directive. Establishments or undertakings carrying
out treatment operations must strip end-of-life vehicles before treatment and recover
all environmentally hazardous components. Priority must be given to the re-use and
recycling of vehicle components (batteries, tyres and oil).
At present, 75% of end-of-life vehicles are recycled (metal content). The aim of this
Directive is to increase the rate of re-use and recovery to 85% in terms of average
weight per vehicle/year by 2006, and to 95% by 2015, and to increase the rate of reuse
and recycling over the same period to at least 80% and 85% respectively in terms
of average weight per vehicle/year. Less stringent objectives may be set for vehicles
produced before 1980.
Member States must ensure that producers use material coding standards which
allow identification of the various materials during dismantling. The Commission must
establish European standards on material coding and identification.
Economic operators must provide prospective purchasers of vehicles with information
on the recovery and recycling of vehicle components, the treatment of end-of-life
vehicles and progress with regard to re-use, recycling and recovery. On the basis of
this information, Member States must report to the Commission every three years on
the implementation of the Directive. The Commission must then publish a report on
the implementation of the Directive.
Member States may incorporate some of the Directive's provisions into national law
by means of agreements with the economic sectors concerned.
International Review of Waste Policy: Annexes

1.4.1.3 Waste Electrical and Electronic Equipment
Directive 2002/96/EC on waste electrical and electronic equipment (WEEE) applies
to the categories of electrical and electronic equipment listed below, with subcategories
being the business-to-consumer (B2C) stream (which ends up predominantly
in the householder waste stream) and the business-to-business (B2B)
stream.
Category 1 - Large household appliances
Category 2 - Small household appliances
Category 3 - IT & telecoms equipment
Category 4 - Consumer equipment
Category 5 - Lighting equipment
Category 6 - Electrical & electronic tools
Category 7 - Toys, leisure & sports equipment
Category 8 - Medical devices
Category 9 - Monitoring & control equipment
Category 10 - Automatic dispensers
The WEEE directive is quite precise with regard to producer responsibility, specifically
referring to “producers”, providing a definition of what constitutes a “producer” and
requiring them to undertake specific actions. Until recently, these actions were as
follows:
1) producers must take into account waste management at the design stage of the
product e.g. by making design modifications that make WEEE easier to dismantle,
recycle and recover;
2) producers must guarantee fixed re-use and/or recycling and recovery rates either
individually or via collective organisations (the WEEE directive currently sets a
minimum collection target of 4 kg per annum per inhabitant for WEEE from
households);
3) producers are obliged to finance at least the collection, treatment, recovery and
environmentally-sound disposal of household WEEE deposited at collection sites;
and
4) for WEEE placed on the market after 13th August 2005, producers are obliged to
finance those operations associated with the waste from their own products/
production processes.
Distributors are also linked to the WEEE producer responsibility via an obligation to
take back products free of charge on a ‘one-for-one’ or ‘old-for-new’ basis.
In December 2008, a proposal for revised laws on WEEE was drafted by the European
Commission. The Commission noted that, following implementation of the Directive:
20
29/09/09
More than four years later only about a third of electrical and electronic waste
is reported to be treated in line with these laws and the other two thirds is
going to landfill and potentially to sub-standard treatment sites in or outside

21
the European Union. Apart from losing out on valuable secondary raw
materials, this is especially worrisome since inadequately treated products
pose major environmental and health risks. The illegal trade to non-EU
countries also continues to be widespread. Moreover many electrical and
electronic products not complying with the substance restrictions have been
found in the EU.
With regard to bullet point 2 above, it proposed that the collection target be altered
from 4 kg per annum per inhabitant to a 65% collection rate, calculated according to
the average amount of EEE placed on the market in the two preceding years. In
addition, in order to encourage the re-use of whole appliances, it is proposed that
such re-use be included within the 65% target. The proposal also goes further than
bullet point 3, suggesting that Member States should, where appropriate, encourage
producers to finance all the cost occurring for collection facilities for business to
consumer WEEE.
1.4.1.4 Batteries and Accumulators and Waste Batteries and Accumulators
Directive 2006/66/EC on batteries and accumulators and waste batteries and
accumulators outlines three distinct battery classifications – industrial, automotive
and portable (usually defined as sealed and hand carried). While it is clear which
sector of the economy industrial batteries belong, portable batteries are used across
consumer, commercial and industrial sectors (though the vast majority are used in
consumer applications). Automotive batteries also straddle all three sectors.
As noted in the Directive, “batteries” is used to mean single-life batteries (sometimes
also referred to as ‘primary’ batteries), and “accumulators” to mean rechargeable
batteries (sometimes also referred to as ‘secondary’ batteries). In this report
“batteries” is taken to mean both batteries and accumulators, unless otherwise
specified.
The intended impact of the Batteries Directive is to improve the environmental
performance of batteries and of the activities of all economic operators involved in
the life cycle of batteries. Key provisions of the Directive are:
� Restrictions on the use of mercury (0.0005%) and cadmium (0.0002%) in all
batteries by weight (with the exception of button cells at 2%);
� Labelling requirements for new batteries to aid consumer choice and recycling;
� A 25% collection rate for waste portable batteries to be met by September
2012, rising to 45% by September 2016. Note that the collection rate is not
the same as a recycling rate;
� A prohibition on the disposal by landfill or incineration of waste industrial and
automotive batteries – in effect setting a 100% collection and recycling target;
� The introduction of “producer responsibility” obligations;
� The setting of recycling efficiencies to ensure that a high proportion of the
weight of waste batteries is recycled (65% of lead acid batteries, 75% of
nickel-cadmium batteries and 50% of other waste batteries); and
� The setting of waste battery treatment standards.
International Review of Waste Policy: Annexes

Member State implementation of the Directive reflects these objectives. Member
States must take whatever measures are needed (including economic instruments) to
promote and maximise separate waste collections and prevent batteries and
accumulators being thrown away as unsorted municipal refuse. They have to make
arrangements enabling end-users to discard spent batteries and accumulators at
collection points in their vicinity and have them taken back at no charge by the
producers.
In principle, it must be possible to remove batteries and accumulators readily and
safely. It is for Member States to ensure that manufacturers design their appliances
accordingly.
Member States also have to ensure that, from 26 September 2009 at the latest,
batteries and accumulators that have been collected are treated and recycled using
the best available techniques. Recycling must exclude energy recovery. As a
minimum, treatment must include removal of all fluids and acids. Batteries and
accumulators must be treated and stored (even if only temporarily) in sites with
impermeable surfaces and weatherproof covering, or in suitable containers.
If there is no viable end market, or if a detailed assessment of environmental,
economic and social impact concludes that recycling is not the best solution, Member
States may dispose of batteries and accumulators containing cadmium, mercury or
lead in landfills or underground storage. Otherwise, it is prohibited to put waste from
industrial and automotive batteries and accumulators into landfill, or to incinerate it;
only residues from treating and recycling them may be disposed of in these ways.
The producers have to bear the cost of collecting, treating and recycling industrial,
automotive and portable batteries and accumulators, as well as the costs of
campaigns to inform the public of these arrangements. Small producers may be
exempted from this obligation if this does not impede the proper functioning of the
collection and recycling schemes. All producers of batteries and accumulators have to
be registered.
1.5 The Landfill Directive
Article 1 of the Landfill Directive sets out the objective: 23
22
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to provide for measures, procedures and guidance to prevent or reduce as far
as possible negative effects on the environment, in particular the pollution of
surface water, groundwater, soil and air, and on the global environment,
including the greenhouse effect, as well as any resulting risk to human health,
from landfilling of waste, during the whole life-cycle of the landfill.
Article 5 concerns waste and treatment not acceptable in landfills. Para 1 of Art. 5
states: 24
23 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999.

23
1. Member States shall set up a national strategy for the implementation of
the reduction of biodegradable waste going to landfills, not later than two
years after the date laid down in Article 18(1) and notify the Commission of
this strategy. This strategy should include measures to achieve the targets set
out in paragraph 2 by means of in particular, recycling, composting, biogas
production or materials/energy recovery. Within 30 months of the date laid
down in Article 18(1) the Commission shall provide the European Parliament
and the Council with a report drawing together the national strategies.
Article 5(2) sets targets for reducing the quantity of biodegradable waste sent to
landfill: 25
2. This strategy shall ensure that:
(a) not later than five years after the date laid down in Article 18(1),
biodegradable municipal waste going to landfills must be reduced to 75 % of
the total amount (by weight) of biodegradable municipal waste produced in
1995 or the latest year before 1995 for which standardised Eurostat data is
available
(b) not later than eight years after the date laid down in Article 18(1),
biodegradable municipal waste going to landfills must be reduced to 50 % of
the total amount (by weight) of biodegradable municipal waste produced in
1995 or the latest year before 1995 for which standardised Eurostat data is
available;
(c) not later than 15 years after the date laid down in Article 18(1),
biodegradable municipal waste going to landfills must be reduced to 35 % of
the total amount (by weight) of biodegradable municipal waste produced in
1995 or the latest year before 1995 for which standardised Eurostat data is
available.
Two years before the date referred to in paragraph (c) the Council shall reexamine
the above target, on the basis of a report from the Commission on
the practical experience gained by Member States in the pursuance of the
targets laid down in paragraphs (a) and (b) accompanied, if appropriate, by a
proposal with a view to confirming or amending this target in order to ensure a
high level of environmental protection.
Member States which in 1995 or the latest year before 1995 for which
standardised EUROSTAT data is available put more than 80 % of their
collected municipal waste to landfill may postpone the attainment of the
targets set out in paragraphs (a), (b), or (c) by a period not exceeding four
years. Member States intending to make use of this provision shall inform in
advance the Commission of their decision. The Commission shall inform other
Member States and the European Parliament of these decisions.
The implementation of the provisions set out in the preceding subparagraph
24 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999.
25 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999.
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may in no circumstances lead to the attainment of the target set out in
paragraph (c) at a date later than four years after the date set out in
paragraph (c).
Article 5(3) effectively bans a range of waste from landfill, including waste which does
not meet specific acceptance criteria laid down in Annex II of the Directive.
Article 6 concerns waste to be accepted in the different classes of landfill, and Art
6(a) is of particular significance since it requires that waste must be treated prior to
being landfilled: 26
Member States shall take measures in order that:
(a) only waste that has been subject to treatment is landfilled. This provision
may not apply to inert waste for which treatment is not technically feasible,
nor to any other waste for which such treatment does not contribute to the
objectives of this Directive, as set out in Article 1, by reducing the quantity of
the waste or the hazards to human health or the environment;
Article 2 defines treatment as follows: 27
"treatment" means the physical, thermal, chemical or biological processes,
including sorting, that change the characteristics of the waste in order to
reduce its volume or hazardous nature, facilitate its handling or enhance
recovery;
Different Member States have interpreted this requirement to treat with varying
degrees of vigour. Some have banned many wastes from landfill (and some of these
were doing so before the Directive), others have set thresholds for biodegradability
(so as to ensure treatment reduces this to very low levels) and some have adopted
very weak approaches (for example, the UK interprets the Article 2 definition very
generously, and takes the view that any amount of separation of materials (e.g. use of
a paper collection) constitutes pre-treatment. The EPA has recently issued Guidance
on how it intends to interpret the requirement to treat. 28 This is discussed in more
detail in Section 51.5.2 of these Annexes.
The Directive makes various other important points in respect to the operation of
landfills, and the recovery of costs, including those for aftercare. These requirements,
and their implementation within Ireland, as well as other (pre-Directive) efforts by the
EPA to close down unregulated dumps, have been important in increasing disposal
costs in Ireland from the very low levels of the early 1990s.
26 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999.
27 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999.
28 EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Johnstown Castle Estate: EPA.

1.6 The Incineration Directive
The Directive on the Incineration of Waste (‘the waste incineration Directive’, or WID)
was published in 2000. 29 The Directive replaces earlier Directives relating to
incineration.
25
The aim of this Directive is to prevent or to limit as far as practicable negative
effects on the environment, in particular pollution by emissions into air, soil,
surface water and groundwater, and the resulting risks to human health, from
the incineration and co-incineration of waste.
Co-incineration plant is defined under Article 3(5) as:
stationary or mobile plant whose main purpose is the generation of energy or
production of material products and:
— which uses wastes as a regular or additional fuel; or
— in which waste is thermally treated for the purpose of disposal.
Hence, the Directive covers emissions from facilities such as cement kilns which may
make use of wastes as fuel.
The Directive does not apply to some plants, set out in Article 2, such as those
treating only: 30
(i) vegetable waste from agriculture and forestry,
(ii) vegetable waste from the food processing industry, if the heat generated is
recovered,
(iii) fibrous vegetable waste from virgin pulp production and from production of
paper from pulp, if it is co-incinerated at the place of production and the heat
generated is recovered,
(iv) wood waste with the exception of wood waste which may contain
halogenated organic compounds or heavy metals as a result of treatment with
wood preservatives or coating, and which includes in particular such wood
waste originating from construction and demolition waste,
(v) cork waste.
Such plants may be regulated differently to incineration plants covered by the
Directive.
Some key aspects of the Directive are highlighted below.
Article 4 states: 31
29 Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the
incineration of waste, Official Journal of the European Communities L 332/91, 28/12/2000.
30 Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the
incineration of waste, Official Journal of the European Communities L 332/91, 28/12/2000.
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2. Without prejudice to Directive 96/61/EC, the application for a permit for an
incineration or co-incineration plant to the competent authority shall include a
description of the measures which are envisaged to guarantee that:
(a) the plant is designed, equipped and will be operated in such a manner that
the requirements of this Directive are taking into account the categories of
waste to be incinerated;
(b) the heat generated during the incineration and co-incineration process is
recovered as far as practicable e.g. through combined heat and power, the
generating of process steam or district heating;
(c) the residues will be minimised in their amount and harmfulness and
recycled where appropriate;
(d) the disposal of the residues which cannot be prevented, reduced or
recycled will be carried out in conformity with national and Community
legislation.
3. The permit shall be granted only if the application shows that the proposed
measurement techniques for emissions into the air comply with Annex III and,
as regards water, comply with Annex III paragraphs 1 and 2.
Article 6 lays down some of the key technical operating conditions for incineration
and co-incineration plants. Article 7 sets out rules regarding emission limit values,
making reference to Annex II and Annex V of the Directive, where these limit values
are set out. Articles 8 and 9 refer to water discharges, and the management of
residues, respectively. Article 10 lays out the requirements for control and monitoring,
whilst Article 11 establishes rules regarding measurement requirements, and
essentially sets out what is required in order to demonstrate compliance with the limit
values set out in the various Annexes to the Directive.
It is of interest to note that the pre-amble to the Directive makes reference to the
United Nations Economic Commission for Europe (UNECE) Convention on long-range
transboundary air pollution with regard to emissions of dioxins and furans, and of
particulates and mercury.
31 Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the
incineration of waste, Official Journal of the European Communities L 332/91, 28/12/2000.

1.7 The UNECE / Stockholm Conventions
1.7.1 The 1979 UNECE Convention on Long-range Transboundary Air
Pollution and Protocols:
The 1979 UNECE Convention on Long-range Transboundary Air Pollution (CLRTAP)
entered into force in 1983. It has since been extended by eight specific protocols. The
two most relevant of protocols are those on POPs and Heavy Metals. 32
POP POPs POP s Protocol: Protocol: The Executive body to the Convention on Long-Range Transboundary
Air Pollution adopted the Protocol on Persistent Organic Pollutants (POPs) on 24th June 1998. The POPs protocol focuses on a list of 16 substances that have been
selected according to agreed risk criteria. They comprise eleven pesticides, two
industrial chemicals and, of particular interest for incineration, three unintentionally
produced by-products.
The Protocol was signed by 36 of 48 Parties to the CLRTAP and by all EU Member
States and entered into force on 23 rd October 2003. Ireland signed the UNECE
protocol on 24 th June 1998 but has not yet ratified. 33 The protocol has 29 Parties and
entered into force on 23 rd October 2003. The Protocol was signed by the European
Community on 24 th June 1998 and approved on 30 th April 2004.
The objective of the protocol is to eliminate discharges, emissions and losses of
POPs. It bans the production and use of some chemicals outright (aldrin, chlordane,
chlordecone, dieldrin, endrin, hexabromobiphenyl, mirex and toxaphene); others are
scheduled for elimination at a later stage (DDT, heptachlor, hexachlorobenzene
(HCB), and polychlorinated biphenyls (PCBs)). It includes provisions for dealing with
the wastes of chemicals that will be banned.
It also obliges Parties to reduce their emissions of dioxins, furans, polycyclic aromatic
hydrocarbons (PAHs) and HCB below their levels in 1990 (or an alternative year
between 1985 and 1995). For the incineration of municipal, hazardous and medical
waste it lays down specific limit values.
The The Protocol Protocol on on Heavy Heavy Metals Metals: Metals This was adopted on 24 June 1998 in Aarhus,
Denmark. It targets three particularly harmful metals: cadmium, lead and mercury.
According to one of the basic obligations, Parties have to reduce their emissions for
these three metals below their levels in 1990 (or an alternative year between 1985
and 1995). The Protocol aims to cut emissions from industrial sources (iron and steel
industry, non-ferrous metal industry), combustion processes (power generation, road
transport) and waste incineration.
It lays down stringent limit values for emissions from stationary sources and suggests
best available techniques (BAT) for these sources, such as appropriate filters or
32 UNECE (1998) Aarhus Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution
on Persistent Organic Pollutants. 1998; UNECE (1998) Aarhus Protocol to the 1979 Convention on
Long-Range Transboundary Air Pollution on Heavy Metal. 1998.
33 http://www.unece.org/env/lrtap/status/98pop_st.htm
27
International Review of Waste Policy: Annexes

scrubbers for combustion sources or mercury-free processes. It also introduces
measures to lower heavy metal emissions from other products, such as mercury in
batteries, and proposes the introduction of management measures for other mercurycontaining
products, such as electrical components (thermostats, switches),
measuring devices (thermometers, manometers, barometers), fluorescent lamps,
dental amalgam, pesticides and paint.
1.7.2 The Stockholm Convention
The Stockholm Convention was formally adopted on 22 nd – 23 rd May 2001. 34 The
Convention entered into force on 17 th May 2004, the ninetieth day after the date of
deposit of the fiftieth instrument of ratification. By 11 th May 2009 there were 152
signatories and 163 countries and economic regions including the European
Community were parties.
The Convention establishes a strong international regime for promoting global action
on twelve POPs which are also included in the UNECE Protocol. Specific reference is
made to the precautionary approach as set out in Principle 15 of the Rio Declaration
on Environment and Development. Nine intentionally produced chemicals (aldrin,
chlordane, dieldrin, endrin, HCB, heptachlor, mirex, toxaphene and PCBs) are subject
to a ban on production and use except where there are generic or specific
exemptions. In addition, the production and use of DDT is severely restricted.
There are special provisions for those Parties with regulatory assessment schemes to
review existing chemicals for POPs characteristics and to take regulatory measures
with the aim of preventing the development, production and marketing of new
substances with POPs characteristics.
At the fourth Conference of the Parties, held in Geneva between 4 th and 8 th May
2009, nine new POPs were added to the Convention under the review procedures. 35
These chemicals were:
28
� Alpha hexachlorocyclohexane to Annex A;
� Beta hexachlorocyclohexane to Annex A;
� Hexabromodiphenyl ether and heptabromodiphenyl ether to Annex A (the
commercial formulation of Octa Brominated Diphenyl Ether ‘c Octa BDE’);
� Tetrabromodiphenyl ether and pentabromodiphenyl ether to Annex A (the
commercial formulation of Penta Brominated Diphenyl Ether ‘c Penta BDE’);;
� Chlordecone to Annex A;
� Hexabromobiphenyl to Annex A;
34 UNEP (2001) Stockholm Convention on Persistent Organic Pollutants
, United Nations Environment
Programme, Editor. 2001.
35 Stockholm Convention (2009) Governments Unite to Step-up Reduction on Global DDT Reliance and
add Nine New Chemicals under International Treaty, Press Release, Geneva, 8 May 2009.
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29
� Lindane to Annex A;
� Pentachlorobenzene to Annex A and C; and
� Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride to
Annex B.
Within Europe, this is likely to lead to a revision of Regulation 850/2004, and this will
have knock-on implications for Ireland.
The use of best available techniques for new sources within the major source
categories, including incineration of municipal waste, is promoted and, in accordance
with the implementation schedule of a country’s action plan, is required.
The Convention also foresees identification and safe management of stockpiles
containing or consisting of POPs; this can include incineration residues. Waste
containing, consisting of, or contaminated with, POPs should be disposed of in such a
way that the POP content is destroyed or irreversibly transformed. Where this does
not represent the environmentally preferable option or where the POP content is low,
waste shall be otherwise disposed of in an environmentally sound manner. Disposal
operations that may lead to the recovery or re-use of POPs are forbidden, a barrier to
the re-use of incinerator air pollution control residues.
It should be noted that at present, the ‘low POPs level’ is currently set at 15 parts per
billion for dioxin by Reg 1195/2006. 36 This level is higher than the dioxin levels which
are likely to be found in modern incinerator air pollution control residues but is likely
to be reduced in the future to a lower threshold as the Regulation requires that the
issue is revisited and parties at the Fourth Conference of the Parties (COP4) to the
Stockholm Convention have expressed concern that the levels need to be reduced.
1.8 Summary
In respect of waste management, there are some increasingly strong markers
provided in respect of policy development. The revised Waste Framework Directive
gives greater emphasis than has been present hitherto to the priority position
accorded to waste prevention. Also, the revised Directive suggests that policy would
do well to take heed of the requirement to:
� Develop objectives in line with the hierarchy outlined in Article 4 of the WFD,
though with departures from this ranking made clear where the case, based
on life-cycle thinking, justifies this;
� Include a specific programme for waste prevention. A forward looking strategy
would pre-empt the decoupling objective foreseen by the WFD. Ireland’s
National Waste Prevention Programme is a foresightful development in this
regard;
36 European Commission (2006) Council Regulation (EC) No 1195/2006 of 18 July 2006 amending
Annex IV to Regulation (EC) No 850/2004 of the European Parliament and of the Council on persistent
organic pollutants. Official Journal of the European Union, 2006: p. L217/1 - 217/3
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30
� Put in place means to ensure that targets for recycling of at least 50% from
household waste and 70% from construction and demolition waste are met in
the spirit of pre-empting the WFD objectives. Ireland is already meeting the
50% target for household waste, narrowly defined; 37
� Ensure that mechanisms are in place which lead to the separate collection of
glass, metals, paper and plastic (where appropriate), again pre-empting the
WFD requirements;
� Implement measures designed to lead to separate collection of biowaste;
� Implement policies or mechanisms that encourage the use of products of
biowaste management;
� Ensure that where incineration or co-incineration are employed, permits
should not be issued unless the recovery of energy takes place ‘with a high
level of energy efficiency’;
� Apply the polluter pays principle; and
� Give substance to the concept of resource efficiency;
In addition, Regulation (EC) No. 850/2004 should be implemented as soon as
possible within Ireland. Although a National Implementation Plan is in development,
this is a rather late development. 38 Finally, the Landfill Directive targets, and indeed,
some of the technical measures besides (for example, the requirement to pre-treat
waste prior to landfilling) need to be addressed. With respect to the Landfill Directive
targets, no measure is yet in place which cascades responsibility for meeting these
targets down to the actors capable of delivering them. With regard to the pretreatment
requirements, the EPA has recently acted to rectify the absence of any
such measures, though exactly how this will unfold is as yet unclear. 39
37 The exact interpretation of this is yet to be made clear by the European Commission, though the
suggestion is that the target may be applied to the totality of waste included within a country’s chosen
range of waste streams.
38 European Commission (2004) Regulation (EC) No 850/2004 Of The European Parliament and of the
Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC Note
that whilst this was published in the Official Journal of the European Union L158 of 30th April 2004. A
Corrigendum to the Regulation was subsequently published in the Official Journal L229/5 of 29th June
2004. 2004, Official Journal of the European Union L 229/5.
39 EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Johnstown Castle Estate: EPA.
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2.0 Policy Instruments for Waste Management
2.1 Introduction
There are a range of different policy instruments which could be used to address the
issues which arise in the context of waste management. Most countries resort to a
mix of:
31
� Command and control instruments, which set standards that have to be met
(e.g. compulsory targets for recycling), or limits (e.g. to emissions of pollutants)
that cannot be exceeded. These might include:
• Technology standards:
for example, elaboration of best available techniques;
• Product quality standards:
for example, standards for different quality grades of compost;
• Emissions standards or limit values:
for example, the limit values set for emissions from incinerators under
the Waste Incineration Directive; and
• Performance targets:
for example, local authority recycling targets.
� Economic instruments, including: 40
• User charges:
for example, charges for the use of waste services. Note that the
definition of ‘charges’ is not formalised, but that typically, a charge will
be paid in exchange for a service, and the charge will vary with the level
of service demanded / received;
• Product charges:
for example, charges applied to products that create pollution either
through their manufacture, consumption or disposal (e.g. charges on
batteries). In the waste arena, these are typically used to modify
relative prices and / or to finance collection and treatment systems;
• Taxes:
Taxes differ from charges in that they are unrequited payments to the
central government. The unrequited nature of these payments relates
to the fact that they are paid irrespective of the level of service received
from central government (for example, landfill taxes, product (e.g.
plastic bag) taxes, etc.). Taxes are occasionally ear-marked for specific
40 See, for example, OECD (1999) Economic Instruments for Pollution Control and Natural Resources
Management in OECD Countries: A Survey, ENV/EPOC/GEEI(98)35/REV1/FINAL, October 1999.
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purposes (as with the revenues from the Irish taxes, which are
channelled to an Environmental Fund). There has been much
discussion in the literature regarding the wisdom, or otherwise, of this
type of approach; 41
• Tradable / transferable allowances, or credits:
for example, the use of tradable allowances for landfilling, or tradable
compliance credits for achieving packaging recovery targets, as used
(in both cases) in the UK;
• Deposit-refund schemes:
These are most commonly used for beverages
• Non-compliance fees:
imposed under civil law on polluters who do not comply with
environmental or natural resource management requirements and
regulations. They can be proportional to selected variables such as
damage due to non-compliance, profits linked to reduced (non-)
compliance costs,
• Performance bonds:
polluters or users may be required to deposit revenue in the form of a
bond so as to guarantee compliance with specified requirements. The
fund (or part of it) is typically refunded once compliance is achieved;
• Liability payments:
these are payments made to ‘victims’ to compensate for damage
caused by pollution activity. They can operate in the context of specific
liability rules and compensation schemes, or the payments can be
made from a fund financed by contributions from ‘potential polluters’
(the best examples relate to oil-spills); and
• Subsidies:
Subsidies include any form of explicit financial assistance to polluters
(grants, soft loans, tax breaks, accelerated depreciation, etc.).
� Voluntary / negotiated agreements, which constitute non-statutory measures
undertaken by an industry sector, often at the behest of government (or its
41 There is also a great deal of discussion, in the literature, regarding whether a tax applied in the
environmental sphere is ‘really environmental’, or ‘just a revenue raiser’. This debate often centres on
how the revenue being raised is to be used (will it be used for environmental purposes?). The view of
the OECD on the matter is quite clear: it is not the use of revenue which makes a tax ‘environmental or
not’, rather it is the basis for the tax itself (is it something which pollutes, or otherwise causes
environmental harm?). The logic is quite sound: the effect of the incentive conveyed by the tax itself in
the market ought not to be affected by the motives of government. The only question, therefore, is
whether ear-marking of revenues is a good idea or not, and under what conditions might it be so.

33
agencies), and occasionally under the threat of the application of one of the
above. The OECD differentiates between four types of initiative: 42
• Unilateral commitments made by polluters / producers;
• Private agreements between polluters and pollutees (essentially,
victims);
• Environmental agreements negotiated between industry and public
authorities (or their agents);
• Voluntary programmes developed by public authorities, to which
individual firms are invited to participate.
Whatever the configuration of policy, it is important to note three things:
1) None of the policies act in isolation;
2) The distinction between categories is far from clear cut. For example, tradable
allowances operate in either ‘cap-and-trade’ form or ‘baseline-and-credit’ form. In
either case, the economic incentive is established through the magnitude of the
cap, or the required change from baseline. In other words, there is a regulatory
(target) component to the instrument as well as a economic / market based
incentive (in the form of trading); and
3) Importantly, when new policies are introduced, they essentially alter the economic
calculus confronting actors in the economy. The calculus in terms of the potential
benefits associated with evasion / illegal behaviour essentially change.
Consequently, incentive / target based instruments need to be supported by
adequate enforcement mechanisms, preferably anticipating the nature of illegal,
quasi-legal and evasive behaviour to ensure that perverse consequences are kept
to a minimum. It is not surprising, therefore, that the list of economic instruments
elaborated by the OECD includes a growing number related to compliance,
enforcement and liability.
2.2 What is the Right Policy Mix?
Attempts to elicit ‘the best’ policy mix have tended to focus on theoretical
considerations. In addition, the evaluations tend to be dominated, not without some
reasonable justification, by economic concerns. In essence, it is generally accepted
that, in perfect markets, a first best solution is to apply taxes on all externalities so
that the market internalises, within market prices, the costs of environmental
damages. Three clear problems arise:
a) From the economic perspective, markets are not all perfect (the problem of
market failure); 43
42 OECD (2003) Voluntary Approaches for Environmental Policy: Effectiveness, Efficiency and Usage in
Policy Mixes, Paris: OECD.
43 The issue of market failure is frequently treated, in what one might call economic orthodoxy, as
though it provides a framework for analysis accepted by all economists. This is not entirely true. From
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34
b) In respect of both the status of economic science, and the status of the
natural sciences, quantifying the external damages associated with economic
activity is not straightforward; and
c) From the political perspective, nation states do not have the competence to
impose taxes in other nation states. They do, and may (with reasoned
justification, and as long as the measures do not place imports at a
disadvantage) apply border taxes on imports, but in order to internalise all
externalities associated with producing imports, the complexity of border tax
adjustments would be considerable.
For this (and other political) reasons, few cases exist of environmental taxes that have
been set through direct reference to externalities, the best examples being the UK
landfill tax (in its early days), the UK aggregates tax and the Danish packaging tax.
Much of the public policy sphere, therefore, relates to implementation of second best
solutions wherever the first best solution – taxing the cause of environmental
damage, or subsidising the generation of positive externalities - is not readily
available. An excellent example is provided by the case of recycling. If all externalities
of producing primary and secondary materials were internalised, then most analyses
suggest that the environmental benefits of recycling would manifest themselves
through a considerable price differential in favour of secondary materials. In the
absence of the ability to implement the first best solution, public policy has, by and
large, sought to encourage recycling through means of second best instruments.
However, it may do so (depending upon the detail of implementation) at the expense
of the potential incentives for waste prevention that the first best solution – through
making both primary and secondary materials more expensive (but by differing
amounts) – would effectively generate. In other words, the second best solution tends
to ‘grope towards’ the outcome that the first best solution might deliver.
Notwithstanding the above, typically, ex ante evaluations of environmental policy
favour those that work through the market mechanism. The reason for this hinges on
the assumed – and usually, real – heterogeneous nature of the costs of the
opportunities for abatement of pollution, or for environmental improvement.
an institutional perspective, markets do not ‘fail’ so much as they deliver (though not in a deterministic
manner) the outcomes which are commensurate with their (institutional) design. The institutions do not
‘fail’ either, other than in the sense that they do not deliver the sort of market which the orthodox
economist would like to see. Since economists have been concerned (in their pursuit of the Holy Grail
of ‘market success’) primarily with the notion of efficiency, we must presume that what is being sought
is institutional change commensurate with the attainment of this goal. But as Bromley (Daniel W.
Bromley (1989) Economic Interests and Institutions: The Conceptual Foundations of Public Policy,
Oxford: Basil Blackwell) has pointed out, the question of efficiency lacks any social and policy
relevance without asking whether efficiency in and of itself is a relevant policy goal. To the extent that
one asks this question at all, one immediately begins to transgress what for many economists is the
cherished boundary between ‘positivist’ economics (in which no value judgements are made - Mirowski
(Philip Mirowski (1989) More Heat Than Light: Economics as Social Physics, Physics as Nature's
Economics, Cambridge: Cambridge University Press) has traced this habit amongst economists to what
he calls their ‘physics envy’) and what (from a normative as opposed to a realist position) is a
normative discipline, that of policy making,
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Mechanisms which operate through the market can ensure that a given
environmental outcome is achieved at the lowest cost to the economy, overall.
A key issue remains the ‘strength of the instrument’ to be applied. As mentioned
above, this ought to consider the marginal environmental damages, or benefits, and
the marginal private costs, but the former are not straightforward to measure, and the
latter are not especially well understood in advance of a measure’s implementation. 44
External costs are tolerably well known for some air pollutants for which the
epidemiological evidence is of high quality, but even here, there remain debates
concerning methodology. The strength of any instrument, whether target or economic
instrument, therefore tends to be set through the political process and by negotiation,
influenced by studies that may be carried out in the context of the development of the
instrument. Lobbying also occurs with the intention of influencing the design of the
instrument.
In essence, therefore, the theory of public policy has not been highly influential in
terms of policy design. That being the case, ex post assessment of policy has much to
recommend it. This can highlight policies with significant potential for environmental
improvement.
However, ex post policy assessments of a high quality are very rare. There is a weak
tradition of policy evaluation, and policies are rarely implemented with a view to
understanding the effects of the policy and learning from it. This is certainly true of
Irish waste management policy, but it applies with some force, also, to other
countries’ waste policies. Quality evaluations seek to understand the effects of policy
against a plausible counterfactual (i.e. what would have happened in the absence of
the policy).
2.3 Key Policy Issues in Waste Management
Waste management problems such as littering, ‘overproduction’ of waste, and levels
of recycling that are considered to be ‘too low’, can be explained, in economic terms,
as resulting from incorrect price incentives. Economic theory suggests that if a waste
management system is to be efficient, then participants, such as producers and
consumers, should at each step, face prices that reflect the marginal social cost (that
is the social cost arising from the production of one extra unit of waste).
For many waste management systems, prices do not accurately reflect marginal
social costs for three key reasons. The first is that waste management often
generates uncompensated external costs that impact upon third parties. The second
is that handling of waste is frequently subsidised by governments who pay a
proportion of the marginal private cost of waste management, though this appears
not to be a strong influence in Ireland. The third is that the pricing used to charge for
44 The main reason for this is that the world is not static. Most ex post assessments are shy of
estimating how learning effects, innovation and technical change might have affected costs.
Consequently, private costs tend to be over-estimated in ex ante policy assessments. In the case of
Irish waste management, this matter is compounded massively by the absence of a solid foundation
from which to launch a meaningful analysis of the costs as they currently stand.
35
International Review of Waste Policy: Annexes

waste management services is not always such that marginal changes in quantities
are reflected in changes in the charges paid.
The marginal private cost of waste management is composed of the extra wage and
equipment costs, along with the opportunity cost of the land needed for collection
and disposal of one extra unit of waste, all of which can readily be calculated.
Marginal external costs, however, such as noise, dust, litter, and groundwater
pollution are less obvious. The marginal social cost is simply the sum of marginal
private costs and marginal external costs.
Where external costs are present, marginal social costs (MSC) exceed marginal
private costs (MPC). Where subsidies exist, MPC exceeds the price (P) paid by the
waste generator, e.g. the household. In theory, creating an efficient system of waste
management requires the development of policies, such as taxation to internalise
environmental costs, in order that the MPC equals the MSC, as well as the removal of
subsidies such that MPC equals P.
2.3.1 Policies to Achieve the Optimal Pricing for Waste Services
Numerous studies have considered what an optimal policy for municipal waste
management might be. 45 As suggested above, the goal of such a policy would be to
make manufacturers and consumers aware of the social costs associated with the
disposal of products, by introducing taxes that reflect the marginal social costs that
products and packaging impose at the end of their use. This is not always possible in
the direct sense where goods and services are widely traded, and where the ability of
national policy to influence matters is limited. It is possible with some of the impacts
which occur within national borders, for example, with respect to disposal.
Generally the most favoured approach of most theorists is one or other combination
of an advanced disposal fee (ADF) levied on the manufacturer at the point of sale, a
charge on householders for disposal (pay by use) (PBUC), and a subsidy for recycling
or appropriate disposal. Palmer and Walls also consider an upstream combination
tax/subsidy, where effectively the ADF is replaced by a tax on materials use and the
subsidy is paid to collectors of recyclables. 46
For a system with no recycling, theory suggests that the results from approaches
based on either an ADF or PBUC, reflecting the marginal social costs of disposal, are
45 See, for example, H. Bartelings (2003) Municipal Solid Waste Management Problems, An Applied
General Equilibrium Analysis, PhD Thesis, University of Wageningen; V. Linderhof, P. Kooreman, M.
Allers and D. Wiersma (2001) Weight-based Pricing in the Collection of Household Waste: The
Oostzaan Case, Resource and Energy Economics, 23, pp.359-71; Thomas Skinner and Don Fullerton
(1999), The Economics of Residential Solid Waste Management, NBER Working Paper 7326
http://www.nber.org/papers/w7326; K. Palmer and M. Walls (1999) Extended Product Responsibility:
An Economic Assessment of Alternative Policies, Discussion Paper 99-12, January 1999, Washington
DC: Resources for the Future; Don Fullerton and Amy Raub (2003) Economic Analysis of Solid Waste
Management Policies, in OECD (2004) Addressing the Economics of Waste, Paris: OECD.
46 K. Palmer and M. Walls (1999) Extended Product Responsibility: An Economic Assessment of
Alternative Policies, Discussion Paper 99-12, January 1999, Washington DC: Resources for the Future.
36
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identical, but in practice they have quite different characteristics and shortcomings.
Two key differences are outlined below:
37
• Collection and disposal costs vary so it would be very difficult to design an ADF
for producers, who may serve a national market, based on where the product
is likely to be disposed to take account of the varying social costs of disposal.
An PBUC on households, however, can take these more location and
household specific aspects into account; and
• Different products have varying collection and disposal costs. An ADF can vary
according to the (typical) cost of collecting and disposing of the product, but an
PBUC must be uniform across products (for example at a set price per tonne),
unless it is to become very complicated and expensive to administer.
Once recycling becomes an option, in theory, a subsidy to encourage recycling can be
coupled with an ADF to encourage generation of the optimum level of waste.
However, the difficulties of transferring these theoretical approaches to the real world
are neatly summarised by Porter: 47
“Any ADF would ideally be equal to some aij where i is the product (or package)
and j the place where it is sold (or more precisely, where it will be disposed of).
But in fact, it would be very difficult to vary the ADF by place, so it would end
up being ai, varying across products (and packages) but not across places.
Similarly any trash collection charge (t) or recycling collection charge/refund
(r) would ideally be equal to some tij or rij also varying across product and
place. But in fact it is very difficult to vary them across products since that
would require extensive household sorting or lengthy collector examinations,
so these would end up being tj and rj varying across places but not across
products. In a sentence, it is in practice impossible to achieve a fully first-best
policy – close is as close as we can come”.
In the absence of a perfect application of marginal cost pricing in the real world, an
increasingly common approach is to attempt to internalise external costs through
what is known as extended producer responsibility.
2.3.2 Extended Producer Responsibility
Extended producer responsibility (EPR) describes a range of approaches that aim to
address the externalities associated with waste disposal through placing with
producers the financial or physical responsibility for the environmental impacts their
products have when their useful life ends. The goals of EPR in broad terms are both
to relieve some of the financial burdens of waste management from municipalities,
and to incentivise producers to reduce resources, increase use of secondary
materials, and bring about waste reduction through product re-design. 48
47 Richard C. Porter (2004), Efficient Targeting of Waste Policies in the Product Chain, in OECD (2004)
Addressing the Economics of Waste, Paris: OECD.
48 OECD (2001) Extended Producer Responsibility: A Guidance Manual for Governments, Paris: OECD.
International Review of Waste Policy: Annexes

Several policy instruments are available that are aligned with the principles of EPR.
These include advance disposal fees, deposit refunds, product take-back and
recycled content standards. In accordance with Walls’ maxim that ‘the goal of EPR
policy should be …… to maximize social welfare’, these instruments can be used to
tackle negative externalities in an efficient manner. 49
Results from a number of theoretical economic studies have shown that using an EPR
instrument, namely a deposit-refund, can deliver reductions in waste more costeffectively
than when other instruments are applied in isolation. 50 The key reason for
this is the bringing together of output reduction and input substitution incentives
within one policy. In cases where illegal dumping is considered a problem, or where
recycling markets are not functioning well, EPR policies are considered to be
particularly effective in creating appropriate incentives for reducing waste. 51
A number of the key policy instruments, and variants of those instruments, that fall
under the EPR umbrella, as detailed by Walls, are summarised below: 52
38
� Product take-back mandate and recycling rate target – Here the government
requires manufacturers and/or retailers to accept the return of products once
their useful life has ended. Such mandates are often combined with a
recycling or waste diversion target requiring each producer to meet a recycling
rate goal of, for example, 75% for its products. The German packaging law
works in this way; take-back is required and material-specific recycling rate
targets are set. Firms often form a ‘producer responsibility organisation’ (PRO)
to handle collection, arrange for recycling, and ensure recycling targets are
met in a cost-effective manner;
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However, beyond increasing take-back and recycling rates, it is not always
clear that such schemes actually impose a sufficient incentive on producers to
both reduce packaging, and design more recyclable products.
Fullerton and Raub 53 suggest that if the firm is only responsible for the private
cost of disposal, it does not internalise the full social marginal cost. They argue
49 M. Walls (2004) EPR Policy Goals and Policy Choices: What Does Economics Tell Us? In OECD
(2004) Economic Aspects of Producer Responsibility, Paris: OECD.
50 D. Fullerton and T. C. Kinnemann (1995), Garbage Recycling and Illicit Burning or Dumping, Journal
of Environmental Economics and Management, 29 (1); T. Dinan (1993) Economic Efficiency Effects of
Alternative Policies for Reducing Waste Disposal, Journal of Environmental Economics and
Management 25: 242–56; K. Palmer & M. Walls (1994) Materials Use and Solid Waste: An Evaluation
of Policies, Resources for the Future Discussion Paper 95-02, Washington: Resources for the Future.
51 M. Walls (2003) The Role of Economics in Extended Producer Responsibility: Making Policy Choices
and Setting Policy Goals, Resources for the Future Discussion Paper 03-11, Washington: Resources for
the Future.
52 M. Walls (2006) Extended Producer Responsibility and Product Design: Economic Theory and
Selected Case Studies, Resources for the Future Discussion Paper 06-08, Washington: Resources for
the Future.
53 D. Fullerton and A. Raub (2004) Economic Analysis of Solid Waste Management Policies, in OECD
(2004) Addressing the Economics of Waste, Paris: OECD

39
that firms may still need to be made to pay the full marginal external damages
of disposal, and that if this cost is internalised, they will then have the correct
incentives, with no need for subsidies for ‘green design’ of products and
packaging.
OECD 54 identifies a range of external costs and benefits associated with
different waste management options. While landfilling has a negative benefit
(i.e. a cost) ranging from -€9.61 to -€44.75 per tonne, recycling of paper/card
has an external benefit of €45.86 to €94.17 per tonne. Thus a tonne of
paper/card that is recycled rather than being landfilled has an external benefit
ranging from around €55 per tonne to €138 per tonne.
Indeed in many cases it is clear that producers involved in such schemes still
do not pay the full marginal private cost of disposal, let alone the full marginal
social cost. Current levels of payments from producers to PROs often simply
cover a typical cost of collecting and transporting material to a recycler, thus
not meeting other private costs of landfill such as gate fees. Basing fees on
marginal social costs of disposal would allow for a greater incentive for the
collection of products for recycling, with subsequent higher payment for
collectors more accurately reflecting the benefits of avoiding disposal via
landfill.
On a wider scale, where municipalities still undertake the collection of
packaging materials for recycling in countries where producer responsibility
schemes operate, the private costs have certainly not been fully internalised 55.
� Product take-back mandate and recycling rate targets with a tradable recycling
credit scheme – The same as outlined above except that targets apply not to
each individual producer but to the industry as a whole; tradable credits are
issued with firms trading among themselves. An industry wide recycling rate
target can therefore be met with some producers exceeding the target and
some failing to meet it. Tradable credit schemes can be set up in various ways.
One example is the UK’s packaging recovery system. Reprocessors of
packaging materials issue “packaging waste recovery notes”, or PRNs, which
firms and PROs can trade with one another to meet their recycling obligations;
� Voluntary product take-back with recycling rate targets – In such an approach,
firms within an industry agree to organise a take-back system for their
products and set recycling goals. There are no government regulations or laws
mandating compliance, and no penalties for not meeting the goals. In the US,
voluntary take-back programs of this type include the Rechargeable Battery
Recycling Corporation (RBRC), which represents manufacturers of
rechargeable batteries, who pay a fee to operate a collection and recycling
54 D. Hogg (2006) Impact of Unit-based Waste Collection Charges,
ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
55 Perchards (2005) Study on the Progress of the Implementation and Impact of Directive 94/62/EC
on the Functioning of the Internal Market, Final Report; Eunomia et al (2007) Household Waste
Prevention Policy Side Research Programme, Final Report for Defra, May 2007
International Review of Waste Policy: Annexes

40
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system. Another is Carpet America Recovery Effort (CARE), created by an
agreement that arose from a 2002 MOU between manufacturers, several
state governments and the US EPA. The memorandum set voluntary recycling
rate goals for carpet to be reached by 2012;
� Advance recycling fees – An ARF – which was originally referred to as an
advance disposal fee, or ADF – is a tax assessed on product sales and often
used to cover the cost of recycling. ARFs are often assessed per unit of the
product sold but can also be assessed on the basis of weight. ARFs may be
visible to the consumer on the purchase of a product, as a separate line on the
bill, or imposed upstream on producers and later incorporated in the sales
price; and
� ARF combined with a recycling subsidy – An ARF raises money that can be
used in a variety of ways. The incentive effects of the policy depend greatly on
both the type of ARF and the use of revenues. A ‘back-end’ recycling subsidy –
either a subsidy per unit of the product recycled or unit weight of material
recycled – leads to quite a different policy instrument than one in which ARF
revenues are used to cover waste management cost or infrastructure costs in
a lump-sum fashion. California’s used oil programme, the western Canada
used oil programme, lead-acid batter programmes in several US states, and
California’s e-waste programme are all ARF/recycling subsidy programs.
All of these policy instruments make the producer financially or physically responsible
for the end-of-life environmental impacts of his product. In this sense, they could all
be considered EPR. However, they have very different incentive effects and ultimately
may lead to different environmental outcomes, and the costs of the instrument may
differ widely.
Other non-EPR policy instruments can lead to similar outcomes but do not focus
upstream on producers. To illustrate the contrast, four such non-EPR instruments are
outlined below
� Landfill bans – Many US states and European countries ban disposal of
particular items in landfills (or incinerators);
� ‘Pay as you throw’ pricing of waste collection/disposal – A large number of
Irish authorities, as well as many municipalities in the EU, more than 4,000
communities in the US, all municipalities in South Korea and many other
municipalities in other countries besides, charge for the collection and
management of waste using a variable fee element. In some countries, end-oflife
fees are charged for specific items that are difficult to dispose of. None of
these policies are aimed at the producer, and so do not qualify as EPR, but
they do have some effects on waste generation and recycling, usually through
affecting consumption decisions and through changing citizens’ behaviour.
� Recycling subsidies – The government may raise funds in ways that are not
ARFs/ADFs, and subsidize recycling. The government could make a payment
per unit or kg of material recycled, or it could make lump-sum grants to
communities or recycling centres. Such grants are quite common in the US.
Whether the subsidy is per unit volume, per unit of weight, or a one time lump
sum will have different effects; and

41
� Recycling investment tax credits – In this case, government gives a credit on
income taxes to anyone who invests in recycling infrastructure. Effectively this
is a direct subsidy to capital.
2.4 Summary
The above discussion focuses on some of the key issues confronting policy makers
who might seek to implement a policy that is ‘optimal’ from the economic perspective.
There are considerable problems with seeking to design such a policy configuration,
many of which have been touched upon above.
In essence, however, the suggestion is that the workings of the market can be
harnessed to deliver environmental benefits. Some lessons are the standard ones:
insofar as possible, markets should be made to operate more efficiently by
internalising externalities. However, here, first best solutions, particularly where the
matter of waste prevention are concerned, are not so obviously available owing to the
information needs, and the absence of any clear hope, at least for the foreseeable
future, of multilateral externality taxes (which, in any case, would be fiendishly difficult
to design such that they were genuinely reflecting externalities).
The issue of policy design is a complex one. In Walls’ words: 56
Identifying, designing, and implementing cost-effective environmental policies
is no small job. Accomplishing this goal when multiple environmental
objectives are on the table, when it is vital that the policy spur DfE [design for
the environment], and when some markets, such as recycling markets,
function poorly is even more difficult.
This is the challenge which faces the existing study – to focus on the relevant
objectives, and the necessary policies required to deliver these.
56 M. Walls (2004) EPR Policy Goals and Policy Choices: What Does Economics Tell Us? In OECD
(2004) Economic Aspects of Producer Responsibility, Paris: OECD.
International Review of Waste Policy: Annexes

KEY INSTITUTIONAL ISSUES
Ireland has been moving from a government run monopoly of waste management
services in the 1990s toward a privatised approach to waste collection and disposal.
Forfás (2008) estimates that 67 percent of municipal waste in Irish regions is
collected by private companies. 57
Ireland has a set up of 29 local authorities and 5 urban authorities. These have been
consolidated into regions for the management of waste, giving rise to 7 regions and 3
independent local authorities. The regions are responsible for designing waste
management plans in line with the national waste management plan devised by
central government.
In 2006 dissatisfaction in the waste industry led to a government decision to review
waste regulations. This was welcomed by IBEC 58 who had outlined several issues
pertaining to Irish waste management for several previous years.
A review of regulations was required, according to IBEC, for the following reasons:
42
� Artificially high cost of waste management in Ireland (as a result of an
imperfect market);
57 Forfás, (2008) Waste Management Benchmarking Analysis and Policy Priorities, available at:
http://www.forfas.ie/media/forfas080528_waste_benchmarking.pdf
58 IBEC (2006) Press Centre: IBEC welcomes Governments review of waste market, available at:
http://www.ibec.ie/ibec/press/presspublicationsdoclib3.nsf/wvPCICCC/2DE72CDC52A50B9780257
1BF0057ADA5?OpenDocument
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43
� Lack of communication between the regions;
� Conflict of interest with respect to local authorities; and
� Inadequate development of infrastructure.
This report builds on an earlier report for Greenstar carried out by Eunomia in 2007 59.
The previous report identified several key institutional issues within the Irish waste
management industry. The following analysis will target each of three issues and
examine both the causes of and potential solutions.
The issues for consideration are:
1) Competition ‘in the Market’, or ‘for the Market’;
2) Governance structures / responsibilities for delivery of national strategy; and
3) The role of local authorities (characterised by some as being regulator and player
in the market).
59 Eunomia, with TOBIN (2007) Waste Policy, Planning and Regulation in Ireland, Final Report for
Greenstar.
International Review of Waste Policy: Annexes

3.0 Competition in the Market for Waste Collection
Some Irish local authorities moved away from providing household waste
management services in the mid 1990’s following the introduction of the Waste
Management Act 1996. The market for waste services then opened for competition
with the local authorities effectively determining who could compete in the collection
market (and through providing which service) through their role in issuing waste
collection permits. The OECD discusses the appropriate approach to competition. 60 It
suggests there are two categories of competition which could be considered in the
context of the Irish market:
44
1) Competition in the market; and
2) Competition for the market.
3.1 Definitions
3.1.1 Competition in the Market
This can be viewed as a standard free market approach to service provision. The ideal
free market approach consists of removing all trade barriers thus letting the market
and competitors within the market adjust to the equilibrium, or most efficient, level of
participation. To develop the aims of central government regarding waste, a certain
level of regulation will exist in the market. Householders choose to contract
individually with a waste collection company (or not, as the case may be).
There has been, in the context of the existing situation in Ireland some discussion as
to the need, or otherwise, for a regulator in the market. 61
3.1.2 Competition for the Market
This relates to competition for a contract to be responsible for waste management for
a specific geographic region. This occurs through periodic tendering processes, in
which companies bid for time-limited monopolies over service provision. Through the
tendering process, costs of the underlying service are revealed. Key to obtaining value
for money is the design of the tendering process itself. There is a considerable body
of literature regarding the economics of contracts, and the likely behaviour of
participants in bidding situations. 62 In practice, there is also a variety of experience
with tendering processes.
60 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13
61 DoEHLG (2006) Regulation of the Waste Management Sector: Consultation Paper,
http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,1446,
en.pdf
62 See, for example, J-J. Lafont (1989) The Economics of Uncertainty and Information, Cambridge: MIT
Press; J-J. Lafont and J. Tirole (1993) A Theory of Incentives in Procurement and Regulation,
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3.2 Issues with Current Situation
In the waste industry competition in the market can provide a benefit to customers
through revealing an efficient price and, where the process is well managed, through
bringing forth a choice of services, some of which might include innovative aspects.
The OECD proposes that for large producers of waste, competition in the market
approach is possible and appropriate. 63 This is particularly true of major commercial
waste producers and producers of industrial waste.
For other producers of (smaller quantities of) waste, however, the issues that can
arise from an ‘in’ the market approach to competition in waste management service
provision are as follows:
45
� The absence of service provision in some areas where the marginal costs of
provision are high relative to the likelihood of gaining full cost recovery. This is
sometimes referred to as ‘cherry picking’ by private companies of customers,
but the reality is more that anything other than ‘cherries’ is avoided
completely; 64
� Lowered level of service quality due to the desire to reduce the costs of service
provision;
� Reduced likelihood of the scope of the service being broadened to include
separate collection of new materials due to the risks inherent in
understanding the likely level of service uptake (and hence, the costs of
provision);
� An increase in illegal activity related to the level of coverage. The counterpart
of the ‘cherry-picking’ issue is that service coverage is less than 100%.
Currently the EPA estimates that service coverage stood at 80% in 2007. 65
One European survey noted: 66
‘when looking at the quantity of MSW that is collected regularly in
different countries, nearly half of the 24 countries that responded on
this issue - Austria, Andorra, Belgium, Germany, Liechtenstein,
Cambridge: MIT Press; Bernard Salanie (1997) The Economics of Contracts: A Primer, Cambridge: MIT
Press.
63 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13
64 ‘Cherry picking’ refers to the selection of the best, or most lucrative, customers or householders. The
consultation on waste carried out by the DoEHLG notes that this is an issue with any utility that
becomes privatised (which is effectively what has occurred in the Irish market). DoEHLG, 2006,
‘Regulation of the Waste Management Sector’, available at:
http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,1446,
en.pdf
65 EPA (2009) National Waste Report 2007, Wexford: EPA.
66 C. Preda (2007) MSW Management in Europe, Waste Management World, July 20007,
http://www.waste-management-world.com/display_article/304406/123/CRTIS/none/none/MSWmanagement-in-Europe/
International Review of Waste Policy: Annexes

46
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Lithuania, Luxembourg, Monaco, Switzerland and the UK - estimate
100% MSW collection rates. The remaining countries, which by and
large are from Eastern and South-eastern Europe, reported collection
grades below 100%.
The Czech Republic, Denmark, Finland and Slovenia report collection
rates of >95%; Azerbaijan, Estonia, Greece, Hungary and Sweden 90-
95%; Bulgaria, Romania and Poland 80-85%; and Ireland 77%. The
reported minimum was 50% for Montenegro.
Where no service exists, or where it is provided, but only at very high cost,
those who are not covered have to make ‘alternative arrangements’ for their
waste. In some cases, this is likely to encourage the management of waste in
ways that are illegal (dumping), or unsociable (burning). 67 At the same time,
because there is no obvious correspondence between the charges at civic
amenity sites and charges requested of households, households could
conceivably deposit waste at civic amenity sites for lower charges;
� Failure to capitalise on economies of density in terms of logistics. The OECD
notes that the scope for competition in the market relies on the economies of
density – the more dense the area the more likely that competition in the
market will be a successful system; 68 and
� Enhanced uncertainty on the part of developers of treatment facilities, as to
whether the facility will be commercially bankable (because of the lack of
security regarding the supply of waste into the facility).
The above issues would tend to arise even where the market is a competitive one.
They may be exacerbated where the market is not competitive because only one
service provider exists, or where one is dominant in a given area. In this context, it is
worth considering the potential of the dominance of a given provider to act as a
barrier to entry to other firms, even in a market where capital requirements for
starting up waste collection enterprises are smaller than in many other industries.
The mere fact that a provider already exists implies that it is in a better position to
benefit from economies of density, with would-be competitors being unlikely to
achieve the same densities as the incumbent provider in the short-term. To attract
customers, therefore, the service provider would most likely have to seek to attract
customers at price levels below the cost of delivery, at least in the short-term. This
issue was raised in the context of a ruling by The Competition Authority: 69
67 It is not clear that backyard burning of waste is against the law. See, for example, Sue Scott and
Dorothy Watson (2006) Introduction of Weight-Based Charges for Domestic Solid Waste Disposal, Final
Report Prepared for the EPA by the Economic and Social Research Institute, (2000-DS-6-M1).
68 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13
69 The Competition Authority (2005) Decision of The Competition Authority (Case COM/108/02)
concerning Alleged Excessive Pricing by Greenstar Holdings in the Provision of Household Waste
Collection Services in Northeast Wicklow, 30 th August 2005, available at:
http://tca.ie/search.aspx?SearchTerm=e/05/002

47
Greenstar claims that when the local authorities first left the waste collection
business, private operators cornered territories and it is now very difficult to
enter another operator’s high density area. Unless a firm goes into its rival’s
high density area very aggressively it is unlikely to succeed. One operator
interviewed confirmed that in order to compete with Greenstar in northeast
Wicklow they would probably have to go in below cost to try and secure a
sufficient customer base. Another operator noted Greenstar’s customer
density as a factor affecting its decision not to enter that market and the fact
that Greenstar has sufficient resources at its disposal to respond to attempts
to compete with it by directing additional resources to the area in question.
Greenstar overcame the difficulties associated with entering other operators’
high density areas in the northeast Wicklow market by entering via acquisition
in 2000 and acquiring the incumbent operators’ existing customer bases.
However, any new entrants in the relevant market will now have to secure a
customer base via the greenfield route, the difficulties with which are
described above.
In addition, the commercial reality of the Irish household waste collection
market is that collectors generally appear unwilling to enter each other’s
areas of operation or to compete head-to-head with each other, although
competition may occur at the boundary between the areas served by each
firm. One operator contacted as part of a previous enquiry by The Competition
Authority claimed that household waste collection has naturally evolved in
such a way that each of the operators tends to have control over certain areas
but that some overlap occurs on the outskirts of their areas of operation. The
Competition Authority’s previous market enquiries have shown that even
where there are three or more private operators servicing a particular county
in the State, this does not automatically imply that these operators compete
head-to-head within that county. Often these firms have control over
household waste collection in a certain part of that county and compete only
on the boundaries of their areas of operation. Even in some boundary areas
where household waste collectors operate side-by-side The Competition
Authority has received complaints regarding a general unwillingness among
collectors to infringe on each other’s territory and a general preference to
focus on retaining their existing customers without trying to expand into their
competitors’ terrain.
While this general business model may help explain the lack of new entry into
the northeast Wicklow household waste collection market since 2000, it is
unlikely in itself to constitute significant evidence of entry barriers as it is more
a choice or preference of the individual firm rather than a rigid structural
feature of the market concerned. It is nonetheless consistent with the finding
that an incumbent firm enjoys substantial cost advantages in terms of its
existing customer density and can consequently react strongly to any new
entry into its high density area. Economies of density would therefore appear
to constitute a significant entry barrier into this market and protect Greenstar
from potential competition in the relevant market.
The DoEHLG consultation on Regulation of the Waste Management Sector noted that
excessive profits may be generated for the supplier in a situation where there is
International Review of Waste Policy: Annexes

competition in the market, as in Ireland. 70 Dunne et al. assert that illegal dumping
has increased in recent years, although it must be noted that the rise could be
attributed to a number of factors including increased reporting of dumping, a rise in
awareness of the legislation, and the linked issue (to the one discussed here) of the
manner of implementation of pay-by-use. 71
Local governments have a legal responsibility to deal with waste arising in their
jurisdictions though the prevailing legislation does not require households to opt into
a service. The OECD notes that when the service is fully privatised (as it is in 67% of
the cases) local authorities do not have recorded evidence of the households who are
part of a waste collection scheme. 72
An additional issue in the Irish context is the application of the proximity principle.
This principle states that the most sustainable way to dispose of waste is using the
facilities closest to the area in which the waste has been generated. This has been
targeted as one of the causes for the lack of development of innovative waste
infrastructure in the country. A recent report for Repak notes that Ireland has suffered
due to the current state of infrastructure. 73 Ireland relies on other countries to
process the waste collected for recycling. The recent fall in prices of material to be
processed has affected the Irish market considerably and led to stockpiling of
recovered material. 74
The consultation paper on waste states that there is a trend toward market
consolidation for the service providers. Vertical and horizontal integration have led to
small firms being bought out by larger competitors. The OECD warns that vertical and
horizontal integration can effect competition and thus should be monitored by
competition authorities. 75 Indeed, experience suggests it is important for tenders to
attract an adequate number of bids in order to ensure bidders offer competitive
prices for the service being tendered.
In short, it is less than clear that competition in the market is leading to the provision
of an economically efficient and environmentally sound waste collection service in
Ireland.
70 DoEHLG (2006) Regulation of the Waste Management Sector: Consultation Paper,
http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,1446,
en.pdf
71 L. Dunne, F. Convery and L. Gallagher (2008) An investigation into waste charges in Ireland, with
emphasis on public acceptability, Waste Management, pp 2826 – 2834.
72 OECD (2008) Ireland: Toward an Integrated Public Service, Paris: OECD, available at:
http://www.oecd.org/document/31/0,3343,en_2649_33735_40529119_1_1_1_1,00.html
73 Bacon and Associates (2008) Examination of Impact of Recent Price Collapse in Markets for
Recyclate Materials and Required Intervention, Report for Repak, available at:
http://www.repak.ie/files/Bacon%20Report%20on%20Waste%20Markets,%20Nov.%202008_1.pdf
74 It is important to understand the degree to which difficulties arising in marketing materials are
related to material quality (and are, therefore, potentially amenable to being addressed by collectors
and sorting facilities, or whether ‘infrastructure’ would help in this respect.
75 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13.
48
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3.3 Market Failure
Currently in Ireland waste management follows a free market structure. Institutional
economists argue that no markets are free and all markets are structured by the
state and other bodies. The institutions form the basis of a market. Institutions in this
sense are rules and norms which form the area in which the actors compete. 76 In
Ireland competition has been left relatively unregulated. However, it is important that
the institutions are designed with careful consideration for the long term aims of
waste management.
Warner, noting that some services should be considered natural monopolies,
identifies waste as one such service. 77 Currently waste policies have not been
developed to treat waste as a natural monopoly. There is a divergence between
individual preferences and public preferences which manifest themselves in low
service coverage, issues of illegal dumping and burning (which the collectors do not
have to consider in their private calculus), and a reduced quality of service at a given
price (reflecting the failure to capitalise on economies of density). Ironically, the
private sector market for the provision of treatment infrastructure is effectively
constrained by its ability to develop bankable propositions in the absence of security
of supply of waste for subsequent treatment.
An issue which has emerged as a result of the set of institutions that are in place is
the prospect of market failure. Market failure indicates that the assumptions made
about the market are incorrect and that one party is being made better off at the
expense of the other party i.e. the market is no longer efficient in the Pareto sense.
Some possible market failures are indicated in Table 3-1.
76 See, for example, Daniel W. Bromley (1989) Economic Interests and Institutions: The Conceptual
Foundations of Public Policy, Oxford: Basil Blackwell.
77 M. Warner (2008) Reversing privatization, rebalancing government reform: Markets, deliberation
and planning, Policy and Society 27, pp 163–174
49
International Review of Waste Policy: Annexes

Table 3-1: Potential Market Failures in Irish Waste Collection Services
50
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Market Market Failure Failure
Relevance Relevance to to Irish Irish Waste Waste Management
Management
Market Power (the ability of an
incumbent to alter the price of a
service)
Network externalities (the use of a
service by a customer changes the
value for other users)
Imperfect Information
Externalities –
Environmental/Consumption/Other
Regulatory Capture (when the
regulatory body operates in favour
of one particular interest group)
Government Failure
The local authorities could potentially exercise
market power in their dual role as regulator and
supplier.
Incumbents may make market entry difficult by
manipulating prices to ensure they maintain a
captive market.
Inefficiencies may occur due to the provision of
services by several operators in one area, and the
varying take-up rates of the services on offer.
Collection services exhibit economies of density
which are denied if multiple operators do compete in
the market
Full information is not available to the consumer
regarding the quality of the waste collection service,
resulting in imperfect information in the market
Prices do not fully reflect the externalities associated
with waste, so prices will not convey appropriate
incentives to consumers.
Local authorities have the power to regulate the
market and may use this power in support of their
own interests.
It could be argued that the local authorities have
failed to adequately account for the needs of service
users.
The Competition Authority also gave a large number of examples where competitive
tendering appeared to generate economic benefits: 78
� Kemper and Quigley (1976) estimates for the U.S. that competitive markets
are 25% to 36% more expensive than a single collector, and that contract or
78 The Competition Authority (2005) Decision of The Competition Authority (Case COM/108/02)
concerning Alleged Excessive Pricing by Greenstar Holdings in the Provision of Household Waste
Collection Services in Northeast Wicklow, 30 th August 2005, available at:
http://tca.ie/search.aspx?SearchTerm=e/05/002

51
franchise agreements reduce the costs over municipal collections by another
13% to 30% (depending on the level of service). They found a loss of density
economies to increase the costs of non-franchised suppliers.
� Having observed data for 340 cities in the U.S., Stevens (1978) found the
allocation of exclusive market areas to private operators (e.g., via bidding
procedures) to be 26% to 48% cheaper than a competitive private market and
27% to 37% cheaper than municipal provision.
� Before the introduction of compulsory competitive tendering in the UK in
1988, Domberger et al. (1986) published a study on the effects of contracting
out household refuse collection in the UK. They concluded cost savings of
22% in those municipalities where there was competitive tendering of
household waste collection services to private operators with no evidence that
this was at the expense of service quality. They also found cost savings of 17%
in those areas where the contract was awarded in-house.
� Szymanski and Wilkins (1993) and Szymanski (1996) have confirmed
Domberger et al.’s results. Szymanksi also found no evidence for the UK to
support the notion that cost savings were attributable to quality reductions.
� Ohlsson (1998) reported comparable efficiency gains for contracting out in
Sweden.
� In Denmark surveys showed that in 1990-1991 those Danish municipalities
that had made use of competitive tendering experienced an average cost
saving of 10%.
� A comparison by Reeves and Barrows (2000) of the costs for certain
contracting local authorities in Ireland before and after they contracted out
refuse collection services indicated average cost savings for those authorities
of 33.5%. A comparison of the average unit cost of contracting authorities
versus authorities still engaged in public provision of the service for the three
years 1993-95 indicated lower costs of around 46% on average for
contracting authorities. Furthermore, it was found that the incidence of
efficiency was much greater amongst authorities that contracted out the
service.
� In a survey on solid waste collection services in Canadian municipalities in
2001, McDavid found that on average public producers have higher costs
than contracted private producers and that municipalities that competitively
bid their solid waste collection contract enjoy significantly lower costs per
household.
� In an analysis of the cost structure of a sample of Italian waste collection
firms, Antonioli and Filippini (2002) found franchised monopoly, rather than
side-by-side competition, to be the most efficient form of production
organization in the household waste collection industry and the only way of
introducing competition into this sector to be via competitive tendering to
assign the provision of the service. They found further that the majority of
household waste collectors were not operating at the optimal scale.
International Review of Waste Policy: Annexes

52
� In 2003 Dijkgraaf and Gradus similarly estimated cost savings of approx. 15-
20% from contracting out refuse collection in the Netherlands. 79
� A survey by the Norwegian Competition Authority suggests that quality was not
significantly affected by competitive tendering in Norway. 39% of the
municipalities surveyed said that quality had increased and 52% said that
quality had stayed the same with competitive tendering. Only 8% of the
municipalities surveyed said that quality had deteriorated.
� A UK study found that in the case where a contract is competitively tendered
to an outside private contractor, three-quarters of the 22% cost savings
identified can be attributed to improvements in technical efficiency (i.e., more
efficient use of workers and capital equipment) rather than lower input prices.
3.4 Other Country Experience of Competition in the Market
In this Section, we briefly review the situation in one other country which has adopted
the approach of competition in the market, and comment more briefly on the
experience of another.
3.4.1 Poland
Poland has a similar waste management system in operation to Ireland. Similar local
governmental systems exist with the addition of a district level (municipality, district
and regional levels). Many services were privatised following the introduction of a
democratic rule in Poland. Householders and business pay a fee to waste operators
for a waste collection / disposal service. Household waste fees are set dependent on
the size of container and the frequency of collection chosen. Each household is
obliged to maintain a contract with a waste operator. However, the low rate of service
coverage shows that this control is lacking and waste producers have opted-out of the
service.
An article published in the European Environmental Press claims that the high
fragmentation of the waste collection market results in very low standards of
service. 80 It has been noted that the economics are unfavourable because of the
collection inefficiencies resulting from different collection companies collect waste
from households on the same street.
Due to the set up of the system, where there is no financing of the waste
management system from central government, means that waste management
cannot be organised as government might wish. Movement up the waste hierarchy,
79 Strictly speaking, this example does not highlight the benefits of competition for, as opposed to
competition in, the market. Rather, it suggests lower cost from a tendered service than one provided by
a local authority beforehand.
80 EEP (2008) Systematic waste management systems lacking in Poland says EU, Published March
14 th 2008, Accessed 13 th October 2008, http://waste.environmentalexpert.com/resultEachPressRelease.aspx?cid=6725&codi=28996&idproducttype=8&level=0
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as set out by the EU is limited in Poland, with 97% of waste landfilled according to the
EEP. 81 This can be attributed to the following factors:
53
� Limited opportunity for separate collection of recoverable materials, potentially
reflecting the combination of an open market for waste collection, and the
absence of policies ‘structuring’ the market;
� A competitive market leading to consumer choice and the option to opt out of
collection altogether. This, in turn, is hampered by:
• Municipalities not having control over waste collectors or disposal;
• Waste collection services only serving a portion of the total population;
• Municipalities not generally able to charge local taxation so there being
no funds available to take up management responsibility for waste;
� Resultant high levels of tipping – often creating habitual tipping points around
municipalities; and
� Low costs of disposal. In particular this diminishes the business case to
commence separate collection.
A regional system with the aim of coordinating all the services in Poland has been
proposed.
3.4.2 Finland
It is interesting to observe what has happened in the case of household waste
collection where ‘competition in the market’ exists. At the time of the OECD study on
this subject, some US and Finnish cities had adopted a system allowing competition
in the market. 82 61 percent of the municipalities in Finland adopted a system where
householders contract with waste collection companies for waste services. However,
Finland does have a maximum price for charging and a stipulation on quality of
service provided.
Following the OECD 2000 report, several local authorities in Finland switched to
competitive tendering to raise rates of coverage. The first reason for this change is
the costs associated with enforcing the requirement on households to purchase
waste collection services. 83 Secondly, studies have shown that prices for waste
collection in Finland seem to be higher for those municipalities which have
competition for the market (i.e. a tendering service). The OECD noted that collection
81 EEP (2008) Systematic waste management systems lacking in Poland says EU, Published March
14 th 2008, Accessed 13 th October 2008, http://waste.environmentalexpert.com/resultEachPressRelease.aspx?cid=6725&codi=28996&idproducttype=8&level=0
82 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13.
83 Typically, where households do not pay for any service, they either ‘free ride’ by using litter services,
or other people’s bins, or CA sites where these are free at the point of use, or they dump, litter or burn
their waste. None of these is desirable, though the different options are undesirable for different
reasons.
International Review of Waste Policy: Annexes

costs were 20-25 percent higher in regions where there was competition in the
market as opposed to competitive tendering. 84
The first reason given above is an important one. In principle, competition in the
market could be ‘made to work’. However, it seems likely to us that the scope of the
regulations and institutions which would be required to achieve this would be so
complex as to make such an outcome both difficult and costly to achieve.
3.5 Competition for the Market
The Competition Authority notes that if a competitive tendering process were applied
to the Irish market it would ‘work better’ for consumers. 85 It suggested that if a
tendering process for waste contracts were used, a number of the problems
associated with competition in the market could be avoided:
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on the basis of The Competition Authority’s extensive enquiries into household
waste collection, it appears that the market for household waste collection is
not working well for consumers. One solution - even if it could be
demonstrated that Greenstar charged excessive prices – would be price
regulation. Neither The Competition Authority nor the courts are equipped for
such regulation. Furthermore, a waste regulator would also face a very difficult
if not impossible task of setting prices, either on a State-wide or regional
basis, since it is unlikely to have the information to set the competitive price.
Costs and market conditions vary widely across the State.
In The Competition Authority’s view there are better alternatives than a
regulator to set prices for household waste collection. In the countries
reviewed the predominant form of service provision in household waste
collection is via competitive tendering. This international experience
demonstrates that competitive tendering is the best method of ensuring that
household waste collection providers deliver consumers good service at
competitive prices. This system of competition for for the market should replace
the existing model of competition within the market, i.e., where waste
providers compete side-by-side with each other.
Competition for the market would be set up to control the natural monopoly that is
municipal waste collection. For the process to be efficient, as many service providers
as possible should be competing for the tender (which would be offered on a regular
basis). If local government were to be one of the bodies putting themselves forward to
tender the concern about the dual role of the local authority would be addressed
while simultaneously ensuring the maximum number of competitors for the market.
84 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13.
85 The Competition Authority (2005) Decision of The Competition Authority (Case COM/108/02)
concerning Alleged Excessive Pricing by Greenstar Holdings in the Provision of Household Waste
Collection Services in Northeast Wicklow, 30 th August 2005, available at:
http://tca.ie/search.aspx?SearchTerm=e/05/002

The beneficial network effects, or economies of density, should be enhanced in a
competitive tendering environment. The instances of cherry picking of customers
should disappear also.
55
� There is a relatively limited level of sunk investment in the case of waste
collection. There are no long-lived assets in waste collection and there are well
developed second-hand / lease markets for the only assets of any importance
(the vehicles). Probably the major investment in fixed assets relates to depots.
There may be some investment by a firm in good customer relations, but to an
extent this can be contractually verified;
� Waste collection is a sufficiently homogeneous service that potential bidders
could, in principle, gain a good understanding of the costs involved in waste
collection by direct experience in other city markets. The incumbent’s
information advantage is therefore likely to be weak; 86
� In the case of waste collection the basic service quality parameters (frequency
of collection, services provided, levels of customer complaints) can be
sufficiently well specified to allow effective quality regulation.
Other authors have also pointed out that the cost of service disruption is
comparatively low. 87
The OECD provides a survey of studies that attempt to measure the efficiency gains
from competitive tendering. Generally, these studies suggest that tendering leads to
significant efficiency gains without convincing evidence that this leads generally to
lower quality of service. According to the OECD, in the tendering process, attention
should be paid to: 88
1. The geographic region over which collection services are to be provided should
be large enough to allow successful firms to exploit economies of scale and
density;
2. Where the size of the city or district is much larger than the minimum efficient
scale of collection, the OECD suggests breaking up the region into several
smaller pieces and tendering each piece separately. This allows for
performance comparisons between the firms serving the different regions,
reduces the disruption associated with loss of service from a single firm and
enhances the likelihood that several firms will be in a position to compete
when the time comes for re-tendering;
86 It should be stated that this does not necessarily mean that incumbents do not have an advantage
in other strategically important ways (for example, location of depots, or ownership of local sorting
facilities, or local landfill void, etc. However, the procurement process itself can, when sufficient care is
taken, be designed to negate these advantages.
87 M. Walls (2003) How Local Governments Structure Contract with Private Firms: Economic Theory
and Evidence on Solid Waste and Recycling Contracts, Resources for the Future Discussion Paper 03-
62.
88 OECD (2000) Competition in Local Services: Solid Waste Management, DAFFE/CLP(2000)13.
International Review of Waste Policy: Annexes

56
3. Successful collusion in the tendering process requires the ability to detect and
punish deviations from the cartel agreement. Therefore, the OECD argues that,
from the competition perspective, it is preferable to use sealed bid auctions,
without disclosing the results. 89 According to the OECD, concerns about
political favouritism could be met by the establishment of an independent
agency with responsibility for overseeing all public tenders and with access to
all of the bids.
4. If competition in disposal facilities is limited or non-existent, firms which do not
own disposal facilities will be at a competitive disadvantage in the tendering
process for waste collection. In these cases, the OECD argues that potential
collection firms should be guaranteed access to disposal facilities on nondiscriminatory
grounds. An alternative and, according to the OECD, preferable
solution is to separate ownership of disposal and collection facilities and/or to
prevent owners of disposal facilities from participating in tenders for
collection; 90
5. In many cases, a division or subsidiary of the local government itself is in a
position to provide the services, which are being purchased by tender.
Competitive neutrality is ensured when public and private sector suppliers face
identical regulatory, legal, financial and administrative arrangements. 91
An interesting point is that much of the discussion in the literature relates largely to
household waste collections. Yet the same is almost certainly true for waste collection
from commercial premises. The question, therefore, is why this same logic should not
be extended to commercial waste collections? We are not aware of the same level of
interest in this area since much interest in the contracting out of waste collection
services relates to an interest in privatisation of public services. To the extent that
collection of commercial waste is not a public service as such, the same interest does
not appear to be present among researchers. Even so, the logic for similar, albeit
appropriately adapted, approaches seems to be compelling.
89 Evidently, this is a strange recommendation as ultimately, the result is easily knowable.
90 The alternative – clearly favoured increasingly in the context of English procurements for municipal
waste – is to ‘unbundle’ services and procure different service elements through discrete tendering
processes (most notably, separating collection from contracts for residual waste treatment / disposal).
This reflects a concern to enhance competition in the market, recognising that integrated contracts
tend to favour larger players in the marketplace, with the specialised services which smaller
companies might be able to offer in collection being potentially overlooked. In short, the approach is
more likely to deliver better value for money (see, for example, OGC (2006) Improving Competition and
Capacity Planning in the Municipal Waste Market, OGC Kelly Report to the Financial Secretary to the
Treasury, May 2006
http://www.ogc.gov.uk/documents/OGC_Kelly_Report_to_the_Financial_Secretary_to_the_Treasury_-
_May_2006(1).pdf )
91 This point – the desirability of enabling public and private sector companies to compete in the
market - is a theme of the work of Dijkgraaf and Gradus (see, for example, E. Dijkgraaf and R. H. J. M.
Gradus (2005) Collusion in the Dutch Waste Collection Market, 31 January 2005).
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3.6 Recommendations
What is often described as ‘competition for the market’ has the potential to address
several of the issues that appear to be problematic in the waste collection market,
and which result from competition in the market. The most fundamental change is to
place the responsibility for household collection firmly in the hands of local
authorities, with the authorities being responsible for tendering the service out to
private operators should they wish to do so. This has the potential to:
57
• Enable collectors to benefit from economies of density, so reducing the cost of
service delivery to the users;
• As a result, increase the take-up of services across a given geographical area;
• Enable the quality and scope of the collection service to be specified through
the tendering mechanism;
• Squeeze out monopoly rents where service operators are operating as a local
monopoly; and
• Enable a stronger link to be made between the collection and treatment of
waste, improving the prospects for development of the desired infrastructure.
In short, it should allow for similar or greater environmental quality to be attained at
lower cost (or alternatively, greater environmental benefits will be generated at the
same cost). Some key questions still remain, however.
3.6.1 Should Local Authorities be Able to Provide the Household Collection
Service?
The above discussion has presented two main options:
1. Competition in the market, where no one body has ‘control’ over household
waste, and private and public operators may compete for custom on a day-today
basis; and
2. Competition for the market, where a body which has control for household
waste – the local authority - tenders out that service.
The second approach presumes that the body with control over household waste
does, indeed, tender the service out. In reality, a third option exists in which the
density of logistics is ensured, and the coherence of service provision is made more
likely, but where the local authority itself operates the waste collection service.
In Ireland, it seems unlikely that many local authorities would wish to re-enter a
market they have already vacated. In many authorities, therefore, it might be
expected that the natural approach would be to tender the service out to a private
operator.
In some local authority areas, however, the authorities retain a strong presence as
the direct provider of services. In this context, local authorities could not be forced to
tender the service out to private contractors (for legal reasons). They could, indeed,
choose to operate the service themselves. However, they should be strongly
encouraged to market-test their service in order, periodically, to demonstrate that
their in-house offering represents value for money to residents.
International Review of Waste Policy: Annexes

In these situations, it would be appropriate to have in place benchmarking
mechanisms for the costs of collection services so as to assess the costs and quality
of service of the different operators. We strongly recommend that the benchmarking
data are made a reporting requirement for local authorities. There is a dearth of
quality information on collection costs in Ireland, and this type of reporting
requirement would do much to fill the existing void.
3.6.2 How Will Costs be Recovered?
It is important to note that, as far as household waste is concerned, in most EU
Member States (and several other countries besides), households pay for the waste
management services through a combination of:
58
• Central government taxation;
• Local government taxation; and
• A variable ‘user pays’ element.
In Ireland, the middle of these three tiers is absent.
The attraction of the three tiered approach is that with the exception of the user pays
element, the costs of the service are met by payments which householders are
required to make. Given that, in such countries, the variable element either does not
exist, or constitutes (on average) something of the order 30-50% of the cost of the
service, then there is relatively little incentive for households not to use the service. 92
The question arises as to how, with a tendering approach in place, the costs of the
service would be met by the users? If the costs were to be met through payments by
households, might it not be the case that the costs would still be deemed too high for
some customers to consider availing themselves of the service on offer?
This is an important problem to resolve. Ireland has no local taxes. We would suggest
that:
1. In the absence of such taxes, it would be preferable for a significant proportion
of the costs of service provision to be met through central government
taxation. Local authorities would be paid an amount based upon a formula
92 There is a fundamental misunderstanding of some of basic concepts of how waste services are
financed, and of operational issues, in the OECD’s discussion of cost recovery in the waste sector (see
OECD (2008) Ireland: Toward an Integrated Public Service, Paris: OECD, available at:
http://www.oecd.org/document/31/0,3343,en_2649_33735_40529119_1_1_1_1,00.html). The
OECD praises the Irish model for the extent of ‘cost recovery’, conveniently overlooking that costs are
recovered in all municipal waste collection systems, but rarely with high proportions of that cost being
recovered through variable charges. The OECD also fails to draw the link between the high level of ‘cost
recovery’ and the low level of service take-up. The two are (obviously) linked as the price of the service
at the point of delivery affects demand for it. Particularly in the Irish situation, and in advance of any
measure to require householders to make use of a service, the situation least likely to engender
service take up is the one the OECD seems to be promoting. Furthermore, under pay by use systems,
for reasons associated with revenue stability (the need to ensure the costs of the service are covered)
applying high variable rates is apt to cause problems in terms of early implementation of pay-by-use.
This problem is widely discussed in the literature regarding pay-by-use (see Appendix 8.0).
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59
which was designed to reflect a defined proportion – of the order 50% - of the
total costs of service provision;
2. In the absence of funds coming from either central or local taxation, it
becomes important to have in place some counterpart law which requires
households to avail themselves of the collection service provided. In essence,
this mimics the Danish approach, in which households are required to pay,
first and foremost, for waste collection services. In the absence of such a
measure, which is probably necessary under 1, above, also, tenderers could
not be sure that households would take-up the service they were offering (so
that tenders would include an upward adjustment to account for the risk of
non-use by residents); and
3. In either case, and so as to reduce the costs of waste management at the
point of delivery, the costs of operating separate collection schemes and for
recycling material should be met, as far as possible, in their entirety by
obligated producers. In addition, recognising that there remain pecuniary
externalities upon collectors related to the unrecycled proportion of the waste
targeted under producer responsibility, and recognising also the desirability of
recycling, the targets for recycling of the targeted materials should be suitably
ambitious, and there should be sanctions applied in the event of failure to
meet these targets. The European Commission’s proposal for a revised
Directive on Waste Electrical and Electronic Equipment suggests that where
appropriate, Member States should encourage producers to finance all the
cost occurring for collection facilities for WEEE from private households. This is
in line with the polluter pays principle. The implication of this proposal is that
a) producer responsibility measures need to be re-visited to ensure that all
relevant costs fall fully upon producers; and b) the targets which producers are
required to meet are suitably ambitious.
Either 2) or more palatably, a combination of 2) and one, or both, of 1) and 3), would
be necessary to ensure that households do not simply opt out of the service, with
potentially detrimental impacts for the value for money gained from tenders for
service provision. It should be noted that both of these approaches also enhance the
prospects for setting a more uniform charging structure for household service
provision at an average level. By this, we do not mean setting one type of charging
system, rather that the charges should follow a specific structure to maintain revenue
stability.
3.6.3 Treatment Facilities
Whatever body takes charge for tendering collection, that body effectively has the
ability to control the waste once it has been collected (for example, it can specify the
delivery of different wastes to specified destinations). This makes it possible for the
body controlling that waste to tender for treatments appropriate to the way in which
the material is collected. This would give security of supply of the material to suppliers
of treatment capacity.
In the majority of jurisdictions outside Ireland, the developer of a given waste
treatment facility for dealing with household waste (municipal waste is more broadly
defined in Ireland than in other EU Member States) is typically given a high level of
International Review of Waste Policy: Annexes

certainty in respect of waste being delivered to the facility, not necessarily with
guaranteed minimum tonnages, and not necessarily guaranteed for excessively
lengthy periods. However, the nature of such contracts, and the payment
mechanisms included within them, is usually such as to reduce the risk associated
with the development to a significant degree.
Much depends upon the procurement route chosen, but the reduction in risk to which
the developer is exposed serves two important purposes:
60
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a) it makes the development less risky from the financial point of view,
increasing the likelihood that the development does, indeed, go ahead;
and
b) if it does receive the necessary financial backing, it is likely, other
things being equal, to reduce the cost of the facility to the procuring
party. Having said this, the costs will be significantly affected by the
approach to procurement used.
In the current context, for Ireland, these considerations are of some significance. The
context is one where there is an urgent need to develop facilities.
If bidders are asked to tender for facilities with no substantive guarantee attaching to
the supply of waste into the facility, effectively, they are being asked to absorb the
risk related to the supply of waste into the facility. It is not clear what the role of a
tendering process is in this context, since the development shades into being a
merchant investment, where the developer simply introduces a facility into a
competitive market place.
Competition for the market would enable greater certainty to be given to developers,
in the context of managed procurements, as to the supply of material into a given
facility. This ought to rationalise the development of facilities, and make tenders
attractive to a range of bidders, not least those who see less merit in taking
significant commercial risks in developing facilities. This is likely to be of particular
significance at the current time with access to credit severely constrained, and those
offering credit seeking to de-risk their investments as far as possible. Ongoing UK
experience with public private partnership (PPP) projects provides some sobering
experience in this regard. 93
3.6.4 Managing the Transition
The issue of who has what right to control the flow of which wastes into what facilities
is a matter of legal disputes at present. However, more broadly, the issues currently
giving rise to considerable disquiet, angst and no little uncertainty appear to focus
upon (based on our discussions with various bodies):
93 See, for example, The Observer (2009) Treasury Set to Bail Out Second Recession-hit PFI, 10 May
2009, http://www.guardian.co.uk/business/2009/may/10/pfi-vt-bail-out-treasury and letsrecycle.com
(2009) Delight at greater Manchester PFI deal Close,
http://www.letsrecycle.com/do/ecco.py/view_item?listid=38&listcatid=218&listitemid=51746 .

61
1. Whether the private sector has the right to compete for the provision of
services to households;
2. Whether a local authority can direct waste which it does not itself collect into
specific facilities, specifically, in the case of Dublin, whether collection permits
could be specified such that this could occur;
3. If the answer to 2) is ‘yes’, then under what circumstances could such
direction into a facility whose position is in the lower tiers (recovery / disposal)
of the waste hierarchy be said to compromise the movement of waste up the
hierarchy.
In addition, in respect of 2), we find it difficult to see how a local authority could avoid
the charge that it was:
1. Supporting the establishment of a monopoly on the part of the facility in
question;
2. Thereby, effectively opening up waste collectors to discriminatory pricing on
the part of the operator; as well as
3. Through affecting journey times to and from facilities, significantly affecting
the costs of waste management on the part of both the providers and the
users of the waste management service being provided.
These matters are, in the existing legal framework, for the courts, and for the
Competition Authority to decide upon. Their determinations will affect how one
construes ‘the baseline’ from which it is intended that the situation should change.
Our remit has been to propose policies which we believe would further the cause of
Irish waste management in terms, broadly speaking, of its overall performance in cost
and environmental terms. Irrespective of the interpretation of existing law, therefore,
we believe the recommendations to be the right ones for Ireland.
However, there will be transition costs, and these will be affected by the decisions of
the courts (which will influence, for example, whether the actions of private actors in
providing household waste collection services should be considered as a ‘public
undertaking’, and hence, how any transition to a situation where local authorities
have exclusive control over waste management might occur). Providing adequate
time for the current incumbents to react and determining the appropriate
geographical regions of tender also requires attention. Also, seeking to ensure
‘competitive neutrality’, which is to say, seeking to ensure that advantages which a
given bidder might possess are neutralised as far as possible, is an important step in
implementing a system of competitive tendering.
We take the view that if the proposed changes are announced some time in advance
of when they are due to take effect, then this should allow for adjustment in the
existing market to take place in anticipation of the proposed change. Equally, the lead
time should not be excessive. The following issues are of relevance:
1. Some local authorities may wish to develop single-client structures such that
they let tenders jointly for collection services. We would encourage local
authorities to consider the options without necessarily confining themselves to
partners within the existing waste management planning regions;
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62
2. To have all local authorities tendering at once would be undesirable from the
perspective of bidders, and would likely lead to a lack of competition for some
tenders. Some phasing of tenders is likely to be necessary, and this is likely to
require some co-ordination;
3. There is likely to be a compelling need for upskilling of local authority staff in
respect of the management of procurements for collection services. Some
central support for the local authorities may well be warranted, with expertise
made available to ensure procurement strategies maximise the likelihood that
quality services will be delivered at an efficient price;
4. The lead time of the principle assets in respect of collection are vehicles with a
life-time of seven years or so. This sets an outer limit for the period of
adjustment;
5. The longer is the period of adjustment allowed, the less likely are problems to
arise in respect of complaints regarding stranded assets on the part of
unsuccessful bidders. Presumably, participants in the existing market are, in
any case, aware that in principle, unless they are already beneficiaries of
existing tender processes, they could lose market share to competitors.
Elsewhere, we have proposed a National Board for the oversight of an Irish Waste
Management Plan. It is suggested that an early task of this Board would be to
consider the outcome of the legal cases pending and then to make recommendations
for the transition from the existing situation to one in which local authorities control,
even where they do not operate (i.e. through tendering out the service), household
waste collection.
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4.0 The Role of Local Authorities
4.1 Functions as Regulator and Service Provider
In Ireland, local authorities have two functions in the waste management sector. They
are responsible for both providing waste collection and disposal services, and playing
a role in the way in which these markets are structured and regulated. Often the
provision of waste management services is contracted out to private firms; the
alternative is the local authority providing this service.
Regulatory responsibilities include:
63
� Issuing waste collection permits, and setting the terms of these;
� Developing bylaws influencing, for example, the way waste materials are
presented;
� Responsibility for waste planning issues (insofar as these are not major
projects – see below);
� Determining applications for, and issuing, waste facility permits;
� Controlling illegal dumping;
� Monitoring compliance with regulations implementing producer responsibility
with respect to packaging;
� Monitoring waste disposal;
� Collecting and providing data; and
� Devising regional waste management plans (RWMPs).
In terms of operations, local authorities:
� Can engage directly in waste collection activity;
� Are involved in the operation of civic amenity sites;
� May be involved in street cleaning and clean-up of fly-tips; and
� Are likely to submit planning applications for landfills and other waste
management facilities in their own right with a view to operating them.
The task of regulating the market when combined with a business interest in the
same market can lead to a conflict of interest. For example, if local authorities are
operating a waste treatment operation, they may have a commercial to influence
other collectors such that they deliver the collected waste to their own facility.
Much of the literature in respect of environmental regulation highlights problems
associated with the issue of ‘regulatory capture’. In the case of local authorities in the
current context, it is clear that the possibility exists for such capture to be
International Review of Waste Policy: Annexes

institutionalised unless matters are handled with considerable sensitivity, and unless
appropriate constraints are in place. This has been recognised by DoEHLG in its
Consultation Paper on the Regulation of the Waste Sector: 94
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‘The private waste sector has highlighted the following main areas of concern
to the industry:
(a) Unlike their private sector counterparts, local authorities are not
required to obtain collection permits in order to engage in the
commercial collection of waste.
(b) Local authorities are required to undergo a less onerous
registration process for certain waste activities, whereas their
private sector counterparts are required to obtain waste permits
for the same activities. Permitting is also more costly for the
private sector.
(c) The planning system operates differently for private sector and
public sector projects. It takes longer to obtain planning
permission for private sector projects than it does to obtain
permission for local authority projects. In addition, while local
authorities can obtain registration for their projects within a
short timescale, the permitting of private sector projects can be
subject to delays. Disparities in planning and permitting
timescales may give local authorities an advantage over private
waste companies in setting up their own waste facilities. The
Strategic Infrastructure Bill seeks to address this issue.
(d) The Environment Fund comprises monies raised through both
the plastic bag levy and the landfill levy. The landfill levy is
charged at €15 per tonne based on every tonne of waste which
goes to landfill. Local authority waste infrastructure projects are
part funded by the Environment Fund, however no funding is
available for private sector waste projects despite the
contribution that private sector waste companies make towards
the landfill levy and ultimately the Environment Fund.
(e) Local authorities and the private sector are both competing in
the same market therefore it would be expected that they would
operate under the same market conditions.’
In addition, local authorities do not have to charge value-added tax (VAT) on the
provision of waste services whereas private companies are required to do so. The
OECD notes that local authorities have also been allowed to build landfill above the
capacity set out in the regional waste management plans. It does, however, also note
94 DoEHLG (2006) Regulation of the Waste Management Sector: Consultation Paper,
http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,1446,
en.pdf

that there have been no significant and conclusively demonstrated examples of a
local authority using these powers to benefit their waste collection services.
These issues appear to have the potential to distort competition. The Indecon Report,
for example, noted that the lack of full cost recovery on the part of local authorities
was likely to affect competition, not to mention, require additional revenue sources to
support the services provided. 95 Allegations that additional time and cost are spent in
the planning process, and that the difference in processes which the private sector
and local authorities are required to go through to obtain permits impose additional
administrative burdens on industry relative to local authorities, might not always be
straightforward to substantiate conclusively, but nor are they so straightforward to
dismiss out of hand.
Finally, if it is the intention of the Government to engender genuine competition in the
market, then save for support for matters such as dealing with legacy issues (where
the past pattern of ownership of landfills might implicitly bias funding in favour of
local authorities), then the differing terms of access to the Environmental Fund also
appear to have the potential to distort competition.
Local authorities have traditionally occupied a strategic position in waste
management. They have, historically, owned and operated landfills, and have been
the main collectors of household waste. In the period following the Waste
Management Act, one might reasonably assume that as costs increased, so local
authorities, as landfill operators, may have sought to benefit from the scarcity of void
space in the country. This could have allowed landfill prices to be raised above levels
which might have prevailed in a more competitive market. In addition, where the
same local authority both operated the household collection service and operated the
landfill, there would have been scope for differential pricing in which commercial
collectors making use of the site were effectively cross-subsidising the costs of
landfilling household waste.
Furthermore, local authorities will also have had the power to engineer continuing
scarcity of void space provision, so prolonging their somewhat privileged position. The
potential for abuse of what is, effectively, market power appears to have been
recognised in an ESRI report: 96
65
‘Where Local Authorities continue to be the only supplier of services in an
area, there is a requirement to ensure that pricing reflects efficient levels of
operation. Currently, Local Authorities act as suppliers, planning authorities
and environmental regulators in the waste management industry. This means
they are potentially conflicted in dealings with private operators, which could
distort competition. With each Local Authority acting as regulator, there is
95 Indecon International in association with the Institute of Local Government Studies at University of
Birmingham (2006) Indecon Review of Local Government Financing, Report Commissioned by the
Minister for the Environment, Heritage and Local Government.
96 John FitzGerald and Edgar Morgenroth (2006) Ex-Ante Evaluation of the Investment Priorities for the
National Development Plan 2007-2013, ESRI Report Commissioned by Department of Finance,
October 2006.
International Review of Waste Policy: Annexes

66
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scope for inconsistency geographically and temporally. A single regulatory
structure applicable throughout the State would help encourage private
participation in the market.’
Whether such abuses actually occurred, or whether they did not, might be considered
idle speculation. What may be at issue is that the existing system allows for the
perception of abuses and grievances to persist. The question then becomes one of
whether these are sufficiently of concern to require change, and if so, what these
changes should be.
Eunomia noted, in previous work, that the varied roles of local authorities may have
served to keep landfill gate fees high in the past. 97 When local authorities were the
major operators of landfills, and where they required additional revenue to support
their activities (especially following the eradication of rates), then it would have been
useful to raise gate fees as a means of raising revenue for other services. Now, as
more void space is consented, and as regional monopolies are weakened with the
emergence of the private sector in landfilling, so gate fees appear to be falling. The
arrival of the private sector in landfill operation might, therefore, have led to falling
landfill gate fees, with the indirect effect of possibly giving rise to budgetary problems
in other aspects of local government.
This view is echoed in a Forfás report, which notes that landfill gate fees in Ireland the
third highest of the eleven countries used in their analysis – that is after a drop from
€135 in 2006 to €127 in 2007. 98 The current situation where the local authority has
the power to regulate and participate in the market has caused inefficiencies. The
OECD notes that private operators claim that when local authorities were the sole
operators of landfills gate fees were used as a source of revenue. Following the
introduction of a higher number of private landfill operators gate fees have fallen. 99
It should be noted that the degree to which the local authorities’ role allows them to
distort the market ‘in their favour’ is not entirely a ‘one-way’ consideration. The fact
remains that local authorities have additional responsibilities in the operational
sense, over and above the collection of waste, and the management of that collected
waste, which are do not pre-occupy the private sector providers. These include cleanup
of old landfills, operation of CA sites (and bring sites), provision of information /
education and provision of street cleaning services, whilst local authorities may also
operate waiver schemes for low-income households.
97 Eunomia, with TOBIN (2007) Waste Policy, Planning and Regulation in Ireland, Final Report for
Greenstar.
98 Forfás (2008) Waste Management Benchmarking Analysis and Policy Priorities, available at:
http://www.forfas.ie/media/forfas080528_waste_benchmarking.pdf. The point made by Forfas is fine
insofar as it goes, but the reality is that of the ten countries and regions chosen, 6 (Massachusetts,
Flanders, Austria, Netherlands, Sweden and Denmark) had implemented landfill bans of varying
breadth. Consequently, for many wastes, the costs of landfilling are effectively infinite unless some
form of exemption can be found.
99 OECD (2008) Ireland: Toward an Integrated Public Service, Paris: OECD, available at:
http://www.oecd.org/document/31/0,3343,en_2649_33735_40529119_1_1_1_1,00.html

Local authorities have no obvious mechanism – other than charges to households,
and on landfilled waste - through which to recover costs of other services which
private sector operators do not need to offer, especially in respect of the more ‘public
good’ elements of the waste management service (such as street cleaning, controlling
illegal dumping, etc.). It is not clear that receipts from the Environmental Fund would
cover all these costs, so that authorities may be competing in the waste collection
market from a position where they are seeking to recover costs, through their
charges, which their competitors do not have to bear.
Indeed, we may now be entering a period where, instead of landfill gate fees
supporting the revenues required to operate waste services, the pendulum is
swinging the other way, and local authorities would be required to raise revenues over
and above the cost of provision of collection and treatment services in order to run
other aspects of the waste management service, as well as to support clean-up of old
landfills. 100 In such a situation, private sector operators would be able to operate
profitably in the collection market even with lower economies of density in collection.
The perception of conflict clearly persists, and whilst instances of abuse of power
might be considered, by many, to be largely anecdotal, such abuses could not be
completely ruled out. The local authority clearly retains advantages by not being
required to obtain permits or charge VAT.
It is worth noting, in passing, that giving local authorities responsibility for the
household waste collection service, and allowing them to tender out the service,
would effectively make any perceived inequality, to the extent it exists, less relevant
for the simple reason that there would be one provider of the household collection
service in a given area.
4.2 Moving Forward
The aims of local authorities and the central government with respect to waste
management are as follows:
67
� Prevention;
� Reduction;
� Recycling;
� Sustainable disposal of other waste;
� Integrated waste management approach; and
� A more effective and equitable system of waste charging. 101
100 See, for example, CCMA (2007) The Local Authority Perspective on the Realities of Irish Waste
Management, a Position Paper Presented by the City and County Managers’ Association, 23 rd April
2007.
101 EPA (1998) A Policy Statement: Waste Management – Changing Our Ways available at:
http://www.epa.ie/downloads/pubs/waste/plans/epa_changing_our_ways_1998.pdf
International Review of Waste Policy: Annexes

It is widely suggested that the existing structure of responsibilities is not tenable.
Such tensions as already exist could be heightened as waste management in Ireland
moves into a phase in which major items of infrastructure will have to be developed.
In such a situation, the potential for local authorities to exert their influence over the
structure of the market to achieve market dominance could give rise to
understandable concerns.
One could start from the perspective that in order to eliminate the perception, and the
possible reality of, a conflict of interest, two extreme possibilities exist:
68
� The local authority withdraws completely from service provision; and
� The local authority withdraws completely from any regulatory role.
Between these two extremes, clearly, there are many possibilities for some ‘middle
ground’ to emerge. Such a middle ground would, of course, need to be considered
very carefully to ensure that the respective roles did not engender potential for a
continuation of real, or perceived, conflicts. The extremes serve, however, to highlight
some of the key issues.
At present the EPA is responsible for proactive waste management which includes
providing information on waste prevention and implementing regulations e.g. the
Waste Electrical and Electronics Equipment Directive. Other duties include drafting a
hazardous waste management plan. 102
The EPA could, in principle, replace the local authority as a regulator by assuming the
regulatory roles of the local authority. This might make for more even application of
the regulatory apparatus, and ought to ensure that local authorities and the private
sector are dealt with in a more even-handed basis.
Taking the regulatory role away from the local authorities would enable centralisation
of the regulatory functions and level the playing field across actors in the sector. It
would also enable local authorities to maintain, should they be sufficiently
competitive, a presence as service providers within the sector. This may be desirable
in Ireland as a means to maintain greater competition in the market, especially if
recommendations made above – to introduce competition for, rather than in, the
market – are implemented, since in this context, it is important to attract sufficient
numbers of bidders for a given tender.
On the other hand, if local authorities were removed from operations completely, one
could argue that they could concentrate upon the regulatory function more effectively.
It is not clear, however, that this balance – involvement in regulation, but no
involvement in service delivery – sits easily with local authorities. Indeed, to the
extent that local authorities are obvious bodies to take over responsibility for
household waste collection in a situation where competition ‘for the market’ is
102 EPA, 2007, National Waste Prevention Programme: Annual Report, available at:
http://www.epa.ie/downloads/pubs/waste/prevention/final%204th%20nwpp%20annual%20report%2
0to%20minister%20july%202008%2022.pdf
29/09/09

introduced (and under which, they would manage tendering processes), then it might
not make sense for them to be regulating at the same time.
Probably a more nuanced view of the situation is required in which the regulatory
functions are reconsidered in the context of the revised market structures being
recommended (in respect of competition for the market).
Bacon Associates, in its report for Repak, has recommended that the EPA takes over
the role of monitoring compliance with the packaging regulations from the local
authorities. 103 The role of local authorities in respect of implementing / enforcing
producer responsibility does vary across the producer responsibility streams, and the
manner of this variation does not follow an obvious logic.
4.3 Recommendations
The OECD notes that there is a lack of regulatory coherence in Ireland. Infrastructure
investment on a private level will not, it suggests, advance at the desired pace until
clarity is achieved as to the future of waste management regulation in Ireland.
However, it offers no obvious solution to the problems, specifying what Ireland might
aim for in rather broad terms: 104
69
To establish well-functioning waste management, Ireland should implement a
system that entails: 1) a regulatory regime that eliminates conflict of interest;
2) lower market entry barriers by reducing lengthy procedures; 3) contractual
arrangements that oblige service deliverers, whether public or private, to
deliver on sustainable development objectives such as broader environmental
goals and universal service; 4) a financing system that removes hidden
subsidies and allows all service providers to bear the actual cost of service
delivery in their fee structure (including recycling costs), in accordance with
the polluter-pays-principle; and 5) planning and co-ordination arrangements
that allow rational infrastructure use and investment.
No one could disagree with, for example, the desirability of a regulatory regime that
eliminates conflict of interest (if indeed the conflict is more than merely perceived,
which the OECD implicitly – in making this recommendation - suggests that it is), or of
implementing contractual arrangements which aspire to universal service and
broader environmental goals. The question is, rather, how to achieve that.
Our view is that at least some of the regulatory tensions stem from the public sector
becoming increasingly involved in shaping developments in the markets for
commercial and industrial waste, and the private sector becoming increasingly
involved in household waste even where (some) local authorities feel they have no
right to be involved due to their being the incumbent provider. The ongoing legal
103 Peter Bacon and Associates (2008) Examination of Impact of Recent Price Collapse in Markets for
Recyclate Materials and Required Intervention, Report for Repak, available at:
http://www.repak.ie/files/Bacon%20Report%20on%20Waste%20Markets,%20Nov.%202008_1.pdf
104 OECD (2008) Ireland: Toward an Integrated Public Service, Paris: OECD, available at:
http://www.oecd.org/document/31/0,3343,en_2649_33735_40529119_1_1_1_1,00.html
International Review of Waste Policy: Annexes

disputes (and the time taken to resolve them) highlight the fact that the law is
insufficiently clear.
In this context, we suggest that there is a need to strengthen the demarcation of local
authority roles in respect of different waste streams. One possible reason that
tensions arise in the collection market is that no one seems entirely sure (until the
courts decide) who has the right to compete in which market. In addition, the local
authorities’ power to direct waste appears to be being used to direct commercial
waste collected by commercial collectors into facilities in which the local authorities
may have a significant commercial interest. We suggest that the market needs to be
clearly delineated as follows:
70
1. Local authorities will become responsible for (directly, or through tendering)
household waste collection. They will also have responsibility for, and would
choose whether to procure facilities, or capacity at existing facilities, for the
treatment and disposal of the waste so collected. In other words, they would
be expected to direct household waste to specific facilities. The issue
regarding waivers for low-income households would effectively become one for
local authorities to address in the context of their role in organising service
delivery;
2. A very different situation would prevail in respect of commercial waste
collection. The local authority would have no powers of direction over this
waste. A collection market would remain for commercial and industrial waste.
The market, suitably configured (with a residual waste levy in place, alongside
the EPA’s Guidance on Pre-treatment, and requirements to sort waste on the
part of businesses) would be left to determine how this waste was treated. The
market would also be expected to provide the relevant treatment and disposal
infrastructure for the collected material.
At least two areas escape this seemingly neat division:
29/09/09
a) Both local authorities and the private sector operate landfills. The two
compete, and would do so for both household and commercial waste.
They will continue to do so in future, so the issue – real or perceived –
of how facilities are consented retains significance;
b) Both local authorities and the private sector collect commercial waste.
The two would, where the local authority was active in collection,
compete in this market. There are, in this case, some issues worthy of
consideration. The OECD notes: 105
Local authorities are not subject to value-added tax (VAT) for
their waste management services as in the case for the private
sector. While this is not an issue at the household level, it is an
issue for commercial customers where service users cannot
claim back VAT. This allows local authorities to offer their
105 OECD (2008) Ireland: Toward an Integrated Public Service, Paris: OECD, available at:
http://www.oecd.org/document/31/0,3343,en_2649_33735_40529119_1_1_1_1,00.html

71
International Review of Waste Policy: Annexes
services 13.5% cheaper; this disadvantage for business was
calculated at EUR 30 million.
Local authorities are also partially subsidised for their waste
management activities. Local public waste infrastructure
projects (both capital and operating costs) are partly funded by
the Environment Fund, to which the private sector is not eligible,
though this is also to compensate, in part, for the local
authorities’ recycling activities. By the end of 2005, EUR 42
million of the Fund had been used to support local authority
investments in waste management and recycling
infrastructure.19 It is important to note that EUR 42 million
relates to the total spent from the fund in 2005 and does not
relate entirely to investment in waste recycling infrastructure,
but also includes areas such as enforcement and awareness
campaign schemes to prevent/reuse waste, etc.
The most obvious way to resolve the first issue – related to landfill ownership - would
be to require local authorities and the private sector to follow exactly the same
process. In principle, it would be desirable also to exclude the local authorities from
the process, but this is likely to prove rather difficult.
The second issue – related to competition in collection – is more complex. One
matter which might easily be cleared up, however, relates to the Environment Fund.
We would suggest that the Environment Fund must be reconfigured such that:
a) In the absence of competition (for funds), local authorities should only be a
beneficiary in cases where disbursements are not used to support any activity
in which the public sector and private sector are in direct competition (for
example, cleaning up old landfills);
b) In all cases where it is intended that the local authority may be a beneficiary,
and where the private sector also provides the service under consideration,
then the relevant funds should be made available to all relevant parties,
preferably on a competitive basis, to ensure that disbursements deliver value
for money;
This ought to ensure that the revenues from the Environment Fund should not distort
competition in future.
With regard to VAT, the sentiment of the OECD is clear enough. We would agree with
this. If players are competing in the same market, it makes little sense to give one
competitor a major advantage through the VAT system. We recommend, therefore,
that in the context of ongoing review of local government finance, the law in relation
to the treatment of local authorities for VAT be examined. In principle, the aim should
be to achieve the following:
� To ensure that where commercial companies bid for tenders being let by local
authorities for the provision of services to households, the cost of the services
to households is affected by VAT in the same way as it would be if the service
was provided by the local authority itself. Ways of doing this could include
either allowing local authorities to claw back the VAT on, or exempt from VAT,
the services provided to households;

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� To ensure that where commercial companies and local authorities compete
directly in the market, that the two services are treated equivalently from the
point of view of VAT. One way of doing this would be to require local authorities
to charge VAT to customers where they engage in what is effectively the
provision of a commercial service.
In the absence of these changes, the rather obvious point is that local authorities, in
benchmarking the value for money of their services, would effectively have a
significant head start in seeking to demonstrate such value. Indeed, the
consequences might be to preserve existing levels of inefficiency as long as these
were not in excess of the implied level of cost advantage implied by the VAT regime.
If this delineation is successfully achieved, and made explicit in legislation, one might
have good reason to hope that some of the existing tensions will become less
problematic. The spheres of influence will be clarified somewhat.
Indeed, we doubt, if this situation were to become established, whether the current
role of local authorities in issuing waste collection permits, would remain as it
currently stands. The OECD was keen to highlight the potential for local authorities to
make use of their licensing powers to improve the quality of service delivery:
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As for local authorities, in the short-term, they should review how they could
better make use of their licensing authority. As this step, however, will
increase conflicts of interest under the dual responsibility model, it may be
wise to transfer licensing authority to the regional or national levels in the
longer-term.
If, as proposed elsewhere in this review:
� Ambitious targets are set for household waste management (see Main Summary
Report);
� Local authorities are given responsibility for household waste collection (see
Annex 3.0);
� Service standards are set for commercial and industrial waste collection (see
Main Summary); and
� Levies on residual waste management are set so as to internalise externalities
and improve the management of waste (see Annex 56.0),
then the key issue in terms of licensing waste collectors is likely to become one of
ensuring the collectors are registered and operating in line with Articles 26 and 34 of
the Waste Framework Directive.
As an additional point, as mentioned above, it is not clear why local authorities play
different regulatory role in respect of producer responsibility for packaging to their
role in other producer responsibility schemes. It may be that there are good reasons
for this (the diffuse nature of the responsibility), but there might also be some
inefficiencies in the regulation of these schemes, not least to the extent that the
regulated parties across the different waste streams are, in some cases, one and the
same entity.
Finally, it is difficult to completely separate concerns regarding the role which local
authorities play in the market from their role, in the regions, as developers of

statutory waste management plans. In our view, this aspect has not been explored in
sufficient depth. The implications for competition of a system in which:
� Regions, composed of local authorities, develop regional waste management
plans;
� The plans designate the required facilities; and
� Alternatives to the facilities in the plan are rejected for being non-compliant with
the plan
are clear. In short, monopolies are de facto established, the more so if local
authorities seek to use powers of direction to channel waste into a specific facility.
This is not a healthy situation. The role of the regions is addressed in Annex 5.0.
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International Review of Waste Policy: Annexes

5.0 Governance Structures / Responsibilities for
Delivery of National Strategy
Ireland has 34 City and County Councils. Under the Local Government Act 1991, 8
regional authorities were established. 106 These regional authorities are responsible
for promoting the coordination of public service provision and monitoring the delivery
of the EU Structural Fund assistance in the regions. The regional authorities carry out
the following tasks:
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� Reviewing the development plans of the local authorities and examining the
plans with consideration for the overall development needs of the region;
� Preparing regional planning guidelines and regional economic/social
strategies; and
� Promoting cooperation and joint arrangements among the local authorities
including the implications and effects of their decisions on the services for the
regions.
Membership of the regional authorities consists of elected officials from the local
authorities (numbers related to the population of the local authority area). The
regional authorities are the Border, the West, the Mid-West, the South-West, the
Midlands, the South-East, the Mid-East, and Dublin.
5.1 Regional Authorities in Waste Management
The Waste Management Act (1996) suggested, in Article 25, that local authorities
might come together to plan for waste management. In 1998, DoEHLG set out a plan
to change the waste management in Ireland – ‘Changing Our Ways’. This policy
statement advocated the development of regional waste management.
The result of this was the formation of 7 regions, with three counties developing their
own separate waste plans. These were Donegal, Wicklow and Kilkenny County
Councils. The remaining 7 regions are as follows:
� Cork
� Connaught
� Dublin
� South-East
� Mid-West
� North-East and
� Midlands.
106 Irish Regions Office (2006) Regional Authorities, available at: http://www.iro.ie/irish_regions.html
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Each region has devised, and periodically revises, a separate waste management
plan (Regional Waste Management Plan – RWMP). These plans account for the
growth in waste arisings and create a plan to process these with consideration for the
waste hierarchy. The National Overview of Waste Management Plans proposed to
consolidate the RWMPs and chart the expected waste arisings in the country,
objectives in terms of recycling and infrastructure development, and the implications
of change. 107
The first thing that will be noticed is that the regions which have emerged for the
purposes of waste management are not the same as those which were established
under the Local Government Act 1991. Indeed, there appears to have been no
constraint placed upon local authorities in constituting regions, and certainly no clear
logic, or plan, leading to the selection of the regions as they emerged. Local
authorities were neither forced to work together, nor prevented from forging their own
path. Discussions with DoEHLG officials suggest that local authorities formed regions
that appeared to make sense to them.
In the document, Taking Stock and Moving Forward, DoEHLG stated:
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When Changing our Ways was published in 1998, it encouraged local
authorities to form regional groupings in order to secure more efficient
provision of infrastructure and services. One of the main benefits arising is the
resultant significant economy of scale, providing a viable framework in
planning and volume terms for the development of integrated and innovative
solutions and a favourable climate for the creation of beneficial partnership
arrangements between local authorities and the private sector.
Expected benefits of the RWMPs included the aforementioned economies of scale. In
addition to these economies of scale, further benefits were expected in terms of:
� Efficiency of collection services;
� Beneficial partnerships between the public and private sector; and
� A framework for the development of an integrated waste management
approach.
It was also expected that following the development of a plan, procurement processes
for waste infrastructure not provided by the private sector would follow.
5.1.1 Reaction to RWMPs
The RWMPs had a somewhat problematic gestation. One academic commentator has
a critical perspective on the changes which occurred with a view to ensuring
implementation of the RWMPs, suggesting the move eroded local democracy: 108
107 DoEHLG (2004) National Overview of Waste Management Plans, available at:
http://www.environ.ie/en/Environment/Waste/PublicationsDocuments/FileDownLoad,1465,en.pdf
108 Anna Davies (2003) Waste Wars – Public Attitudes and the Politics of Place in Waste Management
Strategies, Irish Geography, 36 (1), pp.77-92.
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So challenging did some local authorities find reaching agreement about
incineration that by 2000 six out of 28 of them still had no plan in place.
During 2001 Europe was beginning to lose patience with the lack of progress
in adopting waste management plans in Ireland and the threat of being taken
to the European Court of Justice had been voiced. This potential intervention
from Europe created tensions between national and local government. At a
national level the Government needed to move the waste plan adoption
process forward in order to avoid confrontation with Europe. […]
While the environmental and health issues around the various waste
management strategies were still being hotly contested during 2001 the
National Government was keen to resolve the deadlock over the adoption of
plans. Attention to scalar politics of waste management and the design of
appropriate structures for democracy were key to the Government’s strategy
for achieving movement in the planning process. In a decisive act, which was
to fuel rather than contain heated debates about democracy, the Minister for
the Environment intervened in the stalemate in March 2001 when he
introduced the Waste Management (Amendment) Bill, 2001. Alongside the
more progressive developments contained within the Bill, including an
environmental levy both on plastic bags and waste sent to landfill, was the
transfer of the responsibility for the adoption of waste management plans
from the elected members of local authorities to local authority managers. As
noted by Boyle (2001) the aim of this transfer was to remove the adoption
decision from the electoral process, but by doing so it was also open to
criticism for eroding fundamental aspects of local democracy. It appeared to
some, particularly opposition TDs, that at this stage of the process the
Minister for the Environment simply wanted plans adopted irrespective of the
local appropriateness of the strategies contained within them.
Following the passage of the Waste Management (Amendment) Act, 10 regional
waste management plans were finalised.
From the outset bodies such as IBEC found fault with the system for the following
reasons:
1) Failure to cater for commercial and industrial waste;
2) An underestimation of quantity of waste generated;
3) No clear implementation mechanism in place;
4) Insufficient capacity planned to provide real competition;
5) Lack of coordination between the 10 regional plans; and
6) Flow control issues related to inter-regional movement of waste.
It is not clear that all these criticisms bear scrutiny, but the breadth of the criticism is
of note. IBEC claims that ‘poorly co-ordinated regional planning has resulted in

uneconomic infrastructure and regional monopolies.’ 109 Forfás suggests that cost
efficiency has been sacrificed for the development of regional waste management
plans, but neither in the case of Forfás nor in the case of IBEC is the evidence for the
statements concerning infrastructure being ‘uneconomic’, or similar, made clear. 110
The OECD claims that the regional waste management planning has had an effect
which is the opposite of that intended. 111 They argue that the result has been
overcapacity for landfill and a slowdown in the development of infrastructure higher in
the hierarchy. Again, the argument is not substantiated by clear evidence, and in any
case, where infrastructure is slow to develop, then capacity for landfill would,
presumably, have to be greater than would otherwise have been envisaged. In other
words, the one might be a logical requirement of the other.
5.2 A National Waste Board?
In 2002 the DoEHLG reviewed the policy statement ‘Changing Our Ways’ and
suggested several recommendations with respect to regionality. Included in these
recommendations was the suggested creation of a National Waste Board which would
oversee the regional plans.
The National Waste Board was expected to: 112
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� coordinate the national and regional waste management plans
� provide advice to public bodies and the private sector
� act as a consultative body in the development of EU policy change
� ensure the achievement of the targets set out in the national waste strategy
� monitor and evaluate best practice
� undertake public consultations on developments in waste strategy and provide
awareness education
The review which followed the ‘Changing Our Ways’ policy statement, ‘Taking Stock
and Moving Forward’, suggested that planning at the national level was unnecessary:
There have been calls to consider replacing the regional approach to waste
management planning with a single national waste management plan. The
reality is that a very clear national policy policy framework, setting ambitious targets
for radical change in our approach to waste management to be achieved over
109 IBEC (2006) IBEC welcomes Government's review of waste market, available at:
http://www.ibec.ie/ibec/press/presspublicationsdoclib3.nsf/wvPCICCC/2DE72CDC52A50B9780257
1BF0057ADA5?OpenDocument
110 Forfás (2008) Waste Management Benchmarking Analysis and Policy Priorities, available at:
http://www.forfas.ie/media/forfas080528_waste_benchmarking.pdf
111 OECD (2008) Ireland: Toward an Integrated Public Service, Paris: OECD, available at:
http://www.oecd.org/document/31/0,3343,en_2649_33735_40529119_1_1_1_1,00.html
112 EPA (2002) Delivering Change: Preventing and Recycling Waste, Wexford: EPA, available at:
http://www.epa.ie/downloads/pubs/waste/plans/name,11646,en.html
International Review of Waste Policy: Annexes

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the period to 2013, has been in place since 1998; this was re-affirmed in the
current Government programme and is now reinforced further by this
document.
The replacement of regional waste management planning by a single national
plan has also been advocated in terms of potential cost efficiencies and the
opportunities for the provision of a smaller number of larger facilities for
managing our wastes. However, such considerations have to be balanced
against environmental factors, particularly the need to respect the “proximity
principle” which encourages the management of waste in close proximity to
the location of its production. Essentially, what must be achieved is a balance
between optimising the costs and efficiencies of waste management facilities
and the energy and air pollution costs of transportation, and the impacts of
large-scale developments on a local area.
It is not evident that a national plan would bring any marked improvement in
terms of the delivery of services and infrastructure, or that it would offer
greater refinement or flexibility in addressing local and regional requirements.
Against this background, it is considered that the focus should continue to be
on implementation
implementation of regional waste plans, rather than effectively suspending
current progress on implementation pending the completion of a national
plan.
However, it would appear that this view is not shared by other key stakeholders in the
waste management sector. Indeed, Forfas takes an opposing view:
The regionally based waste planning framework is hindering the delivery of
cost effective, commercially viable, sophisticated waste treatment options
along the waste hierarchy as it tends to result in smaller scale facilities than
would be the case if infrastructure planning was done at a national level. The
regional waste management plans need to be coordinated at national level to
attract investment in waste infrastructure in a way that maximises potential
economies of scale, competition and enables the market to pass on the
benefits to businesses and households.
The EPA attributes the low level of necessary infrastructure development to the lack
of national waste management plan. 113
Waste contractors face considerable uncertainty in developing much needed
infrastructure because there is no integrated national plan that outlines
detailed waste infrastructural requirements, which in turn informs regional
waste management plans. The National Biodegradable Waste Strategy does
not provide the level of detail necessary for such a national waste
management plan – an integrated plan should outline not only the targets but
also where, by whom and how these targets should be achieved, as well as a
113 EPA (2008) Hitting Targets for Biodegradable Municipal Solid Waste: Ten Options for Change,
Wexford: EPA, available at:
http://www.epa.ie/downloads/consultation/epa_bmwoptions_discussion_2008.pdf

79
programme of measures to achieve the targets. In addition overall
responsibility for driving the plan must be assigned. A national plan would
overcome the deficits inherent in regional waste management plans and
provide clear guidance to planning officials and waste regulatory authorities. It
would also provide clarity to investors on whether their infrastructure projects
are compliant with national waste and planning policies.
The EPA goes on to conclude:
The absence of an integrated national waste management plan creates
uncertainty for investors developing new infrastructure while regional waste
management plan boundaries are potentially artificial obstacles to cost
effective waste management.
It suggests that the following should be considered:
� A detailed national waste management plan should be developed with
responsibility for delivery clearly designated.
� Remove unnecessary restrictions on waste management proposals that
curtail waste movements across county or regional boundaries, as these
restrictions may add to the cost of waste management.
Thus, it stops short of recommending that the regions should no longer take
responsibility for waste planning, though to the extent that it also suggests that
national guidance on site selection might also be part of a National Waste
Management Plan, then the proposed National Plan would seem to fulfil many of the
functions of the existing Regional Waste Management Plans.
Several other stakeholders consulted during the course of this exercise expressed the
view that they felt that the RWMPs were ineffective. They made comments to the
effect that investment was made despite, rather than because of, the RWMPs. Some
felt a national plan was necessary, lamenting the fact that this was never introduced.
Some of the advocates of a national coordinating mechanism took the view that the
RWMPs should remain, but others suggested that the RWMPs should simply be cast
aside in favour of a national waste board, or waste management authority.
5.3 Performance and Monitoring of Regional Waste Management
Plans
The Regional Waste Management Plans all set targets for recycling of different waste
streams. They also set out plans for the treatment of waste. Both of these vary widely
across the regions.
The RWMPs are essentially intended to constitute the means to deliver these, but
where local authorities have withdrawn from the provision of waste collection
services, then their ‘ability to ensure’ delivery of targets is likely to be rather more
limited than in those cases where they have control over the process through either
collecting materials themselves, or through tendering out services. Failing this,
authorities would need to be pro-active in ensuring collection permits were specified
so as to ensure the collection services offered by collectors were capable of delivering
on targets.
International Review of Waste Policy: Annexes

Targets such as those in the NBWS should be reflected in the RWMPs, and in
particular, given that the NBWS was completed after the revision of many RWMPs, in
the Annual Implementation Reports on the RWMPs. The NBWS stated:
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Each Annual Implementation Report to be prepared by local authorities on the
implementation of the Waste Management Plan, as required under Key Point
13 of Waste Management: Taking Stock and Moving Forward, should
record progress made in relation to the National Strategy on Biodegradable
Waste over the previous year. The format to be followed in the Annual
Implementation Report will be specified in a Circular letter issued to all local
authorities by the DoEHLG.
Circular WPPR 17/08 states: 114
4.9 Annual Reports on the implementation of waste management plans
should be sent to the Department. In addition, Annual Reports should also
be transmitted to the EPA, so that the information can be taken fully into
account by the Agency when compiling their annual National Waste
Reports. Annex IV provides an outline template of the format of an Annual
Waste Management Plan Implementation Report.
DoEHLG confirms that the Annual Reports which Regions are required to prepare, and
which should reflect targets in, for example, the NBWS, have been received only from
Dublin, Midlands, Mid-west (Limerick, Clare and Kerry) and Connacht. A review of
these reports highlights the fact that the Regions have not, in general, sought to
understand (for example) how much paper and card, or textiles, or organic waste is
being captured in their Region. These are some of the more obviously ‘transposable’
of the NBWS targets, but these have not been considered thus far by the Regions.
In essence, therefore, the requirement to prepare Annual Reports does not appear to
have been fulfilled. When these reports are received, it is not clear what happens to
them in the sense that whether Regions are, or are not, on track to deliver against
their stated plan triggers no form of sanction. Indeed, in those areas where local
authorities have withdrawn from service provision, it is not clear upon whom any
sanction would be made to stick. In short, no one has any specific interest or
incentive to make sure that what they hope will happen will in fact materialize.
5.3.1 The Proximity Principle
The proximity principle is referred to occasionally in respect of regional plans. The
Waste Framework Directive discusses proximity in Article 16:
The network shall enable waste to be disposed of or waste referred to in
paragraph 1 to be recovered in one of the nearest appropriate installations, by
means of the most appropriate methods and technologies, in order to ensure
a high level of protection for the environment and public health.
114 DoEHLG (2008) National Strategy on Biodegradable waste: Implementation of Segregated “Brown
Bin” Collection for Biowaste and Home Composting, Circular WPPR 17/08 to each City and County
Manager, 31 July 2008.

Waste referred to in paragraph 1 is:
81
mixed municipal waste collected from private households, including where
such collection also covers such waste from other producers, taking into
account best available techniques.
Proximity therefore, applies to ‘disposal’, and to ‘recovery of mixed municipal waste
collected from private households’, and possibly, ‘recovery of mixed waste from other
producers’. Proximity also has to account for the nature of the network of facilities
available, which may be more or less dispersed, spatially.
Ireland is obliged to follow the Waste Framework Directive. However, in the context of
Irish waste management, the RWMPs do not so much ‘have respect to’ the proximity
principle. Within Ireland, they have effectively had the ability to determine what
‘proximity’ means. This raises some questions as to whether the spatial distribution of
facilities for disposal and recovery of mixed municipal waste from households, as
envisaged in the RWMPs, is likely to be ‘right’ for Ireland.
5.4 Recommendation
Stakeholders have found it difficult to be entirely positive about the RWMPs. If one
sets aside the criticisms leveled at the system by Davies (see above), then the
RWMPs appear to have been based upon a presumption that regionalization would
lead to economies of scale. The OECD recommends that waste management is best
catered for at local level to reduce transaction costs. The OECD also notes that the
area needed for efficient economies of scale in waste management is geographically
small (circa 50,000 inhabitants). Hence, it is not clear that many of the local
authorities in Ireland are of a size which is so small that such economies cannot be
realized, or ‘more or less’ realized, particularly in respect of collection (where, in any
case, the private sector is increasingly providing the collection service).
Moving on to treatment, the presumption that RWMPs would allow economies of
scale to be attained, seems to have overlooked the fact that ‘competition in the
market’ left no one with clear and unequivocal control over the waste stream. It is
difficult to ‘scale up’ facilities and take advantages of any anticipated economies of
scale without control over the supply of material into a given facility. The response of
local authorities appears to be to seek to bridge this gap by challenging the role of the
private sector in the waste collection market, and directing waste from various parties
into facilities which they re involved in developing.
Finally, if the intention was to ‘go after’ economies of scale in a concerted manner,
then it seems anomalous that the regions vary so much in scale. The latest EPA report
suggests that the smallest ‘region’ is Wicklow, managing 56 thousand tonnes of
household waste, whilst the majority of regions deal with 125-200 thousand tonnes
of household waste, with Dublin Region dealing with 479 thousand tonnes. The
variation in size seems somewhat at odds with a logic of seeking to capitalize on
scale economies.
The upshot is that the RWMPs appear to be able to lay claim to rather little in the
majority of cases at present. It is claimed that the roll out of ‘green bins’ for recycling
has been a success, but it remains questionable that this change can be traced
entirely to the existence of the RWMPs, rather than resulting from the actions of local
International Review of Waste Policy: Annexes

authorities and private companies themselves, responding to the rising savings to be
made from avoided disposal (i.e. rising landfill charges – see Annex 11.0) Moreover, it
is difficult to see what ‘the Regions’ really do, or indeed, what they can do to promote
development. They have especially limited competences where they have withdrawn
from service provision.
This raises the inter-related questions:
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� Is there a role for Regions?
� If so, what should that be, and should the Regions be as they are currently
constituted?
� Is there a role for a National Board, and if so what would that be?
Neither RWMPs nor any national waste management board can do anything to call
forward development if:
� The market (notably for collection) is as free as it is in Ireland; and
� The incentives in place are not such that the market delivers the desired
facilities in a timely and efficient manner.
Assuming, therefore, that one shifts to a situation where local authorities have control
over household waste (see Annex 3.0), then the first change which may occur is that
economies of scale might become a concept which can be given greater significance
as a consequence of local authorities having clear control over the household waste
stream. Even here, however, it is unclear that regions need to be formed, as distinct
entities, for this purpose. Rather, it may be equally reasonable to allow local
authorities to come together in groupings as they see fit to collaborate on, for
example, procurements of collection contracts, or treatment infrastructure.
It is worth pointing out that in the European context, the Cities and Counties of Ireland
are far from being ‘uniquely small’ where local authorities are concerned. In regions
such as in the Flemish region of Belgium, local authorities group together in
Intermunicipalities, which work together for the purpose of waste management.
Responsibilities for waste management are devolved down to much smaller
municipalities in countries such as Italy, and this has not hindered the development
of services for treatment and collection. 115 Arguably, legislation simply has to allow for
this possibility, and perhaps, facilitate it, rather than forcing it.
In short, therefore, it is difficult to see why Regions need to play a major role in Irish
waste management. Rather than creating additional bodies and layers of
Government, it will be rather more important to design the institutional architecture in
the right manner, and to create the right incentives for actors within the sector, to
deliver the right outcomes.
115 It is worth clarifying here that ‘Italy’ is not ‘Naples’. The inevitable scoffing that frequently
accompanies the suggestion that any part of Italy might have a sensible waste management
infrastructure belies the reality in which, as in many other countries, excellent performance sits
alongside some less educative examples.
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It is suggested that the regions should be abolished. It is proposed that the
requirement, under the Waste Framework Directive, to prepare a waste management
plan be delivered through a National Plan.
We propose that the RWMPs be replaced with one national waste plan. This would
require a change in the Waste Management Act. We propose that the process of
changing the law, and developing the Plan, should be initiated as a matter of urgency
as soon as a decision has been taken as to which of the policy recommendations
made in the Main Review Document are to be taken forward. In the interim, whilst a
National Plan is being developed around these policies, these policies would then
guide the implementation of waste management at the local level in the intervening
period. Planning decisions should reflect the policies being implemented.
The ultimate responsibility for developing a National Waste Plan would rest with the
Minister. A Ministerial Programme Board chaired by the Minister and including
representatives from DoEHLG, EPA, IBEC, IWMA, Cre, CCMA, the CIF, An Taisce and
environmental NGOs, would be responsible for steering the Plan. The Minister would,
however, still make the executive decisions.
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POLICIES FOR MUNICIPAL WASTE
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6.0 Review of Irish Policy on Prevention and
Recycling
The main policy documents relating to Waste Policy in Ireland are:
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� Changing Our Ways (1998); 116
� Preventing and Recycling Waste - Delivering Change (2002); 117
� Waste Management - Taking Stock and Moving Forward (2004); 118 and
� National Biodegradable Waste Strategy (2006). 119
These four Policy Documents are the drivers behind each of the policies analysed in
this Report. This Annex highlights the documents’ influence on policy in respect of
waste prevention, and on recycling and composting / digestion.
6.1 Waste Prevention in Ireland
The latest EPA National Waste Report 2007, states that a total of 3,397,683 tonnes
of municipal waste was generated in Ireland in 2007, is an increase of 1.4% on the
2006 figures. 120 The report also states that the recycling of municipal waste
increased by 3.6% to an overall recycling rate of 36.5% and recycling of household
waste continued to increase (by 8% in 2007) to an overall recycling rate of 26%.
From Figure 6-1 below it is apparent that in the period 2002-2006, personal
consumption of goods and services increased by 6%, gross domestic product (GDP)
increased by 6% and there was a 2.6% increase in population. Over this period,
municipal waste generation appears to have grown at a similar rate to GDP and
personal consumption. There is a suggestion; therefore, that economic growth and
the commensurate growth in consumption have been strong factors influencing the
quantity of waste that is produced. Over this period, there appears to have been little,
if any, decoupling effect. This suggests that, at least during this period, waste
prevention policies and initiatives have not managed to exert a significant influence
on waste generation.
Ireland relies on material recycling facilities abroad, with just 24% of all waste
recycling took place in Ireland in 2007. 121 Implementation of the Market
Development Group commenced in 2008, the aim of which is to develop existing
116 DoELG (1998) Waste Management: Changing our Ways, September 1998.
117 DoELG (2002) Preventing and Recycling Waste: Delivering Change, March 2002.
118 DoEHLG (2004) Taking Stock and Moving Forward, April 2004.
119 DoEHLG (2006) National Biodegradable Waste Strategy, April 2006.
120 EPA (2009) National Waste Report 2007, Wexford: EPA.
121 EPA (2009) National Waste Report 2007, Wexford: EPA.
International Review of Waste Policy: Annexes

markets for recyclables and identify new applications and markets for recyclable in
Ireland. One of the key issues which the Programme will address is the need for more
recycling infrastructure in Ireland in order to reduce reliance on overseas markets.
Figure 6-1: Municipal Waste Generation linked with GDP & Personal Consumption
Source: EPA (2007) National Waste Database 2006, Johnstown Castle, Wexford: EPA
Prevention means reducing the quantity and harmfulness to the environment of
materials and the substances contained therein. Waste prevention initiatives can
therefore be successfully applied at any time in the life-cycle of a material or
substance, including in the production process, the marketing, distribution, or
utilisation stages, up to eventual discard at the end-of-life stage. Prevention is the
most desirable method of waste management since the absence of waste totally
eliminates the need for handling, transportation and treatment of discarded
materials. Prevention of waste provides the highest level of environmental protection
optimises the use of available resources and removes a potential source of pollution.
It can bring bottom-line benefits to businesses, and to households, through avoiding
wasted expenditure, and reducing the costs of waste management.
The ultimate objectives of waste prevention are to achieve verifiable results in
reversing current trends in waste production, stabilising waste arisings and
decoupling waste generation from economic growth by maximising resource use
efficiency. One definition of waste prevention used in Ireland is: 122
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“Elimination or reduction at source of materials and energy consumption,
waste arisings (solid, liquid, gaseous and heat) and harmful substances.”
In 2002/2003 the EPA carried out a study with a view to developing a framework for
waste prevention in Ireland. This report, entitled “Assessment and Development of a
Waste Prevention Framework for Ireland (2001-WM-DS-1) Synthesis Report”, set out
ten core building blocks which were considered to be a prerequisite for any such
framework, these included:
1. Commitment & leadership;
122 EPA (2001) based on definition provided in the ERTDI Waste Prevention Programme.

2. High quality data relating to waste and resources;
3. The ability to measure prevention;
4. The setting of realistic targets & effective targets;
5. A solid foundation of instruments;
6. A material management focus;
7. The consideration of energy and equity issues;
8. Taking a full product life-cycle approach;
9. Linking and synergies with other national strategies; and
10. A consideration of qualitative as well as quantitative prevention.
Section 28 of the Waste Management Act, 1996 to 2003, provides for a wide range
of legislative and economic instruments to be applied in support of prevention
initiatives.
In order to build the framework mentioned above the EPA Report on “Assessment and
Development of a Waste Prevention Framework for Ireland (2001-WM-DS-1)
Synthesis Report” sets out ten main specific measures which it suggested were
required components for developing a waste prevention strategy. These were
considered under three headings, namely, Communications/Information, Economic
and Regulatory:
Communications/Information
Communications/Information
Communications/Information
1. Awareness Raising Programmes (e.g. Its Easy to Make a Difference/ Race Against
Waste);
2. Technical Support and Training;
3. Research (research programme regarding materials and waste data acquisition);
4. Green Public Procurement;
Economic
Economic
5. Environmental Taxes and Charges (e.g. landfill and plastic bag levy);
6. Extended Producer Responsibility;
7. Economic Supports and Grants (e.g. EPA - Cleaner Greener Production Programme
etc…);
Regulatory
Regulatory
8. Restrictions and Bans;
9. Agreements and Covenants; and
10. Industrial Permits and Licenses.
6.2 Waste Recycling in Ireland
The Waste Framework Directive defined recycling as “any recovery operation by which
waste materials are reprocessed into products, materials or substances whether for
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International Review of Waste Policy: Annexes

the original or other purposes. It includes the reprocessing of organic material but
does not include energy recovery and the reprocessing into materials that are to be
used as fuels or for backfilling operations” 123. This Directive states that Member
States shall take the necessary measures designed to achieve the following targets
by 2020, “the preparing for re-use and the recycling of waste materials such as at
least paper, metal, plastic and glass from households and possibly from other origins
as far as these waste streams are similar to waste from households, shall be
increased to a minimum of overall 50 % by weight” 124 .
For household waste, recycling policy has been driven, in Ireland, by targets set out in
policy document “Changing our Ways, 1998”, by producer responsibility legislation, by
the landfill levy and by the requirement to implement pay by use (PBU) system
(though this is not being implemented in all local authorities). The landfill levy has
raised revenues which are paid into an Environmental Fund, along with funds raised
from the plastic bag levy. The proceeds are used to support a range of measures,
programmes and schemes to prevent or reduce waste, the operation of waste
recovery activities, litter prevention, environmental partnership projects and
environmental awareness, education and training. In 2007 €17,246,428 of the fund
was paid to local authorities to assist in capital costs associated with the provision of
waste management infrastructure, while €11,914,847was paid to local authorities to
assist with the operational costs of waste management. This funding has allowed a
large number of recycling facilities/infrastructure to be put in place in Ireland, which
has had a positive impact on recycling levels in Ireland.
A key issue for Ireland is the freedom of the market for household waste collection.
This freedom is most likely to be increasing the costs of waste collection to
households to above levels, which might otherwise prevail. Household waste
collection costs are rather high in Ireland compared with other countries, and this is
unlikely to be conducive to bringing more households within the formal waste
collection infrastructure. Rather, it is likely to act as an incentive for some households
not to have their waste collected, with all that this may imply in terms of unauthorised
waste activities including waste burning, and dumping.
The situation in Ireland– where private and public sector may compete openly for
custom from households (competition in Ireland is in the market and not for the
market) – is almost unique in Europe. It is an awkward situation on which to base the
development of sound collection systems and infrastructure precisely because
recovering additional investments cannot be guaranteed in such an openly
competitive market. The nature of the system becomes driven by price, and the
willingness of the service providers to take on risk.
Whilst the matter has recently proved the subject of controversy in Ireland, the
overwhelming majority of other countries grant, effectively, either a monopoly to a
123 Directive 2008/98/EC of the European Parliament and of the Council of 1 November 2008 on
waste and repealing certain Directives.
124 Directive 2008/98/EC of the European Parliament and of the Council of 1 November 2008 on
waste and repealing certain Directives.
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company linked to the municipality (or a group thereof), or a time limited monopoly to
a waste contractor for household waste collection, following a competitive tendering
process. This process should, where the procurement process is managed effectively,
allow the collecting organization to achieve ‘economies of density’ in their logistics
through increasing the number of pick-ups which are undertaken across a given area.
This should, in turn, allow for reductions in cost for a given level of service.
Other key issues in Ireland relate to the overall funding structure for household waste
collection. In Ireland, whilst local authorities receive some funding support (for
example, through the Environmental Fund), the service is funded increasingly through
direct charges on users, usually a combination of a fixed and variable rate. Evidently,
whilst local authorities may use their powers to require those holding collection
permits to provide a given standard of service, they cannot control the price charged
for such services.
6.3 Key Policy Documents and their Contents
6.3.1 Changing Our Ways
The primary purpose of the Policy Statement, Changing Our Ways, was to provide a
national framework within which local authorities and the waste industry could plan
ahead with confidence. 125 This was the first in a series of government policy
documents on the management of waste in Ireland. It endorsed an ‘integrated waste
management approach’, based around the waste hierarchy as it was then
understood, with the following order of preference:
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� Prevention,
� Minimisation,
� Reuse
� Recycling
� Energy recovery,
� Disposal.
While this document contains the key quantitative targets for Irish waste
management; to be achieved over a 15-year period (i.e. to 2013), with the exception
of the second target (diversion of BMW from landfill, driven by the Landfill Directive),
there does not appear to be any supporting rationale or evidence provided to justify
the choice of these particular targets. The targets set out in Changing our Ways
appear to be inconsistent with the National Biodegradable Waste Strategy. In addition
no numeric assessment of growth rates, past or projected is provided. Changing Our
Ways is not prescriptive on residual waste treatment.
125 DoELG (1998) Waste Management: Changing our Ways, September 1998.
International Review of Waste Policy: Annexes

6.3.1.1 Waste Prevention
Specifically in relation to waste prevention, the document is somewhat inconsistent,
making one or two strong statements, but also omitting references in what might be
considered key contexts. The document made reference to the statutory objective of
the local authorities’ waste management plans under the Waste Management Act.
The first of these is ‘to prevent and minimise the production of waste and its harmful
effects.’ However, the document also advises that where landfill capacity issues exist,
these should be dealt with, in the first instance, through maximising composting and
materials recovery. Waste prevention, somewhat strangely, is not mentioned in this
context. In the final Section, also, in discussing ‘a preferred planning approach’,
waste prevention is not mentioned.
On the positive side, the document does raise the issue of charging for waste
management in line with the level of use, specifically highlighting the potential
incentive effect this may create:
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“As a matter of equity, and in order to directly incentivise waste reduction, the
level of waste charges should vary according to usage. […]
Where local authorities provide waste collection services, they should review
their approach to household and commercial waste charges with a view to
introducing weight related charging to the fullest extent possible. Similarly,
every effort should be made to ensure that landfill gates fees are levied in
relation to the quantity of waste accepted for disposal.”
The document also highlights the role of local authorities in involving households in
waste prevention activities. Considerable weight was, therefore, placed upon
informing and educating the public:
“The key to mobilising the general public to take a more responsible approach
to waste, and support waste minimisation and recovery, is sustained public
information and education. Local authorities that have not already done so
should develop an on-going public awareness programme, aimed at
generating a clear appreciation of the nature and scale of the waste problem,
and providing practical guidance on the day to day choices which can be
exercised by individuals and households.”
6.3.1.2 Waste Recycling
Changing Our Ways states that performance with regard to recovery and recycling
must be substantially improved to address the requirements of Government Policy.
The policy document sets out the following targets for recycling over a fifteen year
timescale (i.e. by 2013):
� Diverting 50% of household waste away from landfill;
� Recycling of 35% of municipal waste; and
� The development of waste recovery facilities employing environmentally
beneficial technologies, as an alternative to landfill, including the development
of composting and other feasible biological treatment facilities.
One of the main objectives set out in Changing Our Ways, 1998, is reducing, reliance
on landfill in the short to medium term while encouraging alternative systems and

infrastructure with a high emphasis on waste recovery and recycling. This included a
review of alternative waste collection systems and alternative Thermal and Biological
Technologies in order to divert significant quantities of waste away form landfill.
Various options were outlined in order to segregate materials for recovery purposes,
including the use of multiple bins, alternate collection schedules, kerbside collection
and “bring” systems (e.g. bottle banks).
6.3.2 Preventing and Recycling Waste – Delivering Change
The policy agenda in relation to waste took a further step forward in March 2002 with
the publication of a policy statement specifically focused on waste prevention and
recycling. Preventing and Recycling Waste: Delivering Change set out an agenda of
initiatives designed to achieve progress at the top of the waste hierarchy, in terms of
preventing waste arising in the first place and achieving improved levels of recycling
of waste that does arise. 126 Funding to modernise Ireland’s recycling infrastructure
and other initiatives such as the introduction of a landfill levy (subsequently
introduced in mid-2002) and new Producer Responsibility Initiatives were among the
instruments envisaged. The targets as set out in Changing Our Ways remain
unchanged in “Preventing and Recycling Waste”. In addition there is a stated aim of
recovering 50% of packaging waste by 2005 (which follows from the Packaging
Directive). The policies described within this Policy document to help to achieve
targets are not supported by any quantitative information as to the likely impact that
the schemes will make, nor is progress towards them stated in any meaningful way.
6.3.2.1 Waste Prevention
A key recommendation arising from the document was that a National Waste
Management Board would be established. However, the Board has never been set
up. Even so, the document made a number of other recommendations in respect of
waste prevention.
Specifically, it noted:
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“Prevention is one of the most challenging aspects of waste management
because it demands a wide range of linked initiatives, presenting a direct
challenge to householders as well as commercial and industrial waste
producers. Excessive waste is generated through poor product development;
inefficient production or manufacturing processes, creation of disposable or
short-duration goods, and unsustainable consumption patterns – for example,
by purchasing excessively packaged products. Taking action to prevent waste
being generated in the first place is fundamental to the overriding objective of
de-coupling economic growth from growth in waste arisings. […]
An intensive and well structured waste prevention programme must now be
put in place with the overall objective of stabilising, and in the longer term
reversing, the growth in waste generation.” (Our emphasis).
126 DoELG (2002) Preventing and Recycling Waste: Delivering Change, March 2002.
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To this end, the document envisaged the setting up of a National Waste Prevention
Programme, this to be drawn up by a newly established Core Prevention Team (CPT)
within the EPA. The remit of the CPT was set out as:
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� “developing and prioritising programme objectives, with the goal of stabilising
waste arisings and reversing current trends in waste production;
� identifying the key organisations best placed (either individually or collectively)
to contribute to the achievement of these objectives, and pursuing their
engagement in support of the programme;
� identifying and prioritising necessary actions to be initiated directly by or on
behalf of the Core Prevention Team in pursuit of the programme objectives;
� co-ordinating the activities of the different stakeholders;
� identifying appropriate targets or performance indicators, and devising a
representative methodology for the measurement of national performance in
relation to waste prevention and minimisation.
In implementing a progressive and ambitious Prevention Programme, the Core
Prevention Team will –
� advise and contribute to policy development and action in relation to waste
prevention and minimisation, including the provision of advice to the Minister
with regard to actions within the remit of Government which are necessary or
desirable in support of improved national performance;
� prioritise and target relevant activities within the industrial/commercial sector;
� provide financial support for significant waste prevention initiatives;
� support the establishment of local or regional Waste Minimisation Clubs and
Networks;
� initiate or facilitate research to identify potential constraints and incentives
with regard to waste prevention/minimisation initiatives;
� provide advice and support on all aspects of waste prevention and
minimisation to relevant stakeholders, by means of
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• training programmes,
• the provision of help-line services, and
• the publication of procedural manuals and other relevant guidance;
� finance or initiate appropriate R&D and demonstration projects that can
provide visible and factual evidence of the benefits of specific waste
prevention and minimisation initiatives;
� monitor and evaluate international developments in relation to best practice;
� establish and finance a best practice programme and ensure effective
dissemination of results;
� monitor and evaluate waste audits and waste reduction programmes
submitted on foot of statutory requirements (see paragraph 2.4.2), engage
with businesses concerned to support consequent waste reduction initiatives,

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and liaise with local authorities in support of their enforcement function in this
area; and
� report annually on progress achieved.”
Measures envisaged included the following:
� Through the Waste Management Act 1996, and the general obligation on
waste producers to reduce waste, it was envisaged that the CPT would come
forward with proposals for regulations requiring businesses to conduct waste
audits and implement waste reduction programmes;
� It was envisaged that promotion of re-use could occur through, inter alia, use
of economic instruments and producer responsibility obligations;
� Regarding packaging, the document noted:
“The obligations arising from the implementation of the Packaging
Directive, and other proposed initiatives such as mandatory waste audits,
will encourage business to reduce the amount of packaging which it
places on the market. Mandatory re-use systems will be considered in
appropriate circumstances in order to ensure that the requirements under
the Packaging Directive are fulfilled.”
� On non-packaging materials, it suggested that re-use could be encouraged:
“through educating the public in relation to the range of products which
can be re-used and also regarding the operation of those organisations
which accept products for re-use and resale. Individual consumers can
maximise the re-use of materials in their daily lives by adopting a few
simple techniques:
• use of a reusable shopping bag in preference to a disposable one;
• use of resalable containers for food in preference to disposable
wrappings;
• use of rechargeable batteries;
• servicing and repair of household equipment in preference to the
purchase of new equipment; and
• avoidance of the use of disposable products e.g. cups, plates, cutlery,
razors, cameras.
The National Waste Management Board will be asked to advise on what
practical measures can be taken to encourage further the re-use of nonpackaged
products.”
� Waste exchanges were also highlighted as an approach to enhance re-use;
� Charity shops were also the subject of some discussion;
� The re-use of IT was identified as an approach, which could generate social
benefits.
These measures are all of interest, though in terms of concrete policies, as defined in
this work, the first four bulleted measures above are of greatest interest.
International Review of Waste Policy: Annexes

The EPA has published a new Prevention Plan 2009-2012, this document is
presented as a framework statement of intent for work to be completed on the
Prevention Programme for the four-year period to 2012, subject to resources being
available.
6.3.2.2 Waste Recycling
Preventing and Recycling Waste: Delivering Change identified the main constraints on
recycling activity historically in Ireland which included the readily availability of cheap
landfills, a perception of the inconvenience of recycling, undeveloped and fluctuating
markets for recyclables, absence of an adequate charging system and the lack of
recycling and reprocessing facilities. These constraints outlined in 2002 are similar to
what is being experienced today; currently the main barriers include the lack of stable
and economically attractive markets and outlets for recyclable materials, the lack of
development and roll out of source separation and segregated collection systems.
In this policy document, educational and awareness initiatives were identified as
being an important element to encourage the use of recycled products in Ireland. The
policy statement called for the establishment of a Market Development Group to
progress the existing work on market development and to expand market
development initiatives for recycled products on an all island basis which would be
co-ordinated through the North / South Ministerial Council. This Market Development
Group (MDG) was established by the DoEHLG in July 2004, however its Programme
was not officially launched until the end of October 2008. It was tasked with
promoting the development of markets for recycled materials. The Market
Development Programme aims to fully harness existing outlets in addition to
identifying and developing new, reliable and stable markets for recycled materials in
Ireland. The overarching Programmes will include green procurement, recycling
feasibility and demonstration projects and research and development projects. The
main waste streams that offer the greatest potential for recycling in Ireland include
organics, plastic and paper.
Over three million tonnes of municipal waste are generated annually in Ireland. The
national recovery rate for household waste reached 36.5% in 2007. Most regions
plan to achieve a recycling rate of 40% - 6-% in the coming decade, which will lead to
an increase in the volume of recyclable materials available from the domestic waste
stream. While a doubling of the recycling rate is forecast for commercial and
industrial waste. Currently the majority of waste collected in Ireland for recycling is
exported for reprocessing.
The main goals of the Market Development Group are:
94
� Promote Sustainable and Indigenous Recycling Technologies;
� Stimulate Growth in Recycled Products;
� Develop Markets for Recycled Materials;
� Stimulate Demand for Recycled Materials; and
� Increase in Recycling Rates.
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To date the Market Development Group has developed its Business Plan, which
details the activities the Market Development Group will undertake over the following
year(s). Specific deliverables are set out in the Action Plan for 2009. 127
The Action Group on the Recyclate Market was established in November 2008 by the
Minister following a dramatic fall in the international price for ‘recyclates’. The drop in
demand was very rapid and was caused by the current international economic
situation, combined with the very large fall in oil prices. Ireland exports 85% of its
recycling material, and the price fall has led to serious difficulties within the recycling
industry in Ireland. The Action Group met on the 6 th of November and the following
synopsis of their findings was provided:
95
� All agreed that storage of materials (which had commenced as a means to
deal with material for which no market could be found) was only a short term
solution;
� Anecdotal evidence suggested that some small operators were ceasing
collection of recycling bins and requesting their customers to use the ‘black
bin’ (for residual waste) only;
� Industry / local authorities indicated that the additional costs associated with
recycling would have to be passed to households and businesses. Awareness
would have to be raised among the public of the costs associated with
recycling.
� All agreed that high quality material was required for access to the key
Chinese market (to which much of Ireland’s collected paper and card is sent,
sometimes via the UK), and that this had implications for some operators’
current collection and treatment systems;
� Some members of the industry said movement on the landfill levy was urgently
required in order to ensure that recycling efforts are not undermined and to
remove any future temptation to landfill such material;
� Both industry and the EPA recommended co-firing (at, for example, cement
kilns) be considered for some of the material; and
� Infrastructure and indigenous recycling industry need to be developed.
Other initiatives such as the development of the National Strategy on Biodegradable
Waste (published in 2006) and a National Compost Standard were also identified in
this Policy document as being important projects to undertake to further develop
markets for recycled products in Ireland. 128
127 DoEHLG (2009) Market Development Programme for Waste Resources, Action Plan 2009,
http://www.mdg.ie/MDGUploadedFiles/file/MDP%20Action%20Plan_8_06_09.pdf
128 DoEHLG (2007) Market Development Programme for Waste Resources 2007-2011.
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6.3.3 Waste Management – Taking Stock and Moving Forward
In April 2004, the Minister for the Environment, Heritage and Local Government
published the National Overview of Waste Management Plans and Waste
Management: Taking Stock and Moving Forward. 129 The report involved an overview
of progress from 1998 to 2003 and a strategy for progress into the future. Relative to
the previous policy statements, the document appears to have a reduced emphasis
on waste prevention. The emphasis is very much on ‘management’ of waste that is
generated.
The report noted that waste growth was proving to be greater than had been
anticipated:
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“From a waste management planning perspective, the significance of the data
centres on the fact that municipal waste arisings in 2001, at about 2.7 million
tonnes, had already exceeded the medium term projections in waste
management plans. In the context of projections of possible future waste
arisings, local authorities should have regard to the possible scenarios
identified by the EPA in the National Waste Database Report 2001.”
Elsewhere, we have commented on the fact the scenarios referred to in the EPA
National Waste Database Report 2001 are hardly definitive, with one positing a slight
decline in waste over 14 years (2001-2015), and another implying a near-quadrupling
of waste over the same period (with five other scenarios in between - the projections
are shown in Figure 1-2 below). 130 The report recognises that a key aim of the Core
Waste Prevention Team within the EPA ‘will be to improve data on waste arisings so
that a sound basis for the measurement and monitoring of the Programme’s impact
can be established.’
129 DoEHLG (2004) Taking Stock and Moving Forward, April 2004.
130 See Eunomia with Tobin (2007) Waste Policy, Planning and Regulation in Ireland, Report for
Greenstar.

Table 6-1: Generation of Municipal Waste Projected to 2015, tonnes
Source: EPA (2003) National Waste Database Report 2001, Johnstown Castle, Co. Wexford: EPA.
6.3.3.1 Waste Prevention
The document itself noted that progress in recycling had been made, but less
progress had been made at other tiers in the waste hierarchy:
97
“In particular, while good progress has been made in relation to recycling,
there is a need to secure greater advances on activities higher higher in the
hierarchy - in relation to waste waste waste prevention prevention and and minimisation minimisation - as well as those
at the lower levels - in terms of thermal thermal treatment treatment treatment and and residual residual landfill. landfill.” landfill.
This Policy document states that waste prevention initiatives are crucial in order to
effectively decouple waste generation from economic growth. It states that “It
therefore remains true that, although waste prevention has been the paramount
objective of both national and Community waste management policies for many
years, limited progress has been made so far to turn the objective of waste
prevention into practice.”
The report announced the launch, with immediate effect, of the National Waste
Prevention Programme, which had been proposed in the previous policy document. As
had been envisaged, the Programme was to be led by a Core Prevention Team within
the Environmental Protection Agency, the work being supported with €2million in
start-up funding from the Environment Fund. However, the National Waste Board had
disappeared from view.
6.3.3.2 Waste Recycling
This Policy document states that progress has been achieved in recycling since the
publication of “Preventing and Recycling Waste: Delivering Change, 2002”; however
close attention must be paid to the development of markets for recyclable materials.
The Policy document stated four key areas have to be addressed if Ireland’ recycling
International Review of Waste Policy: Annexes

performance is to be radically improved, these include, better separation and sorting
of waste at source, provision of an adequate infrastructure for the collection and
management of waste arisings, greater reprocessing capacity to convert waste into
usable products or raw materials and the generation of markets and improved
demand for recycled or recyclable materials, especially in the manufacturing and
construction sectors.
On pay-by-use charging, the document set out a date by which it expected the
completion, nationally, of the switch to weight/volume based charging. It envisaged
that responsibility for doing so would rest with individual collectors, with local
authorities including appropriate conditions in waste collection permits, the first twoyearly
reviews of which were then starting to fall due.
6.3.4 National Biodegradable Waste Strategy
The National Biodegradable Waste Strategy (NBWS) states that its most desirable
option is waste prevention or reduction of biodegradable municipal waste production,
to minimise the amount of waste requiring collection and treatment. The next most
desirable option is reusing biodegradable municipal waste (BMW), such as cardboard
and textiles. This strategy provides a combination of measures based on education /
awareness and economic instruments aimed at reducing BMW generation. For
biodegradable waste that must be collected and managed, materials recycling and
biological treatment are favoured, since they recover the material for new beneficial
uses.
6.3.4.1 Waste Prevention
The National Biodegradable Waste Strategy (NBWS) includes ambitious targets for
the prevention of biodegradable waste. It is not clear, however, who is to be charged
with implementing these, other than the EPA through its waste prevention
programme.
Elsewhere, we have commented on the significant change in tone and substance
between the Draft and the Final Biodegradable Waste Strategy. 131 The draft strategy,
published in 2004, applied an annual growth rate of 3.8% to the arisings of
biodegradable municipal waste. This was the growth rate experienced from 1995-
1998 as reported in the EPA Report of 2001. The logic was presented as follows:
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“A waste growth rate of 3.8% per annum has been applied for the period of the
Strategy. This is the growth rate that was experienced in the period 1995-1998.
While economic growth and population growth may moderate in the coming
years, choosing a relatively high growth rate such as this means the strategy
should prescribe adequate waste recovery capacity and in any case there will
be no difficulty if the landfill diversion targets are ultimately exceeded.” 132 (our
emphasis)
131 Eunomia with Tobin (2007) Waste Policy, Planning and Regulation in Ireland, Report for Greenstar.
132 DOEHLG (2004) Draft National Biodegradable Waste Strategy. 2004

No adjustment was made to the projected growth rate to allow for the impact of waste
prevention activities. The report stated that:
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“Figures record that biodegradable municipal waste generation has increased
by about 50% in that 9-year period [1995-2004], with 1.935 million tonnes
generated in 2004.” 133
The Final NBWS discusses, in Section 3.2, waste growth rates. Although the approach
taken seems far from transparent, growth rates appear to have been based on work
undertaken in 2004 (apparently, at the same time as the Draft Strategy was being
developed). 134 In relation to historical growth rates the Final NBS states that:
It adds that:
“There have been anecdotal reports of appreciable reductions in the amount
of waste presented since the introduction of the ‘Pay-by-Use’ (PBU) system on
1 st January 2005.”
“Significant results are anticipated from the implementation of the National
Waste Prevention Programme – combined with the awareness/ education
campaigns, the application of Pay-By-Use systems of waste charges and other
ancillary waste prevention activities - over the duration of the Strategy.”
Reductions in biodegradable waste were forecast as follows (being essentially a
reduction in the trend in arisings):
� 2005 to 2007 3% reduction factor each year
� 2008 to 2010 4% reduction factor each year
� 2011 to 2013 5% reduction factor each year
� 2014 to 2016 6% reduction factor each year
As regards future waste arisings, the EPA-led National Waste Prevention Programme
was forecast, in the Final NBWS, to be the prime mechanism for achieving reductions
in biodegradable waste, along with ‘related initiatives’. 135 As discussed elsewhere,
there appears to have been little or no attempt to model exactly which measures
would contribute what level of reduction, and hence, contribution to the reduction
targets set. 136
Targets were set for home composting, the aim being to ensure this takes place at
20% of urban households and 55% of rural households – equivalent to some 35% of
all households - by 2010. It was anticipated that potential yield from this would be
between 10% to 12% of available organic waste in the years 2010 and 2016.
133 DOEHLG (2004) Draft National Biodegradable Waste Strategy. 2004
134 DOEHLG (2004) National Overview of Waste Management Plans, April 2004.
135 DoEHLG (2006) National Biodegradable Waste Strategy, 2006.
136 Eunomia with Tobin (2007) Waste Policy, Planning and Regulation in Ireland, Report for Greenstar.
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6.3.4.2 Waste Recycling
The Strategy states that source separation is the key to maximizing recycling. The
Strategy details recycling rates for paper and cardboard in order to meet the overall
landfill diversion targets for BMW. It states that a combination of kerbside collection
and centralised reception facilities (Recycling Centres and Bring Centres) will be
employed to achieve these. They are set in terms of the capture of paper and
cardboard:
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� 45% for households and 61% for commerce in 2010, corresponding to 55% of
overall paper / cardboard generation within BMW;
� 55% for households and 71% for commerce in 2013, corresponding to 65% of
overall paper / cardboard generation within BMW; and
� 60% for households and 73% for commerce in 2016, corresponding to 67% of
overall paper / cardboard generation within BMW.
In relation to recovery infrastructure, the Strategy states that there is a requirement to
expand the existing Materials Recovery Facility (MRF) capacity in all regions to accept,
separate, grade and bale various paper grades and can do so in parallel with recovery
of other wastes such as packaging.
The majority of recovered paper and cardboard in Ireland is exported (mainly to the
UK) into an international market for waste paper. The Strategy states that
mechanisms which will lead to a rapid expansion in recycling include promotion of
separate collections, restricting disposal outlets, restricting illegal activities,
developing markets and producer responsibility mechanisms.
For organic waste, the targets were:
� 40% coverage for households and 60% coverage for commerce in 2010 at an
estimated average yield of 45% to 60% respectively, corresponding to 25% of
overall organic waste generation within BMW;
� 45% coverage for households and 70% coverage for commerce in 2013 at an
estimated average yield of 50% to 65% respectively, corresponding to 33% of
overall organic waste generation within BMW; and
� 50% coverage for households and 70% coverage for commerce in 2016 at an
estimated average yield of 55% to 70% respectively, corresponding to 36% of
overall organic waste generation within BMW.
The NBWS also includes proposals for regulations banning the following materials
from mixed collection and landfill:
� Office Paper 2006
� Green Waste 2007
� Food Waste 2008
The NBWS also proposed that producer responsibility initiatives for the following
materials should be developed;
� Newspaper and magazines; and
� Telephone directories,
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whilst initiatives for unsolicited mail and textiles were also mooted.
Finally, a Strategy Implementation Group was to be established to co-ordinate the
Strategy’s implementation.
6.4 Summary
Policy statements on waste management have blown somewhat ‘hot and cold’ where
waste prevention and recycling policy measures have been considered.
6.4.1 Waste Prevention
In the national documents, the following policies (or consideration thereof) relating to
waste prevention have been mentioned (and we indicate where they have been
implemented):
101
� Requiring businesses to conduct waste audits and implement waste reduction
programmes (not implemented);
� Promotion of re-use of non-packaging materials through, inter alia, use of
economic instruments and producer responsibility obligations (not
implemented);
� Mandatory re-use systems for packaging to be considered in appropriate
circumstances in order to ensure that the requirements under the Packaging
Directive are fulfilled (not implemented); and
� On non-packaging materials, National Waste Management Board to advise on
what practical measures can be taken to further encourage the re-use of nonpackaged
products (not implemented, National Waste Management Board
never established).
In addition, the following were mentioned:
� Establish a National Waste Prevention Programme (implemented);
� Education / provision of information (implemented);
� Waste exchanges were also highlighted as an approach to enhance re-use
(implemented locally);
� A target for home composting to be carried out at 35% of all households
(mentioned but not actively pursued);
� Charity shops were also the subject of some discussion (already in existence);
and
� Develop guidance on refurbishment and re-use of IT equipment, including
computers (in place).
The Biodegradable Waste Strategy expects great things from the National Waste
Prevention Programme, but little information was provided to indicate how it was
expected that this would generate the significant reductions in biodegradable
municipal waste, relative to trend, envisaged in the document.
A review of various policies and initiatives that have influenced household and nonhousehold
waste prevention can be found in other Annexes to the Policy Review. It
International Review of Waste Policy: Annexes

should be noted that in the case of some of the policies outlined, waste prevention
may not have been the primary objective, but nevertheless several of the policies
outlined have influenced, at the margin (and could be designed to influence more),
household and non household waste prevention and hence the reason for their
inclusion.
6.4.2 Waste Recycling
With respect to recycling, the following policies are highlighted in the national policy
documents (a number of policies mentioned above under waste prevention relate to
recycling also):
102
� Pay-by-use (implemented, although the policy of universal application has
probably not been fulfilled. In addition, many households do not avail
themselves of any collection service);
� Landfill levy (implemented, although charge levels remain low; see Annex
11.0);
� WEEE Regulations came into effect in Ireland in August 2005. Data from the
National Waste Report 2007 suggests that in 2007 Ireland exceeded the
recovery targets with the exception of the category “large household
appliances” (77% versus 80%);
� ELV Regulations came into effect in Ireland in June 2006. A supplementary
fact sheet to the National Waste Report 2007 containing this information will
be published in April 2009. The EPA is also currently compiling the Annual
Report 2007 on end of life vehicles. This is due to be published in June 2009;
� Batteries Regulations came into effect in Ireland in September 2008. As this is
a new policy, analysis of the effectiveness of this policy will not commence
until end February 2009;
� Establishment of a Market Development Group (MDG) tasked with promoting
the development of markets for recycled materials. The Market Development
Programme aim is to fully harness existing outlets in addition to identifying and
developing new, reliable and stable markets for recycled materials in Ireland.
(implemented by the DoEHLG in July 2004);
� Segregated Collection of Organic Waste (implemented in July 2008 via a
Circular to all City and County Managers, though this has not as yet been rolled
out in all local authorities);
� Producer responsibility initiatives for newspaper and magazines, telephone
directories, textiles and unsolicited mail (not implemented);
� A ban on following materials from mixed collection and landfill (not
implemented, though the Pre-treatment Guidelines of the EPA will lead to a
ban, in due course, on the landfilling of untreated residual waste).
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7.0 Pay-By-Use - Ireland
7.1 Outline of Policy
Pay-By-Use (PBU) charging for domestic waste collection was first outlined in a policy
context in a Circular Letter from the Department of the Environment, Heritage and
Local Government (DoEHLG) in 2004, Circular WIR/09/04, sent to all Directors of
Service in all local authorities. 137 The Circular letter gave substance to the Minister’s
announcement of 2004. The Circular refers to the Minister’s announcement,
103
“Made last March (2004), in which he set 1 January 2005 as the date for the
completion, nationally, of the changeover to the weight or volume based
charging systems for the collection of waste.”
It goes on to say:
“In order to get a firm indication on developments, I would appreciate if you
would forward a note indicating progress made to date on achieving the 1 Jan
target, and the expected position at 1 January 2005 in so far as collectors in
your functional area of responsibility are concerned”
“Where a final pay-by-use service is not likely to be in place by 1 January
2005, it is important that an interim solution be in place by that deadline.
Where this is the case, please give details of the interim solution and indicate
the likely date for final implementation of the service”.
Circular WIR/09/04 indicates that Local Authorities are expected to have received
information for their functional area on the ways in which PBU would be implemented
from all waste collectors.
In addition to the deadline set for the introduction of PBU ordered by the Minister and
in the Circular, legislation was introduced in 2007 with regard to charging for the
collection of household waste collection. The Waste Management (Collection Permit)
Regulations, 2007 (SI No. 820 of 2007), do not specifically mention pay by use
systems in terms of volume based or weight based collection charging, but refer more
generally to the ‘polluter pays principle’. Sub-article 20 (2), part (h) states:
“Notwithstanding the provisions of sub-article (1), the nominated authority
shall attach to each waste collection permit granted by it, conditions requiring
the permit holder to” – (h) “apply charges for household waste collection with
respect to the polluter pays principle”.
It may be noted that Sub-article 20 (3), part (c) states:
“The nominated authority may attach to each collection permit that may be
granted by it” – (c) “conditions to encourage sound environmental
137 Circular WIR/09/04 RE: Weight/Volume related Waste Charging sent to the Director of Services in
all local authorities on the 11 Sep 2004.
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104
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management of waste and in particular to encourage waste prevention, reuse,
recycling and recovery as set out in, but not limited to, those conditions in
section 34(7) of the Act”
The instruction in the circular suggests that customers can no longer be charged a
flat rate for waste collection services. Instead, customers will pay by volume or weight
of waste placed out for collection. An EPA report reviewing PBU domestic waste
charging in Ireland, identified and defines three types of charging systems in use in
Ireland: volume-based systems, tag-based systems and weight-based systems: 138
� Volume-based systems require householders to subscribe to a weekly bin
collection, for which they pay an annual charge. This system is considered PBU
as householders can select the size of bin they subscribe to; the annual
charge is based on the volume of the bin, with larger bins incurring a higher
annual charge;
� Tag-based systems include both tag-a-bag and tag-a-bin. These involve
householders purchasing tags to attach to their bag or bin with collectors
picking up only those bags and bins with the appropriate tag attached. The
system is considered PBU as householders only pay for waste collection when
they place bags or bins out for collection. In effect, this implies charging on the
basis of frequency;
� Weight-based systems involve householders paying per kilogram of waste
placed out for collection. The waste collector weighs the bin and bills the
householder based on this weight.
Some charges are implemented on the basis of a combination of these systems, e.g.
both based on volume and on weight.
In addition to setting the collection fee based on more than one system above, some
collectors also introduced a standing charge (usually an annual standing charge),
which was payable as a partial element of the total fee structure, in addition to any
variable element. Schemes vary between local authorities but commonly under a PBU
charging system eligible householders are not required to pay a set standing charge
for waste collection, and instead are only charged based on the volume/weight of
waste they present for collection. 139 Although all waste collectors, both public and
private, were given the deadline of 1st January 2005, by which to implement the pay
by volume/weight charging, not all collectors introduced the revised charging
structure, and some continued to levy only a flat rate charge after that date.
138 A. O Callaghan-Platt and A. Davies (2007) A Nationwide Review of Pay-By-Use Domestic Waste
Charges in Ireland, Interim Report to the EPA.
139 EPA (2008) A Nationwide Review of Pay-By-Use (PBU) Domestic Waste Collection Charges in
Ireland, Strive Report Series 9.

One of the waste management commitments in the Programme for Government is to
ensure that ‘flat rates on waste disposal will be abolished and a mandatory system of
weight-related charges for waste collection introduced.’ 140
7.2 Policy Context and Reason for Introduction
PBU domestic waste pricing charges households per unit of waste placed out for
waste collection. A kilogram of waste, a bag of waste and a bin of waste, for example,
can all be considered a unit for waste charging purposes. PBU charges were deemed
appropriate by the Department of Environment, Heritage and Local Government
(DoEHLG) as a means to implement the ‘polluter-pays principle’ in the waste
management sector.
The decision to introduce PBU domestic waste charges was made on the back of a
number of key waste policy documents released by the Department (see Annex
6.3.1.1). PBU charges were selected for implementation as a route to reducing
Ireland’s dependence on landfill and increasing Ireland’s recycling rates to reach the
national target for 2013.
Such charges give the public a financial incentive to reduce the amount of waste
produced and presented for collection and disposal. In theory, PBU charges send a
more accurate pricing signal for generation of refuse and therefore encourage
householders to reduce waste, recycle more and change waste management
habits. 141
7.3 When was the Policy Introduced?
The policy context, as mentioned in the section above, means that even prior to the
Ministerial Circular and the 2007 Waste Collection Permit Regulations, charging for
waste collection to householders had been gradually becoming more widespread:
In 2004, the deadline for the implementation was set out in Circular WIR/0904, ‘for
the completion of the changeover to weight or volume based charging systems was
set as 1st January 2005’. Given that recent research suggests that the changeover is
still incomplete, this indicates a lack of monitoring and enforcement of the expected
change.
140 EPA (2008) A Nationwide Review of Pay-By-Use (PBU) Domestic Waste Collection Charges in
Ireland, Strive Report Series 9
141 D.V. Nestor and M.J. Podolsky (1998) Assessing incentive based environmental policies for
reducing household waste disposal. Contemporary Economic Policy 16(4): 401-411; V. Linderhof, P.
Kooreman, M. Allers, and D. Wiersma (2001) Weight-based pricing in the collection of household waste
the Oostzaan case. Resource and Energy Economics 23 (4) 359-371.
105
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7.4 Key Organisations Involved in Implementation and
Management
The DoEHLG is responsible for the overall policy context set out in the documents
published since 1997. The DoEHLG and the Minister for the Environment were the
bodies, which instituted the change across the board in 2004.
As mentioned above the DoEHLG and the Minister take an overall position of
guidance in the area of the management of household waste. On-going circulars are
issued to Local Authorities, and via Local Authorities to private waste collectors.
Local Authorities are responsible for the issuing of waste collection permits within
their administrative area, under the waste management regulatory framework. In
2001, two statutory instruments were introduced regulating the issuing of collection
permits for waste management operators, these being the Waste Management
(Collection Permit) Regulations, 2001 (SI No. 402 of 2001) and the Waste
Management (Collection Permit) (Amendment) Regulations, 2001 (SI No. 540 of
2001). The 2001 Regulations were revoked and superseded by the Waste
Management (Collection Permit) Regulations, 2007 (SI No. 820 of 2007) and the
Waste Management (Collection Permit) (Amendment) Regulations, 2007 (SI No. 87of
2008).
Domestic waste collection across Ireland is provided by a variety of methods, namely:
106
� Exclusively by the local authority;
� Exclusively private waste collection companies; and
� A combination of local authority and private waste collection companies.
Hence, Local Authorities and private waste operators are involved in the collection of
household waste and, therefore, in the charging of collection fees to customers.
It may be noted that the fee structure charged by either Local Authorities or private
operators is currently not regulated (a variety of charging methods exist). This is
described further in the section on implementation costs. Therefore, the Local
Authorities (or indeed any other bodies) are not specifically involved in confirming that
customers are being charged, or that the level of cost recovery from the charge levied
encapsulates the environmental costs.
The experience of Cork County Council in attempting to enforce variable changing in
the county, as identified in the Fehily Timoney report referenced in Section 7.5.1 of
these Annexes, talks of the difficulties encountered in attempting to ensure that all
private waste collectors operating within the County introduced a DVC mechanism.
While the council operated services took the lead in the introduction of pay by weight
systems, the council was limited in term of sanctions that could be imposed or
enforced on operators, allowing many to continue with flat fee services.
7.5 Monitoring and Measurement Techniques Applied
Both the EPA and DoEHLG are involved in a supervisory role in the overall
implementation of waste management in Ireland. Local Authorities and Private
Operators are obliged to provide data on waste collection, recovery and disposal
volumes to the EPA for analysis on the regional and nationwide trends and for
29/09/09

eporting in the Annual National Waste Reports. These data and figures collated and
reported by the EPA are used by all stakeholders in the analysis of the current status
of the waste management infrastructure and in assessing ways of moving forward, as
mentioned in the section below on monitoring.
The EPA carried out a review in order to discern how PBU charges impact on domestic
waste management activities such as waste presentation, waste recycling and illegal
waste diversion. The nationwide review was conducted by collating figures on waste
management behaviour and data on PBU charges for each of the 34 local authorities
in Ireland.
The high level of private sector involvement in waste collection means that in many
cases local authorities have little control over access to information on waste
collected or recycled, on systems and levels of charging and on waiver systems. This
prohibits effective and accurate monitoring and assessment of the effectiveness of
PBU systems.
7.5.1 Evaluation Studies Available
A number of studies have been completed these include:
107
� Davies, A., Meade, F., Taylor, D. (2005) Environmental Attitudes and
Behaviour: Values, Actions and Waste Management, Final Report, Final Report
Prepared for the EPA, by the Geography Department, Trinity College Dublin,
Authors: ERDTI (2001-MS-SE2-M1)
� Scott, S., Watson, D. (2006) Introduction of Weight-Based Charges for
Domestic Solid Waste Disposal, Final Report Prepared for the EPA by the
Economic and Social Research Institute, (2000-DS-6-M1)
� O’Callaghan-Platt, A., Davies, A. (2007) A Nationwide Review of Pay-By-Use
(PBU) Domestic Waste Collection Charges in Ireland: Extensive Survey
Findings (2005-WRM-MS-33) Interim Report, Report for the EPA, Department
of Geography, School of Natural Sciences, Trinity College, Dublin
� O’Callaghan-Platt, A., Davies, A. (2008) Nationwide Review of Pay-By-Use
Domestic Waste Charges in Ireland - Case Studies Report
� Fehily Timoney & Company (2008) Direct and Variable Charging for Residual
Waste from Householders, Report for Welsh Assembly Government, December
2008, wales.gov.uk/docs/desh/consultation/090429wastechargingen.pdf
This report contains a number of case studies to charging systems in Ireland in
Appendix 1 of the document, with the most detail to be found in the Cork
study.
� ESRI (2009) An Economic Approach to Municipal Waste Management Policy in
Ireland, Preliminary Report for Dublin City Council, 27 July 2009.
7.6 Environmental Benefits
Summary findings of the 2006 report include:
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108
� Charges by weight are a strong incentive to reduce one’s weight of rubbish.
The move from a flat-rate charge to the pay-by-weight charge resulted in a 45%
reduction in waste collected in one sample area;
� Weight reductions varied by socio–economic characteristics of the household;
� Recycling was the key to waste reduction, but at the time it was only glass
recycling facilities that were widely considered to be convenient;
� There are economies of scale of waste generation and waste reduction with
respect to numbers in the household, which are estimated in this study. The
amount of waste per head decreases with increasing numbers in the
household, though at a diminishing rate;
� The overwhelming majority of the population have not experienced others
using their bins. Experience of this tends to be confined to those in rented
accommodation;
� With respect to attitudes to charges, an overwhelming majority say that they
would prefer the new pay-by-weight system to having to pay through other
means, such as through increased income taxes; and
� The majority say that the new pay-by-weight scheme is fair. However, fairness
is not the verdict of over a quarter of respondents.
Summary findings of the 2007/2008 reports include:
� Following the introduction of the PBU systems, a decrease in the amount of
waste presented by households has been reported by local authorities;
� Under the pay by weight system, case study areas reported reductions in the
domestic waste presentation rates 142 of between 28% and 61% from the year
prior to PBU up to the most recent report year of 2007;
� Under the tag a bin system case study, waste presentation by householders for
landfill reduced by 38% from the year prior to PBU up to the most recent report
year of 2007;
� It was concluded from the case studies that pay by weight is more effective for
reducing household waste presentation than tag a bin;
� Stage 1 of the study found that out of the survey responses from 34 local
authority administrative areas, pay by weight was only in use in 15% of the
areas for which responses were received, whereas pre-paid tag systems were
in use in 82% of areas;
� Three administrative areas examined in stage 2 of the study had moved from a
flat rate to pay by weight charge. The average reduction experienced by the
three areas in the presentation of waste for landfill (black bin) was 47%
142 The waste-presentation rate is designated as the weight of waste presented by householders for
delivery to landfill by waste collectors.
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109
� In the absence of a kerbside recycling service, pay by weight will still facilitate
waste reduction; one administrative area without kerbside recycling showed a
reduction in the waste going to landfill of 39%;
� Stage 1 of the study found that the only local authority area which does not
have a kerbside recycling service has the fifth highest total waste presentation
rate per person in the country. The Local Authority area with the lowest rate of
waste presentation, offers kerbside recycling collections on a weekly basis
throughout its functional area; and
Negative Impacts of the Policy in relation to pollution prevention
� The 2006 report finds that the number of households stating that they
engaged in burning was alarming and the numbers increasing this activity
under the new price regime more so;
� The systems for monitoring illegal diversion of household waste are not well
developed. The answer to the question of the link between the introduction of
Pay by Use and rates of illegal disposal of household waste is inconclusive.
Stage 2 of the study, including case studies, found that just less than half of
the 30 interviewees experienced increases in illegal diversion of waste
following the implementation of PBU.
The detail of the data for the Cork County Council experience provided in the work for
the Welsh Assembly Government is not sufficient to allow detailed assessment of the
effects of the operated pay by weight schemes. A reduction in kerbside collected
waste occurred between 2005 and 2006, though it is not clear whether this is due to
genuine waste prevention, diversion of waste to civic amenity sites, or illegal activity
such as backyard burning. Total waste collected in the county fell by 3%, but it is not
apparent how many households were using the collection services (whether Council
or private contractor provided). The data suggests that kerbside recycling rates in the
County have improved over the duration within which weight based charging has been
introduced. Percentage recycling rates for contractor provided services (of which the
suggestion is that some may have switched to weight based charging in recent times)
increased from 22% to 26% between 2005 and 2006, and the recycling rate for local
authority services increased from 15-22%. However, the degree to which this may be
an effect of the weight based charge is not clear as other service changes occurred
during this time (additional kerbside recycling services) and there is an admission
that contamination of recycling bins by residual waste was observed.
7.6.1 Benefits of Pay by Use Policy in Relation to Prevention
As mentioned in the previous section the Local Authorities which implement a PBU
system have found there is a decrease of (residual) waste presentation rates. This
finding could indicate that PBU charges have reduced waste presentation rates in
Ireland on a nationwide level. It has not been possible to determine whether this
translates into a genuine impact on waste prevention in the Irish case as the data in
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general does not allow assessment of flows of waste into alternate channels –
recycling, civic amenity sites, direct delivery to landfill, or illegal disposal routes.
ESRI (2009) reports: 143
110
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Although PBU areas saw a decline in waste presentation - 227 kg per person
in 2003 to 219kg in 2005 – many collectors used volume-based charging, a
system that can yield similar (ineffective) results to the flat-rate charging of
waste collection in the past. The average reduction found in this study is quite
low by international standards. And by the end of 2006, six LAs still had waste
collectors operating a flat-rate charge in parts of their functional area
(O’Callaghan-Platt & Davies, 2008a).
An effective PBU system sends a more accurate pricing signal to the
producers of waste than a flat rate, and encourages them to reduce their
waste generation, but the continued use of a flat rate or even bin-size based
charging weakens this incentive to change household and business habits. In
O’Callaghan-Platt and Davies’ survey, it emerged that volume-based charging
is used in 62% of LAs’ functional areas, and that the price difference between
a 140l and 240l bin is quite small, thus explaining in part the weak effect of
the PBU system in Ireland. It is notable that this form of charging is not used
by any public waste collectors. This fact also illustrates the lack of control LAs
have over collection practices under the current permitting system
(O’Callaghan-Platt & Davies, 2008b).
These observations are consistent with international experiences, where
‘subscription-based’ schemes, in which householders sign up for a given service
configuration for a fixed period, lead to minimal incentives, at the margin, for
behavioural change. Stronger stimulus is provided by schemes where ‘frequency’ and
‘weight’ are the bases for charges, with these being up to households to determine
(through tagged, or other identification-based, bag and bin schemes).
7.6.2 Benefits of Pay by Use Policy in Relation to Recycling
The increased proportion of waste which may be recycled is also likely to have been
positive. Recycling rates have certainly increased in recent years, over the time where
pay-by-use has become more commonplace. However, since there have been
considerable service changes during this time no quantitative assessments have
been able to be made.
7.6.3 Negative Impacts of Pay by Use in Relation to Recycling
One negative impact of PBU appears to have been illegal dumping, and an increase in
backyard burning. Scott’s work indicates very high levels of reported burning of waste
143 ESRI (2009) An Economic Approach to Municipal Waste Management Policy in Ireland, Preliminary
Report for Dublin City Council, 27 July 2009.

in case study areas, and an increase in the quantity being burned by those who
engage in the activity after the introduction of charging: 144
111
“The remarkable feature is the 42% of the full sample and the Clonakilty
sample who say they burn household waste. In addition, the number who say
that they are burning more [since the charging scheme was introduced], at
33%, is practically double the number who say that they are burning less, at
17%. This important finding backs up reports that that there has been an
increase in burning occurring since the introduction of the pay-by-weight
regime. Although the numbers of complaints about burning recorded in data
from the West Cork Laboratory are small, they reveal an increase in
complaints since the introduction of the new charging scheme, from an
average of one per year between 1998 and 2002, to seven in 2003, 15 in
2004 and nine in 2005. The numbers undoubtedly understate the true extent
of burning as people are likely to be reluctant to complain. Nevertheless, they
suggest that illegal means of waste disposal, such as burning, are likely to
increase in response to such charges.”
This suggests that the manner of implementation may be affecting the balance of
costs and benefits to Ireland of implementing PBU.
7.7 Implementation Costs
Little information is available on the costs to operators in Ireland of implementing
PBU schemes. For the waste collection system as a whole, anecdotal evidence
suggests that costs may have fallen as presentation rates have fallen.
An associated cost implication of delivering the PBU system, is that in order to
incentivise separating the waste into segregated waste streams at the household
level, the corresponding infrastructure in terms of recycling and recovery facilities
have to be available to the waste collector following collection of the waste, whether
the facility is managed by the same operator, or whether the facility is that of another
operator. Many Local Authorities pointed to a lack of recycling and recovery
infrastructure as the reason behind a delay in the provision and roll out of PBU and
separated waste collection services.
7.8 Response from Public and Industry
One study assessed public responses to PBU in two communities. The key results are
shown in Table 7-1. The majority feel that charging is fair. The authors speculate as to
reasons for views that charging is unfair: 145
144 Sue Scott and Dorothy Watson (2006) Introduction of Weight-Based Charges for Domestic Solid
Waste Disposal, Final Report Prepared for the EPA by the Economic and Social Research Institute,
(2000-DS-6-M1).
145 Sue Scott and Dorothy Watson (2006) Introduction of Weight-Based Charges for Domestic Solid
Waste Disposal, Final Report Prepared for the EPA by the Economic and Social Research Institute,
(2000-DS-6-M1).
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112
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“However, over one-quarter disagree and this may reflect the fact that they
are unfamiliar with the waiver system or that they do not think that the
waivers adequately meet the needs of certain households. They may also feel
that some people generate waste through no fault of their own and yet have to
pay. There is also the issue that tax relief on the waste charge is granted to
compliant customers, but those that are not earning sufficient money to be in
the tax net cannot avail of the relief.”
The most negative attitude was reflected by the 47% of respondents who felt that it
had increased the mess and bother of waste disposal. This might reflect a lack of a
wide scope of recycling service, with only glass recycling considered to be convenient
in these areas.
Table 7-1: Perceptions of the New Pay-by-weight Scheme
Possible views about the new pay-byweight
scheme
Agree
Neither agree nor
disagree
Disagree
New pay-by-weight scheme is fair 64% 8% 28%
New scheme encourages households to
reduce waste
93% 4% 3%
Makes people more aware of the cost of
waste disposal
90% 4% 5%
Better than the old flat annual charge 56% 13% 31%
Better than paying through an increase
in income tax
78% 15% 8%
Scheme has increased mess and bother
of waste disposal
47% 11% 42%
Feel I have enough information on
recycling and other methods
71% 3% 26%
Source: Sue Scott and Dorothy Watson (2006) Introduction of Weight-Based Charges for Domestic
Solid Waste Disposal, Final Report Prepared for the EPA by the Economic and Social Research
Institute, (2000-DS-6-M1).
7.9 Effects on Technical Change / Innovation
PBU has resulted in new waste collection technologies. Under the pay by weight
scheme each residual waste collection vehicle is installed with weighing equipment
designed to weigh wheeled bins as they are lifted into the truck. Every bin is fitted
with a microchip in the underside of the lip of the bin. Each chip has the individual
householder’s details scanned onto it. When a bin is emptied a microchip reader on
the back of the truck sends the information to the on board computer. The
information gathered is then downloaded to an invoicing system and this is how
householders can then be billed in accordance with the weight of waste they produce
for disposal.
Waste collection vehicles with separated compartments within the trucks to allow for
collection of both residual black bin waste and dry recyclables have been developed.
This allows the collection of both types of materials in the same route shift coverage
on the same day using the same staffing (administrative) resource to achieve the
objective. This development has occurred in response to the alternative
administrative cost option of collecting the material in separate trucks, on separate

shifts/by separate staff, which in some cases posed administrative and cost
restrictions to operators.
There are an increasing number of recycling and recovery treatment facilities being
developed in Ireland to deal with the growing amount of segregated recyclable
material. The degree to which charging can be considered responsible for this is
difficult to estimate.
At the household level, it seems clear that one undesirable innovation is the tendency
to resort to (increased) burning of waste. Some households may also choose not to
avail themselves of a service, though whether and how this has changed as a
consequence of PBU is not clear. Others may simply choose to deliver waste direct to
available facilities. On the more positive side, there may be increased sorting of
wastes, and an improvement in waste prevention behaviours. However, an
assessment of the extent of these effects across Ireland is not available.
7.10 Social and Distributional Consequences
A study was completed in 2004 by the Department of Geography in Trinity College, on
“Environmental attitudes and behaviour: values, actions and waste management”. 146
This survey revealed that respondents understood that it was necessary to pay for
waste management. However there was concern that the level of waste charges did
not reflect the standard of service provided. Providing a pay-by-weight system was a
popular suggestion amongst respondents who felt people would then attain a double
benefit for reducing waste– moral (in terms of benefiting future generations and the
environment) and financial (in terms of saving money).
As mentioned above, a study following the introduction of PBU suggested that around
three-quarters of respondents thought PBU was fair.
As mentioned previously, the overwhelming majority of the population have not
experienced others using their bins. Experience of this tends to be confined to those
in rented accommodation. Therefore, evasion of payment in terms of the pollution
pays principle does not seem to occur through use of neighbours bins.
Some Local Authorities point to what they identify as a broader expense base
concerning waste management (over which costs need to be recovered) than that
which is imposed on private operators. There is a divergence among Local Authorities
as to what constitutes their public service obligations in the provision of waste
management services. Some Local Authorities point out that there is no specific
obligation placed upon them under the Waste Management Acts to provide a
household waste collection service, and in some cases have withdrawn totally from
household waste collection; other Local Authorities interpret their public service
obligations as requiring the provision of a networked waste management service,
where the efficacy and efficiency in the provision of household waste collection is
influenced by the costs of provision of other service elements e.g. infrastructure in
146 EPA /TCD Anna Davies, Frances Fahy Honora Meade & David Taylor (2005) Environmental
Attitudes and Behaviour: Values, Actions and Waste Management,
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terms of waste processing and disposal facilities and programmes for education and
prevention.
As a result of this, those Local Authorities who have remained in the household waste
collection system, have identified difficulties in recovering (what they feel are) the
total costs incurred in the implementation of the PBU / separated household waste
collection service at a price competitive with collection fees charged by other
operators in the market.
7.11 Complementary Policies
A number of policies exist which compliment changes in the presentation of waste at
household level. These policies are complementary because they aim to achieve
some of the same objectives, including the minimisation of waste materials and
household waste generated, and an increase in the amounts being recycled with the
aim of materials and energy recovery. These are:
114
� The Landfill Levy (see Annex 11.0);
� The Circular WPPR 17/08 (see Annex 33.0); and
� The Packaging Regulations.
7.12 Effect of the Policy on Pricing of Resources / Services
The intention of PBU is to give incentives to households to use the waste
management service in a more efficient manner. The degree to which PBU has
achieved this objective depends upon the specifics of the charging mechanism used.
Other things being equal, however, the aim is to ensure that, at the margin,
households consider the quantity of waste they generate and how it is managed.
Although recycling rates have increased, depending upon charging structures used,
the system has the disadvantage of allowing households to believe that recycling is
‘free’. 147 Some pricing structures – possibly most to date – have not highlighted the
fact that collection and processing of all waste, whether black bin, green bin or brown
bin, has associated expenses. The issue ought to be about setting the right price
differentials. Furthermore, offering a ‘free’ recycling service and a relatively high
marginal charge on refuse may have the effect of increasing the level of
contamination of the recycling containers if, at the margin, the incentive is high, and
the potential for quality checks is low (as it undoubtedly is with bin-based recycling
schemes).
In addition some Local Authorities have been dissatisfied with the lack of
transparency in the charging systems used by private waste collectors within their
functional area. The local authority state that itemised bills are not issued to
householders by collectors (at least in the case of fixed fee, tag based or potentially
volume based charging) prompting the concern that the reduced waste to landfill is
147 A. O Callaghan-Platt and A. Davies (2007) A Nationwide Review of Pay-By-Use Domestic Waste
Charges in Ireland, Interim Report to the EPA.
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not reflected in reduced costs to consumers. This may reduce householders’ ability to
see the real benefit of source reduction. 148
7.13 Evasion and Enforcement
Where pay-by-use is concerned, households’ response to charging for services is to
seek to reduce exposure to the charge. This can take forms which are both legal and
illegal in nature. Some, such as burning, are not illegal per se, but they may cause
nuisance. Emissions from domestic premises are covered under the Air Pollution Act
1987. This Act gives local authorities the lead role in control of air pollutants from
premises. Section 24(2) of the Act imposes a general obligation on the occupier ‘not
to cause or permit an emission in such a quantity or in such a manner as to be a
nuisance.’ The Act, though somewhat unspecific, is of significance to domestic
burning, though it is not exactly clear what constitutes a nuisance. The responses to
the survey could under-represent the amount of burning if householders are aware of
the Act and it is possible that there is uncertainty in the public mind about the legality
of burning and about differentiation by material.
In 2005 the EPA published a Report on “The Nature and Extent of Unauthorised
Waste Activity in Ireland”. This report sets out the findings of a nationwide
investigation by the EPA’s Office of Environmental Enforcement (OEE) on the nature
and extent of unauthorised waste management activities in Ireland from the period
1996 onward. This report stated:
115
“every year, in the region of 287,000 tonnes of household waste is not
presented for collection with this waste being disposed of by the householders
themselves. Many local authorities have reported recent increases in
backyard burning and fly-tipping of household waste which, anecdotally, is
being linked to the increases in household waste charges” 149 .
There appears, therefore, to be a problem in terms of lack of enforcement of matters
related to illegal tipping and burning in the Irish context. The extent to which this is
something which would occur in the absence of charging is unclear, though it seems
reasonable to believe that these are matters which are problematic even in the
absence of PBU, but which PBU exacerbates.
One can also argue that some collectors have evaded, or are still evading, the
requirement to implement PBU. By not enforcing the requirement to make PBU
mandatory, local authorities allow collectors to continue to operate on a flat fee basis.
Concerns have been raised by local authorities that they had little ability to enforce
PBU systems if private collectors did not use them. In principle, permits for private
waste-collection companies could contain more requirements with regards to PBU
charges, with the threat of revocation of the permit if a PBU system is not
implemented by the collector.
148 A. O Callaghan-Platt and A. Davies (2007) A Nationwide Review of Pay-By-Use Domestic Waste
Charges in Ireland, Interim Report to the EPA.
149 EPA (2005) The Nature and Extent of Unauthorised Waste Activity in Ireland, EPA, 2005.
International Review of Waste Policy: Annexes

7.14 Lessons Learned
7.14.1 General Lessons
Most policy statements regarding waste have assumed that there will be benefits to
be derived from implementation of PBU. However, the benefits are likely to be
assured only where conditions are such as to maximise the benefits and minimise the
potential for perverse consequences.
There are a growing number of studies evaluating PBU in Ireland. These seem to have
been conducted mainly from an academic perspective, with less attention given to
key operational issues than may be warranted. Evidently, illegal dumping and burning
are problematic, but even those studies which highlight this as an issue make no
recommendations as to how this should be addressed. As such, it is not clear that
lessons are necessarily being learned in respect of implementation of PBU in Ireland.
Key issues, in our view, relate to the current level of service coverage, to the nature of
charging structures, and to the simple fact that households are not required to avail
themselves of the collection service.
One study suggests that pay-by-weight is generally believed to be more effective at
reducing the quantity of household waste sent to landfill compared to tag-based
systems. However the nationwide survey (Stage 1) found that pay-by-weight was only
in use in 15% of local authorities, whereas tag-based is in use in 82% of local
authorities in the country. The study suggests that as pay-by-weight is more effective,
there maybe a requirement to incentivise this form of PBU. However, there are likely
to be more fundamental issues which need to be considered regarding
implementation of PBU in Ireland, notably the degree to which implementation can be
expected to lead to the most advantageous outcomes where the market for collection
is configured as a free one.
Of some interest is the fact that although several studies purport to address the
economics of waste collection, the focus has been on behavioural responses (what
charge gives what outcome in terms of waste quantities), and still, there is a paucity
of studies seeking to understand the implications of different approaches to PBU for
the costs of service provision (as opposed to quantities of waste). The costs of
collection systems are affected by the frequency of pick-ups, and whilst weight-based
charges are likely to generate marginal reductions in the weight of waste set out, they
do not necessarily incentivise reduced set-out frequencies (and hence, collection
costs). Indeed, they can, in the absence of shifts in frequency, lead to inefficient
logistics in terms of the costs of collection of refuse. More work is warranted on
understanding collection costs (that is to say, costs, not charges – the two are not
necessarily the same in the Irish market), and the effect of the charging approaches
on these in Ireland.
Generally, in Ireland, implementation of pay by use systems may be considered
somewhat unique. In many regions, it remains the case that large proportions of
households are not ‘connected’ to any household waste collection system. In the
absence of thorough recycling and composting collection systems, and with the
choice of residual waste service provider left to the individual household pay by use is
likely, in some regions, to have reduced the number who avail themselves of any
collection service. The risk here is that illegal behaviour becomes widespread, and the
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extent to which this compromises any attempts to model household behavioural
responses in this regard is not entirely clear (not least since the quantities within and
without the collection system may change if households decide to opt-in or opt-out as
a consequence of the charging system itself). This issue of the effect of charges on
actual service take-up is also not widely explored in the existing literature. Its
relevance in Ireland stems from the absence of a requirement on households to use
the waste collection service.
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International Review of Waste Policy: Annexes

8.0 Pay-by-use - International
8.1 Outline of Policy
Charging for waste (commonly referred to under a variety of titles including ‘User
Pays’, ‘Differential and Variable Rate charging’ (DVR), ‘Pay-As-You-Throw’ (PAYT), or
‘Pay-by-weight’ charging), is an approach whereby a business or individual is subject
to a fee which is linked to some quantitative measure of waste set out for collection.
National government has the authority to prescribe in law the rights and
responsibilities of the local authorities or municipalities responsible for organising
and administering waste management. Typically, this will either allow (for example
Germany, Italy, Ireland) or prohibit (for example England) local authorities from
charging households for waste services. 150 It is often up to the discretion of individual
authorities how charging systems are operated on the local level. Some countries,
such as South Korea, and some regions within countries, have made pay-by-use
mandatory.
There are a number of different motivations for introducing charging schemes. These
include cost recovery, creating an economic incentive to reduce waste, and/or
creating an economic incentive to recycle or recover waste, as well as improving data
collection and the efficiency of collection logistics. A typical pay-by-use approach is
shown in the following ideological pricing structure, with the total fees paid covering
the full costs of collection, recovery, treatment and disposal, as well any monetised
environmental damage costs (where environmental taxation can be used to offset
damages caused):
118
� Flat rate service provision fee;
� Recycling – zero or low variable fee;
� Organic waste – zero or low / medium variable fee;
� Residual waste – higher variable fee.
Economic theory suggests that there are likely to be two responses where services
are charged for:
� Reduction in demand for the service (output effect); and
� Resort to alternatives (switching effect).
As such, the strongest impact on waste prevention may be expected where a charge
is placed on all collection streams, including recyclable materials. The charge
differentials ought to be significant enough to encourage separation, the recycling fee
low enough to maintain use of the service but still sufficient to promote prevention,
150 Section 45 of the Environmental Protection Act 1990 states “No No charge shall be made for for the the
collection collection of of household household waste waste except in [specific] cases…” and furthermore “It shall be the duty of each
waste collection authority… to make such arrangements for the emptying, without charge charge, charge
of privies
serving one or more private dwellings…”
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and residual waste fee not so great as to encourage illegal disposal. The flat rate fee
element is important to help balance these objectives. It can also be used to ensure
that the costs of service provision are covered, even where waste prevention and
recycling behaviour improves significantly (in which case, in the absence of a flat fee
raises the issue of revenue instability).
The range of approaches to pay-by-use includes systems where households are
charged based on:
1) The weight of material set out;
2) The volume of material generated;
3) The frequency of collection; or
4) A combination of these factors.
The following sections describe the approach used in particular countries and, based
on a desktop evaluation of available literature, assess the success of particular
approaches and the impact on waste prevention.
8.2 Where Has the Policy Been Applied and Why?
The following sub-sections give the background to selected countries which operate
waste charging systems. Assessment of the systems, and other evidence where
available, is given under the standard headings used through this report in the
sections that follow. Section 8.5 of this report in particular attempts to assess the
impact of charging on waste prevention and recycling. This is done by drawing
evidence from individual case studies to assess particular charging mechanisms,
rather than by assessing charging on a country by country basis (which would disguise
the impacts of particular locally implemented approaches).
We have focussed our attention on a range of examples from counties where lessons
can be learnt from the charging systems employed.
In individual countries, different parts of the infrastructure may operate somewhat
differently. In particular, the scope of kerbside collections in countries such as
Denmark tends to be very narrow (sometimes, just paper and card and glass are
collected at kerbside). In the Netherlands, the scope tends to include biowaste (and
prior to the introduction of charging systems, garden waste has typically been
collected free of charge), though it does not always include all packaging fractions. In
other countries, notably Belgium, Austria and Germany, the scope of kerbside
systems is much more comprehensive. Bring sites tend to be more important in
countries such as Denmark, the Netherlands, Sweden and Norway. Of course, there is
local variation in the scope of kerbside collection schemes in most countries, but this
is less true in countries / regions where:
119
� Ordinances are in place for the collection of biowaste (Austrian, Germany,
Catalonia (Spain), Flanders (Belgium), and ‘voluntarily’ in the Netherlands);
� Producer responsibility (see Annexes 19.0 to 26.0) measures require
commodity related organisations to fund, more or less completely, the
kerbside collection of various materials, notably packaging materials
(examples of ‘full financial responsibility’ being Germany, Austria, Belgium);
International Review of Waste Policy: Annexes

120
� There are stipulations as to which materials should be collected and with
which frequency (most notably, Flanders in Belgium).
In these cases, local variation is somewhat reduced. Some examples of how the
approach is implemented in different countries is given below.
8.2.1 Denmark
In Denmark, municipalities (local councils) are responsible for managing all waste,
including municipal waste generated in their territories. Responsibilities include
collection, transport, sorting, storage, composting, recycling, incineration, treatment
and disposal of waste.
Pursuant to the Environmental Protection Act, municipalities can determine a fee that
covers the costs of planning, establishing, operating and administrating waste
collection schemes, and of establishing and operating waste processing and disposal
facilities, the collection and registration of information, and advance payment of
planned investments in the field of waste management. As such, in almost all
municipalities, the costs of waste management are fully covered by fees.
Waste fees are typically collected on the same bill as the real estate tax. Earlier in this
decade, just 6 of the 275 municipalities were presenting a separate bill. 151
Of the municipalities that have a differentiated waste fee, most have a weight-based
payment system, a few have volume-based payment system. Approximately 10% of
Danish municipalities have weight-based schemes for household and small
company/institution waste. The first scheme was introduced in 1991 in Tinglev
municipality.
All the municipalities that have introduced a weight-based collection scheme are
small or medium-sized rural municipalities with few multi-storey buildings. Other
municipalities charge an additional fixed fee if the amount of waste set out by a
household exceeds the amount on which the fee is calculated (e.g. two bags instead
of one).
8.2.2 Italy
The National Waste Management Act (Decree 22/97, also called the Ronchi Decree)
in Italy delegates the responsibility for organising the collection, transport and
disposal of municipal and comparable waste to municipalities (Article 21). Municipal
tasks mandated by Decree 22/97 include:
� Organization of collection of MSW and its transportation to treatment and
disposal facilities. This can be done also in association with other
municipalities;
151 Eunomia (2003) To Charge or Not to Charge? Final report to IWM (EB). Referred to hereafter as the
‘IWM charging review’.
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121
� Choosing collection schemes and tools most suited to achieve the targets
mandated by the Decree (e.g. doorstep collection, road containers, civic
amenity sites, etc.)
� The assessment of contributions for the MSW tax; this includes specific
parameters to be defined for each category (type of dwelling, commercial
activity, etc) and tax savings for households with low incomes or belonging to
particular categories (e.g. with a single person, or doing home composting,
etc.).
The municipality has to consider any guidance or guidelines issued by Institutions at
higher levels (districts, provinces, etc.), though adherence to such guidelines is not
compulsory; in particular, the strategies defined by the Waste Management Plan
issued by the region and/or the province have to be considered.
Before 1999, all businesses and citizens in Italy paid a waste management levy
(typically based on the size and type of property) related to the overall cost of waste
management but unrelated to the individual quantities of waste produced. This
meant cross-subsidisation of high waste producing households by low waste
producers, as well as subsidisation of household produced waste by businesses.
Along with the Ronchi Decree, the Decree of the President of the Republic 158/1999
provides the basis for a new system of waste management charging based upon ‘payby-use’
systems. It was the Ronchi Decree which first gave voice to the principle of
pay-by-use, but although the Decree contains this as a general principle, it is the later
Decree which provides for implementation details. It was intended that as of January
2008, all municipalities would be operating a variable charge system constituting two
parts:
� A fixed portion determined by the basic components of the service, particularly
investment and depreciation;
� A variable portion linked to the quantity of waste produced, service provided,
and management costs, in order to ensure full coverage of investment and
operational costs.
Further simplified details on fee structuring from the legislation are given in Table 8-1.
Table 8-1: Parameters for Application of the Fee in Italy
Type Type of of user user
Terms Terms for for determining determining the the fee fee
Reduction
Reduction
Fixed Fixed portion portion
Variable Variable portion portion
Variable Variable portion
portion
Household
Household
Non-
Non
household
household
Area and factor relative
to the size of the
household
Area and waste
production factor per
activity
International Review of Waste Policy: Annexes
Quantity of waste produced and
factor relative to the size of the
household
Quantity of waste produced and
production factor per activity
Participation in
sorting schemes
Waste intended for
recovery
Source: The IWM charging review: Eunomia (2003) To Charge or Not to Charge? Final report to IWM(EB)
It may also be noted that collection of dry recyclables is partially subsidised by the
producer responsibility organisation, the National Association of Packaging Producers
(CONAI). Each municipality receives financial support proportional to the quantity and

quality for materials collected, though this typically only partially covers the collection
costs for these materials. Producer responsibility for packaging and other materials is
studied separately in Annexes 19.0 to 26.0.
8.2.3 United States
In the United States, the role of state government is to develop plans and standards,
while local government implements solid waste policy. Thus, individual states and
municipalities typically develop municipal solid waste (MSW) management plans
within which direct charging systems can be proposed and consulted upon. As such,
charging systems in the U.S. have evolved over time. In the past, markets for waste
were highly decentralised (with householders taking waste to dumps). Once it was
decided to run more formalized collection operations, two main routes were followed:
a) an equivalent to a local authority run collection service, accompanied by local
authority billing, and b) a contract / franchise approach, the key difference being that
in the latter the contractor / franchisee (not the municipality) was responsible for
billing households. 152
Municipalities have been able to pass ordinances asking households to 'hire their
own company', and although examples of this competitive model (similar to the
approaches in Ireland) still exist, a single collector is now the norm.
The number of municipalities using PAYT schemes in the US stands at more than
6,000, covering a population of 50 million. Pay-per-bin and pay-per-bag schemes are
the most commonly used, though weight based systems have seen increasing
prevalence (27 communities in the state of Maine alone by 2006). 153 154
8.2.4 Korea
Korea became the first country to introduce a mandatory DVR scheme country wide
when, in 1995, the volume-based waste fee (VBWF) was introduced. The VBWF is
essentially a pay-per-sack scheme under which households are required to place
residual waste in pre-paid sacks whilst recyclables are collected free of charge.
Charges are also levied on the collection of bulky wastes.
In recent years, the country has introduced free food waste collections for
households, having commenced collections for larger producers of food waste (such
as restaurants) in 1997. In 2005, the landfilling of kitchen waste from households
was banned.
152 Thomas Kinnaman and Don Fullerton (1999) The Economics of Solid Waste Management, NBER
Working Paper 7326, Massachussets, August 1999.
153 Lisa Skumatz (2002) Variable Rate or ‘Pay-as-you-throw’ Waste Management: Answers to
Frequently Asked Questions, Los Angeles: Reason Foundation, July 2002.
154 Jan Canterbury, Sue Eisenfeld (2006) The Rise and . . . Rise of Pay-As-You-Throw, MSW
Management, Elements, www.mswmanagement.com/elements-2006/waste-managementchallenges.aspx.
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8.3 Key Organisations Involved in Implementation and
Management
The usual approach is for national government to write into law the framework within
which local government and waste collectors can operate. In most situations, the
local authority, or a contractor to the local authority, provides the collection service to
householders.
The service is funded typically through a combination of:
123
• Central government taxation;
• Taxes raised at the local level; and
• The revenue from the variable charge element.
As such, the actors involved usually include local, and sometimes, central
government, as well as local government and the service operator, where this is not
the municipality itself.
Concerns generally arise with regard to the issue of fly-tipping. As a result, local
authorities and other competent authorities also have some involvement in the
matter. This may bring environmental protection agencies into play (as an enforcer).
8.4 Evaluation Studies Available
The list of studies that have been undertaken in respect of waste charging is
extensive. However, much of the literature reports only on the high level outcomes in
terms of recycling and waste reduction. Rarely is there much by way of detailed
discussion as to the outcomes of the scheme, and how these might be explained
through reference to the specifics of the charging scheme, and the background
collection system against which charges are introduced. Indeed, this has been one of
the main drivers behind our own attempts to carry out more detailed case studies in
previous work. 155 156 157
Other studies of interest are referred to through the body of this review.
A recent study includes a summarised evidence base regarding the pros and cons of
charging systems with a reference list extending to over 50 case study reviews. The
literature review covered Australia, Austria, Belgium (Flanders and Wallonia), Canada,
Denmark, France, Germany, Italy, the Netherlands, Norway, South Korea, Spain,
155 Eunomia (2003) To Charge or Not to Charge? Final report to IWM (EB).
156 Eunomia (2005) Evaluation of Local Authority Experience of Operating Household Waste Incentive
Schemes, Defra.
157 D. Hogg (2006) Impact of Unit-based Waste Collection Charges. Referred to within the text of this
report as ‘the OECD charging review’. ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
International Review of Waste Policy: Annexes

Switzerland, the US, and New Zealand. 158 We draw heavily from this source for the
details given here and refer to it subsequently as ‘the Defra charging report’.
8.5 Environmental Benefits
Charging for waste has an effect both on waste prevention and on quantities of waste
separated for recycling. Where possible, the two are considered separately in the
following subsections. In the first instance, it is important to establish that when we
talk about the recycling and prevention, that these are proxies for environmental
effectiveness.
8.5.1 Evidence of Environmental Effectiveness
8.5.1.1 Benefits Related to Waste Prevention
Charging for waste can be one of the most direct and influential approaches to
stimulating waste prevention. This was a key conclusion of a review of existing
policies which have potential to encourage prevention of household waste. 159
Because it is a mechanism that acts directly at the point where a product becomes a
waste, it can deliver the incentive to an individual or organisation to change waste
production behaviour. The charges on waste can act to discourage consumption (and
related waste production) and encourage individuals to take management
responsibility for avoidable wastes (for example home composting).
The environmental benefits of waste prevention have been long recognised, and are
reflected as such at the top of the familiar waste hierarchy. However, where municipal
waste is concerned, the environmental benefits are more often assumed than
identified in detail. Indeed, the matter is not entirely straightforward. For example, the
magnitude of the benefits of preventing waste in the form of paper depend upon
whether or not that paper was made from virgin materials or from recycled ones. 160
Consequently, we might assume that the benefits from waste prevention change as
the recycled content of the material / product which is the subject of the waste
prevention activity increases or declines.
Within this section (and indeed throughout this report) we use the proxy that:
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“Waste Prevention = Environmental Benefit”.
This assumption is likely to be a reasonable one whether the effect is on the
hazardousness of waste (which is clearly an environmental benefit) or on the quantity
158 D. Hogg, D. Wilson, A. Gibbs, M. Astley and J. Papineschi (2006) Modelling the Impact of Household
Charging for Waste in England, Final Report to Defra. Referred to within the text of this report as ‘the
Defra charging report’.
www.defra.gov.uk/environment/waste/strategy/incentives/pdf/wasteincentives-research-0507.pdf
159 Eunomia et al (2007) Household Waste Prevention Policy Side Research Programme, Final Report
for Defra, April 2007.
160 See, for example, USEPA (2002) Solid Waste Management and Greenhouse Gases: A Life-Cycle
Assessment of Emissions and Sinks, EPA530-R-02-006, May 2002.

of material generated as waste (since avoiding the production of waste entails a
reduction in primary or secondary material demand and associated reductions in
energy use, hidden material flows, pollution and other general adverse impacts on the
environment and human health).
There are likely to be possible exceptions to this rule. For example, if home
composting of organics effectively prevents the anaerobic digestion of the same
material, then it is possible that there may be a negative environmental benefit.
Home composting does eliminate the environmental impacts associated with
vehicular transport, but these tend to be a relatively minor contributor to the overall
environmental impacts associated with waste (though this assumes that the systems
for collecting waste are efficient ones). In our analysis, however, even though the
environmental impacts of home composting may be inferior to well performing
anaerobic digestion systems, the cost savings implied may justify the loss in
environmental benefit. 161
8.5.1.2 Evidence of Environmental Benefits Related to Recycling
Compared to waste prevention, the environmental benefits of recycling are typically
easier to quantify and, under the majority of circumstances, tend to be positive.
Recycling post consumer waste into new products gives environmental benefits
associated with the avoided extraction of primary materials, and the balance of
energy consumption between manufacture from primary and secondary materials.
Typically, product manufacture from recycled material uses significantly less energy,
and produces less emissions compared with manufacture from primary resources. A
policy guidance note for UK government indicates that recycling paper can entail 28-
70% less energy use, produces 95% fewer emissions, requires less water, and far
fewer raw materials. Similarly, producing aluminium from recycled materials uses only
5% of the energy used in primary production and generates only 5% of the
greenhouse gas emissions associated with manufacture from raw materials. Again,
making carrier bags from recycled plastic consumes two thirds less energy, releases
lower levels of pollutants and uses nearly 90% less water than manufacture from
primary polymer. 162
As such, within this report we also use the proxy that:
125
“Recycling = Environmental Benefit”.
We can, however, look to the literature to confirm this. The OECD charging review
assesses the private costs of waste management considered alongside monetised
environmental costs and benefits associated with avoided energy usage in the
manufacture of products and the reduction in environmental damage resulting from
disposal of residual waste. Of particular interest is the study into the Belgian
experience of Ghent and Destelbergen. Figure 8-1 (taken from the OECD review)
161 See Eunomia (2007) Managing Biowastes from Households in the UK: Applying Life-cycle Thinking
in the Framework of Cost-benefit Analysis, Banbury, Oxon: WRAP.
162 The Parliamentary Office of Science and Technology (2005) Recycling Household Waste, December
2005, POST Note Number 252, www.parliament.uk/documents/upload/postpn252.pdf
International Review of Waste Policy: Annexes

shows improvements made in separate collection due both to improvements in
provision of recycling services and also the introduction of charging in 1998. In the
year 1998 a slight constraint on the overall growth of waste arisings may be
observed, though this is barely discernible and could not be assumed to be
statistically significant. However, separation of materials for recycling is much more
apparent.
Figure 8-1: Evolution of Waste and Recycling in Ghent and Destelbergen
Tonnes Waste Collected
126
120,000
100,000
80,000
60,000
40,000
20,000
0
29/09/09
1995 1996 1997 1998 1999
Year
Others
SDW (small dangerous waste)
Wood
Non-glass Packaging
Electrical & Electronic Equpt.
Metal
Glass
Garden green waste (containerpark)
Separately Collected Biowaste (doorstep)
Paper/hardboard
Demolition waste
Residual waste
Source: Hogg, D. (2006) Impact of Unit-based Waste Collection Charges. Referred to within this report
as ‘the OECD charging review’. ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
The review goes on to assess permutations of costs and benefits associated with
these changes in waste production and separation, the results of which are shown in
Figure 8-2. Because the scheme was introduced in a period where other changes
were being made, the cost benefit is shown for cases where 25%, 50% and 100% of
the effects of the DVR scheme and the enhanced service are attributed to the DVR
scheme. The net costs clearly depend upon the attribution. Attributing all the change
to the charging scheme seems unrealistic and would lead to benefits (cost
reductions) far greater than in the other schemes examined even though the effect on
waste prevention is barely existent in this case. However, even where only 25% of the
effects of the change from 1997 to 1999 are attributed to the scheme, net social
benefits (cost reductions) lie between €3 and €5 per household. It may be concluded
from this not only that recycling leads to a positive balance of financial costs and
environmental benefit (measured as monetised costs), but also that DVR charging
itself can lead to outcomes where the benefits exceed the costs of the change.

Figure 8-2: Balance of Costs and Benefits of DVR scheme, Ghent and Destelbergen
€ per Household
127
€ 5.00
€ 0.00
-€ 5.00
-€ 10.00
-€ 15.00
-€ 20.00
-€ 25.00
-€ 30.00
-€ 35.00
-€ 40.00
25% Effect Attributed to
DVR Scheme
Low Damage
Costs
High Damage
Costs
50% Effect Attributed to
DVR Scheme
Low Damage
Costs
International Review of Waste Policy: Annexes
High Damage
Costs
100% Effect Attributed to
DVR Scheme
Low Damage
Costs
High Damage
Costs
Private Costs
Net External Cost, Time Excluded
Net External Cost, Time Included
Balance of Costs and Benefits, Time Excluded
Balance of Costs and Benefits, Time Included
Source: Hogg, D. (2006) Impact of Unit-based Waste Collection Charges. Referred to within this report
as ‘the OECD charging review’. ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
Within this study, there are few permutations where the system imposes net social
costs. These are where a) a relatively small effect is attributed to the DVR scheme,
and b) where the damage costs used are low (so benefits of avoided disposal and
recycling are smaller). Such a scenario is shown on the left in Figure 8-2. The
situation appears slightly worse where the costs of time are taken into account.
However, even in the worst case the net social costs are of the order €2.00 per
household.
If, on the other hand, the DVR scheme is attributed with a more significant proportion
of the change occurring between 1997 and 1999, then benefits may be as high as
around €10 per household (50% effect attributable) rising to €21-34 if all the change
occurring in the period is attributed to the DVR scheme.
On balance, therefore, and based upon the effects of DVR schemes in similar
situations elsewhere, it seems likely that the DVR charging scheme will have
contributed to the generation of net social benefits. Indeed, perhaps the more
important observation is that, as part of a package, the DVR scheme contributed
(however significantly) to the generation of net social benefits of the order €20-30 per
household. This is one of the key conclusions of the OECD charging review. 163
163 D. Hogg (2006) Impact of Unit-based Waste Collection Charges.
ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.

Although it may be demonstrated that DVR schemes (in the general case) can lead to
positive outcomes, the specific impact of charging on households depends very much
on the services in place and on the charging structure. The key issues are explored
further in the following sections.
8.5.2 General Themes on the Impact of Charging
8.5.2.1 General Themes: Waste Prevention
The evidence in the literature highlights varying results in different circumstances, but
this is generally supportive of the waste prevention effects associated with pay-by-use
schemes.
It is fair to say that although evidence for increased recycling is very strong, not all
studies report considerable quantities of waste ‘being prevented’; however, many
report some effect. The quality of the evidence does not always allow detailed
analysis since the scope of the investigation in the individual studies is not always
clear. A large number of the studies identified in the Defra charging review focus only
on the quantity of waste collected from households for disposal. Frequently, the
headline figure reported is the ‘reduction in the quantity of material sent to landfill or
incineration’.
Where effects on total waste quantities are observed, it is not unusual for this figure
to be in excess of 30%. In these instances, it is not always clear whether this is merely
the effect of waste moving from one place to another (for example through ‘waste
tourism’, illegal dumping, or through waste moving from domestic collection to
commercial collection services or civic amenity sites). Gaining a clear understanding
of the re-routing of waste is not straightforward.
In general terms, associations between charging and waste prevention vary most
greatly with the nature of the charging system as well as the nature of the collection
systems before and after charging commences. Price clearly plays a role. To give a
broad-brush figure, the Defra charging review reports that, depending on scheme
types and charge levels, total waste quantities can fall by 10% and sometimes more
due to pay-by-use systems.
It is often difficult to isolate the impacts of a new charging system since they are
normally accompanied by additional service changes. It is as important to appreciate
the effect of the collection system on waste quantities as it is to understand the effect
of any charge that is levied. The characteristics of garden waste generation are
particularly important in the context of pay-by-use. Garden waste tends to increase in
quantity when collected free of charge, but it can be dealt with reasonably
comfortably in the home where collections are not free (or not in place at all). As such,
the effects of charging (or not) for garden waste must be considered in the context of
the pre-existing collection arrangements. Much greater reductions tend to be
achieved where the system in existence prior to charging included free garden waste
collections, and where the charging system introduces charges for the garden waste
element.
A general shortcoming of most of the available case studies is that they tend to be
based upon ‘before and after’ assessment as though waste quantities are static.
Evidently, what ought to happen is that comparisons should be made against a
128
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counterfactual. This type of approach is surprisingly rare in case studies, though some
reports make comparisons between areas with, and areas without charging systems
in place over a given period of time. Bischof et. al., for example, compares areas with
differential charging in Switzerland (where ‘residual’ waste reduced by 30%) with
areas with a flat fee for disposal (where residual waste collected increased by up to
13%). 164
Even where studies look to assess overall waste reduction, there are some key
caveats which need to be borne in mind when looking at much of the literature:
129
� First of all, and probably most importantly, many studies appear (it is not
always made clear) to concentrate on door-to-door collections of waste and do
not take a ‘whole system’ view (e.g. how the quantity of waste taken to Civic
Amenity (CA) sites changes in the wake of the charging system’s
implementation); and
� Second, there is ongoing discussion as to the underlying cause of the
‘disappearing waste’. Not all studies seek to explain the changes witnessed or
reported.
8.5.2.2 General Themes: Recycling
The effects of charging on recycling are much more broadly recognised and widely
documented, not least because the impact is much easier to measure and
demonstrate in comparison to prevention.
The trends demonstrated in the data in Figure 8-1 shown above for Ghent and
Destelbergen are commonly observed following the introduction of charging schemes
– material separated for recycling increasing significantly. Where prevention effects
are strong, quantities recycled/composted may not increase so sharply, but the
proportion recycled/composted clearly increases. Evidence discussed in the following
sections goes on to qualify observed impacts on recycling in a range of situations.
Three factors in particular have a strong influence on the impact of PAYT schemes:
• The pre-scheme situation. Other things being equal, where there are lower
levels of recycling prior to PAYT, the impact of charging may appear more
significant;
• Recycling system changes. The introduction of PAYT is often accompanied by
improvements to recycling collection systems or centralised recycling facility
provision. This makes the impacts of charging alone less easy to isolate;
• The nature (and level) of charges. We investigate further in the following
sections how different approaches to charging (pay by weight, pay by volume
etc.) tend to perform in operation.
Headline results from the VBWF in Korea have been impressive both in terms of the
impact on waste prevention and recycling. As shown in Figure 8-3, total waste
164 R. Bischof, M. Chardonnens, M. Hugi, M. Textor, D. Lehmann, W. Siebert and K. Ammon (2003) La
Taxe au Sac Vue par la Population et les Communes, Cahier de L’Environment 357, Berne: OFEPF
International Review of Waste Policy: Annexes

production has declined by 15% over the period following introduction of charging in
1995. The amount of residual waste has declined significantly, while the amount of
waste recycled or composted has increased from approximately 15% in 1994 to
nearly 50% in 2004. The quantity of waste recycled has increased by over 250%.
Figure 8-3: Effects of Volume-based Waste Fee in Korea
Waste Qauntity (tonnes per day)
130
70,000
60,000
50,000
40,000
30,000
20,000
10,000
0
29/09/09
1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Year
Residual Waste
Waste Recycled / Composted
Source: Korea Environmental Policy Bulletin, Update Version of Issue 1, Volume 1, January 2006.
Once again, however, the nature of waste collection service and recycling centre
provision is important as this also influences performance. Other things being equal,
a new charging system would be expected to encourage both prevention and
recycling, but any accompanying new or expanded recycling services will lead to a
change in performance whether charges on waste were applied or not.
The following subsections attempt to draw together some individual lessons learnt on
the effects of charging.
8.5.3 Impact of Different Charging and Collection Structures
A general assumption may be made that the order of ranking for both waste
prevention and recycling is likely to be as follows, with the charging system achieving
greatest effect listed first:
� Weight (including biowaste) and frequency based (including biowaste);
� Sack based (including biowaste);
� Weight based (excl biowaste);
� Frequency based;
� Sack based (refuse only);

131
� Bin-volume based (i.e. where households subscribe for a fixed period for a bin
of a given size).
The work by Tønning for the Danish EPA, summarized in Table 8-2, suggests that
weight-based systems deliver the strongest effect both in terms of the reduction in
collected waste and in terms of the increase in recycling. 165 We know that this study
does not include ‘whole system’ wastes, however, so it could not be entirely ruled out
that what is happening is that waste is simply moving through different routes in the
system. Other details of the study – for example, the rates of home composting
quoted – seem to imply that it is unlikely that this could account for all of the
differences across schemes.
Table 8-2: Performance of Different Waste Systems in Denmark
Residual
Residual
Waste
Waste
(kg/inhab)
(kg/inhab)
Paper Paper and
and
Card
Card
Glass Glass Total
Total
(Increase (Increase in) in)
in)
Paper
Paper
Captures
Captures
(Increase (Increase in)
in)
Glass
Glass
Captures
Captures
Weight Weight-based
Weight based 325 108 38 471 71% 87%
Reference 729 67 34 830 41% 77%
Difference -404 41 4 -359 (+30%) (+10%)
Difference in % -55% 61% 12% -43% 43% 43% (+73%) (+13%)
Volume Volume-based
Volume based 552 104 40 696 61% 89%
Reference 660 76 30 766 44% 67%
Difference -108 28 10 -70 17% 22%
Difference in % -16% 37% 33% -9% 9% (+39%) (+33%)
Source: Tønning (2000)
On the surface, the figures from this study look impressive. However, this study
reminds us of an important lesson. In systems with kerbside recycling and
composting schemes of narrow scope, the stated effects on total waste quantities
may be exaggerated because more material is likely to be re-routed away from the
doorstep collection system (to, for example, bring or CA site collections). If there are
limited opportunities for segregation of materials presented by the kerbside
collection, waste may be squeezed in other directions. This would be especially true
where:
� The recycling / composting service provision is more heavily oriented towards
the provision of bring sites and CA sites; and
� CA sites do not charge for the delivery of refuse-type waste.
When assessing the literature, it is often difficult to know from the presentation of
data whether particular studies suffer from the same shortcomings.
A study undertaken for VROM by KPMG (2001) attempted to understand the fate of
materials diverted from residual waste. In particular, it attempted to determine how
much of the reduction in refuse was due to genuine waste reduction and how much
due to evasive activities / illegal disposal. Comparative results across 4 different
165 K. Tønning (2000) Fordele og ulemper ved gebyrdifferentierede indsamlingssystemer for
husholdningsaffald, Teknologisk Institut, Miljoprojekt 576, Report for the Danish EPA.
International Review of Waste Policy: Annexes

‘DIFTAR’ system types were reported in an AOO (2001) publication and are shown in
Figure 8-4. These results match the order of ranking for the impact on waste
prevention as listed above. However, the study and its outcomes could be questioned
on the basis that:
132
1. The municipalities using different systems may not be comparable in the
manner suggested (there may be other factors compounding the analysis);
and
2. Possibly more significantly, it has not been possible for us to clarify whether
this study addresses only door-to-door collections.
Figure 8-4: Quantities of Separated Waste and Refuse by Charge System Type, 1999
Waste Collected (kg/inhabitant)
500
450
400
350
300
250
200
150
100
50
0
Source: AOO (2001)
29/09/09
Volume-based Volume and
frequency-based
Sack-based Weight-based Without DVR
scheme
Type of Scheme
Vegetables, Fruit and Garden Waste
Textiles
Glass
Paper
Residual Waste
The Dutch studies by Dijkgraaf and Gradus looked at data from the Netherlands
Waste Management Council (AOO) for 1998, 1999 and 2000 to estimate the effects
of different charging schemes. 166 167 The later study suggested the following lending
further support to the ranking of charging systems:
� Weight-based schemes reduce total waste by 38%;
166 E. Dijkgraaf and R. Gradus (2003) Cost Savings of Unit-Based Pricing of Household waste, the case
of the Netherlands. Research Memorandum 0209, OCFEB, Erasmus University, Rotterdam.
167 E. Dijkgraafand R. Gradus (2004) Cost Savings in Unit-based Pricing of Household Waste: The Case
of The Netherlands, Resource and Energy Economics, Vol.26 (2004) 353-71 (note, the former paper is
somewhat more extensive in its treatment).

133
� Sack-based schemes with charges also placed on compostable waste reduce
total waste by 36%. Where compostable waste is not charged for, the
reduction in total waste is 14% (the difference in the two is reflected mainly in
the quantity of material collected separately from the kerbside);
� The frequency based system delivers a reduction in total waste of 21%; and
� The volume based bin system delivers a reduction in total waste of 6%.
This data suggests that the approach to the charging of garden waste is also
important. It should be noted that these effects were achieved at different price
levels. However, the same work includes estimates of elasticities as shown in Table
8-3. These high results are probably indicative of the Netherlands experience where
garden waste had previously been collected free of charge (so giving greater scope for
reduction).
Table 8-3: Estimated Price Elasticities under Different Charging Schemes
Price Price Total Total Unsorted Unsorted Compos Compostable
Compos table Recyclable
Recyclable
Standard model
Weight 4.39 -0.47 -0.67 -0.92 0.16
Bag, refuse and
compostable
2.02 -0.43 -0.66 -0.97 0.25
Bag, refuse 2.15 -0.14 -0.71 0.29 0.14
Frequency 3.91 -0.22 -0.28 -0.40 0.08
Volume
Model with environmental
activism
1.94 -0.06 -0.12 0.01 0.01
Weight 4.39 -0.40 -0.53 -0.81 0.12
Bag, refuse and
compostable
2.02 -0.36 -0.51 -0.85 0.20
Bag, refuse 2.15 -0.07 -0.58 0.40 0.09
Frequency 3.91 -0.16 -0.16 -0.31 0.04
Volume 1.94 -0.00 0.01 0.09 -0.03
Source: Dijkgraaf, E., and Gradus, R. (2003) Cost Savings of Unit-Based Pricing of Household waste,
the case of the Netherlands. Rotterdam: OCFEB
The work by Dijkgraaf and Gradus is of particular interest in the evaluation of
environmental effectiveness of PAYT systems. In their studies they attempted an
extensive cost-benefit analysis of DVR charging systems, noting:
“From a welfare point of view a number of effects are important with respect
to the evaluation of unit-based pricing systems:
1. The change in collection costs due to the effect on the collected
quantity.
2. The change in treatment costs due to the effect on the collected
quantity.
3. The change in administrative costs due to the introduction and
maintenance of the unit-based pricing system.
4. The social costs of extra illegal dumping due to the introduction of unitbased
pricing system.
International Review of Waste Policy: Annexes

134
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[…] As we are interested in the welfare effects of the different systems not
only the out of pocket costs (private costs) are important, but also the effects
on the environment of collection and treatment.”
A thorough review of this work is given in the OECD charging review but a summary of
the details and findings is useful here. The system examined was based entirely on
bring sites where the collection of dry recyclables (GPT, or glass, paper and textiles)
was concerned. A door-to-door collection for refuse and for VFG (vegetable, fruit and
garden) waste was in place. An important feature of the study was the attempt to
model different DVR charging systems.
The results of the analysis are shown in Table 8-4. One assumes that the
presentation is based upon costs per household (the study is not absolutely clear on
this). The suggestion is clearly that weight and sack based schemes (and to a lesser
extent volume or volume and frequency based schemes) deliver both private cost
savings and environmental improvement (relative to a flat rate fee baseline).
Some of the observations regarding net costs and benefits are important in the
context of changes in waste arisings and recycling:
“It should be noticed that the weight-based and the bag-based system
decrease the amount of solid waste with large environmental costs
substantially and increase the amount of recyclable waste with high
environmental benefits also substantially. From the view of private costs the
weight-based system performs better than the other systems. The reason for
this is the higher savings on collected waste. Therefore, in social terms the
weight-based system performs slightly better than the bag-based system.” 168
In a subsequent paper, the authors appear to have revised their views somewhat.
They conclude:
“We find that the weight- and bag-based pricing systems perform far better
than the frequency- and volume-based pricing systems. The bag-based system
seems to be the best option, as its effects are comparable to those of the
weight-based system and yet its administrative costs are far lower.” 169
The principle reason for this appears to be appreciation of the administrative costs of
running the schemes. The later study suggests these are €6.86 per inhabitant for a
weight-based scheme and €3.18 for a bag-based scheme. 170
168 E. Dijkgraaf and R. Gradus (2003) Cost Savings of Unit-Based Pricing of Household waste, the case
of the Netherlands. Research Memorandum 0209, OCFEB, Erasmus University, Rotterdam.
169 E. Dijkgraafand R. Gradus (2004) Cost Savings in Unit-based Pricing of Household Waste: The Case
of The Netherlands, Resource and Energy Economics, Vol.26 (2004) 353-71 (note, the former paper is
somewhat more extensive in its treatment).
170 These figures are taken from VROM (1997).

Table 8-4: Costs under Flat Rate Fees and Changes in Costs Under Different Charging
Schemes
135
Costs Costs (interpreted (interpreted to be
€ € per per household)
household)
Flat Flat rate
rate
(level)
(level)
International Review of Waste Policy: Annexes
Weight
Weight
(change)
(change)
Bag
Bag
(change)
(change)
Vol. Vol. and and and Freq.
Freq.
(change)
(change)
Volume
Volume
(change)
(change)
Total Total private private costs costs
45 -14 -12 -6 +1
Total Total environmental environmental costs costs
-12 -6 -6 -3 -0
Total Total social social costs costs
33 -20 -18 -9 +0
Source: Dijkgraaf and Gradus (2003)
8.5.4 The Movement of Waste and Impact of Changes in System
Infrastructure
A report in the Netherlands by Proietti cites a particular study conducted for the VROM
(The Netherlands Ministry of Housing, Spatial Planning and the Environment) by
KPMG in 1995-1996. 171 This reported a 12 to 30% reduction in household refuse
owing to DIFTAR schemes, including:
� 6 to 8% due to improved sorting (for recycling) by householders;
� 3 to 10% due to ‘unintended activity’; and
� 3 to 12% due to genuine prevention measures (calculated).
This indicates that PAYT systems ‘squeeze’ waste in a number of directions.
In France, a recent study examined the differences between 4 municipalities without
incentive based schemes, and six who had implemented them. 172 Summarised
results are available in Table 2 within the Defra Charging Review. Although, more
analysis would be required to see whether total waste quantities were actually
increasing or falling under the schemes, the study does reveal some interesting
trends. Generally, rates of recycling were higher and residual waste per inhabitant
was on the decline in those areas with incentive based systems in place. The weakest
impact appears to have been in the volume based bin system. Crucially, the data also
highlights that there were changes in the proportion of waste managed through bulky
waste and CA-site type locations. The study suggests, however, that in several cases
171 Stefano Proietti (2000), The Application of local Taxes and Fees for the Collection of Household
Waste: Local Authority Jurisdiction and Practice in Europe, Report for the Association of Cities for
Recycling, Brussels: ACR.
172 Olivier Arnold, Damien George, Rachel Bauudry, Thomas Gaudin, Eve Toleedano d’Amorce (2005)
Causes et Effets du passage de la TEOM a la REOM, Final Report, Ministere de L’Ecologie et du
Developpement Durable, August 2005.

the infrastructure in this regard was improved over the period drawing more material
through this route.
The literature most clearly shows that charging for household waste moves material
from refuse to kerbside recycling. Beyond this however, changes in flows of material
caused by charging schemes are generally poorly understood. It is fair to assume that
if constraints are placed on one part of the waste management system, then material
has a habit of flowing onto other parts of the system. In an original case study we
carried out in Schweinfurt, the director of the service was particularly keen to
understand where the waste had gone. 173 Even after exploring all of the following,
one-sixth of the reduction in residual waste remained unexplained:
136
� Quantities of recycled material, before and after;
� Composition of residual waste before and after;
� Rates of home composting, before and after;
� Possible causes of a reduction in the amount of inert building / DIY waste
generated;
� Change in the use of nappies from disposables to re-usables;
� Consumer choices;
� Burning of waste by households (regarding this issue, the county sought
information from chimney sweeps).
� Householders taking their waste to their place of work;
� Waste being flushed into sewers (down toilets);
� Fly-tipping.
Clearly, this is a complex issue, and measuring any one of these in a manner which
gives confidence is not straightforward. The list above may not tell the whole story.
Discussions with a representative from the Treviso area of Italy, where waste was
reduced by more than 10%, suggested that there are three main avenues through
which waste quantities were reduced following charging: 174
� Increases in home composting;
� Movement of commercial waste into the right avenues; and
� Genuine waste prevention.
Another issue which may be important in some contexts is that of waste tourism. In a
study for the OECD, in the case of the Spanish municipality of Torrelles de Llobregat,
we estimated that the phenomenon might account for 15% of the observed reduction
in waste quantities. 175 The municipality would have been particularly likely to give rise
173 Eunomia (2003) To Charge or Not to Charge? Final report to IWM (EB).
174 Personal communication, Paolo Conto, Consorzio Intercommunale Priula.
175 D. Hogg (2006) Impact of Unit-based Waste Collection Charges. Referred to within the text of this
report as ‘the OECD charging review’. ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
29/09/09

to this type of abuse given a) its small size; and b) the fact that no other municipality
in Catalunya (or Spain) was implementing such charges. Other things being equal,
one would expect problems of waste tourism to be greater in such situations (the
opportunity is greater and the benefit is maximised), and much reduced where
charging is implemented over large, contiguous areas.
It has been suggested that one of the effects of household waste charging is that it
leads to commercial waste that is otherwise being collected through the household
system being shifted into the “correct” channels (so that households are not crosssubsidising
small businesses).
8.5.5 Specific Impacts on Organic Waste (Due to Changes in Collection
Systems)
In many instances, the key waste prevention measure observed tends to be due to
home composting. This happens most of all:
137
� For perhaps obvious reasons, where charges are levied on biowaste sacks /
bins as well as refuse sacks / bins. This is becoming a widespread
phenomenon in Germany, Austria and Belgium; or
� Where the only biowaste collection is for kitchen waste, and where support is
offered for home composting (this occurs in Italy).
The large reduction in collected waste seen in the Netherlands, for instance may be
strongly related to the garden waste collection previously in existence. Such a
prevention effect may not be expected where no such collection has ever been in
place. The case of Comuni dei Navigli in Italy, as documented in the IWM charging
review, involved a sack-based system where the previous approach to organic wastes
was collection of kitchen waste, with garden waste not included in the collection
system. 176 The study indicated little by way of reduction in waste quantities. Given
that in most studies, a key contribution to waste prevention appears to come through
the increased uptake and intensity of home composting, the likelihood that relatively
little garden waste was previously being collected suggests that the ‘opportunity’ for
waste prevention through this avenue would have been reduced.
This indicates a possible element of ‘path-dependence’ in the measured
effectiveness of charging systems as regards waste prevention.
8.5.6 Factors That Can Reduce the Impact of Charging on Waste
Prevention
The IWM charging review showed pay-by-use can have significant impacts on waste
prevention. For example a scheme in Landkreis Schweinfurt, Germany delivered a
reduction in total waste collected of around 28% of the pre-scheme quantity (using a
volume, frequency and weight based scheme including charges for garden waste);
this percentage is reduced somewhat if ‘expectation effects’ (household clear outs
176 Eunomia (2003) To Charge or Not to Charge? Final report to IWM (EB). Referred to within the text of
this report as ‘the IWM charging review’.
International Review of Waste Policy: Annexes

efore the onset of charging) are accounted for. Additionally, a scheme in the Treviso
2 area of Italy showed a reduction of around 12% was achieved through a frequency
based scheme.
The evidence (and logic) would suggest that a restriction on the volume of waste does
not necessarily translate into a reduction on the weight of waste disposed. The IWM
charging review revealed that in Nijmegen (a sack-based scheme), quantities did not
change significantly. In this case, the recycling infrastructure was poor, and it may be
that households merely crammed their sacks more than previously.
Table 8-5 shows the results of a study carried out in 2002 by Skumatz. 177 This used
two approaches to estimate the source reduction effects of charging schemes in the
United States. These effects are not as great as one finds in many cases where
charging schemes are implemented in Europe. Specifically, many weight-based and
frequency-based schemes report much higher reductions in waste collected. Skumatz
reported that no full-scale weight-based programmes were operating in the USA. Binvolume
or tagged sack schemes were in widespread operation (for example Seattle,
San Francisco).
Table 8-5: Source Reduction Estimates from Variable-rate Waste Disposal
Programmes in the US (combination of bin-volume and paid sack (volume) schemes)
Community Community Compari Comparison
Compari son
Method
Method
Time Time Series Series Method Method
Method
Total effect of variable-rate programme 16 % 17.3%
Minus recycling effect for variable rates 5-6% 6.9%
Minus yard-waste effect for variable rates 4-5% 4.6%
Leaves estimate of source-reduction effect
5-7% from 5.8% from source
attributable to variable rate programs
source reduction
reduction
Source: SERA (2000) Measuring Source Reduction: Pay as you Throw / Variable Rates as an Example,
Seattle: Skumatz Economic Research Associates.
We would consider that, excluding flat fee systems, subscription-based volume
related charging systems, where households choose a bin size for use over a year or
longer, have the lowest impact in terms of waste prevention.
8.5.7 Price Responsiveness
Fee levels can have a big impact on the success, or otherwise, of a charging scheme.
We have mentioned above that it is important to set charge differentials broad
enough to encourage positive behaviour, but not so broad (or high) that illegal
behaviour (see Section 8.11 of these Annexes) is encouraged.
Work has been done on the effect of different charge levels on the quantities of waste
disposed. A study for OVAM (Gellynck and Verhelst, 2005) conducted regression
analysis on 306 municipalities with what appears to be good quality data – including
collections from containerparks, etc. The aim was to develop an equation to describe
177 L. Skumatz (2002) Variable-Rate or “Pay As You Throw” Waste Management: Answers to Frequently
Asked Questions, Los Angeles: Reason Foundation.
138
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the effect of certain variables on residual waste per inhabitant. The equation
developed suggests that for every additional Euro paid (on a variable rate) for residual
waste, quantities fall by around 400g per inhabitant. The average payment for
residual waste in Flanders is around €60-70 per household per year, giving a net
reduction of the order 24-28 kg per inhabitant per year (with additional effects
potentially attributable to the proportion of costs covered through direct means). The
Flemish experience is significant in that the country has set a target for residual
waste to be no more than 150kg per inhabitant across the whole region. The
equation does not give evidence of waste prevention per se. It does, however, give
some indication of the combined effect of recycling and waste prevention at the level
of the individual. It does so taking into account a range of variables including personal
income per inhabitant, collection frequencies, and whether organic wastes are
collected.
A demonstration of the price responsiveness of residual waste disposal to the cost of
sacks is given in Figure 8-5. The extensive literature review of price elasticities (ε)
under different charging schemes summarised within the Defra charging review is
reproduced here in Table 8-6. This table groups studies according to the type of
scheme used (with the exception of those looking at various scheme types). It can be
seen that there is a tendency for the elasticity (for refuse quantities) to increase
moving through volume-based, to sack-based to weight-based schemes. This ranking
reinforces trends demonstrated in the Dijkgraaf and Gradus work shown in Table 8-3
in Section 8.5.3 above.
Figure 8-5: Plot of Residual Waste per Inhabitant (y-axis) Against Sack Price (x-axis) for
Flemish Schemes
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
139
International Review of Waste Policy: Annexes

Table 8-6: Empirical Estimates of the Effect of Unit-pricing
140
29/09/09
Study Study Study
Data
Data
Wertz (1976)
Jenkins (1993)
Hong et al.
(1993)
Strathman et al.
(1995)
Van Houtven and
Morris (1999)
Van Houtven and
Morris (1999)
Reschovsky and
Stone (1994)
Fullerton and
Kinnaman (1996)
Podolsky and
Spiegel (1998)
Kinnaman and
Fullerton (1997)
Van Houtven and
Morris (1999)
Van Houtven and
Morris (1999)
Hong (1999)
Linderhof et al
(2001)
Linderhof et al
(2001)
Miranda et al.
(1994)
Callan and
Thomas (1997)
Seguino et al.
(1995)
Volume based - Compares subscription
program in San Francisco with flat fees
imposed by “all urban areas”
Volume-based - Panel of 14 cities (10 with
user fees) over 1980-88
Volume based - 1990 survey of 4,306
households in and around Portland,
Oregon.
Volume-based - Seven year (1984-1991)
time series in Portland, OR
Change Change in
in
Refuse
Refuse
ε = -0.15
ε = -0.12
No significant
impact
ε = -0.11
Volume (household survey data) ε = -0.10
Volume (municipality data) < 0
Sack-based - 1992 mail survey of 1,422
households in and around Ithaca, NY.
Sack-based - Two-period panel of 75
households in 1992
Sack-based - 1992 cross-section of 159
municipalities in NJ, 12 with unit-pricing
Sack-based - 1991 cross-section of 959
towns across the U. S., 114 with unitpricing
ε = -0.076
(weight)
ε = -0.226
(volume)
ε = -0.39
ε = -0.19
ε = -0.28
Sack-based (household survey data) ε = -0.26
Sack-based (municipality data) ε = -0.19
Sack-based – National data from Korean
volume based waste fee
Weight-based – compostable waste
(Oostzaan, Netherlands)
Weight-based - residual waste (Oostzaan,
Netherlands)
Various - Panel of 21 cities over 18
months beginning in 1990
Various (bag, tag, volume) - 1994 crosssection
of 324 towns in MA, 55 with unit-
pricing programs
1993-1994 cross section of 60 towns in
Maine, 29 with unit-pricing
ε = -0.15
ε = -1.39
ε = -0.34
17%-74%
reduction in
garbage
56% decrease
Change Change in
in
Recycling
Recycling
Unspecified
positive
relationship
No significant
impact
Cross-price
elasticity is 0.073
ε = 0.23
ε = 0.22
Average increase
of 128%
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
8.5.8 Further Summarised Evidence Concerning Waste Prevention
ε = -0.07
The review in the appendices of the Defra charging review highlights many other
individual case studies where reductions in arisings are reported. Although prevention

effects are not always verifiable in the ‘whole system’ sense, they are at least
suggestive of some degree of waste prevention in the case of some systems.
On balance, one might say the literature offers support for the prevention effects of
charging, but that the quality of evidence is somewhat variable, so that the accuracy
of the reported effects is not what it might be. It would be reasonable to assume,
however, that reported effects in schemes where the scope and convenience of the
kerbside collection service is extremely good – as it is in Flanders, for example – will
tend to give a more accurate picture than in those where the collection service is less
convenient, and where it is clear that the focus is on waste collected from the
doorstep only. In these systems, rather like a balloon, waste has greater potential to
be ‘squeezed’ from one part of the management system (doorstep collection) to
another (illegal dumping, bring sites, CA sites, etc.).
A final point worth making is that the prevention impacts of charging systems are
difficult to define in absolute terms due to the compounding complication of waste
growth. As indicated above there tend to be limited opportunities to reference to a
satisfactory counterfactual; instead, measurements of ‘prevention’ tend to be based
on ‘before’ and ‘after’ comparisons of waste arisings. The true impact, therefore, can
be somewhat obscured by waste growth, which can vary widely on a yearly basis due
to other factors besides (not least changes in the collection systems as discussed
above). Any data based on annual arising figures needs to be considered within the
context that waste prevention equates not just to ‘a reduction in waste’ but a
‘reduction in waste growth’.
8.5.9 Further Summarised Evidence Concerning Recycling
In a large number of studies in the literature, the demonstrable effect of PAYT is to
increase the proportion of waste being recycled and composted, as opposed to
increase the quantity.
A widely quoted meta-study is that of Kinnaman and Fullerton who used communitylevel
data on aggregate recycling quantities. 178 179 Correcting for endogenous local
policy choices, they suggest that a unit pricing program has an insignificant effect on
recycling while the presence of a kerbside recycling program has a positive and
significant effect. Yet the same work includes model specifications for the quantity of
residual waste. This shows the annual weight of garbage to be higher (under the
endogenous choice model) where kerbside recycling systems only are in place. Where
charging systems are also in place, the effect is to strongly reduce residual waste
quantities in a highly significant manner. In this context, the suggestion that recycled
quantities are not heavily affected by charging schemes is not a rejection of the
effectiveness of charging schemes in increasing the intensity of recycling (as
measured by capture rates). What the modelling seems to suggest (but what the
178 Thomas Kinnaman and Don Fullerton (1997) Garbage and Recycling in Communities with Curbside
recycling and Unit-pricing, NBER Working Paper 6021; NBER, Massachussetts, Cambridge.
179 Thomas Kinnaman and Don Fullerton (1998) Garbage and Recycling with Endogenous Local Policy,
Mimeo, 1998.
141
International Review of Waste Policy: Annexes

authors do not point out) is that the same quantity of material appears to be being
recycled from a smaller total amount. In other words, the recycling rate would have
increased (and residual waste would have fallen). Taken together, the modelling
seems, subject to caveats, to support (rather than oppose) the view that charging
schemes encourage waste prevention and separation for recycling, though the
authors also highlight the potential for illegal dumping.
This is not the only econometric meta-study to gloss over potentially important details
of scheme design. Arguably, in specific case studies, if charging systems are
introduced where all else remains the same from the householder’s perspective (of
the system), then before and after cases are likely to provide more reliable evidence.
Here, the evidence is rather more compelling (and the weight of evidence makes the
econometric studies seem out of kilter with empirical experience). A thorough
literature review is given in Appendix 1 of the Defra charging report. Individual studies
quote PBU leading to anywhere from a zero increase in quantities recycled (but
normally a reduction in residual waste, thereby implying an increase in the proportion
captured), to increases in recycling of 5–6 percent (see Table 8-5), to increases in the
weight of material recycled of between 32% and 59% - this specific case being for
cities that did not change their recycling program with the introduction of PBU. 180
The Appendix to the Defra charging report shows a large number of results, very few
of which lead to no change in the level of recycling following the introduction of
charging systems. Two such examples are given in the IWM charging review - the
cases of Comuni dei Navigli and in Nijmegen. In the former, the small areas
concerned were already achieving high recycling rates and the ‘head room’ for
improvement may have been limited. In Nijmegen, the collection system was not
especially comprehensive. Much emphasis was placed upon the development of a
new major bring recycling centre in the city, and this appears to have been as, if not
more, important than the charging system itself in the development of services to
households. Evidently, if this hypothesis is correct, one would expect to see the
greatest impacts being experienced at the major bring system.
The literature is less able to show differing levels of impact from the different
approaches to charging. A problem here is that relatively few studies assess capture
rates. The work by Tønning (see Table 8-2) indicates that captures in weight-based
systems lead to greater increases in captures of paper, whilst volume based systems
are more successful in increasing captures of glass. It is not clear how the capture
rates were determined in the study (and in particular, how pre- and post-scheme
compositions were estimated).
180 Marie Lynn Miranda and Sharon LaPalme (1997) Unit Pricing of Residential solid Waste: A
Preliminary Analysis of 212 U.S. Communities, June 4, 1997, Nicholas School of the Environment,
Duke University.
142
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A French study (results shown in Figure 8-6) by Sebastien in 2005 tentatively notes
that weight-based systems have a stronger effect than sack-based schemes: 181
143
The key point is that that the use of on-vehicle weighing is the most effective
method to reduce the quantity of residual waste and the total quantity of
waste, like improving the rate of sorting (voluntary glass and contributions). It
is however advisable to handle these data with precaution because they were
comparisons between different cities, and not the comparisons within the
same city where two different modes of tariffing would have been used.
Figure 8-6: Effectiveness of Different Charging Schemes
Source: Sebastien, G. (2005) La tarification des ordures ménagères liée à la quantité de déchets :
enseignements des expériences européennes et perspectives pour la France, Report for ADEME.
In summary, there is very little evidence to support a ranking in terms of the effect of
different charging systems on captures of recyclables, and indeed, one might argue
that what seems more likely is that combinations of collection and charging systems
are likely to deliver different results. On the basis of information which is available,
more analysis could help to provide comparative changes in captures. However, this
would, in turn, require some pre- and post-scheme composition analysis, and it is rare
to find this for authorities implementing any scheme change, let alone one involving
charging.
Charging schemes invariably increase the proportion of material recycled through
waste prevention combined with a nominal uplift in the percentage capture of
recyclable material. Furthermore, although significantly dependant on the pre- and
post-scheme collection systems, as well as the charging system used, many studies
demonstrate overall increases in the quantities of material recycled.
181 Galliano Sebastien (2005) La tarification des ordures ménagères liée à la quantité de déchets :
enseignements des expériences européennes et perspectives pour la France, Report for ADEME,
January 2005.
International Review of Waste Policy: Annexes

8.5.10 Climate Change Assessment of the Impacts of Variable Charging
The review given so far within this section has demonstrated that charging systems
have the effect of increasing recycling and composting, as well as preventing the
generation of some wastes in the first place. Analysis we conducted as part of the
Defra charging report estimated the climate change-related benefits from pay-by-use
systems being applied in England using data on the benefits associated with recycling
from three different sources: 182
144
� Using research undertaken by ERM, Defra has supplied ‘low’ and ‘high’
estimates of the benefits of recycling different materials;
� Using work undertaken on behalf of WRAP; and
� Using our own review of some of the literature, with specific figures were
chosen for specific materials.
Figure 8-7 shows the benefits (for the situation in which 62% of England households
are assumed to be on charging schemes) from recycling under the different scenarios
alongside what would have happened if the same materials had been treated through
energy from waste (EfW) incineration, or landfill. For the ERM Low and High
Scenarios, the ERM low and high benefits from EfW incineration and landfill
respectively were used. For the Eunomia Scenarios, the average of ERM’s high and
low benefits was used.
The situation is shown in tabular form in Table 8-7, which also includes benefits from
the recycling of dry materials estimated using figures from WRAP’s recent review of
life-cycle studies in the field. The first row of figures shows the saving from recycling.
The second row shows what savings would have occurred had the material been
recovered as residual waste or disposed of (through EfW incineration or landfill). The
final row shows the net effect of switching from the disposal route to the recycling
route, and is calculated by subtracting the figure in the second row from the figure in
the first.
These benefits, expressed in terms of savings of CO2, were converted to a monetary
figure. The savings were estimated as shown in Table 8-8. The savings were
estimated at between £4-£15 million where the alternative disposal route is assumed
to be EfW, and £8-24 million where the waste would have been landfilled (which
seems more likely in the current context).
It is important to note that these savings relate only to the additional recycling. There
are also benefits associated with waste prevention. These are more difficult to
calculate as the benefits rely on prior knowledge as to the average ‘recycled material
content’ of each of the materials which are being ‘prevented’ from arising as waste. It
is worth pointing out, however, that the additional recycling is far smaller in total
quantity than the waste prevention (the latter is approximately four times the former).
182 D. Hogg, D. Wilson, A. Gibbs, M. Astley and J. Papineschi (2006) Modelling the Impact of Household
Charging for Waste in England, Final Report to Defra. Referred to within the text of this report as ‘the
Defra charging review’.
29/09/09

Therefore, it would seem reasonable to assume that the benefits would most likely be
at least of the same order as for the recycling. Indeed, one would expect them to be
higher.
Figure 8-7: GHG-related Impacts of Recycling Associated with Charging Schemes and
Avoided Disposal (all figures expressed as savings in tonnes CO2 equivalent)
Tonnes of CO2 (equ) Saved in Process
145
1,200,000
1,000,000
800,000
600,000
400,000
200,000
0
-200,000
-400,000
-600,000
Eunomia, EfW ERM Low, EfW ERM High, EfW Eunomia, Landfill ERM Low, Landfill ERM High, Landfill
International Review of Waste Policy: Annexes
Scenario
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
Recycling Total
Disposal Total
Table 8-7: Impacts of Additional Recycling Due to Charging in England Net of Disposal
(all figures expressed as savings in tonnes CO2 equivalent)
Eunomia, EfW ERM Low, EfW ERM High, EfW WRAP
EfW
Recycling Total 1,050,150 247,590 627,641
Disposal Total 199,117 42,207 356,026
Net Benefit 851,033 205,383 271,615 591,199
Eunomia, Landfill ERM Low, Landfill ERM High, Landfill WRAP
Landfill
Recycling Total 1,050,150 247,590 627,641
Disposal Total -324,745 -181,045 -468,445
Net Benefit 1,374,895 428,635 1,096,086 991,272
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
Consequently, it was estimated that the monetised benefits for England associated
with avoided GHGs alone would be of the order:

146
� £7-30 million where the avoided disposal routes are EfW; and
� £15-48 million where the avoided disposal routes are landfill.
In per household terms, therefore, one would expect inclusion of these benefits to
increase the overall benefits associated with charging schemes by:
� £0.51-£2.17 per household covered by the charging scheme where the
avoided disposal route is EfW; and
� £1.09 - £3.47 per household covered by the charging scheme where the
avoided disposal route is landfill.
Table 8-8: Monetised GHG-related Benefits from Charging in England, Recycling Only
29/09/09
Eunomia,
Eunomia,
EfW EfW
ERM ERM Low,
Low,
EfW
ERM ERM ERM High,
High,
EfW
WRAP WRAP EfW
EfW
Avoided GHG Related Damages £15,086,496 £3,640,873 £4,814,992 £10,480,340
Eunomia,
Eunomia,
Landfill
Landfill
ERM ERM Low,
Low,
Landfill
Landfill
ERM ERM ERM High,
High,
Landfill
Landfill
WRAP
WRAP
Landfill Landfill
Landfill
Avoided GHG Related Damages £24,373,133 £7,598,522 £19,430,617 £17,572,541
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
It is clear that the potential for significant cost savings exists, and that whilst reducing
costs, charging can also increase recycling performance. This in turn has the potential
to generate significant reductions in greenhouse gases generated through improved
materials management, That being said, the figures reproduced here must be treated
as indicative, and sensitivity analysis undertaken for the Defra charging review shows
how variation in the extent and pace of uptake can affect the extent of benefits to be
derived at the national level from the implementation of household charging.
8.6 Implementation Costs
Some specific details of schemes’ costs are provided in the IWM charging review.
Costs of implementing schemes depend upon the nature of the scheme itself (sackbased,
frequency-based, weight-based, etc.). They also depend upon the nature of the
scheme already in place. This is particularly true with respect to billing. Key set up
costs include:
� Informing communities
� Equipping containers as necessary;
� Equipping vehicles as necessary;
� Billing software;
� Arranging for sale of sacks as necessary
� Introducing teams to check up on fly-tipping
� Service lines to deal with start-up queries

In many jurisdictions, where the pre-existing situation is collection of revenue through
flat-rate charging, establishing a new billing system – an issue particularly for
frequency and weight-based schemes - can imply a significant part of the set-up cost.
In such situations, prior to pay-by-use being introduced, waste related fees would
have been included as part of a wider charge on services provided by, or on behalf of,
the public sector. Following introduction, dedicated billing for waste related services is
required. Arguably, in Ireland, this is not an ‘additional cost’ since the bill would have
been sent to households by collection companies irrespective of whether a PBU
system was in place.
Much of the focus of the Defra charging report was to assess the costs and benefits
associated with a broad implementation of charging schemes across England. Key
figures are shown in Table 8-9.
The summarised financial cost-benefit results from this report are shown in Table
8-10. These highlight the fact that up front costs can be offset by system savings. The
report highlighted how these savings change as the marginal costs of avoided
residual waste treatment / disposal change.
Table 8-9: Key Costs for Introduction of Charging Schemes
Sack Sack-based Sack Sack based
Bin
Bin
Volume-
Volume
based
based
Frequency Frequency-
Frequency
based
based
Weight-
Weight
based
based
Unit Price Number Number Number Number
CAPITAL CAPITAL ITEMS
ITEMS
Fleet Fleet Fleet management management software software £5,000 1 1
Scanners Scanners £1,500 2 2
Delive Delivery Delive Delive ry and and Scanning Scanning Scanning of of Bins Bins Bins 65 65 £65,000 1 1
Startup Startup Call Call Centre Centre 25 25 700hrs 700hrs 8400 8400 up
up
to to to 30
30
£30,000 1 1 1 1
Start Start up up Info Info Info £100,000 1 1 1 1
Bin Bin changes changes (averaged (averaged over over 10 10 years) years)
£0.17
Annualised Annualised Annualised Capital Capital Cost Cost per per hhld hhld hhld
£0.49 £0.66 £0.77 £0.77
OPERATI OPERATING OPERATI OPERATING
NG COSTS
Additional Additional Staff Staff for for Implementation Implementation /
/
queries
queries
£24,000 2 2 2 2
Additional Additional Additional Monitoring Monitoring of of Fly Fly-tips Fly tips £50,000 1 1 1 1
Annual Annual Cost Cost per per per hhld hhld
£1.96 £1.96 £1.96 £1.96
TOTAL TOTAL COST COST PER PER HHLD HHLD (before (before billing) billing)
£2.45
1p per sack
£2.62 £2.73 £2.73
Billing Billing Costs Costs (pe (per (pe (pe r hhld)
hhld)
sales
revenue to
vendors
£5.08 £5.60 £5.60
TOTAL TOTAL COST COST PER PER HHLD HHLD (after (after billing)
billing)
Approx
£3.00
£7.70 £8.33 £8.33
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
147
International Review of Waste Policy: Annexes

Table 8-10: Summarised Cost Benefit of the Introduction of Charging Schemes in
England
Additional Costs due to rerouting of Garden and Bulky Waste to CA Sites
Change Change
Change
(£/hhld)
(£/hhld)
£0.38
Introduction Costs £2.82
Billing Costs £4.83
Fly-tip Costs £1.73
Change in Kerbside Collection and Treatment / Disposal Costs -£13.95
Net Costs -£4.19
Source: Hogg, D., Wilson, D., Gibbs, A., Astley, M., Papineschi, J. (2006) Modelling the Impact of
Household Charging for Waste in England, Final Report to Defra.
Annual costs of organising and administering billing were modelled at £4.83 per
household. As noted above, it is questionable whether this cost is genuinely
‘additional’ in the Irish context.
It should be noted that these costs were modelling costs (based on researched
itemised costs) for partial (71%) roll out of a range of different charging schemes
across England. What is not shown in the headline table is the cost benefit of
universal roll out of one or other particular charging approach in any particular local
authority. Sensitivity analysis revealed that the net cost/benefit per charged
household if preferential (the most effective and efficient) charging schemes were
employed may result in an annual saving of almost £12 per household. Greenhouse
gas savings are additional to this figure, and as shown in Section 8.5.10 may be in
excess of £3 per household depending upon one’s assumptions, and the nature of
the systems used.
The true delivery of these cost savings inherently necessitates a strong and freeflowing
financial relationship between the bodies responsible for waste management
and administration at every level. In practice, policies needs to be carefully
constructed if this is to happen (i.e. to ensure that collection cost savings and avoided
disposal savings contribute to the clean up of fly-tips etc.).
8.7 Effects on Technical Change / Innovation
In terms of waste prevention, the nature of changes tends to be related to purchasing
decisions, and increasing home composting. There is some anecdotal evidence which
suggests that where pay-by-use systems are in place, householders tend demand
reduced packaging. A report for SNIFFER undertook surveys of multinational
companies, some of whom hinted at possible effects of charging on packaging
design: 183
183 Eunomia Research & Consulting and M. E. L. Research for ECOTEC Research & Consulting (2002)
Towards Sustainable Waste Management Practice, Report for SNIFFER, SR(02)05a, April 2002.
148
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149
“M&S [Marks & Spencer] sell the same products and packaging across all
stores since they do not think it worth their while changing packaging for a few
continental stores. However, they have experienced clear differences
(‘problems’) in consumer attitudes in Germany and Holland (no significant
differences, relative to the UK, were found in France in this respect). For
example, in these countries, consumers do not like pre-packaged sandwiches
and the use of PVC. M&S responded with a PR campaign to inform consumers
of their approach and why they believed it to be good. They felt that it did not
lose them significant market share. In German stores, however, plastic bag
consumption is at a far lower level than in the UK, and they also had to
introduce a reusable canvas bag to meet customer demand/pressure.
M&S have found that training German staff has been interesting in that there
were far more environmental questions than there would be from UK staff -
probably reflecting both the interest of the staff and the fact that they know
that they will be asked similar questions by the public. […]
For example, in Zurich and Berne, householders have to pay 1.50 Swiss
Francs per refuse bag. According to Nestle in Vevey, there is therefore a
definite economic incentive to them buying as much lightweight flexible
packaging as possible.”
A desire for minimisation of (particularly) packaging material can lead to
diversification into different or new materials, as well as the development of new
techniques for product packaging (greater resort to refillable packaging).
Perhaps the strongest effect in terms of technical innovation occurs due to the often
observed step changes in materials separated and returned for reprocessing. This
can spur the development of new or additional recycling industries.
Furthermore, the technical infrastructure necessary to administer (and bill for)
charging schemes (identification and weighing equipment on vehicles, as well as
centralised accounting systems) means that much better data on waste production is
generated when charging systems are put in place. There has been considerable
innovation over the years with the types of systems used, the accuracy of the data
generated and the reliability of on-vehicle weighing systems. Innovation has occurred
in the nature of the chips used on bins (which can be in read only, or read-and-write
form, the latter helping to show / prove to residents that their bins have been
emptied).
This gives further scope to assess trends in waste production and devise new
approaches to further progress the objectives of sustainable waste management. In
particular, the information obtained from households through ‘identification schemes’
can improve the efficiency of vehicle routing and lead to more efficient collection
logistics. Some advanced schemes now make use of infrared detection enabling
crews on collection rounds to choose to empty only those containers which are
relatively full. This can lead to ‘bespoke collection rounds’, in which crews’ rounds are
determined by the number of bins exceeding the ‘emptying threshold’.
International Review of Waste Policy: Annexes

8.8 Social and Distributional Consequences
PBU for waste comes with a risk that low income households can be inordinately
penalized. If this is the case then the ‘distribution’ of the incentive lacks equality
across the social makeup of society.
The available evidence suggests the absence of a clear link between household
income and waste arisings. If this were the case then the social consequences would
be much reduced. Instead however, the strongest relationship concerning waste
arisings (perhaps unsurprisingly) is most probably related to household size.
The absence of such a link between income status and waste generation suggests
the potential for the impact of charging to be regressive. A number of means to offset
the regressive nature of charging exist. These include:
1) Dealing with any perceived increase in hardship through adjusting existing
instruments of redistributive policy;
2) Dealing with any perceived hardship through locally implemented redistributive
policies;
3) Dealing with perceived hardship through the charging system itself. Here, there
are essentially three options:
150
A) Reducing the fixed rate tariff;
B) Reducing the variable rate tariff;
C) Offering a levy-free element to the service (e.g. free emptyings in a frequency
based system).
In practice, 2) and 3) tend to be used more widely, with 3) probably being the most
favoured approach owing to the relative administrative ease with which it can be
implemented. In economic terms, 1) would be considered the most efficient policy.
Other options exist to offer reduced charges to compliant households. A number of
municipalities in Denmark and Italy charge households a reduced fee for those
engaged in home composting. Some municipalities allow a lower collection frequency
of residual waste for households with 2 persons. Municipalities with summer
residences have less frequent collection during part of the year. Fees are also
typically lower for households in multi-storey buildings compared to households in
areas of lower density housing (single-family-housing, rural, semi-detached, detaching
housing), because collection costs are lower from higher density housing.
From the above, it should be clear that the implications of pay-by-use for income
distribution are dependent upon the details of the scheme itself, but also, the nature
of the scheme it replaces. The net outcome cannot be determined in the absence of
knowledge of these effects. However, it is clear that:
� Where residual waste treatment / disposal costs are high; and
� Where the system has a strong effect on waste prevention; and
� Where the system has a strong effect in improving recycling,
then on average, households are likely to be better off as the overall cost of providing
the service shows considerable potential to be lowered, at least where the avoided
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cost of residual waste treatment is high (as is the case in Ireland). This suggests, at
least, the scope for dealing with some of the effects through the lower costs involved
in service provision.
8.9 Complementary Policies
As identified in Section 8.6 of these Annexes, a high marginal cost of residual waste
treatment / disposal is desirable to ensure that the savings associated with avoiding
disposal are significant enough to offset additional costs on collection operations,
and the other associated positive costs resulting from this approach. Indeed, any
‘sustainable’ waste management needs to ensure that the external costs of
treatment / disposal are reflected in the financial costs. This will tend to make
options other than disposal more competitive in financial terms.
Charging for residual waste (and organics) relies on a convenient and effective
recycling system being in place. Such systems work best where materials are
collected from the kerbside. The costs for this service needs to be paid for, but (so as
to maintain the differential charging structure where residual waste attracts the
highest, but still palatable, charge) the full costs can not be directly charged to
householders at the point of generation. Instead, producer responsibility on products
and packaging (see Annex 13.0) can be one of the most effective measures to
directly fund recycling collections.
8.10 Effect of the Policy on Pricing of Resources / Services
An important aspect of charging policies is that they make the individual responsible
for his/her own waste. This can be the strongest direct incentive for the individual to
improve behaviour in line with environmental objectives. The analysis in Section 8.6
shows that PAYT schemes can reduce overall waste management costs. Together
with the impacts on recycling and waste minimisation, this would suggest a trait of
economic efficiency associated with well administered regimes.
In Korea, average prices for 20 litre bags have increased as municipalities have
sought to maintain or increase the share of total service costs covered by VBWF
revenues. Evidently, if such schemes improve recycling performance and reduce
waste sent for disposal, the revenue base declines even though collection costs may
not. The general increase in the average price for a 20 litre bag in Korea is shown in
Figure 8-8 (different municipalities levy different sack charges).
151
International Review of Waste Policy: Annexes

Figure 8-8: Average Prices for 20 Litre Volume-Based Waste Fee Sacks, Korea
152
0.40
0.35
0.30
0.25
0.20
0.15
0.10
0.05
0.00
29/09/09
average watse bag price(20 liters)
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Source: Korea Environmental Policy Bulletin, Update Version of Issue 1, Volume 1, January 2006.
8.11 Evasion and Enforcement
A policy which places a financial impact on waste production can inevitably lead to
illegal behaviour to avoid the charge. Issues such as ‘waste tourism’ and illegal
dumping, and how to limit them / deal with them when they occur need to be
considered.
8.11.1 Waste Tourism
One such effect, ‘waste tourism’, can be observed where charging regimes are not
enforced in nearby areas.
Linderhof et al report a study by the city of Oostzaan, which estimates that about 4–
5% of waste is taken to surrounding municipalities (which is approximately 13–17%
of the reduction in waste prompted by the introduction of the weight-based pricing
system in the area). 184 Dijkgraaf and Gradus, on the other hand, carry out a modelling
exercise to estimate the impact of pay-by-use on waste in surrounding communities.
Few of the coefficients were found to be of significance; however, the largest effect
was reported for weight based systems which suggested a 0.6% increase in the
quantity of collected refuse in neighbouring communities. 185
In the OECD charging review, in the case of the Spanish municipality of Torrelles de
Llobregat, we estimated that the phenomenon might account for 15% of the observed
184 V. Linderhof, P. Kooreman, M. Allers and D. Wiersma (2001) Weight-based pricing in the collection
of household waste: the Oostzaan case, Resource and Energy Economics 23, 359–371.
185 E. Dijkgraaf and R. Gradus (2003) Cost Savings of Unit-Based Pricing of Household Waste, the Case
of the Netherlands, Rotterdam: OCFEB.

eduction in waste quantities. The municipality would have been particularly likely to
give rise to this type of abuse given a) its small size; and b) the fact that no other
municipality in Catalunya (or Spain) was implementing such charges. Other things
being equal, one would expect problems of waste tourism to be greater in such
situations (the opportunity is greater and the benefit is maximised). 186
8.11.2 Illegal Disposal
Issues of illegal dumping or backyard burning tend to raise greater concern than
waste tourism. Charging has been shown to increase recycling, move materials into
different collection systems and promote prevention activities. However, such a policy
on residual waste stands the risk of leading to illegal disposal. It is certainly not true
that unexplained waste prevention equates with illegal dumping (as some authors,
such as Fullerton and Kinnaman appear to have assumed). 187 The rest of the
literature, as assessed in the Defra charging review, varies in the extent to which
illegal dumping is shown to be a problem. There is no clearly defined relationship
between the introduction of charging systems and the incidence of fly-tipping beyond
the statement that there is a tendency for illegal dumping to increase if the issue is
not addressed, and where the collection scheme does not provide convenient
possibilities for source separation of a wide range of materials.
The literature, and our experience speaking with waste managers concerning the
issue, would suggest that there is a tendency for fly-tipping to worsen once charging
schemes are introduced. The extent of this, and for how long it is sustained, are the
key issues. In terms of quantification, one problem is that many authorities do not
monitor the extent of fly-tipping before a scheme is introduced, or at least, they do not
do so as intensely as they do after it is introduced. This is partly because most
jurisdictions anticipate illegal dumping as a potential problem and therefore seek to
take actions to enforce the system in its early stages to make clear that action will be
taken against transgressors.
In Korea, Hong showed that dumping was substantial after the adoption of unit-based
pricing systems. 188 The OECD charging review, however, concludes that enforcement
and the increased scope of collection of recyclables (notably, the increasingly
widespread collection of kitchen wastes) has meant that the problem is becoming
less problematic over time. No information was obtained for the pre-scheme situation,
but following the scheme’s introduction, there has been a steady decline in incidents,
as shown in Figure 8-9, down to 13% of the 1995 level. Control measures include a
system of fines which effectively encourages citizens to report people disposing of
186 D. Hogg (2006) Impact of Unit-based Waste Collection Charges. Referred to within the text of this
report as ‘the OECD charging review’. ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
187 D. Fullerton and T. Kinnaman (1996) Household Responses to Pricing Garbage by The Bag,
American Economic Review, 86 (4), September, pp 971-84. For a review suggesting that the authors’
interpretation of the evidence is flawed see D. Hogg (2006) Impact of Unit-based Waste Collection
Charges, ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD.
188 S. Hong and R. Adams (1999) Household Responses to Price Incentives for Recycling: Some Further
Evidence, Land Economics 75, pp 505-14.
153
International Review of Waste Policy: Annexes

their waste illegally. Of the 75,631 incidents reported in 2004, more than half
resulted in fines for the perpetrators. Overall the scheme is considered a success by
the authorities.
Figure 8-9: Illegal Dumping Incidents since Introduction of Volume-Based Waste Fee
in Korea
Number of Incidents
154
1,200,000
1,000,000
800,000
600,000
400,000
200,000
29/09/09
0
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Year
Source: Korea Environmental Policy Bulletin, Update Version of Issue 1, Volume 1, January 2006.
Cases of Illegal Dumping
Reschovsky and Stone (1994) find no relation between illegal dumping and charging
systems (though they find little of any effect in their study), while Van Houtven and
Morris (1999) report that ‘officials … found little to no evidence of more littering or
increased use of accessible dumpsters.’ In the Netherlands, Linderhof et al. (2001)
state that illegal dumping is virtually non-existent in Oostzaan. According to them, the
monitoring system in Oostzaan, with fines for illegal dumping, appears to be very
effective in terms of deterrence.
8.11.3 Mitigating Measures
Our experience when discussing fly-tipping with local, regional and national
authorities is that the problem has the potential to worsen after the implementation
of charging systems. The question arises as to how to control any potential increase.
The literature (specifically Appendix 2 of the Defra charging review) and discussions
with scheme operators suggest that communities which provide comprehensive and
convenient schemes for separate collection of materials for recycling and composting,
who also take a pro-active approach to dealing with illicit behaviour, and where the
marginal rates for avoiding disposal are not set too high, are likely to experience
limited problems.

A useful report on illegal dumping, and fears concerning this, together with an
encouraging assessment of mitigating measures is given by Skumatz: 189
155
“A detailed report on illegal dumping and variable rates by SERA examined
several kinds of data to identify whether illegal dumping has been found to be
a problem. Surveys showed low actual incidence of illegal dumping problems.
From interviews with over 1,000 communities that implemented variable-rate
programs, the report found that less than one-fourth reported actual problems
with variable rates, and all said that the problems were short-term and easily
dealt with through fines and education. A small percent insisted that the
focus on illegal dumping actually helped them get a handle on the problem
and the situation improved. All of the communities felt that fears of illegal
dumping should not be a deterrent to variable-rate pricing, because a variety
of effective enforcement options were available to address the problem.
Follow-up interviews with haulers noted that there was some initial increase in
bags alongside commercial dumpsters, but lockable dumpsters usually solve
this problem. All communities recommended fines and visible enforcement.
The report also found that residential waste was not a large component of
illegally dumped material. The surveys did not find a significant increase in
illegal dumping associated with variable-rate programs. However, it was
difficult to find communities that tracked dumping before and after
implementing variable-rate programs. The most compelling information
uncovered by the SERA study was an examination of the composition of
illegally dumped waste: over 75 percent to 85 percent of it was non-residential
in origin (i.e., commercial waste). The largest components were construction,
demolition, and land-clearing waste (over 25 percent), brush (almost 40
percent), and—the only important component of household origin—bulky items
such as mattresses, sofas, and appliances (“white goods”). Therefore,
communities recommend implementing a convenient “bulky waste” program
concurrently to increase the success of the variable-rate program and
minimize the incentives for illegally dumping these awkward materials.
Prompt cleanup, bulky waste programs, lockable dumpsters, burn bans, fines,
and other strategies will help reduce the incidence of illegal dumping as a
result of variable-rate programs. If a community is concerned about illegal
dumping, variable-can or hybrid programs—which include some base level of
service for all customers, may reduce the incentives for illegal dumping. The
SERA report includes a wide variety of suggestions to help reduce illegal
dumping concerns.”
There are clearly measures that can be enacted to minimise illegal activity. Locally,
enforcement needs to be coordinated with schemes’ introduction.
In Flanders, the attitude of the regional waste management agency, OVAM, appears
to be that some residents (a hard core of perhaps as many as 5% or so of
189 L. Skumatz (2002) Variable-Rate or “Pay As You Throw” Waste Management: Answers To
Frequently Asked Questions, Los Angeles: Reason Foundation.
International Review of Waste Policy: Annexes

households) will tend towards fly-tipping irrespective of whether there is a charging
system in place, though with potential for the problem to worsen with pay-by-use in
place. The approach is to take early action against those who fly-tip and explain how
the system works. Clearing hot-spots frequently is also seen as important. 190 Some
authorities report that bring sites and recycling centres act as ‘attraction points’ for
fly-tippers. The IWM charging review reports that:
156
� In Nijmegen, charging may have increased the number of tips at these
‘attraction points’;
� In Comuni dei Navigli, the fact that bring sites for glass and cans appear to act
as attraction points for illegal dumping was leading the Comuni to consider
switching to kerbside collection for those materials collected at bring sites;
� Landkreis Schweinfurt had, as one of its strategies to prevent fly-tipping, the
more frequent clear up of fly tips at litter bins and at mini recycling centres.
They believed this would reduce the attraction which already fly-tipped waste
creates to those who are considering of fly-tipping.
� In Treviso, around 0.3% of all waste is illegally tipped. The key areas are bring
sites, and at the recycling centres operated by the responsible consortium.
� Gent reports a maximum level of 0.5% of waste being fly-tipped. They suggest
the main problems are at, and around, high rise buildings, and that ‘lowincome
residents and foreigners’ are the most frequent culprits. Interestingly,
they have argued for a change in the way the municipality deals with lowincome
residents arguing that they should not be given a ‘compensation
cheque’ by the municipality, but a number of ‘free sacks’, or ‘free emptyings’,
so as to reduce the problem.
A study by Webb et al 2006 191 makes some interesting comments around the issue
of civic amenity site provision. The availability of these, and of other waste disposal
sites, is seen as a key determinant of fly-tipping. This – and experience elsewhere –
suggests that (quite apart from the quality of kerbside recycling infrastructure) the
following have some bearing upon the extent of fly-tipping:
� The density of CA site provision;
� The site layout (reducing visit times);
� The range of materials collected separately, and free of charge, at CA sites for
recycling / composting;
� The charge levels for residual waste at CA sites; and
� The nature, and cost of, bulky waste provision.
190 Personal comm., Danny Ville, OVAM.
191 Barry Webb, Ben Marshall, Sarah Czarnomski and Nick Tilley (2006) Fly-tipping: Causes, Incentives
and Solutions, Jill Dando Institute of Crime Science, UCL, 31 May 2006.
29/09/09

Generally, the view which prevails is that charging schemes are less likely to lead to
illegal activity where recycling schemes are convenient and broad in the scope of
materials they cover.
One issue with free market competition in collection is that private sector collectors
are not the ones who have to deal with the consequences of poorly designed systems.
If illegal tipping, or backyard burning is prevalent, the costs of dealing with this tends
to fall upon public authorities rather than collectors themselves (who may be the
source of the problem).
In Poland the situation is extreme. There are a vast number of uncontrolled dumpinggrounds
on which municipal waste is left. Although dumping-grounds are removed day
by day in many municipalities (in 2003, 6,109 of them were removed), in a very short
time they appear again. At the end of 2006, municipal offices counted 2,509
dumping-grounds on their area. Tojo estimates that approximately 10% of MSW is
dumped in this way. 192
The Central Statistical Office attributes this situation to the fact that not all
households are served by a waste collection system. 193 The fees charged for
collection (anticipated to be higher than necessary resulting from collection
inefficiencies where competing companies serve the same streets), as well as the
absence of a system to enforce the use of a collection service, may also have a strong
bearing here.
8.12 Lessons Learned
The international review of charging systems teaches some valuable lessons.
Charging tends to work best where:
157
� National policy sets a clear and structured agenda for local waste charging;
� The marginal benefit of avoided residual waste treatment / disposal is high;
� Separate collection of biowastes and recyclable collections include a wide
range of materials, and are convenient (typically kerbside collected) – this
tends to limit the likelihood of illegal disposal / contamination of separately
collected waste streams;
� Charge levels are set with a flat rate fixed fee supplemented by variable fees
so as a) to ensure problems of revenue stability do not arise and b) to ensure
variable rates are not so high they give rise to more compelling incentives to
fly-tip;
192 Naoko Tojo (2006) Evaluation of Waste Management Policies and Policy Instruments: Three Case
Studies, Report written as part of 6FP project HOLIWAST: Holistic Assessment of Waste Management
Technologies, International Institute for Industrial Environmental Economics at Lund University,
Sweden.
193 Central Statistical Office (2007), Municipal Infrastructure In 2006, accessed 13 th October 2008,
http://www.stat.gov.pl/gus/45_1726_ENG_HTML.htm
International Review of Waste Policy: Annexes

158
� Charges are placed on residual waste taken to civic amenity sites as well as
the kerbside; and
� Charges are levied – albeit at different rates - on all waste streams, including
recycling – this fully integrated approach best delivers the incentive for waste
prevention.
8.13 Prerequisites for Introduction
A political will, and associated public acceptance, can be a very strong determinant in
passing law to allow charges to be made for waste. Despite significant investigation
into the impact of charging for waste in the UK showing the benefits it would bring,
this policy remains a political hot potato.
Minimum standards for a quality, convenient collection service including a wide range
of recyclables is desirable in order for charging systems to deliver the best outcomes.
Eunomia described a charging scheme in Fingal, Ireland, where half of households
had no kerbside recycling scheme available to them. The scheme led to many
protests concerning the system.
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9.0 Pay-by-use – Germany
9.1 Outline of Policy
The local competent authorities in Germany (439 cities and counties) raise disposal
fees from their citizens for the disposal of waste. These fees are required to cover the
costs of collection and disposal. The law on charges lays down the principle of costrecovery
– the collection of waste fees is not intended to generate a profit. The levels
of waste fees, as well as the design of the charging systems themselves, vary
considerably across Germany.
In the waste laws of several of the 16 states in Germany, it is stated explicitly that
charges for the disposal of waste shall constitute incentives for the prevention of
waste as well for the separation of waste for recycling (e.g. Art. 9 para 2 of the Waste
Law of Nord-Rhine-Westphalia). In other states of Germany these incentives are not
regulated explicitly (e.g. the Waste Law of Hesse) but their regulations have to
consider the principle of waste avoidance in a similar way.
The calculation of waste charges in Germany is based around either of the two
following models:
159
� Flat rate charging. Households are charged in accordance with the number of
persons per household (the flat rate model is applied by the majority of the
municipalities in Germany). Waste fees are usually divided into an annual fee
and a container fee. The annual fee depends on the number of persons in a
household; the container fee depends on the size of the container, usually a
wheeled bin.
� Pay-as-you-throw (PAYT) charging. Direct charging according to the quantity of
the waste disposed (pay-per-volume model is used, for example. in
municipalities in the counties Darmstadt-Dieburg and Gießen in the state
Hesse).
Only the second of these approaches can be considered a pay-by-use system.
It is important to note that according to German law, citizens are obliged to dispose of
their waste using the local waste disposal system. Citizens cannot, therefore, refuse
to have a wheeled bin. This is due to the fact that the fees for the public disposal
service have to be paid by the community.
Countywide uptake of charging systems has tended to take several years. Darmstadt-
Dieburg County introduced the first charges in 1996 and achieved full coverage of
municipalities in 2001. Gießen in the Land Hesse took from 2001 to the end of 2005
to introduce the fee system across all municipalities.
9.2 Where Has the Policy Been Applied and Why?
There is no statistical overview about the situation in the 439 cities and counties in
Germany due to differences in application of waste management systems, including
the charging systems used. Typically, PAYT systems are more common in counties
International Review of Waste Policy: Annexes

than in large cities due to the habitant density and the higher share of large housing
stocks in the larger towns. However, special waste sluices with a volume based fee
levied for disposal of household waste are in practice in several German cities in
certain housing areas. In Erfurt for instance, waste sluices have been installed for
4,730 apartments since January 2008. 194
Starting in 1996 in the county Darmstadt-Dieburg, a waste disposal charge per
volume was introduced and implemented using a barcode-sticker on the wheeled bin.
Countywide application of the PAYT scheme in all municipalities was achieved by
2001.
The latest structure of the waste disposal charges includes a basic flat fee which
includes 12 bin collections per year, as well as supplementary charges levied for
additional pick ups (maximum 12 per year). These fees are described in Table 9-1.
Table 9-1: Waste Disposal Charge Structures in Darmstadt-Dieburg County
160
29/09/09
Size Size of of wheeled wheeled bin bin
Basic Basic fee fee per per year year a Fee Fee Fee for for additional additional pick pick-up pick up
50 litre €96.00 €8.00
60 litre €115.20 €9.60
80 litre €153.60 €12.80
120 litre €230.40 €19.20
240 litre €460.80 €38.40
1,110 litre b €3,162.00
a Including 12 collections b Collection every fortnight
Other household wastes, like the Duales System Deutschland “Gelber Sack” for
packaging waste (see Annexes 13.0 and 14.0) and waste paper are not directly
included in the above mentioned pay-by-use system, but the lower costs associated
with those waste streams are taken into account in the overall-calculation of waste
charges. Further information on the structure of waste disposal charges in the county
Gießen is given (in German) at www.trend-abfall.de.
Authorities recommend a standard volume residual waste wheeled bin at 15 litres per
person per week. Citizens are advised, however, that high separation can mean a
lower minimum volume of 7.5 litres per person per week is possible. This minimum
volume relates to this minimum fee which has to be paid by individual households.
Typically, the fees shown in Table 9-2 are applied for residual waste. Lower fees for
organic waste are shown in Table 9-3.
194 EUWID (2008), German news website, www.euwid-recycling.com

Table 9-2: Charges for Residual Waste
161
Size Size of of the the the bin bin Emptying Emptying intervals intervals
Fee
Fee
60 litre
120 litre
240 litre
1.100 litre
once a month
twice a month
once a month
twice a month
once a month
twice a month
once a month
twice a month
Table 9-3: Charges for Organic Waste Collection
Size Size of of the the bin bin Emptying Emptying interval interval Fee
Fee
International Review of Waste Policy: Annexes
€71.40
€147.60
€133.20
€277.20
€262.80
€538.80
€1,212.00
€2,472.00
120 litre twice a month €28.80
240 litre twice a month €57.60
In addition to the residual waste, organic waste and packaging waste (dual system)
collection systems described above, 240l waste paper bins are provided for all private
households free of charge. This waste paper bin is emptied monthly.
The county of Landkreis Schweinfurt in Bavaria is another case in point. In the late
1980s, the system started changing from a one bin to a three bin system. By 1994,
the doorstep collection of residual waste, biowaste and producer responsibility
funded recycling fractions (see Dual System Deutschland, Sections 13.0 and 14.0),
supported by separate collections for glass, cans, and paper and card at bring sites,
was delivering a recycling rate of 58.6% with households only paying for residual
waste collections on an annually charged volume based fee related to the size of bin
chosen (i.e. not a “variable” charge after the household’s beginning of year decision).
In 1997, by modification of the existing system, the County decided to improve the
incentive for waste reduction to reduce costs through the incorporation of an
additional (frequency based) emptying fee and also a weight-based fee. The charging
system was calculated in such a way that on average, householders would pay the
same cost after the system’s introduction as before (with higher waste producers
paying more and others less). It is notable that prior to the system’s introduction, the
quantity of residual waste per inhabitant was already extremely low by international

standards at 120kg/inhabitant, making the system’s objectives all the more
challenging. 195
The Schweinfurt system billing scheme works through an annual invoice (billed in 4
instalments) calculated upon the previous year’s performance by the household. Each
year, an adjustment is made to the preceding year’s bill based upon the performance
of the household relative to the beginning of year estimate. The three part tariff
comprises:
1. A fixed fee. This was intended to cover the fixed costs of the collection
infrastructure, including the bulky waste collection, the collection of tyres, fridges,
special wastes etc. The annual cost for this fixed element varies with the size of
residual waste bin chosen (the fixed fee is only linked to the refuse bin). For a
120l bin, the fee is €8 per month, and for a 240l bin, the fee is €16 per month.
The minimum bin size is 120l. It is felt that smaller bins are unlikely to lead to
optimised collection of the different fractions.
2. A fee per emptying of any bin. The basis for the ‘emptying charge’ is the amount
saved by not emptying a bin. This was calculated as €0.20 per emptying;
3. A weight-based fee. This is set at €0.25/kg for residual waste and €0.15/kg for
biowaste.
9.3 Key Organisations Involved in Implementation and Management
In Germany the technical side of waste management is carried out by specialist
associations for waste disposal (the joint waste management authority
“Abfallzweckverband”). The establishment of such an association or the conversion of
the structure of an existing association is considered to bring economic and logistical
benefits in the management of waste.
In Germany the local municipalities or counties are responsible, by law, for the
collection and disposal of waste (Art. 15 para 1 of the Waste Recycling and Disposal
Act, Art. 4 para 1 of the Waste Law of Hesse, Art. 5 para 1 of the Waste Law of Nord-
Rhine Westphalia). Therefore the local authorities have the right, and indeed an
obligation, to set up waste charge regulations.
9.4 Evaluation Studies Available
For general aspects see:
162
� Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen,
SRU) Environmental Report („Umweltgutachten“) 2008, July 2008 (See:
http://www.umweltrat.de for further information).
� Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen,
SRU) Environmental Report („Umweltgutachten“) 2004, July 2004 Council of
195 Eunomia (2003) To Charge or Not to Charge? Final report to IWM (EB).
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163
Environmental Advisors (Sachverständigen Rat für Umweltfragen, SRU)
Environmental Report („Umweltgutachten“) 2002, July 2002.
Specific report for the County Darmstadt-Dieburg:
� DA-Di Werk Waste Management Concept (“Abfallwirtschaftkonzept 2007“),
County Darmstadt-Dieburg, August 2007.
9.5 Environmental Benefits
PAYT systems are observed to stimulate the recycling of material fractions of
household waste if appropriate services are in place. It is not so straightforward,
however, to assess the impact on waste prevention. Figure 9-1 shows the waste
streams for Darmstadt-Dieburg, a county with a sophisticated PAYT system using barcoded
wheeled bins.
Figure 9-1: Waste Streams Per Capita and Year in County Darmstadt-Dieburg
kg / capita / year
500
450
400
350
300
250
200
150
100
50
0
1990 1992 1994 1996 1998 2000 2002 2004 2006
International Review of Waste Policy: Annexes
Year of First Implementation
Source: County Darmstadt-Dieburg (2007) DA-Di Werk Waste Management Concept
“Abfallwirtschaftkonzept 2007”, August 2007.
Metal cans (recycled)
Packaging plastics
(recycled: yellow bag)
Glass (recycled)
Paper (recycled)
Kitchen and garden
waste (composting)
WEEE (separated)
Residual waste
(households)
The figure shows the total amount of household waste (excluding bulky waste which is
not a target of the PAYT system, but including waste from small companies)
increasing from 311 kg/capita in 1990 to 423 kg/capita in 2001 – the first year with
the application of the system in all municipalities of the county. However, this
increase may have been significantly driven by the enhanced centralised composting
service in the county (increase from 13 kg to 176 kg/capita) which may have resulted
in increased waste arisings (see Sections 8.5 and 33.7.1 of the Annexes). Centralised
collections may have reduced home composting (there is a high proportion of
detached houses in the county).

From 2001 to 2006 the total amount of all waste fractions shows zero growth.
Although this data does not directly prove the waste prevention effect, the further
reduction of the residual waste (from 95 to 82 kg per capita 196) could be an effect of
waste prevention. Furthermore, set against the context of (a) historical arisings
growth, (b) continued economic growth through the period 2001 to 2006, and (c) a
general trend towards lower numbers or residents per property in Germany (which is
known to increase average waste arisings per capita), a zero growth rate in fact
suggests that residents are adapting to the economic incentive to minimise waste.
With just 82 kg residual waste per capita in 2006 the Darmstadt-Dieburg county was
among the communities with the lowest figures in Germany. The increase in material
separated for recycling and composting is also impressive. Although this does not
prove a waste prevention effect, it suggests that a PAYT-system combined with
convenient separation, collection and recycling services delivers remarkable effects
to reduce the amount of residual waste. The incentive for citizens to prevent and
recycle waste is delivered through the financial stimulus. 197
The overall reduction of residual waste per capita from 230 kg/capita in 1990 to 127
kg/capita in 1995 (last year without the PAYT system in all of the communities in the
county) and further to 82 kg/capita in 2006 can be considered to have delivered
significant environmental benefits. Residual waste in the region goes to the local
incinerator. The environmental benefits of recycling over incineration are well
established, as such the specific emissions per capita caused by the incineration of
municipal waste have been reduced significantly. Furthermore the increases in
recycled or composted fractions (glass, metals, kitchen and garden waste etc.) help
conserve primary resources and to reduce linked environmental effects associated
with material extraction and processing (compared with recycling pathways).
The Schweinfurt scheme is worthy of detailed analysis as it takes an already well
performing system and interlaces volume, frequency and weight based charges to
achieve further environmental improvement (as associated with waste prevention
and increased recycling). In understanding the effects of the scheme, one must
understand the linkages between what has happened to collections at the doorstep,
and what has happened at other collection routes.
Figure 9-2 shows the effect of the schemes on the quantities of material collected at
the doorstep. The effect is clearly dramatic, with collections falling by more than 40%
of the original quantity. Figure 9-3 clearly shows that this is an exceptional result,
even when compared with well-functioning schemes elsewhere in Germany.
196 In 1995, the last year without the PAYT system in all of the communities of the county the amount
of residual waste was 127 kg/capita.
197 A private interview with one citizen of the Darmstadt-Dieburg county demonstrates that use of the
offered separation, collection and recycling systems, allows a household with four persons to choose
the smallest bin (50l) with just five additional pick-ups in addition to the twelve free pick-ups. This was
suggested to have created savings €56, or a 29% reduction of the annual bill compared to the
previous year.
164
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Figure 9-2: Quantities of Residual Waste Collected Through Doorstep Collections
165
Residual Waste Collected
(tonnes)
16,000
14,000
12,000
10,000
8,000
6,000
4,000
2,000
Source: Landratsamt Schweinfurt
0
International Review of Waste Policy: Annexes
1995 1996 1997 1998 1999 2000 2001 2002
Year
Figure 9-3: Comparison of Residual Waste Collected at Doorstep, Landkreis
Schweinfurt and Other Counties in Germany
Residual Waste per Inhabitant per Year (kg)
160
140
120
100
80
60
40
20
0
Source: Landratsamt Schweinfurt
149.2 67.89
123.1
Bayern Unterfranken Lkr. Schweinfurt
It might be expected that this decline in residual waste quantities would be explained
through an increase in source separation. However, the quantity of material collected
on the door-to-door biowaste collection also dropped by more than 40%. In absolute
terms, the fall was of about 5,500 tonnes.
Part of the biowaste fraction has simply moved into a different collection outlet. The
County operates a network of 29 locations where citizens can bring material from the

garden for chipping. There was an increase of around 2,800 tonnes of this material
(estimated on the basis of a volume of approximately 7,000 m 3 when shredded).
Hence, this does not completely explain the reduction in biowaste collections, which
suggests an increase in home composting. A net reduction of around 2,700 tonnes
(23kg per inhabitant) of biowaste still remains.
Figure 9-4: Biowaste Collections, Door to Door System, Landkreis Schweinfurt
Biowaste Collected (tonnes)
166
29/09/09
16,000
14,000
12,000
10,000
8,000
6,000
4,000
2,000
0
Source: Landratsamt Schweinfurt
1995 1996 1997 1998 1999 2000 2001 2002
Figure 9-5: Change in Material Received at Chipping Stations (volume), Landkreis
Schweinfurt
Volume Collected (cu. m)
25,000
20,000
15,000
10,000
5,000
0
Source: Landratsamt Schweinfurt
1995 1996 1997 1998 1999 2000 2001 2002
Year

The bulky waste collections, Figure 9-6, show the effects of the expectations of a
change in the system. The amount collected showed a sharp increase just before the
change, and a drop immediately after. This suggests that many households had a
grand ‘clear out’ prior to the scheme’s introduction.
Figure 9-6: Bulky Waste Collections, Landkreis Schweinfurt
167
Tonnes Collected
7,000
6,000
5,000
4,000
3,000
2,000
1,000
0
Source: Landratsamt Schweinfurt
1995 1996 1997 1998 1999 2000 2001 2002
International Review of Waste Policy: Annexes
Year
Figure 9-7: Paper Collections Through NGO Activities, Landkreis Schweinfurt
Tonnes Collected
2,000
1,800
1,600
1,400
1,200
1,000
800
600
400
200
0
Source: Landratsamt Schweinfurt
1996 1997 1998 1999 2000 2001 2002
Year

The county was operating a network of 160 mini-recycling centres (bring sites) at
which, typically, glass (colour separated), cans and plastics, paper and card, and
textiles are collected. Paper collected separately by non-government organisations
and through the bring sites increased by 400 tonnes (see Figure 9-7 and Figure 9-8).
Figure 9-8: Paper Collection Through Bring Schemes
Tonnes Collected
168
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1995 1996 1997 1998 1999 2000 2001 2002
Source: Landratsamt Schweinfurt
Year
The amount of DSD (i.e. packaging) waste collected changed very little (see Figure
9-9), initially falling, though this was believed to be due, in part, to ongoing changes in
the nature of packaging placed on the market.
Figure 9-9: Packaging Waste Collected (doorstep system)
Tonnes Packaging Collected
2,500
2,000
1,500
1,000
500
0
1997 1998 1999 2000 2001 2002
Year

The net effect of these changes for Landkreis Schweinfurt is shown in Figure 9-10.
Between 1999 and 2000, total waste collected fell by 28%. However, this includes
the expectations-related effects (in which ‘clean-outs’ occurred prior to scheme
introduction). Taking this into account, the reduction was from 52,000 tonnes or so to
45,000 tonnes, a reduction of 13%.
Figure 9-10: Net Effect on Waste Management System, Landkreis Schweinfurt
Total Tonnes
169
70,000
60,000
50,000
40,000
30,000
20,000
10,000
0
Source: Landratsamt Schweinfurt
1995
1996
1997
1998
International Review of Waste Policy: Annexes
1999
Year
2000
2001
2002
Residual
Waste
Separately
Collected
Residual waste fell from a pre-scheme average of 165kg to a post-scheme average of
92kg per inhabitant, a reduction of 46%. The pre- and post-scheme average recycling
rates shifted from 64% to 76%. This is truly outstanding performance by any
comparator.
Refuse had fallen to marginally more than 50% of what was there previously, but the
organic fraction had also fallen significantly in proportionate terms from 33% to 8% of
residual waste. This implies a reduction of around 29% of the original residual waste
fraction due to changes in the way in which the organic fraction was being treated by
households. Of course, such analyses cannot be relied upon to provide a completely
accurate picture of the changes in quantitative terms, but they suggest a major
change in how this fraction was treated. A survey of households was carried out to
find out the main reason for the change, and it is believed that increased activity in
respect of home composting was the principal explanation for the change.
The paper fraction, previously 12% or so of residual waste, fell only slightly in
proportionate terms to 11% of residual waste. Yet, bearing in mind the reduction in
absolute quantities, the reduction suggests that approximately 6% of the reduction in
residual waste was due to changes in householders’ handling of the paper and card
fraction.

The above line of thinking led the County to believe that it could readily explain
around 35% of the drop in residual waste, but that the remaining reduction
demanded closer examination. The County considered the possibilities for legitimate
and illegitimate changes in behaviour which could explain the ‘unexplained’ reduction
in residual waste. As regards legitimate routes, the following were considered:
1. A reduction in the amount of inert building / DIY waste generated;
2. A change in the use of nappies from disposables to re-usables. Statistics and
compositional analysis suggest a reduction from 9.4kg/average-inhabitant before
the scheme to 7kg/average-inhabitant after implementation; and
3. Consumer choices. Some evidence suggests that consumers are changing
consumption habits to reduce the quantity of packaging and / or waste generated.
The illegitimate disposal routes are discussed in Section 9.11.
9.6 Implementation Costs
For the local competent authorities the shift to a pay-per-volume system has a –
sometimes considerable – cost saving effect. For example after changing to the payper-volume
system, the county Gießen has saved costs estimated at €1.3 million per
year. The investment costs required for a district or county to change to this waste
charge system are effectively more than balanced by the reduction in the quantities
of residual waste, and constraint on total waste. 198
The levels of the fees (and the corresponding cost savings) differ from county to
county. 199 The differences result from varying utilisation of waste disposal facility
capacities as well as the population in the local municipal authorities.
In the Schweinfurt scheme, although collections are only offered fortnightly, for
several bin types the set out rate is close to 50% (i.e. for many householders bins are
being set out approximately once a month). Interestingly, the set out rate tends to be
lower for those using smaller bins. For those using larger bins, the materials tend to
be collected approximately once every three weeks. This change in set out rates has
led to reduced staffing levels. The materials are collected on vehicles, and the prescheme
situation, in which vehicles were operated with a driver plus one crew, has
changed such that they now operate as driver only side-loading vehicles.
9.7 Effects on Technical Change / Innovation
The policy stimulates sophisticated collection and recycling systems for multi material
waste fractions. This needs to include provision for centralised food waste
composting or anaerobic digestion. Furthermore, new technologies are brought onto
198 See www.uni-giessen.de/ilr/gaeth/projekte/pro_gebuehrensystem/pro_gebuehrensystem.html; the
introduction of the flexible pay per volume system in the county Gießen was scientifically attended by a
university project at the University Gießen.
199 EUWID from 23.08.2005, p. 11.
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29/09/09

the market such as waste sluices (each household has a signature key to open the
sluice and is charged accordingly). 200
9.8 Social and Distributional Consequences
In terms of distributional effects, one-person-households (who may be
disproportionately penalised by the charging structures) can legally reduce their
waste disposal costs in Germany by sharing services with a neighbour. In this
instance, only one household receives the fee-invoice for the shared wheeled bin.
In Schweinfurt, those who suffer from incontinence problems are given a reduction in
the fixed fee (the fixed component is as for 120l but they are given a 240l bin). The
weight-based and emptying fees are the same. Since the typical breakdown in the fee
is that fixed fees account for 60% of system costs, the reduction is significant (30% or
so of the usual fee).
9.9 Complementary Policies
“Pay as you throw” policies need a framework of suitable collection and recycling
services for an overall integrated and successful waste management system. This
may be specified in national or local governance as minimum service standards.
Policies that ensure residual waste is high in cost will help to encourage diversion of
material up the waste hierarchy.
9.10 Effect of the Policy on Pricing of Resources / Services
“Pay as you throw” systems are economically efficient and link the costs of waste
disposal with the progress in waste reduction and resource efficiency. Where
treatment and disposal of residual waste is high in cost, charges provide the stimulus
to reduce residual waste, leading to cost (and environmental) savings.
Due to the transparency of charging for the individual households, systems are
considered to be fair for the citizens as well as good for the environment. It is quite
typical for responsible politicians of engaged communities to discuss success stories
in the local media, thereby re-engaging citizens to actively participate in the system.
Flat rate per-person charging system means there are no incentives to avoid waste,
because charges are calculated based on the number of residents rather than the
quantity of disposed waste. With the introduction of the pay-per-volume system, waste
avoidance and separation are directly stimulated by financial incentives. The decision
to introduce the pay-per-volume model (‘waste producer pays’) thus follows both, the
cost recovery principle and the goal of waste prevention.
200 There may be lessons to be learned for Ireland in implementing such schemes. The message is that
pay-by-use does not need to be confined to detached and semi-detached houses, but can be deployed
at blocks of flats. However, it is very difficult to see why any private collection company would invest in
such systems if the investment might subsequently be used by an alternative contractor (owing to the
nature of competition in the market).
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The fees per household for those using a 120l bin for residual waste and a 120l bin
for biowaste in Schweinfurt have evolved as in Figure 9-11. The costs which have
resulted are not only lower than those which were projected, but they were 15% lower
in 2002 than the costs prior to the scheme’s introduction. These are figures which
are not adjusted for inflation, so the real cost to householders has probably fallen by
approximately 20%. The scheme saves money. It is important to stress that there are
other sources of revenue for the scheme. The charges paid by households cover all
system costs.
Figure 9-11: Evolution in Average Costs for Households Using 120l Refuse Bin and
120l Biowaste Bin, Schweinfurt
Cost (£ per household)
172
160
140
120
100
80
60
40
20
0
29/09/09
1996-1999 (actual) Future cost projected in
2000 (assuming incineration
of residual)
2000 (actual) 2001(actual) 2002 (actual)
The scheme costs are shown in Table 9-4. As mentioned previously, there are savings
on logistics as well as disposal. Furthermore, there have been savings on the costs of
invoicing.
Table 9-4: Annual Costs and Savings Relative to Pre-scheme Situation. Schweinfurt
Costs DM Costs (approx. €/hhld)
System cost (hardware, software and containers) DM 750,000 € 8.26
System cost (variable elements) DM 455,000 € 5.01
Admin DM 300,000 € 3.30
Reduction in amount of refuse -DM 1,830,000 -€ 20.16
Lower set out -DM 180,000 -€ 1.98
Savings on admin -DM 490,000 -€ 5.40
Reorganising bulky DM 300,000 € 3.31
Fly-tipping (monitoring) DM 142,000 € 1.56
Total Total Costs DM DM 1,947,000 1,947,000
€ 21.42
Total Total Savings Savings DM DM 2,500,000 2,500,000
€ 27.56
Costs Costs Net Net Net of of Savings Savings
- DM DM 553,000 553,000 553,000
-€ 6.10
Year

Prior to the system’s introduction, each of 29 Councils were paying DM 500,000 for
each Council to prepare invoicing. Following the scheme’s introduction, three people
were responsible for all the invoicing. This saved DM100,000 on invoicing. In total,
the analysis suggests savings which are less than is suggested by the per household
analysis above. The household analysis in Figure 9-11 above is based on one type of
system user only, whereas the cost data in Table 9-4 refers to aggregate figures. The
estimated saving was over €6 per household.
An interesting aspect of the system has been its effect on incineration costs. Those
operating the system make the point that the operators of the incinerator plant clearly
do not want these types of system to be implemented as they reduce the quantity of
waste available for the facility. The incinerator operator is now charging lower rates
for larger quantities. The Schweinfurt waste manager noted that this reflected
completely the opposite philosophy to that which the County wished to follow.
9.11 Evasion and Enforcement
Although illegal dumping of household waste occurs, e.g. in public parking lots or
quiet rural locations, these are rather singular and occasional problems which by no
means hinder the overall effectiveness of the PAYT policy in Germany. It must be
pointed out that citizens according to German law are obliged to dispose of their
waste using the local waste disposal system. Citizens cannot, therefore, refuse to
have waste collected. This is due to the fact that the fees for the public disposal
service have to be paid by the community. This is especially important for Ireland
where there is currently no such obligation for individual households to engage with
collection services.
A principal problem is the contamination of recycling bags or bins of the Duales
System (for separate collection of packaging) by regular household wastes (i.e.
residual waste) especially in urban areas. In this case it is difficult to differentiate
between intentional and unintentional disposal (miss-throw). The costs to deal with
this illegal disposal must be borne by the Duales System and therefore are effectively
funded across all household packaging purchases. Standard practice, however, is
that in case of obvious misuse, the recycling bag/bins will not be emptied.
Nevertheless, the proportion of waste disposed in this way is small and as such it may
be said that the PAYT is not significantly affected by such attempts at evasion.
The issue of contamination has not arisen in the Schweinfurt scheme; biowaste
collections are still above 95% purity and wastage rates from DSD recyclables are no
different from other systems and from the pre-scheme situation. Post implementation
review for the Schweinfurt scheme assessed the following illegitimate disposal routes:
1. Burning of waste by households. Regarding this issue, the County sought
information from chimney sweeps. They do not think is an issue, and there is
evidence to suggest that if burning did occur in gardens, that neighbours would
tend to report such activity.
2. It was suggested that some householders might take their waste to their place of
work. Though they consider this a possibility, they have no evidence to suggest it
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174
is, or is not, an explanatory factor. The County is inclined not to believe that this is
a major issue given the approbation that might follow from peers;
3. Some waste might be flushed into sewers (down toilets), but the County has made
checks with water companies and there is no evidence to suggest a change in the
nature or quantity of sewage;
4. Fly-tipping was, of course, considered a possibility. There were two critical places
where fly-tipping was deemed likely to occur. One is at the mini recycling centres,
the other is litter bins. There is no evidence of increases in disposal of waste in
fields and forests and so forth. The evidence that the County gathered through its
monitoring suggests that clearly fly-tipping happens, but the degree to which there
may have been a significant increase is not clear. There has been an increase in
the number of cases prosecuted. Penalties for illegal tipping were imposed in 54
cases in 1998/1999, and the number increased to 79 in 2000. The attitude of
the County is that this is something which happens anyway, it seems that it might
have occurred more frequently in the early days of implementation than at
present, and that with the support of politicians, the clean up of bring sites will
occur more often so as not to attract others to follow suit. It is not possible to
quantify the quantity of material cleaned up. On the one hand, there was no prescheme
data, and on the other, once cleaned up, the waste sometimes enters the
‘formal’ system without data being separately recorded.
The upshot of the Schweinfurt evidence is that it is not clear how one should account,
exactly, for around one sixth of the reduction in residual waste achieved. However,
the degree to which this is related to undesirable activities is believed to be small,
though clearly not zero.
9.12 Lessons Learned
The levels of acceptance and satisfaction among citizens are higher regarding a payper-volume
system compared with the flat rate per-person system. This is due to the
fact that the local competent authorities can pass on the reduction in costs
associated with improved performance in waste prevention and recycling directly to
the citizens. In addition, compliant households observe reductions in their fees,
sometimes considerable ones, directly related to the decreased amount of residual
waste for disposal. 201 In the long run the pay-per-volume fee system is more
transparent, since the citizens can control and follow the resulting costs.
From observable data, the effects on waste separation and recycling are often more
significant compared to waste prevention. However, with PAYT promoting the mindset
of waste awareness and the importance of separation, this can encourage waste
avoidance (such as home composting) and general waste prevention (such as
smarter shopping).
201 EUWID from 22.3.2005, p. 17.
29/09/09

The case of Schweinfurt is truly outstanding. Here, an already high-performing system
was made more so by the application of an intelligently designed hybrid pay-by-use
scheme. Weight-based systems, if not designed in this manner (i.e. with a frequencybased
charging element), might lead to high set out rates of bins with small quantities
of waste. Here, the inclusion of both weight- and frequency-based charges acts to
incentivise low set out rates of refuse bins. Citizens have clearly responded to this
incentive (so that savings in the quantity of residual waste set out for collection
translate into genuine savings in the collection system). The study clearly points the
way towards ‘tailor-made’ incentive schemes to achieve specific objectives.
Generally, waste prevention effects are highest where schemes have previously
collected biowaste free of charge, and have then introduced charges for the biowaste
container. A key factor in this ‘prevention’ appears to be increased home composting.
There is clearly a view that weight-based pricing affects waste quantities in the
strongest manner, but there is some concern that such approaches can give a greater
stimulus to illegal behaviour. On the other hand, it is clear that ‘subscription-style’
charging, where households sign up to a particular service option at the
commencement of a given period, has least effect as it gives little stimulus, at the
margin, for behavioural change. Consequently, charges per bag, or on the frequency
of the pick-up, or on the weight of the refuse set out, or a combination of the last two,
tend to be the most favoured options. Weight-based systems may offer the promise of
better performance, but without being coupled to frequency based charges, they may
fail to derive any benefit from improving the efficiency of the refuse collection
logistics.
9.13 Prerequisites for Introduction
A basic prerequisite for the introduction of waste charges is a legal regulation
requiring local waste charge statutes. Also, households need to be ‘connected’ to the
system – the approach used in German law is a specific obligation for households to
dispose of waste through the local waste disposal service. Charging at containerparks
is also necessary to ensure that no evasion of charges takes place.
In regard to the technical/logistical aspects of operating the pay-per-volume system, it
is important to integrate bar code reader systems (or alternative bin-chip systems)
with collection operations. Additional coordination of appropriate collection
frequencies is also important.
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10.0 Pay-by-use – Flanders, Belgium
10.1 Outline of Policy
Flanders is one of the few European regions to have set a target for the amount of
residual waste that should be produced per capita, i.e. 150 kg of residual waste per
inhabitant per year. In order to achieve this target, a mixture of instruments is used.
One of the economic instruments used is the PBU scheme.
The PBU system is based on differentiated tariffs (it is known as DIFTAR in Belgium
and the Netherlands): high charges for the residual fraction, lower charges for
packaging and organic waste and no charges for other selectively collected waste
streams (other recycling). This creates an effective financial incentive for households
to prevent waste or to sort out the household waste into different fractions. This gives
Flanders one of the highest recycling/composting rates in Europe, i.e. more than 70%
of household waste.
The ‘polluter pays principle’ is implemented at three levels through three different
tariff structures:
1) Prevention, at no costs or subsidised: home composting equipment is made
available for a reduced price, free stickers against unsolicited mail for post boxes
are made available, etc.
2) Selective collection, at a partial cost: low charge for waste flows that can be
avoided, such as biowaste (~ home composting) and plastic packaging waste (~
environmentally responsible products)
3) Residual waste, charged at full cost: waste charge covers the costs of the disposal
(i.e. incineration in Flanders).
Flat rate charges (in addition to the variable rate element) are also charged to hep
support the cost-recovery for the waste management system.
10.1.1 Prevention
As biowaste used to be the largest fraction of the residual waste (30-40%), Flanders
gives a lot of attention to the prevention of this fraction through home composting. In
most municipalities, composting equipment is available for a reduced price, yearly
education and communication actions are undertaken, a training programme for
‘compost masters’ is offered, composting demonstration areas are set up in recycling
centres and in schools, and similar places. 202
202 For a description of the master composting scheme run by OVAM, see, for example, Eunomia
Research & Consulting and M. E. L. Research for ECOTEC Research & Consulting (2002) Towards
Sustainable Waste Management Practice, Report for SNIFFER, SR(02)05a, April 2002.
176
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10.1.2 Approaches to Selective Collection
In Flanders, 70% segregation of household waste is achieved through door-to-door
collections and bring site methods (recycling centres). Since the municipalities are
responsible for the organisation and financing of municipal waste management,
different collection methods (e.g. bags or containers), frequency, types of collected
waste and charges are possible. However, the Flemish Public Waste Agency, OVAM,
demands minimum fractions to be collected and minimum collection method and
frequency. Where DIFTAR receptacles are mentioned, the price for waste collection is
determined by the weight or the volume of containers (specific bags, chipped bins or
other receptacles). Details are presented in Section 10.3 of these Annexes.
10.2 Where Has the Policy Been Applied and Why?
A strong driver for the frequent and efficient separate collection of many waste
streams is found in the environmental policy agreements or covenants. These
covenants are voluntary agreements between the Flemish government and the
municipalities. The municipalities receive financial support from the Flemish
government when they meet a number of environmental management targets during
a certain period. This financial support is partly linked to the performance obtained
and can be considered as a goal-oriented instrument: e.g. in the field of waste policy,
financial support is only received when the municipality produces less than the target
150kg residual waste per habitant per year. For certain cities the target is adjusted
taking into account the presence of illegal immigrants, tourists, students, etc.
The covenants are financed by the revenues from an environmental policy fund
(MINA-fund), supported by environmental levies on landfill and incineration. The first
voluntary covenant (2002-2004) was drawn up to cover separate collection of
municipal waste and investment in infrastructure (Milieu als opstap naar duurzame
ontwikkeling, 2001). Nowadays waste prevention is the main priority together with
encouraging the use of sustainable materials and products (reflecting past success
with separate collection systems).
10.3 Country-specific Characteristics
Segregation of household waste is organised in Flanders as described in Table 10-1.
A differential tariff (DIFTAR) applies to mixed household waste, separate collection of
vegetable, fruit and garden (VFG) biowaste and of waste packaging.
The costs in Flanders for collection and disposal of waste are lower than in other
countries with less ambitious targets and lower rates of diversion. The overall cost of
the extended system of separate collection based on supply and collection methods
amounts to €220 per year per average family of 2.4 people. Of this:
177
� €36 of this is paid through producer responsibility price increases (on
packaging, batteries, WEEE, etc.)
� €184 is paid at municipality level. The municipality receives funds from three
sources, each contributing roughly a third of the municipality level payment:
� Direct charging for waste – a variable cost based on quantities of
residual and other chargeable wastes (DIFTAR applies);
International Review of Waste Policy: Annexes

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� A fixed residual waste tax per household, covering all fixed costs and
also the variable costs that are not directly charged to the polluter (e.g.
personnel, costs of evasive behaviour etc.);
� General tax related to household income.
In 2000, the average price of a 60l residual waste refuse bag was €0.66. This has
meanwhile risen to €1.5 on average, and even to €2 in some municipalities. In the
case of weight based schemes, some regions have established maximum tariffs with
the objective of ensuring that the incentive to dump is not too great. So, for example,
in the Antwerp region, it is considered acceptable to have a tariff no greater than 0.15
euro/kg. 203
Table 10-1: Separately Collected Fractions of Household Waste in Flanders
Household waste
Fraction Fraction
Collection Collection method
method
Bi-weekly door-to-door collection (more frequent in tourist areas) in
DIFTAR receptacles
Bulky waste CA / bring sites, door-to-door collection, collection on demand
Vegetable, fruit and garden waste Door-to-door collection in DIFTAR receptacles or home composting
Paper and cardboard waste Door-to-door collection and CA sites
Glass waste (glass cullet)
PMD-waste (plastic bottles and flasks,
metal packaging and drink cartons)
Bottle bank – two-colour separations, CA sites, sometimes door-to-door
collection
Door-to-door collection in DIFTAR receptacles
Textile waste CA site, door-to-door collection, separately placed containers
Construction and demolition waste
containing asbestos
CA site
Stone debris – inert CA site
Pruning CA site, sometimes door-to-door collection
Fine garden waste and grass CA site
Metals, discarded iron CA site
Wood waste CA site
Tree trunks Composting facility or CA site
Small hazardous waste (all fractions) +
injection needles
Old and expired medications / drugs Pharmacist
Waste electrical and electronic
equipment (WEEE)
CA site (SHW-safe) or door-to-door collection or district collection
(mobile SHW-safe)
CA site and re-use centres, conform to acceptance requirement
Re-usable goods Door-to-door collection on demand, re-use centre
203 Personal communication with Paul Macken, IOK.

10.4 Key Organisations Involved in Implementation and
Management
The implementation of PBU measures is coordinated by OVAM (the Public Flemish
Waste Agency) through a household waste plan, and realised by the municipal
authorities. A key role is held by the expert centre VLACO, the Flemish organisation for
promoting composting and compost use, as well as home composting.
10.5 Pre-implementation / Evaluation Studies Available
The following evaluation reports are available with specific relevance to Belgium and
the Flanders situation. These have been used to provide the references for this
section:
179
� DIFTAR in Vlaanderen. Evolutie belastingen en retributies 1996-2000, OVAM,
2001, on the evolution of differentiated tariffs in taxes and retribution systems
between 1996 and 2000. (Dutch)
� DIFTAR op containerparken, OVAM 2003, manual on how to apply
differentiated tariffs on a civic amenity site for selective waste collection.
(Dutch)
� DIFTAR binnen het Vlaamse afvalbeleid, OVAM 2002, manual for local
government on the implementation of DIFTAR systems. (Dutch)
� Eindevaluatie van het afvalvoorkomingsproject DILBEEK, OVAM 1998,
research project evaluating the progressive waste prevention programme in
the municipality of Dilbeek near Brussels, using an alternative approach
differing from the common approach in Flanders. (Dutch)
� Evaluatie van de reductie van de terminaal te verwijderen huishoudelijke
afvalstoffen in Vlaanderen, OVAM 2002, research report on the reduction of
the amount of household waste that has to be disposed of by landfill and
incineration. (Dutch)
� Evaluatierapportage Uitvoeringsplan huishoudelijke afvalstoffen 1997 –
2001, OVAM, 2002, evaluation report on the waste management plan 1997-
2001. (Dutch)
� Evaluatierapportage Uitvoeringsplan huishoudelijke afvalstoffen 2002-2007
OVAM, 2008, evaluation report on the waste management plan 2002-2007.
(Dutch)
� Het effect van huisvuilbelastingen en retributies op het aanbod van
huishoudelijk afval, OVAM, 1999, on the effect of household waste retributions
and taxes on the amount of waste collected. (Dutch)
� Gemeentelijke belastingen en retributiesystemen voor de inzameling en
verwerking van huishoudelijk afval - Enquêteresultaten 1996, OVAM, 1996,
result on an inquiry on municipal taxes and retribution systems for the
collection and treatment of municipal waste. (Dutch)
� Inventarisatie huisvuilbelasting- en retributiesystemen voor inzameling en
verwerking van huishoudelijke afvalstoffen in Vlaanderen - Enquêteresultaten
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1998, OVAM, 1996, result on an inquiry on municipal taxes and retribution
systems for the collection and treatment of municipal waste. (Dutch)
� Inventarisatie huisvuilbelasting- en retributiesystemen in Vlaanderen en de
impact op de huisvuilproductie - Enquêteresultaten 2000, OVAM, 2000,
update on municipal taxes and retribution systems for the collection and
treatment of municipal waste, and its impact on the amount of waste
collected. (Dutch)
10.6 Environmental Benefits
In 1991, the national situation was that Flanders produced on average 406kg waste
per habitant per year. 20 per cent of this waste (82kg) was recycled or composted. By
2004, waste generation per inhabitant had risen to 560kg a year (this figure stopped
rising in 2002) and 71 per cent of this waste (401kg) was recycled or composted.
Residual waste largely goes to incineration with energy recovery.
It is difficult to examine a cause and effect relationship between PBU instruments and
the decrease of the generation of waste or the increase of the percentage recycled of
composted waste. Household waste policy has always been implemented using a
mixture of policy instruments among which PAYT is only one. The evolution of the
statistics is influenced also by market shifts (such as the wider availability of separate
collection infrastructure, the market value of recyclable waste). Even climatic
conditions can influence the figures (warm and moist summers generate more garden
waste). Changes in the way waste data are registered can play a role as well. As a
consequence of the above mentioned covenants between the local and the regional
governments, company waste that is comparable with household waste is
progressively taken out of the statistics.
In any case a correlation can be seen between the progressive introduction of PBU
principles and increases in recycling rates. It is reasonable to presume that PBU was
an important factor in supporting this evolution.
10.7 Implementation Costs
The costs of implementing DIFTAR systems is fairly well established in Flanders. It
does, however, depend on the specifics of the scheme. Different schemes use
expensive sacks, frequency based charging, or weight-based systems. The last of
these requires greatest up-front investment in vehicles, whilst both frequency and
weight-based schemes may require adjustments to the approach to billing.
OVAM reports a minimal cost of €50/family for the implementation of a DIFTAR
system (containers, hardware and software, adjustment of waste collection trucks,
etc.). The cost of implementing DIFTAR in a civic amenity site (CAS) averages €80,000
(weighbridge, badges, hardware and software, barrier, etc.). 204
204 OVAM (2008) Uitvoeringsplan milieuverantwoord beheer van huishoudelijke afvalstoffen,
Mechelen: OVAM.

FOST-Plus reports the following collection costs for separately collected waste
streams: 205
181
� Glass: €1.51/capita;
� Paper-cardboard: €1.01/capita;
� PMD (collection and sorting): €5.61/capita; 206
� Communication: €0.36/capita;
� Other costs: €0.65/capita.
With regard to these waste streams, FOST-Plus pays the intermunicipal organisations
the full cost of collection and sorting, in the frame of a EPR mechanism for packaging
waste (see Annex 15.0).
10.8 Effects on Technical Change / Innovation
The implementation of DIFTAR systems required some technical changes to waste
collection operations. The first generation of DIFTAR systems were sack- or tag-based
(the constraint being on the volume of material generated), the charge being levied
through the sale of specific sacks, or of identifying stickers. These systems remain the
most commonly applied approach.
A desire for more sophisticated systems which better convey the incentive to reduce
the weight of waste produced has led to development of pay by weight DIFTAR
systems. In this case chipped bins are weighed when loaded onto collection trucks.
Additionally, in the more urban context, underground containers with limited capacity
loading and automated identification systems have been developed (much as with
the German sluice gate systems). 207
DIFTAR may be said to have increased the number of segregated waste streams and
amount of material recycled. It cannot, however, be seen as the only reason for the
growth and the consolidation in this sector in the last decade (see also Section 10.6).
It may also be noted that municipal waste remains under 10% of the total quantity of
waste generated in Flanders.
10.9 Social and Distributional Consequences
DIFTAR could affect social inequality where more wealthy households are able to
afford to produce more mixed waste than households on the edge of poverty even
when sorting a large amount of their waste.
205 FOST-Plus (2008) Annual Report 2007 (note FOST-Plus is the entity responsible for household
packaging waste recycling in Belgium – see Appendix 15.0).
206 Note PMD = plastic, metals and drinks containers.
207 These systems are dewscribed in the Luxembourg case in D. Hogg (ed.) (2002) Financing and
Incentive Scheme for Municipal Waste Management: Case Studies, Final Report to DG Environment
the European Commission.
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DIFTAR charges are intended to replace part of the municipal taxation on income, as
well as a flat rate municipal waste tax. Low income individuals often do not pay
income taxes so it is possible that waste associated costs may be increased for this
section of society. However, social correction mechanisms have been introduced by
different municipal authorities to reduce disproportionate effects. Specific exclusions
apply for families with newborn children to account for diaper waste (the use of
reusable diapers is only marginally introduced in Flanders). Low income families and
families with newborn children usually get a number of residual waste bags for free,
e.g. 20 to 40 bags per year.
Ideologically, DIFTAR ought to replace an equal income generated from surtaxes or
municipal waste taxes. However, several municipalities have introduced DIFTAR and
only partially reduced municipal taxes, thus leading to a general increase in the
revenue take from households. This diminishes the social acceptance of DIFTAR and,
more generally, of environmental taxation.
10.10 Complementary Policies
DIFTAR systems should be combined with policy measures that ensure alternative
avenues for individual materials. These alternatives need to be easily accessible for
individuals. Minimal standards for separate collection have been deemed necessary
in Flanders, ensuring that when DIFTAR schemes are introduced, households’
propensity to resort to fly tipping is minimised. Waste minimisation (and ease of
recycling) policy measures need also to be targeted at producers and distributors.
DIFTAR ought also to be combined with initiatives to enhance the home treatment of
biowaste. One way of doing this, which is used in many Flemish authorities, is the
introduction of charging for the biowaste container. Home treatment can be realised
by promoting home composting or ‘chicken projects’. Several municipalities in
Flanders actively promote the ownership of chickens because they eat leftover
biowaste. An average consumption of 150g/day kitchen waste or 50 kg/year can be
reached. The Animal By-Product Regulation needs to be observed when feeding
chickens with kitchen waste. The material is not considered to be waste, as it is not
discarded, and it is in principle fit for human consumption. However, three important
principles needs to be respected:
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� The food chain has to be controlled through to the end consumer;
� Cannibalism must be avoided; and
� Feeding with animal products is forbidden.
The effects on the private chicken owner are that no meat, fish or meat products may
be given to the chicken, and no kitchen waste with meat (like spaghetti sauce). The
eggs and the meat of the chicken are only destined for private consumption.
Policies that make residual waste more expensive help to encourage diversion of
material up the waste hierarchy.
10.11 Effect of the Policy on Pricing of Resources / Services
In principle, waste charging policies ought to be financially neutral for the government
or municipality, as long as PBU systems replace existing flat fee taxation. The aim is
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to recover costs in such a way that an incentive is given to households to segregate
waste, and reduce waste generation.
While the flat taxation system has no link to (or impact on) the quantities of waste
generated by individual citizens, the DIFTAR financing system does discriminate
between small and large waste producers. The consequence is that individuals are
directly incentivised to improve their waste production behaviour. The resultant
reduction in residual waste can translate into a reduction in net costs.
It may be said, therefore, that such a regulatory system ensures a better
correspondence between financial costs (charges for waste production placed on
individuals) and environmental costs (associated with waste disposal) and it may
therefore be considered a move towards a more economically efficient pricing system
which shifts society towards a more optimal allocation of resources. It might not be
‘efficient’ in the strict sense, but it is likely to be more efficient than a policy where no
variable charge element exists, and where ‘over-use’ of waste services results from a
zero marginal cost regime.
10.12 Evasion and Enforcement
With the introduction of pay-by-use schemes such as pay-by-use there is always
concern that an increase in evasive behaviour might occur, such as illegal dumping,
waste tourism, backyard incineration, and contamination of separated waste
fractions. There is currently no information in the available literature as to whether
this has been the case in Flanders. Some municipalities report there has been an
increase in illegal dumping, while others (mainly the intermunicipal organisations who
have insight into the total amounts of waste across municipalities) contradict this.
The argument on illegal dumping and waste tourism has been used very frequently in
the discussion by the people opposed to PBU, but an increase in dumping or waste
tourism was not substantiated through scientific studies. This may not exclude
occasional cases of illegal avoidance in response to PBU systems.
The quality of segregated waste appears currently to be high, and targets are aimed
to further reduce contamination. The current targets are a maximum of 3%
contamination for VFG (vegetable, fruit and garden waste) and paper and cardboard
waste, 5% for wood and glass waste, 15% for construction and demolition waste, and
5 to 15% for textile waste.
10.13 Lessons Learned
The Flanders experience may be summarised as follows:
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� PBU systems are accepted when they are not perceived by the population as
an additional cost, but as a benefit for those producing less waste.
Communication and a clear and obvious link with flat rate tax cuts is
necessary.
� PBU can only be successful if an infrastructure for separate collection is
available to allow producers to avoid using the residual waste collection
service. Since PBU can result in high captures of recyclables, it can create the
environment for cost-effective collection of additional selective material
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streams. Charging at containerparks is important to maintain the incentive to
recycle (and not allow a free outlet for waste);
� The concept that PBU can enhance fly-tipping or illegal waste activity has to be
regarded on its own merits as no scientific studies in Flanders have proved the
existence of a relation between the two. It should be noted, however, that
typically, the variable charge element in Flanders is of the order €60 per
household per annum. The payment of such a charge does not constitute a
major incentive to dump waste (indeed, it might cost more to drive to a
relevant place and dump the waste);
� PBU requests mitigating measures for people at the edge of poverty and for
families with very young children.
10.14 Prerequisites for Introduction
The implementation of PBU systems needs to be coupled with a reduction in
alternative forms of taxation. As such, a working relationship needs to be in place
between the body administering waste charges (potentially the local authority via
waste collection companies) and the bodies responsible for other financing
mechanisms (both local and central government).
Social acceptance of PBU systems is best achieved where there is a high level of
public awareness of the environmental issues concerning waste. Public education
programmes may help create the public will to take responsibility for its own waste.
Although industry will quickly adapt to PBU (since new market opportunities for waste
collection, recovery and treatment will be created), a basic infrastructure with
sufficient recycling capacity remains necessary.

11.0 Landfill Levy - Ireland
11.1 Outline of Policy
Ireland has a number of targets to meet in relation to waste management. A target of
diverting 50% of household waste from landfill by 2013 remains some distance away,
with only about 26% recovered in Ireland in 2007, though this has increased from
22% in 2006.
The relatively low cost of landfill in Ireland had contributed to an over-reliance on this
waste management option and mitigated against other, more desirable, waste
recovery options. One instrument used to combat this was the introduction of a
landfill levy.
The Government introduced a levy of €15 per tonne on the landfill of waste on the 1st
of June 2002 under the Waste Management (Landfill Levy) Regulations 2002. On the
1st of July 2008, the landfill levy rate was increased to €20 per tonne for each tonne
of waste disposed of at authorised landfill facilities.
There are proposals in place to amend the levy, which would include significant
immediate increase to the landfill levy, with the upper limits of the levy also to be
significantly increased. Furthermore, it is known that the Government is considering
broadening the landfill levy such that it becomes a waste facility levy, encompassing
incineration (see also Annex 56.2.1).
11.2 Policy Context and Reason for Introduction
The landfill levy was introduced to encourage the diversion of waste away from landfill
and generate revenues that can be applied in support of waste minimisation and
recycling initiatives.
The landfill levy emerged, and has evolved in the following ways:
� 1998 1998 - Changing Our Ways emphasised the need for producers of waste to bear
the full costs of waste collection, treatment and disposal, in accordance with the
Polluter Pays Principle and advocates that the level of waste charges imposed
should vary according to usage, so as to incentivise waste minimisation and
recovery. In response to this the Government decided to introduce a landfill levy
in 2002, to encourage the diversion of waste away from landfill.
� 2002 2002 – A levy of €15 per tonne on the landfill of waste was introduced on 1
June 2002 under the Waste Management (Landfill Levy) Regulations 2002. The
levy was designed to encourage the diversion of waste away from landfill and
generate revenues that can be applied in support of waste minimisation and
recycling initiatives. All levies are remitted to the Environment Fund. There are
exemptions under the Waste Management (Landfill Levy) Regulations, 2002,
including the following summarised materials:
185
• non-hazardous inert waste from construction and demolition activity used
for landfill site engineering;
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• excavation spoil used for landfill site engineering;
• stabilised waste arising from the composting of the biodegradable
fraction of municipal waste (to which fraction sewage sludge may have
been added);
• waste arising from street cleaning activities;
• illegally deposited waste;
• residues from filtration during the extrusion of recycled polymeric
material:
• non-metallic residues from the shredding of end-of-life vehicles, white
goods and other metal waste; and
• dredge spoil from inland waterways and harbours.
� 2006 2006 - As a penalty for those who illegally deposit waste, the Waste
Management (Landfill Levy) (Amendment) Regulations 2006 introduced a levy of
€20 per tonne for each tonne of waste disposed of at unauthorised facilities on
and from 28 July 2006. This means that persons responsible for the illegal
deposition must pay the levy and remove the waste, as required by Section 60
Policy Direction, and remediate the land, apart from any other penalties that
may be imposed through the courts;
� 2008 2008 - As of 1 July 2008, the Minister for the Environment, Heritage and Local
Government increased the landfill levy, using the power available to him under
the Waste Management Acts. The Waste Management (Landfill Levy) Order
2008 amends section 73(3) of the Waste Management Acts 1996 to 2008 to
allow for the landfill levy to be increased from €15 per tonne to €20 per tonne
for each tonne of waste disposed of at an authorised landfill facility;
� 2008 2008 (August) (August) – The Government initiated a Regulatory Impact Assessment
(RIA) for a Waste Facility Levy (WFL) which would include a significant immediate
increase to the landfill levy, with the upper limits of the levy also to be
significantly increased. Furthermore, the landfill levy is to be broadened to a
waste facility levy. The RIA for the Waste Facility Levy (WFL) was forwarded to
interested parties on the 29th of August for comment. The results of the RIA are
not currently publicly available.
11.3 When was the Policy Introduced?
The policy development chronology is detailed in the Section above.
11.4 Key Organisations Involved in Implementation and
Management
The key organisations involved in implementation are:
� The Department of Environment, Heritage and Local Government;
� The Local Authorities;
� The Controller and Auditor General; and

187
� Landfill operators.
Local Authorities effectively act as collectors of the landfill levy. To the extent that they
operate landfills themselves, they are required to remit their levy liability directly to
the Department of Environment, Heritage and Local Government (DoEHLG). Operators
of private landfill facilities are required to remit their levy liability to the relevant local
authority in whose functional area the facility is located. The authority will then
transfer the revenue to the DoEHLG.
The DoEHLG publishes an Environment Funds Account Report. This report details the
income from the environmental levy on the landfill of waste and also from the
environmental levy on plastic bags.
11.5 Monitoring and Measurement Techniques Applied
The income from the landfill levy is a direct measure of the waste being disposed of in
a landfill. This allows the DoEHLG to examine if this levy actually disincentives waste
contractors (public and private) from disposing of waste in landfills.
It is the function of each local authority to enforce and audit compliance with the levy
requirement within its functional area. The local authorities must prepare and submit
annual reports to the Minister of the Environment and Local Government on their
enforcement activities. Section 12 of the Waste Management (Landfill Levy)
Regulations 2008 states that:
“For the purpose of ensuring compliance with these Regulations, a relevant
landfill facility shall be subject to inspection and audit by, as the case may be,
a relevant local authority, a Local Government Auditor or any other auditor
appointed by the Minister or a local authority for that purpose.”
11.5.1 Evaluation Studies Available
The effect on waste prevention of the landfill levy is somewhat indirect and therefore
very difficult to measure. Even if one could identify a change in the quantity of waste
generated, tracing back this to the levy itself would not be straightforward. There are
no evaluation studies, which have really sought to understand the effects of the levy
other than in respect of the revenue generated.
During the course of this review, work has been published concerning the way in
which PBU systems might interface with the landfill levy to influence waste arisings,
and to influence the level of recycling achievement. However, these studies assume a
direct correspondence between PBU systems and the level of the levy, suggesting
that weight based systems necessarily reflect the cost of disposal directly in their
existing, and future, pricing structures. Whilst this could be the case, and whilst some
schemes such as the Schweinfurt scheme described in Annex 9.0, seek to relate
weight-based pricing directly to the marginal benefits of avoided disposal, it is not
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necessarily clear that systems do price on the basis of landfill disposal costs, nor that
they would necessarily do so in the future. 208
The Environmental Fund allows one to review the revenue from this levy, which can
be used as part of the picture needed to assess its effectiveness. An audit of the
financial statements of the Environment Fund for the year ended the 31st December
2007 under Section 74 (6) of the Waste Management Act 1996 (as amended) was
carried out by the DoEHLG. Table 11-1 represents the amounts collected by the local
authorities in respect of the Environmental Levy on the landfill of waste from 2002 to
2007.
Table 11-1: Landfill Levy Funds 2002 - 2007
Environmental
Levy on the
Landfill of
Waste
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2002 2002 2003 003 003 2004 2004 2005 2005 2006 2006 2007
2007
€17,868,726 €29,359,585 €26,765,514 €27,798,605 €30,750,433 €33,398,929
Source: Department of Environment, Heritage & Local Government, 2002 – 2007
It is apparent from the table above that the revenue earned from the landfill levy
increased between 2005 and 2006.
Various attempts to analyse the effectiveness of the landfill tax have concluded that it
has affected construction and demolition wastes (C&D), and commercial and
industrial (C&I) wastes, but that its affect on household waste has been limited thus
far. The National Waste Database Report 2006 indicates that household waste
generation increased in 2006 by 229,774 tonnes when compared with 2005 figures,
as shown in Table 3-2. This table also illustrates that the amount of waste generated
since 2001 has increased by 33%.
208 One report highlights a mean across all areas of €0.0442/kg with a maximum of 0.460/kg and a
standard deviation of €0.104/kg (J. Curtis, S. Lyons & A. O’Callaghan-Platt (2009) Managing
Household Waste in Ireland: Behavioural Parameters and Policy Options, ESRI Working Paper 295,
http://www.esri.ie/UserFiles/publications/20090728095754/WP295.pdf . However, this report
included areas without weight-based charging, so the average figure would be biased downwards by
zero values in some areas. The high end figure suggests that the pricing in weight based systems might
not always be closely related to landfill gate fees, though clearly, there may be some influence from the
gate fee through to the marginal charge rate. At the high end of this range, however – equivalent to a
€460 per tonne disposal cost – changes occasioned by changes in landfill gate fee might have a
proportionately lower additional effect than in cases where the marginal weight-based charge is
currently lower.

Table 11-2: Trends in Household Waste Management
Quantity
Landfilled
Quantity
Recovered
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2001 2001 2002 2002 2003 2003 2004 2004 2005 2005 2006 2006 2006 2007
2007
1,254,857 1,294,061 1,231,109 1,214,908 1,198,504 1,379,246 1,200,980
74,887 132,602 185,753 285,872 344,964 393,995 424,510
Total Total 1,329,744 1,426,662 1,426,662 1,416,862 1,416,862 1,500,780 1,500,780 1,543,468 1,543,468 1,773,242 1,773,242 1,773,242 1,625,490
1,625,490
Source: National Waste Database Reports, 2006 and 2007
When the levy was first introduced in Ireland, landfill gate fees were on a rising trend,
therefore (it has been suggested that) there was no real requirement to increase the
levy while landfill gate fees were on an upwards trend. In recent years however, gate
fees in Ireland have started to decrease.
� The average landfill gate fee in Ireland in 1999 was €30; 209.
� The average landfill gate fee in Ireland in 2002 was €102 (excluding landfill tax);
� In 2005 the average landfill gate fee was €124.50 (excluding landfill tax). 210
There are local variations for example the average gate fee in the Cork Region
was €182.50 in 2005 (excluding landfill tax);
� In 2006 the average landfill gate fee was €120.00 (excluding landfill tax); 211
� The average landfill gate fee in Ireland in 2007 was €112 per tonne (excluding
landfill tax), therefore it seems that the general trend in landfill gate fees are
returning to the 2002 levels. 212 In some parts of Ireland, gate fees excluding tax
have fallen to €80 per tonne.
Landfill gate fees can vary considerably across the country due to a number of factors
such as the amount of excess landfill capacity available, the amount of waste
generated and the availability of alternative landfills and waste treatment options in
the region.
Although Ireland has some of the highest landfill gate fees (pre-levy) of any Member
State, it has one of the lowest levies. However, it has to be highlighted that many
countries with high landfill taxes in place also have in place landfill bans or
209 Forfás Research, http://www.smallbusinessforum.ie
210 Study Completed by TOBIN Consulting Engineers in December 2006
211 Forfás (2007) Waste Management in Ireland, Benchmark Analysis and Policy Requirements, March
2007.
212 Forfás (2008) Waste Management in Ireland, Benchmark Analysis and Policy Requirements, May
2008.
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estrictions (see Annexes 52.0 to 55.0), so that the option of landfilling of waste
without any form of treatment is progressively outlawed completely. The effectiveness
of the levy is, to some degree, being undermined by the reduction in the cost of the
gate fee per tonne. This is even more significant when considered in real terms.
Whilst gate fees appear to be declining in nominal terms in recent years, between
2002 and 2008, the levy’s effectiveness was simply being eroded by inflation. Table
11-3 details the landfill gate fee inclusive of the levy, and the proportion accounted
for by the levy. It is apparent that the landfill levy of €15 per tonne as a percentage of
the landfill gate fee remained similar over this six year period. The fact that the levy
has remained constant in nominal terms has meant that as pre-levy gate fees fall, so
the total costs of landfilling are also declining, not just in nominal terms, but in real
terms as well.
Table 11-3: Percentage of Landfill Levy on Gate Fee
Date Gate Fee (incl levy) Landfill Levy as % Total Gate Fee
2002 €117.00 12.8%
2005 €139.50 10.8%
2006 €135.00 11.1%
2007 €127.00 11.8%
* Inclusive of €15 Landfill Levy
The landfill levy was increased in July 2008 to further discourage the use of landfill as
a treatment option. The aim of the increase was to reduce the quantity of waste being
disposed of in landfill and to increase recovery and recycling rates (DoEHLG). This
increase in the levy of €5 per tonne may not be effective in reducing the rate of waste
being treated at landfill as the increase appears only to counter some of the
reductions in landfill gate fees that have been occurring in recent years.
Given the above, then it seems likely that the effect of the levy will have been
somewhat limited. To the extent that the costs of landfilling might have influenced
behaviour, probably, the strongest influence will have been exerted in the period
during which landfill gate fees rose in response to tighter regulatory controls.
While the landfill tax is stated on invoices, for businesses that produce little waste,
the landfill tax is minimal. For an office the average cost related to the landfill levy is
of the order €2-3 per month. This gives very little incentive to change behaviour.
11.6 Environmental Benefits
The degree to which environmental benefits will have been delivered by the incentive
effect of the levy is not clear. In this context, it is worth examining, for example, the
likely incentive effects to recycle packaging coming from:
190
• Changes in landfill gate fees;
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191
• The effects of the Repak Payment System (RPS); 213 and
• The landfill levy. 214
Towards the end of 2000, a review of gate fees conducted by Kirk McClure Morton in
the context of work establishing the basis for the landfill levy suggested that gate
fees, in 1999, ranged from IR £15 (€19) per tonne to IR £32 (€41) per tonne for
household and commercial and industrial waste, with one landfill charging a higher
rate of IR £52 (€66) per tonne. By 2002, these had reached €102 per tonne, and by
2005, €124.50 per tonne (pre landfill levy gate fees). In short, between 1999 and
2005, the average costs of landfilling increased by a factor of 5 in nominal terms, or a
factor of approximately 3.7 in real terms.
In real 2005 terms, the differential was around €91 per tonne. Relative to the levy, at
a maximum of €15 per tonne in these years, this is a huge change. Equally, for waste
producers / collectors, because recycling ‘runs off’ the avoided costs of disposal, this
change will have had a significant impact.
It would seem reasonable to suppose that for commercial waste in particular, with the
relatively small (compared with those for household waste) levels of price support
through the RPS supports outlined in Table 11-4 below, that the significant rise in
landfill gate fees, as well as the (until recently) upward trend in materials prices would
have been far more influential in increasing packaging waste recycling than the RPS
rates themselves. These rates are only of any significance for steel and plastic.
The rates for household waste are more likely to have been influential in determining
the effort made to collect and recycle packaging waste (see Table 11-5). Yet the
quantities of packaging recovered through the household stream are far lower than
from the non-household stream (of the order a third of the recovered material.
Table 11-4: RPS Rates for Commercial ‘Back Door’ Waste Recycled (2008 rates, € per
tonne recycled)
Material Material Open Open Loop Loop Closed Closed Loop Loop Recovery Recovery Metal Metal Protocol
Protocol
Glass 4.20 12.60
Paper/Cardboard 4.20 9.45 4.20
Wood 6.30 10.50 4.20
Aluminium 10.50 12.50
Steel 36.75 36.75 10.50
Plastic 52.50 52.50
Source: Repak
213 See Appendix 12.0 for further information on the RPS.
214 One could argue that the Environmental Fund should also be considered as a separate influence.
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Table 11-5: RPS Rates for Household Waste Recycled (2008 rates, € per tonne
recycled)
Material Material Material
Kerbside Kerbside Kerbside Bring Bring
Bring
Glass Packaging (e.g. bottles, jars, etc.) 20.00 20.00
Glass Packaging open loop recycling 4.20 4.20
Paper Packaging (e.g. cereal boxes, etc.) 76.23 68.14
Used Beverage Containers 76.23 68.14
Aluminium Packaging (e.g. drinks cans, etc.) 76.23 68.14
Steel Packaging (e.g. food packaging, etc.) 96.80 86.53
Plastic Packaging - Plastic Rigid Bottles 220.00 220.00
Other Plastic Packaging – tubs, pots, trays, jars 76.23 68.14
Source: Repak
In summary, as regards recycling, it seems reasonable to suggest that one of the
most powerful influences will have been exerted by the increase in pre-levy landfill
gate fees since the second half of the 1990s. Also important in recent years will have
been the buoyant market for secondary materials. Importantly, the market has now
shifted from one where quality barely mattered, to one where the market only wants
quality materials. This will certainly be affecting low quality mixed paper grades
destined for the export market, in turn, tending to encourage collectors to consider
quality more closely than they might hitherto have done.
However, the levy has raised revenues, which are paid into an Environment Fund. This
was established by the Waste Management (Amendment) Act 2001 (No.36 of 2001)
and is managed and controlled by the Minister for the Environment and Local
Government. The fund was established with effect from 17 th July 2001. The details of
how the Environmental Fund 2006 was spent on waste prevention and recycling is
outlined below.
The proceeds from both the landfill levy and the plastic bag levy, collected by local
authorities, are paid into the fund and the money is used for a range of measures
including programmes and schemes to prevent or reduce waste, operation of waste
recovery activities, litter prevention, environmental partnership projects and
environmental awareness, education and training.
11.6.1 Environmental Benefits – Prevention
There are no statistics available which would allow for a confident prediction of the
influence of the waste levy on waste growth either in the household or non-household
municipal waste streams. The rate of waste growth prior to the introduction of the
landfill levy is not well known. As such, it is difficult to assess whether waste growth
has been materially influenced by the levy. There are studies which have assessed
the sensitivity of demand for waste services with respect to price, but these tend to
suggest inelastic responses, so that with the effects on landfill prices being relatively
small, the price effect would be expected to be similarly weak.
We are not aware of any attempt to evaluate the environmental benefits of the
expenditure of fund revenues, but they might reasonably be assumed to have been
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positive. In 2007, of the €32,398,929 (as shown in Table 11-1 above) generated in
income from the levy on the landfill of waste, the following was spent on Prevention
Initiatives:
193
� “Waste Prevention and the National Market Development Group”,
€1,518,213;
� “Producer Responsibility Initiatives”, €905,793; and
� “Environmental Awareness”, €1,615,332.
The above figures illustrate that a large number of Environmental Awareness
Campaigns and Waste Prevention Programmes, both nationally and within local
authorities, have been supported through monies available from the Environmental
Fund. Therefore this levy has indirectly influenced preventative initiatives in Ireland.
11.6.2 Environmental Benefits Associated with Recycling
In 2007, of the €32,398,929 (as shown in Table 11-1 above) generated in income
from the levy on the landfill of waste, the following was spent on recycling initiatives:
� “Waste Management including Recycling Projects”, €17,246,428. This
represents payments made to local authorities to assist in capital costs
associated with the provision of waste management infrastructure; and
� “Recycling Operational Costs”, €11,914,847. This represents payments made
to local authorities to assist with the operational costs of recycling.
This funding has assisted in the development of recycling facilities/infrastructure to
have been put in place, having a positive impact on recycling in Ireland. The monies
from this Environmental Fund are only made available to local authorities. The private
sector is not eligible to receive support from the Environmental Fund.
The main objective of the landfill levy is to encourage the diversion of waste away
from landfill and generate revenues that can be applied in support of waste
minimisation and recycling initiatives. Figure 11-1 below details the trends in
municipal waste recovered and disposed of from 2001 to 2007. Table 11-6 below
details the trends in household waste managed from 2001 to 2007.
From the table above it is apparent that the recycling rates have increased since the
introduction of the landfill levy in 2002; this can in part be as a result of monies
available from the Environmental Fund for the development of recycling infrastructure
in local authorities’ functional areas, but as discussed above, more significant effects
are likely to have been experienced through the change in landfill prices more
generally (i.e. before the addition of the levy).
The amount of household waste managed by local authorities and the waste industry
has increased by 33% since 2001, while during the same period the amount of
household waste recovered has increased four-fold since 2001, which reflects
increases in recycling infrastructure. 215
215 EPA (2007) National Waste Report 2006, Wexford: EPA.
International Review of Waste Policy: Annexes

Figure 11-1: Trends in Recovery and Disposal of Municipal Waste
Table 11-6: Trends in Household Waste Management
Quantity
Landfilled
Quantity
Recovered
Total
Total
Waste
Waste
Produced
Produced
Average
Landfill
Gate Fee
Landfill
Levy
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2001 2002 2003 2004 2005 2006 2007
1,254,857 1,294,061 1,231,109 1,214,908 1,198,504 1,379,246 1,200,980
74,887 132,602 185,753 285,872 344,964 393,995 424,510
1,329,744 1,329,744 1,426,662 1,426,662 1,416,862 1,416,862 1,500,780 1,500,780 1,543,468 1,543,468 1,543,468 1,773,24 1,773,242 1,773,24 1,625,490
1,625,490
€117 €139.50 €135 €112
- - - - €15 €15 €20
11.7 Implementation Costs
The Environment Fund Accounts 2007 indicate an expenditure of €388,025 for
“Environmental Levy Collection Costs”, this equates to less that 1% of the total
income from the levy on the landfill of waste.
Landfill Operators incur a cost in the compilation of the data and preparation of
returns to the Department. The cost of the establishment of necessary systems is not
known.

11.8 Response from Public and Industry
There is probably a low level of awareness, on the part of the public, regarding the
levy. As the landfill levy is not a direct charge, but rather is subsumed in waste
collection charges, the public in general would probably not be aware of its existence.
While the landfill levy is stated on invoices, for businesses that produce little waste,
the landfill levy is minimal. For an office, the average landfill levy on an invoice may
be an integer number of euros per month.
It seems that the landfill levy is very much obscured from view as it remains
(currently) a small part in the total costs of landfilling (refer to Table 11-3 above).
Furthermore, the link between charging households and the landfill levy is not a direct
one, even where collectors make use of weight-based charging. For example, Indecon
report that in Cork, weight-based charges were as high as €0.46 per kg of residual
waste. 216 In some other cases where weight-based charges are in place, the link
between charge rates and landfill gate fees appears somewhat more closely aligned,
though this should not be taken as evidence of a firm link between the two.
As detailed in the section above, the landfill levy revenues are directed into the
Environmental Fund, which is made available to support local authority run projects in
waste management. This arrangement has been highlighted by private sector
operators as unfair, since in the Irish market, the private sector competes with local
authorities. Therefore the Environmental Fund potentially becomes a source of
competitive advantage for local authorities.
11.9 Effects on Technical Change / Innovation
As far as municipal waste is concerned, the levy has probably had very limited impact
on technical change and innovation. Weighbridges at landfill sites were required in
order to manage the landfill levy but by 2002 most landfill sites had already installed
weighbridges as a requirement of waste licences granted by the EPA. The
Environmental Fund might have achieved more in this regard.
11.10 Social and Distributional Consequences
The landfill levy is paid by the contractor delivering waste to the landfill. Costs are
ultimately passed on directly to those producing the waste. In the case where pay by
weight collection systems are in place, costs can be transmitted more directly.
The low level of the levy almost certainly implies that whilst the levy might have the
potential to be regressive, social and distributional consequences are likely to be
minimal.
216 Indecon International in association with the Institute of Local Government Studies at University of
Birmingham (2006) Indecon Review of Local Government Financing, Report Commissioned by the
Minister for the Environment, Heritage and Local Government.
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11.11 Complementary Policies
In addition to the Landfill Levy, an environmental levy on plastic bags has been
introduced. The proceeds of both the Environmental Levy on the supply of plastic
bags (collected by the Revenue Commissioners) and the Environmental Levy on the
landfilling of waste (collected by the Local Authorities) are paid into an Environment
Fund which is used for a range of waste prevention schemes.
The levy ought to complement pay-by-use schemes, since the rationale for charging
for refuse collections is strengthened where disposal costs are higher. However, it
should be recognised that there is not necessarily a direct link between residual
waste disposal / treatment costs and the marginal rates charged by collectors for the
residual waste collection system. Evidently, the link is less likely to be a strong one
where the charges are not based upon weight.
11.12 Effect of the Policy on Pricing of Resources / Services
An earlier report by Eunomia assessed the externalities associated with Landfill,
Incineration and MBT. 217 The results from that report are shown in Table 11-7.
Elsewhere within these Annexes, we have also assessed the externalities from landfill
and other residual waste treatment options (see Annex 63.0).
Table 11-7: Externalities from Landfill, Incineration and MBT
Landfill Landfill Incineration Incineration MBT
MBT
Direct emissions non-GHG related €2.64 €23.51 0.49
Direct emissions GHG related €59.13 €28.71 15.62
Total Direct Emissions €61.78 €52.22 €16.11
Offsets GHG related -€1.60 -€6.79 -€4.72
Offsets non-GHG -€2.95 -€9.61 -€6.18
Total Offsets -€4.55 €4.55 -€16.40 €16.40 -€10.90 €10.90 €10.90
Net Environmental damages €57.23 €35.82 €5.22
Disamenity €4.25 €14.30 €9.28
Total External Costs €61.48 €50.12 €50.12 €14.49 €14.49
€14.49
The results indicate that the current level of the landfill levy is – subject to the
assumptions used - well below the current level of the levy. They also show that other
residual waste treatment options should be subject to non-zero, though lower, levies.
The first best option would be to internalise these externalities, and hence, limit
demand for landfill. Equally, the first best option would be to internalise externalities
of all management options, but first best options in respect of recycling are generally
not available, and the second best option would be an implied subsidy for recycling
activities, 218 which few Governments are prepared to sanction.
217 Eunomia with Tobin (2007) Waste Policy, Planning and Regulation in Ireland, Report for Greenstar.
218 See, for example, for an estimate of external costs and benefits of recycling, D. Hogg (2006) Impact
of Unit-based Waste Collection Charges, ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD; Sound
Resource Management (2009) Environmental Life Cycle Assessment of Waste Management
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When the landfill levy was first introduced, landfill gate fees were on an upward trend.
The landfill levy needs to be restructured to ensure that it targets the source of the
externalities, for example a higher rate should be introduced for landfilling of
untreated waste, while a lower level should be put in place for landfilling of waste
which has been stabilised. As it stands the existing landfill levy at €20 per tonne, is
approximately 11.8% of the total landfill gate fee. Landfill levies in EU Member States
are much higher at an average of €45 - €50 a tonne. The significance of the low level
of the levy in the context of declining ex-levy gate fees is that the confidence in
investing in alternatives is undermined as the ex-levy gate fee declines. Setting a
higher levy, and giving certainty about future levels will encourage investment in
alternatives in future.
11.13 Evasion and Enforcement
It is the function of each Local Authority to enforce and audit compliance with the levy
requirement within its functional area. The levy is payable by weight which is recorded
using weighbridges at the landfill facility. There is no evidence to suggest that the
landfill levy is being evaded.
Under Section 73 of the 1996 Act, a person who fails to pay levy which is due and
payable under the forthcoming Regulations, or who fails to comply with a provision of
those regulations, would be guilty of an offence. Penalties for an offence under the
1996 Act include fines of up to £10 million and/or imprisonment. In addition, in the
case of a privately operated landfill, a conviction for an offence under Section 73
could lead the EPA to conclude that the relevant licensee (or licence applicant) was
not a “fit and proper person” to hold a waste licence.
11.14 Lessons Learned
11.14.1 General Lessons
One of the key lessons which the foregoing discussion seems to suggest is that the
landfill levy has been too low to have a significant influence on behaviour, at least as
far as municipal waste is concerned. The degree to which the levy has contributed to
an increase in recycling must be questioned, given the role likely to have been played
by the increases in (ex-levy) landfill gate fees since the mid-1990s, and the various
policies in respect of producer responsibility. The effect of the levy in terms of waste
prevention is likely to have been similarly weak, though no formal analysis has been
conducted here.
The rate of increase in the levy has been limited to €5 per tonne per annum. In terms
of the costs of landfilling, inclusive of the levy, this would have done little more than
maintain the costs of landfilling in line with inflation. The reality, in recent years,
appears to have been that the costs of landfilling have been declining in real terms.
Strategies with a Zero Waste Objective, Study of the Solid Waste Management System in Metro
Vancouver, British Columbia, Repoprt for Belkorp Environmental Services Inc. June 2009
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On the plus side, the levy is a simple measure and is thought to be relatively easy to
enforce. Political backing for its implementation was important in pre-implementation
stages. Future changes expected are an increase in the levy and broadening of its
scope. Indeed, the EPA, in the National Waste Database Report, 2006, considered
that:
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“the use of economic and policy instruments such as increasing the landfill
levy and banning untreated waste from landfill should be immediately
considered as it will present the strongest possible economic signal to the
private waste industry to seek alternative outlets”.
Most commentators recognise the need for an increased levy. The EPA, as one of its
ten recommendations for change, suggests that: 219
A higher landfill levy would increase the incentive to divert wastes to
alternative treatments. Revenue from the increased levy could fund initiatives
that specifically target OFBMW diversion and treatment.
It goes on to say:
A landfill levy specifically targeting OFBMW would rebalance the economics
towards OFBMW treatment rather than disposal
Such a levy would be difficult to design in the general sense, but the sentiment
reflects the fact that the majority of the known externalities appear to be associated
with methane releases, these being driven by the biodegradable waste component of
landfilled materials.
219 EPA (2008) Hitting the Targets for Biodegradable Municipal Waste: Ten Options for Change,
Wexford: EPA.

12.0 Producer Responsibility, Packaging - Ireland
12.1 Outline of Policy
The introduction of Producer Responsibility in relation to packaging in Europe was
brought about through a number of Council Directives including; the Packaging Waste
Directive (Council Directive 94/62/EC), Council Directive 2004/12/EC and Council
Directive 2005/20/EC, both of which amend the 1994 Directive.
In Ireland, the requirements of the Packaging Waste Directive (Council Directive
94/62/EC) were first introduced through the “1997 Packaging Regulations” (S.I. No.
242 of 1997) and the “1998 Packaging Amendments Regulations” (S.I. No. 382 of
1998), both of which are now revoked in legislation.
Following on from these, the existing Irish legislation was updated and replaced
through the introduction of the Waste Management (Packaging) Regulations, 2003
(S.I. No. 61 of 2003). The 1997 regulations (and 2003 regulations which replaced
them) place primary obligations on all producers 220 of packaging waste to:
199
� To separate certain ‘specified categories’ (‘glass, aluminium, steel, paper and
fibreboard, plastics, wood and textiles, or such other categories as may be
specified by the Minister from time to time’) of waste packaging at source into
segregated waste streams to allow for the collection by or on the behalf of the
producer, or by a recovery operator 221 for the purposes of recycling and
recovery; and
� Ensure that producer packaging waste other than specific categories,
including back door waste, is collected by or on the behalf of the producer, or
by a recovery operator for the purposes of treatment, recovery or disposal.
The 2003 Regulations (and 1997 Regulations) effectively prohibit the landfilling, from
commercial sources, of such ‘specified categories’ of waste packaging.
The 2003 Statutory Instrument came into effect on 1 st March 2003, and was
introduced for the purposes of giving effect in Ireland to the Packaging Waste
Directive (Council Directive 94/62/EC) and to set the legislative target in Ireland for
220 “Producer” is specified, under and in accordance with section 27 of the Waste Management Act,
1996 (No. 10 of 1996) as amended by the Waste Management (Amendment) Act, 2001 (No. 36 of
2001) to mean a person who, for the purpose of trade or otherwise in the course of business, sells or
otherwise supplies to other persons packaging material, packaging or packaged products, and
“produce” shall be construed accordingly.
221 Recovery Operator” means (a) a local authority or other person engaged in waste recovery or waste
collection for the purposes of recovery, subject to that person having obtained all necessary licences or
permits required under the Act, or (b) a major producer when acting in accordance with the exemption
from the requirement to hold a permit when collecting packaging waste in accordance with article
22(e) of the Waste Management (Collection Permit) Regulations, 2001 (S.I. No. 402 of 2001), or with
any regulation replacing or amending that article.
International Review of Waste Policy: Annexes

the recovery of 50% of packaging waste by end 2005. This legislation was further
amended in the Waste Management (Packaging) Regulations, (S.I. No 871 of 2004).
Council Directive 2004/12/EC was introduced at European level, to amend the
original Directive 94/62/EC on packaging and packaging waste. In 2006, Irish
legislation was aligned with this through the introduction of the Waste Management
(Packaging) (Amendment) Regulations (S.I. No 308 of 2006). The 2006 Statutory
Instrument introduced material-specific recycling targets, to be achieved in Ireland by
end 2011 and the updated EU packaging waste recovery targets of 60% of packaging
(with 55% by way of recycling).
The most recent legislation to come into play in Ireland with respect to the Producer
Responsibility elements of the Packaging Waste Directives is the Waste Management
(Packaging) Regulations (S.I. No. 798 of 2007). All producers, including retailers,
participating in the placing of packaging on the Irish market, must segregate the
packaging waste arising on their own premises into specified waste streams (i.e.
waste aluminium, fibreboard, glass, paper, plastic sheeting, steel and wood) and have
it collected by authorised recovery operators for recycling. The regulations consolidate
the existing regulations of 2003 as well as the amending regulations of 2004 and
2006 respectively to bring improved clarity, transparency and accessibility to the
packaging waste regulatory regime. The principal articles of the regulations came into
effect on the 31 st March 2008.
As part of the measures in the 2007 Statutory Instrument, there has been a change
in the ‘Major Producer’ category, and a reduction in the de minimis threshold (one of
the thresholds to determine ‘Major Producer’ status) from 25 tonnes to 10 tonnes,
following on from the higher packaging recycling and recovery targets that have to be
achieved under Directive 2004/12/EC. As a result this will result in bringing more
businesses into the ‘obligated producer’ category.
It is worth noting that Ireland received a derogation within the implementation
deadlines, in relation to recycling and recovery targets set down at European level in
the original Directive, only having to achieve at least 25 per cent recovery by 2001
and 50 per cent recovery by 2005. This was in order to allow for the development of
required (recycling and recovery) waste management infrastructure.
12.2 Policy Context and Reason for Introduction
Packaging waste policy in Ireland is contained, in the most part, within the packaging
regulations described in the Outline of Policy Section above, which have been brought
into force through the introduction of legally binding Statutory Instruments. Within the
area of packaging waste policy, Ireland has followed the requirements set down in a
number of European Council Directives. The policy elements in Ireland did not
develop independently, and until recently, policy had been introduced entirely in a
reactive manner to the binding requirements of European legislation.
The individual European Council Directives and Irish Statutory Instruments are listed
in the section above. It may be noted that the main driving elements behind the
majority of the measures in the Packaging Waste Directives were focused on the
recycling and recovery of packaging materials and all of the binding targets to date
that have been set a European level have focused on recycling and recovery targets.
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Although the European legislation does mention minimisation of packaging material
use and volumes, this was not translated into specific targets in relation to the
prevention of packaging at source with implementation deadlines as had been done
for recycling and recovery.
12.3 When was the Policy Introduced?
The original Statutory Instruments were introduced in Ireland in 1997 and 1998, as a
means of transposition of the 1994 European Directive, and therefore the
background of the policy framework has been in place for 10 years. The 1997 and
1998 regulations were replaced in law in Ireland by the 2003 regulations and then
further amended in 2004. Most recently, the waste packaging policy was
consolidated in the 2007 Regulations, which came into effect on 31st March 2008.
12.4 Key Organisations Involved in Implementation and
Management
12.4.1 Policy and Transposition of Regulations in Ireland
Overall waste management is developed by the Department of the Environment
Heritage and Local Government (DoEHLG). Within the area of packaging waste, the
DoEHLG are also the government body, which approves the application of Compliance
Schemes/Compliance Bodies, of which to date only one has been approved in
Ireland, namely Repak.
12.4.2 Implementation and Administration of the Regulations
The DoEHLG are involved in the implementation of the packaging regulations, both
through being the responsible body for the transposition of the European legislation
into Irish law, and in terms of the interaction they engage in with the Repak
Compliance Scheme. Within this framework, the DoEHLG are also the body to which
feedback and consultation is returned for the on-going operation and performance of
the regulations. As part of this function, the department undertook consultation prior
to the drafting of the replacement 2003 Packaging Regulations. Most recently, the
DoEHLG undertook Regulatory Impact Analysis in relation to the introduction of the
2007 Waste Management Packaging Regulations (S.I. No. 798 of 2007).
Repak, as the operator of the only approved compliance scheme, is responsible for
the administration and demonstration of compliance for participating companies,
through funding from packaging levies, via its participating companies of the scheme,
through management of the reporting at a national level from their members to the
EPA and through the dissemination to members of information on compliance and
innovation.
At a local level, the individual Local Authorities are involved in implementation
through the provision of information on packaging regulations to producers and
recovery operators within their administrative area, and through the receipt of
reporting from producers and recovery operators, where those companies are not
demonstrating compliance through membership of the Repak scheme (Self
Compliers).
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As a result of the various organisations involved at an administrative level (Self
Compliers, Repak and Local Authorities), the Environmental Protection Agency (EPA)
takes a coordinating role in the reporting of waste packaging data. The data are
collected from all of these organisations, along with further data from the public
(Local Authority) and private operators of waste recycling, recovery and disposal
facilities. The EPA reports on packaging consumption, recycling and recovery rates to
the DoEHLG and to the public.
The EPA has a supervisory role over Local Authorities under the EPA Act, which is
provided through the EPA’s Office of Environmental Enforcement and through the
EPA/Local Authority ‘Packaging Enforcement Network’, an enforcement group chaired
by the Office of Environmental Enforcement of the EPA and including enforcement
officers from Local Authorities.
The EPA also has an advisory role in the development of research, the generation of
national reviews and the production of guidance in best practice and expertise within
the area of waste management and waste prevention. The EPA provides this guidance
through its “Core Prevention Team”.
Regulatory Regulatory Enforcement
Enforcement
Local Authorities are responsible for the enforcement of the regulations within their
individual functional areas. The powers of the Local Authorities include the power to:
202
� Enter and inspect a premises;
� Serve a notice on an individual or company and require the production/ or
proof of compliance through information and documentary evidence; and
� Take summary proceedings for an offence, and in the case of prosecution,
recover the cost of the proceedings from the offender.
Local Authorities are responsible for the permitting of recycling and recovery facilities
located within their administrative area along with the permitting of the collection and
transportation of recycled and recovered waste.
The EPA is responsible for licensing the major recovery operators. The EPA has
supervisory control over all local authorities under Section 63 of the Environmental
Protection Agency Act, 1992 and has been assigned a role in producer responsibility
on a range of waste streams, including packaging.
As mentioned in the introduction, the main driver within the packaging regulation
framework to date has been in the generation of recycling and recovery targets.
While these mandatory targets continue to be of importance, attention is now
beginning to focus on Packaging Prevention as the means by which to effect a change
in future packaging trends.
The EPA’s Core Prevention Team has initiated a project to search for all newly
obligated producers in order to directly alert them to their obligations under the
packaging waste regulations and to assist local authorities in their enforcement
efforts.
Responsibilities for the packaging system are summarised in Table 12-1.
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Table 12-1: Distribution of Responsibilities in the Packaging System
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International Review of Waste Policy: Annexes
Activity Activity
Responsible Responsible body
body
Transposition of directive into national legislation DoEHLG
Monitoring of meeting targets (national + directive) DoEHLG
Monitoring and control of compliance DoEHLG+ EPA
Supplier of packaging data EPA (recyclers, local authorities, Repak)
Collection Collection of of packaging packaging waste
waste
Collection of packaging waste from households Local authorities/private operators/Repak
Collection of packaging waste from industry/commerce Waste producers/private operators/Repak
(Compliance administration with)
Recycling and treatment of packaging waste
Expenditures of packaging system covered by Repak + self-compliers
Repak + self-compliers
(not involved specifically in collection & treatment)
Source: EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An
EEA Pilot Study, EEA Report No 3/2005.
It may be noted that the systematic administration for the compliance with recycling &
treatment of packaging waste is the responsibility of the individual self compliers, or
of the compliance scheme where a Producer is a member of Repak. However, neither
the individual Producer, nor the compliance scheme, undertake the direct collection
or treatment of the packaging waste (though in principle, a Producer could do so).
12.5 Monitoring and Measurement Techniques Applied
12.5.1 General Requirements of the Packaging Regulations – Producer
Responsibility Obligations
As mentioned in the section on Policy Context, as a result of the 2003 Regulations
(and the revoked 1997 Regulations), all producers, including retailers, participating in
the placing of packaging on the Irish market, must:
� Segregate the packaging waste arising on their own premises into specified
waste streams (i.e. waste aluminium, fibreboard, glass, paper, plastic
sheeting, steel and wood); and
� Have it collected by authorised contractors for treatment and recycling or
recovery.
A producer must identify their status under the Irish regulations, in terms of being
either a ‘Producer’ or a ‘Major Producer’, as Major Producers have additional
responsibilities under the regulations. As a result of the changes in Ireland brought
into place by the 2007 Regulations, the ‘Major Producer’ category has been revised,
so that:
A ‘Major Producer’ is a producer with an annual turnover in excess of
€1,000,000 and and where the aggregate weight of packaging supplied exceeds
10 tonnes in a calendar year.

Therefore, where turnover is less than €1,000,000 per annum, or where the weight of
packaging supplied is less than 10 tonnes, this person automatically is not a ‘major
producer’, so it is defined a ‘producer’ if it supplies etc. packaging. Such ‘Producer ‘Producers’ ‘Producer
have a number of obligations, including the need to:
204
� Declare its status as a ‘producer’ to the relevant Local Authority;
� Separate all packaging waste from other waste, without contamination;
� Arrange for the collection of the packaging waste by a permitted collector (or or
for the supplier to ‘take back’ the packaging);
� Ensure the waste collector is permitted for collection and and and for the final
consignment destination;
� Provide weights of the packaging materials supplied to trade customers, if
requested; and
� Facilitate the Local Authority in confirming its compliance, and with conducting
any inspections.
Producers are not themselves confronted with targets for recycling and recovery.
Rather, their obligations relate more to their own waste management arrangements
and their reporting. As such, whilst, in principle, a Producer could join the Repak
compliance scheme, it is not immediately obvious what would be gained from doing
so.
‘Major Producers’ can either ‘Self Comply’ or join the Compliance Scheme, Repak.
They have additional obligations to those of producers, set out under Articles 10-16
and 25 of the Regulations, though these can be discharged by an approved body, of
which Repak is the only one in Ireland. Crucially, major producers are those who are
required to demonstrate that (Article 11(2)):
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(2) On and from the 31st day of December 2008, a major producer who is an
importer of packaged products or is a packer/filler shall take such steps as
are necessary to ensure that in any quarterly period, the aggregate weight of
packaging waste which is accepted or, as appropriate, collected by that major
producer for the purposes of recovery—
(a) is not less than 60% of the aggregate weight of packaging material and
packaging imported or packed/filled and supplied by that major producer in
the preceding quarterly period, and
(b) that a minimum 55% of the aggregate weight of packaging material and
packaging imported or packed/filled and supplied by that major producer in
the preceding quarterly period is recovered by way of recycling, and, where
appropriate,
(c) that a minimum—
(i) 60% by weight for glass, and as appropriate,
(ii) 60% by weight for paper and board, and as appropriate,
(iii) 50% by weight for metals, and as appropriate,
(iv) 22.5% by weight for plastics, and as appropriate,

205
(v) 15% by weight for wood,
supplied by that major producer in the preceding quarterly period is recovered
by way of recycling.
As stated above, ‘Major Producers’ may choose to discharge these obligations
through Repak. However, where companies do not participate in the Repak scheme,
they must demonstrate compliance directly to the Local Authority in their
administrative area. Self-complying ‘Producers’ must fulfil their obligations in the
following way:
� Register with the relevant Local Authority as a Self Complier;
� Pay an annual levy for the amount of packaging supplied;
� Submit a proposal for packaging management at your premises;
� Submit a quarterly report within 10 days of the end of each quarter, with
information specified in the second schedule of the regulations;
� Renew registration annually with annual results and an amended plan for year
ahead;
� Compile a new packaging management plan every three years;
� Comply with their recycling obligations as listed above;
� Accept packaging back from the public, including packaging purchased
elsewhere, provided that packaging is dealt with at the premises;
� Collect packaging back from trade customers within 1 week of request;
� Hold documentary evidence for up to 3 years to prove accuracy of the
reporting submitted;
� Display required signage at the entrance to each premises; and
� If an Importer/ packer/ 1st User – a minimum of 50% of the volume of
packaging introduced into the market in the previous quarter must be taken
back.
As mentioned below, the percentage tonnage of packaging waste not covered by the
Repak scheme, and therefore coming under the category of Self Compliers, is
estimated by Repak to be 43% of the tonnage of packaging material entering the
waste stream for recycling and recovery. 222
As a result of the 2007 regulations, the Local Authority registration fees for Self
Compliers have been adjusted to reflect inflation. The fees can now be levied in the
range from €500 up to a maximum of €15,000.
222 International Review of Waste Management Policy - Presentation to TOBIN Consulting Engineers.
International Review of Waste Policy: Annexes

12.5.2 The Packaging Regulations “Essential Requirements”
Article 9 of the Packaging Waste Directive requires all packaging placed on the
market in the EU to comply with ‘essential requirements’ set out in Annex II of the
Directive. The Essential Requirements were transposed in Ireland on the 1 st
December 1998 as part of an Amendment to the 1997 Packaging Regulations.
The Essential Requirements outlined in these regulations can be summarised as
follows:
206
� Packaging weight and volume must be reduced to the minimum necessary for
safety, hygiene and consumer acceptance of the packaged product;
� Hazardous substances and materials must be minimised as constituents of
packaging (Article 11 lays down specific limits on named heavy metals);
� Packaging must be suitable for at least one of the following – material
recycling, energy recovery or organic recovery; and
� If reuse is claimed, packaging must be suitable for that purpose as well as for
material recycling, energy recovery or organic recovery.
The European Committee for Standardisation (CEN), which is a standardisation
organisation, has created a number of standards in the area of packaging. These are
effectively referred to under Part VI of the Irish Regulations, which states:
29/09/09
28. (1) Subject to sub-article (2), a producer shall not supply packaging or
packaged products to other persons within the State unless the packaging
concerned complies with the requirements of the Fourth Schedule.
(2) Packaging shall be deemed to comply with the requirements of the Fourth
Schedule if it complies with a European standard duly adopted, or a standard
prescribed under section 29(4) of the Act, in relation to the requirements of
the Fourth Schedule.
It was intended that the methodology within the standards would contain
specifications that might allow validation of compliance with packaging regulations on
a European wide basis. As the approach taken in creating the standards did not
facilitate this, individual countries effectively need to develop strategies for
compliance.
Repak notes:
“Companies in Ireland should demonstrate compliance by providing the Local
Authorities with sufficient technical documentation for a period of up to four
years from the date the packaging was placed on the market.
Irish companies which import packaging or packaged goods from other EU
member states should contact their suppliers to obtain the necessary
information. Companies manufacturing packaging in Ireland or sourcing
packaging from outside the EU should compile a dossier containing the
necessary information. Repak suggests that companies use the CEN
standards to compile the necessary information.

207
Companies that supply packaging or packaged goods to customers in other
member states, particularly in the UK or France, may receive requests for
information from these customers.”
Where packaged goods are found not to be in compliance, the goods could be
removed from the market and the Local Authority can make a prosecution.
Repak highlights that although EU countries including Ireland have transposed the
Directive, of these countries, only France and the UK have specified a procedure
which companies must follow to demonstrate compliance. 223
12.5.3 Producer Responsibility - Participation via Repak Compliance
Scheme
Repak is the only approved Compliance Scheme in relation to packaging in Ireland.
Members, through membership, effectively pass on responsibility to Repak for the
recycling and recovery of the packaging waste they are required to meet, with
participating companies paying a fee for membership, based on their membership
type. Repak estimates that in 2006, 57% of the waste packaging tonnage came
within the remit of the compliance Scheme, with 43% being outside as Self Compliers.
Repak’s members are of two types: 224
� Regular members (854 members) are those companies that are importers or
brand holders, and have primary packaging responsibility. They are required to
submit statistics biannually and pay an average fee of € 12,500; and
� Scheduled members (1,327 members) are smaller operators, who are not
involved in the branding or importation of products. They are not required to
submit statistics to calculate the fee element required annually, and instead
pay an annual flat fee, based on their turnover. These include small retailers,
off licences, hotels, pubs, clubs and restaurants.
The membership is split, so that 39% of the membership is made up of Regular
members (involved in direct importation or branding), and this set within the
membership makes up 95% of the income generated from membership fees. For the
regular members, the fee is split within the 5 categories of producer/manufacturer,
converter, brand holder/importer, distributor/wholesaler and retailer.
223 The approach taken in the UK is not especially ‘hard line’. For a discussion, see Eunomia, The
Environment Council, Oko Institut, TNO and Atlantic Consulting (2007) Household Waste Prevention:
Policy Side Research Programme, Final Report for Defra, April 2007. It can also be argued that the
different ways in which the requirements of the Packaging Directive are implemented do, themselves,
have an impact on the extent to which producers are likely to minimise packaging. Other things being
equal, the greater the proportion of the cost of compliance borne by the producers (as opposed to local
authorities and the generality of households), the stronger will be the incentive to minimise packaging.
In this respect, the UK approach has to be considered alongside the very low proportion of compliance
costs borne by producers, which offers somewhat limited (though non-zero) incentives for compliance
(see also Annex 13.0).
224 International Review of Waste Management Policy - Presentation to TOBIN Consulting Engineers.
International Review of Waste Policy: Annexes

There is a flat fee per tonne in four of these categories, while the brand holder/
importer is charged a Material Specific fee, as shown in Table 12-2.
Repak is concerned that the way in which the scheme is enforced is inadequate for
the purposes of highlighting those who are not compliant with the scheme. This, they
argue, places an additional burden on the scheme itself to ensure that the obligation
for Ireland as a whole can be met. Effectively, the existence of non-compliers
suppresses the number of possible Repak members, and increases the cost to those
members (above those which would otherwise prevail) required to support the
scheme, and in particular, to provide the required revenue for RPS payments.
Table 12-2: Fee Structure for Repak ‘Regular Members’
Activity Activity
Cost Cost (cent/kilo cent/kilo cent/kilo) cent/kilo
Fee Fee Fee type
type
Producer/Manufacturer 0.205 Participation fee
Converter 0.205 Participation fee
Brand holder/ importer Specific to material Material specific fee
Distributor/ Wholesaler 0.205 Participation fee
Retailer 0.410 Participation fee
In this context, it can be noted that Repak estimates that the number of noncompliers
was about 1,050 in 2001, declining to an estimated 700 in 2004. 225 It has
been suggested that some of this reduction can be attributed to stepped-up
enforcement activity by the authorities.
12.5.4 Availability of Packaging Data
As mentioned in Section 12.2 of this chapter, the manner of the transposition and
administration of the policy in Ireland means that the regulations do not provide
quantitative objectives or obvious indicators by which to enforce minimisation. The
current regulations have, to date, primarily acted as a recycling policy. The data from
the EPA and the packaging compliance scheme, Repak, can, however, still provide
figures of total packaging waste tonnages, in terms of assessing waste packaging
arisings.
Monitoring of the compliance of producers with the packaging regulations is carried
out through assessment of their reporting on packaging volumes submitted either
individually as Self Compliers, or through reporting by the Compliance Scheme Repak.
As identified above, and further below, Local Authorities also have the powers to
make inspections of individual premises and to request the production of
documentary records to prove compliance.
225 Repak (2008) Submission & Presentations on International Review of Waste Management Policy -
Presentation to TOBIN Consulting Engineers
208
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Data from both Repak and self-compliers reporting to their Local Authority are both
returned to the EPA as the overall agency collating the data.
An EEA Report flags the methodology which has been used to generate packaging
statistics: 226
209
“The packaging statistics are based partly on compositional analysis of
landfilled household and commercial waste and questionnaire surveys among
recycling (and recovery) companies. In keeping with the need for continuous
improvement, and to address concerns about the reliability of the
methodology, the EPA is testing a new methodology. 70–80 % of the
packaged goods consumed in Ireland are imported, mostly from the UK,
showing that Ireland's estimated per capita packaging consumption, 40 %
above that of the UK, may well be an overestimate. A consultancy study led by
Perchards consultancy, London suggests that the previous methodology used
in Ireland has resulted in some over-estimate of arisings. A research project is
in progress with the aim of developing a methodology for determining
quantities of packaging placed on the market”.
It has also been flagged in the 2006 EPA National Waste Report that: 227
“It has been noted […] that there are concerns with regard to the classification
by the waste industry of municipal waste being disposed at landfill. […] The
EPA is committed to researching this issue in 2008 and ensuring that the
landfill of waste is accurately and consistently reported.”
This concern of the EPA’s has to be taken in context of the reporting being dependent
on composition data to monitor the tonnages of packaging waste generated, with
different compositions used for different waste streams.
In the National Waste Report 2007 published at the end of 2008, the section on
packaging waste makes the comment: 228
“The new (municipal waste) composition studies also provide comprehensive
information on the contamination of the different packaging waste streams.
Up to 20%, or more in some cases, of the weight of packaging waste is food
and food residues and these residues are discounted from the packaging
figures on both the landfill and recovery side of the equation.”
Whilst this might be scientifically accurate, it would also be incumbent on all parties
to understand the level of contamination of packaging sent for recycling in order to
ensure that the reported recycling rates are consistent with the deductions made for
contamination. The issue of materials quality is one which, generally, is important for
Ireland to address, especially in the context of its dependence on export markets for
reprocessing of collected materials.
226 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No3/2005
227 EPA (2007) National Waste Report Report 2006, Wexford: EPA.
228 EPA (2009) National Waste Report Report 2007, Wexford: EPA.
International Review of Waste Policy: Annexes

12.6 Evaluation Studies Available
210
� EPA/Clean Technology Centre (2002), ‘A Strategy for Developing Recycling
Markets in Ireland’, Synthesis Report
� EPA (2008) National Waste Prevention Programme Fourth Annual Report
2007/2008
� Perchards, FFact Management Consultants and SAGIS Ltd (2004). Study on
the progress of the implementation and impact of Directive 94/62/EC on the
functioning of the internal market: Interim report. Volume 1: main report. Web:
http://www.europa.eu.int/comm/enterprise/environment/interim_report.pdf
� EEA (2005) ‘Effectiveness of Packaging Waste Management Systems in
Selected Countries: An EEA Pilot Study’, EEA Report No 3/2005
� DoEHLG (2007) ‘Market Development Programme for Waste Resources 2007
– 2011’
� Perchards (February 2008), ‘Report on Packaging Supply Chain (Packaging
Prevention)’ – commissioned by Repak Ltd in association with the packaging
Waste Prevention Steering Group as part of the Packaging Prevention
Programme 2007
� Action Group on Recyclates (2008), ‘Action Group on Recyclates First Report’
� DoEHLG (2006) ‘Statement on Regulatory Impacts’, Responses from 2006
Consultation’
12.7 Environmental Benefits
12.7.1 Benefits in Terms of Prevention
We are not aware of any study which looks at the extent to which the Regulations
have:
� Encouraged prevention / re-use; and / or
� Encouraged switching from one packaging material to another.
Over the period from 2001-2007, packaging waste quantities have grown at an
average compound rate of 3.2%. The effect by material is quite different, with some
materials showing much higher growth than others (see Table 12-3). This reflects the
linked effects of changing consumption patterns and the effect of economic growth.
29/09/09

Table 12-3: Average Compound Rate of Growth of Packaging by Material, 2001-2007
Packaging Packaging Material Material Average Average Annual Annual Growt Growth Growt
Rate Rate, Rate , 2001 2001-2007 2001
2007
Paper and Card 1%
Ferrous 2%
Glass 9%
Aluminium -1%
Plastic 2%
Other Metals -32%
Textiles -4%
Wood 14%
Others -3%
Source: EPA National Waste Reports, 2001 and 2007
The materials showing positive growth rates are those which arise in largest
quantities, and in absolute terms, the greatest growth has been seen in glass, wood
and plastic (in that order). There is a suggestion that glass packaging – typically used
for premium beverages – might have increased, possibly at the expense of growth in
other packaging materials, as disposable incomes have increased.
Repak provides data for a short period of time on EPA figures for packaging waste
tonnages, and those for Repak members (see Figure 12-1).
Figure 12-1: Trend in Tonnes of Packaging for Repak Members, Total Packaging
Reported by EPA, and Retail Sales Volume Index
It is not clear that the data enable one to conclude much other than that the quantity
of packaging waste, as reported by the EPA, has fluctuated considerably over time. In
the first year, there is a reported decline in EPA figures (-15%), but an increase in the
tonnages reported by Repak Members (approx +7%). In the following year, growth
rates are the same, but in 2006, growth appears lower in the Repak tonnages than in
211
International Review of Waste Policy: Annexes

the EPA figures. Growth declines in the next year also for the Repak members. 229
Latest EPA data suggests that the 2007 growth figure would be marginally less than
the figure shown for Repak members. The period covered by this data is too short for
one to draw any conclusive observations from it.
The EEA identifies three packaging waste prevention measures which have been
created within the policy framework to minimise packaging waste generation (see
Table 12-4). 230 The producer responsibility requirements in relation to packaging
separation and collection and the funding of packaging awareness raising campaigns
are administrative measures identified in the report, along with the economic
incentive provided by the plastic bag levy. The plastic bag levy is described in more
detail in Annex 27.0. In relation to packaging waste prevention, the EEA report notes
that:
212
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“The plastic bag levy aims to reduce the amount of plastic bags used and thus
has a clear preventative objective.”
Table 12-4: Intended Impacts of Policy Measures in Ireland
Measure
Producer
responsibility
/Repak
Awareness
raising
campaigns
Year of
introduction
1997
Plastic bag levy 2001
Landfill levy 2002
Ban on landfilling of
particular wastes
Obligation on
producers to
segregate
packaging waste
and have it recycled
National Waste
Prevention
Programme
1999–2002,
2003
2003
(some LA’s
started earlier)
2003
2004
Purpose/targets
To help member companies
meet their packaging waste
management obligations.
To raise awareness.
To reduce the number of plastic
bags used annually.
To achieve national targets for
the diversion of waste away
from landfill towards recycling
options.
To divert waste away from
landfill as there is a shortage of
landfill capacity.
To ensure that packaging waste
materials are not mixed and that
all packaging waste generated
by producers (as defined in the
legislation) is recycled.
To promote waste prevention
and minimisation through a
broad range of instruments.
Relation to the objectives of
the directive
To meet the recycling and
recovery targets of the
packaging directive.
To promote a greater
appreciation of the impact
of personal behavior and
highlight steps to reduce the
impact on the environment.
Prevention of plastics
waste.
To reduce final disposal of
waste and support the
recovery/recycling targets.
To reduce final disposal of
waste and support the
recovery/recycling targets.
To support
recovery/recycling targets.
Prevention of waste.
Source: EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An
EEA Pilot Study, EEA Report No 3/2005.
229 International Review of Waste Management Policy - Presentation to TOBIN Consulting Engineers.
230 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 3/2005

The EEA report identifies the role of the compliance scheme in packaging waste
prevention:
213
“The weight-based Repak fee is an incentive for prevention, since it makes
companies responsible for the amount of packaging placed on the market”.
A stimulus for packaging minimisation and prevention also comes from internal cost
reduction assessments undertaken by companies proactively. Repak provides
guidance to its members with regard to packaging reduction and prevention.
The incentives for companies to reduce and minimise packaging come both from the
regulatory side in terms of the fees associated with packaging regulations compliance
and from the basis of profit saving and cost effectiveness of their operations.
The National Waste Prevention programme is described in more detail in Annex 18.0.
Under the auspices of the overall EPA waste prevention programme, the EPA and
Repak launched The Packaging Waste Prevention Programme (PWPP) in 2007. The
Packaging Waste Prevention Programme was announced as having an initial
programme budget of €200,000, to be co - funded by the EPA and Repak, with the
objective of the programme being to help Irish industry reduce the amount of
packaging on their products.
The proposed measures within the EPA/ Repak Packaging Waste Prevention
Programme were detailed in the press release announcing the launch of the
programme: 231
� A series of awareness raising seminars;
� A what is best practice packaging website;
� A supply chain benchmarking study;
� Exemplar best practice case studies;
� Consumer research study on packaging preferences and purchase behaviour;
� Packaging Design Awards aimed at promoting examples of best practice;
� Development of a carbon footprint calculator for member companies; and
� Development of a interactive householder carbon footprint calculator.
We understand that the Programme is currently suspended due to lack of funding.
The absence of packaging prevention objectives being identified in national policy
creates difficulties at the level of Local Authority regulation in that enforcement
officers do not have a straightforward set of criteria for enforcement activities against
which they could take action – whilst it is not part of the packaging regulations policy,
it is nevertheless important to highlight the existence of the EPA/Repak Packaging
Waste Prevention Programme, as it is the only visible initiative within the
administrative framework that specifically focuses on packaging prevention. Although
231 Slattery Communications / Eoin Kennedy (14 March 2007) Repak and EPA Launch the First
Packaging Waste Prevention Programme.
International Review of Waste Policy: Annexes

this is laudable, its suspension due to lack of funding does raise the issue of how
seriously the Essential Requirements aspect of the Directive have been taken in Irish
policy. To the extent that producers are required to comply with the Essential
Requirements, arguably, there should be no need for external funding sources to
support this. It is the task of producers.
In some European countries, e.g., Belgium, Slovakia and Spain packaging waste
prevention and minimisation is set out in statutory targets. In the case of Spanish law,
the target has been set by measuring the total quantity of packaging waste arising in
a particular year against the total weight of packaged products consumed within the
same year, against baseline year data of 1997 and 2001. 232 The report references
an evaluation of packaging minimisation in Belgium, and notes that the quality of the
packaging plans has improved as both the authors and authorities have gained
experience over time.
As stated above, we are not aware of any study which looks at the extent to which the
Regulations have encouraged (or discouraged) prevention / re-use, and encouraged
switching from one packaging material to another. The Repak figures give no reason
to be confident of a discernible influence on the rate of growth in packaging over
time, but properly, this would need to be considered against a possible counterfactual
(no policy) in order for one to be clear about the extent to which the Regulations
themselves may have been responsible for changes. It seems reasonable to believe
that a logical response of companies – whether self-compliers, or complying through
Repak – would be to reduce the financial and other burdens implied by the
Regulations by reducing, at the margin, the weight of packaging used. One exception
might be self-compliers, to the extent that these might be companies who take in
significant quantities of readily recyclable packaging and who find that this makes
compliance relatively straightforward.
To a degree, therefore, any analysis which purported to distinguish the performance
of Repak companies, or ‘self-compliers’, from another group in respect of waste
prevention performance might not be reflecting a causal connection between the
route for compliance and the prevention performance. Rather, the direction of
causality might be the other way round (people who are more able to meet
requirements with minimal changes in behaviour might be more inclined to opt for
self-compliance).
In a 2005 study, it was stated that: 233
214
29/09/09
Repak — and Enterprise Ireland find that the intentions of the directive are
not fully transposed, as prevention and reduction of packaging amounts are
not included in the regulation.
232 Perchards (2008) Report on Packaging Supply Chain (Packaging Prevention), Report
Commissioned by Repak in conjunction with the Packaging Prevention Steering Group.
233 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 3/2005.

The same study went on to highlight some difference of opinion between DoEHLG and
Repak:
215
Repak gives the system's waste prevention a low rating, as does Enterprise
Ireland, which points out that the weight-based payments give little motivation
to reduce the volume of packaging produced, and that opportunities to benefit
financially from packaging prevention and reduction strategies are not clear to
companies. The Department of the Environment argues that the scale of
membership fees has been designed to relate directly to the amount and type
of packaging placed on the market. If less is placed on the market,
membership fees will decrease correspondingly: an implicit waste prevention
measure.
This is of some interest as it supports the notion – as would appear to be the case,
anecdotally, in other countries - that if the incentive for waste prevention is to hit
home, the full financial responsibility for the obligation should rest with industry.
Currently, this appears not to be the case with the existing compliance scheme, with
collectors still facing a ‘non-zero’ net cost for collection of waste for recycling. The
logical solution might be one where the full costs of an efficient recycling collection
were borne by obligated producers. 234
12.7.2 Benefits in Terms of Recycling
The intended impact of the Irish Packaging Regulations on recycling to date has
specifically been to increase the rate of packaging recycling in line/ in reaction to the
binding European targets. The national packaging recycling targets are based on the
tonnages recycled as a percentage of overall tonnages of waste packaging generated
that year. In the time period since the introduction of objective of meeting the
recycling targets have been met.
Estimates of packaging consumption are based either on packaging data from Repak
or on packaging data from local authorities collating data from self compliers i.e. the
estimate of the tonnages of packaging waste consumption is based on the tonnages
of packaging entering the waste stream for recovery.
According to data provided by Repak, the packaging waste target of 25% of packaging
recycled in the year 2001 was met and exceeded (with 27% packaging recycled),
while the target of 50% of packaging recycled in the year 2005 was met and
exceeded (with 59% packaging waste recycled).
In the National Waste Report 2007 published, the section on packaging waste makes
the comment: 235
234 It should be noted that this is one reason why the comparison of costs of compliance with the EU
Directive targets in a study by the EEA should be questioned. The emphasis there was on costs born by
compliance schemes. However, different Member States effectively require compliance schemes to
cover a varying scope of the total costs of compliance. In some schemes, obligated companies pay for
all packaging recovery, in others, they pay only to stimulate, at the margin, the additional packaging
collection and reprocessing needed to meet a given target.
235 EPA (2008) National Waste Report Report 2007, Section 5, Wexford: EPA.
International Review of Waste Policy: Annexes

216
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“ … As a consequence of reduced landfill, accompanied by a large increase in
recycling, the packaging recovery rate increased from 57.3% in 2006 to
63.6% in 2007.”
The data for packaging waste from the annual EPA National Waste Database Reports
are presented in Table 12-5 and in Figure 12-2. The following are observed:
� An increase in the total tonnages of packaging waste generated from 2001 to
2007 (an average compound rate of growth of + 3.2 % for the period, or a 21%
increase overall);
� A fall in the total tonnages of packaging waste landfilled from 2001 to 2007
(an average annual fall of 5.9%. or 30% for the whole period); and
� An increase in the total tonnages of packaging waste recovered from 2001 to
2007. The annual compound rate of increase has been 20.3%, a net change
of over 300% for the period).
Table 12-5: Packaging Waste Generation, Disposal and Recovery, 2004 - 2007
Year Year Year
2001 2001 200 2002 200 200 200 2003 200 2004 2004 2005 2005 2006 2006 2007
2007
Gross
quantity
(tonnes)
Quantity
landfilled
(tonnes)
Quantity
recovered
(tonnes)
872,917 899,125 1,006,287 850,911 925,221 1,028,472 1,055,952
551,651 602,736 586,687 371,371 370,589 438,952 384,322
221,266 296,389 419,600 479,540 554,632 589,519 671,630
Source: EPA National Waste Reports 2004, 2005, 2006 & 2007
The changes in the management of waste are generally positive, though as
mentioned above, any effect on waste growth is not so easy to discern, not least since
the different materials have witnessed differing rates of growth (see above).
The degree to which these changes in management can be attributed to the existing
policy on packaging is unclear. Some interventions are likely to have had a significant
impact. For example, following the introduction of the requirement for producers to
sort packaging waste, the EPA reported: 236
The recovery of packaging waste increased by 14.3% in 2004, due to the
increased availability of mixed dry recyclables collections from households
and increased obligations on commercial premises to segregate and recycle
packaging waste. The largest fraction by weight recycled is paper and
cardboard, followed by wood and glass. Since March 2003, producers of
packaging are obliged to segregate for recovery specified packaging waste
236 EPA (2005) National Waste Report 2004, Wexford: EPA.

217
materials at source, effectively banning the landfill of these materials. This is
reflected most dramatically in an increase in the recovery rate of paper and
cardboard, from 41% in 2003 to 70% in 2004.
As noted in Annex 11.0, there have been significant increases in landfill gate fees
over the period since the late 1990s. These will have driven increases in dry recycling
as collectors seek to avoid the rising costs of disposal. The Repak RPS payments are
not, however, as significant in the commercial sector as they are in the household
sector. At present, the majority of packaging recycling is associated with nonhousehold
waste, and here, the effect of rising landfill costs and improving prices for
secondary materials are likely to have been more significant than the RPS payments.
It seems reasonable, however, to believe that the Regulations have had a positive
effect, albeit possibly only a marginal one, through the financial inducements to
companies collecting packaging waste which Repak provides.
Figure 12-2: Packaging Waste Generation, Disposal and Recovery, 2004 - 2007
Quantity (tonnes)
1,200,000
1,000,000
800,000
600,000
400,000
200,000
0
2001 2002 2003 2004 2005 2006 2007
International Review of Waste Policy: Annexes
Gross quantity Quantity landfilled Quantity recovered (tonnes)
A National Strategy Group on Packaging Waste Recycling was set up in October 2004
to engage in consultation on an on-going basis with stakeholders and to facilitate
achievement of the targets of the packaging regulations. The Group is chaired by
DoEHLG and Repak and includes representatives from Local Authorities, Producers,
business organisations e.g. IBEC, the EPA, waste collectors and re-processors.
Prior to the introduction of the 2007 regulations, consolidating the existing legislation,
DoEHLG undertook a Statement on Regulatory Impacts of the draft Waste
Management (Packaging) Regulations to assess the state of current implementation
at that time, and to assess the pros and cons of the introduction of further regulation.
This Statement flagged the role of the Strategy Group, in being involved with
reviewing the implementation and operation of the regulations and monitoring of the
regulations. It indicated that the process of monitoring the regulations will be done

through the input of data from Repak and from national data complied by the EPA,
and that the performance indicators to be used would be:
218
� The increase in levels of recovery/recycling;
� The increase in the numbers in the compliance scheme or as Self Compliers;
and
� Increases in the roll out of required recycling infrastructure including bring
banks etc.
It is worthy of note that the requirements, upon producers, under Article 5 of the
Regulations, to separate packaging relates to the sorting of material for ‘recovery’.
This reflected the definition in the 2006 version of the Waste Framework Directive of
‘recovery’. So as to avoid the possibility that separately collected fractions of
packaging waste, that were intended to be recycled were subsequently sent for
recovery at incineration plants, it would seem sensible to re-word this in the existing
Regulations.
12.8 Implementation Costs
12.8.1 Implementation Costs of Packaging Recycling Policy
The implementation costs for setting up and operating the administrative measures
primarily revolve around providing staff and training resources. The staffing resource
is spread across all those organisations described in Section 12.4 of these Annexes.
The staff required range across the regulatory and guidance authorities and
organisations, from policy and guidance staff in DoEHLG and the EPA, to enforcement
officers in the enforcement network of the EPA & Local Authorities, to technical and
guidance staff in the EPA/Repak, to the project staff at the compliance scheme
Repak, to external consultant auditors of the compliance scheme, to staff in
stakeholder groups like the Irish Waste Management Association and IBEC.
Local Authorities indicated during the 2006 consultation that there is an existing
burden on their staffing levels with the current requirements of the regulations. 237
They flagged that the reduction in the de minimis threshold would increase the
number of companies in the ‘Major Producer’ category and which would place a
resource burden on Local Authorities in meeting administration and enforcement
requirements with the same number of staff.
The EEA report notes:
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“No specific estimates of the public authorities' administrative costs (general
administration, monitoring of packaging and packaging waste, etc.) or the
costs of the self-complying companies are available.”
Repak administers the monthly data processing and auditing of subsidy claims by
Repak authorised service providers (Private and Public waste management collectors
237 DoEHLG (2006) ‘Statement on Regulatory Impacts’, Responses from 2006 Consultation

and processors). In terms of the reporting and data returns requirements involved in
the compliance scheme, the month to month data administration of scheme
members is managed by Repak on behalf of scheme members.
For those companies representative of the 43% of packaging currently not under the
remit of the Repak scheme, these companies must undertake all of the
administrative functions themselves, and individual Local Authority staff resources
are required to be available to assess the packaging data and enforce compliance.
In addition to the Statutory fees required to be paid, Producers may also incur fees in
payment to Consultants, either in the production of packaging plans for the Local
Authorities, or where a Consultancy report is produced in response to a request from
a Local Authority as part of the process determining whether the operator comes into
the Major Producer category. In the Consultation process mentioned above by the
Strategy group, both the Local Authorities and representative of small businesses
identified this potential additional cost as being a financial burden to small
businesses.
12.8.2 Establishment of the Market Development Programme
The DoEHLG established the Market Development Group to develop and Implement
the Governments Market Development Programme 2007 – 2011, to progress the
development of new markets for recyclates. The waste management industry
stakeholders have been concerned with the poor development of market outlets for
recyclates in addition to the variation in market values. The objective given in the
report for the programme is that: 238
219
“the Market Development Programme for Waste resources, for the first time,
seeks to identify and address barriers to greater levels of reprocessing waste
in Ireland” And “This programme sets out a specific set of measures through
which greater levels of recycling can be achieved in Ireland which in turn will
reduce our reliance on overseas infrastructure and provide greater incentives
for waste recovery activities in the country”.
Packaging materials recovered on behalf of Producers by private and public waste
collection and treatment operators have a monetary value, which can be realised
when the materials are recycled. The material values available to waste collection
operators will influence the fees that they apply for the service they provide in
accepting the materials from producers. When the income associated with selling
recovered materials on the markets is low, this increases the net cost of providing
collection services for recycling.
The Market Development Programme 2007 – 2011 identified barriers experienced by
waste management companies in the area of market development:
� the existence of market limitations (e.g. a limited supply of recovered paper),
limited market outlets within Ireland;
238 DoEHLG (2007) Market Development Programme for Waste Resources 2007 – 2011.
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220
� instability and price fluctuations of the markets for recyclable materials;
� limited alternative outlets (in some cases due to quality requirements for
potential outlet uses being undeveloped);
� lack of approved existing standards for recycled waste packaging products;
and
� lack of financial support to businesses to extend capability for reprocessing of
materials.
More recently, the DoEHLG has also administered the convening and meeting in
November 2008 of the Action Group on Recyclates Markets 239 in communication with
the IWMA:
29/09/09
“Arising from a significant collapse of prices in the recyclate market, the
IWMA sought a meeting with the Department to highlight immediate concerns
with regard to storage of materials. Following on from this the Department
issued a circular to local authorities setting out a range of permitting and
licensing options for the industry, as outlined by the EPA.”
This Action Group on Recyclates Markets is focusing on addressing current actions
that may specifically be required in the current economic market environment, and in
relation to compliance requirements in the context of difficult recyclates markets.
Some of the action points arising from the November 2008 meeting included:
“In relation to markets, the Market Development Programme team will be
asked to compile a database of outlets / companies that accept recyclates in
Ireland to promote the movement of these goods”
“The development of a national brokerage for recyclates to ensure that Irish
companies have help in achieving better deals in world markets is to be
examined”
“The Market Development Programme work plan will be reviewed to take
account of the need to provide high quality paper and plastic in order to
secure markets, and the growing importance of developing an indigenous
recycling industry”
“An additional €2 million will be provided in 2009 to underpin the local
authority recycling infrastructure and public confidence in recycling”.
12.8.3 Packaging Prevention Policy Measures
Article 15 of the regulations effectively requires major producers to prepare plans
which set out the measures to be taken to prevent or minimise packaging waste. This
is one of the Articles which Major Producers are effectively exempted from through
their membership of a compliance scheme. However, Part VI of the Regulations refers
to the ‘Essential requirements of packaging’ and European standards, so that whilst
239 DoEHLG (2008) Action Group on Recyclates Markets 1 st Report, December 2008.

Repak members, and non-major producers, are not bound by Article 15, self
complying major producers are, and all producers are effectively required to assess
packaging against the CEN Standard on Prevention (EN 13428:2000). Local
authorities are responsible for enforcement of the Regulations, including this part of
them.
The EPA’s Core Prevention Team, in conjunction with the DoEHLG and Local
Authorities, is responsible for providing guidance on packaging waste prevention.
At the compliance scheme level, Repak provides guidance and technical services to
its members through its Packaging Waste Prevention Programme and advertises this
to its members. It notes that the Packaging Waste Prevention Programme is part of
the National Waste Prevention Programme administered by the Environmental
Protection Agency (EPA) and is co-funded by the EPA with the support of the
Department of Environment, Heritage & Local Government.
Repak also provides a packaging prevention service to its members, ‘Reduce and
Save’, using the technical guidance and expertise of a packaging technologist.
However, laudable as these measures are, it does not seem clear that the
Regulations are being enforced as strongly as they might be, especially in respect of
waste prevention.
12.9 Response from Public and Industry
The response from Industry on the whole has been to comply with their
responsibilities. Prior to March 2008, when the classification of Major Producer was
changed, Repak members numbered 2,333, with the estimated number of selfcomplying
companies being of the order 150. 240 These numbers will have changed in
the wake of the drop in the de minimis thresholds.
Industry stakeholders in the consultation process in the DoEHLG Statement of
Regulatory Impacts were concerned with the issue of cost implications associated
with the change in the de minimis threshold under the revised packaging regulations.
The industry stakeholders opposed to the change estimated that this could cost
between €2,000 to €3,000 for a business in hiring consultancy firms to carry out
work to assist in an assessment of packaging waste management and compliance.
This was regarded by the industry stakeholders as an unnecessary financial burden,
particularly on small businesses, given their scale of operation. 241
A number of submissions were received and their comments summarised in the
Statement on Regulatory Impacts produced by the DoEHLG. Some of these responses
include:
221
“The proposed changes make self-compliance too onerous and unattractive
an option for producers, thereby forcing them to join a compliance scheme. If
240 Information from Repak presentation to Eunomia, February 2009.
241 DoEHLG (2007) Statement on Regulatory Impacts, Strategy Group Consultation Responses 2006
on 2007 Regulations.
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the self-compliance regime becomes too burdensome, the question has been
raised as to whether this would be perceived as restricting competition,
particularly given that only one compliance scheme has been approved under
the existing Regulations (namely Repak)”;
“The reductions in the de minimis threshold were unnecessary, having regard
to existing and proposed recovery and recycling rates and would be
disproportionately burdensome on small businesses, having regard to the
contribution such reductions would make to increases in the recycling and
recovery of packaging waste. In this context, the reductions proposed by the
Strategy Group should be subject to Regulatory Impact Assessment (RIA) to
quantify the impact on small and medium enterprises before a final decision
is made on the matter; the Department should carry out this assessment”;
“The de minimis concept was meant to exclude producers who place small
amounts of packaging waste on the market”
“Turnover threshold (at the time in 2006) of €1million and 25 tonne threshold
are much lower than the corresponding de minimis thresholds in the UK”
“If local authority registration fees (€15,000 max) can be adjusted by
reference to the Consumer Price Index (CPI), this should also apply to the
current de minims threshold”
“There should be significant focus placed on small and medium sized
enterprises in all education programmes operated by Repak, in particular
programmes on waste prevention/minimisation”
The EEA 242 Report cites that there may be queries in relation to the relative size of the
compliance costs on smaller businesses and some of which have been raised by
Repak in the consultation for that report:
“Repak is concerned that standards of compliance are not equitable: not all
major companies are obligated, and among those who are, some are getting
away without paying. Moreover, self-complying companies may not be
addressing the objectives of the directive”.
The report also elicited some feedback in relation to the perceived functions of
administrative organisations:
“As regards the institutional structures, DoEHLG, the Dun Laoghaire
Rathdown county council and Enterprise Ireland generally find that there have
been no major problems due to structural organisation. Repak, however, sees
a problem with the responsibility being fragmented among central government
and 34 politically independent local authorities, with the Irish EPA overseeing
their actions. Repak also finds that packaging is given low priority since it only
makes up about 1 % of total waste”.
242 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 03/2005/

In their submission of information for this review by Repak noted: 243
223
“clearly a need for the adoption of a national strategy on packaging prevention
and minimisation, with agreed targets, timelines, programme measures and
implementing agency(ies)”
The Repak submission notes a potential ‘dichotomy of roles’ in administration of
prevention activities and of the compliance scheme but notes:
“In that regard, there is no reason why Repak could not continue to be the
main implementing agency, providing adequate resources were made
available, and that there was adequate transparency”.
“The implementation of a national strategy will require adequate resources.
While a more detailed implementation plan would identify a more precise
budget, an annual operating budget of the order of two million euro is the
minimum required to deliver a meaningful programme” And “Repak is already
operating under financial constraints, both from its members (seeking
reduced costs) and its operators (local authorities seeking extra funding). As
such, the ability of Repak to fully resource the required programme is severely
constrained.”
In relation to the potential funding sources to be used to provide resources for
packaging Waste prevention, the EPA notes in their National Waste Report 2006, that
with regard to packaging waste: 244
and that:
“Packaging waste recycling is strong and continues to grow. Addressing the
growth in the use of packaging, as illustrated by the growth in packaging
waste, should now become a new priority for Repak, as opposed to finding
new, and more expensive, sources of packaging waste to recycle”
“With the de minimus for major producers being reduced from 31 March
2008, Repak will have many new members, representing a new source of
income to Repak”.
12.10 Effects on Technical Change / Innovation
The key changes that have been associated with the Packaging Regulations are
probably the changes in segregation activity undertaken by businesses and
households, the changes in collection services offered by waste companies and the
increase in the infrastructure required to deal with the collected materials. However,
as stated above, the degree to which this is directly traceable to the effects of the
Regulations is not clear. High landfill gate fees might have been sufficient to
stimulate part of the change, though perhaps not all of it.
243 Repak (October 2008) Submission & Presentations on International Review of Waste Management
Policy - Presentation to TOBIN Consulting Engineers.
244 EPA (2007) National Waste Report 2006, Wexford: EPA.
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Article 9.1 of EU Directive 94/62 on packaging and packaging waste requires
Member States to ensure that with effect from 31 December 1997, packaging may
be placed on the market only if it complies with all Essential Requirements. The
Packaging (Essential Requirements) Regulations were introduced in Ireland in 1998
as part of an amendment to the Waste Management (Packaging) Regulations 1997.
A Repak report of 2008 identifies the key decision makers within a number of
packaging supply chains and highlights both opportunities and obstacles for
packaging prevention and minimisation. 245 The report examines a number of
common products and works back through the supply chain to identify the factors and
dynamics of packaging decisions. This is done in order to enforce the notion that
packaging can be kept to the minimum adequate amount to maintain safety hygiene
and acceptance by the customer, as set out in the packaging Essential Requirements.
The report notes also that reducing packaging also reduces the cost of procurement,
fuel consumption and vehicle movements.
The implementation and enforcement of the Essential Requirements aspects has not
been a major thrust of the existing Regulations thus far.
Repak’s submission and feedback in relation to packaging waste prevention is given
in the subsection above on Responses from Industry. In their submission for this
review Repak notes that:
224
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“The Department of Environment, Heritage and Local Government, which is a
member of the NSGPWR and participates in the Steering Group, has not
adopted any formal policy or strategy. The only recent strategy measure
adopted by the Department is to seek a voluntary packaging reduction
agreement with the retail sector, as outlined above, but there is no clear
evidence of any endgame or developed strategy in what it is that the
Department is seeking to achieve from this measure”.
As mentioned in the Section 12.7.1 of these Annexes, the manner of the
transposition and administration of the policy in Ireland means that the regulations
do not provide quantitative objectives or a structure or by which to enforce packaging
waste prevention. Industry feedback seems to suggest, as mentioned above, that in
its current form the current packaging policy has too loose a structure within which
prevention measures can be administered and enforced.
12.11 Social and Distributional Consequences
The social and distributional consequences of the existing system depend upon a
range of variables. These include:
1. For businesses, the degree to which compliance costs are linked to the size of
business, or to its nature, this, in turn, depending upon the net effect of:
245 Perchards (2008) Report on Packaging Supply Chain (Packaging Prevention), Report for Repak,
February 2008.

225
a. Direct costs of compliance (in respect of e.g. payments to Repak,
additional time spent in managing waste, costs of any spatial
requirements which may arise); and
b. The effects on waste / resource management costs resulting from
avoided disposal costs, including the extent to which the effects of RPS
payments to collectors are passed through to businesses in terms of
cost savings; and
c. The effect of the regulations on the net cost of packaging materials.
2. For households, the degree to which:
a. The RPS payments support the costs of collection (the net effect on
collection costs); and
b. Where PBU systems are in place, the nature of the benefits associated
with avoiding disposal.
We are not aware of any systematic attempt to understand the effect of these on
different actors.
In the DoEHLG Regulatory Impact Statement, it is suggested that there is a significant
cost differential between the collection of packaging waste at commercial premises
and that which takes place at households:
“Domestic packaging waste is typically more expensive to collect/ recover
than commercial packaging waste, with Repak estimating this cost to be
higher by a factor of 7:1 and continuing to increase.”
The differential is expected, but the magnitude of the ratio as suggested above seems
rather high (and the costs net of revenues from material sales would be expected to
vary with market conditions). This is not entirely in line with work carried out by
RECOUP for WRAP on kerbside collection of plastic bottles, which indicates
economies of scale in collection thereof, leading to considerable reductions in the
costs of kerbside collections of plastic as the capture rate increases. 246
It is noted in the DoEHLG Regulatory Impact Statement
“The Strategy Group considered that it was appropriate that the base of major
producers should be extended to assist in financing the extra tonnages that
will arise in the domestic sector” and
“The introduction of pay by weight and pay by use, coupled with the circa
90,000 (2006 estimate) annual new house completions, have been among
the main drivers underpinning this upward trend (in domestic recycling
activity)”.
246 See RECOUP (2005) Study to Identify Methods of Enhancing Local Authority Collection of Plastics,
Report for WRAP, PLA022, May 2004.
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12.12 Complementary Policies
A number of policies exist which complement the aims and objectives of the
packaging regulations. These complementary policies include:
226
� Pay by use (where provision is made for separation of household packaging
and dry recyclable waste);
� The landfill levy; and
� The plastic bag levy.
Although not strictly speaking ‘a policy’ in the terms of this study, the National Waste
Prevention Programme is also of relevance.
12.13 Effect of the Policy on Pricing of Resources / Services
In terms of the polluter pays policy, the polluter is both the packaging producer, who
has the final decision on packaging design, and the consumer, who makes the
decision about purchasing the product. In principle, the mechanism in place ensures
that producers pay for an undefined proportion of the costs of recycling collections,
with these being, to a degree, reflected in the prices paid by producers (strictly
speaking, the extent of this pass through is dependent upon the price-responsiveness
of demand for the packaging in question.
In principle, this type of mechanism improves the efficiency of resource use, without
necessarily being ‘efficient’ in the technical sense. The payments bear no relation to
estimations of externalities associated with packaging waste management.
Data for a number of years financing costs for Repak are shown in Table 12-6. These
charges are effectively transferred onto producers, who account for the costs in the
prices of their goods. The row highlighting ‘financing need’ is somewhat misleading
since the payments are effectively set in advance, and do not bear relation to a
funding gap required to deliver services. The figures do, however, indicate the
average level of payments made per tonne of waste collected for recycling.
Table 12-6: Cost-effectiveness of Compliance Scheme, Repak
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2001 2001 2002 2002 2003 2003 2004
2004
Financing need*), mEUR 11.1 13.9 15.8 18.5
Collected quantity, 1 000 t 237 323 415 470**)
Financing need per t collected, EUR/t 47 43 38 39
Change in financing need, per t collected, % – – 8 – 11 + 1
*) Total turnover.
**) Provisional Repak estimate, September 2004.
Note: Note: The table covers response indicator 10 on cost-effectiveness. Data for 1997–1998 are not available. Data
for 1999–2000 are not directly comparable with the ones in the table.
Source: Source: Source: Repak communication for EEA Report

As noted above, there are differences in the cost of collecting packaging from
households and from commerce and industry. As packaging recycling increases,
proportionately more material is likely to be required to be captured from households.
The EEA report notes: 247
227
“As increasing volumes of household waste, which are more expensive to
collect than commercial waste, are collected as a result of the implementation
of local authority waste management plans, it is anticipated that compliance
costs will further increase in the years ahead.”
Reflecting a similar perspective, in their National Waste Report 2006 the EPA notes
that with regard to packaging waste: 248
“Packaging waste recycling is strong and continues to grow. Addressing the
growth in the use of packaging, as illustrated by the growth in packaging
waste, should now become a new priority for Repak, as opposed to finding
new, and more expensive, sources of packaging waste to recycle”
12.14 Evasion and Enforcement
Repak estimates that the number of Non Compliers, was about 1,050 in 2001,
declining to an estimated 700 in 2004 and around 150 in 2008. It has been
suggested that some of this can be attributed to stepped-up enforcement activity by
the local authorities. According to Repak, 48 convictions have been secured by 8
local authorities over a ten year period, with the maximum fine being €15,000. 249
However, the record of enforcement does not appear to be an especially strong one. A
clear issue for the scheme is that local authorities might not have sufficient
resources, or incentives, to ensure compliance. In particular, if enforcement were to
bring more companies within the compliance scheme fold, the levies required from
each scheme member in order to provide revenue for RPS payments and other
activities would decline. There is an argument, therefore, for removing the de minimis
threshold altogether in the context of a tightened compliance regime. It might also be
interesting for local authorities to be incentivised to enforce the scheme by, for
example, designing this such that those who are not complying with the Regulations
are required to pay fines to the local authorities themselves. This would require
provision to be made for that purpose.
12.15 Lessons Learned
The Packaging Regulations have most likely had a positive effect in increasing the
recycling of packaging in Ireland through the application and use of various
measures, including obligations on producers to segregate packaging waste and have
247 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 03/2005.
248 EPA (2007) National Waste Report 2006, Wexford: EPA.
249 Information from Repak presentation to Eunomia, February 2009.
International Review of Waste Policy: Annexes

it recycled, the requirement for companies to demonstrate obligations have been
met, and the Repak scheme to reward collectors for collecting packaging waste. As
far as we are aware, there has been no attempt to ‘apportion’ responsibility for the
improvement to any one of the measures, let alone the Regulations themselves vis a
vis other policy instruments. Several changes have been taking place simultaneously,
so some of these will have contributed to progress made, notably, in our view, the
increase in landfill gate fees, and the increasing buoyancy of markets for secondary
materials in recent years.
Although the legislation and efforts to date have been heavily focused on targets
associated with recycling and recovery, it seems that there is a desire to shift
emphasis in future towards packaging waste prevention. Initiatives thus far have
centred around suasive measures, sometimes funded with public support. However,
there would be merit in seeking to ensure that the RPS payments covered the whole
cost of the provision of the collection service to households and businesses, this itself
acting as an incentive to encourage additional effort in waste prevention on the part
of producers.
However, even with such a measure in place, there would be merit in – and the
forgoing suggests that several stakeholders would support – measures to instate,
within legislation, stronger requirements to take efforts to prevent waste. To the
extent that this might stretch to consumers as well as producers, one means through
which to achieve this could be efforts to provide those businesses who are not
producers with the training and technical guidance to complete internal audits and
assessments and identify areas within their businesses where packaging can be
minimised. The approach to producers ought to be somewhat different, and should be
considered as part of the obligation placed upon producers. Hence, whilst producers
should be required to take actions to reduce, and prevent, packaging waste, public
support should be targeted at those who are not producers, with assistance given to
help minimise the generation of packaging waste. Furthermore, households could be
encouraged, though changes in legislation, to report examples of excess packaging,
which would trigger inspections of these cases against the technical arguments in
support of the packaging approach used.
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13.0 Producer Responsibility, Packaging -
International
13.1 Outline of Policy
A generalised description of this policy would be that it makes the companies that
bring packaging to the market responsible for its collection and recycling, though the
extent of this responsibility varies from one country to another. All packaging,
including retail packaging, such as plastic or paper bags and fast food wrappers can
be included in the policy scope. Occasionally, the policy also aims explicitly to
enhance both prevention and recycling of waste packaging.
The companies who typically have some form of obligation under the policy may
include those that:
229
� Package products;
� Sell packaged products;
� Import packaged products (including raw materials and parts);
� Bring packaged products into the market under their brand name;
� Provide customers with a carrier bag, other bag or box;
� Produce carrier bags, other bags or boxes.
Typically, a producer responsibility organisation will be established through which
funds are directed from packaging producers to the organisations charged with
recycling and recovery. The fee companies pay to the producer responsibility
organisation is linked to the amount and type of packaging they introduce to the
market and may also be linked to the costs of collecting, sorting and reprocessing the
collected material, though this depends upon detailed implementation. The fee
setting exercise is typically carried out annually and reflects the cost of the operation
and takes into account the price received for the recyclates. In principle, the better
quality and higher the market value of the recyclates, the cheaper the overall fee
ought to become, reflecting the level of revenue generated by material sales.
Another key factor influencing the magnitude of the levies paid, and the level of
achievement of the policy, is the level of the targets set as part of the policy.
From a waste prevention perspective, there are three ways in which producer
responsibility for packaging can aid prevention:
� Reduce the volume and weight of packaging used (e.g. light weighting and
reducing excessive packaging);
� Increase the share of reusable packaging in the packaging market (e.g.
refillable beverage cans); and
� Reduce the toxicity of materials used in packaging (for example, heavy metals
in glass).
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13.2 Where Has the Policy Been Applied and Why?
All EU Member States are forced to transpose the Producer Responsibility Directive(s)
as specified in the European Union's Fifth Environment Action Programme. One of the
key Directives is the Packaging Waste Directive. 250 The method of transposition
differs from country to country. Some of the more interesting (or most distinct)
approaches are outlined below.
In addition to EU Member States, several other countries, or states, have introduced
producer responsibility policies on packaging, sometimes under the heading of
‘product stewardship’. The following is intended to give a flavour of the manner of
implementation.
13.2.1 Germany
The details of the German implementation are discussed in Section 14.0.
13.2.2 Czech Republic
The Czech Green Dot system for packaging started with a voluntary agreement in
1999, which was supplemented by the obligation to recycle in 2001. In 2002, a
Packaging Act defined more precisely the obligations connected with handling
packaging and packaging waste. An increasing number of municipalities are now
involved in the system.
Producers of packaging pay a subscription to the Green Dot system, based on the
amount of packaging they produce. This is then used to help pay for the collection
and recycling of packaging waste carried out by the municipalities and other
authorised waste handlers. There is now a de minimis clause in the policy to exempt
small producers.
There are different license fees payable by material and by type of packaging i.e.
whether it is consumer, trade, transport or industrial packaging.
13.2.3 United Kingdom
The Producer Responsibility Obligations (Packaging Waste) Regulations 2005 are the
UK Government’s means of implementing the requirements of the Packaging Waste
250 Council Directive 94/62/EC on packaging and packaging waste (OJ No. L 365, 31.12.1994, p. 10)
as amended by:
230
• Council Regulation (EC) No 1882/2003 adapting to Council Decision 1999/468/EC the
provisions relating to committees which assist the Commission in the exercise of its
implementing powers laid down in instruments subject to the procedure referred to in Article
251 of the EC Treaty (OJ No. L 284, 31.10.2003, p. 1.);
• Council Directive 2004/12/EC amending Directive 94/62/EC on packaging and packaging
waste (OJ No. L 47, 18.2.2004, p. 26.); and
• Council Directive 2005/20/EC amending Directive 94/62/EC on packaging and packaging
waste (OJ No. L 70, 16.3.2005, p.17).
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Directive. The current Regulations are a consolidated version of the original
regulations, which were amended a number of times. The regulations concentrate on
important industrial and commercial sources (i.e. companies that handle more than
50 tonnes of packaging per annum and have a turnover of more than £2 million per
annum) and apply the shared producer responsibility approach.
There are a number of producer responsibility policies currently in place in the UK.
These are both legislative policies that have been transposed into UK law (as a
means of implementing European Directives), and also voluntary measures,
monitored by Government, that have been initiated by trade associations,
manufacturers and retailers.
In the UK, considerable time was spent seeking to understand who, in the supply
chain, should hold what level of obligation of packaging placed on the market. The
obligation which a given enterprise must meet is a function of the quantity of
packaging it handles, with the proportion of this quantity being affected by its position
in the supply chain:
231
� Raw Raw Raw material material material manufacturer: manufacturer: manufacturer: 6%. 6%.
6%.
Manufacturing of packaging raw materials. Example: Manufacturer of steel for
baked beans cans.
� Converter: Converter: 9%.
9%.
Manufacturing a recognised packaging item. Example: Manufacturer of the
steel can for the baked beans.
� Packer/filler: Packer/filler: 37%.
37%.
Putting a product into packaging or applying packaging to a product. Example:
the Company which fills the can with baked beans.
� Seller: Seller: Seller: 48%.
48%.
Supplying the packaging to the end user of that packaging. Example: The
supermarket which sells the baked bean can to the consumer. Additionally it
may be noted that a wholesaler selling cans of beans bulked up into boxes
would have an obligation for the boxes which are removed by the supermarket.
� Importer: Importer: rolled rolled rolled up up obligation.
obligation.
Companies who directly import packaging, packed goods or packaging
material are also obligated. The level of their obligation depends on the stage
of the chain at which the packaging is brought into the UK.
Not all companies who handle packaging are obligated to recover and recycle
packaging under the UK Regulation. ‘Producers’ are defined within the Regulation
through Schedule 1. This sets thresholds for companies who are, or are not obligated
to recover and recycled packaging under the Directive. These thresholds are set out in
Para 3 of Schedule 1:
3. A person satisfies the threshold tests if—
a. his turnover in the last financial year in respect of which audited
accounts are available before the relevant date was more than
£2,000,000; and
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b. in the calculation year the person handled in aggregate more than 50
tonnes of packaging or packaging materials.
Under the packaging waste regulations, a producer is obliged to recover and recycle
the packaging that is needed to discharge its obligation either through its own
actions, or through joining a compliance scheme. In the latter case, which is followed
by the vast majority of obligated entities, the compliance scheme then takes on the
producer’s obligation. There are currently 24 such compliance schemes in the UK.
A de facto system of tradable compliance credits helps drive compliance forward. 251
The nature of evidence which is generally used to demonstrate that the obligation of a
company, or compliance scheme, has been discharged is the Packaging Recovery
Note (and the Packaging Export Recovery Note). Accredited reprocessors are entitled
to issue these when packaging waste is recycled or recovered, and they may sell
them to obligated companies / compliance schemes. Essentially, if the market for
‘evidence’, in the form or PRNs / PERNs is tight (demand is strong relative to supply),
then the value of PRNs / PERNs will be higher than in situations where it is well
known that compliance is assured. It should be noted that PRNs / PERNs are material
specific, and since the relevant targets are also, the way in which PRN / PERN prices
move reflects the market for evidence of compliance for specific materials. It also
reflects what happens ‘at the margin’. In other words, if in a given year, compliance is
certain to be secured, PRN/PERN values are very low. If, on the other hand, the
market is tight, values increase, so that compliance costs are affected to a significant
degree by what happens ‘at the margin’. Equally, the overall costs of PRNs and PERNs
to producers and compliance schemes bear limited relation to the overall costs of
compliance, as represented by the costs of collecting, sorting and reprocessing
packaging materials.
13.2.4 Japan
The Containers and Packaging Recycling Act (1995) introduced producer
responsibility, at a time when 60% of household waste was deemed to be
packaging. 252 The Japan Containers and Packaging Recycling Association (JCPRA)
was set up to receive fees from producers and distributors of packaging and carry out
the required recycling. It did not cover aluminium, steel or cardboard – these are
recycled without any producer responsibility (the aluminium recycling rate was
estimated at over 80% in 2000). 253 By being members and paying the appropriate
fees, the producers and distributors undertake their recycling obligations.
The JCPRA does not organise or operate the system for collection of the materials,
this being carried out by the municipalities. The fees paid by members are a
proportion of the calculated recycling costs. These costs and proportions are agreed
251 This scheme was not initially designed explicitly as a tradable credit scheme.
252 Quoted from a 1995 survey by the Ministry of Health and Welfare, on the JCPA website,
http://www.jcpra.or.jp/eng/jcpra/02.html
253 Japan for Sustainability website, article of November 2004,
http://www.japanfs.org/en/pages/025737.html

each year by an Industrial Structure Council, a body of industry representatives
formed by the Ministry of the Economy, Trade and Industry, based on government
waste forecasts.
Recycling fees paid by the members are calculated as a proportion of the recycling
unit cost and multiplied by their estimated output. 2009 recycling costs are shown in
Table 13-1 below. The unit costs for PET, paper and plastics have fallen significantly
since 2000. For example, the unit cost for PET bottles has come down from 88,000
Yen per tonne in 2000 (€819 at January 2000 rates) to 1700 Yen per tonne (€14 at
January 2009 rates) in 2009. 254
Table 13-1: Japanese Recycling Unit Costs, 2009
Glass
233
Material Material
Cost Cost per per tonne tonne (Euro, (Euro, at at Jan Jan 2009 2009 exchange exchange exchange rate)
rate)
International Review of Waste Policy: Annexes
Colourless 35
Amber 47
Other 78
PET Bottles 14
Paper 113
Plastics 559
Source: JCPRA, 2009
The proportion of this recycling cost that members pay depends on their industrial
sector, whether they are ‘users’ (companies that package their goods) or packaging
manufacturers, and whether the packaging is classed as a container or wrapping (for
paper and plastic).
For example, a container user would pay 55% of the recycling cost of PET bottles per
tonne used, while the manufacturer would pay around 5%. Proportions are as high as
80% for users of plastic packaging (0.5% for manufacturers) and as low as 4% for
users of paper packaging (0.3% for manufacturers).
Japan historically has a high recycling rate for steel and aluminium because of the
lack of space for landfill and the market value of the recyclates. PET rates are
increasing fast with nearly 70% recycled (including municipal and other sources of
collection) in 2007, according to the Council for PET Bottle Recycling. 255 Plastic
packaging recycling has increased from less than 60,000 tonnes in 2000 to over
800,000 tonnes in 2007. Table 13-2 below shows the volume and change in
packaging recycling in Japan. 256 It is also worth noting that, in Japan, some
segregation schemes sort waste into ‘burnable’ and ‘non-burnable’ fractions, with
plastics considered non-burnable.
254 From the JCPRA website, accessed January 2009, http://www.jcpra.or.jp/eng/statistics.html
255 PET Council for Recycling website accessed January 2009, http://www.petbottlerec.gr.jp/english/index.html
256 From the JCPRA website, accessed January 2009, http://www.jcpra.or.jp/eng/statistics.html

Table 13-2: Packaging Recycling in Japan
Glass
234
29/09/09
Material Material
Volume Volume recycled recycled 2007
2007
% % change change in in recycling
recycling
2000 2000-2007 2000 2007
Colourless 131,666 -29
Amber 107,754 16
Other 112,495 15
PET Bottles 272,850 182
Paper 56,364 18
Plastics 802,036 429
Source: JCPRA, accessed January 2009
13.2.5 Other countries
Producer responsibility schemes for packaging have also been introduced in Korea,
Canada, Taiwan, Brazil, Argentina and Mexico.
13.2.6 Commercial and Industrial Packaging Collection and Recycling
It is interesting to note the different ways in which countries split responsibilities for
dealing with packaging waste from households, and packaging waste from
commercial and industrial sources. In some countries, there are different
organisations dealing with commercial and industrial packaging, and household
packaging (DSD in Germany, for example, only collects household packaging), whilst
in other countries, the same organisation does both jobs (Conai in Italy, for example).
There is little information about the split between household and non-household
packaging in Europe apart from the assumed split used in the Waste Strategy for
England 2007, shown in Table 13-3. If these figures are representative of other
countries, then it seems reasonable to state that given that around half of non-wood
packaging (and 44% of all packaging) is derived from households, those countries
that target both the household packaging stream and the commercial stream are
likely to be at the top of the overall packaging recycling table.
Table 13-3: UK Split of Household/non-Household Packaging, 2004
Material Household C&I
Total tonnage (‘000) Tonnes (‘000) % Tonnes (‘000) %
Paper 3,725 931 25% 2,794 75%
Glass 2,400 1,800 75% 600 25%
Aluminium 141 134 95% 7 5%
Steel 690 483 70% 207 30%
Plastics 1,844 1,176 64% 668 36%
Sub-total excluding wood 8,800 4,524 51% 4,276 49%
Wood 1,404 0 0% 1,404 100%
Other 22 0 22
Total packaging 10,226 4,524 44% 5,702 56%
Table 13-4 below shows the European situation for household/non-household
producer responsibility organisations. Commercial and industrial packaging is

generally cheaper to collect as it arises in larger quantities, and is often more
homogeneous (potentially increasing the sales value of the material). In schemes
where targets are set at less ambitious levels, then particularly where there is no
distinct separation of responsibilities, commercial and industrial packaging tends to
be collected first (as ‘low hanging fruit’).
Table 13-4: Producer Responsibility Organisations
235
Country
Country
International Review of Waste Policy: Annexes
Organisation Organisation for for Household Household
Household
Packaging
Packaging
Organisation Organisation for
for
Commercial/Industrial
Commercial/Industrial
Packaging
Packaging
Austria Branch organisations Branch organisations
Belgium Fost Plus Val-I-Pack
Finland PYR PYR
France ECO-Emballages, Adelphe
No organisation exists – it is up
to each company producing C&I
packaging to be responsible for
its recycling
Germany DSD Different organisations
Ireland Repak Repak
Italy Conai Conai
Luxembourg Valorlux
Portugal SPV SPV
Spain Ecoembalajes, Ecovidrio
Sweden REPA
Valorlux for commercial, no
organisation for industrial
(industrial companies must
satisfy regulations themselves)
No organisation exists – it is up
to the companies and
municipalities
For most companies, no
organisation: waste
management companies handle
packaging. For small
companies, REPA provide free
collection points
UK Split between household & commercial/industrial is not applicable
13.3 Key Organisations Involved in Implementation and
Management
Packaging Recovery Organisation (PRO) Europe is an international umbrella
organisation for national member systems for the recovery and recycling of packaging
waste in Europe. All these systems use the Green Dot mark as a symbol of financing
packaging waste recycling. The PRO has the following remit:

236
� It serves as a forum for the participating national partner organisations, as an
intensive exchange of experiences and ideas essential for optimal application
of Directive ES 94/62 on packaging and packaging waste;
� It grants the right to use the Green Dot registered trademark in accordance
with certain rules applied to individual systems which are established in
participating European states, the objective of which is the optimal application
of Directive ES 94/62;
� It develops and checks the criteria for using the Green Dot trademark for
manufacturers and distributors of packaging and/or packaged goods in
accordance with the European Cartel Office.
In each country there is an authorised licensee of Green Dot. For example, in
Germany the licensee is Duales System Deutschland GmbH, while in the Czech
Republic, it is EKO-KOM a.s.
Countries where Green Dot is not in operation, such as Japan, have an equivalent
organisation (in that case, the JCPRA), which receives fees and either organises the
collection and recycling, or contributes financially towards it.
13.4 Evaluation Studies Available
The following sources of information, as well as other sources, are the basis of the
overview that follows:
Schwarz and Gattuso (2002) Extended Producer Responsibility: Reexamining Its Role
in Environmental Progress, Report for the Reason Foundation,
www.reason.org/ps293.pdf
European European Union
Union
Report from the Commission to the Council and the European Parliament, 2006 The
Implementation Of Directive 94/62/Ec On Packaging And Packaging Waste And Its
Impact On The Environment, As Well As On The Functioning Of The Internal Market,
Dec 2006.
Report from the Commission to the Council and the European Parliament, 2005
Taking sustainable use of resources forward: A Thematic Strategy on the prevention
and recycling of waste, Dec 2005
Perchards (2005) Study On The Progress Of The Implementation And Impact Of
Directive 94/62/Ec On The Functioning Of The Internal Market, Final Report to the
Europen Commission, May 2005
Argus (2001) European Packaging Waste Management Systems, Report for the
European Commission, February 2001
European Topic Centre on Resource and Waste Management (2005) Effectiveness of
packaging waste management systems in selected countries: an EEA pilot study,
Report for the European Environment Agency, 2005.
Taylor Nelson Sofres (2000) Cost-Efficiency Of Packaging Recovery Systems- the
Case Of France, Germany, The Netherlands And The United Kingdom, Report for the
European Commission, February 2000.
29/09/09

Netherlands
Netherlands
Netherlands
Henderson (1997) Waste charges and taxes in the Netherlands , pp. 97-112, in
Environmental taxes and charges, Dublin: European Foundation.
Ger Germany Ger many
Prognos AG (2002) Assessment of Sustainability and the Perspectives of the DSD,
report commissioned by the Duales System Deutschland AG, Düsseldorf, June 2002.
Öko-Institut (2002) Advantage of the Green Dot for the Environment, report
commissioned by the Duales System Deutschland AG, Düsseldorf, March 2002.
United United Kingdom
Kingdom
David Davies Associates (2005) Packflow 2008 , UK compliance with the 2008
targets of the European Packaging & Packaging Waste Directive,
http://www.valpak.co.uk/docs/packaging/packflow_2008_summary_report_recomm
endations.pdf
Perchards (2003) Impacts of the Packaging (Essential Requirements) Regulations: A
Brief Survey, Report for DTI, Oct 2003.
13.5 Environmental Benefits
13.5.1 Across Europe
Packaging consumption is responsible for around 80 million tonnes of CO2 equivalent
per annum in the EU 15 (2% of the total emissions). The recycling and recovery of
packaging has been attributed with greenhouse gas savings and also reduces other
environmental impacts, such as those associated with residual waste treatments,
whilst it also reduces emissions of particulates and other air pollutants, and soil
acidification.
Table 13-5 shows recycling and recovery rates for all packaging in the EU 15 for 2001
and 2006, with countries ordered by 2006 recycling performance. This is shown
graphically in Figure 13-1. Table 13-6 shows the split of financial responsibility for the
collection and sorting of household packaging, according to Perchards, and with
updates where available. 257 This is significant as it is one of the two main financial
variables seen in the implementation in Europe that may have an impact on the
recycling rate. Where producer responsibility schemes fund the same range of
services (e.g. in Germany, Belgium and Austria, where 100% of the collection and
sorting of household waste is funded), the other financial variable between them is
the fee for each type of packaging material – see Table 13-7 under implementation
costs for a cross section of these.
Table 13-6 shows that the top three countries in terms of recycling all packaging each
visits 100% of the financial burden of collection and sorting household packaging
257 Perchards (2005) Study On The Progress Of The Implementation And Impact Of Directive 94/62/Ec
On The Functioning Of The Internal Market, Final Report to the Europen Commission, May 2005.
237
International Review of Waste Policy: Annexes

materials onto the packaging industry, rather than the household / municipality. They
all have more or less universal household waste collections for packaging, and thus
would be expected to have some of the higher fees in Europe. Some cases suggest a
gradual move towards a higher percentage: for example, Italy’s producer
responsibility organisation was estimated to cover 65% of costs in 2001, but now
covers around 83% (with the intention being to have 100% cost coverage).
Table 13-5: Packaging Recycling Rates (all packaging)
238
29/09/09
Country Country Country 2001 2001 % % Recycling Recycling Recycling 2001 2001 % % Recovery Recovery 2006 2006 % % Recycling Recycling Recycling 2006 2006 % % Recovery
Recovery
Belgium 71 88 79 94.5
Austria 64 73 68 87.5
Germany 76 79 66.5 88
Luxembourg 57 69 64 92.5
Netherlands 56 59 60 88
Sweden 63 66 58 81
UK 42 48 57.5 62
Denmark 57 90 56 94
Portugal 38 52 56 56
Italy 46 51 55 65
France 44 59 55 64
Ireland 27 27 54.5 57
Spain 44 50 54 61
Finland 47 62 49 77
Greece 33 33 43 43
Source: European Commission, accessed 2009
Many of the European countries’ producer responsibility organisations work with the
municipalities to some degree to organise collection and sorting of waste packaging.
The UK solution is different as accredited reprocessors of recyclates sell packaging
recovery notes (PRNs) for each tonne of material they process into what amounts to a
market for compliance credits, some of which are openly traded. Companies that put
packaging on the market (or the compliance scheme of which they choose to be a
member) then buy these PRNs to the tonnage value of that packaging. This process
supports the market for reprocessing; it has no direct link with the collection and
sorting of packaging waste (household or non-household). It therefore does not fund
the collection of recyclable materials directly, but it may influence the price of
materials offered by reprocessors at any moment in time (though this is likely to be
incremental for local authorities operating services through contracts with operators).

Figure 13-1: Packaging Recycling and Recovery Rates in the EU15 (all packaging)
239
100
90
80
70
60
50
40
30
20
10
0
Belgium
Austria
Germany
Luxemburg
Netherlands
Sweden
International Review of Waste Policy: Annexes
UK
Denmark
Portugal
Italy
France
Ireland
Spain
Finland
Greece
2001 % Recycling
2001 % Recovery
2006 % Recycling
2006 % Recovery

Table 13-6: Split of the Financial Burden of Collection and Sorting of Household
Packaging
Country
Country
240
29/09/09
% % of
of
collection/sorting
collection/sorting
collection/sorting
cost cost borne borne by
by
recovery
recovery
organisation
organisation
% % of
of
collection/sorting
collection/sorting
cost cost borne borne borne by
by
municipality municipality /
/
households households
households
Belgium 100 0
Austria 100 0
Germany 100 0
Luxembourg unclear unclear
Netherlands
Reported as 1% (in
2001) by
Perchards (2005)
Reported as 99%
(in 2001) by
Perchards
(2005)
Sweden 95 5
UK
Reported as 7% (in
2001) by
Perchards (2005)
Reported as 93%
(in 2001) by
Perchards
(2005)
Denmark 2 98
Portugal 65 35
Comment
Comment
Fost Plus organises and finances collection of
glass (bring site); paper and card; plastic
bottles and flasks, metallic packaging and
drink cartons
ARA runs nationwide systems for the
collection and recovery of all household and
commercial packaging waste
Duales System Deutschland GmbH organises
the collection, sorting and recycling of
packaging waste in Germany with the support
of 724 waste management partners
Designed to cover all expenses of collecting,
sorting and recycling packaging. Valorlux
transfer funds per tonne to the municipalities
based on tonnages handed over to registered
recycling plants: Glass €36.92; Paper €6.68;
Cardboard €18.56; other (plastic & metal)
€164.52
The traditional approach has been to increase
packaging recycling through a voluntary
agreement between government and local
authorities. Since January 2008, a packaging
tax is payable, with some of the revenue going
to a waste fund which pays out to
municipalities per kg collected
The producer responsibility organisation,
REPA owns the national bring system, around
5,800 places. It contracts waste management
companies for transportation and recycling.
PRNs provide support for recycling market
rather than direct support to municipalities.
Perchards’ percentages likely to be out of
date, but no new estimate available
No producer responsibility – instead a
packaging tax covers the cost of municipal
responsibility for recycling/recovery. Also, a
deposit refund scheme is in place

Country
Country
241
% % of
of
collection/sorting
collection/sorting
cost cost borne borne by
by
recovery recovery
recovery
organisation
organisation
International Review of Waste Policy: Annexes
% % % of
of
collection/sorting
collection/sorting
cost cost borne borne borne by
by
municipality municipality /
/
households households
households
Italy 83 17
Comment
Comment
The principle is that 100% of costs are
covered by the PRO, but the estimated
position is 83% 258
France 65 35 Still an accurate assessment in 2009 259
Ireland 68 - 92 8 - 32
Spain 65 35
Finland 7 93
Greece 0 100
Source: Perchards (2005), and updates based on personal communications
Repak estimates – Repak paid an average
domestic subsidy of €77 per tonne in 2008
and estimate that the direct cost base is in
the region of €84 to €113 (before receipt of
income from sale of recyclates) 260
In terms of waste prevention, the picture for all packaging, in Figure 13-2, is not
particularly clear. It is likely that this is somewhat affected by differing perceptions
regarding reporting requirements as well as different methodologies for reporting of
data. Whilst Belgium, Austria and Sweden have a smaller waste generation per capita
than the EU15 average, Germany and Luxembourg do not (despite the high charges
per tonne of packaging in Germany). 261 However, other reports (see section 13.5.2
below), suggest that in an earlier period (from 1991 to 2000), there was a waste
prevention impact. The packaging waste generation per capita also reflects the
wealth and consumption habits of the country. Unfortunately the household/nonhousehold
split of packaging waste was not obtainable for all countries, but this
would certainly help shed additional light on the situation. Another complicating factor
might be the presence of re-use targets and deposit refund schemes in some
countries.
What is interesting is that by some measures, the Irish system does not appear to
perform especially well, on a comparative basis. For example, in terms of what might
be an appropriate target for packaging, the recycling target is a useful driver but it
does not incentivise waste prevention. It could be that a more suitable target, which
would reward waste prevention, would be a target to ensure residual waste packaging
is below a specified level. For the old EU-15, this is shown in Figure 13-3.
258 Personal communication with Enzo Favoino of the Scuola Agraria del Parco di Monza, June 2009.
259 Personal communication with Pascal Gislais, June 2009.
260 Personal communication with Tony O’Sullivan, Repak, June 2009.
261 European Environment Agency website, accessed January 2009,
http://dataservice.eea.europa.eu/atlas/viewdata/viewpub.asp?id=2696

Figure 13-2: Packaging Waste Generation (kg per capita)
242
29/09/09
300
250
200
150
100
50
0
Czech Republic
Hungary
Greece
Poland
Slovenia
Estonia
Finland
Latvia
Austria
Sweden
Belgium
Portugal
EU 27
United Kingdom
Denmark
Spain
EU15
Germany
France
Italy
Netherlands
Luxembourg
Ireland
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
Source: European Environment Agency, accessed January 2009
Figure 13-3: Packaging Waste per Capita, and Unrecycled / Unrecovered Quantities
Packaging (kg per capita)
300
250
200
150
100
50
0
IRE
M
IT
F
SP
LUX
P
DK
UK
SWE
FI
GER
CY
EST
SLO
POL
GR
LIT
Total Packaging Waste (kg per capita) Unrecycled Packaging (kg per capita)
H
A
ROM
BU
SLA
BE
CZ
NO
Sources: Packaging quantities, recycling and recovery rates for 2006 from European Commission:
http://epp.eurostat.ec.europa.eu/portal/page/portal/waste/data/packaging_waste Population data
from Eurostat.
http://epp.eurostat.ec.europa.eu/tgm/table.do?tab=table&language=en&pcode=tps00001&tableSel
ection=1&footnotes=yes&labeling=labels&plugin=1

It can be seen that against this measure, the Irish position is one with very high per
capita generation, and reflecting this, given that many other countries have decent
recycling performance, the performance in respect of residual waste is not especially
good. Having said that, the quality of the data is not what it might be, and the
calculation in respect of per capita quantities might not be especially robust. The
figure also suggests that this type of target would be much fairer across the EU as a
whole, with countries at lower income levels effectively performing better than those
at higher income levels, even at relatively low recycling levels.
13.5.2 Packaging Regulations Essential Requirements
Three countries – the UK, France and the Czech Republic - have put enforcement
measures in place to enforce compliance with the Essential Requirements for
packaging (Articles 9, 10 and 11 of the Packaging Waste Directive). These include
minimisation of packaging weight and volume to the amount needed for safety and
consumer acceptance of the packed product, and suitability for reuse, material
recycling, energy recovery or composting. Packaging materials must also keep the
concentration of heavy metals below certain targets.
The UK and France both use the CEN (European Committee for Standardisation)
standards as a baseline for packaging. PIRA and Ecolas in 2004 identified a
correlation between enforcement of the Essential Requirements in France and the UK
and a decoupling of GDP from packaging waste generation. This decoupling is
comparable with that in Belgium and Spain, where the requirement to develop
prevention plans appears to have had broadly similar effects, and is greater than for
EU-15 as a whole. 262 The CEN standard on prevention by source reduction (EN
13428: 2000) provides companies with a methodology for a systematic evaluation of
their packaging reduction opportunities.
13.6 Implementation Costs
The implementation costs of the producer responsibility will depend upon a range of
factors in a given country, amongst other being:
243
• The baseline waste management system (what was happening before the
system was introduced);
• What are the background costs of residual waste collection and treatment;
• How the market for waste collection is configured;
• Whether or not countries operate pay-by-use schemes;
• The quality of the material being collected for recycling; and
• The possibilities for marketing materials in a pro-active manner;
262 Study On The Progress Of The Implementation And Impact Of Directive 94/62/Ec On The
Functioning Of The Internal Market, Perchards, 2005
International Review of Waste Policy: Annexes

What is often reported in the literature is the cost of the producer responsibility
scheme, sometimes referred to as the ‘financing need’, but the reality is that the
costs of collection, sorting and reprocessing have to be shouldered by somebody, and
the manner of implementation of producer responsibility, whilst it may affect the
costs of implementation, probably has the most significant effect on the distribution
of these costs across households / local authorities / businesses (those who pay for
the collection of waste) and the obligated companies (those whose responsibility it is
to demonstrate compliance). In essence, whatever the costs of the system, those
which are not borne by ‘producers’ will have to be borne by other actors.
The key financial actors are the waste collector and the producer responsibility
organisation (representing the packaging manufacturers and ‘users’). In the German
example, the waste collection is wholly paid for by the producer responsibility
organisation (based on the fees charged to the manufacturers and users). The DSD’s
18,560 members paid 540 million Euros (£377.6 million) in 2003. With DSD
receiving Green Dot fees for 4,495,692 tonnes of packaging waste, this makes for an
average of over €120 per tonne. This figure includes the income from recycled
material. Costs (licence fees) payable to DSD for packaging produced or sold in
Germany are shown in Figure 13-4.
In schemes such as the Japanese one, the collection is done at a cost to the
municipality and a share of the recycling cost is borne by the producer responsibility
organisation (to bridge the gap between the cost of the recycling process and the
value of the recyclate).
In schemes such as that operated in the UK, the vast majority of the cost of
household collection is borne by taxpayers, whilst obligated companies contribute a
fraction of the cost of collecting, sorting and reprocessing the material. The
Table 13-7 shows the fees levied by material in some of the Green Dot schemes in
Europe, all expressed in Euros per tonne. Where the producer responsibility scheme
pays 100% of the collection and sorting of household waste there are generally higher
fees to pay for these efforts. In addition, one notes that the fees tend to follow the
relative costs of collection. Plastics, being a low bulk density material, and typically
requiring post-collection sorting, are relatively more expensive to collect, even taking
into account the relatively high revenues which can be obtained from sales of sorted
polymers. In all countries shown, the fees for plastic are high, whereas the fees for
glass are much lower, reflecting the lower costs, and in many parts of Europe, the
reduced necessity for colour sorting and / or the potential to collect high proportions
of glass through bring schemes.
244
29/09/09

Figure 13-4: German License Fees Payable to the Governing Authority per Tonne of
Packaging Produced (effective 2007)
Licence fee per tonne (euro)
245
1400
1200
1000
800
600
400
200
0
Plastic Other composites Beverage cartons Aluminium Tin-plate Paper and
cardboard
International Review of Waste Policy: Annexes
Material
Natural materials Glass
Table 13-7: Fees by Material for Green Dot schemes in Europe (Euros per tonne)
Material
Material
Belgium
Belgium
(2008)
(2008)
Germany
Germany
(2007) (2007)
(2007)
Austria
Austria
(2007)
(2007)
France
France
(2007)
(2007)
Spain
Spain
(2008)
(2008)
Greece Greece
Greece
(2005) (2005) (2005) *
Glass 29.30 74 61 3.6 - 10
Plastics 159.40 1296 610 177.80 278-329 62
Steel 18.80 - - 22.60 61 20
Aluminium 33.90 733 370 45.30 102 8
Paper/card 15.70 175 105 122.10 51 50
*Plus a fee of 0.4 Euro cents per item
Source: Pro Europe, 2008
This can be contrasted with the UK scheme where the fluctuation in PRN price is
driven by the closeness to balance of supply and demand for PRNs as ‘evidence’. The
fluctuating value of PRNs is shown in Figure 13-5. This shows, for example, how for
most materials, following the end of the 2001 compliance year, PRN prices for most
materials made no upward movement in the period to the end of 2003 as
Government did not change the level of the targets from 2001 to 2003 (and everyone
knew they would be met).
In 2004, material specific rates were introduced, and the overall recovery
requirement was much more closely aligned with the recycling requirement. This
meant that energy recovery PRNs lost a considerable amount of their value, although
those for recovery of energy from wood have remained somewhat higher. What

appears to be happening, however, is that as targets rise, the PRN values for some
materials are becoming more volatile and it would appear, at least from the price
trends, that there has been greater anxiety surrounding targets for the metals, for
plastic and for glass than for other materials. On the other hand, the sensitivity of the
market to changes in information and data is also clear. Announcements by Defra
that the quantity of obligated packaging placed on the market was 466,000 tonnes
(5%) or so less than was previously estimated for 2006 sent PRN prices tumbling
downwards.
Figure 13-5: Evolution in PRN Values for Specific Materials
PRN Price (£/tonne material)
246
180
160
140
120
100
80
60
40
20
0
29/09/09
Oct-00
Jan-01
Apr-01
Jul-01
Oct-01
Jan-02
Apr-02
Jul-02
Oct-02
Jan-03
Apr-03
Jul-03
Month / Year
Oct-03
Jan-04
Apr-04
Jul-04
Oct-04
Jan-05
Apr-05
Jul-05
Oct-05
Jan-06
Apr-06
Jul-06
Oct-06
Glass
Paper
Aluminium
Steel
Plastics
Mixed - energy recovery
Wood - energy recovery
This is not an effective mechanism to support local authority investment in recycling,
not that of industry, and tends not to incentivize ongoing efforts to prevent packaging
waste, nor to design it for recyclability. It also bears no relation to the ongoing costs of
recycling activity. PRN revenues were £59 million and £57 million per annum in 2006
and 2007, respectively. A broad brush estimate of the cost of only household services
for packaging waste recycling in the UK would be of the order £200-£250 million,
suggesting that the funding within the system covers at the very most around a
quarter of the costs of household waste recycling, but most likely, a rather smaller
percentage of the costs of recycling household and non-household packaging.
13.7 Effects on Technical Change / Innovation
Generally, producer responsibility for packaging increases recycling of packaging,
though it often is one of a range of policies used to achieve this objective. The
incentive imparted to companies to minimise waste varies with the extent to which
they are made financially responsible for the system being implemented.
It can be expected that material switching will take place at the margin either to avoid
the heavier materials, or to avoid the more difficult to recycle packaging materials.

This is likely to have been dependent upon the weight based payments made by
obligated entities, and the targets the scheme is required to meet. Some materials
are lower in weight, but some of these, notably plastics, are more expensive to
recycle.
Reuse systems that had been based on glass (such as in Denmark and Finland) have
been encouraged through tax policy to remain reuse rather than one-way, but start to
move to PET bottles. This was the case after the Finnish tax was introduced in 1994,
as shown in Table 13-8. Where legislative support has not been in place for reusable
systems, these have tended to dramatically diminish.
Table 13-8: Finnish Packaging Mix
247
1995 1995 Market Market Share Share %
%
International Review of Waste Policy: Annexes
1999 1999 Estimated Estimated
Estimated
Market Market Market Share Share % %
%
1995 1995-9 1995 9 Growth Growth Growth %
%
Cans 13 16 25
Refillable Glass 77 64 -18
Non-refillable Glass 0 0 0
Refillable PET/PEN 9 19 97
Non-refillable PET/PEN 0 0 0
Total 100 100 -2
Source: Study on Environmental Taxes and Charges in the EU, 2001
There are a number of drivers for technical innovation in packaging and so it is not
always simple to assign change to a particular one. For example, lightweighting of
aluminium cans would be driven by the price of the material, so the producer
responsibility fee would have to be high in order to contribute more inducement.
Some of the recent packaging changes do however point towards single material use,
such as the all cardboard packaging for Duracell batteries or some small electrical
appliances. In addition, the increase in use of re-usable packaging – particularly for
haulage of products in crates / pallets has been incentivised by producer
responsibility.
13.8 Social and Distributional Consequences
The cost of packaging waste collection and disposal is covered either by municipal
charges or by a producer responsibility organisation. See Table 13-6 for the split in
Europe. Where the majority of the cost is covered by the producer responsibility
organisation, it is recouped via the producers from the cost of their products.
Otherwise, it is charged directly to the householders either as a flat charge or a
mixture of fixed and variable (by use) charges.
13.9 Complementary Policies
In a number of countries deposit refund systems are used in conjunction with
producer responsibility. They are an attempt to increase recycling rates and address
the problem of littering by giving an incentive to the consumer to take back the
container. A one-way container tax is complementary to producer responsibility,

incentivising producers to set up reuse systems. There is not yet unequivocal
evidence to support this – reuse systems depend on short delivery distances and
repeated reuse to score environmentally over on-way packaging. Allied to this,
policies to encourage a minimum recycled content, such as that in Belgium, in which
containers that are made with more than 50% recycled material are exempted from
the one-way container tax may help to support the recyclate market.
As referred to in the introduction, the other policy to complement producer
responsibility is PBU. Producer responsibility can favour one material type over
another, which PBU cannot. PBU can adjust the marginal cost per tonne of waste
management by location, reflecting the differing costs associated with urban or rural
areas.
Other policies which support producer responsibility are policies which make the
costs of dealing with residual waste relatively high (landfill / incineration levies and
bans). In these cases, irrespective of the distribution of costs, there will be incentives
to increase recycling and to prevent waste so as to avoid the high costs of residual
waste treatment / disposal.
13.10 Effect of the Policy on Pricing of Resources / Services
There are a number of incremental costs of the producer responsibility policy:
248
� Capital equipment (for reuse);
� Storage space (for reuse);
� Information gathering and reporting;
� ‘Marketing’ of the service;
� Establishment of the institutions;
� Administration overheads; and
� Operation of the recycling/recovery (covered by fees).
The cost of the policy applied to household packaging can be borne either by the
taxpayer, supporting the work of the municipalities, or the packers/fillers/importers,
or shared between the two. If the cost is partially or totally borne by industry, then
depending on the elasticity of demand for the product and the commercial conditions,
some or all of the cost may be passed onto the end consumer. This can be
considered as another cost of production, and the producers
(packers/fillers/importers) can reduce it effectively, for example by lightweighting,
material switching or alternative logistical processes.
One report identified the so-called financing need of different systems and suggested
that for the German system, this is far greater than that in the UK, France or the
Netherlands (see Table 13-9). The costs considered, however, clearly do not account
properly for the costs born by taxpayers and companies for the collection of
packaging, but only the funds which are required to be paid under the scheme being
operated. Hence, they show the costs falling mostly upon the fillers/importers. This
highlights, however, the difference between systems in the extent to which they are
likely to lead to costs being passed onto the consumer through the price of products
and services (rather than through taxation).
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Table 13-9: Financing Sources for Recycling of Household Packaging, 2000
249
€ € per per tonne tonne sorted sorted France France Germany Germany
NL NL
UK UK
Tax payers/charities 41 0 53 -10
Fillers/importers 40 315 0 0
Packaging chain 0 0 0.08 38
Source: Taylor Nelson Sofres (2000) Cost-Efficiency Of Packaging Recovery Systems- the Case Of
France, Germany, The Netherlands And The United Kingdom, Report for the European Commission,
February 2000.
One of the features of producer responsibility systems is that other things being
equal, the greater the proportion of costs which are placed upon producers, the closer
the system is likely to come to one where pricing delivers efficient outcomes. This is
especially true where a) the requirement to fund a more-or-less universal recycling
service exists (or, what amounts to an equivalent requirement, the target recycling
rate is high), and b) PBU systems are in place. In these cases, households are faced
with the costs of the recycling services through their purchases, and are then
effectively incentivised to use the ‘already paid for’ recycling service in preference to
the residual waste bin through the PBU system.
13.11 Evasion and Enforcement
In Germany, the revised packaging ordinance (1998) introduced responsibility at the
level of individual organisations. Retailers and other members can choose whether
they take back packing waste themselves (or supported by waste management
companies) or join a comparable system to the DSD, or the DSD itself.
The Green Dot image is intended to denote products whose producers are a part of
the recycling system to reduce free-riders. However, as separation of products is
done by householders, non-Green Dot branded items can find their way into this
recycling stream.
In Japan there is no equivalent to the Green Dot and the only defence against free
riders is that the Japanese Containers and Packaging Recycling Association publish
the names of producers that have performed their obligation on its website.
The UK has fines for non-compliance (e.g. £10,000 for avoiding packaging costs of
£3,500) 263 , and the clear cut administration by a single organisation (Environment
Agency in England and Wales) also helps enforcement.
13.12 Lessons Learned
If the policy is aimed towards household packaging, as for example in Germany, then
the overall cost of recycling is higher, whereas if industry can choose the source of
263 Article in PackagingNews.co.uk, 26 September 2008,
http://www.packagingnews.co.uk/news/849282/Renoir-Shoes-fined-breaching-pack-wasteregulations/
International Review of Waste Policy: Annexes

ecycling to meet its targets (such as in the UK) then the cheapest sources will be
addressed first. As recycling targets are increased then the cheaper – commercial
and industrial sectors – will have to be supplemented by household recycling, and the
higher cost of collection will increase the overall cost (which will then be passed onto
the consumer).
One report that examined the cost effectiveness of packaging recycling concluded
that amongst France, Germany, the Netherlands and the UK, Germany accrued the
greatest environmental benefits and recycling rates but at a higher cost per unit. 264
This is likely to be inevitable as the recycling performance improves as this
necessarily implies having to collect packaging from higher cost sources. It does not
necessarily imply that such collections should not be undertaken.
Indeed, the above analysis suggests that, not only in terms of principles, but also,
potentially in respect of performance, schemes which require producers to fund 100%
of the costs of collection of household packaging, and which require services to be
provided to all householders, are likely to deliver highest performance. Without strong
coverage of households, rate of recycling far in excess of 60% or so are likely to be
more difficult to achieve. The top 3 performing countries – Austria, Germany and
Belgium – also all make widespread use of PBU schemes at the household level.
Another message is that recycling of packaging does, where logistics are efficient,
deliver environmental benefits. These have been well documented in respect of GHG
emissions, though our analysis suggests they apply equally in terms of non-GHG air
pollutants (see Annex 63.0).
Key recommendations from the Packflow 2008 report for the UK were as follows: 265
i) Non Non-compliance Non compliance penalties penalties. penalties
The packaging regulations should be amended at the
earliest opportunity to introduce a mechanism for dealing with non-compliance by
imposing non-criminal tonnage-related financial penalty charges on compliance
schemes and producers that fail to meet their obligations. The revenue from these
charges should be used to enhance UK packaging recycling and recovery.
ii) Targets Targets. Targets . Business Targets for the years 2006 to 2008 should be calculated from
the estimates in the likely growth of obligated tonnage. In addition the Government
should adopt a process, ideally not requiring continual amendment of regulations, to
set 5-year rolling targets extending beyond 2008 and allowing targets to be managed
through regular annual review.
iii) Packaging Packaging obligation obligation and and recovery recovery data data. data There is a need for more accurate and
timely data and it is essential if sound target setting and review is to be
accomplished.
264 Taylor Nelson Sofres, 2000 Cost-Efficiency Of Packaging Recovery Systems- the Case Of France,
Germany, The Netherlands And The United Kingdom, Report for the European Commission, Feb 2000.
265 Adapted from the Packflow 2008 report,
http://www.valpak.co.uk/docs/packaging/packflow_2008_summary_report_recommendations.pdf
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iv) Operational Operational Operational Plans Plans & & & Business Business Plans Plans. Plans Operational Plans and Business Plans
prepared by compliance schemes and accredited reprocessors should be subject to
much closer scrutiny, and should demonstrate the extent to which they are directly
linked to the expansion of packaging recovery from local authority collections and
other sources.
v) Consistency Consistency in in interpretation
interpretation. interpretation There needs to be improved consistency in the ways
in which agency guidance and protocols are applied and interpreted by reprocessors.
vi) Recycling Recycling Credits Credits. Credits Steps should be taken to improve local authority packaging
recycling, expand municipal waste recycling and the recovery of ‘away from home’
packaging by encouraging third parties to provide high-performing enhanced recycling
facilities through the wider payment of recycling credits.
vii) PRN/PERN PRN/PERN PRN/PERN fraud fraud The positive activities undertaken by the enforcement agencies
to combat and eliminate PRN fraud should be continued and, where possible,
strengthened to counter temptations to engage in fraudulent transactions as targets
and prices rise and recycling markets tighten.
In Italy, there was a debate around whether the producer responsibility organisation
should cover only the extra cost (over and above the existing services) or the full cost
of separate collection of packaging waste. 266 This question of interpretation has a
profound impact on the level of financial support to the municipalities and therefore
the effectiveness of the scheme. Clearly a lesson to learn is for legislation/regulations
to be specific, such that the producer responsibility organisation gives the amount of
financial help that the government desires.
13.13 Prerequisites for Introduction
The introduction of producer responsibility legislation requires the following policy
details to be determined:
251
� Decision on type: dual system (collection of packaging alongside municipal
collection e.g. DSD); recycling/recovery support (e.g. UK model); tax based
systems, etc.. This decision on the nature of scheme is likely to be linked to
questions regarding the distribution of costs to be visited upon the obligated
producers;
� Single or multiple compliance organisations. This will be a balance between
economies of scale (e.g. purchasing power) and risks of monopoly
inefficiencies;
� Proportion of the impact of the overall obligation to be visited upon each actor
in the supply chain (e.g. producer, filler, importer etc);
� Decisions concerning recycling rates / service obligations;
� Methodology for calculating fees. There has been surprisingly little innovation
in this regard, with costs being the principle consideration. It could be argued
266 Personal communication with Enzo Favoino, Scuola Agraria del Parco di Monza, June 2009.
International Review of Waste Policy: Annexes

252
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that these costs ought to incorporate some measure related to the
environmental consequences associated with the use of different materials,
and to reflect reprocessing destinations; 267
� Method for dealing with free riders;
� Means to incentivise / regulate for / establish targets for packaging waste
prevention; and
� Whether or not there is to be a de minimis threshold for producers taking on
an obligation.
267 Current discussions in the UK include the question as to whether or not to introduce differentiation
in the PRN price according to whether e.g. glass is recycled through closed loop or open loop systems.
This reflects the overwhelming weight of evidence which suggests that the environmental benefits of
the former far exceed those of the latter (see, for example, Enviros (2003) Glass Recycling – Life Cycle
Carbon Dioxide Emissions, internal report for the British Glass Public Affairs Committee).

14.0 Producer Responsibility, Packaging -
Germany
14.1 Outline of Policy
The first Packaging Ordinance, 1990, introduced a new mechanism – the take-back
obligation in the packaging chain and in specific cases an obligatory deposit. It was
not intended to realise this take-back obligation in the sales outlets themselves since
this approach is costly, and hence, unpopular with retailers. Instead it was agreed
upon in advance to install a “dual waste management system” for packaging waste
parallel to the rest of municipal waste management system (the Duales System
Deutschland GmbH - DSD). Participation in this system exempts the retailers from the
take-back obligation as long as the system fulfils specific conditions (countrywide
operation, kerbside collection, meeting recycling targets).
The German Packaging Ordinance requires that no later than 31 December 2008, the
annual share of all packaging waste being recovered shall be at least 65 percent by
weight and the share being recycled (stoffliche Verwertung) shall be at least 55
percent by weight. The recycling targets for the different materials contained in all
packaging shall be 15 percent by weight for wood, 22.5 for plastics, counting
exclusively material that is recycled back into plastics (either bottle to bottle or into
other materials such as wood substitute for furniture), 50 for metals and 60 for glass,
paper and board (Art. 1 para 3 Packaging Ordinance).
For the recycling (stoffliche Verwertung) of sales packaging arising at private
households the German Packaging Ordinance sets targets for manufacturers and
distributors participating in a dual system and these are shown in Table 14-1 (see Art.
6 para 3 and Annex I Packaging Ordinance).
Table 14-1: Recycling Targets for Sales Packaging According to German Packaging
Ordinance
253
Materi Material Materi Materi al
International Review of Waste Policy: Annexes
Packaging Packaging in in percent percent by by weight weight to to be be recycled recycled
recycled
on on average average per per year
year
Glass 75%
Tinplate 70%
Aluminium 60%
Paper, cardboard 70%
Composites 60%
Formerly the Packaging Ordinance had no individual responsibility mechanisms
forcing an individual retailer, producer or filler to meet their obligations. It was
sufficient that they offered the take-back to customers even if the take-back offer was
just theoretical as far as its practical use was concerned. The enforcement
mechanism was a collective one that inevitably produced free riders.

The revision of the Packaging Ordinance in 1998 introduced responsibility at the level
of individual organisations. Retailers and other members could choose whether they
would take back packaging waste themselves (or supported by waste management
companies), or join a comparable system to the DSD (a dual system), or the DSD
itself, as before. The principle change was that they now had to provide proof of
compliance with the quantitative demands of the Packaging Ordinance through the
measures they have taken (where they do not join a system).
The Green Dot is an internationally registered trade mark. In its early years, it was
used as a PR-Symbol to make the DSD-system popular for separate collection. It
simply shows that the producer or distributor of the packaging has paid licence fees
to DSD (or another Green Dot system). It is not a ‘recycling guarantee’ and does not
imply anything about the specific qualities of the packaging itself. The Green Dot
provides a check as to whether license fees for the packaging have been paid. Being
a registered trade mark, any use of the Green Dot constitutes a legal relation between
the user and the organisation holding the property rights of the trade mark. In any
case of misuse, a claim in court has a sound legal basis. Therefore the trade mark
character of the Green Dot is one precondition for managing the free rider problem.
14.2 Where Has the Policy Been Applied and Why?
In the late Eighties and early Nineties, the debate concerning the so-called “waste
emergency” raged all over Germany. At the time, authorities, the economy, the media
and the public feared that in the near future, it would be extremely difficult to find
sufficient disposal outlets in many regions (especially in regions with a high density of
population and in those with a intense concern for environmental issues). As a result,
the government was very much aware of the need to find solutions which could
address the emergency. Against this background, the Federal Government decided to
introduce the Packaging Ordinance, with the implementation of the DSD to foster
waste prevention and recycling.
14.3 Key Organisations Involved in Implementation and
Management
The Packaging Ordinance gives producers and retailers and obligation to take-back
their packaging material unless they join the DSD or a comparable system. If they
choose not to be part of such a system, they have to manage the recycling system
themselves. Otherwise, the organisations managing the take-back-system, such as
the DSD, take over the product responsibility and along with it the management of the
material.
Besides DSD, the dual systems operating in Germany are shown in Table 14-2
(according to their share in contract and licences of dual systems).
The DSD is the operating company responsible for the widespread separate collection
system in Germany. Companies who printed the Green dot on their products have to
pay a licence fee to DSD. However, collection, transport and sorting of packaging
waste are not accomplished by the DSD itself. The DSD commissions other waste
management enterprises through tendering processes.
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Table 14-2: Operators of Dual Systems in Germany 2009
255
Company Company Market Market share share for for glas glass glas
International Review of Waste Policy: Annexes
Market Market share share share for for
for
lightweight
lightweight
packaging packaging (LWP)
(LWP)
Market Market share share share for for
for
paper paper paper and and
and
cardboard cardboard
cardboard
DSD GmbH 55.83% 57.73% 71.6%
ISD Interseroh GmbH 16.37% 11.17% 5.3%
Landbell AG 3.84% 2.87% 4.0%
Eko-Punkt GmbH 18.11% 21.37% 16.1%
VfW Repak DS 1 0.00% 0.00% 0.0%
BellandDual 2.87% 3.87% 2.9.%
Redual 2.71% 2.87% 0.0%
Zentek DSZ 0.27% 0.12% 0.1%
Veolia Dual 1 0.00% 0.00% 0.0%
1 = started to operate 2009
Source: Data from the Clearing house for the forth quarter (Oct. - Dec.) 2008. 268
The DSD is forced by the Packaging Ordinance to hand over detailed statistics on the
amount of packaging, and the amount recycled, on an annual basis to the ministries
for environment of the German Länder. Furthermore the DSD publishes, voluntarily,
the summary statistics for the whole of Germany. To do this, DSD collects the data
from the licensed partners of DSD (recycling and disposal companies).
There is no obligation to show figures which address waste prevention effects
separately (i.e. reduction of waste quantities). It is, of course, a difficult task to
separate the waste prevention effects of the DSD from the effects of other influences.
14.4 Evaluation Studies Available
Prognos AG (2002) Assessment of Sustainability and the Perspectives of the DSD,
commissioned by the Duales System Deutschland AG, Düsseldorf, June 2002.
Öko-Institut (2002) Advantage of the Green Dot for the Environment, commissioned
by the Duales System Deutschland AG, Düsseldorf, March 2002.
Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen, SRU)
Environmental Report (“Umweltgutachten”) 2008, July 2008 (See:
http://www.umweltrat.de for further information).
268 EUWID from 7.01.2009, p. 7.

14.5 Environmental Benefits
14.5.1 Effects on Waste Prevention
Aside from the effects of the DSD on enhancement of recycling or energy recovery
quotas for packaging waste (see below), two different studies claim positive effects of
the DSD on waste prevention (i.e. of reducing its amount and its hazardousness).
The Prognos AG calculated an 18 % decrease between 1991 and 2000 (1.6 Million
tonnes per annum in 2000) of packaging material in Germany caused by the DSD
system. 269 The figure was created by a hypothetical calculation of the packaging
material developments with, and without, the existence of the DSD. The experts of the
Prognos AG underscored the decoupling of the amount of packaging material from
GDP growth in Germany.
The second study was carried out by the Öko-Institut commissioned by the DSD. 270
The results of the in depth work showed a 4 % absolute decrease of packaging
material in Germany over the period of time 1990 – 1999. The Öko-Institut pointed
out, that this decline followed a long period of continuous increases in packaging
material and packaging waste. Furthermore the Netherlands (without a system like
DSD) showed an increase of packaging material (15 – 20%) over the same time
period. The Öko-Institut assumed that the relative effect (against the growth in the
Netherlands) of the DSD on waste prevention could be as high as 25 %. However, the
experts of the Öko-Institut suggested deeper investigations of waste prevention and
the effects of DSD would be required to obtain a clearer picture.
The task of isolating the effects of the DSD on waste prevention is not trivial because
various other developments and influences (GDP growth, trends in the packaging
sector such as usage of PET instead of glass, light weighting of packaging) must be
taken into account.
14.5.2 Effects on Recycling
In addition to the hypothesised prevention of packaging waste, the recycling of the
material collected by the DSD has significant effects in terms of the reduction of CO2
emissions. According to the DSD, the take-back-system led to a reduction of the
equivalent of 1.5 million tons of CO2 in 2007 and 1.4 million tons of CO2 in 2008 (see
Table 14-3). 271
Furthermore the DSD System has had a marked impact on other fractions of
household waste – especially goods made of plastic and metals which are not
packaging materials. People often place these plastic goods (plastic cups, spoons
etc.) at the end of their life in the yellow bag (and not the conventional waste bin)
269 Assessment of Sustainability and the Perspectives of the DSD, Prognos AG, commissioned by the
Duales System Deutschland AG, Düsseldorf, June 2002.
270 Advantage of the Green Dot for the Environment, Öko-Institut, commissioned by the Duales System
Deutschland AG, Düsseldorf, March 2002.
271 DSD Press Release “Recycling rate on a record level”, from 1.9.2008.
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provided by the DSD. Through the DSD system, those materials are also becoming
input streams for recycling plants.
Table 14-3: DSD Key Figures for 2007 and 2008
257
Characteristic Characteristic
Effect Effect 2007 Effect Effect 2008
2008
Licensed quantity of sales packaging
Sales packaging recovered
Primary energy saved thanks to recycling of
sales packaging
Greenhouse Gas Emissions Avoided
(expressed in CO2 equivalents)
Source: DSD www.gruener-punkt.de.
14.6 Implementation Costs
International Review of Waste Policy: Annexes
approx. 2.93 million
tonnes
approx. 3.32 million
tonnes
approx. 2.6 million
tonnes
68.5 billion megajoules 59 5 billion megajoules
1.5 million tonnes CO2
1.4 million tonnes CO2
Regarding the implementation costs of the DSD GmbH in the first years (from 1993
until 1997) the costs for the system were almost 3 Billion German Mark (about 1,5
Billion Euro) and rose up to 4.2 Billion German Mark (about 2.1 Billion Euro) in 1997
at the peak of system costs (see Figure 14-1).
Figure 14-1: Costs of Dual System and Amount of Packaging Waste Recovered (1993
- 2000)
Amount of Packaging material
recovered in thousand tonnes
Source: DSD AG 2002
Note: 1 DM = roughly 0.50 Euro Cent.
System costs of the DSD in
Million German Mark (DM).

The study by Prognos mentions that the DSD system would imply a financial burden
for the economy and the consumers relative to an alternative system based on
incineration and landfilling. 272
The Öko-Institut concluded that the criticism levelled against the DSD on financial
grounds did not take into account the significant external benefits associated with the
system relative to alternative forms of waste treatment.
14.7 Effects on Technical Change / Innovation
In the first years of the implementation of DSD, the lack of recycling capacity in
Germany led to abuses such as illegal export of DSD-Waste to Asia. Due to the legal
take-back and recycling duties as well as the duty to pay for the use of Green Dot
system, money was raised to be spent on the development of recycling technologies
and recycling capacities. Due to the generally low value of post-consumer packaging
plastics, without the DSD funding system, the above mentioned investments would
have not taken place.
Technical changes and innovation raised by the introduction of a Dual System have
taken place on all levels of the system. In the first half of the 90’s the packaging
manufacturers reduced the specific weight of packaging and removed superfluous
packaging. Throughout the nineties the sorting-technology for light weight packaging
(LWP) improved significantly: from mainly manual sorting to semi-automatic sorting. In
a next step, fully automatic sorting technologies with integrated refinement were
introduced. Another innovation was NIR (near infrared) sorters, facilitating an
increase in homogeneous plastic fractions. Concerning the reprocessing of recycled
material, the recycling of used PET-bottles to new PET-bottles was possible due to the
development of the “bottle-to-bottle”-technology.
The Prognos AG published a report in the year 2002 that suggested the DSD had
created 17,000 jobs in total (this was a net figure - job cuts in some specific sectors
of the economy were factored in). 273 Furthermore the study underlined the important
contribution of the DSD in promoting technical innovations and investments.
14.8 Social and Distributional Consequences
In the first years of the DSD, arguments against the system were very often of a social
nature. It was argued that people would not accept that they should separate their
household waste, or that the separation of waste was not acceptable to those who
would have to do this. Many politicians have claimed that the end of the DSD system
and the “yellow bag” was imminent, stretching back to 1990. Nevertheless the
majority of the population has learned to deal with the “yellow bag” and accepted the
Green Dot system.
272 See Fn. 269.
273 Prognos AG (2002) Nachhaltigkeitsbewertung und Perspektiven des Dualen Systems in
Deutschland, Report for DSD, 2002.
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Following a poll in 2004, it became clear that the percentage of population who think
“the Green Dot is a good thing” had risen from 27 % in 1992 to 67 % in 2004 (and
has risen to 89% in 2006). 274 The percentage of the population who think negatively
about the Green Dot system fell from 52 % in 1992 to 20 % in 2004 (and has fallen
to 8% in 2006). 275 Therefore, many years after implementation of the DSD, such
arguments have become irrelevant for the majority of the population.
Nevertheless, it should be mentioned that social implications could often be found in
housing areas dominated by large multi-occupancy residential buildings. In these
areas the single household is not always rewarded for its contribution to waste
prevention and recycling because the other households in the same building might
not be so concerned about waste separation.
Regarding the distributional consequences, at the beginning arguments against the
DSD were focused around issues of “monopoly” and “inefficiency”. But the debate
was mostly polemical and triggered by self-interest on the part of the different parties.
There were some scandals in the early years of the system (recycling of green dot
packaging waste in inappropriate plants overseas) and these contributed to damage
the image of the DSD in the media.
Irrespective of this opposition, the large retailers increasingly demanded the use of
the Green Dot by their suppliers. Suppliers refusing to do so had to risk losing their
customers. The retailers had a strong interest in the build-up, and function of, the
DSD because otherwise they had to install the take-back of packaging in their stores,
which they wanted to avoid on the basis of cost. The collective pressure mechanism
of the packaging Ordinance worked well in the case of the large retailers (a small
number of companies have a market share of more than 80 % in the food sector, and
the market concentration is even greater in the non-food sector).
The food sector is the most important for business to consumer packaging waste. In
Germany consumers still have quite a strong influence over food retailers.
Despite the fact that large companies in this sector are well known and very
prominent in the market, the market concentration is quite low and large companies
are in competition in the food sector. Therefore it is very difficult for the companies to
transfer the cost of the Green Dot system to the consumers. On the other hand this
means an incentive for the suppliers to act in the spirit of producer responsibility by
minimizing packaging waste.
Despite this the DSD claims a 36 % reduction of its overall costs (and so prices)
between 1998 and 2006 following the implementation of innovative technologies
and better contracts with the different recycling partners resulted. 276
274 See: forsa, Gesellschaft für Sozialforschung und statistische Analysen mbH, Verbraucherbefragung
zum Thema Umweltbewusstsein, 25. April 2006 (Doc. P6570/16336 Sr/Sc).
275 See “Study Environment 2004“, Institut für Demoskopie Allensbach, 2004; forsa (see Fn 274).
276 www.gruener-punkt.de ‘What are the costs of the Green Dot?’
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14.9 Complementary Policies
The Packaging Ordinance defining producer responsibilities for producers of
Packaging complements the general regulation on waste - the Closed Substances and
Recycling Act (Kreislaufwirtschafts- und Abfallgesetz). The producer responsibility
regulated in Articles 22 sqq of the Closed Substances and Recycling Act commits
producers and distributors to design their products in a way that prevents waste in
the manufacture and usage of a product.
The Packaging Ordinance should be implemented as an integrated part of other
policies for household waste, especially the Landfill Ordinance (Deponie-Verordnung -
DeponieV) and the pay-by-use policy.
14.10 Effect of the Policy on Pricing of Resources / Services
The policy has shifted the society towards a better allocation of resources. Without
doubt, the system incurs significant costs. However, it should be taken into account
that plastic recycling is the main task of the Duales System and plastic recycling is,
under normal circumstances, less attractive from an economic point of view
compared to metal, or paper recycling. The price impact per product sold is small,
reflecting the impact of packaging on product costs.
14.11 Evasion and Enforcement
In recent years the free rider problem has become a major issue due to a lack of
enforcement. In 2007 the Duales System Deutschland GmbH recycled far more
packaging than had been registered with the company. The total recycling rate was
113 per cent (see Figure 14-2).
Figure 14-2: Recycling Rates
Source: DSD 2008
To prevent free-riders another amendment to the packaging ordinance has been
passed and will become effective on January 1 st 2009. Under this amendment all
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packaging has to be licensed by the DSD or an equivalent system. Also, retailers have
to issue a statement highlighting the level of completeness of licensing for the
packaging they have distributed. Exemptions can be approved by the public agency
responsible for the take-back-system. It is expected that this will lead to a
strengthening of the position of the DSD as in future, nearly all packaging waste is
expected to be covered by the dual system. For companies that choose selfmanagement
of packaging waste disposal, there is no free rider protection.
14.12 Lessons Learned
Despite the sometimes negative image presented by commentators, the DSD is
working quite well in terms of resource efficiency. The positive effects are mainly in
the enhanced recycling rates. Positive effects on waste prevention must be proven by
further in-depth analysis on this issue.
The system has been criticised, not without some justification, for being expensive.
Not all of this criticism has been well-informed, but it is almost certainly true to say
that in early days, contracts which were entered into by the DSD were not necessarily
competitively priced. Matters appear to have improved somewhat over time, but the
costs remain high. In one OECD document, Ingham notes: 277
261
Where recycling is economically viable, as it is with aluminium and steel
materials because of the high value of raw materials and the relatively low
costs of processing, and where low processing costs and efficient markets
make recycling feasible, government mandates may push industries to reduce
packaging waste without enormous economic disruptions. However, when
recycling faces higher technical and economic barriers, as it does with
plastics, government mandates may create enormous disruptions. The costs
of DSD rose as a consequence of including plastic packaging in the scheme.
Thus, despite the fact that the DSD system does take a large amount of
plastic material out of the waste stream, it is costly.
He concludes:
One weakness of the German system is that its goals are not based on a costbenefit
analysis and, as such the level is not chosen on the basis of an
economic rationale. (The dominant hierarchy of waste management gives
recycling a priority, and so to some extent is pursued for its own sake.) Whilst
Germany achieves high recovery rates, the DSD system shows that this is
expensive, and substantially exceeds the costs, including environmental costs,
of alternative waste disposal methods. The targets set by the German
government imposed have perhaps been too ambitious. High goals may be
reasonable for materials like aluminium and steel where recycling is technically
and economically practical, but such goals may not be practical for materials
like plastics.
277 Alan Ingham (2005) Improving Markets for Waste Plastics, in Improving Recycling Markets,
ENV/EPOC/WGWPR(2005)3/FINAL. Paris: OECD.
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This highlights the fact that there might be limits to what such schemes might seek to
achieve. In particular, some schemes, including Flanders, have tended to limit their
ambition in respect of collecting mixed non-bottle plastics, mainly on grounds of the
cost related to the environmental benefits, without otherwise limiting their ambition in
terms of packaging waste recycling (see Section 15.5.1.2 of these Annexes).
14.13 Prerequisites for Introduction
A waste management hierarchy is established in Art. 4 of the German Act for
Promoting Closed Substance Cycle Waste Management and Ensuring Environmentally
Compatible Waste Disposal (Kreislaufwirtschafts- and Abfallgesetz – KrW/AbfG) and
also in the European Waste Framework Directive (75/442/EEC) in Art. 3. To comply
with these clauses, waste generation must, firstly be prevented by means of reducing
its amount and its hazardousness. Secondly, waste must be subjected to recycling or
for energy recovery (i.e. using waste as a substitute fuel). Only in a third step, when
minimisation or recovery is not possible, waste should be disposed of.
Besides the waste hierarchy a legislative act is necessary that regulates the producer
responsibility for a product group (e.g. like the Packaging ordinance does for
packaging). Such a legislative act makes the duty concrete and binding. In this
context it is important to notice that the producers are only released from their
producer responsibility by the “Green Dot”, because it runs beside the normal waste
collection, as long as they run the separate collection system.
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15.0 Producer Responsibility – Flanders,
Belgium
15.1 Outline of Policy
Extended Producer Responsibility (EPR) aims at creating an incentive for producers of
new products to take into account the treatment of these products when they become
post-consumer waste. By redirecting or internalising the costs for the treatment of the
waste to the producer of the product, the producer will have a clear financial benefit
for designing products that create the least possible waste. As such, it encourages
product design to be as reusable and recyclable as possible. This is also necessary
since producers are required to meet designated recycling targets. While the policy of
EPR was designed as an incentive for waste prevention and ‘design for recyclability’, it
has often resulted in being simply an instrument that helps finance recycling.
EPR is mainly realised through the instrument of the take-back-obligation combined
with recycling targets. In some cases the producers of packaging may collect and
recycle or treat it themselves, and sometimes they finance third parties or
municipalities to do this. Some EPR is limited to a statistical exercise, proving to the
competent authority that waste has been collected and recycled. Communication and
awareness campaigns to promote recycling are frequently financed by the industry
bodies responsible for managing the policy.
15.2 Where Has the Policy Been Applied and Why?
In Belgium the policy of EPR through take-back obligations was a favourite economic
instrument in 1999-2004 when the green party was in the Flemish government (after
2004, some smaller EPR schemes, such as those on agricultural foil and wood waste
were withdrawn). EPR has been implemented for a set of waste streams which go
beyond the EPR imposed by the European recycling directives (packaging, batteries,
WEEE, ELV). Two systems of EPR have been developed:
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� Take-back-obligations for packaging waste organised in a concerted way in
cooperation with the three Belgian regions, implementing the packaging
directive using the instrument of a Belgian cooperation protocol; and
� Acceptance duties organised on a regional level using regional legislation and
instruments, but also in consultation with the other regions. These duties are
imposed for the waste streams described below. Usually an EPR is
implemented through an MBO (milieubeleidsovereenkomst), an environmental
policy agreement between the Flemish government and one or more sector
federations, and brought into practice through an industry body. Table 15-1
shows the industry bodies subject to EPR and the legal starting dates of the
obligations.
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Table 15-1: Flemish EPR systems
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Waste Waste Waste type type
Since… Since…
Since…
Printed materials:
� Publicity and unsolicited mail (interventiefonds oud papier)
� Periodical press (diverse federations)
1998
Waste batteries (BEBAT) 1995
Waste accumulators (RECYBAT) 1998
Old and expired medication (diverse federations) 1985
End of life vehicles (FEBELAUTO) 1999
Waste tyres (RECYTYRE) 1999
Waste from electrical and electronic equipment (RECUPEL)
Phased: 1999, 2001,
2003, 2004, 2005
Flash torches (BEBAT) 2004
Used oil (VALORLUB) 2004
Animal and vegetable fats and oils (VALORFRIT) 2003
Waste photochemicals (FOTINI) 2004
The implementation of EPR for the waste streams illustrated in Table 15-1 is realised
through MBOs (environmental policy agreements with producers) and the
establishment of the industry bodies. Often three rather similar MBOs are established
within the three Belgian regions. The activities of these bodies vary from data
collection to assessing quantities of materials collected and recycled against targets;
they also run awareness raising campaigns to augment separate collection and set
up specific collection infrastructure.
Individual compliance with the EPR-system is legally possible without contribution to
an industry body. However, in practice the costs inherent in a producer individually
attempting to meet the EPR requirements prevent such a course of action for most
products except for very specific WEEE items.
15.3 Key Organisations Involved in Implementation and
Management
The following organisations are involved in Belgium’s producer responsibility:
� Competent authorities in the three regions: OVAM (public Flemish waste
agency), BIM (Brussels institute for environment), DGRNE-OWD (Wallonian
directorate general for natural resources and environment- Wallonian office for
waste).
� The interregional office on packaging waste.
� The regional Parliaments as recipients of yearly reporting on the compliance
with the collection and recycling targets.

265
� The industrial federations that effect an environmental policy agreement with
the governments.
� The industry bodies specified in the frame of the policy agreements.
� The individual producers of goods that have to join these notified bodies.
� The individual producers of waste or the waste collectors that report to the
notified bodies.
� The reuse centres and the civic amenity sites that are active in the collection
of EPR-wastes – the costs of which are to be remunerated.
In the following paragraphs the relevant organisations and their key tasks are
explained in more detail for every Flemish EPR system.
15.3.1 Packaging Waste
In Belgium the European Packaging Directive has been translated as a take-back
obligation, with producers being responsible for meeting the targets. It is up to each
producer to decide how to meet the targets, whether that is via their own collection,
sorting and recycling systems or via an accredited organisation.
The implementation of the take-back obligation is realised through the establishment
of an interregional secretariat (IVCIE), uniting the Flemish, Walloon and Brussels
Regions of Belgium, and national industry bodies FOST-Plus and VAL-I-PAC. FOST-Plus
organises the collection of household waste in collaboration with the intermunicipal
utility companies that organise selective collection rounds for paper, and for the
combined stream of plastic packaging, metal packaging and beverage cartons. VAL-I-
PAC organises mainly the data gathering on industrial packaging waste and creates
incentives for companies to sort this kind of waste. The split between household and
industrial waste is roughly 50/50. 278 Companies are not obliged to join one or both
organisations, but can instead opt to fulfil their take-back obligations individually. In
this case they have to report directly to the IVCIE.
Parties responsible for household packaging that join FOST-Plus sign an open ended
agreement (which can be terminated each year) with FOST-Plus. They make a yearly
declaration of the weight, type and quantity of packaging they put on the Belgian
market. They then pay a fee (using the Green Dot tariff) depending on the material
and the weight of that material placed onto the market. Simpler declaration systems
are in place for smaller companies. 279
Intermunicipalities (waste management services that cover a number of
municipalities) are responsible for dealing with waste in their area and sign a
standard five year agreement with FOST-Plus. They can either use their own collection
infrastructure or contract it out to a waste management company (through a tender
process managed by the intermunicipality and supervised by FOST-Plus). There is
278 IVC activiteitenverslag (2007) Annual report IVCIE, Dutch.
279 FOST-Plus (2007) Annual report, English version available.
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oughly a 50/50 split between those collecting themselves and those contracting it
out. Intermunicipalities that choose not to collect the waste themselves consult the
market using a standardised tender book, written by FOST-Plus. This ensures that the
requirements and expectations of service delivery are equally met across Belgium.
FOST-Plus and the intermunicipality make a joint decision as to which waste
management company to use. 279
Essential in the cooperation between FOST-Plus and the intermunicipal utility
organisations is the idea that no costs for the collection of packaging waste should be
borne by the public purse. Even if public infrastructure is used for the collection of
the waste, the costs have to be paid by the producers of the packaging material
through FOST-Plus. In order to guarantee this principle, the IVCIE guards the
application of realistic costs for the use of this infrastructure, e.g. for the use of civic
amenity sites or public waste collection rounds.
In turn, part of the agreement FOST-Plus provides the intermunicipalities with
specifications for collection and sorting, including quality criteria. It also provides an
administrative monitoring system (ProFost) which allows individual trucks to be
monitored and the location of waste to be known at all times. 279
The recyclers used are selected by FOST-Plus, again using a standardised tender
book with detailed specifications. The selection of recyclers is supervised by joint
committee of the intermunicipalities, IVCIE and FOST-Plus. The price indexation is
linked to the evolution of raw materials. The recycling process is verified by
independent auditors. 279
Parties responsible for industrial packaging that join Val-I-Pac sign an open ended
agreement (which can be terminated each year) with Val-I-Pac. They make a yearly
declaration of the weight, type and quantity of packaging they put on the Belgian
market. They then pay a fee in function of the total weight of the packaging, the
material it is made of, and the possibility to recycle it at the end of use
(www.valipac.be).
15.3.2 Printed Materials
The implementation of the take-back obligation for printed materials is realised
through two different MBOs: one for publicity and unsolicited mail 280 , and one for
dealing with periodicals. 281 .
The MBO on publicity and unsolicited mail was signed by the federations BDMV
(Belgian direct marketing association, FEBELGRA (federation of the Belgian printing
and communication industry), FEDIS (Belgian Federation of distributors), VEGRAB
(federation of printing companies), NAVETEX (national association of textile retailers)
and VDV (association of food retailers). The members of these federations all pay a
contribution of €0.005 per kg paper they put on the market. These contributions are
280 B.S. 10/02/99 Milieubeleidsovereenkomst papier met BDMV, FEBELGRA, FEDIS, NAVETEX, VDV en
VEGRAB.
281 B.S. 24/04/98 Milieubeleidsovereenkomst Papier met BVDU, NFIW, UUP en VUKPP.
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used to reimburse (inter)municipalities for their waste paper collection through CA
sites and door-to-door collection.
The MBO for the periodical press was signed by BVDU (Belgian association of
publishers), NFIW (national association of informative magazines), UUPP
(International federation of periodical press) and VUKPP (federation of catholic
periodical press). The members of these federations do not have to pay a contribution
for the paper they put on the market, but they have to reserve a certain amount of
advertisement space for the Flemish government. The aim is that the space has a
total value of more than €3 million per year. By way of example, the members of NFIW
have to reserve 4 pages or 8 half pages for the Flemish government. The government
uses this space mainly for advertisements on prevention or recycling, and consider
this as a payment ‘in kind’. There is a discussion on the environmental effect of this
measure and the stimulus it creates, or does not create, for DFE and waste
prevention.
15.3.3 Waste Batteries
In 1993, a federal Belgian tax on batteries was agreed by the Belgian Government as
part of their ecotax legislation. Before this was implemented, a voluntary agreement
with the industry resulted in the ecotax law for batteries: batteries were to be
exempted from the ecotax when a voluntary collection and recycling scheme was
established. In response, the battery industry set up the non-profit organisation
BEBAT to co-ordinate the collection and recycling of batteries, and to ensure that the
target percentages were reached (collection target: 65% in 2004). The financing of
the 'collection and recycling contribution' is paid by members of the organisation (i.e.
battery producers and distributors). This contribution is passed on to the consumers
through a price increase. (€0.1239 per battery - for the connection with the Belgian
ecotax, please see Section 30.5.2.2 of the Annexes).
In 1997, a take-back obligation for waste batteries was implemented. The collection
percentage was increased to 75%; the recycling target was set to 65%.
BEBAT places collection boxes at more than 20,000 collection points (hyper- and
supermarkets and local shops, jewellers, photo shops, do-it-yourself stores, toy
stores, electrical stores, pharmacies, etc., as well as schools, public and private
institutions, and the CA sites) at no cost for the owners of the collection points.
Batteries are sorted by type: button cells; rechargeable batteries with nickelcadmium;
rechargeable batteries with nickel-metalhydride; rechargeable batteries
with lithium-ion; lead batteries; other types, especially alkaline and zinc-carbon
batteries (being the most common).
The batteries collected by BEBAT must be recycled according to the agreements
signed with the three regions. For monitoring purposes, BEBAT is required to provide
information to the ecotax commission, the regional governments (e.g. OVAM) and the
federal government at fixed intervals. All producers of batteries in Flanders have
joined BEBAT (www.bebat.be -English version available).
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Figure 15-1: BEBAT Collection Box for Batteries to be Placed at Point of Sale
15.3.4 Waste Accumulators
The implementation of the take-back obligation for waste accumulators is realised
through the MBO on waste accumulators (2003) and the establishment of RECYBAT.
Like other industry bodies, RECYBAT should co-ordinate the collection and recycling of
the waste accumulators, finance the system, monitor and report collection and
recycling targets. In practice, the activities of RECYBAT are limited to monitoring and
reporting. Due to the high residual value of waste accumulators (as a result of the
high price of lead), no supplementary collection system needs to be put in place. In
2005, almost 95% of waste accumulators were collected spontaneously, driven by
the high value of the material. The implementation of the MBO on waste
accumulators did not have any affect on the collection percentage. 282
15.3.5 Old and Expired Medication
Between 1985 and 1994, the collection of old and expired medication was organised
and coordinated by OVAM. In 1994, this collection was taken over by the
pharmaceutical sector. In 1998, the first MBO on old and expired medication was
implemented, and a new MBO has since been signed in 2008 which will shortly be
implemented. The following federations are involved: ABP (Belgian pharmaceutical
association), OPHACO (Belgian association of pharmaceutical cooperatives), NVGV
(national organisation of pharmaceutical wholesalers), AVGI (Belgian pharmaceutical
industry association) and FEBELGEN (generic pharmaceutical organisation).
282 OVAM (2007) Evaluatie van aanvaardingsplichten (Evaluation of take-back obligations).
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Consumers can bring old and expired medication to the local chemist. The following
expired or unused medication can be handed in:
269
� unused tablets and capsules;
� remains of creams and ointments in tubes;
� syrups and liquid medication in their containers;
� remains of spray/aerosol medication; and
� x-ray photographic plates.
The following products are not accepted:
� empty glass bottles (glass collector);
� empty cardboard boxes and information leaflets (paper and cardboard waste);
� remains of toothpaste, shampoo, bath foam, soap, cosmetics and care
products (household garbage or small hazardous household waste);
� pesticides and insecticides (small hazardous waste);
� used hypodermic needles (collected in a rigid container for small hazardous
waste);
� blister plasters (household garbage); and
� band aids, bandages, cotton wool, gauzes, diapers, incontinence material, test
strips, diet- and baby food (household garbage).
The chemist collects the expired and unused medication in special cardboard boxes,
which are picked up by the wholesalers when delivering new medication. If the
collection of these boxes were to be free of charge, then they would not be completely
filled or they would contain products that are not subject to the MBO. If the charge on
the boxes was too high, then the boxes would tend to get overfilled, making them less
stackable at the wholesalers and leading to a potential safety risk. 283 Thus the
chemist pays the wholesaler €1 per box for collection, reflecting a balance between
high and low costs.
Unlike other waste streams with take-back obligation, where a large proportion of the
materials are recycled or recovered, the old and expired medication is incinerated. In
2007, 3 Belgian incineration plants were responsible for the disposal of this waste
medication: Siomab (Brussels), IBW (Virginal) and Ipalle (Thumaide). 283
The costs of collecting and transporting the old and expired medication to the
incineration plants are financed by the wholesalers; the costs for incineration are
financed by the pharmaceutical industry. 284
283 OVAM (2008) Oude en vervallen geneesmiddelen – Inzamelresultaten 2007 (Old and expired
medication – Collection data 2007), Dutch.
284 Draft MBO on old and expired medication, 2008.
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The wholesalers report the number of boxes that are transported to the incineration
plants. The pharmaceutical industry (i.e. AVGI and FEBELGEN) reports the quantity
(kg) of incinerated old and expired medication and the yearly costs for incineration. 285
15.3.6 End of Life Vehicles
The implementation of the take-back obligation for end of life vehicles was realised
through the MBO on end of life vehicles (1999, revised in 2005) and the
establishment of FEBELAUTO. 286 This was set up in 1999 by car distributors and ELV
treatment companies as a non-profit organisation to ensure implementation of the
MBO by organising and monitoring the management of recovery and disposal.
Car dealerships must take back free of charge any ELV returned to them. The
dealership will provide a certificate of acceptance in exchange for the vehicle they
have received. Distributors must then accept back from the retail trade, at their own
expense, all ELVs delivered to the dealerships, and pass them on to the producer or
importer of that vehicle make. Producers and importers must, at their own expense,
regularly collect all ELVs taken back by distributors, and if appropriate from retailers,
and have them treated in an authorised centre within 6 months of receiving them.
The MBO and VLAREA stipulate a few conditions that should be met for free take back
of an ELV:
270
� The ELV contains all components indispensable for the functioning of the
vehicle;
� It does not contain any other waste;
� It has been registered in Belgium by the last owner for at least 6 months; and
� It has a registration document, a certificate of conformity, the number plate
and if appropriate, the most recent technical testing certificate.
Vehicle manufacturers must provide the following information annually:
� The quantity of vehicles by weight and type that they have put on the market in
the Flemish Region;
� The quantity of vehicles by weight and type for which a Certificate of
Destruction has been issued;
� Which treatment facility they have returned the vehicles to, and which
treatment procedures have been used; and
� The total amount of waste recovered, incinerated and sent to landfill.
Vehicle dealerships and distributors must provide OVAM with the type and weight of
ELVs taken back in the previous year.
285 Draft MBO on old and expired medication, 2008
286 B.S. 19/04/05 Milieubeleidsovereenkomst betreffende de uitvoering van de VLAREAaanvaardingsplicht
afgedankte voertuigen.
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15.3.7 Waste Tyres
The implementation of the take-back obligation for waste tyres is realised through the
MBO on waste tyres (2003) and the establishment of RECYTYRE. 287
RECYTYRE was founded by six of the world’s largest tyre producers in 2006. Waste
tyres are collected by almost 5,000 garages, tyre specialists and distributors. In some
municipalities, waste tyres are also collected at CA sites. The financing of the
collection is paid by the consumer (depending on the type and size of the tyre; e.g.
€2.4 per tyre for cars, €12.46 per tyre for lorries and buses). RECYTYRE subsequently
collects the waste tyres at the collection points (www.recytyre.be, Dutch).
The operators of collection points have to take back the waste tyres for free, even if
the consumer does not buy a new tyre. The collection points are exempt from this
obligation, when collection of waste tyres is possible in a nearby CA sites.
Like other industrial bodies, RECYTYRE is required to achieve collection and recycling
percentages, to monitor and report collection and recycling percentages, to draw up
prevention plans, amongst other functions.
15.3.8 Waste from Electrical and Electronic Equipment
Implementation of the take-back obligation for waste from electrical and electronic
equipment (WEEE) is realised through the MBO on WEEE (2001) and the
establishment of RECUPEL. 288 A revised MBO will be published shortly.
RECUPEL was founded by the industrial federations Agoria (Federation for the
technology industry) and FEE (Federation of electricity and electronics), to ensure the
collection and treatment of WEEE. Information is available at www.recupel.be (English
version available). These branch associations also founded sector associations, socalled
RECUPEL “sectors”, each one representing a group of well-defined products:
271
� BW-Rec (for large household electronics);
� Recupel AV (for audiovisual equipment / consumer electronics);
� Recupel SDA (for small domestic appliances);
� Recupel ICT (for information and communication technology);
� Recupel ET / Garden (for electronic tools and garden equipment);
� LightRec (for lighting equipment and gas-discharge lamps); and
� MeLaRec (for medical devices and laboratory equipment).
RECUPEL acts as a ‘contractor’ for these 7 RECUPEL sectors.
The MBO stipulates the following obligations:
287 B.S. 8/11/03 Milieubeleidsovereenkomst betreffende de uitvoering van de Vlareaaanvaardingsplicht
afvalbanden.
288 B.S. 1/06/01 Milieubeleidsovereenkomst betreffende de uitvoering van de VLAREAaanvaardingsplicht
van afgedankte elektrische en elektronische apparatuur.
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272
� Organisation of the separate collection of WEEE (responsibility lies with
municipalities);
� Social economy undertakings are to be included in the collection of WEEE;
� Take-back of a similar product when a new product is purchased (retailer
responsibility); and
� Realisation of the environmentally sound treatment of WEEE (producer
responsibility).
Each manufacturer or importer has to join a system for WEEE collection and
treatment. Alternatively, manufacturers or importers may establish an individual
waste management plan and have it approved by the authorities.
The collection network of RECUPEL relies on the following collection points:
� all 518 CA sites in Belgium (89 serviced directly, 444 serviced through
regional transhipment stations);
� 28 intermunicipal regional transhipment stations (‘intercommunales’);
� 17 used goods centres acting as regional transhipment stations;
� 2 re-distribution centres of retailers (for approximately 112 branches);
� approximately 2,700 retailers; and
� collection facilities such as repair companies and waste management
companies.
Requests for the collection and transport of household appliances from these
collection points can be submitted through the RECUPEL website. The minimum
amount required in order to arrange a collection is either 8 large appliances or one
box pallet (for small appliances or CRT appliances). Bulk transport is organized when
there is at least one full container or 24 box pallets. CA sites are also provided with
so-called 'RECUPEL containers’, solely intended for the collection of WEEE. The only
types of WEEE that cannot be collected at CA sites are medical devices and laboratory
equipment. A tailor-made solution has been created for the collection and recycling of
these very specific types of WEEE.
In order to safeguard the EPR principle, and to ensure that no public money is used
for the collection of any WEEE for which a take back obligation exists, the costs for
the use of public infrastructure such as CA sites has to be carefully assessed. The
Flemish ministerial decision includes a model within the framework on EPR
mechanisms on how to calculate a fair price for the use of the public infrastructure of
CA sites.
RECUPEL works together with one main logistics partner and 6 treatment partners for
WEEE in Flanders and the Walloon region, with between 2 and 4 treatment partners
per product flow group.
Producers and importers, via RECUPEL, must provide the following yearly information:
� the amount (types, number and weight) of EEE put on the market in the
Flemish Region;
� the total amount of collected WEEE (types, number and weight);
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273
� which treatment facilities they have returned the WEEE to and which treatment
procedures have been used; and
� the total amount of WEEE recovered, incinerated and sent to landfill.
Distributors of EEE must provide OVAM with information on the total amount of WEEE
(kg) collected per annum, and on the number and types of WEEE and their treatment
specifications.
15.3.9 Flash Torches
The implementation of the take-back obligation for flash torches is realised through
the MBO on flash torches (2006). 289 BEBAT, the organisation responsible for the
collection of waste batteries, also collects flash torches. A joint collection system for
waste batteries and flash torches is used (see Section 15.3.3 of these Annexes for
more information on BEBAT).
15.3.10 Used Oil
The implementation of the take-back obligation for used oil is realised through the
MBO on used oil (2008) 290 and the establishment of VALORLUB.
VALORLUB was founded in 2004 (operational since 2007) by the Belgian Petrol
Federation (BPF), the Lubricants Association Belgium (LAB), the Belgian Federation of
distributors (Fedis) and the Belgian confederation gathering the different groupings of
the Belgian automotive sector (FEDERAUTO). The goal of VALORLUB is to carry out the
take-back obligation imposed on the members of the founding federations.
Each company subject to the take-back obligation can meet its obligations individually
or can join VALORLUB. The obligations are:
� For final sellers, intermediaries, producers and importers to accept used oil
from their customers for free, without obligation to purchase;
� For producers and importers
• To have the collected oil processed at their own expense in an
institution licensed for this purpose;
• To obtain the stipulated percentages of collection;
• To obtain the percentages of recovery; and
• To inform and sensitise consumers and collectors/processors.
The VALORLUB system of collection is different for domestic oil and for commercial
oil. For used oil coming from householders, no take-back is organized at the point of
sale. The collection of domestic oil takes place through the (inter)municipalities: CA
289 B.S. 28/03/06 Milieubeleidsovereenkomst betreffende de uitvoering van de terugnameplicht voor
inzake zaklampen.
290 B.S. 29/08/08 Milieubeleidsovereenkomst betreffende de aanvaardingsplicht voor afgewerkte olie.
International Review of Waste Policy: Annexes

sites, collections organised within communities or door-to-door collections. VALORLUB
reimburses the municipalities for the costs of using the infrastructure at the CA sites,
and for the processing of this oil afterwards.
Companies that produce used oils (like garages or industry) can contact any collector
officially accredited by the government for the collection of used oils. Companies and
operators are not bound by obligations imposed by VALORLUB, they merely have to
follow the existing legislation on used oils. But VALORLUB can reimburse the
producers of used oil if the collection is done by a collector that is also accredited by
VALORLUB itself. The reimbursement depends on the market value, the quantity
(

VALORFRIT reimburses the municipalities for the costs of using the infrastructure at
the CA sites, and for the processing of this oil afterwards.
Companies that produce animal and vegetable fats and oils (like hotels, restaurants,
hospitals etc.) can contact any collector officially accredited by the government for the
collection of this material. Companies and operators are not bound by obligations
imposed by VALORFRIT, they merely have to follow the existing legislation on waste
animal and vegetable fats and oils. There is no reimbursement for the producers to
cover the collection costs.
VALORFRIT reports the percentages of collection and of useful use to OVAM.
15.4 Pre-implementation / Evaluation Studies Available
275
� Aanvaardingsplichten – Referentiedocument voor milieubeleidsovereenkomsten,
OVAM 2004, reference document for municipalities and
companies on acceptance obligations (Dutch)
� Aanvaardingsplichten in het Vlaamse Gewest, OVAM, 2008, six monthly
progress report on the implementation of EPR (Dutch)
� Evaluatie van de effectiviteit en de efficiëntie van het instrument
aanvaardingsplichten en de invulling die er nu aan gegeven wordt met het oog
op verbetering van de wetgeving, HIVA by order of OVAM, 2006, evaluation of
the effectiveness of the EPR policy and its actual implementation in view of
amelioration of the legislation. (Dutch)
15.5 Environmental Benefits
15.5.1 Packaging Waste
15.5.1.1 Environmental Benefits of Prevention
In 2007, collection yields of domestic packaging waste remained high. Around 63 kg
of packaging were collected per capita (116 kg per capita when taking the whole
waste paper segment into account). Except for a very slight decrease in arisings of
Plastiek- Metaal- en Drankverpakkingen(PMD), which is plastic packaging, metal
packaging and composed beverage packaging (tetrabrick etc), quantities collected
per material remained almost identical: 15 kg for PMD, 30 kg for glass and 70 kg for
paper-cardboard (including non-packaging). 292
292 Fost Plus (2007) Annual Report.
International Review of Waste Policy: Annexes

Figure 15-2: Trend in Collection of Household Packaging Waste in Flanders
(kg/capita/year)
Source: Annual Report 2007, FOST Plus
An analysis of the use of reusable packaging in Belgium (2008) shows that the use of
domestic reusable packaging has diminished between 2005 and 2006. The use of
industrial reusable packaging (mainly glass, wood and a few new materials) has risen
(see Figure 15-2). 293 - Figure 15-3 below shows the trend in packaging waste
generation, in comparison with the EU15.
Table 15-2: Total Quantities of Packaging in Belgium (tonnes)
276
29/09/09
Type Type
Quantity, Quantity, 2005 Quantity, Quantity, 2006
Domestic non-reusable 719,000 730,000
Domestic reusable 838,000 802,000
Industrial non-reusable 612,000 643,000
Industrial reusable 1,915,500 2,045,000
293 IVCIE (2007) Annual Report.

Figure 15-3: Belgian Packaging Waste Generation per Capita, 1997-2006
200
180
160
140
120
100
80
60
40
20
0
277
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
Source: European Environment Agency, 2009
15.5.1.2 Environmental Benefits of Recycling
In Flanders, the following collection scheme for household packaging is in place:
� Glass: voluntary deposit, sorted by colour, approximately one site per 1,000
inhabitants;
� PMD (plastic bottles and flasks, metal packaging and drink cartons): door-todoor
collection, twice a month, transparent blue bag (which enables
contaminants to be easily identified), with subsequent sorting into several
waste segments; and
� Mixed paper and cardboard (packaging and waste paper): door-to-door
collection
To complement the above, all waste streams can also be collected via CA sites.
International Review of Waste Policy: Annexes
Belgium
It was decided to collect only that which is recyclable. This ensures a homogeneous
waste stream, provides sufficient quantity of recyclables which meets high quality
standards, and ensures continuity of supply. The possibility of recycling mixed plastics
was investigated, but it was found that the benefits were insufficient to justify the
additional costs involved, i.e. it would increase overall recycling rates by 5% to 8%, but
would incur an overall additional cost of 60% to 70%.
Table 15-3 and Table 15-4 show that the recycling and recovery targets in Belgium
are much more ambitious than the ones set across Europe (Directive 94/62/EC on
packaging waste). Nevertheless, these targets were already surpassed in 2006. 294
294 IVCIE (2007) Annual Report.
EU15

Table 15-3 Recycling and Recovery Targets for Packaging Waste in Belgium
Household Household packaging
packaging
278
29/09/09
2009
2009
(% (% by by weight)
weight)
2010
2010
(% (% (% by by weight)
weight)
Achieved Achieved 2006
2006
(% (% by by weight)
weight)
Recycled 80% 80% 82%
Recovered or incinerated with
energy recovery
Industrial Industrial packaging
packaging
90% 90% 94%
Recycled 75% 80% 80%
Recovered or incinerated with
energy recovery
Source: IVCIE (2007), Annual Report
80% 85% 87%
Table 15-4 Recycling Targets for Materials Contained in Packaging Waste (Annual
Report 2007, IVCIE)
Material Material
Target Target (% (% by by weight) weight)
Achieved Achieved (2006)
(2006)
Glass 60% 99.8%
Paper and board 60% 89.1%
Metals 50% 93.2%
Plastics (counting exclusively
material that is recycled back
into plastics)
30% 38.5%
Wood 15% 63.8%
Following FOST-Plus, the key factors for the success of the Belgium packaging waste
management system are:
� A close public-private partnership – a successful collaboration between:
• Regions;
• Municipalities and intermunicipal authorities;
• Industry (via FOST-Plus and Val-I-Pac);
• Private waste operators; and
• Most importantly: citizens.
� Active participation of people in separating their packaging;
� Rational and optimised collection scenario;
� Acceptable cost for industry and striking the balance between price and
quality;
� Implementation in phases (10 years to implement across the country);
� Strong communication;
� High cost for residual waste;

279
� Widespread use of PBU;
� Transparency; and
� Well managed tenders for collection, sorting, and recycling.
Selective collection of industrial packaging is stimulated by 2 incentives for
companies that joined Val-I-Pac (www.valipac.be ):
� Recycling incentive:
• Plastics: 40 Euro per tonne
• Wood: 10 Euro per tonne
� Container incentive, for example:
• Containers of 1000 litres or more: 110 Euro per year;
• Containers 660 to 999 litres: 60 Euro per year; and
• Collection bags for plastics (> 200 l) or EPS (expanded polystyrene) >
500 l: 0.5 Euro per year.
15.5.2 Printed Materials
15.5.2.1 Environmental Benefits Prevention
The MBO on publicity and unsolicited mail stipulates the following obligations with
regard to prevention:
� Reduction of the use of plastic packaging;
� Use of environmentally sound ink and paper;
� Respect for the stickers against unsolicited mail for post boxes; and
� Reduction of the amount of unsolicited mail.
The MBO for the periodical press stipulates similar obligations.
No evaluation report is available.
15.5.2.2 Environmental Benefits Recycling
Both MBOs stipulate that the paper that is used for mail and periodical press contains
at least 40% of recycled fibre.
No evaluation report is available.
15.5.3 Waste Batteries
15.5.3.1 Environmental Benefits Prevention
The Flemish regulation for waste (VLAREA) includes several actions, such as limits on
the quantities of cadmium and lead in batteries. VLAREA stipulates, literally, that
these actions are intended to stimulate the use of rechargeable batteries. The MBO
on waste batteries, however, makes no reference at all to the stimulation of the use
International Review of Waste Policy: Annexes

of rechargeable batteries. According to the industry, there is no scientific proof that
rechargeable batteries would be better than non rechargeable batteries from an
ecological point of view.
Nevertheless, the number of rechargeable batteries has increased four-fold from
1997 to 2005. In addition, the maximum limits on the quantities of cadmium
(

Figure 15-4: Collection for Recycling of Batteries since the Introduction of an EPR on
Batteries in Belgium (BEBAT).
Note: Andere (light green) = ‘other’
15.5.4 Waste Accumulators
15.5.4.1 Environmental Benefits Prevention
RECYBAT reports no prevention actions: there are no producers of waste
accumulators in Belgium, so ecodesign in Flanders is not an option. The importers
have little influence on the design of the batteries. 299
Reuse is not an option.
15.5.4.2 Environmental Benefits Recycling
Table 15-5 shows the collection and recycling targets that are in force. 300
Table 15-5 Collection and recycling percentages of waste accumulators
281
International Review of Waste Policy: Annexes
Target Target
Achieved Achieved (2005)
(2005)
Collection 95% 93.7%
Recycling of lead 95% 95%
Recycling of plastics 30% 36%
Source: OVAM, 2007
299 OVAM (2007) Evaluatie van aanvaardingsplichten (Evaluation of take-back obligations), in Dutch.
300 OVAM (2007) Evaluatie van aanvaardingsplichten (Evaluation of take-back obligations), in Dutch.

15.5.5 Waste Tyres
15.5.5.1 Environmental Benefits Prevention
RECYTYRE makes no report on prevention.
15.5.5.2 Environmental Benefits Recycling
There are almost 5,000 tyre collection sites in Belgium. In 2007, they collected about
80,000 tonnes of waste tyres. In Flanders, about 51,000 tonnes of waste tyres were
collected, which amounts to a collection percentage of 92.34%. The collection target
is 100%.
Flemish legislation sets a recycling target for waste tyres of 25%, a disposal with
energy recovery target of 55% and a re-treading target of 25%. In 2007, RECYTYRE
reported a recycling rate of 47.5% and a disposal rate with energy recovery of 42%.
The re-treading rate was not achieved, however. In 2007, a re-treading rate of only 8%
was achieved. The ETRA report ‘Introduction to Tyre Recycling: 2006’ shows that the
rate of re-treading in Europe has averaged 11 to 13% since 1992. This certainly is a
point of concern for Belgium/Flanders. 301
15.5.6 Old and Expired Medication
15.5.6.1 Environmental Benefits Prevention
According to the MBO, local chemists are required to advise their customers on the
correct usage of medication. In doing so, the purchase of new medication might be
prevented, and the amount of unused/expired medication reduced.
15.5.6.2 Environmental Benefits Recycling
Not relevant. The aim of the take back obligation for old and expired medication is not
to recycle the waste, but to guarantee its safe treatment in an appropriate
installation.
15.5.7 End of Life Vehicles
15.5.7.1 Environmental Benefits Prevention
Prevention is limited to qualitative prevention.
15.5.7.2 Environmental Benefits Recycling
In Flanders, more than 73,000 end of life vehicles (ELV) were collected and
decommissioned. The recycling targets to be reached are:
282
� by January 2006, reuse and recovery of 85% by weight per vehicle, and reuse
and recycling of 80%;
301 OVAM (2008) Internal Report On Waste Tyres, Dutch.
29/09/09

283
� by January 2015, reuse and recovery of 95% by weight per vehicle, and reuse
and recycling of 85%.
In 2007, almost 90% of the weight of the vehicle was recovered in Flanders. The
recycling rate amounted to 68% and the reuse rate amounted to 19.8%. 302
In order to allow separate treatment to be carried out and the above recycling/reuse
targets to be fulfilled, manufacturers and importers must prepare dismantling
information for each new type of vehicle within six months of it first being placed on
the market, including information on individual components and materials and where
hazardous substances are located.
Manufacturers are to make information on dismantling, storage and testing of
reusable components available to dismantling facilities upon request.
Authorised centres enter data such as the relevant date, number and weight of ELVs,
and the type and weight of waste streams, after decommissioning, into a national
database. The database is managed by FEBELAUTO.
A problem that has not yet been solved is the illegal export of ELVs as second-hand
cars, often to Eastern Europe or the west coast of Africa. In Belgium, there is no link
between the registration number of the car and the car owner, so an ELV cannot be
traced to his of her owner. For several years, the Flemish government has been
pleading with the federal government to update the registry system, but so far nothing
has been changed. An additional control mechanism would be to ensure certificates
of destruction (CoD) are issued with every vehicle deregistration in the region.
15.5.8 Waste from Electrical and Electronic Equipment
15.5.8.1 Environmental Benefits Prevention
The MBO stipulates the following actions for producers:
� Use of easy-to-recycle materials;
� Prevention of the use of hazardous substances;
� Use of environmentally sound production technology; and
� Reduction in the energy consumption of products and facilities.
However, no evaluation report is available on the effectiveness of the WEEE MBO on
the prevention of waste.
15.5.8.2 Environmental Benefits Recycling
In 2007, 55,000 tonnes of WEEE were collected in Flanders, an increase of 10%
compared to 2006. Per capita, 8.9 kg of WEEE was collected, exceeding both the
European target of 4 kg/capita, and the higher Flemish collection target of 8.5
kg/capita.
302 FEBELAUTO (2007) Annual Report.
International Review of Waste Policy: Annexes

RECUPEL has more than 3,600 collection points in Belgium. In addition to CA sites
(container parks), used-good centres and retailers, there are specific collection
channels for gas discharge lamps, medical devices and laboratory equipment (see
Figure 15-5).
In Flanders, approximately 41% of the electrical and electronic equipment that is put
on the market is collected as WEEE by RECUPEL.
Figure 15-5: Collection System of RECUPEL in Belgium (Annual report 2007,
RECUPEL)
Source: RECUPEL (2007), Annual report
Most of the WEEE is collected via the CA sites (30,600 tonnes). The used-good
centres account for 5,700 tonnes. The large household appliances, however, are
collected mainly via retail (where take-back is free if a new appliance is being
purchased).
284
29/09/09

RECUPEL has continually sampled 5 % of the collected WEEE for a number of years.
The aim of this detailed sampling is to expose the relationships between the various
product groups in the mixed WEEE streams. It also represents the basis for reporting
to the authorities. The sampling is audited annually by an external party. In 2007
RECUPEL developed an automated sampling machine. Upon arrival of the WEEE at
processing sites, the full box pallets are manually emptied and sorted. Each appliance
then passes by on a conveyor belt, whereby the operator indicates by means of a
touch screen to which WEEE category the appliance belongs. At the same time the
appliance is weighed and photographed, which allows for subsequent checks.
Automation therefore implies improvement in efficiency compared to the earlier,
manual sampling method. RECUPEL entrust WEEE sampling completely to the
sheltered social workshops Revam (Flanders) and Hautes Ardennes (Wallonia). The
RECUPEL sampling machine is also gaining support outside of Belgium. 303
Table 15-6 presents the recycling and recovery percentages of the different types of
WEEE in Flanders. 304
Table 15-6 Recycling and Recovery Percentages of WEEE in Flanders
Type Type of of WEEE WEEE
Target
Target
Result Results Result
(VLAREA)
(VLAREA)
(Recupel)
(Recupel)
Large white
goods
Total Reuse and recycling 80% 82.91%
Total Recovery 85% 82.44%
Ferrous Reuse and recycling 95% 100.00%
Non-ferrous Reuse and recycling 95% 100.00%
Synthetic
materials
Reuse and recycling 50% 73.04%
Synthetic Recovery 80% 75.64%
Cooling and
freezing
appliances
Total Reuse and recycling 80% 79.70%
Total Recovery 85% 93.80%
Ferrous Reuse and recycling 95% 100.00%
Non-ferrous Reuse and recycling 95% 100.00%
Synthetic Reuse and recycling 50% 33.47%
Synthetic Recovery 80% 90.61%
Television
screens and
monitors
Total Reuse and recycling 70% 86.92%
Total Recovery 75% 89.09%
Ferrous Reuse and recycling 95% 100.00%
Non-ferrous Reuse and recycling 95% 100.00%
Synthetic Reuse and recycling 50% 71.23%
Synthetic Recovery 80% 82.25%
Other
appliances
Total Reuse and recycling 70% 81.17%
Total Recovery 75% 82.03%
303 RECUPEL (2007) Annual Report.
304 RECUPEL (2007) Annual Report.
285
International Review of Waste Policy: Annexes

Type Type of of of WEEE WEEE
Target Target
Target
Result Results Result
(VLAREA)
(VLAREA)
(Recupel)
(Recupel)
Ferrous Reuse and recycling 95% 100.00%
Non-ferrous Reuse and recycling 95% 100.00%
Synthetic Reuse and recycling 50% 85.51%
Synthetic Recovery 80% 97.79%
Gas discharge
lamps
Total Reuse and recycling 80% 96.33%
Total Recovery 95% 100.00%
Ferrous Reuse and recycling 95% 100.00%
Non-ferrous Reuse and recycling
Synthetic Reuse and recycling
Synthetic Recovery
Source: RECUPEL (2007), Annual report
15.5.9 Flash Torches
15.5.9.1 Environmental Benefits Prevention
The MBO stipulates the following actions for producers:
286
� Use of easy to recycle materials;
� Prevent the use of hazardous substances;
� Use of environmentally sound production technology; and
� Reduction in the energy consumption of products and facilities.
There is no evaluation report on flash torches available with respect to these actions.
15.5.9.2 Environmental Benefits Recycling
No collection or recycling targets are defined yet. According to OVAM, they should be
implemented with the revision of VLAREA by June 2009 at the latest.
15.5.10 Used Oil
15.5.10.1 Environmental Benefits of Prevention
Every year, VALORLUB draws up a prevention plan. The MBO stipulates that producers
and importers (through VALORLUB) must inform and sensitise consumers on the
proper and economical use of oil.
The article on prevention in the MBO, however, focuses more on proper and safe
collection and disposal of used oil (qualitative prevention) rather than on quantitative
prevention (reduction of the quantities of used oil).
15.5.10.2 Environmental Benefits of Recycling
The percentage of collection that has to be obtained amounts to 100% of all the
collectable used oil. The percentages of useful use that have to be obtained are at
least 85% recycling and maximum 15% energy recovery.
The achieved recycling percentage amounts to 95%. The collection percentage is not
clear yet. First, the total amount of collectable used oil needs to be identified. A study
29/09/09

is currently being performed to identify this amount. According to VALORLUB, a
collection percentage of almost 100% will probably be achievable. 305
15.5.11 Animal and Vegetable Fats and Oils
15.5.11.1 Environmental Benefits Prevention
The MBO stipulates no specific actions with regard to prevention.
15.5.11.2 Environmental Benefits Recycling
The MBO obligates a collection percentage of at least 95% of collectable waste oil. In
2007, a collection percentage of only 40% of collectable oil was achieved. Mainly the
oil used by households seems ‘to get lost’. 306
In 2007, about 28,000 tonnes of domestic oil was put on the market. It was analysed
that about 76% of this oil generates waste oil. This would mean that about 21,000
ton of domestic oil should have been collected. In reality, only 8,000 tonnes were
collected! Surveys suggested that about 78% of the people claim to hand in their
domestic oil. VALORFRIT will perform a new study to investigate the differences. 307
In 2007, about 35,000 tonnes of commercial oil were put on the market. was
Analysis suggested that about 60% of this oil generates waste oil. This would mean
that about 21,000 ton of domestic oil should have been collected. In reality, 18,000
tonnes were collected. 308
As a collection percentage of 95% seems difficult to get to, the target will be reduced
in the new VLAREA. An annex with the new target will soon be published.
Due to the high residual value of waste animal and vegetable oil, 100% of the
collected oil is recovered. In 2007, 63% was converted into biodiesel, 14% was
recovered in plastics, industrial soap, lubricants, etc, and 19% was incinerated with
energy recovery. 309 No targets for the different treatment options were stipulated in
the MBO, since a LCA study performed by VITO showed no significant difference with
regard to environmental performance. 310
15.6 Implementation Costs
The nature of the policy means that costs are to be carried by the producers subject
to EPR. Costs can be split up into:
305 Frank Vanderpooten, personal communication.
306 Tom Smidts, VALORFRIT, personal communication.
307 Tom Smidts, VALORFRIT, personal communication.
308 Tom Smidts, VALORFRIT, personal communication.
309 www.valorfrit.be
310 K. Briffaerts, F. Sleeuwaert, I.Vanderreydt, K. Vrancken (2008) Vergelijkende levenscyclusanalyse
van toepassingen van dierlijk vet en gebruikte frituurvetten en oliën (Comparative Life Cycle Analysis
Of Uses Of Animal Fats And Used Frying Fats And Oils), Dutch, VITO, 2008.
287
International Review of Waste Policy: Annexes

288
� Financing the data collection. Several industry bodies buy data on collected
amounts of a specific waste from the waste collectors;
� Financing the awareness raising and creating incentives for sorting the waste
into selective waste streams by the producer;
� Financing the waste collection. In the cases where municipal infrastructure is
used, it is considered important to take care that no public resources are used
to serve a private company or to fulfil the EPR obligations imposed on
industrial sectors. For example, a Flemish Ministerial Decree of 2005 sets in
place the calculation of the collection costs on a standardised civic amenity
site and points out how industry bodies have to remunerate the civic amenity
sites for the collection of the EPR-waste.
The traditional relationship between waste producer and waste collector is broken as
there is no cost implication at the point of waste generation. Rather, this cost is
included at the product purchase stage. The industry body of an EPR-scheme will
determine who will collect the waste. Costs borne by collectors are reimbursed by the
management body – which in turn is funded by producers. Of course, this is likely to
be reflected in product prices, but it does ensure that the full costs of a product life
cycle are incorporated in purchase costs.
15.6.1 Packaging Waste
FOST-Plus pays the intermunicipalities the full cost of collection and sorting as well as
paying for communication with residents, follow up and quality-based bonuses. In the
case of services being provided by the intermunicipality, the price is based on average
cost. In 2007, the operating costs of FOST-Plus amounted to €138 million. 311
FOST-Plus operating income in 2007 amounted to €119.7 million, which represents a
4.6% increase from 2006 (€ 114.5 million). This rise can be totally ascribed to the
increase in proceeds from materials. The value of all materials increased from
€32.1m to €41.0 m in 2007. The members’ contributions (Green dot fees) were
therefore lowered from € 82.4 to €78.74 million (see Table 15-7 and Figure 15-6).
The combination of the total costs of €138 million, the operational income of €119.7
million and additional income of €25.36 million led to a net surplus of income over
expenditure of €7.148 m in 2007.
311 Fost Plus (2007) Annual Report.
29/09/09

Table 15-7 Green Dot Fees for Packaging (Annual report FOST-Plus, 2007)
Source: Fost Plus (2007), Annual Report
Table 15-8 Fees for Commercial Packaging
Single use packaging
Paper, cardboard, metals, glass,
recyclable natural fibres, wood,
other recyclable materials
289
International Review of Waste Policy: Annexes
Financing Financing contribution contribution in in €/ton
2007 2008
14.50 13.00
Recyclable plastics 39.50 35.50
Non recyclable materials 43,50 43.50
Reusable packaging
Recyclable plastics for the
construction industry
Source: VAL-I-PAC (2008), IMPACT nr 3, January 2008 newsletter
35.50 40.50

Figure 15-6: Earnings from Green Dot Fees and Recyclates Sales, Fost Plus
15.6.2 Printed Material
‘Publishers’ of publicity and unsolicited mail pay a contribution of €0.005 per kg
paper they put on the market. These contributions are used to reimburse
(inter)municipalities for their waste paper collection (container parks and door-to-door
collection).
‘Publishers’ of periodical press reserve advertisement space worth €3 million per year
for the Flemish government. As mentioned above, the government uses this space
mainly for advertisements on prevention or recycling.
15.6.3 Waste Batteries
Companies pay an annual fee of €60 to BEBAT, which covers the operational costs of
BEBAT. In addition, a fee of €0.1239 per battery is paid by the producers to finance
the collection and recovery/disposal of the waste batteries. This fee is passed on to
the consumers. In 2007, total income through these contributions amounted up to
€19 million. 312
The contribution from the consumers, however, exceeds the costs for collection and
recovery/disposal by 30%. In 2007, the costs of operating BEBAT amounted up to
€12.7 million.
312 BEBAT (2007) Annual Report.
290
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Green Dot Sales of recyclate

Moreover, the provisions of BEBAT now amount to more than €37 million.
According to OVAM, these high provisions show that the contribution per battery is set
too high. As the contribution is determined at federal level (through ecotax
legislation), OVAM has no say in a possible reduction of the contribution.
15.6.4 Waste Accumulators
Companies pay an annual fee of €100 and €0.08 per battery to RECYBAT. In 2007,
total income of RECYBAT amounted to about €68,000. Operational costs of RECYBAT
amounted to €38,500 (no collection system had to be put in place). 313
15.6.5 Old and Expired Medication
Almost 2,600 chemists participate in the collection of old and expired medication.
Nine wholesalers coordinate the collection and transport of the medication to the
incineration plants. The 111 members of AVGI and FEBELGEN finance the
incineration of the medication. 314
In 2007, 23,395 special boxes were used for the collection of waste medication in
Flanders, representing about 300,000 kg (around 50 gram/capita). The costs for
collection of these boxes amounted to €68,313. The costs for incineration amounted
to €99,556. Since 1996, the amount of collected waste medication has remained at
similar levels.
15.6.6 End of Life Vehicles
Members of FEBELAUTO pay an annual contribution. These contributions are used to
finance the operational costs of FEBELAUTO. Due to the relatively high residual value
of end of life vehicles, no contributions are necessary to finance the recovery and
disposal of the vehicles. In 2007, the turnover amounted to €344,000.
15.6.7 Waste Tyres
The financing of the take-back system for tyres is paid by the consumer. He or she
pays a fee per tyre, depending on its type and size; e.g. €2.4 per tyre for cars, €12.46
for lorries and buses. In 2007, RECYTYRE had an operating income of more than €17
million (almost 80 ktonnes waste tyres). 315 Among other charges, RECYTYRE
compensates the operators for the collection and recovery/disposal of the waste
tyres (more than €14 million) and the 435 CA sites that accept waste tyres from
private sources (€ 173,000).
313 RECYBAT (2007) Annual Report.
314 OVAM (2008) Oude en vervallen geneesmiddelen – Inzamelresultaten 2007 (Old and expired
medication – Collection data 2007), Dutch.
315 RECYTYRE (2007) Annual Report.
291
International Review of Waste Policy: Annexes

15.6.8 Waste from Electrical and Electronic Equipment
Manufacturers and importers pay a recycling contribution when bringing products
onto the Belgian market. These contributions are paid to, and are managed by, the
sector associations.
For certain products, an all-in contribution is charged. This is the case for all domestic
categories of the existing 7 sectors as well as all medical devices and laboratory
equipment, and all lighting devices. This all-in contribution is used to finance the
costs of the collection, transport, sorting and treatment of the discarded appliances
that are taken back to the store or the container park. A part of this contribution is
used to finance the coordination and communication by RECUPEL (administration,
reporting, audits). The all-in contribution ranges from €0.5 for small household
appliances to €1 for freezers and refrigerators (www.recupel.be, English version).
For certain products only, an administrative contribution is charged when the product
is put on the Belgian market. This is the case for all professional appliances (other
than household), including monitoring and control appliances. This administrative
contribution is used to cover reporting and administrative costs. The costs for the
transport and treatment of the appliances is calculated when the discarded product is
delivered to the treatment partners. The administrative contribution ranges from
€0.05 for fittings for gas discharge lamps to €1.5 for professional laboratory
equipment (www.recupel.be, English version).
In 2007, total income of RECUPEL amounted up to €28.5 million. About €27.8 million
was spent to remunerate municipalities and operators for the collection and
recovery/disposal of WEEE.
15.6.9 Flash Torches
Producers and importers of flash torches pay an annual contribution of €60 and a
contribution of €0.20 per flash torch put onto the Belgian market. This contribution is
passed on to the consumers.
No data on the operational costs of BEBAT are publicly available.
15.6.10 Used Oil
VALORLUB pays the costs for the collection and the processing of used oil in
container parks, companies, etc. VALORLUB also has to obtain the objectives laid
down by the legislator (maximal collection, priority to regeneration and reuse).
To finance this, the producers and importers of oil pay an annual contribution to
Valorlub. This contribution depends on the quantities and the type of oil that they
bring into the market (VAT (21%) excluded):
292
� Annual contribution: €150 the first year of membership; €150 for the following
years of membership;
� Contribution per litre of oil brought into the Belgian market or oil imported for
own use:
29/09/09
• Domestic oil (= engine oil in packs of up to and including 25 kg): €0,28
per litre;

293
• All other types of oil generating waste oil: €0,02 per litre.
No data on the operational costs of VALORLUB are available yet. The first annual
report is expected by June 2009 (VALORLUB has only recently been operational).
15.6.11 Animal and Vegetable Fats and Oils
Producers and importers of oil pay a contribution to VALORFRIT, depending on the
quantities and the type of oil that they bring into the market:
International Review of Waste Policy: Annexes
Fat Fat
Oil
Domestic rate ≤ 2.5 kg: €0.030/kg ≤ 3 l: 0.0276/l
Commercial rate > 2.5 kg: €0.030/kg > 3 l: 0.00828/l
For some larger companies, the yearly contribution amounts to €750,000. This
contribution is usually passed on to the consumers.
In 2007, VALORFRIT had an operating income of almost €2 million (Annual report
2007, VALORFRIT).
In 2007, the charges of VALORFRIT (€2 million) were composed of the
reimbursements of the operators for the collection and recovery/disposal of the
waste oil (more than €95,000), the reimbursement of the municipalities for the
collection of domestic oil via their container parks (€ 380,000), communication and
sensitization costs (€1 million) and the operational costs of VALORFRIT
(€460,000). 316
The monetary reserve of VALORFRIT amounted to €2.7 million in 2007 and will be
systematically diminished in the period 2008-2012 in accordance with the
management plan for the period.
15.7 Effects on Technical Change / Innovation
OECD remarked in its study on extended producer responsibility that EPR really did
have an impact on the amount of waste collected for recycling, but that the relation
with prevention and design-for-environment is hard to prove: “it is hard to know
whether firms made the changes in response to the policies or for cost-savings or
other reasons.” 317 EPR schemes often tend to evolve from a prevention incentive
towards a funding scheme for recycling.
In Flanders most EPR schemes operate with overall goals to be achieved by an entire
sector, and only limited goals to be achieved by individual participants of the system.
316 VALORFRIT (2008) Annual Report 2007.
317 OECD working group WGWPR, EPR Policies and Product Design: Economic Theory and Selected
Case Studies, 2006.

This affects the incentive that the EPR could have on promoting ecodesign within
individual companies. This is because of what are effectively free-rider effects
associated with the effects of the activities of individual producers.
15.8 Social and Distributional Consequences
Households and private consumers are charged an EPR contribution when buying
electrical of electronic equipment or other EPR goods. The Flemish legislation
requires that the part of the cost of the EPR that is charged to the consumer should
be clearly visible on the sales invoice. In respect of comparable products this raises
awareness on the environmental impact associated with a product.
However, the analysis in Section 15.6 suggests that the costs of EPR are a minimal
part of the price of products. As such, although the approach is, by its nature,
regressive, the effects on prices are not significant. Indeed, as discussed in the pay
by use section for Flanders, the costs of all producer responsibility schemes are
reflected in a net cost of around 36 Euros per year for each household on average.
This is unlikely to have a major social impact.
15.9 Complementary Policies
Since an EPR combines a take-back obligation with recycling targets, accompanying
policies might be necessary to create enough recycling capacity. The dynamics of the
free market ought to open up recycling capacity when the demand for capacity
increases. It is however necessary to ensure that the recycling capacity is sustainable.
Export of EPR goods like paper or WEEE to non-OECD countries for recycling needs to
be monitored and the quality of the recycling technology needs to be assured.
Communication efforts on the collection of a specific waste, paid for by the industry
bodies, can be completed with more general awareness raising activities by the public
authorities.
Compliance with EPR objectives is assessed on the basis of the data provided by the
producers themselves, which originates from the industry bodies. It is important for
the competent authorities to compare the reported data with an independent and
neutral data source to evaluate the credibility of this data.
15.10 Effect of the Policy on Pricing of Resources / Services
Where the strongest influence on the management of waste (both prior to and at the
point of production) was previously held by the waste collectors (who operate on a
competitive basis and so may be expected to provide lower quality services), the
introduction of EPR policies shifted this market influence to the producers of
products. The EPR policies create industry bodies of a more monopolistic nature. In
Belgium the cost structures of these industry bodies do not need to be made public in
a financial report. The cost structure is therefore not transparent, which gives rise to
controversies about whether the Belgian solution is more expensive in comparison
with other international approaches.
On the other hand, the government has a larger possible impact on a centralised body
on which it can impose concrete and specific conditions through its notification
294
29/09/09

procedure. It would be considerably more difficult to manage several different waste
collectors though their individual permits.
15.11 Evasion and Enforcement
MBOs are signed with representative industry associations which do not always cover
the full 100% of the market. Industry bodies are established but companies are free
to join these bodies or to fulfil their EPR-obligations on their own. In practice, a certain
percentage of producers neither join the EPR bodies nor fulfil EPR obligations on their
own. They are called ‘free-riders’ because they profit from the advantages of the MBO
(e.g. they are not subject to extra legislation) while they do not contribute to the
efforts of the MBO. In the Environmental Policy Agreements, eliminating free-riders is
explicitly included as an important responsibility for the signing authority.
A specific service within OVAM, containing 15 employees, has been established with
the explicit task to enforce the EPR and to identify free-riders. Within the IVCIE, five
employees are involved in enforcement on packaging waste free-riders.
Households are also obliged to use the correct collection channels for obligated
materials. Figure 15-7shows an example of measures taken to enforce compliance.
Figure 15-7: Sticker Used by FOST Plus to Warn the Householder of Wrong Content
15.12 Lessons Learned
EPR mechanisms do not always lead to better environmental design, but are very
effective in enhancing the amount of waste collected for recycling.
When EPR-targets are imposed in a rather large industry group, e.g. the producers of
packaging waste, the incentive for individual companies to change their packaging
strategy can become watered down. When easy to recycle packaging is collected in
sufficient amounts, the recycling targets of the sector can be reached and the
producers of difficult to recycle packaging can profit from the results of the sector as
a whole without being incentivised to develop more recyclable packaging waste
themselves. In Belgium, companies contributing to FOST-Plus (the industry body for
household packaging waste) receive a green dot label. But the FOST-Plus collection
scheme for packaging is selective in the kind of packaging waste that is collected.
Difficult or expensive to recycle waste, such as butter packaging, is excluded from the
295
International Review of Waste Policy: Annexes

collection, although they have a green dot and contribute to the system. The costs for
recycling are not increasing and, with the policy structured in this way, companies like
Alpro do not have an incentive to revise their packaging strategy.
To be cost effective EPR industry bodies must work in full transparency and should be
prevented from applying a monopolistic approach to the waste collection market
(collection costs are expected to be minimised in a competitive market where bidding
for the collection contract occurs).
Data is often purchased by the industry bodies from the waste collectors. This could
lead to bias, when the waste collector sells what the industry body wants to receive.
Unbiased information on waste generation and collection (via independent sources of
data or independent auditing) is necessary to check the reliability of the compliance
reports of the industry bodies.
15.13 Prerequisites for Introduction
An important element in the establishment of EPR-policies is the political will to go
further than the EPR imposed by the European Recycling Directives. In Flanders EPR
policies on wood waste, agricultural foil and floor coverings have been removed from
the legislation, even before they entered into force, due to changing political will.
Industry support is not easy to obtain, and both the waste collection industry and the
involved production industry may oppose an EPR except where this is accompanied
by strong legislation.
EPR policies require manpower and administrative tools both for inspections relating
to free-riders and for data gathering.
296
29/09/09

16.0 Deposit Refund Systems - International
16.1 Outline of Policy
“A deposit-refund system is the surcharge on the price of potentially polluting
products. When pollution is avoided by returning the products or their residuals, a
refund of the surcharge is granted.” OECD, Glossary of Statistical Terms. 318
A deposit refund system encourages the return of the materials into an organized
recycling or reuse process. The producers can finance that process through a fraction
of the deposit, or to ensure that the deposit paid is the same as that received, those
subject to the deposit scheme can pay a separate payment for the administration of
the scheme.
Drinks containers are the most common target of deposit refund systems, though
economic theory suggests that the schemes could be applicable to hazardous
materials and other waste streams, subject to transaction costs being minimised (see
Annex 2.0). The systems can encourage recycling and / or reuse where otherwise it is
easy to dispose of containers with the residual waste. The same policy mechanism
can also be used to target difficult to dispose of, or hazardous, items to ensure that
these do not reach the residual waste stream. This can be considered a waste
prevention policy as it reduces the hazardousness of materials in the waste stream.
Non-drinks container examples include:
297
� Batteries (Swedish Östhammar example) and car batteries (Germany); 319 and
� Tyres (Maine, USA).
Finally, some countries, e.g. Sweden make use of vehicle scrapping charges, which
discourages the dumping of vehicle bodies in rural areas and ensures that cars are
returned to registered scrapping destinations at the end of their life. 320
16.2 Economic Rationale for Deposit Refund Schemes
Deposit refund schemes are a particular form of product tax/recycling subsidy. In
such programmes, also known as ‘bottle bill’ programmes, consumers pay a deposit
(tax) on a container at the time of purchase. This should, in theory, be set at the extra
social cost of improper disposal over the net recycling cost (assuming there is already
an Advance Disposal Fee (ADF) on the manufacturer equal to the net recycling cost).
This means that if the product is improperly disposed of, that individual pays the
318 http://stats.oecd.org/glossary/detail.asp?ID=594
319 http://www.eeb.org/activities/waste/EEB-mini-brief-deposit-schemes-for-Batteries-March2004.pdf
320 The (sometimes temporary) scrapping charges which have become popular across nations in the
context of the current economic decline have their precedent in the more permanent schemes which
some countries employ to ensure that end-of-life vehicles are returned to an appropriate recycler.
International Review of Waste Policy: Annexes

external cost of improper disposal by foregoing the refund, which would typically be
set equal to the initial deposit.
This incentive is considered particularly appropriate for items with hazardous
contents where it is important to keep them out of landfills or incinerators, as well as
to discourage their illegal dumping. Likewise for products where the temptation to
litter is high, or the resulting litter is considered to create significant disamenity
impacts, mandatory deposits may be imposed.
The distinction between deposit refund schemes on the one hand, and ADFs coupled
with a household recycling refund on the other, is in the re-collection of the product at
the end of its useful life. Mandatory deposit schemes involve a separate collection
path, rather than being collected as part of the municipal recycling system.
Several theoretical studies have argued that a deposit/refund is the best policy in the
presence of illegal disposal. 321 Palmer et al model paper, glass, plastic, aluminium,
and steel. They find a substantial difference in the intervention levels necessary to
achieve reductions in disposal with the various policies. A $45/ton deposit /refund
would reduce all wastes by 10%. Alternatively, the government could obtain a
comparable reduction using an ADF of $85/ton or a recycling subsidy of $98/ton.
A key point is that the deposit/refund creates incentives for both recycling and source
reduction, whereas an ADF or a recycling subsidy takes advantage of only recycling or
source reduction in isolation. 322 However, it is important to note that the theoretical
studies, in abstracting from the real world situation, have not taken into account all
the potential costs of administering such schemes. In fact they are not precisely
modelling existing ‘bottle bill’ programmes, but rather a more generalised version of
deposits and refunds, applied ‘upstream’ on manufacturers and recyclers.
Palmer and Walls accept that in practice there could be significant administrative
costs associated with refunding deposits, which could reduce the efficiency of the
approach. 323 This issue is discussed by Palmer et al with numerical estimates of the
effects of administrative costs on the overall efficiency of deposit refunds relative to
product taxes and recycling subsidies. 324 Viewing their results alongside empirical
evidence from Ackerman et al., they suggest that administrative costs may be of the
321 T. Dinan (1993) Economic Efficiency Effects of Alternative Policies for Reducing Waste Disposal,
Journal of Environmental Economics and Management 25: 242–56; D. Fullerton and T. C. Kinnemann
(1995), Garbage Recycling and Illicit Burning or Dumping, Journal of Environmental Economics and
Management, 29 (1); Peter S. Menell (1990) Beyond the Throwaway Society: An Incentive Approach to
Regulating Municipal Solid Waste, Ecology Law Quarterly, vol. 17, pp. 655-739; Hilary Sigman (1995) A
Comparison of Public Policies for Lead Recycling, RAND Journal of Economics, vol. 26, no. 3 (Autumn),
pp. 452-478.
322 K. Palmer, H. Sigman and M. Walls (1997) The Cost of Reducing Municipal Solid Waste, Journal of
Environmental Economics and Management 33, 128-50.
323 Palmer and Walls (1997) Optimal Policies for Solid Waste Disposal Taxes, Subsidies and Standards.
Journal of Public Economics 65(8): 193-205.
324 K. Palmer, H. Sigman and M. Walls (1997) The Cost of Reducing Municipal Solid Waste, Journal of
Environmental Economics and Management 33, 128-50.
298
29/09/09

same order as the cost savings from using a deposit/refund. 325 Due to such
considerations, Palmer et al., Fullerton and Kinnaman, and Palmer and Walls all
argue that deposit refunds should be imposed upstream on producers rather than on
final consumers to minimize administration and transaction costs. 326
The question of administrative costs of such schemes is a focus of much debate
between supporters and opponents of such schemes, However, the debate is one
that is unfortunately – on the basis of our attempt to elicit such evidence - largely
uninformed by impartial evidence of scheme costs.
16.3 Where Has the Policy Been Applied and Why?
There are a number of jurisdictions where deposit refund schemes have been
applied. Table 16-1 shows a list of these. In the following sub-sections, we give a
flavour of the schemes which have been implemented in different countries.
16.3.1 Denmark
The “Danish Bottle Bill” was passed in 2002, and set up the Dansk Retursystem A/S
to implement and administer the deposit-refund system for beverage containers. The
following deposits apply:
299
� Beverage containers up to 1 litre: €0.13;
� Plastic containers 0.5 litre: €0.27; and
� Beverage containers > 1 litre: €0.40.
When a producer or importer sells beverages to retailers in Denmark, the deposit is
added to the price of containers.
The total deposit collected by the producers and importers is paid to Dansk
Retursystem. That deposit cost is passed onto the consumer by the retailer and then
the consumer returns the container either manually or via a reverse vending machine
to the retailer. The containers are then transported to Dansk Retursystem’s collection
centres where they are registered and counted and on the basis of this the company
pays the refund back to the retailers.
Essentially, even prior to the Danish Bottle Bill, deposit refund systems had been in
place for decades for refillable containers. Until 2002, domestically produced beer
and soft drinks were only sold in reusable glass, and plastic bottles with a deposit,
whilst sales in cans were prohibited. In 2002, the law was changed, allowing all beer
and carbonated soft drinks to be sold in one-way packaging, including metal cans. It
was this change that prompted the introduction of the Bottle Bill.
325 Frank Ackerman, Dmitri Cavander, John Stutz, and Brian Zuckerman (1995) Preliminary Analysis:
The Costs and Benefits of Bottle Bills, Draft report to U.S. EPA/Office of Solid Waste and Emergency
Response, Boston, Mass.: Tellus Institute.
326 D. Fullerton and T. C. Kinnemann (1995), Garbage Recycling and Illicit Burning or Dumping, Journal
of Environmental Economics and Management, 29 (1); Palmer et al (1997); Palmer and Walls (1997).
International Review of Waste Policy: Annexes

Table 16-1: Experience with Deposit Refund Schemes in Other Countries / States
Country Country System System
Year Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture
Rate*
Rate*
Austria Law to make deposit 1992 PET bottles (non-refillables 30% PET
regulatory
excluded)
60% Cans
Belgium
Ecotaxes
Act of 1993
300
Containers taxed $0.52
per litre unless they have
deposit.
Croatia Deposit-return plus
‘incentive fee’ to be paid
by producer if 50% refill
isn’t met (5% paid still, if
Denmark
29/09/09
target is met).
Packaging Law. All beer
and soft drinks must be
sold in refillable bottles.
Metal banned until 2002.
Regulatory deposit for
imported glass/plastic
containers. Ecotax also.
1993 Beer, soda and soft drinks
containers
2005 Glass, PET and metal
containers for beer, soft
drinks, water, wine and
spirits.
1989
(amended
1991)
Beer and soft drinks
containers. Deposits on
some wine and spirit
bottles dependent on
retailer.
Estonia Deposit-return 2004 Beer, low alcohol drinks,
carbonated/ noncarbonated
soft drinks,
water, juice, cider and
Finland
Tax on beverage
containers Exemption from
tax only if part of refillable
deposit scheme.
Germany Einwegpfand Deposit on
one-way a standard
amount, deposit on
refillables manufacturer
dependent, not legally
specified, though tend to
be similar.
Hungary Tax linked to market share
quotas.
perry.
1970s 1990 One-way beer and soft
drink containers
2003 Not containers for wine,
fruit juice or spirits
2005 Beer, low-alcohol drinks,
wine, mineral water,
carbonated and non-
99.5 %
(beer and
soft drinks
containers
only)
Glass
bottles
99%
Cans 86%
Quota-
Glass 90%
Alu. 90%
Plastic 80%
Quota-
Beer 67%
Low alcohol
Deposit Deposit
Redemption
Redemption
Site
Site
Driver Driver
Reference
Reference
$0.40 Government www.BottleBill.org
$0.12 50cl
$0.27 99cl
Tax $0.14-0.33
Glass 1.0 kroon (refill
and NRB)
Metal and PET < 0.5 l
0.5 kroons PET>0.5l
1kroon
Non-refillables
$0.11
$0.45 for larger sizes
Tax
$0.24 beer $0.47
plastic $0.71 glass
Glass refillable-
Beer € 0.08 Soft drink
€ 0.15 (many prices,
not all listed)
Government www.BottleBill.org
Government EUROPEN Report
2007
Government
www.BottleBill.org
Retailers Government EUROPEN Report
2007
8,000 sites Government
Manufacturers
http://www.ymparisto
.fi/download.asp?con
tentid=16253&lan=E
N
http://www.bookrags.
com/Container_depo
sit_legislation

Country Country System System
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture
Rate*
Rate*
carbonated soft drinks. 28% Wine
20%
Iceland Tax on non-refillable 2008 Non-refillable glass, steel,
containers.
aluminium and plastic.
Kiribati Special Fund Act 2004 2004 Aluminium cans and PET
drinks bottles
Malta
Deposit
Return
System
301
Previous ban of non-glass
beverage containers, lifted
Mexico Higher tax on non-refillable
bottles and cans.
Fed. States (Deposit-return) 1991 Currently only aluminium
of
(amended cans, but glass and plastic
Micronesia
2006) expected to be added
Kosrae
Recycling
Program
soon.
Netherland Agreement deposit 1993 Soft drinks and water in
s
one-way and refillable
glass and PET containers
Norway
Deposit on containers and
tax dependent on return
rate.
Refillables only exempt if
95% return rate is
achieved. Retailers (on
site >25m²) selling nonrefillables,
must also sell
similar products in
refillable.
International Review of Waste Policy: Annexes
1994 Most drinks excluding milk,
vegetable juices and water
Peru Deposit on some bottles 620ml size beer bottles
Portugal Fillers must ensure quotas
Quotasmet
Beer 80%
Retailers must sell
Wine (with certain
refillables for all non-
exceptions) 65% Soft
20,000
cans per
day
Refillable
glass 98%
Refillable
PET 99%
Wine/
spirits 60%
Beer 98%
Soft drinks
98%
Deposit Deposit
Redemption
Redemption
Site
Site
$0.05 ($0.04
returned)
Kaoki Mange
operating
centres.
$0.06 ($0.05 back) Kosrae Island
Resource
Management
Authority
(KIRMA) sites
PET and glass:
$0.16 5l
$0.16 5l (+Tax
inversely proportional
to return rate, but if
above 95%, no tax)
Over 9000
establishments
in the country,
plus 3000
deposit
machines
where receipt is
given
Driver Driver
Reference
Reference
Industry
Tax is
government
driven, but
recycling fee in
place is retailer
driven
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org

Country Country System System
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture
Rate*
Rate*
refillables sold. drinks 30%
South Deposit return system, Around Approx. 75% beer, 45%
Africa voluntary i.e. manufacturer 1948 soft drinks and some wine
driven, not Government.
and spirits bottles
Spain Return
overall 87%
Reuse beer
Sweden Law requires rate of 90%
recycling of aluminium
cans, or complete ban.
Industry implemented
deposit system to avoid
this. PET introduced later
as well.
deposit
Switzerland Deposits required on all
refillable drinks containers
except cans, which have a
voluntary tax of $0.04.
South
Australia
Canada-
Alberta
302
Container Deposit
Legislation- deposit
required on almost all
drinks containers, with
onus on manufacturer/
wholesaler to ensure
convenient system in
place for deposit of
container/ refunds for
customers.
All containers sold in
Alberta (including imports)
must be registered
29/09/09
Deposit on
one-way
containers-
1984 for
cans.
1994 for
PET
(refillables
already in
place)
Aluminium cans and PET
law. Deposit now on most
beverage containers.
1990 All above a certain weight
(currently all!)
1975
(integrated
into
Environment
Protection
Act in 1993)
Most included except wine
(unless in plastic bottle),
milk, pure fruit juice or
flavoured milk >1l.
1972 All beverage containers
regulatory except milk,
which is under a voluntary
57%
Recovery
rate of 80-
90% on
one way
containers
Refillable
glass 95-
98%
Refillable
PET 70%
85% nonrefillable
glass
84% cans
74% PET
Glass (AB
Beer) 96%
Glass
Deposit Deposit
Redemption
Redemption
Site
Site
Between 8-15% of
product cost
(or 0.5-1% if
wine/spirit)
Voluntary Cans $0.07
Refillable PET $0.56
One-way PET $0.14-
0.24
Ref. glass $0.166l
Ref and one-way PET
$0.40>1.5l
$0.10 if refillable to
retailer (rare) $0.05 if
refillable to collection
depot (99.9% done
this way)
$0.05 1l Beer $0.10
Mostly
collection
depots, though
some store
refillables.
215
independent
depots and 78
Driver Driver
Reference
Reference
Manufacturer
Law government
driven.
Standard bottle
and deposit
brewer/bottler
driven.
Government
Government
legislation with
manufacturer/
wholesaler
responsibility
Initially
government,
until 1997 when
http://www.cervecero
s.org/
www.BottleBill.org
http://en.wikipedia.or
g/wiki/Container_dep
osit_legislation
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org

Country Country System System
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture
Rate*
Rate*
through the Beverage
scheme
(import
Container Management
beer) 92%
Board (BCMB).
Alu (beer)
89%
Alu (soft)
79%
Overall
78%
Canada-
British
Columbia
Canada-
Manitoba
Canada-
New
Brunswick
Canada-
Newfoundla
nd
303
All containers must be
refillable, and none
collected can be landfilled
or incinerated.
Beer separate system,
though still under
legislation.
Beverage producers given
option of setting up
deposit-return system, or
adding a 2 cent per
container levy. Only beer
producers choose the
former.
Deposits paid on all
containers (bar milk), but
whilst full paid back on
refillables, only half paid
back on non-refillables.
Half-back system, with
manufacturers prohibited
from selling containers
other than recyclable or
refillable for selected
products. Beer operated
International Review of Waste Policy: Annexes
1970 All beverage containers
except milk, soya milk,
infant formulas, dietary or
meal supplements, or
other milk substitutes.
81.3%
1995 Beer containers only Refillable
beer 95.5%
Dom beer
74%
Glass 34%
Overall
residential
1992
(revised
1999)
All except milk
1997 Beverage containers
smaller than 5l, excluding
milk, dietary supplements
and medicine.
31%
Refillable
beer 96%
Dom beer
75%
Nonalcoholic
75%
Refillable
beer 95%
Domestic
beer 55%
Deposit Deposit
Redemption
Redemption
Site
Site
retail outlets
(for beer bottles
and cans only)
Non-alcoholic $0.05
1l
Alcoholic (not incl.
beer)
$0.10 < 1l
$0.20 >1l Beer $1.2
per dozen
$0.10 Retailer
500ml $0.20
Non-alcoholic $0.08
($0.04 back)
Alcoholic (excluding
beer) $0.20
($0.10 back)
Beer varies -full refund
Depots or
retailers (all
retailers obliged
to take back as
much as they
sell). Beer back
to retailer.
89 depots
around the
province.
‘Green Depots’
run as
businesses.
Beer returned
to certain retail
outlets.
Driver Driver
Reference
Reference
it was turned
over to private
sector
Industry
Opportunity
government
driven,
implementation
producer driven
Industry
Government, but
brewers for beer
system.
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org

Country Country System System
separately, run by brewers.
Only have to refund when
customer buying (1 for 1),
otherwise negotiable.
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture
Rate*
Rate*
Canada- Deposit-return system, 2005 All beverage containers Very new
Northwest with additional handling
except milk.
system, so
Territory charges for different
no certain
products/ materials in
figures yet.
container.
Approx.
72%
Canada-
Nova Scotia
Canada-
Ontario
Canada-
Prince
Edward
Island
Canada-
Quebec
304
Half-back deposit system.
Full refund on refillables,
half on non-refillables.
Deposit-return system on
alcoholic drinks containers
only.
Use of ‘Industry Standard
Bottle’.
Non-refillable drinks
containers for beer or soft
drinks banned since 1977.
Wine may have half-back
system in place.
Return-to-retail deposit
system, with industry
required to fund kerbside
collection for containers
not part of the system.
29/09/09
1977 ban,
1984
deposit
All beverage containers
except milk.
Refillable
beer 96%
Dom. beer
70%
Alcoholic drinks containers Refillable
‘industry
standard
bottles’
beer 97%
Soft drinks and alcoholic
drinks. Wine may be
included.
All beer and soft drinks
containers (not juice, water
and iced tea)
Refillable
beer 96%
Wine/ spirit
59%
Soft 98%
Refillable
beer 98%
Dom. beer
76%
Deposit Deposit
Redemption
Redemption
Site
Site
when same number of
beer bought as
empties returned.
Wine or spirit $0.25
Other $0.10
Plus additional $0.05-
0.10 handling fee
Non-alcoholic $0.10
Alc. refillable
1l $0.20
Alc. non-refillable
500ml $0.20
Containers up to
630ml, or metal
containers up to 1l
$0.10 Over those sizes
$0.20
Non-al
1l $0.70 Alc. $1.20
per dozen, or ).07 each
Soft drinks and beer
cans
$0.05
Beer bottles $0.10
Beer bottles and soft
drinks >450ml $0.20
18 government
depots or 26
community
depots.
83 provincewide
depots.
Beer store only Brewers
Mainly retailers
(inc.
supermarkets
and
convenience
stores), also 15
depots
Retailers
(including
depanneurs -
small
convenience
stores not
usually
included in
Canada).
Driver Driver
Reference
Reference
RRFB-Resource
Recovery Fund
Board
Government and
industry.
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org
www.BottleBill.org

Country Country System System
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture
Rate*
Rate*
Canada- Deposit-return system plus 1973- Litter All beverage containers Refillable
Saskatche environmental handling Control apart from milk (under beer 92%
wan charge (EHC) for non- Regulations voluntary system).
Dom. beer
refillable containers, for (unclear,
cans 95%
recycling, and beer bottle appears the
Alu. cans
deposit system for deposit
95%
refillables.
system
Glass 83%
introduced
Overall
to this in
1998)
86%
Canada-
Yukon
USA-
California
USA-
Connecticut
305
No kerbside collection.
Deposit-return system,
with ‘recycling club’ for
children offering ‘prizes’ as
well as refund if certain
numbers reached.
Refillables not charged
recycling fund fee, all
others are.
California Beverage
Container Recycling and
Litter Reduction Act
Deposit-return system on
non-refillable containers
Beverage Container
Deposit and Redemption
Law
International Review of Waste Policy: Annexes
1998 All beverage containers
except milk.
1987
(Expanded
2000 to
include all
noncarbonated
and nonalcoholic
drinks
excluding
milk.)
Non-refillable drinks
containers, inc. beer,
spirits, carbonated, fruit
drinks and some vegetable
juices. Not milk.
1980 Beer, malt, soft drinks and
mineral water.
Refillable
bottles
103%
Non-refill.
bottles
113% (?)
Liquor
containers
1L 79%
(includes
refillables)
Alu 73%
Glass 58%
PET 46%
HDPE 51%
Overall
61%
Not
recorded.
In 2004
Deposit Deposit
Redemption
Redemption
Site
Site
Deposits vary widely Beer bottles
for diff. materials and can only receive
sizes
full refund if
Non-ref. glass
returned to 10
$0.40-1.00
specific sites,
Metal cans
but can be
$0.10-0.20
returned for
less at retailers.
Other returns at
71 SARCON site
D=deposit, R=refund
Liquor ref. D=$0.10
R=$0.10
Liquor non
500ml D=$0.35
R=$0.25
Under 24oz $0.05
Over 24oz $0.10
22 depots or
four Liquor
Commission
outlets
Redemption
centres (not
retailers)
$0.05 Redemption
centres, or
retailers (but
Driver Driver
Reference
Reference
Government www.BottleBill.org
http://www.sarcsarca
n.ca/sarcan/faqs.php
Government www.BottleBill.org
www.BottleBill.org
www.BottleBill.org
http://www.cga.ct.gov
/2005/rpt/2005-R-

Country Country System System
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture Deposit Deposit
Redemption
Redemption Driver Driver
Reference
Reference
Rate*
Rate*
Site
Site
Deposit-return system. CRI
only for brands
0836.htm
estimated
/products they
recycling
rate to be
similar to
Massachus
etts of 69%
sell).
USA- Beverage Container 1982 All non-aluminium beer, Not $0.05 Retail stores,
www.BottleBill.org
Delaware Legislation
Wholesale malt, carbonated, mineral recorded.
but only for
Deposit-return system 1983 Retail water and soda water
brands they
containers less than 2
quarts (approx. 1.9L).
sell.
USA-Hawaii Deposit Beverage
2002 All beverage containers 72% for $0.05 Redemption Government www.BottleBill.org
Container Law Deposit-
excluding milk and dairy 2008
centres or
return system
derived products, except
retailers (if not
tea and coffee or liquor
within 2miles of
containers.
red. centre in
highly pop.
areas, or if
under 5,000sq
ft of retail
space
USA-Iowa Beverage Container 1979 Beer, soft drinks, soda 93% Not less than $0.05 Redemption
www.BottleBill.org
Deposit Law
water, mineral water, wine,
centres or
Deposit-return system.
liquor and wine coolers.
retailers (who
Deposit containers banned
can refuse if
from landfill in 1990.
they have an
agreement with
former).
USA- Maine Refillable Beverage 1978 Beer, soft drink, wine Not Wine and liquor $0.15 Redemption
www.BottleBill.org
Maine Container Law Deposit-
cooler, mineral water. recorded. Other $0.05
centres or
return system
Expanded to include wine,
retailers (who
liquor, water and non-
can refuse if
alcoholic drinks in 1989.
they have an
agreement with
former).
USA- Beverage Container 1983 Beer, soft drinks and 69% $0.05 Any retail
www.BottleBill.org
Massachus Recovery Law
carbonated water.
establishment
etts Deposit-return system
that sells the
container.
306
29/09/09

Country Country System System
Year Year of of Intro Intro Containers Containers Covered Covered Capture
Capture Deposit Deposit
Redemption
Redemption Driver Driver
Reference
Reference
Rate*
Rate*
Site
Site
USA- Michigan Beverage 1978 Beer, soft drinks,
97% $0.10 Retail stores wwiw.BottleBill.org
Michigan Container Act
carbonated and mineral
Deposit-return system
water. Wine coolers and
canned cocktails in 1988.
USA- New New York State Refillable 1983 Beer and other malt drinks, Soft drink Minimum of $0.05 Retail stores
www.BottleBill.org
York Container Law
carbonated soft drinks, 62%
and redemption
Deposit-return system
wine coolers, mineral and Beer 77%
centres.
soda waters.
Wine
coolers
65%
Overall
70%
USA- The Beverage Container 1972 Beer, malt, carbonated soft Overall Standardized refill Retail stores. www.BottleBill.org
Oregon Act
drinks, mineral and soda 84% bottles $0.02
Deposit-return system
water and (as of 2009)
Non-standardized and
Only US deposit law with
water and flavoured water.
non-refillable $0.05
no handling fee.
Bottles and cans under 3L
USA- Beverage Container Law 1973 Beer, soft drinks, malt, Overall 90- Liquor above 50ml Retail stores
www.BottleBill.org
Vermont Deposit-return system
soda and mineral water, 95% $0.15
and redemption
mixed wine and liquor
(added 1987).
Other $0.05
centres.
Source: Oakdene Hollins (2008) Refillable Glass Beverage Container Systems in the UK, Report for WRAP, 26 June 2008.
The report notes that capture rate includes containers returned for recycling as well as refilling. Separate figures were not so readily available. Unless
specifically listed as something else, the monetary unit is American dollars. The only exception is Canada where the Canadian dollar is used.
Percentages given for US capture rates are taken from various sources, often telephone conversations by the Bottle Bill researchers. For more detailed
references see www.BottleBill.org
307
International Review of Waste Policy: Annexes

16.3.2 Sweden
Deposit refund schemes are in place in Sweden for glass, PET and aluminium drinks
containers. Both refillable and one-way containers are managed under the system. A
number of materials-specialist companies manage the scheme, for example, Ab
Svenska Returpack-Pet, Svenska Returglas 50-Cl Ab and Ab Svenska Returpack.
Deposits are paid as follows: 327
308
� Cans: €0.04;
� 0.33 L glass bottle: €0.05;
� 0.50 L glass bottle: €0.08;
� ≤ 1 L non-refillable PET bottle: €0.09; and
� > 1 L non-refillable PET bottle: €0.18.
In one small Swedish municipality, a deposit-refund system has been put into place
for batteries. A very small (€0.03) deposit is levied on each battery sold, and this is
redeemed when the battery is returned to one of the shops participating in the
scheme. The estimated result is that approximately 80% of batteries are returned.
The cost of the system is covered by the municipal budget.
16.3.3 Germany
For car batteries, the consumer has to pay €7.50 if he buys a new car battery without
returning a used one. A number of states in the USA also operate these schemes.
Usually the replaced battery must be returned to the retailer of the new one within 30
days.
For beverage containers, Germany has a deposit refund scheme on non-refillable
containers as a result of the failure to meet certain recycling and reuse targets that
were set in the Packaging Ordinance. Germany differs from the Scandinavian model
because no single enterprise is given the sole right or obligation to operate a
nationwide system. The DPG (Deutsche Pfandsystem GmbH) was established to
coordinate the deposit refund system making it possible for the independent system
participants to operate on an equal and fair basis (see Annex 17.0).
16.3.4 Taiwan
Taiwan has used a deposit refund system for PET bottles since 1989. Manufacturers
and importers pay fees into a recycling management fund, and the end-consumers
are given a refund when they return the bottle to a designated collection site. The
fees are set by a Recycling Fund Management Board, on a level per kilogram plus the
per bottle refund amount. For example, in 1998, PET bottles attracted a fee of
327 Sveriges Brygerier, accessed 2009, http://www.sverigesbryggerier.se/eng/1-emballage/1index.html
29/09/09

NT$13.01 per kg (US$0.39 at January 1998 rates) for single material containers,
plus a refund amount of NT$0.70 (US$0.02 at January 1998 rates) per bottle.
Recycling rates started from a low base but were 41% in 1991. By 1992, the PET
recycling rate had jumped to 80%. 328 The scheme then ran into problems with
manufacturers’ not registering with the scheme, under-reporting production, and not
paying fees so that the fund ran into a deficit and had to reduce the refund from
around US$0.06 to around US$0.02. 329 However, recycling rates continue to be high,
reaching 100% and remaining there (which does however, suggest that there
continues to be some under-reporting of production). In 2007, over 97,000 tonnes
were recycled.
16.3.5 Other Countries
Many other countries in Europe, as well as countries in Asia and the Americas use the
deposit refund system for beverage containers.
Eleven US states have a legal deposit on bottles and cans for beer and soft drinks. Six
states also have deposits on mineral water containers. Deposits are made mandatory
through the State’s ‘bottle bills’ and range from 2.5¢ to 15¢ per container. According
to the US Container Recycling Institute, beverage container recycling rates are far
higher (72% on average by weight) in states with bottle bills than those without (28%
recycling rate). 330 In most states, retailers are required to take back containers that
are in their product line, even if the product was not purchased through their store. In
some states (e.g. Maine and California) retailers are exempt where they are near to
redemption (civic amenity) sites.
Deposit refund arrangements for containers are also in place in most Canadian
provinces and are also common in Europe. According to a UK report for Friends of the
Earth, glass and PET bottle reuse rates as high as 90% are found in Denmark,
Sweden, Germany and Finland. 331 Such schemes raise awareness and help to change
consumer attitudes and behaviour. They have also been shown (in the USA) to have a
low direct cost per tonne of material recovered although the administrative costs can
be high if the scheme is not well designed and implemented. In the USA the states
with bottle bills also have approximately three times the national average market
share for refillable beverage containers, i.e. around 15% rather than around 5%. 332
328 D. O’Connor (1996), Applying Economic Instruments In Developing Countries: From Theory To
Implementation, Report for the OECD Development Centre, May 1996 web.idrc.ca/uploads/user-
S/10536145810ACF2AE.pdf
329 Asia-Pacific Environmental Innovation Strategies (2004) Deposit-Refund Systems for PET bottles in
Taiwan, Report for Taiwan Environmental Protection Administration, December 2004,
www.iges.or.jp/APEIS/RISPO/inventory/db/pdf/0133.pdf
330 http://www.bottlebill.org
331 Eunomia (2002), Maximising Recycling Rates, Tackling Residuals, Report for Friends of the Earth,
http://www.foe.co.uk/resource/reports/maximising_recycling_rates_report.pdf
332 Robert C. Anderson (2000) The United States Experience with Economic Incentives for Protecting
the Environment, Report for US EPA, Nov 2004.
309
International Review of Waste Policy: Annexes

All the provinces of Canada operate some deposit-refund systems for drinks
containers. The beer industry organises collection and refilling of its refillable bottles
and has a return rate of 90-99%. For other drinks containers, industry associations
fund the kerbside recycling programs run by municipalities. They use a number of
different mechanisms to raise fees:
310
� Container recycling fee. This reflects the net cost of recycling, and therefore
depends on the material and the recovery rate. These range from zero to
$0.08;
� Environmental handling charge. $0.03 to $0.07 per unit, depending on size
and material. The provincial government collect the funds to operate the
program and retain any surplus;
� Beverage container levy. $0.02 per unit, used to finance 80% of kerbside
collection;
� Half-back. Represents half of the deposit paid on a non-refillable container.
In systems other than the half-back (in which only half the deposit is refunded to the
consumer on return), the whole deposit – between $0.05 and $0.40 – is refunded on
return of the container.
There is also some application of the concept in relation to other waste streams.
Austria has deposit-refund schemes for light bulbs/tubes, batteries and refrigeration
equipment. The US State of Rhode Island requires a US$5 deposit on all replacement
vehicle tyres. The deposit is refunded if the customer returns the old tyres to the point
of sale within 14 days of purchasing new tyres. It is also used for pesticide containers
in some US states.
The OECD noted in 2001 that among middle-income countries, South Korea has one
of the most extensive deposit systems in terms of items covered. Under a 1991
amendment to its Solid Waste Management Act, South Korea introduced a
comprehensive deposit program in 1992. The products affected by the system
include packaging, batteries, tyres, oil, televisions, air conditioners and washing
machines. Producers and importers of the listed products pay the deposits into a
“Special Account for Environmental Improvement” and receive refunds as they collect
and treat the resulting post-consumer waste. The products covered and the size of
the deposit were modified in 1993 and again in 1996. The largest deposit applied to
large tyres and amounted to about $0.40. The deposit on paper, metal, glass and
plastic packaging was a fraction of a US cent per container. 333
New Zealand is currently examining the case for container deposit legislation. This is
specifically regarded as a combination of product tax (the deposit) and recycling
subsidy (the refund). The system being considered is likely to be based upon the
South Australian model, in which the consumer takes the empty container to a small
local collector and receives the refund, and the collectors give the product to 3 super-
333 Robert C. Anderson (2004) The United States Experience with Economic Incentives for Protecting
the Environment, Report for US EPA, Nov 2004.
29/09/09

collectors. These super-collectors receive the deposit from the brand-owner and pass
on the material to the recycler. The New Zealand system will attempt to address the
perceived weaknesses of this system, which are:
311
� High collection costs;
� Lack of incentive for brand-owners to assist in recycling, as they keep
unclaimed deposits;
� Sorting by brand required of the materials collected; and
� Excessive market power held by the super-collectors.
To do this, it is proposed that collection will be at point of sale, unclaimed deposits
will go to a public body, and no sorting between brands will be required. 334
16.4 Key Organisations Involved in Implementation and
Management
To implement and manage deposit refund systems, there is normally a fund
holder/manager which is an organisation that carries out the following functions:
� Accepts the fees from the manufacturers/importers and the consumers;
� Organises the collection systems; and
� Manages the refund payments to the bottle collectors
In Denmark, it is Dansk Retursystem A/S that is responsible for the implementation
and administration of the system, in Sweden there are several in this position, each
dealing with a specific material, such as Ab Svenska Returpack-Pet, Svenska
Returglas 50-Cl Ab and Ab Svenska Returpack.
The recycling fees or deposits are usually set by a body specified for the purpose such
as the Resources Recycling Fee Rate Review Committee (in Taiwan). Fee setting can
be a political decision.
Another key player in the implementation is usually the Environmental Protection
Agency of the country, which monitors enforcement and performance.
The retailers are also involved in implementation, as they have to either be equipped
with reverse vending machines or have sufficient space to keep returned containers
until collection so as to allow for return of the containers.
16.5 Pre-implementation / Evaluation Studies Available
The following selected references from this review give some specific information on
the performance of deposit refund systems:
� Enviros (2004) International Waste Prevention and Reduction Practice: Final
Report For Defra, October 2004;
334 Covec Report (2008) Potential Impacts of the Waste Minimisation (Solids) Bill: Update Report,
Report for Packaging Council of New Zealand, May 2008, http://www.pca.org.au/uploads/00548.pdf
International Review of Waste Policy: Annexes

312
� Robert C. Anderson (2004) International Experience with Economic Incentives
for Protecting the Environment, Report for US EPA, Nov 2004;
� Robert C. Anderson (2001) The United States Experience with Economic
Incentives for Protecting the Environment, Report for US EPA, Jan 2001;
� Covec Report (2008) Potential Impacts of the Waste Minimisation (Solids) Bill:
Update Report, Report for Packaging Council of New Zealand, May 2008,
http://www.pca.org.au/uploads/00548.pdf ;
� N. Tojo, T. Lindhqvist and G. Davis (2001) OECD Seminar on Extended
Producer Responsibility, EPR: Programme Implementation and Assessment,
Seminar for the OECD, December 2001
� RDC-Environment & Pira International (2003) Evaluation of costs and benefits
for the achievement of reuse and recycling targets for the different packaging
materials in the frame of the packaging and packaging waste directive, Report
for the European Commission, March 2003
� D. O’Connor (1996) Applying Economic Instruments in Developing Countries:
From Theory to Implementation, OECD Development Centre, May 1996
� ERM (2008), Review of Packaging Deposit Systems for the UK, Report for
DEFRA, December 2008, accessed from
http://randd.defra.gov.uk/Document.aspx?Document=WR1203_7722_FRP.p
df
16.6 Environmental Benefits
Deposit-refund systems are reported, in the literature, to have a range of possible
environmental benefits. The key ones mentioned in the literature are:
� Increasing the use of / reducing the extent of decline in the use of refillables;
� Increasing the recycling of containers covered by deposits (for refill or
recycling);
� Reducing the extent of littering; and
� Avoiding harmful chemicals being mobilised in the environment (usually not in
beverage schemes, e.g. lead acid batteries, or pesticides).
In addition, the logistics may or may not be more efficient. These issues are examined
in turn below.
16.6.1 Maintaining Use of Refillables
Not all deposit schemes are designed with the intention of shoring up the market
share of refillables, and where they are, they are not always well designed. The
question we are interested in this Section is whether this is an environmentally
justifiable goal.
29/09/09

A study in 2002 reviewed the outcomes of 11 different LCAs comparing refillable
against one-way packaging (including glass). 335 The study suggested that in terms of
five types of air pollutants, the use of refillable containers was, on balance, beneficial.
Refillables were also found to generate less solid waste per unit volume of packaged
beverage. Comparing refillables with one-way bottles, furthermore, revealed that
refillables use less water and use less energy. However, cans compared favourably to
refillable glass bottles in respect of water pollution and energy use. Conversely, a
study summarising the results of seven LCA studies of refillable glass versus
aluminium showed that all LCAs favoured refillable packaging with a 47-82%
reduction in water use.
IFEU undertook an LCA on beer packaging in Germany and concluded that from the
perspective of climate change, re-usable PET and glass bottles had the least
environmental burden producing less than half the emissions (expressed in CO2
equivalent) of the three one-way systems (see Figure 16-1).
Figure 16-1: Greenhouse Gas Impacts of Different Packaging Options
Source: IFEU (2003) Relevant Packaging for Beer, LCA III, in Peter Lee, Paul Vaughan,
Caroline Bartlett, Tracy Bhamra, Vicky Lofthouse and Rhoda Trimingham (2008)
Refillable Glass Beverage Container Systems in the UK, report for WRAP, June 2008.
Interestingly, the same organization – IFEU – undertook a separate analysis on
refillable packaging on behalf of PETCORE (the PET recycling company). 336 This study
suggested a more equivocal view. It highlighted the significance of assumptions
regarding collection and recovery of used packaging, and distribution logistics.
The 2006 Beer Store Annual Report 2006 included LCAs provided by the Canadian
Government. The Beer Store, which is responsible for 75% of all beer sold in Ontario,
335 Institute for Local Self-reliance (2002) Environmental Benefits of Refillable Beverage Containers,
Washington: ILSR.
336 IFEU (2004) Okobilanz fur PET-Einwegsysteme unter Berucksichtigung der Sekundarprodukte,
Repoirt for PETCORE, August 2004.
313
International Review of Waste Policy: Annexes

eported that on average, each glass bottle is washed and refilled 12-15 times before
being recycled. It calculates that re-using refillable glass bottles an average 15 times
results in an overall energy saving of 2.4 million gJ and the avoidance of nearly
160,000 tonnes of greenhouse gases. 337
A study undertaken for the EC in 2005 included a review of LCA studies that
compared refillables against one-way systems. The report found that no type of
packaging was clearly always better or always worse for the environment, irrespective
of the assumptions used. The report concluded that the findings of these studies
were highly dependent on the product supply system, return rates, transport
distances, control mechanisms, incentives such as deposits and electricity generation
methods. 338 The relationship between capture rate and transport distance was
reviewed in detail and Table 16-2 shows the findings from the analysis. The analysis
suggested refillables (glass) would be beneficial when the transport distance is below
100km and the capture rate is high, and one-way containers would be beneficial
when transport distance is high and capture rates are low. It suggested that refillable
PET bottles may be the best option for short distribution distances (

315
The existing studies show that the environmental comparison of refillables
versus one-way containers is not a simple one and that a number of factors
need to be considered. Three key factors, cited in a number of the studies, are
transport transport distance, capture rate for for reuse and collection collection rate for for for recycling.
recycling.
Another factor they do not mention is the number of uses per container, which is
partly a function of capture rate, but also a function of the number of uses prior to
breakage. This is usually a key factor in such studies (i.e. how many ‘lives’ does a
container have before it enters the ‘discard’ phase).
The suggestion is that the studies are not conclusive. They also suggest, however,
that some variables – such as transport – should be entitled to vary freely. Issues
such as transport distance are, however, amenable to being influenced by policy.
LCAs appear to treat this as an exogenous variable, yet clearly, it is not, and one
might legitimately ask whether restriction of transport movements might not be a
legitimate area for policy intervention.
This important point was raised in the study by Ecolas-PIRA, where it was suggested
that: ‘This inevitably leads to debates on the proper balance’ between Internal Market
and environmental objectives, to which there is no simple answer.’ 341
The actual outcomes of some deposit schemes are not always as intended. To the
extent that the German scheme was designed to increase the market share of
refillables, it seems to have failed, partly as a consequence of high deposit rates (see
Section 17.0). Bevington notes: 342
The mandatory 25 cent deposit on non-refillables is much higher than the
commercially-determined deposits on refillables: 8 cents (glass) and 15 cents
(PET). This was intended to encourage consumers to buy refillables, in order to
protect the refill market. A perverse result of this has been that consumers
who do not intend to return their empties buy refillables so they lose a smaller
deposit. Thus the return rate for refillables has fallen.
The deposit has failed to protect refillables, and their market share has fallen
in all categories except beer since 2003, as shown in the chart below. They
are below the levels in 2001, just before the deposit took effect. Most of the
non-refillables are PET, as consumption of cans has not recovered. The fact
that beer is not commonly sold in PET, together with the conservative nature
of the German beer market, explains why refill levels for beer have been
maintained. Government data for 2006 are not yet available, but industry data
suggests that refill levels declined further in 2006 for all drinks categories
including beer.
341 Ecolas – Pira (2005) Study on the Implementation of Directive 94/62/EC on Packaging and
Packaging Waste and Options to Strengthen Prevention and Re-use of Packaging, Final Report to the
European Commission, Report 03/07884.
342 G. Bevington (2008) A Deposit and Refund Scheme in Ireland, Report commissioned by Repak Ltd.,
September 2008.
International Review of Waste Policy: Annexes

This may reflect the ease with which consumers can make use of the DSD system as
an alternative route – free, to themselves, at the point of disposal – for ensuring an
environmentally sound management of beverage containers, namely, recycling.
The above example does not necessarily imply that a scheme could not be designed
where refillables were not encouraged. For example, if households were incentivised
to reduce the use of recycling services through applying small charges on recycling
services, this might do more to improve the incentive to use refillables rather than
one-trip packaging. More likely, the combined effect of a primary material tax and a
deposit – as happens in Denmark – might reinforce the case for refillables. Finally, if
deposit schemes are successful in achieving high captures of material, it seems
reasonable to ask why it should be necessary to retain a second collection route for
the materials targeted by the deposit refund scheme. This important point is taken up
below in respect of costs.
Deposit-refund schemes have been used to encourage the refillable container
market, particularly for beer bottles, in Canada and some states of the USA. As
suggested above, where distances to transport the bottles are relatively short this
probably has a positive environmental benefit. Refillable PET bottles are increasingly
an alternative to the heavier, traditional refillable glass, particularly for the large
volume containers.
16.6.2 Increasing Recycling
To the extent that re-use might not be the objective of a deposit-refund scheme, it
becomes of interest to know whether deposit refund schemes can increase recycling.
This is not the same question as that of whether deposit refund schemes achieve
higher return rates than any alternative policies. This question is discussed, and it is
touched upon below, since this is often the question addressed by those discussing
deposit refunds. It would not, in and of itself, be evidence of the superiority of one
instrument relative to another. If the improvement in performance was obtained at a
cost that does not justify the benefit, then one might reasonably argue that an
instrument with enhanced performance is one where benefits are not justified by
costs.
16.6.2.1 Effects of Deposit Schemes on Recycling Rates
Ideally, one has some indication of ‘before’ and ‘after’ performance, controlling for
other variables. To some extent, this is made difficult by the absence of data of a
usable form. Surprisingly few studies actually take this approach.
Some data allows for comparison of performance in areas with and without deposits,
In the US, in 1999, the recycling performance of states with and without deposits in
place is shown in Figure 16-2. The recycling rates, and the number of containers
recovered per capita, were far higher in the deposit states.
316
29/09/09

Figure 16-2: Performance of US States with and Without Deposits, 1999
317
Recycling rate (%) and per capita containers
recovered in the US (1999)
490
72 28
Also of interest is the performance of deposit schemes in the context of wider
recycling systems. In Sweden, for example, the recycling rate for plastic packaging
increased from 17% to 30% between 2003 and 2005 (44% in 2006). In the same
period, recycling rates for PET under the deposit scheme were 77% to 82% (85% in
2007). This, in and of itself, might not prove much. The components of plastic
packaging are many and varied, and PET bottles are readily recyclable. Perhaps more
telling, however, is the performance in respect of metals. Metal packaging recycling
rates were around 65% in 2004-2005, but the recycling rate for aluminium under the
deposit system was 85% to 86% in the years 2002 to 2007. More impressive still is
the return rate for glass bottles which is 99% on 33cl bottles and 90% on 50cl
bottles. 343 In Denmark, return rates in 2007 were 84% for cans, 93% for plastic
bottles and 91% for glass bottles. 344
Similarly, in Germany, recycling rates in 2005 for plastics, tinplate and aluminium
were 50%, 85%, 76% and 79% for plastics, tinplate, aluminium and glass,
respectively. The reported return rates under the deposit scheme are 95-98%, but
these rates are not official. 345
Figure 16-3 shows collection rates achieved in 2002 in deposit schemes. This shows
that very few countries see low rates of return, with some jurisdictions achieving close
to 100% return rates. As would be expected under economic theory, deposit
343 http://www.sverigesbryggerier.se/eng/1-emballage/1-index.html, accessed January 2009.
344 ERM (2008) Review of Packaging Deposit Systems for the UK, Report for DEFRA, December 2008,
accessed from http://randd.defra.gov.uk/Document.aspx?Document=WR1203_7722_FRP.pdf
345 Wolfgang Ringel (2008) The German Deposit System on One Way Beverage Packaging,
Presentation to the first Global Deposit Summit, Berlin 2008.
International Review of Waste Policy: Annexes
191
Deposit states (10) Non-deposit states (40)
Recycling rate Containers per capita recovered

schemes’ return rates increase as the deposit increases, these leading to an
enhanced incentive (see Figure 16-4). Figures for Denmark are shown in Figure 16-5.
Figure 16-3: Collection Rates for Non-refillable Containers in Deposit Systems, 2002
100
75
50
25
Note: Figures based on data collected from system operators, data from 2002
Source: Wolfgang Ringel (2008) Introduction on Deposit, Scottish Government Litter
Summit, Edinburgh 26 th November 2008.
Figure 16-4: Relation Between Level of Deposit and Return Rate
Collection rate (% )
Source: System operators, Container Recycling Institute, Data from 1997-2002
Taiwan differs from the European context, as the deposit refund scheme started
without any other producer responsibility systems in place. The scheme therefore
acted in isolation to increase recycling, first of PET and later with a number of other
materials. As described earlier, Taiwan now claims a 100% PET recycling rate, using
its deposit-refund system.
318
0
100
90
80
70
60
50
40
29/09/09
59 59
Collection rate in deposit systems for non-refillable containers (%)
65
69 70 70 70
75 77 77 77
80
83 83 83 84 84 84
90
93 93 95 95 96
California
Prince Edward
New Foundland
Massachusetts
Connecticut
Maine
New York
South Australia
New Brunswick
Ontario
Quebec
Alberta
Denmark
Nova Scotia
Saskatchewan
British Columbia
Oregon
Sweden
Vermont
Iowa
Norway
Finland
Manitoba
Michigan
0,0 2,0 4,0 6,0 8,0 10,0 12,0 14,0 16,0
Deposit (€ cents per container)

Figure 16-5: Return Percentages of One Way & Refillable Beverages
Source: Christian Fischer (2008) Producer Responsibility Schemes Versus Deposits
and Taxes- Danish Experiences, PRO Europe Congress, 15 May 2008
It is common to hear it suggested that it is not the case that recycling rates are higher
under deposit schemes. However, those who suggest this usually do so on the basis
of reviewing recycling rates for all packaging. For example, EUROPEN, argues: 346
319
There are no compensating benefits with regard to an overall improvement in
recycling performance. The Perchards report showed that overall recycling
rates in Member States with deposit systems are not higher than those of
comparable EU countries where there are no special arrangements for
beverage containers.
The problem with this appears to be that the Perchards report looked at rates for all
packaging in seeking to make this point. Deposits do not apply to all packaging (a
point that is frequently made to downplay the potential impact of deposits on total
recycling rates, often by the same organisations who seek to downplay the potential
effectiveness of deposit refunds by using statistics which cover all packaging).
Perchards themselves state: 347
It is certainly true that deposit systems for non-refillable beverage containers
can achieve higher recycling rates for the beverage containers affected than
when these containers are handled through general recycling systems.
However European experience shows that deposit systems do do not not achieve achieve achieve a
a
346 EUROPEN (2007) Economic Instruments in Packaging and Packaging Waste Policy, Brussels:
EUROPEN.
347 G. Bevington (2008) A Deposit and Refund Scheme in Ireland, Report commissioned by Repak Ltd.,
September 2008.
International Review of Waste Policy: Annexes

320
29/09/09
higher higher higher recycling recycling recycling rate rate rate for for for all all all packaging packaging packaging of of of a a a given given given material, material, because because because beverage
beverage
containers containers represent represent too too small small small a a proportio proportion proportio n of of the total total tonnage tonnage of of that
that
packaging packaging packaging material.
material.
Drinks containers typically represent only about 10% of all packaging and the
recycling rate for beverage containers in general recycling systems is likely to
be higher than the recycling rate for all packaging of the same materials.
They then allude to the performance of Belgium in respect of the recycling of all
packaging even though this is clearly not a good comparator for reasons which the
previous extract makes clear (the targeted materials – beverage containers – are a
relatively small fraction of packaging). 348 In particular, the largest fraction of the
packaging stream is always paper and card, which is also an easy, and relatively low
cost, material to recycle. Consequently, in most countries, the packaging recycling
rate will be heavily influenced by capture of a material that is irrelevant to any
sensible discussion regarding deposit refund schemes.
348 Perchards responded to a similar criticism in a previous report, where they had earlier suggested
that the recycling rates achieved in deposit schemes were no greater than those achieved in other
countries through presenting targets related to all packaging. They responded:
We decided to make a comparison based on overall recycling rates achieved because the
Packaging and Packaging Waste Directive repealed the Directive on containers of liquids for
human consumption, reflecting that the scope of policy has broadened out to all packaging. A
further expansion and/or restructuring of EU policy is now under consideration which may
result in targets for all products of specific materials. Thus, specific arrangements just for
beverage containers go against the trend in EU policy in this area.
GRA has challenged our line of argument, saying that the fact that deposit systems handle
only a small of packaging is no reason not to have a deposit system. GRA used a medical
analogy to illustrate argument – if you have a medicine that can cure 10% of the patients, but
not the other 90%, is there a reason not to use the medicine for the 10%? However, this is not
an exact analogy, because a medicine does exist for a significant proportion of the other 90%
of packaging, namely selective collection.
Several other stakeholders have also challenged the basis of our comparison, arguing that a
clearer picture would emerge from a comparison based on recycling rates for household
packaging waste alone, or, even better, of beverage containers between deposit states and
Member States relying on packaging recovery systems. Unfortunately, though, we were not
able to obtain data which would have enabled us to pursue this suggestion.
(Perchards (2005) Study on the Progress of the Implementation and Impact of Directive 94/62/EC on
the Functioning of the Internal Market, Final Report to the European Commission, May 2005). This
argument fails to counter the possibility that it might be possible to design a system which targets the
10% through one system and targets the remaining 90% through another. No one advocating deposit
refund scheme is necessarily arguing against ‘selective collection’ of, for example, cardboard, or wood.
Equally, several successful selective collection systems for packaging – notably the Belgian one
achieve high rates of recycling without targeting non-bottle plastics from households. So, the question
remains open as to whether a complementary (as opposed to a parallel) system of selective collection
and deposit refund system might be superior to either one acting independently, let alone the two
operating in parallel with duplication in scope. This question has only really been examined in any
study as far as we are aware (see later in this Section). Generally, the question regarding costs has not
been properly answered for the simple reason that the question which really matters has not been
interrogated in sufficient depth. The key variables are likely to be quite system dependent (which
selective system is being ‘replaced’ by the type of complementary system being proposed here) and
dependent upon the (assumed) costs of implementing a deposit scheme.

This is not to deny the possibility of high recycling rates of packaging being achieved
without deposit refund schemes. Other EU countries have achieved impressive
recycling performance without deposit-refund systems, such as Belgium.
Notwithstanding very high overall rates of recycling for packaging, however, based on
its Fost Plus managed packaging collection system, Belgium managed to recycle 67%
of plastic bottles in 2007 (comprising both PET and HDPE) and 97.5% of metal
packaging (steel and aluminium cans). 349 One might still argue, even in this case, that
there might be room for improvement, through use of a deposit scheme, where
plastic bottles are concerned.
In the UK, Alupro, the aluminium industry’s trade body, says 98% of English
households have kerbside collections of aluminium cans, but capture rates can be
anywhere between 30% and 70%. 350 The ‘cans-only’ recycling rate is estimated to be
52% in 2008. 351 Therefore, even with a ‘free to the consumer’ system (in terms of
marginal cost), and a very widespread coverage, the capture rate is still much less
than is seen in the deposit-refund scheme countries. This may be partly a reflection of
the fact that 35% of aluminium cans are consumed away from home, in the
workplace, and at sports, leisure and travel locations, according to Alupro. However,
such a waste stream is one for which deposit refund schemes may be well suited to
dealing with, not least since such containers are less likely to arise as litter where
deposits are in place.
16.6.3 Effects on Littering
There is evidence to suggest that deposit refund policies can reduce litter and even
reduce the number of lacerations caused by glass in the environment. 352 Several oneway
deposit systems were implemented with the clear objective of reducing littering
(e.g. Sweden, British Columbia, California, Michigan and others). Hawaii is a more
recent example of this trend. The potential for deposit systems to be effective in
reducing littering has an intuitively plausible rationale - if the deposit is significant,
then if the consumer does decide to litter, the possibility exists that someone else will
pick up the container to redeem the deposit.
The Container Recycling Institute suggested significant reductions in littering following
introduction of deposits in some US states (see Figure 16-6). The effects on used
beverage containers (UBCs) and on total litter are shown as being between 70-80%
and 30-40%, respectively. It must be said, however, that all studies of this nature
suffer in terms of the lack of clarity about the metric used to measure the contribution
349 Fost Plus (2007) Annual Report, http://www.fostplus.be/files/EN/8/GB_AR.pdf
350 Ends Report (2009) Defra Report Rejects the case for Bottle Deposits, January 2009
http://www.endsreport.com/index.cfm?action=report.article&articleID=20119&q=deposit%20refund&
boolean_mode=all
351 Alupro website, http://www.alupro.org.uk/facts%20and%20figures.htm, accessed May 2009.
352 M. Douglas Baker, MD, Sally E. Moore, and Paul H. Wise, MD, PhD, MPH, "The Impact of 'Bottle Bill'
Legislation on the Incidence of Lacerations in Childhood", American Journal of Public Health, October
1986.
321
International Review of Waste Policy: Annexes

of beverage containers to total litter. It is not clear what the most relevant indicator
should be (counts, volume, hazardousness, etc.) partly because no systematic studies
have been carried out, to our knowledge, to understand the contribution of different
attributes of litter to the disamenity experienced by those who experience litter. There
is also the matter of cost to be considered since clean up of litter costs money. The
effect of litter reduction on costs is considered below.
Figure 16-6: Reduction in Littering in US States Linked to Deposit Schemes
Where supposed counter-arguments to the ‘litter reduction’ effect are put forward,
these very rarely challenge the likely reality of this effect. Indeed, the counterarguments
tend to adopt the view that this effect is not significant because beverage
containers constitute only a small proportion of litter. Even if one accepts the
argument that this might be true, implicit in the counter-argument appears to be an
assumption that if litter ‘is there’, then the amount of it is not a matter of any
importance, or more specifically, that the reduction in the quantity of beverage
packaging in litter is of no significance. Yet none of the literature actually offers any
evidence to support this implied claim. The validity of the implied claim is also
affected by the nature of the assumption (as highlighted above) concerning the metric
used to measure ‘litter’. What the right metric might be has not, as discussed above,
been given adequate consideration by either advocates, or detractors, of the effects
of deposit schemes.
In Ireland, Perchards argue that: 353
322
The National Litter Survey for 2006 indicates that drinks containers (excluding
cartons) represent 5.36% of total litter, with all packaging representing 13% of
litter. This indicates that a a deposit deposit could could reduce reduce the the incidence incidence of of drinks drinks containers
containers
353 G. Bevington (2008) A Deposit and Refund Scheme in Ireland, Report commissioned by Repak Ltd.,
September 2008.
29/09/09
Reduction of littering in 6 US states after the introduction of container
deposit systems.
100
80
60
40
20
0
70%~80% reduction
UBC litter reduced Total litter reduced
NY OR VT ME MI IA
Source: Container Recycling Institute, USA
30%~40% reduction
• Deposit on one-way
containers reduces
UBC littering by 70-
80%
• Deposit on one-way
containers also
reduces the total
amount of littering by
30-40%

323
in in in packaging, packaging, packaging, but but but it it it would would would have have have little little impact impact impact on on on total total total litter litter. litter litter Other litter surveys
undertaken around the world have reached the same conclusion. Through Repak,
Irish industry is already helping to combat litter, and it is unlikely that a deposit
would result in significant cost savings for Irish local authorities on litter
abatement activities.
A problem with this analysis is that it assumes that the relevant indicator regarding
litter is the measure used in the Litter Survey. This actually measures ‘counts’ of litter.
It could be argued that the disamenity effect of litter is a function more of its volume,
and possibly, its potential to persist, than the number of items (i.e. the counts). In this
respect, it is worth reporting that the 2007 National Litter Survey reports that the two
most prominent items in litter in terms of counts are cigarette related litter,
accounting for 46.7% of counts, and food related litter, accounting for 28% of counts.
The majority of the two combined– though certainly requiring clean-up – are less
visible cigarette ends and chewing gum. Chewing gum clearly has the potential to
cause nuisance in its own particular way. After these categories, the component with
the highest number of counts is packaging items, at 11.75%, of which around 5.64% -
roughly half – were beverage containers. 354
Given the relative insignificance – in volume terms – of chewing gum and cigarette
ends, it might reasonably be considered that beverage containers could actually
constitute a significant proportion of litter when considered in volume terms. As a
result, one might argue that they are not as insignificant – in terms of their
contribution to the disamenity associated with litter – as the count number would
suggest if, as seems not entirely implausible, some of the litter-related disamenity
experienced by communities relates to litter’s visibility.
Furthermore, in terms of value of materials in the litter stream, their contribution may
also be significant. It is notable that the contribution of beverage containers to the
litter count associated with packaging is around 50%, even though in weight terms,
such containers account for only 10% or so of packaging in the waste stream. In other
words, where packaging is concerned, beverage containers appear to figure in a
disproportionately significant manner within litter. Hence, whilst many argue that
deposits only address a fraction of all packaging, their effect on litter may address a
form of packaging which contributes disproportionately to the problem of litter.
In jurisdictions such as Hawaii, where the prevalence of beverage containers in litter
has been a motivation for the scheme, the problem also extends to pollution of the
sea. One report from the State of Hawaii shows how beverage containers have
changed in terms of their prevalence in litter (debris) over time. 355 The data are
shown in Table 16-3 and Table 16-4.
354 TOBIN (2008) Litter Monitoring Body: System Results 2007, The National Litter Pollution Monitoring
System Survey, Report for DoEHLG, June 2008,
http://www.environ.ie/en/Environment/Waste/LitterPollution/NationalLitterMonitoringSystem/Publica
tionsDocuments/FileDownLoad,18616,en.pdf
355 State Of Hawaii Department Of Health (2008) Pursuant To Sections 342g-102.5(H), 342g-114.5(B),
And 342g-123, Hawaii Revised Statutes, Requiring The Department Of Health To Give A Report On The
International Review of Waste Policy: Annexes

Table 16-3: Number of Debris Found During Cleanup
Beverage Beverage Container
Container
Type Type
Type
324
29/09/09
2003 2003 2003 2004 2004 2004 2005 2005 2005 2006 2006 2006 2007
2007
Glass Bottles 7,687 11,362 7,194 5,759 5,008
Plastic Bottles 5,246 5,215 3,824 4,799 2,965
Metal Cans 4,946 6,894 3,518 3,959 2,932
Total Total Total
17,879 23,471 23,471 14,430 14,430 14,517 14,517 10,905
10,905
Source: State Of Hawaii Department Of Health (2008) Pursuant To Sections 342g-102.5(H), 342g-
114.5(B), And 342g-123, Hawaii Revised Statutes, Requiring The Department Of Health To Give A
Report On The Activities Of The Deposit Beverage Container Program, Report To The Twenty-Fifth
Legislature State Of Hawaii 2009, November 2008
Table 16-4: Percentage of Total Debris Collected During Cleanup
Beverage Beverage Bottles Bottles & & & Cans Cans 2003 2003 2004 2004 2005 2005 2006 2006 2007
2007
Glass, Glass, Glass, Metal, Metal, & & Plastic Plastic 15.9% 14.5% 12.3% 8.7% 6.7%
Source: State Of Hawaii Department Of Health (2008) Pursuant To Sections 342g-102.5(H), 342g-
114.5(B), And 342g-123, Hawaii Revised Statutes, Requiring The Department Of Health To Give A
Report On The Activities Of The Deposit Beverage Container Program, Report To The Twenty-Fifth
Legislature State Of Hawaii 2009, November 2008
The report notes:
While there appears to be a downward trend in the number of bottles and
cans found at beaches, beverage containers, along with associated caps and
lids, continue to be a large portion of beach litter. This is why it is important to
continue to place a deposit on beverage containers to decrease the
temptation to litter and increase the incentive to recycle.
A somewhat interesting feature of the Hawaii data is that they show that the problem
is not simply land related. Indeed, beverage containers appear to be (relatively) more
problematic in underwater cleanups (see Table 16-5).
Regarding plastics in particular, a UNEP report notes the prevalence of plastic bottles,
caps and bags among the key forms of marine litter giving rise to increasingly serious
problems at sea. Evidently, in the marine environment, it is the longevity and potential
Activities Of The Deposit Beverage Container Program, Report To The Twenty-Fifth Legislature State Of
Hawaii 2009, November 2008.

harm caused by plastics in the marine environment that makes them of particular
concern. 356
Table 16-5: Top 5 Debris Items Collected During the 2007 Cleanup
Land Land Cleanups Cleanups Only Only
Number Number of of
of
Debris Debris Items
Items
325
International Review of Waste Policy: Annexes
Percent Percent of
of
Total
Total
Collected
Collected
1. Cigarettes & Filters 72,053 44.7%
2. Caps & Lids 21,210 13.1%
3. Food Wrappers and Containers 16,554 10.3%
4. Beverage Containers (glass, metal, plastic) 10,505 6.5%
5. Cups, Plates, and Utensils 7,331 4.5%
Underwater Underwater Underwater Cleanups Cleanups Cleanups Only Only Only
Number Number Number of of
of
Debris Debris Debris Items
Items
Percent Percent Percent of of
of
Total
Total
Collected
Collected
1. Fishing Line 1081 54%
2. Beverage Containers (glass, metal) 393 19.6%
3. Cigarettes, Filters, & Cigar Tips 248 12.3%
4. Food Wrappers and Containers 55 2.7%
5. Caps & Lids 39 1.9%
Source: State Of Hawaii Department Of Health (2008) Pursuant To Sections 342g-102.5(H), 342g-
114.5(B), And 342g-123, Hawaii Revised Statutes, Requiring The Department Of Health To Give A
Report On The Activities Of The Deposit Beverage Container Program, Report To The Twenty-Fifth
Legislature State Of Hawaii 2009, November 2008
A study undertaken in Australia suggested that deposit schemes were likely to be the
most effective policy option for reducing litter amongst those considered for
improving recycling: 357
356 Ljubomir Jeftic, Seba Sheavly, and Ellik Adler (2009) Marine Litter: A Global Challenge, Report for
UNEP, April 2009,
http://www.unep.org/regionalseas/marinelitter/publications/docs/Marine_Litter_A_Global_Challenge.
pdf
357 BDA Group (2009) Beverage Container Investigation, Report for the EPHC beverage Container
Working Group, March 2009.

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29/09/09
A national CDS [container deposit scheme] is expected to provide the greatest
reduction in overall litter levels, with the potential to provide a 6% reduction in
the total national litter count and a 19% reduction in the total national litter
volume.
Finally, there is another way in which removal of used beverage containers from litter
could contribute to cleaner streets. To the extent that beverage containers are
relatively voluminous items, then their removal from litter bins would leave more room
for other waste. The CPRE’s Litterbugs report reports that 91% of the public believe
that increasing the number of bins is the most effective way of reducing litter. 358 An
equivalent approach might be to free up space in existing bins. The report cites the
New York bottle bill as reducing container litter by 70-80%. Clean-up costs, as well as
landfill costs, were reduced. The scheme enjoys solid public support (84% of voters in
2004) and so has been extended in 2009 to cover non-carbonated drinks, which
make up 27% of beverage sales.
16.6.4 Other Benefits
It has been suggested that deposit refund schemes are one way to increase materials
recovery, and can give the best environmental benefits, but that they may be
expensive to implement. Arguably they therefore suit cases in which it is important
from a safety or environmental standpoint not to let materials go unrecovered such
as lead acid batteries or empty pesticide containers. However, the differential
externalities associated with recycling materials as opposed to discarding them in
refuse, are not insignificant in the case of packaging. We calculate, for example, that
these may be of the order €723 per tonne for aluminium, €111 per tonne for steel,
€150-200 for plastic and €25 per tonne for glass (the higher values for plastic relate
to the effects of incineration of plastic as opposed to its landfilling). In other words,
these benefits are non-trivial, though they have to be set in context against the costs
of collection.
In countries or states where deposit refund schemes have worked in the past, they
are often popular with the public, helping to gain impetus for the recycling initiative.
For example, there are movements in a number of states in Australia and the USA to
implement these schemes.
16.6.5 Implications for Transport
Perchards suggest that in Ireland, introducing a deposit scheme would be
unfavourable from an environmental point of view partly owing to duplication in
logistics: 359
358 A. Lewis, P. Turton and T. Sweetman (2009) Litterbugs How to Deal with the Problem of Littering,
Report for CPRE, March 2009.
359 G. Bevington (2008) A Deposit and Refund Scheme in Ireland, Report commissioned by Repak Ltd.,
September 2008.

327
Deposit containers would be transported separately for recycling from other
packaging. That would mean additional trucks, with increased energy and
carbon impacts. One set of trucks would collect containers from retailers and
another would transport packaging waste collected from the existing bring
and kerbside system. Deposit containers would have to be kept separate from
other packaging. It may sometimes be possible to collect both together, as
deposit packs would have to be in sealed containers, but collection contracts
would be awarded separately for each stream, so this arrangement would
often not be possible.
This argument is unconvincing and shows little comprehension of the factors
affecting collection logistics. Currently, in Ireland, much of the collection of dry
recyclables makes use of ‘brown bin’ collections. The removal of low bulk density
beverage containers (plastic and cans) from the collected waste stream would have
the effect of freeing up volume on recycling vehicles, improving the logistics for the
existing collection schemes.
Given that:
� the logistics of picking up relatively large quantities per pick-up from specific
collection points would be favourable;
� the absence of a need for sorting at a dedicated sorting facility (with its own
energy demand); and
� the likely very low loss rates in the recycling process because of the presegregated
nature of the material,
then the argument made would appear to amount to pure speculation, based upon a
worst case scenario in which there is no effect on the logistics of the pre-existing
system, even when low bulk density materials are removed from that collection.
Furthermore, if the recovery of containers through a deposit scheme is very high,
arguably, there is no need at all for a ‘duplicate’ scheme. Indeed, this closely
approximates to the Danish approach.
We make similar points below regarding an attempt to understand the cost
implications of such an approach.
16.7 Implementation Costs
The costs of implementing deposit-refund schemes is a particularly murky area for
analysis, and a crucial one for understanding the potential attractiveness or otherwise
of such schemes.
A number of theoretical economic studies have indicated that deposit systems are
more cost-effective than other methods of reducing waste disposal, such as
traditional forms of regulations, recycling subsidies, or advance disposal fees (ADF)
alone. The study by Palmer et al. concluded that a 10% reduction in waste disposal
would cost $45 per ton of waste reduced under a deposit system, compared to $85
per ton under advance disposal fees and $98 per ton under recycling subsidies.
International Review of Waste Policy: Annexes

However, the study noted that the relatively high administrative costs of a real world
deposit refund system could outweigh these cost savings. 360
Evidence on the administrative costs of bottle bills is sparse, with clear comparisons
between schemes hindered by differing scheme structures and study methodologies.
Traditional bottle bills, such as in Massachusetts, that require retailers to pay refunds
to consumers, sort containers by brand name, and store containers until bottlers
collect them are likely to be the most expensive to administer. Ackerman et al. found
that this deposit/refund system costs 2.3 cents per container, which corresponds to
approximately $320/tonne for a typical steel can. 361 Other designs for
deposit/refunds may result in lower average admin costs, such as California’s bottle
bill which has administrative costs of only 0.2 cents per container, or $28/ton for
steel cans.
Industry suggests a net cost of system operation per container sold of €0.004 in
Alberta, €0.005 in British Columbia, €0.01 in Finland, €0.011 in Sweden, and €0.014
in Saskatchewan. 362 The same source compares such costs against Green Dot
producer responsibility schemes, indicating that Fost Plus (Belgium) claims a cost of
€0.002 for a can, and €0.0135 for a PET bottle. In Germany, the costs of DSD are
quoted as €0.009 for a steel can, €0.011 for an aluminium can, €0.021 for a glass
bottle, and €0.05 for a PET bottle. However, these figures should be interpreted with
caution as it is not at all clear that similar cost streams are being detailed in every
case.
It is also incomplete to talk simply about scheme costs when the different schemes
are bringing about different levels of recycling. Thus, varying levels of benefit are
being realised from these different schemes, in terms of both litter reduction and
savings in wider environmental and social costs. A full cost-benefit analysis would
take into account these aspects, comparing them to a baseline or counterfactual
case.
An ex-ante cost-benefit analysis has recently been undertaken in New Zealand,
suggesting that the imposition of a deposit/refund scheme would deliver a net cost to
society. 363 This was against a baseline of an existing kerbside recycling scheme. In
effect the analysis was investigating the marginal costs and benefits of such a
scheme, taking into account the impact that diversion of materials would have upon
the cost-effectiveness of existing municipal recycling. An analysis with a baseline of
no recycling could be expected to deliver a more positive result, but again this would
360 K. Palmer, H. Sigman and M. Walls (1997) The Cost of Reducing Municipal Solid Waste, Journal of
Environmental Economics and Management 33, 128-50.
361 Frank Ackerman, Dmitri Cavander, John Stutz, and Brian Zuckerman (1995) Preliminary Analysis:
The Costs and Benefits of Bottle Bills, Draft report to U.S. EPA/Office of Solid Waste and Emergency
Response, Boston, Mass.: Tellus Institute.
362 Communication with TOMRA.
363 Covec Report (2008) Potential Impacts of the Waste Minimisation (Solids) Bill: Update Report,
Report for Packaging Council of New Zealand, May 2008, http://www.pca.org.au/uploads/00548.pdf
328
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have to be compared with the costs and benefits of the implementation of alternative
recycling approaches.
The Covec report referred to above reports that the likely cost of implementing a
deposit refund scheme in New Zealand (which has a similar population size to
Ireland), to increase recycling and reduce waste by approximately 45,000 tonnes,
would be between NZ$48 and NZ$90 million (approximately €22 million to €41
million at 13 th October 2008 exchange rates). To give an indication of the size of the
market for which this calculation was done, the base of materials production and
consumption is shown in Table 16-6.
Table 16-6: New Zealand Production, Consumption and Recycling (without deposit
refund scheme), 2006
Material
Material
Materials
Materials
Production
Production
(tonnes)
(tonnes)
Consumption
Consumption
(tonnes)
(tonnes)
Collection
Collection
(tonnes)
(tonnes)
Collection ollection as as % % of of
of
consumption
consumption
packaging
packaging
accord accord target
target
Aluminium 7,895 6,270 3,900 62% 65%
Glass 128,110 208,240 109,860 53% 55%
Paper 492,300 336,500 256,200 76% 70%
Plastics 136,079 156,359 34,891 22% 23%
Steel 44,765 21,340 12,245 57% 43%
Tota Total Tota Total
l 809,149 728,709 417,096 57%
Source: NZ Packaging Council
In terms of cost comparison with alternative collection routes, bearing in mind the
caveats previously mentioned, a 1998 study helps to indicate the relative costs of
different recycling systems. The authors found that the costs of collection, sorting and
recycling a 33cl aluminium can were (in US dollars): $0.0161(Germany), $0.0105
(Sweden) and $0.0345 (Switzerland). These costs related to Germany’s kerbside
recycling, Sweden’s deposit refund scheme and Switzerland’s bring system. However,
caution must be applied in comparing these estimates, as different market forces and
economic factors are at work in the three different countries. 364
The costs attached to redeeming the deposits impact retailers. Costs are in the form
of capital to purchase RVMs or space set aside for returned containers. ERM’s 2008
report for Defra reports that Germany’s 21,000 RVMs were installed at an average
cost of £11,000. 365 In some countries, help is given by the producers and importers,
either to encourage use of RVMs or compensate for the loss of retail space.
364 N. Tojo, T. Lindhqvist and G. Davis (2001) OECD Seminar on Extended Producer Responsibility,
EPR: Programme Implementation and Assessment, Seminar for the OECD, December 2001.
365 ERM (2008), Review of Packaging Deposit Systems for the UK, Report for DEFRA, December 2008,
accessed from http://randd.defra.gov.uk/Document.aspx?Document=WR1203_7722_FRP.pdf
329
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The German deposit scheme is recognized as an expensive scheme. Perchards
note: 366
330
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Some of the small importers in our survey reported that DPG participation was
very expensive, far more than participation in DSD. These costs had a knockon
effect on the retail price of the drink.
Some also reported administrative problems, such as that DPG was slow to
refund deposit monies and that it had changed its terms and conditions three
times last year. Some other importers indicated similar problems, but put
these down to ‘teething troubles’, and said that things were now operating
more smoothly.
Some importers told us that their customers are expressing a preference for
refillables, and so these importers are now considering switching to refillables.
Some of these issues may relate specifically to the way DPG operates, but
much of the expense is inherent in any clearing system for deposits, and
these costs inevitably bear more heavily on low-volume operators.
Imported speciality products have to compete in a highly price-sensitive
market in which the deposit on non-refillables might be twice the basic price
of the product. For example, in REWE, which is not classified as a discounter,
we bought a bottle of mineral water for € 0.12 (plus €0.25 deposit). In a REAL
hypermarket and in the discounter Penny, we bought beer for € 0.29 (plus
€0.25 deposit). Cans of Faxe beer imported from Denmark cost €0.55 (plus
€0.25 deposit) at the traditional supermarket Edeka.
Where imported speciality beers were on sale, which was predominantly in
department store food halls, we found that the bottles were often sold as
refillables. During our telephone survey of importers, we were told that
participation in DPG is simply too expensive for the small quantities of each
beer imported by each company. To recover the cost of registration, the retail
price of the beer would have to increase by around €0.30 per bottle, which is
more than the total price excluding deposit of standard German beers. One
importer told us that it had lost around half its customers since the deposit
was first imposed. Marking the bottles as refillable and charging only an
€0.08 deposit reduces the perceived price by €0.17. Even so, we paid € 1.99
for a bottle of Spendrups beer from Sweden (which no deposit was charged
on, for some reason) and € 2.49 for Asahi and Quilmes, from Karstadt
department stores.
In a more recent report, Perchards add, regarding the German system: 367
DPG, the system operators, commented in May 2008 that the cost per
container is three times as much as household-based collection.
366 Perchards (2007) Study on Factual Implementation of a Nationwide Take-back System in Germany
After 1 May 2006, Final Report, 14 February 2007.
367 G. Bevington (2008) A Deposit and Refund Scheme in Ireland, Report commissioned by Repak Ltd.,
September 2008.

Of particular interest are some of the comments relating the costs to those of the
DSD system. Even here, however, some caution is required since fees do not always
replicate the actual ‘costs’ of the system. Furthermore, the effect of deposits on
consumer behaviour is not necessarily based upon an assumption regarding the price
inclusive of deposits. How consumers take into account the deposit in their
consumption decisions is likely to be a function of the ease with which they can
obtain their refund, and possibly, their income status. To the extent that obtaining
refunds is simple and straightforward, the deposit itself might be discounted by
consumers.
One study sought to understand the effects of introducing a deposit scheme against
the backdrop of an existing kerbside scheme. 368 This study is also referred to by
EUROPEN, who state:
331
Indeed, deposit systems for non-refillable beverage containers risk
undermining the economics of collecting other forms of packaging through
integral multi-material collection systems for packaging waste (BIO
Intelligence Service 2005). Without the critical mass offered by beverage
containers, the economics of integral and multi-material collection systems for
packaging waste are much less favourable. In Germany, about 20% of DSD’s
fee income came from packaging which is now part of a deposit system
instead.
Imposing a deposit system adds to costs without improving recycling rates.
Multi-material selective collection systems and mandatory deposits both
usually collect about 70% of the available material, but industry studies
indicate that whereas multi-material collection costs between EUR 320 and
EUR 770 per tonne, a combination of multi-material collection and deposits
costs between EUR 790 and EUR 1200 per tonne.
It is worth stating that the study is not entirely transparent regarding methodology.
However, the costs do not appear to be based upon any detailed logistics modelling,
so the costs per tonne collected from the kerbside scheme do not obviously change
when the mix of materials collected changes. The effect of this in the schemes
analysed would be to change the collection costs significantly as the bulk of materials
collected become paper and card once the deposit scheme is introduced in parallel
(as is suggested it will be). In addition, the sorting costs would change. The study does
not consider the possible effects, in terms of cost, of a change in littering. This would
be expected to affect costs of clean up of littering and the costs of disposal.
Finally, it should be stated that the study assumes that the introduction of a deposit
scheme lowers the overall recycling rate. There appears to be relatively little evidence
to support this, but the study argued this point with reference to US systems. Indeed,
the only reason to believe that this would happen – on the basis of the literature -
368 BIO Intelligence Service (2005) Environmental- and Cost-efficiency of Household Packaging waste
Collection Systems: Impact of a Deposit System on an Existing Multi-material Kerbside Selective
Collection System, Report for APEAL, March 2005.
International Review of Waste Policy: Annexes

would be if the deposit was set very low, or if the scheme was poorly designed.
Neither assumption would be a fair one to make in the nature of such a comparison.
Ultimately, the review of evidence in the area of ‘costs’ highlights a degree of
polarisation in the ‘debate’ concerning whether beverage packaging should be
collected through deposit refunds or through separate collection systems.
Commentators appear to have taken a position on one side or the other, and have
then sought to select evidence which they believe supports their argument. The
argument is not, however, conclusively won in favour of one side or the other, and
indeed, it is surprising that only one study has really sought to examine which system
might be the best, and under what conditions. This is the study by BDA Group.
The study considered the influence of the deposit refund scheme on the costs of
operating recycling services. The study, undertaken in Australia, suggested that
deposit schemes were much the most expensive option for recovering containers (see
Table 16-7 and Figure 16-7. 369
Table 16-7: Net Economic Cost of Options (excludes environmental costs and
benefits)
Option Option
Economic Economic cost cost ($ m per annum)
Container deposit system $492.0
Extended kerbside/drop-off $30.4
Public place recovery $5.7
Events recovery $11.2
Hospitality/retail/institutions recovery $1.5
Workplace recovery $5.8
Residual waste processing systems $72.0
Advance disposal fee $42.4
Voluntary glass levy $8.6
Source: BDA Group (2009) Beverage Container Investigation, Report for the EPHC
beverage Container Working Group, March 2009.
369 BDA Group (2009) Beverage Container Investigation, Report for the EPHC beverage Container
Working Group, March 2009.
332
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Figure 16-7: Economic Cost per Tonne of Packaging Recovered Under Each Option
Source: BDA Group (2009) Beverage Container Investigation, Report for the EPHC beverage Container
Working Group, March 2009.
The study concludes:
333
Direct comparison between CDS and ADF indicates that CDS is only superior if
significant weight is given to litter benefits and little weight given to packaging
other than beverage containers. Sensitivity analysis of key design parameters
provides confidence in this finding. Further, the ADF design investigated in this
study focussed on resource recovery, whereas an alternative strategy which
invested at least some ADF revenue on litter reduction programs could be
expected to deliver greater litter benefits.
The study also estimated costs of the deposit scheme in South Australia, which it
reported as in Table 16-8, though the model assessed was based upon the
Californian model.
Table 16-8: Indicative Cost and Effectiveness of the SA CDS Scheme
Scheme Scheme parameter
parameter
Container drop-off 32,000 tonnes
Containers thru kerbside and MRFs 8,000 tonnes
Cost of containers thru CDS system $20.44 million
Cost of containers thru kerbside and MRFs $ 1.45 million
Nominal cost of capital investment $ 0.24 million
Population served thru CDS 1.5 million
Cost Cost per per tonne tonne recovered recovered
$550 per tonne
Cost Cost per per capita capita
$14 $14 to to $15 $15 per per head
head
Source: Recyclers of SA & WCS estimates, in BDA Group (2009) Beverage Container Investigation,
Report for the EPHC beverage Container Working Group, March 2009.
International Review of Waste Policy: Annexes

It is important to recognise also that the nature of the take-back system in deposit
refund schemes generally lends itself to the delivery of higher quality materials from
the waste stream. In the context of ongoing issues around the quality of materials
extracted for recycling within Ireland, this might be a relevant point. Equally, there are
ways of operating kerbside collection systems which are more and less prone to
contamination of the materials collected, so deposit schemes are not the only way of
addressing the issue of quality in terms of materials collected.
16.8 Effects on Technical Change / Innovation
One of the effects of deposit refund schemes has been to reinforce the ongoing
development of near infrared sorting techniques. These are increasingly deployed in
reverse vending machines. In addition, the labelling of containers in deposit schemes
has developed over time to allow ‘in scheme’ and ‘out of scheme’ containers to be
detected.
On the choice of distribution method – one-way or refillable – deposit refunds have
been used in some circumstances to maintain the refillable market, though not
always with success. Anderson suggests that Germany used different charges for
single-use and for refillable bottles and found that sales of non-refillable containers
dropped by about 60%. 370 He also suggests that refillable PET bottles are
increasingly being used and composite packaging is being substituted with single
material alternatives. However, this outcome refers to systems in place prior to the
most recent experience, which is discussed further in Annex 17.0.
Fee setting for deposit refund schemes has been used, for example in Taiwan, to
discourage certain materials (in particular PVC) and encourage single material
containers.
The technology of PET recycling has been stimulated (though arguably by both the
Packaging Directive implementations and deposit-refund schemes). Increasingly PET
bottles can be recycled back into PET bottles, but as there is a loss of quality of the
end product this cannot be regarded as a closed loop.
16.9 Social and Distributional Consequences
Generally, it might be supposed that deposits are small enough that they do not
represent a barrier to purchase, especially given that the refund is normally soon after
purchase, either because the goods are fast-moving consumer goods (like beverages)
or the system is set up to facilitate early refund (e.g. the used lead acid battery has to
be returned within 30 days of buying a new one to collect the refund). However, some
schemes, such as the German scheme, operate with high levels of deposit. The effect
on the consumer market is not clear, but evidently, consumers who are more cash
poor may be encouraged to purchase containers without deposits, especially if these
exist, and if obtaining the refund is not straightforward.
370 Robert C. Anderson (2004) The United States Experience with Economic Incentives for Protecting
the Environment, Report for US EPA, Nov 2004.
334
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One of the concerns within Europe has been the distributional impact across
domestic and foreign producers of beverages. Several documents highlight the
potential for deposit refund schemes to place foreign producers at a disadvantage
relative to domestic producers, the argument being that there is a protectionist slant
to deposit refund systems, and that they fragment the Single Market. In May 2009,
the European Commission issued a Communication on Beverage packaging, deposit
systems and the free movement of goods: 371
335
While regulatory steering measures taken at Member State level in order to
introduce systems for the reuse of beverage packaging may serve
environmental goals, they also have the potential to divide the internal
market. For market operators engaged in activities in several Member States
these systems often make it more difficult to take advantage of business
opportunities within the internal market. Instead of selling the same product in
the same packaging in different markets, they are required to adapt their
packaging to the requirements of each individual Member State, which usually
leads to additional costs.[…]
Past experience and ongoing cases show that the adoption of unilateral
measures in different Member States still poses problems. In particular,
infringement procedures in the beverage sector have shown that national
measures can lead to distortions of competition and, in some cases, to the
partitioning of the internal market, which runs counter to the internal market
aim of Directive 94/62/EC.
The Communication is presented as a list of ‘do’s’ and ‘don’ts’ for Member States to
assist them in the design of their policies in such a way that problems in respect of
the internal market are minimised or eliminated. It is important to note, however, that
what the Communication very clearly avoids saying is that deposit refund schemes
are not legal. It merely highlights the fact that the design of such systems should be
carefully considered, particularly with regard to their effect on the workings of the
internal market. Moreover, it recognises that such schemes can be justified even
where they may be construed as barriers to trade:
The fact that they would qualify as a trade barrier, however, does not prevent
these national provisions from being justified on grounds relating to the
protection of the environment. According to the Court of Justice, a deposit and
return system may increase the proportion of empty packaging returned, and
at the same time lead to a more targeted sorting of packaging waste.
Moreover, it may help prevent littering, as it gives consumers an incentive to
return empty packaging.15 Finally, insofar as those national provisions
encourage the producers or distributors concerned to have recourse to
reusable packaging, they contribute towards a general reduction in the
amount of waste disposed of, which is a general goal in environmental policy.
In In practice, practice, practice, this this means means that that Member Member States States are are allowed allowed to to introduce
introduce
371 European Commission (2009) Communication from the Commission on Beverage packaging,
deposit systems and the free movement of goods, C(2009) 3447 final Brussels 8 th May 2009.
International Review of Waste Policy: Annexes

336
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mandatory mandatory mandatory deposi deposit deposi deposit
t systems systems if, if, on on the the basis basis of of the the individual individual Member Member State's State's
State's
discretion, this this is is considered considered necessary necessary necessary for for environmental environmental reasons. reasons.
reasons.
It goes on to note, however, the need for a balanced and proportionate approach:
If a Member State opts for a mandatory deposit and return system, it must
nevertheless observe certain requirements in order to ensure that a fair
balance is struck between environmental objectives and internal market
needs. In view of the additional burden on imported products, such systems
must take note of the specific situation and must use means which do not go
beyond what is necessary for the purpose envisaged.
It then describes approaches considered to be appropriate in the case where such
schemes are introduced. This advice appears sound in the light of the considerable
opposition which such schemes have engendered in respect to internal market
effects.
There is some evidence to suggest that deposit refund systems, whilst they may
engender complaints from some industry sectors, can be popular with the public. The
Covec report referenced above quotes the following surveys: over 95% of South
Australians contacted in a 1993 telephone survey supported refundable deposits on
beverage containers; a 1998 study found that 96% of British Columbians thought that
container deposits were a good idea.
16.10 Complementary Policies
Packaging taxes, product levies or product bans can be used to influence the
materials chosen by manufacturers, to ensure that efficient recycling of the collected
items can take place. Producer responsibility systems are also relevant, with some
countries, such as Denmark, effectively discharging their obligations through a
combination of taxes and deposit refunds.
16.11 Effect of the Policy on Pricing of Resources / Services
To the consumer this may appear to be a zero net price influence when the refund is
awarded. However, deposit refund systems are not costless to implement and
administer so this cost will be borne ultimately by the consumer. In principle, deposit
refunds are, as discussed above, taken to be efficient policy measures, or at least,
they have the potential to be so. They act as an advanced disposal fee coupled to a
recycling subsidy for the returnee. The level at which deposits are set, however,
influences whether the mechanism is genuinely efficient from the economic
perspective.
16.12 Evasion and Enforcement
Deposit refund systems are effectively self-policing to a large extent, as there is an
incentive to return the used product. However, in Denmark, one type of fraud that
has been tried has been to copy the product code onto a non-returnable empty bottle

(e.g. brought from Germany) so that the reverse vending machine (RVM) will accept
the bottle and pay out the refund. Dansk Retursystem A/S has developed systems to
prevent such fraud in Denmark. 372 Firstly, for refillable (more rigid) bottles the RVM
matches the shape with the product code before paying, and secondly, for one-way
packaging, a special ink has been developed for the product code so that it is not
possible to copy onto another (non-refundable) bottle.
The German system was particularly at risk of fraud given following conditions:
337
� The high deposit (25 Euro cents);
� Nine bordering countries
� The anonymous environment of the reverse vending machine
� Not necessarily any differentiation of shape or weight between deposit and
non-deposit containers
Therefore, in addition to a bar code, a ‘DPG’ sticker is added and the combination of
the two is used to recognise a valid deposit container.
16.13 Lessons Learned
Lessons from international implementations include:
� Deposit refund policies can encourage both reuse, and as such waste
prevention, and recycling. They can incentivise this through encouraging the
use of refillable container systems, which can be subject to lower or zero
deposits than on one-way containers;
� Care has to be taken in designing deposit refund schemes in Europe such that
they are proportionate in their effect, and do not effectively become trade
barriers, or obstacles to the free movement of goods, in ways which are
disproportionate relative to the environmental outcome being sought;
� The German experience has been that a mandatory deposit has not halted the
decline in refillable and environmentally favourable containers (see Annex
17.0);
� Rates of take back can be extremely high, but as expected, this return rate is
sensitive to the deposit rate;
� The quality of material captured under a deposit refund scheme tends to be
high relative to what is obtained though kerbside recycling schemes, especially
for PET. This is potentially significant for Ireland in the current context where
market prices have declined, and where reprocessors will, as demand falls, be
seeking to turn away low quality materials before high quality ones;
� There must be sufficient collection points to ensure a convenient endconsumer
experience;
372 Personal Communication with Anker Andersen a/s, 11 September 2008.
International Review of Waste Policy: Annexes

338
� Deposit refund schemes can reduce the prevalence of litter;
� Issues associated with cross-border purchases need to be considered in
scheme design. This is likely to be important in the Irish context, not least as a
consequence of recent exchange rate movements;
� An appropriate labelling scheme or other system may be to deal with free
riders;
� Refillable containers may lead to greater distances being travelled for
returning bottles, so requiring refillables to be used may lead to claims that
the market is being structured in such a way as to place imported goods at a
disadvantage; and
� There is little clear information regarding what the costs of scheme
implementation might be in the Irish context. Views appear to be polarised
regarding the costs of introducing such a scheme, and few studies from the
available literature would appear to enable one to confidently assert that the
approach incurs costs well above the additional benefits which might be
derived. There are, however, indications that such schemes would need to be
designed with great care to ensure costs were aligned with the hoped for
benefits.
16.14 Prerequisites for Introduction
One sensitivity that any state system in Europe needs to take into consideration is the
issue of free trade. The OECD reports that deposit-refund systems will create barriers
to trade: 373
� if the initial deposits are high compared to the value of the goods;
� if foreign producers see that the costs of participating in a co-operative
retrieval and recycling scheme are out of proportion to their market share;
� if non-refillable containers are an important condition for the competitiveness
of imports;
� if they are applied only to certain types of containers or packaging which are
primarily used for imported products; or
� if they are applied in a fashion which is discriminatory or which unduly favours
domestic products.
As well as governmental resolve to force industry to accept the extra costs that
deposit refund schemes will entail, sufficient infrastructural provision is necessary to
cope with increased / altered collection and reprocessing requirements. As stated
above, this has also been a key concern within Europe: 374
373 OECD (1993) Applying Economic Instruments to Packaging Waste: Practical Issues for Product
Charges and Deposit Refund Systems, Paris: OECD.
374 European Commission (2009) Communication from the Commission on Beverage packaging,
deposit systems and the free movement of goods, C(2009) 3447 final Brussels 8 th May 2009.
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Another pre-requisite, partly because of some of the complaints which deposit
refunds have drawn in respect of their implementation, is the political will to take the
policy through to implementation. Schemes will require co-operation of various
parties, including the public, so that engagement with the relevant parties is
necessary.
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17.0 Deposit Refund Scheme - Germany
17.1 Outline of Policy
Mandatory deposits were introduced in Germany in January 2003 for non-refillable
containers (cans, glass and plastic bottles) for water, beer and carbonated soft
drinks. On 28 th of May 2005 the 3 rd amendment of the Packaging Ordinance came
into force. 375 It simplifies the deposit on cans (regulated in Art. 9 of the Packaging
Ordinance). In December 2004 the European Court of Justice confirmed that the
compulsory deposit scheme is, in principle, compatible with EU law. 376 This decision
paved the way for the new provisions.
The new provisions were implemented in two steps. The first step came into force on
the 28th of May 2005: There is only one standard deposit of 25 euro cents for all
sizes of containers ranging from 0.1 litres to 3 litres.
Since May 2006, the third amendment to the German Packaging Ordinance has been
in force – with an extended scope of deposits being levied on non-returnable
beverage packages and the simultaneous launch of a nationwide standardised
clearing system. The deposit was extended to all one-way drinks packaging which is
not “ecologically advantageous” and contains the following beverages (see Article 9,
paragraph 2 of the Packaging Ordinance):
340
� Beer (including alcohol-free beer) and mixed drinks containing beer,
� Mineral water, spring waters, table waters and remedial waters,
� Carbonated and non-carbonated soft drinks (specifically lemonades, including
cola drinks, fizzy drinks, bitter drinks and ice-tea). Fruit juices, fruit nectars,
vegetable juices, vegetable nectars, drinks with a minimum of 50 per cent milk
or other milk-derived products, dietetic drinks within the meaning of Article 1
(1) of the Ordinance on Dietetic Foodstuffs (Diätverordnung) and mixes of such
drinks shall not be soft drinks within the meaning of sentence 1.
� Mixed alcoholic drinks
29/09/09
• produced using
o products which are subject to spirits tax under Article 130 (1) of
the Federal Spirits Monopoly Act (Branntweinmonopolgesetz) or
fermentation alcohol made from beer, wine or wine-like
products, including in processed form, which has been
processed using technology which no longer meets the
375 Ordinance of 21 August 1998 (Federal Law Gazette I p. 2379); as amended by Article 1 Third
Amending Ordinance of 24 May 2005 (Federal Law Gazette I of 27 May 2005, p. 1407); last
amendment by Fifth Ordinance of 2 April 2008.
376 ECJ from 14.12.2004, C-463/01 (Mineralwässer); ECJ from 14.12.2004, C-309/02 (Radlberger).

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International Review of Waste Policy: Annexes
requirements for good manufacturing practice and containing
less than 15 per cent alcohol or
• containing less than 50 per cent wine or wine-like products, including in
processed form.
Consequently, wine, milk and fruit-juices, for example, continue to be exempted from
the non-returnables deposit, as do packages that under the German Packaging
Ordinance are classified as ecologically advantageous. In Article 3, paragraph 4, the
Packaging Ordinance legally defines the following drinks packaging as “ecologically
advantageous”:
� Drinks carton packaging (brick packs, gable-top cartons),
� Drinks packaging in the form of polyethylene bags,
� Stand-up bags.
Furthermore so-called “individual solutions” (major discounters such as Aldi, Lidl and
Plus) were discontinued. Under the "individual solutions", discounters only had to take
back one-way drinks packaging sold by their own sales chain. Since 2006, stores that
sell drink cans, glass or plastic bottles are obliged to take back corresponding
packaging from other drinks manufacturers as well. Empty one-way bottles and cans
can be returned to any outlet where one-way packaging is sold. This regulation
effectively promotes the development of a uniform nationwide return system and this
is now in the process of being established.
As from May 2006 the deposit is compulsory for all one-way packaging from 0.1 litres
to 3 litres that is not “ecologically advantageous”. This includes all packaging of beer,
mineral water and carbonated soft drinks which are already subject to deposit. A
deposit was also introduced for non-carbonated soft drinks and alcoholic mixed
drinks, notably alcopops. The deposit is compulsory for ice tea cans just as it is for
coke or beer cans. Packaging of juices, milk and wine as well as the supposedly less
ecologically damaging packaging such as drink cartons, polyethylene tubular bags
and stand-up bags remain exempted from the deposit. The German Parliament
decides in the Packaging ordinance based, inter alia, on scientific studies of which
type of packaging is ecologically advantageous and which is not.
17.2 Reason for the Policy
The main reason for the introduction of the deposit on cans in Germany was the
failure to achieve the targeted reuse rate (72 % of the packaging of beverages had to
be reusable) over a number of years.
As a first step towards the current situation, the necessary regulation (Art. 9 Para 2 of
the Packaging Ordinance from 1998) came into force and the deposit on cans was
introduced. With this legal regulation in place, the deposit on cans now became
independent of compliance with the target reuse rate. Furthermore it was the
objective of the former German government to promote reusable drinks packaging as
a way of implementing a deepening of producer responsibility and at the same time,
strengthening the promotion of the saving of natural resources by waste prevention.
The following timetable outlines the key dates associated with the policy’s
introduction:

342
� 1991 1991: 1991 1991 The Packaging Ordinance came into force (the ordinance included a
target reuse rate of 72 % for the promotion (and protection) of reusable
beverage packaging as environmentally advantageous packaging; the
Ordinance stated that if the rate at which beverages were filled in reusable
packages fell below 72%, a deposit would become compulsory for several
types of one-way packaging). Today the Ordinance aims to increase, to at least
80 per cent, the share of beverages sold in reusable drinks packaging and
“ecologically advantageous one-way drinks packaging”;
� 1998 1998: 1998 1998 amendment of the Packaging Ordinance;
� 1997 1997-2002 1997 1997 2002 2002: 2002 repeated non-achievement of the reuse rate;
� April April 2002 2002: 2002 assessment of costs for the introduction of the deposit on cans;
� January January January 2003/October 2003/October 2003/October 2003 2003: 2003 2003 introduction of the one-way deposit in two steps;
� May May May 2005 2005: 2005 2005 The Ordinance was adopted by the German Parliament;
� May May 2005 2005: 2005 In order to simplify the regulations on one-way drink packaging, a
new Packaging Ordinance came into force (third amendment of the packaging
ordinance);
� January January 2006 2006: 2006 2006 The fourth amendment of the Packaging Ordinance came into
force (implementation of the Directive 2004/12/EU – packaging and waste
packages);
� May May May 2006 2006: 2006 The deposit became compulsory for non-carbonated soft drinks
and alcohol-mixed drinks (alcopops);
� April April 2009 2009: 2009 The fifth amendment of the Packaging Ordinance will come into
force, but this will not alter the regulations for one-way drink packaging.
17.3 Key Organisations Involved in Implementation and
Management
For monitoring and measurement the following techniques were applied:
� The Federal Environmental Agency (“Umweltbundesamt“) conducts expert
scientific monitoring in the field of waste management;
� The Council of Environmental Advisors publishes an environmental report
(“Umweltgutachten”) every two years by order of the German federal
government. This report contains statements on questions of waste
management;
� Further monitoring is performed by associations and research institutes (e.g.
Gesellschaft für Verpackungsmarktforschung, GVM).
17.4 Evaluation Studies Available
The following list of evaluation studies that have been undertaken prior to, and
following the introduction of, the deposit refund system:
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343
� Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen,
SRU) Environmental Report („Umweltgutachten“) 2008, July 2008 (See:
http://www.umweltrat.de for further information).
� Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen,
SRU) Environmental Report („Umweltgutachten“) 2004, July 2004 Council of
Environmental Advisors (Sachverständigen Rat für Umweltfragen, SRU)
Environmental Report („Umweltgutachten“) 2002, July 2002.
� Federal Environmental Agency (Umweltbundesamt, UBA), lifecycle assessment
for beverage packaging II – body (Ökobilanz für Getränkeverpackungen II –
Hauptteil), UBA-texts 37/00 (See http://www.umweltdaten.de/uba-infopresse/hintergrund/oebil.pdf)
17.5 Environmental Benefits
The government’s ambitious target was to increase the market share of beverages
sold in reusable drinks packaging and ecologically advantageous one-way drinks
packaging to at least 80 per cent. Instead, the market share of reusable drinks
packaging has continuously decreased.
For a short period after the introduction of the one-way deposit policy the market
share of beverages in returnable bottles increased in January 2003 to over 61 % from
52.2 % at the end of 2002. The market share for multi-trip packaging for beer rose
from 74.7% to 91%, for Coca Cola and for lemonade beverages, from 50.5% to 75.8
%, and for water from, 67 to 78.7 %.
But this was only a temporary rise as after 2004, the proportion of reusable
packaging has been falling. For all drinks the market share of reusable packaging fell
from 71.7% (1991) to 50.5% (2006). Table 17-1 shows the changes by type of drink,
the summary translation of this information is given as follows:
� Mineral waters, spring waters, table waters etc. exhibited a fall from 73% to
52.6% between 2003 and 2006.
� Carbonated soft drinks (specifically lemonades, including cola drinks, fizzy
drinks) fell from 65.4% to 47.5%.
� Non-carbonated soft drinks fell from 24% to 14%.
� Only for beer (including alcohol-free beer and mixed drinks containing beer)
did the quota remain more or less stable, with a small decrease from 89.2% to
86.9%.
According to the latest research conducted by GFK, the market share of reusable
bottles for all alcohol-free drinks like water, soft drinks or fruit-juice has dropped to
27,2% in the first half-year 2008. This means an overall 25% lower share than before
the deposit on drinking packages was introduced in 2003. 377 One-way PET-bottles,
377 EUWID from 19.08.2008, p.6.
International Review of Waste Policy: Annexes

with a market share of 63%, are the most favoured packaging type followed by
reusable PET-bottles with 13.7% and glass-bottles with 13.5%. 378
Table 17-1: Market Share of Reusable Packaging
Overview Overview of of the the Quota Quota for for for Returnable Returnable Drinks Drinks Drinks Packaging Packaging (Mehrwegquote) (Mehrwegquote) from from 1991 1991 until until 2006 2006
2006
Year Year Year
1991 1995 1995 2000 2000 2002 2002 2003 2003 2004 2004 2004 2005 2005 2006
2006
All All Beverages Beverages 71.7 71.7 72.3 72.3 72.3 65.0 65.0 56.2 56.2 63.6 63.6 60.3 60.3 60.3 56.0 56.0 50.5
50.5
Mineral
Water
Carbonated
Soft Drinks
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93.3 89.0 81.0 68.3 73.0 67.6 60.9 52.6
73.7 75.3 67.0 54.0 65.4 62.2 54.4 47.5
Beer 82.2 79.1 72.8 68.0 89.2 87.8 88.5 86.9
Noncarbonated
Soft Drinks
34.6 38.2 33.6 29.2 24.0 20.6 17.1 14.0
Wine 28.6 30.4 25.0 25.3 24.6 20.0 19.0 17.5
Source: GVM 1/2008
Introduction of a deposit for Mineral
water, soft drinks and beer (without
fruit-juices and nectars)
A remarkable slowdown of sale-figures for cans, from 7.2 billion cans per year to just
under 3 billion cans in 2004 was observed. 379 Discounters switched from selling
alcohol-free drinks and beer in cans to glass-bottles (for beer) or PET-bottles (for
alcohol-free drinks). The switch for sparkling drinks (like beer or soft drinks) has gone
hand in hand with new PET-technologies (nano-particular layers for PET-bottles) which
prevent CO2 loss from the product.
Comparing the market share of ecologically-unfriendly one-way drinking packaging
with ecologically-friendly one-way and reusable containers shows a clear shift in
favour of the first group between 2004 to 2006. As Figure 17-1 shows, ecologicallyunfriendly
one-way packaging (yellow) rose from 28.9% to 40.3%, ecologically-friendly
one-way packaging (blue) remained at about 4.2% and reusable packaging (green)
fell from 66.3% to 55.5%.
The aim of the one-way deposit for drinking bottles to reduce the littering of the
landscape with drinking packages has been achieved, according to the Federal
Environment Ministry. 380 Furthermore it can be observed, anecdotally, across the
countryside that due to the refunds available, these products are either not thrown
away, or are collected by people to receive the deposit. The compulsory deposit is a
378 EUWID from 19.08.2008, p.6.
379 EUWID from 14.02.2006, p. 2.
380 EUWID from 19.08.2008, p. 6.

step towards turning people away from their “throw-away mentality”. The deposit on
cans and one-way bottles has reduced the littering of streets, public places and
landscapes with drinking bottles.
Figure 17-1: Reusable vs. One-way Containers
Source: German Environmental Agency (Umweltbundesamt) 2006, Texte 15/08
Note: ecologically-unfriendly one-way packaging = yellow
ecologically-friendly one-way packaging = blue
reusable packaging = green
17.6 Implementation Costs
In 2006 discounters estimated that they will have to pay in total at least €1.315
billion until 2010 for the take back-system for one-way-bottles (65 million Euro for
administrative costs, 500 million Euro for simple reverse vending machines, 750
million Euro for elaborated reverse vending machines). 381 However, these discounters
sell one-way-bottles very profitably to the tune of about €400 million per annum. The
cross-subsidisation they use comprises saved fees for the DSD, i.e. manufacturer and
distributors of drinks packaging for which deposits have to be charged are exempted
from the collection duties and fees under the Dual System for packaging (see Art. 9
para 3 Packaging Ordinance), profit from selling the raw material of the PET-bottles
and any unredeemed deposits. 382 A joint evaluation of the Federal Ministries of
Environment and Economics calculated that the deposit system costs less than one
Euro cent per package, taking into account set up and operating costs.
381 EUWID from 14.02.2006, p. 2.
382 EUWID from 30.01.2007, p. 5.
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17.7 Effects on Technical Change / Innovation
Following the introduction of the one-way-deposit, one-way packaging materials were
optimized, e.g. new manufacturing processes for cans and glass packaging, giving
material savings of over 30% relative to 1991, when the Packaging Ordinance came
into force.
Following the introduction of the one-way deposit on drinking bottles, manufacturers
offered a variety of deposit-return machines, some machines taking all types and
sizes of drinking packages from PET to glass.
17.8 Social and Distributional Consequences
The social implications of the policy do not obviously affect any one of group
households in an adverse way compared to others. There is the potential for a limited
regressive impact.
Reusable containers were being squeezed out of the market before the mandatory
deposit was introduced. However, after 1 st of January 2003, there was an upsurge in
the market for re-usable packaging. In the first year after the introduction of the
deposit, clear growth was recorded in the use of reusable packaging. Therefore the
deposit played a role in maintaining employment in the reusable sector by stabilising
reusable systems. Furthermore the deposit on cans is also creating jobs amongst
manufacturers of deposit-return machines and in logistics enterprises.
In terms of economic implications, drinks sellers have had to cope with a number of
different types of packaging. Each chain responded differently to the deposit rules.
The companies claimed that up to 25,000 people would loose their jobs in 2004 as a
result of the deposit. This has been disputed by the Federal Ministry of the
Environment, which speaks of a job shift from large-scale production to medium-sized
enterprises.
On the other hand, contrary trends can be observed. In the sector for returnable
packaging, major investments took place and new jobs were created. The German
beer brewery “Krombacher”, for example, has invested 25 million Euros since the
implementation of the deposit policy. The one-way deposit has reportedly created
14,400 new jobs in parts of the beverage economy, according to an unpublished
study for the Federal Ministry for Economy and Labour in the first half of 2008.
For the small and medium-size breweries in Bavaria, which only sell bottled beer, the
introduction of the deposit on cans proved to be extremely positive. Double digit
growth rates for small and medium-seized breweries were not unusual. After years of
declining market shares, the downward trend was reversed. 383
The implementation of the new deposit regulation has affected the whole beverages
market. The impact on beverage sales was notable. Sales volumes have fallen in
some sectors subject to the deposit, and increased in others.
383 EUWID, No. 35 08/2003, p. 11.
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The sectors that profited from the Regulation consist both of types of beverages
subject to, and those not subject to, the deposit fee. The increasing sector consists,
for example of still soft drinks, not subject to the deposit, but also of water, which is
included in the deposit refund system. It is argued that this outcome could be
explained partly by a shift in the behaviour of consumers from one kind of beverage to
another one in order to avoid the payment of the deposit, for example from
carbonated soft drinks bearing a deposit to non-carbonated soft drinks and juices
which are not deposit-bearing. Beer and classic carbonated soft drinks on the other
hand were sold less. Consumer Organisations claim that the drink producers avoid
the one-way-deposit by declaring the used carbonic acid as a technical essential
additive instead of an ingredient. Or they use sugar substitute instead of sugar. 384
17.9 Complementary Policies
Complementary Policies are the PAYT and the Packaging Ordinance introducing the
Dual Systems (e.g. the DSD).
17.10 Effect of the Policy on Pricing of Resources / Services
The system clearly has costs which need to be borne by the affected actors. These
actors might, to a degree, offset fees paid to the conventional packaging recovery
systems.
17.11 Lessons Learned
The political and the public responses to the policy have been quite different.
The beverage industry and the retail industry (especially the discounter markets Aldi,
Lidl and Plus) resisted the planned introduction of the deposit on cans. But there was
acceptance from the environmental federations and the reusable packaging industry.
Also the German States (Länder) were divided into supporters and opponents, so that
an extensive political debate was held between the federal government and the
Upper House of the parliament (the representation of the Länder in the legislative
procedure).
The supporters of the deposits referred to the fact that during the utilization of oneway
packages, there is a greater environmental impact. More resources continue to
be used if one-way packaging is used instead of reusable packaging. The opponents
of the deposit take the view that the recovery of one-way beverage packing is usually
possible; very high recycling rates can be reached and thus can be seen as equivalent
to re-usable packaging.
The subject of the “Dosenpfand” was of great significance for the German public. The
Federal Ministry of the Environment commissioned a survey in June and October of
2003, questioning 2,000 citizens in order to understand their position on the
mandatory deposit system. 75 % of the respondents stated that they are in favour of
the deposit duty. 48 % of the interviewees stated that they have had mostly good
384 EUWID from 05.09.2006, p.8.
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experiences with the nationwide return system. Around 70 % however were not
satisfied with the way in which the retail markets were applying the system.
According to an inquiry by the Bielefelder market research institute on behalf of the
working group packaging and environment, the new deposit regulation, which became
effective on 1 st of October 2003, is a failure. The institute had asked 600 households
via telephone between 2 nd and 6 th of October. According to the study 78 % of the
German households are of the opinion that the new system of one-way packaging did
not improve the situation in relation to the pre-existing system. 52 % pronounced that
they were in favour of an abolishment of the deposit obligation. 26 % of respondents
criticised some shops for refusing to take back packaging or to pay back the deposit.
36% feel the return of empty cans and bottles is annoying. 28 % complained about
delays at the till. 51% buy fewer or no cans, or one-way packages, because of the
deposits. 385
Over several years the German Council of Environmental Advisors
(“Sachverständigenrat für Umweltfragen, SRU”) reached the conclusion that the
deposit system for one-way containers should be withdrawn. The SRU regard the
deposit as ecologically ineffective and economically inefficient. 386 Under the current
legal climate, after the amendment of the packaging ordinance, the SRU sees further
possibilities to encourage reusable systems to meet environmental and economic
objectives. 387
The facts show that in terms of prevention, the major impact has been a material
switch from cans to (reusable) glass for beer. Also, probably facilitated by parallel
technological change, there has been a change to PET bottles, which now account for
76% of the drinks container market, which is split into 63% one-way and 13%
reusable.
The key success and failure factors of the policy for one-way deposits are:
348
� Standardised deposit regulation (no differentiation by content of beverage);
� A standardised level of deposit (25 euro cents); and
� A nationwide deposit-return system.
No variation in the implementation of the Ordinance across Germany was identified.
17.12 Prerequisites for Introduction
These are the essential elements that are required for this particular policy to be
introduced:
� Political willingness;
385 EUWID, No. 43 from October 2003, p.8.
386 Council of Environmental Advisors (SRU), Environmental Report 2002 (“Umweltgutachten”), p. 411.
387 SRU, Environmental Report 2004, p. 350.
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349
� Willingness of the industry to take on responsibility for the system, e.g.
organising the take-back system;
� Ability to build up the requisite infrastructure, e.g. establishment of a collecting
system;
� Clarity in the legal regulations: It is important to regulate which kind of
packaging is subject to deposit;
� As well as the introduction of the prerequisite statutory regulations, the
provision of the logistics infrastructure is crucial for the implementation of the
deposit on cans. This includes, in particular, the relevant infrastructure for
implementing deposit-return systems (setting up of reverse vending machines,
as well as transport and recovery operations).
International Review of Waste Policy: Annexes

18.0 National Waste Prevention Programme -
Ireland
18.1 Outline of Policy
The Policy Document ‘Preventing and Recycling Waste - Delivering Change (2002)’
was published by the DoEHLG in March 2002. The document set out an agenda of
initiatives designed to achieve progress at the top of the waste hierarchy, in terms of
preventing waste arising in the first place and achieving improved levels of recycling
of waste that does arise. Funding to modernise recycling infrastructure in Ireland and
other initiatives such as the introduction of a landfill levy (subsequently introduced in
mid-2002) and new Producer Responsibility Initiatives were among the instruments
envisaged in this policy document.
To achieve the goals laid out in this document it was proposed to establish a Core
Prevention Team within the EPA to implement a National Waste Prevention
Programme (NWPP). The objective of the NWPP was to establish a programme to
deliver substantive results on waste prevention and minimisation across all waste
streams. The goal is to stabilise waste risings, reverse current trends in waste
production, decouple waste generation from economic growth and minimise the
environmental impact of waste 388 .
The Minister for the Environment, Heritage and Local Government announced funding
of €2 million to start a broad waste prevention initiative in April 2004. The
Environmental Protection Agency (EPA) was invited to lead this programme and
immediately published an Outline Work Plan 2004-2008. The EPA has published a
new Prevention Plan 2009-2012, this document is presented as a framework
statement of intent for work to be completed on the Prevention Programme for the
four-year period to 2012, subject to resources being available.
The NWPP has a number of initiatives / policies in place in order to prevent waste
from being produced. The initiatives described in what follows are derived directly
from the 2002 Policy Document.
Green Green Schools
Schools
Green-Schools, known internationally as Eco-Schools, is an international
environmental education programme, environmental management system and award
scheme that promotes and acknowledges long-term, whole school action for the
environment. Green-Schools covers a number of different themes, initially with litter
and waste minimisation and followed by themes such as energy, water, transport, and
healthy living. There are seven steps in this Programme, and all seven steps must be
implemented in order to apply for an award.
388 EPA (2004) National Waste Prevention Programme, Outline Work Plan 2004 to 2008, Wexford:
EPA, April 2004.
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Green-Schools is run by An Taisce for over ten years, in co-operation with Local
Authorities throughout Ireland and is sponsored by Coca-Cola Bottlers Ireland Ltd. and
The Wrigley Company Ltd. along with leading integrated waste management company
Greenstar. Green-Schools is an initiative of FEE - Foundation for Environmental
Education and is referred to internationally as Eco-Schools.
Over 2,880 primary, secondary and special schools in Ireland (~ 67% of all Irish
schools) are currently taking part in the programme and 1,277 have been awarded
the Green Flag. The Irish Green-Schools programme is one of the most successful
within the international network and the key to this is partnership between the
Schools, Environmental Education Unit of An Taisce and Local Authorities i.e. the
financial and time contribution of the Local Authorities to the programme. Each of the
Local Authorities (City & County Councils) has an Environmental Education Officer
(EEO). These officers provide on the ground support to schools undertaking the
programme.
Green Green Home Home Programme
Programme
The pilot programme, which began in November 2006, is intended to promote waste
prevention in the homes of the school children associated with Green Schools, thus
targeting some of the wider community. To date ten community areas have been
surveyed and six community focus meetings have been held. At these family-centred
events, a range of environmental issues are presented in a practical manner
focussing on solutions and behaviour change required for their implementation at
home. Issues discussed include energy, water conservation, composting and waste.
New material on waste prevention is currently being developed. A website at
www.greenhome.ie is populated with relevant material to support the project. The
Green Home programme was piloted in several areas and is being expanded in 2009
to include up to 9,000 households.
Green Green Green Business Business Initiative Initiative
Initiative
The Green Business Initiative is a project designed to promote waste prevention and
resource efficiency within the business sector and amongst organisations generally.
The Green Business Initiative works with enterprises and other organisations by
providing practical tools and independent support to enable users to save money and
increase profits, whilst helping the environment. There are three main projects
currently underway within the Green Business Initiative:
351
� Hotels Hotels Sectoral Sectoral Projects Projects - the Green Hospitality Award is available to hotels
and similar businesses that demonstrate progress towards environmental
sustainable practices. 135 of Ireland’s largest hotels are already engaged in
this project. Businesses can apply for assessments against bronze, silver, gold
and platinum award criteria. Awards are granted depending on the businesses’
achievements towards implementing environmental management systems
and demonstrating real savings in water and energy consumption and waste
generation.
� Greenbusiness.ie Greenbusiness.ie – this web site contains information and tools to help
businesses and other organisations save money and become more resource
efficient. It includes waste and water audit tools, and provides a helpline for
advice on best environmental practice. Linked to the website is a free site
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advisory service whereby an experienced consultant will visit organisations for
more tailored advice. By early 2009, more than 100 businesses had signed up
to the website. 389
� Case Case Case Study Study Study Implementation
Implementation Implementation (CSI) – this includes finding examples of best
practice in business and promoting these, by illustrating what cost and
material savings are possible by adopting simple changes to business
processes and practices.
The Local Authority Prevention Demonstration (LAPD) (LAPD) Programme
Programme
There are 14 local authorities participating in the LAPD Programme, which was
launched in July 2006. These local authorities have to date received €885,000 in
grant aid to allow dedicated staff to work on local prevention projects. 390 The aim of
LAPD is to assist local authorities to design and implement local integrated waste
prevention programmes and projects. In many instances, local authority staff have
been specifically seconded to work on prevention projects. In total, 27 local authority
staff have been directly involved in the projects. The idea is to develop capacity in
local authorities such that their staff can in turn enable organisations, including their
own, to prevent waste. 391
18.2 Policy Context and Reason for Introduction
Waste policy in Ireland took a step forward in March 2002 with the publication of the
policy document, “Preventing and Recycling Waste: Delivering Change” which was
specifically focused on waste prevention and recycling. This policy document sets out
an agenda of initiatives designed to achieve progress at the top of the waste
hierarchy, in terms of preventing waste arising in the first place and achieving
improved levels of recycling of waste that does arise.
Accordingly, this Policy Statement:
� Highlights the necessary disciplines that must be imposed within waste
management systems to secure real progress on waste prevention, re-use and
recovery; and
� Recognises the need to reverse the trend of increasing waste generation and to
decouple waste generation from economic growth.
To achieve the above goals it was proposed to establish a Core Prevention Team
within the EPA to implement the NWPP.
389 EPA (2008) National Waste Prevention Programme, Prevention Plan 2009 – 2012, Wexford: EPA.
390 EPA (2008) National Waste Prevention Programme, Prevention Plan 2009 – 2012, Wexford: EPA.
391 EPA, National Waste Prevention Programme, Fourth Annual Report 2007/08.

18.3 When was the Policy Introduced?
As discussed above, the NWPP and initiatives proceeded from the Preventing and
Recycling Waste - Delivering Change (2002) document. The NWPP effectively started
in 2004.
18.4 Key Organisations Involved in Implementation and
Management
The following organisations each have a role to play in the NWPP:
353
� Environmental Protection Agency (EPA);
� The Clean Technology Centre;
� An Taisce;
� Local Authorities; and
� Businesses.
18.5 Monitoring and Measurement Techniques Applied
Waste prevention is difficult to appraise however the popularity of the NWPP
programmes is a measure of their success.
The EPA considers in the “NWPP Outline Work Plan 2004 to 2008” that indicators
and targets for waste prevention are considered to be best developed in relation to
projects initially and later to sectors as practical prevention experience is gained (e.g.
in relation to hotels under Green Business Initiative).
Green Green Schools Schools
Schools
In Ireland 67% of all Irish schools are currently taking part in the programme, with
1,277 Schools have been awarded the Green Flag. This is a voluntary programme
therefore schools consider this programme an important initiative, which they are
willing to spend time and resources on this programme. The section below on
“Evaluation Studies Available”, details some evaluations that have been completed by
An Taisce in relation to the effectiveness of the Green Schools Programme in waste
prevention.
Green Green Homes
Homes
Green Homes was set up in November 2006 with a total of seven schools
participating (The pilot programme is intended to promote waste prevention in the
homes of the school children associated with the original initiative thus targeting
some of the wider community). In 2007, the number of schools increased to 18 and
in 2008 this increased to 41 schools, which is nearly six times the number of schools
participating in 2006. This illustrates the prominence of this programme. The Green
Home Phase II Results, 2008 are outlined below under Evaluation Studies Available.
There are currently no evaluation studies available for Phase III. The Green Home
programme is being expanded in 2009 to include up to 9,000 households. The
programme now revolves around the website with householders invited to register
and be provided with information on waste prevention, water conservation and energy
International Review of Waste Policy: Annexes

use. A range of meetings with teachers, participating schools and feedback
mechanisms are used to disseminate best prevention practice. 392
Green Green Green Business Business
Business
The ‘Green Hospitality Awards’ project commenced in January 2008. By early 2009
up to 200 hotels had signed up to this scheme and 80 had achieved their awards.
Participants are provided with expert advice and assistance towards achieving waste
prevention and water, energy and resource conservation. Awards (bronze, silver, gold
and platinum) are formally made to recognise their achievements confirmed by
audits. 393
It is hoped to recruit 500 participants by the end of 2011. The fact that this is being
extended to encompass other sectors including restaurants, pubs and contracting
catering illustrates that it is a successful Programme.
The The Local Local Authority Authority Prevention Prevention Demonstration Demonstration (LAPD) (LAPD) Programme
Programme
To date 14 local authorities are participating in the LAPD Programme, which was
launched in July 2006. Overall over 153 businesses have been contacted and 96
engaged with directly on prevention. Over 295 waste audits have been completed
and 1,300 people attended over 20 different events organised to discuss the
prevention projects.
18.5.1 Evaluation Studies Available
The following studies are of relevance:
354
� A Research study completed in 2001 entitled “The Performance of the Irish
Green-Schools Research Programme”
� Green Schools Handbook, Towards a Sustainable Lifestyle, An Taisce.
� An Taisce, Green Home Phase II Results, 2008 Presentation sent to TOBIN
from Green Home Project Manager
� EPA, National Waste Prevention Programme, Third Annual Report 2006/07
and Fourth Annual Report 2007/08.
18.6 Environmental Benefits
� Green Schools: The aim of Green-Schools is to increase students’ and
participant awareness of environmental issues through classroom studies and
to transfer this knowledge into positive environmental action in the school and
also in the wider community. Schools that have successfully completed all the
elements of the programme are awarded the ‘Green-Flag’. This award has now
become a well-recognised Eco-Label. The award has to be renewed every two
years.
392 EPA (2008) National Waste Prevention Programme, Prevention Plan 2009 – 2012, Wexford: EPA.
393 EPA (2008) National Waste Prevention Programme, Prevention Plan 2009 – 2012, Wexford: EPA.
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355
� Green Homes: The Green Homes Programme aims to promote waste
prevention and sustainable living in the homes of the schools children
associated with the An Taisce Green Schools initiative as well as targeting the
wider community.
� Green Businesses: The aim of the Green Business initiative is to deliver
substantive results and savings on resource efficiency; through waste
prevention and minimisation and reduction in energy and water consumption.
� LAPD: The LAPD Programme assists local authorities to design and implement
local integrated waste prevention programmes and projects. This allows local
authority staff to enable organisations including their own, to prevent waste
from being produced.
18.6.1 Environmental Benefits – Prevention
Green Green Green Schools Schools
Schools
A Research study completed in 2001 entitled “The Performance of the Irish Green-
Schools Research Programme”; the primary aim of this work was to quantify any
reduction in waste to landfill achieved by the programme. The approach taken to the
project was to undertake a comparative study of the schools undertaking the
programme; these schools included Pre-Action Plan Schools, Post-Action Plan Schools
and Awarded Green Schools (who have implemented the Seven Steps of the Green
Schools Programme). The results are outlined in Table 18-1. The results indicate that
a considerable waste to landfill reduction occurs during a school’s progress through
the programme. This study revealed that schools that had been awarded the Green
Flag were diverting on average of 45% more of their waste away from landfill in
comparison to schools that were not participating in the programme. Several of the
awarded schools were very close to achieving zero waste to landfill, with some
producing as little as 2 grams of waste per person per day. 394
This study illustrates that the Green Schools Programme is an important mechanism
for preventing waste arisings.
Table 18-1: Average Waste to Landfill Per Capita Values for the Three School Groups
International Review of Waste Policy: Annexes
Pre-Action Plan Post-Action Plan Awarded
Waste per capita per day 53.2g 37.9g 29.0g
As part of the Green Schools Programme, schools monitor the quantity of waste
produced; this results in both less waste being disposed of to landfill and less waste
being produced in the first instance (waste prevention). This study revealed that
monitoring was being undertaken by a number of methods. These included
monitoring by weight, by volume, counting the number of bags or bins going to the
landfill. From this study it was apparent that schools that monitored their waste
394 Green Schools Handbook, Towards a Sustainable Lifestyle, An Taisce.

typically generated less waste to landfill or produced less waste (waste prevention) in
the first instance.
This study also revealed that the average per capita values for Primary Schools is
38.55g/person/day while for secondary school it is 55.1g/person/day.
Further research carried out in 2006 indicated that the awarded schools had
improved their performance and on average were diverting just over 60% of their
waste from landfill. Out of sample of 160 schools, over 8% (13 schools) were diverting
in excess of 90% of their waste from landfill. Calculations indicate that around 5
tonnes of waste is directly diverted from landfills per school day in Ireland due to the
work of Green-Schools. 395
Green Schools promotes environmental awareness in 67% of all Irish Schools 396, this
leads to the following outcomes in terms of waste prevention:
356
� Behaviour towards the environment was significantly different. Students from
awarded Green-Schools drop less litter, take part in more local environmental
projects, conserve more water and more electricity, and are more conscious of
the environment when making a purchase than their non-Green-Schools
counterparts;
� Green-Schools students are better “opinion leaders” for the environment, i.e.
they discuss the environment with more people and in more settings,
particularly the classroom, and provide more encouragement to their peers
than their non-Green-Schools counterparts; and
� The main environmental concern indicated by both types of student was litter.
Green Green Homes
Homes
Green Home Phase II Results illustrate that this programme has encouraged
communities to prevent waste from being produced. Figure 18-1 below illustrates that
in 2008, 42% of those Communities involved in the Green Homes Pilot Programmes
avoid buying over packaged goods; this is an increase from 34% in 2007.
395 Ibid.
396 An Taisce, Green Home Phase II Results, 2008 Presentation sent to TOBIN from Green Home
Project Manager.
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Figure 18-1: Green Homes Research – Packaging Waste
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
357
34%
42%
We avoid buying over-packaged goods
46%
44%
International Review of Waste Policy: Annexes
6%
2%
8% 7%
Always Sometimes Not Sure Never
"07 Pre Green Home
"08 Post Green Home
Source: Presentation by An Taisce Green Home Phase II Results, 2008
In addition the survey results illustrate that there was a 5% increase in people
composting their waste; a 7% increase in the recycling of plastic bottles and a 7%
increase in people recycling paper. 397
Phase III of the Green Home programme commenced in September 2008 and will
involve 40 newly recruited schools and up to 9,000 more families. Community links
will be widened to include the Tidy Towns Network, National Spring Clean, Green
Coast and LAPD/N participants. Online membership in September 2008 was 290
members, this has increased to 2,200 in February 2009. 398 The programme has a
strong emphasis on action based activity where participants undertake household
challenges around the themes of waste, energy, water and transport, the aim of which
is to support householders as they reduce their household utility bills and also help to
protect the environment. The growth of the programme since its inception in 2006
suggests that this programme has been successful to date.
Green Green Business
Business
A major Green Business Initiative the Green Hospitality Awards scheme, which has
been developed, based on previous work completed by EPA/ERTDI on the Cleaner
Greener Production Programme project “Greening Irish Hotels”. The original
programme involved 56 hotels (3 to 5 star) ranging in size from 30 to 255 beds
located around the country. Environmental reviews, training, environmental
management, best practices and cleaner production plans were developed.
397 An Taisce, Green Home Phase II Results, 2008 Presentation sent to TOBIN from Green Home
Project Manager.
398 Dorothy Stewart, Green Homes Project Manager, An Taisce.

Quantified actual savings included diversion of 1,113 tonnes of waste from landfill,
reduction of 5,000 tonnes of water consumption and 3,000 tonnes of carbon
emissions. If extrapolated across the entire sector the economic benefit could
amount to €81.4 million in cost savings, and diversion of 56,000 tonnes of waste
from landfill. 399
This project is currently being developed further with up to 200 hotels being actively
recruited throughout the country by early 2009. A range of awards and assessment
criteria have been developed to underpin this project.
It is anticipated that considerable quantities of biodegradable waste can be
prevented or diverted from landfill with the continued implementation of the Greening
Irish Hotels project under the Green Business Initiative (up to 70% biodegradable 400).
By reducing packaging, preventing waste, increasing re-cycling and segregation the
hotels have saved 4,000 tonnes (1,600 full skips) of landfill waste. This is equal to
monetary savings of between €5,000 and €45,000 per hotel. Eight per cent of Irish
Hotels are now accredited to the scheme. The target for 2009 is to expand the
current membership of 180 hotels and catering firms to 300. It is also intended to
expand the scheme to other similar sectors, including contract catering, nursing
homes and hospitals, which should also realise significant diversion of biodegradable
waste. 401 The level of waste reported in the National Waste Report 2007, allied with
the need for businesses to reduce costs in 2009, reflects the need for continued
support for this Scheme. The fact that this Scheme is being extended to encompass
other sectors including restaurants, pubs and contracting catering demonstrates the
success of this Programme.
As part of the Green Business website (www.greenbusiness.ie ) a Waste Audit Tool
(WAT) was developed, which allows business to break down the types, volumes and
sources of waste, helping business to monitor, prevent waste from being produced
and hence reduce costs. Using this WAT many businesses in Ireland have already
started making resource efficiency savings by reducing the amount of waste
produced, water consumed and energy used. Hotels, manufacturers and food
processors have shown to successfully reduce the amount of waste being disposed of
in landfill site without in any way compromising the quality of service or levels of
comfort offered by the hotel to its customers.
LAPD LAPD
LAPD
As mentioned above the LAPD Programme assists local authorities to design and
implement local integrated waste prevention programmes and projects. This allows
local authority staff to enable organisations including their own, to prevent waste from
being produced. Example projects include Dundrum Shopping Centre which has
reduced waste charges by approximately €168,000 annually following a waste audit
and the introduction of improved practices. They are currently testing an on site
399 EPA, National Waste Prevention Programme, Fourth Annual Report 2007/08.
400 EPA, National Waste Prevention Programme, Third Annual Report 2006/07.
401 EPA, National Waste Prevention Programme, Fourth Annual Report 2007/08.
358
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composter. There are similar savings in Hospitals in Monaghan where improving
waste management practices and avoiding mixing hazardous with non hazardous
waste reduced waste charges by €8,300.
18.6.2 Environmental Benefits Associated with Recycling
While the main focus of the above mentioned schemes is waste prevention, recycling
is also promoted for example:
359
� Green Schools: In Green Schools recycling levels of glass, paper, cardboards
and aluminium, as well as the levels of home composting were significantly
higher within the homes of Green School students.
� Green Homes: Green Homes participants are encouraged to reduce their
waste output through reducing the amount of purchased goods which are
excessively packaged, and through composting and recycling.
� Green Business: WAT under Green Business identifies the amount of waste
recycled and its annual waste cost, thus encouraging recycling for businesses.
� LAPD: While the main aim of the LAPD programme is waste prevention,
recycling is also promoted for example in Phase I Programmes Limerick County
Council reviewed waste Management in conjunction with SISK Building
Contractors. Targets were set to reduce the total number of mixed skips at the
development, through waste prevention practices and the recycling was
encouraged through the introduction of segregated skips. Under Phase II,
which relates to Projects, Dundrum Town Centre segregating food waste and
they are currently trailing an on-site composter.
All of the above programmes are being expanded, continually promoted, encouraged
and funded; this suggests that these programmes have been successful in waste
prevention and recycling. However the current schemes need to be extended
considerably in order to fully see the impact on the national waste arising figures.
18.7 Implementation Costs
The Minister for the Environment, Heritage and Local Government announced funding
of €2 million to start a broad waste prevention initiative in April 2004 from the
Environmental Fund. In 2007/8, the EPA provided 50% of the external costs of the
packaging prevention programme operated by Repak. The source of funding for
subsequent phases of the programme is the subject of ongoing review. 402
The Environmental Fund Account, 2006 stated that in 2006, €1,644,063 was given
to the NWPP. To that point, the EPA stated that almost €5 million from the
Environment Fund has been expended or committed to these projects, 403 whilst
according to the Environmental Fund Account, 2007, another €1,484, 300 was
committed to the NWPP in 2007.
402 EPA (2009) National Waste Prevention Programme, Prevention Plan 2009 – 2012, Wexford: EPA.
403 National Waste Prevention Programme, Third Annual Report, 2006- 2007.
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As part of the NWPP, an agreement to co-fund a Packaging Waste Prevention
Programme has been signed by NWPP and Repak. A budget of €200,000 for 2007
has been approved.
There is no detail of how much each Programme costs.
Householder and Business do not pay to register for either Green Homes or Green
Schools. However, it seems reasonable to suggest that the programme is not costless
to engage with, if only due to demands on staff time. That does not, of course, mean
that these costs are recouped through lessons learned whilst engaging with the
programme.
18.8 Response from Public and Industry
Response to the Green Schools, Green Homes and Green Business Initiatives has
been positive from both the public and Industry. Industry is responsive to the Green
Business Initiatives, especially the Hotel Sector as the savings from diversion of waste
from landfill, reduction in water consumption & carbon emissions if extrapolated
across the entire sector the economic benefit could amount to €81.4 million in cost
savings. It is apparent that the public are responsive to these initiatives as the Green
Schools is now being rolled out to communities in the form of Green Homes.
18.9 Effects on Technical Change / Innovation
The Green Schools Programme has expanded to include the Green Homes
Programme; this is to promote environmental awareness in communities also.
18.10 Social and Distributional Consequences
There are no obvious adverse consequences associated with any of these initiatives.
It is possible that some companies may be less able, or feel less able, to commit time
to the programme.
18.11 Complementary Policies
Waste prevention measures, and the desire to engage with them, will be
strengthened where the costs of waste management are higher. Hence, there are
overlaps with the landfill levy, and pay-by-use policies.
18.12 Effect of the Policy on Pricing of Resources / Services
These initiatives do not change the prices of resources and services. They do,
however, address market failures in respect of waste prevention activity, notably
information failures, and the transaction costs experienced by companies, schools
and homes seeking to understand the opportunities to save money through cost
effective waste prevention measures.
All of the above programmes developed as part of the NWPP are a resource for
school, householders and business in minimising cost to their business. Businesses
can access for free, www.greenbusiness.ie and review all of the Case Studies by
business on cost savings from waste prevention initiatives etc... Schools can access
www.greenschoolsireland.org and review case studies, research undertaken and
360
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information on the various themes including “litter and waste”. Communities /
householders can access www.greenhome.ie and review case studies.
These websites have the relevant information to allow businesses, schools and
householder to prevent waste from being produced and reduce fuel bills by learning
from best practice case studies and implementing these actions into their
lifestyle/business.
18.13 Evasion and Enforcement
The above three Programmes are Voluntary Initiatives which were as a direct results
of the Preventing and Recycling Waste - Delivering Change (2002) policy statement.
Therefore, there are no evasion or enforcement issues.
18.14 Lessons Learned
18.14.1 General Lessons
One of the obvious lessons learned is that measures which seek to provide
information regarding waste prevention and recycling can lead to improved
performance in both respects. The question which logically follows is ‘how can
companies, schools and homes, or any one or more of these groups, be persuaded to
adopt such measures in a more systematic fashion? In other words, can these
‘initiatives’ be made less voluntaristic through fashioning a relevant policy? Such a
policy would, it seems, have the potential to deliver savings to business and society
more generally.
361
International Review of Waste Policy: Annexes

19.0 Producer Responsibility, WEEE - Ireland
19.1 Outline of Policy
The Directive on waste electrical and electronic equipment (WEEE Directive) was
founded on the principle of "Producer Responsibility" and its general objectives are:
362
� To prevent waste of electrical and electronic equipment (EEE) and to promote
the reuse, recycling and recovery of such wastes;
� To improve the environmental performance of all operators involved in the life
cycle of electrical and electronic equipment, e.g. producers, distributors and
consumers and in particular those operators directly involved in the treatment
of waste electrical and electronic equipment.
The WEEE Regulations transpose the WEEE Directive into Irish law; the WEEE
Regulations came into effect on 13 August 2005.
The WEEE Directive applies across ten categories of EEE. The following 10 categories
have been identified in the WEEE Directive as belonging to EEE:
� Large household appliances
� Small household appliances
� IT and telecommunications equipment
� Consumer equipment
� Lighting equipment
� Electrical and electronic tools
� Toys, leisure and sports equipment
� Medical devices
� Monitoring and control instruments
� Automatic dispensers
The WEEE Directive requires producers to be responsible for the financing of the
collection, treatment, recovery and environmentally sound disposal of WEEE from 13
August 2005. This means that final users of such household WEEE are entitled to
return their WEEE free of charge, either to retail outlets in instances where a
replacement item is purchased, or to other authorised collection points, including
local authority civic amenity sites.
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Producers must register with the national registration body, the WEEE Register
Society, and report to the Black Box 404 the amount in units and weights (kg) of EEE
and/or batteries or accumulators placed onto the Irish market on a monthly basis.
At present, there are two approved compliance schemes in Ireland: the European
Recycling Platform (ERP) and WEEE-Ireland. If a producer of Electrical and Electronic
Equipment (EEE) is not a member of an approved compliance scheme they are
required to self-comply in accordance with the WEEE Regulations. Self-compliance is
particularly relevant to producers who primarily sell Business to Business (B2B).
WEEE fees in Ireland are calculated as follows:
363
� Companies placing EEE onto the market up until 31st December 2006 will be
charged a registration fee of €600 and a 2005/2006 annual fee of €600.
� 2007 and 2008 annual fees will be charged based on EEE turnover (turnover
> €250,000 = €600, turnover < €250,000 = €400) and a discount allowed (-
€300) for Producers signing up to direct debit payment.
� Producers not placing EEE onto the market prior to 31st December 2006 will
be charged a €600 registration fee plus the relevant annual fee.
� Once they are fully registered with the scheme, Producers will be invoiced for
all Environmental Management Costs (EMCs) owed to date based on the Black
Box reporting.
� For Producers of Automotive Batteries there is a €600 Registration fee and an
annual fee of €300 (to be paid by direct debit).
� For Producers of Portable Batteries and Accumulators there is a €600
Registration fee and annual fees based on Battery turnover (Turnover >
€250,000 = €600, Turnover < €250,000 = €400) with a €300 discount for
Producers signing up to direct debit
� Existing members of WEEE Ireland received free membership for Portable
battery compliance until 31st December 2008.
From 13 August 2005, each retailer must:
� Be registered with their local authority;
� Provide free in-store take back of household WEEE on a one-for-one basis on
the sale of a new replacement product;
� Ensure that any WEEE collected is delivered to an approved collection facility;
� Ensure that the storage and transport of WEEE collected as above meets the
requirements of the Regulations; and
404 WEEE Register Society Ltd have appointed Deloitte to manage and operate the WEEE Blackbox
function on its behalf. The information gathered will be used to establish producers’ financial liabilities
associated with the management of a proportion of the WEEE arising in Ireland.
International Review of Waste Policy: Annexes

364
� Ensure that private households are informed of the WEEE take back facilities
available to them and that they are encouraged to participate in the separate
collection of WEEE.
Since 13 August 2005, each local authority must accept household WEEE free of
charge at its civic amenity facilities. Local authorities can no longer charge gate fees
for WEEE. Where appropriate, priority should be given to reuse of the whole
appliance, thereby contributing to waste prevention.
19.2 Policy Context and Reason for Introduction
Many everyday consumer items are classified as electrical and electronic equipment
such as mobile phones, computers, drills, hairdryers, as well as industrial equipment,
medical devices and laboratory equipment. When these items reach their end-of-life
they are defined as WEEE. WEEE is made up of many different materials and
components, some of which are hazardous. The increased consumption of electrical
and electronic equipment, together with a decrease in the average lifespan of
products has resulted in a waste stream that is growing three times faster than the
average waste stream. This growth, together with the presence of several hazardous
substances in many products, has lead to the development of European legislation on
WEEE. Today, citizens are likely to generate between 17 and 20kg of WEEE per
inhabitant per annum
Producers are required to meet various recovery, recycling and reuse targets for
WEEE, calculated based on the weight of equipment collected. 405 There are different
targets for the recovery and recycling of the different categories. For large household
appliances, which include fridges and freezers, the rate of recovery must be at least
80% with component material and substance reuse and recycling a minimum of 75%
by average weight by appliance. For televisions and monitors, the rate of recovery
must be at least 75% and component material and substance reuse and recycling a
minimum of 65% by average weight by appliance. Similar targets apply for other
WEEE items. These targets must be achieved by 31 st December 2008.
Retailers are also responsible for the collection, treatment, and environmentally
sound disposal of WEEE. Thus final users are entitled to return their WEEE free of
charge to retail outlets when a replacement item is also purchased.
The WEEE Directive emerged, and has evolved in the following ways:
• 2005: The EU WEEE Directive 2002/96/EC was transposed into Irish law in
August 2005 by the Waste Management (Waste Electrical and Electronic
Equipment) Regulations 2005.
405 'Producer' means any person who, irrespective of the selling technique used, including by means of
distance communication, manufactures and sells electrical and electronic equipment under his or her
own brand, resells electrical and electronic equipment produced by other suppliers under his or her
own brand, imports/exports electrical and electronic equipment on a professional basis into/from the
State or distributes electrical and electronic equipment from a producer who is deemed not to be
registered under the provisions of article 12(2).
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365
• 2008: The Waste Management (Waste Electrical and Electronic Equipment)
(Amendment) Regulations 2008 were introduced in September 2008, which
amend the Waste Management (Waste Electrical and Electronic Equipment)
Regulations 2005.
• 2008: The European Commission proposed amendments to the WEEE and
Restriction on Hazardous Substances (RoHS) Directives in December 2008.
The proposed directives set higher but more flexible targets on the collection
and recycling of electrical and electronic equipment and introduce greater
coherence with other EU legislation. The main change they propose is to
change the collection target from the current 4kg per capita per year to a
variable target that takes into account the economies of individual member
states. The new target is set at 65% of the average weight of products placed
on the market in the two preceding years. Although many Member States have
already reached this target it becomes binding in 2016, thus giving other
Member States time to adjust. Ireland however has already exceeded these
recovery targets, with the exception of the category ‘large household
appliances.’ 406 The amendment also proposes the re-use of whole appliances
as part of the existing re-use/recycling target. This will allow flexibility to
choose the most sustainable treatment option (re-use or recycling) and will
avoid making re-use an unattractive option by needing to meet higher recycling
targets, even when re-use might be more economically and socially valuable.
As about 5% of collected waste electrical and electronic equipment is suitable
for reuse, the overall recovery targets have been increased by 5%. 407
19.3 When was the Policy Introduced?
The WEEE Regulations were introduced in August 2005 and amended in September
2008.
19.4 Key Organisations Involved in Implementation and
Management
As well as consumers, there are a number of organisations involved in the
implementation and management of this Policy. These include:
� Producers:
• Finance the take back of WEEE based on market share;
• Register with the WEEE Register Society;
• Self-comply or join an approved compliance scheme;
• Mark products with crossed-out wheelie bin symbol.
406 EPA, National Waste Report, 2007.
407 Press Release, 3 December 2008, ‘Environment: Commission proposes revised laws on recycling
and use of hazardous substances in electrical and electronic equipment’, Europa.
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366
� Retailers:
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• Register premises with local authority;
• Display environmental management costs of specified EEE;
• Comply with requirements regarding price display and statutory notices;
• Take back household WEEE free of charge when replacing on a one-forone,
like for like basis;
• Store, transport, and dispose of WEEE as set out in Regulations.
� Local authorities:
• Local enforcement responsibilities (particularly in relation to retailer
obligations);
• Management of civic amenity sites.
� Environmental Protection Agency:
• Leads national enforcement of the WEEE Regulations;
• Promotion of eco-design and re-use of EEE.
� WEEE Register Society Ltd. National producer registration body:
• Registration of producers of EEE;
• Notify Environmental Protection Agency where evidence of noncompliance;
• Determine which categories/sub-categories EEE product belongs to;
• Verification of visible environmental management costs;
• Determination of market share of individual producers (function
devolved to the “Black box” currently managed by Deloitte & Touche).
� European Recycling Platform (ERP) – Ireland:
• Approved producer compliance scheme.
• Established in 2005 as a result of the success and expansion of ERP in
Europe. ERP Ireland has 75 members and continues to grow annually.
• To date ERP have collected 29,731 tonnes of recyclable waste from its
members and the public.
• ERP operate in Cavan, Clare, Fingal, Louth, Limerick, Meath, Monaghan
and Kerry.
� WEEE Ireland: 408
408 WEEE Ireland is a not for profit organisation, founded by producers of electrical and electronic
appliances in order to comply with the legal obligations imposed by the WEEE Directive 2002/96/EC.

367
• Approved producer compliance scheme.
� Department of Environment, Heritage and Local Government:
• Issues/amends the WEEE Regulations;
• Provides guidance on the WEEE Regulations;
• Represents Ireland at European Commission meetings (Technical
Adaptation Committee).
� Recovery Operators:
• Possess relevant permits/ licences/ Certificates of Registration where
necessary;
• Storage and/or treatment of WEEE as required under Sixth and
Seventh Schedules of WEEE Regulations;
• Recovery and recycling of WEEE in line with 2008 recovery targets;
• Recording and maintaining accurate records for WEEE.
19.5 Monitoring and Measurement Techniques Applied
Since the WEEE Regulations came into force on 13th August 2005, EPA inspectors
and contractors have been undertaking random, unannounced inspections of
retailers of electrical and electronic equipment (EEE). 409 Significant efforts are being
made also to identify any unregistered, potentially obligated producers or “freeriders”.
Producers/distributors who supply EEE by means of distance communication
(web-sites, mail order catalogues, telesales etc.) are also covered under the WEEE
Regulations, and inspections of such operations are ongoing. All complaints received,
from whatever source, are acted on as part of the surveillance effort.
The following programme of inspection has been and continues to be undertaken:
� Retailers: Retailers: Inspectors have now completed three campaigns of nationwide
retailer inspections on the EPA’s behalf. These campaigns were carried out in
May-June 2006, November- February 2007 and February-March 2008. EPA
inspectors also carry out routine/non-routine inspections where necessary. To
date, approximately 700 impromptu retailer inspections have been completed;
� Distance Distance sellers: sellers: Inspections of distance sellers (web-sites, mail order
catalogues) were made a priority due to concerns of non-compliance in this
sector. A second round of distance seller inspections was completed in
October 2007. Approximately 170 such inspections have been completed to
date and non-compliances followed up with the relevant companies;
WEEE Ireland can organise for the treatment and recycling of waste electrical and electronic
equipment and batteries and accumulators from authorised collection points, on behalf of its Producer
members.
409 EPA (2007) EPA Enforcement of WEEE Regulations, http://www.epa.ie
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368
� Producers: Producers: Producers: The EPA is carrying out inspections of producers where it has been
notified that they are non-compliant by the WEEE Register Society for failing to
re-register. These are detailed inspections where purchase and sales
documentation and stock held on site is inspected to gather evidence of noncompliance
with obligations under the WEEE Regulations. Where noncompliance
is not closed out within agreed time-frame, a recommendation for
prosecution may be put to the Board of the Agency for consideration;
� Trade Trade exhibitions: exhibitions: exhibitions: Inspectors attend exhibitions (open to public and/or trade)
to check compliance of exhibitors selling or advertising EEE. The EPA is
working with exhibition management companies to have terms and conditions
regarding WEEE compliance inserted into exhibition application forms, and to
ensure that non-compliant exhibitors are prohibited from attending future
exhibitions.
In summary the EPA collects and transfers data on the following aspects of WEEE
management:
� Amounts of products introduced to the market;
� Annually recovered appliances; and
� Volume of collected, reused, recovered and exported appliances.
19.5.1 Evaluation Studies Available
According to the WEEE Regulations, by 31 December 2006 Ireland was obliged to
achieve a separate collection rate of 4kg of household WEEE per person per year.
According to the:
• National Waste Report 2006, Ireland achieved a separate collection rate of
7.4Kg of household WEEE per person per year.
• Annual WEEE Ireland Report 2007, this collection rate increased again in
2007 to almost 9Kg. Of the total WEEE collected in 2007, 80% was treated in
Ireland and 20% was exported to other EU countries. 410
19.6 Environmental Benefits
The WEEE Regulations aim to prevent the generation of WEEE and facilitate the
achievement of targets for the collection, treatment, recovery and disposal of WEEE in
an environmentally sound manner. The quantity of WEEE collected in 2007 reached
50,626 tonnes. 411 The EPA National Waste Database Report 2006 stated that this
producer responsibility initiative ‘has proven very successful in achieving the
recycling of waste electrical and electronic equipment and diverting it from landfill’.
However, the report went on to suggest that the increasing generation of any waste
stream is of concern and that as a next step, the focus should be firstly on preventing
410 EPA, National Waste Report, 2007.
411 IBID.
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the generation of electrical and electronic waste in the first place and secondly on
promoting its reuse. 412 In December 2008 a proposal for revised laws on WEEE was
drafted by the European Commission and one of the main adjustments the
Commission proposes is to set a combined recycling and re-use target. This combined
target would avoid making re-use an unattractive option by needing to meet higher
recycling targets, hence would increase the environmental and social benefits
associated with re-use.
The WEEE Regulations aims to reduce quantities of WEEE disposed of via landfill and
reduce the harmful effects caused by WEEE on health and the environment whilst
conserving natural resources.
19.6.1 Environmental Benefits – Prevention
As regards waste prevention, the main aim of the WEEE policy is to provide the
following key environmental benefits:
369
� Reduce the waste produced whilst manufacturing WEEE products as well as
the minimisation of waste produced at the end of the product’s life, both of
which lead to a reduction in WEEE being disposed of to landfill. However no
statistics are currently available in Ireland on if the manufacturing rates of
WEEE.
� Reduce the potential leakage of hazardous materials by controlling the toxicity
of the product and ensuring its safe disposal (includes RoHS). Since July 2006
new EEE cannot, other than the permitted trace levels, contain lead, mercury,
cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and
polybrominated diphenyl ethers (PBDE);
� Re-use of old electrical and electronic equipment. In a press statement in
September 2007, the Minister said that: “There is vibrant social economy
activity in refurbishing old electrical and electronic goods’, adding that ‘there
is evidence that perfectly working equipment is being recycled instead of
being diverted for re-use.” The Minister mentioned that his Department is
working with the relevant stakeholders, including the social economy sector in
developing a protocol to promote and facilitate higher levels of reuse. This
Protocol was to be completed by the end of 2007. 413 However, there was no
information available on this protocol at the time of writing. 414 Re-use of WEEE
requires fewer resources and less energy when compared with recycling or the
manufacture of new products from virgin materials.
412 EPA, National Waste Report, 2006,
http://www.epa.ie/downloads/pubs/waste/stats/name,24094,en.html
413 Press Release “Recycling Rate for Waste Electrical and Electronic Equipment Continues to Grow”,
28/09/07.
414 We understand from DoEHLG that the protocol is due to be published shortly (as of July 2009).
International Review of Waste Policy: Annexes

19.6.2 Environmental Benefits - Associated with Recycling
Waste management infrastructure for WEEE in Ireland is developing rapidly. There are
now six facilities in Ireland that recover WEEE by dismantling it into the material
components and processing it into reusable raw materials. As mentioned in Section
19.5.1, in 2007 WEEE Ireland collected almost 9kg per person of electronic waste
which greatly exceeded the 2008 target of 4kg per inhabitant set for Ireland by the
EU. However, the current level may be somewhat below what is now proposed by the
European Commission.
Household WEEE taken back to retailers or deposited at civic amenity sites is
collected for processing by one of WEEE Ireland’s contracted partners. The five
families of WEEE are treated differently; the dedicated treatment processes ensure
maximum recycling rates can be achieved for the various materials contained in
WEEE.
As shown in Table 19-1 considerable quantities of WEEE are recycled in Ireland. The
EPA considers that producers and their compliance schemes should strive to ensure
that this remains the case. 415
Table 19-1: Recycling Rates of WEEE Families 2007
EU Target 31 st
Dec 2008
WEEE Ireland
Recovery Rate
Recovered &
Recycled
370
29/09/09
Tonnes
Fridge
Freezers
LHA
Mixed
WEEE
CRT Lamps
80.00% 80.00% 70.00% 75.00% n/a
86.73% 68.23% 81.07% 96.71% 93.10%
Ferrous Metal 14,302 66.66% 60.95% 42.43% 4.02% 0.00%
Non Ferrous
Metal
2,146 4.53% 5.16% 11.55% 13.05% 3.10%
Plastic 3,302 15.08% 2.12% 27.07% 15.60% 0.00%
Glass 2,990 0.46% 0.00% 0.02% 64.04% 90.00%
Total 22,740 86.73% 68.23% 81.07% 96.71% 93.10%
Treatments &
Landfill
Waste 5,909 11.69% 31.75% 18.85% 3.28% 6.00%
Hazardous Waste 95 1.58% 0.02% 0.08% 0.01% 0.90%
Total 6,004 13.27% 31.77% 18.93% 3.29% 6.90%
Source: WEEE Ireland, Annual Report 2007
415 EPA, National Waste Report, 2007.

80% of WEEE primary processing takes place in Ireland in permitted, and where
appropriate, licensed facilities, with the reminder going to dedicated WEEE treatment
facilities in the UK and mainland Europe. The processing of WEEE in this way means
consumers can be confident their old and broken electrical appliances are managed
by WEEE Ireland in an environmentally responsible way within Ireland. 416 Recycling
WEEE saves energy, reduces raw material use and combats climate change.
19.7 Implementation Costs
The overall cost for compliance with the WEEE Directive is estimated at €500-900
million per year EU-wide. Of this, €300-600 million will be spent on collection and
€200-300 million on recovery, reuse and recycling.
The WEEE Task Force Report on implementation of the WEEE Directive estimated that
the cost of collection and treatment of WEEE would be in the region of €10 to €14m
annually in Ireland. 417
Producers have to fund the recycling of WEEE arising from goods they place on the
market after 13 August 2005, and also share in the cost of recycling WEEE arising
from all goods placed on the market prior to this date. Producers must fund the
management of this ‘historic waste’ on the basis of their current market share. The
WEEE Directive requires that Member States ensure that for a transitional period of
eight years (10 years for large household appliances) producers are allowed to
display the costs associated with the recycling of historic WEEE on the price of new
products.
The Visible Environmental Management Costs (vEMCs) that the producers are able to
apply to new EEE in order to help pay for historic WEEE are based on the costs of
recycling as approved by the WEEE Register Society Limited. These costs fund the two
collective compliance schemes operating in Ireland, WEEE Ireland and the European
Recycling Platform, to enable them to pay for the environmentally sound management
of all household WEEE that is taken back by retailers or deposited by members of the
public at local authority civic amenity sites.
The vEMCs displayed to consumers cannot exceed the actual costs of recycling. The
WEEE Register, the national registration body for producers, has verified and issued a
schedule of vEMCs to be displayed. Example of EMCs which must be displayed for
various products are as follows; large refrigerators and freezers - €30, large
appliances such as washing machines, dryers, stoves and hobs, €5 and large
television sets €8.
416 WEEE Ireland (2007) The National Compliance Scheme for Electrical Recycling Annual Report
2007.
417 The WEEE Task Force Group is comprises representatives of all the key stakeholders. This Task
Force plays a pivotal role in monitoring the continued implementation of the WEEE and RoHS
Directives and in advising the Department and the Minister of further improvements and refinements
to the WEEE regime in Ireland.
371
International Review of Waste Policy: Annexes

Additional costs to businesses may be incurred due to logistical efforts for the take
back system; however the potential magnitude of these additional costs not clear.
19.8 Response from Public and Industry
The compliance schemes WEEE Ireland and ERP Ireland organise ‘Public Collection
Days’ or ‘Open Days’ to encourage members of the public to bring their household
WEEE free of charge to locations around the country as part of the WEEE Awareness-
Raising Programme. These Open Days have had an exceptional response:
approximately 250 tonnes of WEEE were collected over the period of the fifteen Open
Days which were held by ERP. The most successful Open Day was held in Tralee, Co.
Kerry, where 53 tonnes were collected in one day. Through the take back of old
electronic and electrical equipment to retailers and civic amenity sites, half a million
household appliances have been taken out of the waste stream and recycled since
13 August 2005, including 85,000 fridge freezers, 78,000 TVs and almost 40,000
power tools. 418 These figures suggest that householders are responding to the
available channels for WEEE re-use / recovery.
19.9 Effects on Technical Change / Innovation
The policy generates continuous incentives for improvement in product design, as
well as promoting investment in infrastructure. Six companies have set up WEEE
facilities in Ireland including Cedar Resource Management, Techrec and KMK Metals
Recycling which process the majority of material collected from retailers, civic amenity
sites, and distribution hubs. They handle all categories of WEEE providing it is
available in suitable quantities. In addition Irish Lamp Recycling and Enva Ireland
collect and recycle florescent tubes and gas discharge lamps nationwide.
19.10 Social and Distributional Consequences
WEEE fees do not have direct distributional consequences. Indirectly however
increased WEEE collection rates may lead to benefits in terms of social inclusion in
two ways. First, there is the potential for an increase in the reuse of WEEE. This could
result in second-hand EEE being made available to lower income groups. In addition,
there may be additional opportunities for charities or voluntary organisations to
provide training using second-hand EEE, for example for the long-term unemployed.
One programme which encourages the reuse of WEEE is the Microsoft Authorised
Refurbisher (MAR) programme which is designed to increase the number of low-cost
computers available to charities and schools, whilst also keeping serviceable
computers out of landfills. The company is also actively recruiting new refurbishing
companies to join the programme so that increased volumes of computers can be
refurbished for the benefit of as many non-profit organisations and schools as
possible. There are currently four companies in Ireland actively refurbishing
computers as part of the MAR programme and over 1,000 computers have been
418 Press Release (6 December 2005) Electrical Equipment Take Back Scheme Proves Overwhelming
Success, Leo Donovan, CEO, WEEE Ireland.
372
29/09/09

outed to charities and schools to date. Rehab Recycle is associated with the
Microsoft MAR programme. Rehab Recycle provide a high quality IT reuse, refurbish
and recycle service to customers and are one of the country's largest employers of
people with disabilities. The programme has also received the commendation of
WEEE Ireland; to date WEEE Ireland has financed over 200 of these refurbished
computers in their 'schools awareness campaign' that is operated by Rehab. 419
Secondly, increased separate collection may lead to less fly-tipping of WEEE, which
would result in improvements in terms of visual disamenity, particularly in areas that
have experienced disproportionate levels of flytipping in the past. In addition,
separate collection of WEEE may have benefits in terms of increased awareness of
waste in general.
19.11 Complementary Policies
To tackle the growth in generation of WEEE, Ireland introduced the Waste
Management (Restriction of Certain Hazardous Substances in Electrical and
Electronic Equipment) Regulations 2005, which were amended by the Waste
Management (Restriction of Certain Hazardous Substances in Electrical and
Electronic Equipment) Regulations 2008. The RoHS Regulations requires that new
electrical and electronic equipment being put on the market after 1 July 06 cannot,
other than the permitted trace level, contain lead, mercury, cadmium, hexavalent
chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers
(PBDE) in electrical and electronic equipment, where alternatives are available. The
main aim of the RoHS Regulations is to reduce the amount of the six prescribed
substances in the processing and recycling phases in the lifecycle of electrical and
electronic equipment.
In addition the Irish government implemented the Batteries Directive 2006/66/EC in
September 2008. This Directive applies to all types of batteries and accumulators,
regardless of their shape, volume, weight, material composition or use, including
those incorporated into electrical and electronic equipment (EEE) and vehicles. Since
26 September 2008, all Producers and Distributors (Retailers) of batteries must
comply with these Battery Regulations. Producers of batteries must register with the
WEEE Register Society and where they are supplying portable or automotive batteries
can join a compliance scheme such as WEEE Ireland to help meet their collection,
recycling and reporting requirements as specified in the Regulations.
19.12 Effect of the Policy on Pricing of Resources / Services
As mentioned in “Implementation Costs”, a visible Environmental Management Cost
(vEMC) to fund the cost of the environmentally sound management of historic WEEE,
has been added to the cost of new EEE products. The vEMC’s are assigned for
recycling activity and are not diverted elsewhere. The system should lead to an
improvement in the efficiency with which resources are use, though it seems likely
419 Microsoft Ireland (2008) Microsoft's PC Re-use Programme Encourages Low-Cost PCs for Schools
and Charities, http://www.microsoft.com/ireland
373
International Review of Waste Policy: Annexes

that the effect on prices might not reflect either the full costs of collection, or the
environmental costs of materials use.
19.13 Evasion and Enforcement
In 2006 the WEEE Monitoring Group was established. Representatives from all the
key stakeholders are involved and play a pivotal role in monitoring the continued
implementation of the WEEE and RoHS Directives and in advising the Department
and the Minister of further improvements and refinements to the WEEE regime in
Ireland.
The EPA is working closely with the WEEE Register Society (the national producer
registration body) on producer enforcement, particularly those who fail to register,
who fail to join a compliance scheme or self-comply, or who fail to report what they
place on the market to the WEEE Blackbox.
The EPA is also continuing to follow up on any complaints regarding “free-riders”, i.e.
unregistered producers who are continuing to place EEE on the market. Unregistered
producers fail to contribute their share to the cost of environmentally sound
management of WEEE. Where specific instances of transgression have been
identified, Notifications of Non-Compliance are issued. Where the EPA receives no
response or the company continues in non-compliance, a Final Warning Letter may
issue to the company. Inspections are scheduled where non-compliances persist, and
may be followed by legal action where the company fails to comply. The EPA calls
compliance meetings with producers/retailers where necessary in order to raise
awareness of non-compliance with senior management and agree corrective actions
going forward. The EPA refers non-compliant print advertising to the Advertising
Standards Authority for Ireland (ASAI) for follow through with their media member
organisations. The Broadcasting Complaints Commission (BCC) processes complaints
relating to noncompliant television and radio advertising.
The EPA and the National Consumer Agency (NCA) also work together to ensure
correct pricing of EEE at retail premises. NCA inspectors visited over 200 premises in
late 2005 to check that the retail price of EEE products on the shelf were in
compliance with the Product Prices Regulations. Any complaints regarding price
splitting are forwarded to the NCA for their information and follow up.
The EPA is hopeful that those contacted will work towards compliance without
recourse to legal action. However to date, the EPA has taken prosecutions against a
number of different retailers and producers for failure to comply with producer
obligations under the WEEE Regulations. The companies were all convicted in the
District Court and fines and costs were awarded to the EPA.
Under the WEEE Regulations, local authorities have responsibility for enforcement of
retailer obligations. A Producer Responsibility Enforcement Network has been in place
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since June 2006 to guide and co-ordinate local authorities in their enforcement of
producer responsibility initiatives. 420
The EPA is currently carrying out inspections for RoHS compliance. The initial focus is
on high-risk items, i.e. those associated with a high probability of non-compliance
and/or those with a high probability of being disposed of in the general household
waste stream. The EPA is contributing to European Environment Agency (EEA)-wide
enforcement activities through the EU RoHS Enforcement Bodies Network.
There have been self-reported non-compliances, which were discovered by the
producers at very early stages. Some of the infringements required remedial actions
which have already been carried out.
19.14 Lessons Learned
Through this policy:
375
� Industry is encouraged to design its products for the purpose of reuse and
recyclability;
� Collection and treatment infrastructure is tailored to the amount of WEEE
disposed.
� Consumers find the take back comfortable and are not illegally disposing of
their small electric appliances in the residual waste. However, there is no
evidence available that fly-tipping of WEEE is decreasing as a consequence of
this Directive.
The degree to which the re-use / prevention aspects of the policy have been actively
pursued / enforced have probably been somewhat limited, but the proposed re-use
protocol (due for publication shortly) may improve matters in respect of re-use.
420 EPA (2008) ‘Note on Enforcement of the WEEE and Battery Regulations by the EPA’
www.epa.ie/downloads/pubs/waste/weee/epa_enforcement
International Review of Waste Policy: Annexes

20.0 Producer Responsibility, WEEE -
International
20.1 Outline of Policy
Waste electrical and electronic equipment (WEEE) is currently one of the fastestgrowing
waste streams, increasing at a rate three times that of average municipal
waste growth. 421 In the EU, the WEEE directive (2002/96/EC) has been implemented
with the purpose of, as a first priority, the prevention of WEEE, and in addition the reuse,
recycling and recovery of WEEE, thereby reducing the need for its disposal. By
applying a ‘cradle to grave’ approach to EEE products, it also seeks to improve the
environmental performance of all operators involved in the life cycle of electrical and
electronic equipment, in particular those operators directly involved in the treatment
of WEEE. As a companion to the WEEE Directive, Directive 2002/95/EC on the
Restriction of Hazardous Substances (RoHS) also aims to minimise the use of certain
hazardous materials in newly-produced EEE, both to increase the profitability of
recycling WEEE, and to minimise the release of hazardous substances into the
environment by controlling the disposal route of older EEE at the end of its life.
Producers of EEE must provide evidence that the concentrations of hazardous
materials are below defined levels. The six key restricted substances are lead,
cadmium, mercury, hexavalent chromium, polybrominated biphenyls and
polybrominated diphenyl.
The EU WEEE regulations apply to the categories of electrical and electronic
equipment listed below, with sub-categories being the business-to-consumer (B2C)
stream (which ends up pre-dominantly in the householder waste stream) and the
business-to-business (B2B) stream:
376
� Category 1 - Large household appliances;
� Category 2 - Small household appliances;
� Category 3 - IT & telecoms equipment;
� Category 4 - Consumer equipment;
� Category 5 - Lighting equipment;
� Category 6 - Electrical & electronic tools;
� Category 7 - Toys, leisure & sports equipment;
� Category 8 - Medical devices;
� Category 9 - Monitoring & control equipment; and
421 CIWM (2008) Are You WEEE Aware?, The Chartered Institution of Wastes Management, September
2008 Issue, pp. 31-32.
29/09/09

377
� Category 10 - Automatic dispensers.
WEEE regulations must be complied with for all those who generate, handle or
dispose of waste that falls under one of these categories. The WEEE Directive is quite
precise with regard to producer responsibility, specifically referring to “producers”,
providing a definition of what constitutes a “producer” and requiring them to
undertake specific actions. Until recently, these actions were as follows: 422
5) producers must take into account waste management at the design stage of the
product e.g. by making design modifications that make WEEE easier to dismantle,
recycle and recover;
6) producers must guarantee fixed re-use and/or recycling and recovery rates either
individually or via collective organisations (the WEEE directive currently sets a
minimum collection target of 4 kg per annum per inhabitant for WEEE from
households);
7) producers are obliged to finance at least the collection, treatment, recovery and
environmentally-sound disposal of household WEEE deposited at collection sites;
and
8) for WEEE placed on the market after 13th August 2005, producers are obliged to
finance those operations associated with the waste from their own products/
production processes.
Distributors are also linked to the WEEE producer responsibility via an obligation to
take back products free of charge on a ‘one-for-one’ or ‘old-for-new’ basis.
In December 2008, however, a proposal for revised laws on WEEE has been drafted
by the European Commission. With regard to bullet point 2 above, it is proposed that
the collection target be altered from 4 kg per annum per inhabitant to a 65 %
collection rate, calculated according to the average amount of EEE placed on the
market in the two preceding years. In addition, in order to encourage the re-use of
whole appliances, it is proposed that such re-use be included within the 65 % target.
The proposal also goes further than bullet point 3, suggesting that Member States
should, where appropriate, encourage producers to finance all the cost related to
collection facilities for B2C WEEE.
Several countries outside the EU, including Japan, South Korea, Canada, Norway and
Switzerland, have also implemented some form of producer responsibility with regard
to WEEE. Their policies generally look similar in that they attempt to encourage firstly
the re-use, and secondly, the recycling of WEEE. These countries also combine their
WEEE policy with a policy similar to the RoHS, to try to prevent hazardous material
from WEEE being released into the environment. However, the list of EEE to which the
policy applies, and the way in which the safe collection and disposal of WEEE are
funded, varies slightly in some of these countries. Such variations are discussed
further in Section 20.2.
422 ACR+ (2007) Extended Producer Responsibility, Introducing the Debate…, Journal for Sustainable
Waste Management, Warmer Bulletin 112, pp 3-4.
International Review of Waste Policy: Annexes

20.2 Where Has the Policy Been Applied and Why?
In the EU, the WEEE directive (2002/96/EC) became European law in February 2003,
with all MS except Malta and the UK having transposed at least framework
regulations associated with the directive by 13 th August 2005.
Similar regulations surrounding WEEE are also in place in Norway and Switzerland. In
March 1998, Norway signed an agreement concerning the “Reduction, Collection and
Recovery of Electric and Electronic Appliances” with producers, importers and
retailers all being made responsible for the take back of appliances. In Switzerland, a
collection and recovery system for fridges has been in place since 1991, linked to the
requirement to remove and safely dispose of CFCs from these appliances. The
Ordinance on the Return, the Take-Back and the Disposal of Electrical and Electronic
Appliances subsequently came into force in Switzerland in 1998.
Outside of Europe, comparable policies on responsibility for WEEE have also been
placed on the producer. In April 2001, the Electrical Household Appliance Recycling
Law (EHARL) took effect in Japan with responsibility for refrigerators, washing
machines, air conditioners and televisions shifted from local governments to
producers. 423 Likewise, China also has its own WEEE regulations, with Administration
Order No. 40 - the Management Measures for the Control of Environmental Pollution
by Electronic Waste - setting out disassembly, utilization and disposal criteria for all
types of EEE. In 2007, South Korea also implemented legislation for WEEE entitled
the ‘Act for Resource Recycling of Electrical/Electronic Products and Automobiles’.
Various provinces within the USA and Canada are also currently implementing their
own version of the WEEE Directive, designating a list of categories of EEE that require
waste-diversion programmes. In 2004, California introduced an Electronic Waste
Recycling Fee on all new monitors and televisions to cover the cost of their recycling;
in 2007 Ontario introduced a similar fee for computers and accessories, monitors,
printers, fax machines and televisions, and is also looking to add PDAs, copiers,
flatbed scanners, phones and audio-visual equipment to this list in the near future. 424
Reasons for the implementation of WEEE policies in these countries are discussed in
further detail in Section 20.5, with most driven primarily by legal requirement linked
to environmental benefit. Further details on how WEEE policy has been implemented
in specific countries is presented in Section 20.2.1.
20.2.1 Country-specific Characteristics
Table 20-1 summarises some of the key elements of WEEE policy implementation
within the EU, focusing on the registration of producers, reporting requirements,
responsible parties and financial obligations. Two key reviews used to produce this
423 M. Yamaguchi (2002) Extended Producer Responsibility in Japan – Introduction of “EPR” into
Japanese Waste Policy and some Controversy, Japanese Environmental Management Association for
Industry, ECP Newsletter 19, 1-12.
424 S. Deffree (2008) Ontario Begins WEEE Directive Compliance, Electronic Design, Strategy, News,
[Accessed 8 th October 2008], http://www.edn.com/index.asp?layout=article&articleid=CA6535361.
378
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table are the ‘2008 Review of Directive 2002/96 on Waste Electrical and Electronic
Equipment (WEEE)’ produced by the United Nations University (2007) 425 and ‘The
Producer Responsibility Principle of the WEEE Directive’ presented by Ökopol
(2007). 426 Additional references are provided throughout the document.
Supplementary details for several countries listed in Table 20-1, as well as for non
EU-based examples, are also given in this section. In addition, a more detailed case
study for Germany is given in Section 21.0.
Key points to be drawn from Table 20-1 are as follows:
379
� According to the WEEE Directive, all MS require that their producers and
distributors of EEE be registered. For those MS for which information is
available, Germany, Denmark, Finland, Hungary, Ireland, Poland, Portugal and
the United Kingdom all charge their producers and distributors of EEE for
joining the national register. In addition, Denmark, Ireland, Poland and
Portugal also require that their producers and distributors re-new this
registration annually;
� Reporting requirements vary from bi-monthly to annually, with most requiring
at least the ten category split, and a split by B2B/B2C (with the definition of
this split varying from country to country); the implications of the variations in
reporting requirements are discussed in more detail in Section 20.4;
� The responsibilities associated with the set-up and running of the initial
household collection infrastructure for WEEE (i.e. the physical responsibilities)
were not specified in the Directive. Bulgaria, Cyprus, Latvia and Sweden
subsequently assign this responsibility solely to the producer, whereas
Denmark and Germany assign such responsibility to the municipality and
Poland assign it to the distributor. The remaining countries use some
combination of these three key parties;
425 United Nations University (2007) 2008 Review of Directive 2002/96 on Waste Electrical and
Electronic Equipment (WEEE), Final Report produced for the European Commission.
426 Ökopol (2007) The Producer Responsibility Principle of the WEEE Directive, Report produced for the
European Commission.
International Review of Waste Policy: Annexes

Table 20-1: Summary of WEEE policies in EU countries
National National Register
Register
for for for Producers
Producers
Reporting Reporting Requirements Requirements for
for
Producers
Producers
Responsibility Responsibility for for Household Household WEEE
WEEE
Physical Physical Responsibility
Responsibility
Financial Financial Responsibility Responsibility (ex (extended) (ex tended) (Infrastructure (Infrastructure set set-up). set up).
a
Producer Producer
Producer
Responsibility Responsibility for for
for
Non Non-Household
Non Household
WEEE
WEEE
Country
Country
Annual
Annual Frequency
Frequency
Joining
Joining
Renewal
Renewal of of
of
Fee
Fee
Required
Required Reporting
Reporting
Deviations
Deviations
from
from
Reporting
Reporting
Under Under
Under
Categories
Categories
1-10 10
B2B/
B2B/
B2C
B2C Distributor Distributor Municipality Municipality Producer Producer Distributor Distributor Distributor Municipality Municipality Producer
Producer
split
split
Financing
Financing
Structure
Structure
for for for hh
hh
WEEE WEEEb
Historica Historicalc New
New
380
AT Free Yes
BE - -
BG - -
29/09/09
Quarterly/
Annually
Monthly/
Quarterly
Monthly/
Quarterly
5 categories Yes � � � � � - R1 Producer
Also subcategories
Yes � � � S1 R1 Producer
- Yes � � S2 R1 Producer
CY - - - - - � � S1 R1 Producer
CZ Free No Annually None Yes � � � � S1 R1 Producer
DE Yes No Monthly
B2C/
Annually
DK Yes Yes Annually
- - � � S2 R2 Producer
Also subcategories
Yes � � S2 R1 Producer
EE Free No Annually None No � � � � S1 R1 Producer
ES Free No Quarterly
Also subcategories
FI Yes No Annually None Yes
Yes � � � - R1 Producer
�
�
�
S2 R1 Producer

National National Register
Register
for for Producers
Producers
Reporting Reporting Requirements Requirements for
for
Producers
Producers
Responsibility Responsibility for for Household Household WEEE
WEEE
Physical Physical Responsibility
Responsibility
Financial Financial Responsibility Responsibility (ex (extended) (ex tended) (Infrastructure (Infrastructure set set-up). set set up).
a
Producer
Producer
Responsibility Responsibility for
for
Non Non-Household
Non Household
WEEE
WEEE
Country
Country
Annual
Annual Frequency Frequency
Frequency
Joining
Joining
Renewal
Renewal of of
of
Fee
Fee
Required
Required Reporting
Reporting
Deviations
Deviations
from
from
Reporting Reporting
Reporting
Under Under
Under
Categories
Categories
1-10 10
B2B/
B2B/
B2C
B2C Distributor Distributor Distributor Municipality Municipality Producer Producer Distributor Distributor Municipality Municipality Producer
Producer
split
split
Financing Financing
Financing
Structure
Structure
for for for hh
hh
WEEE WEEE WEEEb
Historica Historicalc New
New
381
FR Free No Half-yearly
International Review of Waste Policy: Annexes
Also subcategories
Yes � � � � � S2 R2 Producer
GR - - - - � � S2 R1 Producer
HU Yes No Annually None Yes � � - R1 Producer
IE Yes Yes Monthly
IT - - Annually
Visible fee
sub-category
Also subcategories
Yes � � � � S3 R1 Producer
Yes � � � � - R1 Producer
LT Free Yes Annually None No � � � � - R1 Producer
LU - - Quarterly
Also subcategories
No � � � � S1 R1 Producer
LV Free No Quarterly None No � � S2 R1 Producer
NL Free No Bi-monthly
Visible fee
sub-category
Yes � � � � S1 R2 Producer
PL Yes Yes Quarterly None No � � - R1 Producer
PT Yes Yes Half-yearly
Also subcategories
No � � � � � - R1 Producer

National National Register
Register
for for Producers
Producers
Reporting Reporting Requirements Requirements for
for
Producers
Producers
Responsibility Responsibility for for Household Household WEEE
WEEE
Physical Physical Responsibility
Responsibility
Financial Financial Responsibility Responsibility (ex (extended) (ex tended) (Infrastructure (Infrastructure set set-up). set set up).
a
Producer
Producer
Responsibility Responsibility for
for
Non Non-Household
Non Household
WEEE
WEEE
Country
Country
Annual
Annual Frequency Frequency
Frequency
Joining
Joining
Renewal
Renewal of of
of
Fee
Fee
Required
Required Reporting
Reporting
Deviations
Deviations
from
from
Reporting Reporting
Reporting
Under Under
Under
Categories
Categories
1-10 10
B2B/
B2B/
B2C
B2C Distributor Distributor Distributor Municipality Municipality Producer Producer Distributor Distributor Municipality Municipality Producer
Producer
split
split
Financing Financing
Financing
Structure
Structure
for for for hh
hh
WEEE WEEE WEEEb
Historica Historicalc New
New
382
SE Free Yes Annually None Yes � � - R1 Producer
SI - - - - - � � � � S2 R1 Producer
SK Free No Annually None No � � � � S1 R1 Producer
UK Yes No Quarterly None Yes � � � � S2 R1 Producer
Sources: United Nations University (2007) 2008 Review of Directive 2002/96 on Waste Electrical and Electronic Equipment (WEEE) and Ökopol (2007) The
Producer Responsibility Principle of the WEEE Directive, both reports produced for the European Commission.
a The WEEE Directive indicates that producers are financially responsible for “at least” the collection of WEEE from collection-point onwards, leaving room for
extended responsibility on municipalities, distributors or producers to finance the collection points for households e.g. via take-back schemes, storage
points.
b S1 - Finance WEEE collection, treatment etc. of their own products being placed on the market post 13 th August 2005.
S2 - Allocation of financial responsibility is via their current market share.
S3 - Producers that are members of an approved body are exempt from individual financial responsibility.
c R1 - Producer responsible when replacing old-for-new. Otherwise end-user is responsible.
R2 - The end-user is responsible for financing B2B WEEE.
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383
� The financial structures associated with the WEEE regulations also vary
according to country. Although producers are financially responsible for “at
least” the collection of household WEEE from collection-point onwards, this
leaves room for extended responsibility to draw upon municipalities,
distributors or producers to finance the remaining set-up and running costs of
the household WEEE collection systems. The producer is responsible for these
extended costs in Bulgaria, Cyprus, Spain, Finland, Greece, Hungary, Lithuania,
Latvia, and Sweden, with Germany and Denmark assigning these costs to the
municipality and Poland placing these costs on the distributor. Thus the
municipalities of Germany and Denmark appear to take a larger portion of the
overall responsibility for the delivery of WEEE policy than other MS;
� There are two key categories of household WEEE for which producers are
financially responsible: historical WEEE and new WEEE, with the former placed
on the market prior to, and the latter after, 13 th August 2005. Considering that
producers could not influence the design of products placed on the market
before the Directive came into force, producers are assigned collective
responsibility for historical WEEE, calculated according to their current market
share. For new WEEE, the producer must bear individual financial
responsibility and, since it cannot be assumed that all producers on the
market today will remain on the market when their products are collected as
WEEE, they must also provide a financial guarantee to ensure that these costs
do not fall on other producers in the future. In countries such as Finland,
Germany and the UK, financial responsibility for new WEEE is made through
contributing to a collective pot, with payments calculated according to their
current market share. This system usually provides sufficient financial
guarantee should the company cease trading. In countries such as Belgium
and the Netherlands, the producer pays specifically for the collection and
treatment of their own returned WEEE. In this instance, some form of financial
guarantee is required (such as recycling insurance or blocked bank accounts)
to account for the possibility that the company ceases trading in future; 427 and
� In all countries, the producer is financially responsible for B2B WEEE placed on
the market after 13 th August 2005. However, the producer may conclude
contracts with end-users which stipulate other financing methods for B2B
WEEE. Regarding historical B2B WEEE, the end-user is financially responsible
in Germany, France and the Netherlands. In all other countries in the EU, the
producer is financially responsible where any historical B2B is being
exchanged for new EEE products on a like-for-like basis; the end-user is only
financially responsible when they do not wish to replace the historical WEEE
with a new like-for-like product.
427 WEEE Forum, Guidance Document, [Accessed 8 th October 2008], available at http://www.weeeforum.org/doc/WEEE_Forum_Guidance_for_Compliance_En.pdf
International Review of Waste Policy: Annexes

20.2.1.1 Austria
In Austria, the majority of household WEEE collections are undertaken via municipal
collection sites. The majority of municipal sites (92.5 % as of 2006) are signed up to
contracts with collective compliance schemes, with variable fees paid to those
collection sites based on the amounts collected. Any municipal sites that are not
signed up to contracts with collective schemes are entitled to lump sums based on
the types of equipment collected and the size of the collection centre. The WEEE
Coordination Body acts as a clearing house in Austria, assigning the pick-up and
treatment of any WEEE collected by municipalities and not covered by contracts. 428
National legislation in Austria excludes retailers with sales areas less than 150 m 2
from the obligation of taking back WEEE from consumers on a 1:1 basis. In addition,
their legislation states that producers must set up at least one collection point per
district. Reflecting their pre-WEEE directive legislation, WEEE in Austria must be
sorted into five categories (large appliances, cooling equipment, CRTs, small
appliances and gas discharge lamps). 428
Implementation of the WEEE Directive in Austria requires that EEE is labelled correctly
(crossed-out dustbin on wheels with line under it), that levels of hazardous
substances are below those specified in the RoHS, and that all producers/distributors
of EEE are registered.
Prior to the WEEE Directive, Austria had only one collective system provider. However,
the transposition of the Directive led to the creation of a more competitive
environment by introducing four more collective producer systems and also allowing
individuals to take on their own financial responsibility for WEEE. 429 In the collective
systems, the provider makes an estimate of how many units will be sold within a
particular time frame and the cost to collect and recycle those units is calculated and
billed to the producer/distributor. The provider is then legally responsible to ensure
that collection points are prepared to accept the products in question. Where the
producers/distributors assume collection and recovery obligations by themselves,
their products must be readily identifiable and they must conclude individual
collection agreements with potential points of collection.
20.2.1.2 Germany
As in Austria, the municipality provides the main avenue for WEEE collection in
Germany. The municipality is responsible for the collection of WEEE from
householders and for the education of the public to source-separate this waste
stream. Unlike many other EU countries, distributors are not obliged to provide a 1:1
collection service in Germany (taking back an old product when a new one is
428 http://www.buyusa.gov/austria/en/weeefaqs.html
429 R. Veit (2005) How do WEEE get it right?, EMSNow, available at
http://www.emsnow.com/npps/story.cfm?id=15184
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purchased), though some offer it voluntarily. 430 Thus the municipality bares a
relatively large overall responsibility for WEEE compared to the majority of other MS.
The EAR foundation centrally co-ordinates WEEE in Germany, assigning ‘pick-ups’ of
WEEE stored at municipal collection sites to producers that are based on an algorithm
method. EAR also allows producers to deduct any individually-collected WEEE from
their allocated share of WEEE that must be collected from the municipal collection
sites. The producers must finance the containers, collection, treatment and recycling
of household WEEE. Germany has opted for full competition among producers
regarding WEEE; consortia of EEE producers are allowed, but the competition
authority has made it clear that it would oppose any consortia of producers whose
market share of any EEE type exceeds 25 % (except for lamps). 431
A financial guarantee is required from all producers. ElektroG provides producers the
choice to finance WEEE collection either from their own products or via a calculated
obligation that is based on the producer’s market share (as per historical WEEE
financial responsibility allocation). The majority of producers choose to finance their
new WEEE obligations based on their current market share of the total EEE quantity
per equipment type, and provide a financial guarantee by participating in an
appropriate funding system, such as recycling insurance or provision of a blocked
bank account. This guarantee is then triggered only once the last remaining producer
exits the market in a particular product group, with the consequent low risk equalling
low premiums. Premiums in this system do not reflect the degree of difficulty of
subsequent recovery of the WEEE at the end of its life, being calculated only
according to the amount of WEEE collected.
20.2.1.3 Japan
In April 2001, the Electrical Household Appliance Recycling Law (EHARL) took effect in
Japan, with responsibility for refrigerators, washing machines, air conditioners and
televisions shifted from local governments to producers. In Japan, retailers are now
also obligated to take-back products at the end of their life and to transport them to
producer stock-points. Contrary to the EU, consumers in Japan are notified of any
recycling fees when they purchase EEE products, but are not required to pay the
recycling fee until the point of disposal (typically when returning the WEEE to
retailers). 432 This recycling fee only covers the cost of collection and pre-treatment,
with any remaining cost met by the producer. The introduction of recycling fees in
Japan has led to an increase in illegal dumping of WEEE, but also to a substantial
increase in the second-hand market for EEE. As a consequence of the introduction of
430 LetsRecycle (2005) Germany implements the WEEE Directive, [Accessed 9 th October 2008],
available at http://www.letsrecycle.com/news/archive/news.jsp?story=4222
431 R. Veit (2005) How do WEEE get it right?, EMSNow, available at
http://www.emsnow.com/npps/story.cfm?id=15184
432 H. Aizawa, H. Yoshida and S-I. Sakai (2008) Current results and future perspectives for Japanese
recycling of home electrical appliances, Resources, Conservation and Recycling, 52, 1399-1410.
385
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the fee, the average lifespan of the television increased from 11.8 years to 12.5 years
from 1997 to 2003. 433
In order to promote good design in order to reduce the recycling fees required, the
fees do not have to be uniform from company to company. However in reality,
Matsushita Electric Industrial Co., Ltd was the first to set fees, and the majority of
companies have followed suit by setting their fees at the same level. In addition, most
leading manufacturers of electric appliances have subsequently set up new recycling
plants via alliances to process WEEE – as of 2002 there were 16 new recycling plants
for this purpose. 433 Business consumers can either bring their WEEE to retailers and
pay a fee, or treat WEEE as industrial waste at their own expense. 434 In rural areas,
some municipalities still take care of WEEE on behalf of their householders, charging
them for either taking the WEEE directly to a pre-treatment company, or returning
them to aggregation points along with payment of the necessary fees.
It is difficult to compare the Japanese and European systems, given that only four
categories of WEEE are included in Japan, that the term ‘recycling rate’ in Japan only
refers to any recycled material that is subsequently sold or taken back by someone
free-of-charge (i.e. where the producer must pay to offload the recycled materials, this
does not count towards the recycling rate), and that the EU system currently sets a
weight-based collection target rather than expressing their collection rate as a
percentage of the total WEEE in the system. For Japan, the recycling target for
televisions has been set at 55 %, but in 2003 Japan was already exceeding this target
by achieving a recycling rate of 78 % (all at a positive monetary flow). 434 The Japanese
system is also generally viewed as providing greater incentives for ‘eco-design’ of EEE
because, as stated above, the manufacturers/producers are closely linked to
recycling plants, with the consequent emergence of ‘design for disassembly’ and the
‘automated disassembly using smart materials (ADSM). 435
20.2.1.4 Norway
Although Norway is not a member of the EU, it implemented its own WEEE policy back
in 1998 entitled the “Reduction, Collection and Recovery of Electric and Electronic
Appliances”. In 2006, this policy was revised to include the EU WEEE Directive
requirement that all producers/distributors of EEE are registered. The WEEE policy in
Norway applies to a slightly broader number of products than in the EU, including the
distribution and metering of electric current and electromagnetic fields.
433 M. Yamaguchi (2002) Extended Producer Responsibility in Japan – Introduction of “EPR” into
Japanese Waste Policy and some Controversy, Japanese Environmental Management Association for
Industry, ECP Newsletter 19, pp 1-12.
434 K. Sasaki (2004) Examining the Waste from Electrical and Electronic Equipment Management
Systems In Japan and Sweden, Master’s Thesis, Lund University, Sweden.
435 Arcadis (2008) Study on RoHS and WEEE Directives, European Commission DG Enterprise and
Industry March 2008.
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In order to facilitate their financial responsibility for WEEE, every producer is required
to be a member of a ‘take-back’ scheme. There are two national collection schemes
in place in Norway: Elretur and Renas are responsible for the education, collection
and processing of household and non-household WEEE respectively. In addition, other
take-back schemes also exist, with all schemes requiring approval from the
Norwegian Pollution Control Authority. Collection systems are via a series of collection
points (including municipal facilities) and via distributor/retailer outlets. Distributors
are obligated to inform customers that they can receive WEEE. Unlike a large number
of EU countries, consumers can return WEEE to distributors without having to
purchase a new product, as long as the distributor sells similar products. This
approach is also in place in Switzerland and on a voluntary basis in Denmark.
According to the Norwegian Pollution Control Authority, Norway was collecting
approximately 28 kg WEEE per inhabitant in 2006, with 85 % of this collected WEEE
subsequently re-used, recycled or used to generate energy. 436 According to the United
Nations University report, this figure is somewhat lower at 13.41 kg per inhabitant per
year. Either way, Norway remains one of the top performing countries discussed in
this report.
20.2.1.5 South Korea
The ‘Act for Resource Recycling of Electrical/Electronic Products and Automobiles’
came into force in South Korea in 2007, building on the previous Extended Producer
Responsibility law of 2003. The aim of this Act was to establish a law to cover the
entire product life cycle of EEE, to promote recycling and to ensure restrictions on the
use of hazardous substance in product design. This Act follows a similar design to
that of the EU, to ensure that manufacturers meet international standards and are
able to continue exporting goods to the EU and elsewhere in the world. Eco-design is
included in its requirements, with implementation geared towards continuous
improvement in product design and recycling technology as and when these become
technically and economically feasible. 437
In Korea, the producers/importers of EEE must designate a collection depot for their
products and inform their distributors of the chosen depot. When customers purchase
new products, distributors are obliged to provide free take-back of old WEEE from the
customer. Distributors can either arrange for the re-use of the WEEE themselves, or
they must transport the collected WEEE to the designated collection depot. Producers
may either take part in a collective scheme e.g. join a Recycling Mutual Aid
Association, or may take individual producer responsibility for their EEE. 438
436 Norwegian Pollution Control Authority (2008) Waste Electrical and Electronic Equipment, [Accessed
13 th October 2008], Available at http://www.environment.no/Tema/Avfall/Waste-electrical-andelectronic-equipment/
437 J. Yoon (2007) Report on the Analysis of the Act for Resource Recycling of Electrical/Electric
Products and Automobiles (Korea RoHS/ELV), available at http://www.koreahelpdesk.eu/rohs/korea/Ecofrontier_KoreaRoHS.pdf
438 RSJ Consulting (2007) What is Korea “RoHS”?, available at
http://www.rsjtechnical.com/WhatisKoreaRoHS.htm.
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There are, at present, certain specifics within the Act that require further decisions
before it can become fully effective within South Korea. These decisions include
which hazardous substances to restrict, the mandatory recycling rates that will be set
for the various types of EEE (though the Act has already specified that these rates will
be based on how much WEEE is separately collected compared to the yearly amount
of EEE that is produced, as well as past performance records of recycling), and
acceptable recycling methods and standards.
20.2.1.6 Sweden
In Sweden, until recently El-Kretsen has been the single national collective system for
compliance with WEEE producer responsibility requirements. The collection system
from householders has achieved the highest rate of collection reported in the EU,
reaching 15.8 kg per capita per year in 2006. Collection is via WEEE containers at
municipal collection sites, with municipalities providing storage space to accept WEEE
from households. The provision and collection of these containers is financed by
producers. There are currently over 1,000 collection sites in Sweden, with 700
available for household and more than 300 available for non-household WEEE. El-
Kretsen’s nationwide collection and recycling system currently also covers 5 % of EEE
retailers and business consumers.
The success of this collection system has been attributed to the level of cooperation
between the partners, municipalities and contractors, plus the willingness of the
public to participate in the separate collection. The system has also simplified how
historical WEEE collection is financed, because there has been only one compliance
scheme, removing the need to verify that each scheme is handling the required
amount of historical WEEE.
A new compliance solution is, however, currently emerging on the Swedish market
that will mostly likely use an existing network of 2-3 large retailers for its collection
system. In addressing the need for greater competition within the WEEE market in
Sweden, the outcome should be lower costs of compliance, and hence, at the margin,
lower product prices. 439 However, this additional compliance solution will add
complexity to the system – with the probable need for a clearing house in order to
apportion historical WEEE collection.
Distributors in Sweden are not obligated to offer WEEE take-back on a 1:1 basis due
to the relatively strong performance of the municipal collection systems.
Financial guarantees for the producer responsibility system can be offered via
recycling insurance, blocked bank accounts, an annual bank guarantee or via
membership in collective finance systems. In Sweden, recycling insurances in
particular are being used as a way of influencing product design. Whereas in
countries such as Germany where the recycling insurance is only calculated according
to the amount of WEEE production, in Sweden the insurance premiums are being
adjusted to reflect a combination of the following: the projected future cost to recycle
439 R. Veit (2005) How do WEEE get it right?, EMSNow, available at
http://www.emsnow.com/npps/story.cfm?id=15184
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that product, the risk that the materials will be classed as hazardous in the future, as
any expected increases in efficiency of the recycling process, and projected future
material revenues. 440 Thus premiums become lower where the company can
demonstrate ease of recycling of their product, thereby providing financial incentive
for companies to look for more environmentally-friendly product designs.
20.2.1.7 Switzerland
In 1998, the Swiss Government issued an Ordinance on the Return, the Taking Back
and the Disposal of Electrical and Electronic Appliances (ORDEA), placing
responsibilities on the consumer to return the product at the end of its life, and on the
retailer to take back the product from the consumer free-of-charge. The Swiss
Foundation for Waste Management (SENS) covers all categories listed in the EU
directive except category three (IT and telecommunications) and category four
(consumer equipment) products, which are covered by The Swiss Association for
Information, Communication and Organisational Technology (SWICO). In addition, the
Swiss Association for Illumination (SLG) operates a collective scheme for lighting
equipment.
Producers and importers have to pay an advanced recycling charge in Switzerland for
every product that they place on the Swiss market. The charge is calculated based on
the retail price. 441 Switzerland differs from the EU, because buyers pay an advanced
advertised recycling fee on top of the purchase price which the producers/importers
then use to pay their recycling charge and finance collection and treatment of WEEE.
The consumer can return the WEEE to a distributor or other collection point free of
charge for processing. Similar to Norway, distributors are obliged to take-back similar
EEE without the consumer having to purchase a new product. A disadvantage to this
approach could be that certain distributors receive more than others. However a
reimbursement is used in Switzerland to account for any imbalance, and the system
has led to greater increases in take-back from distributors than from municipality
collection sites in recent years.
The ordinance does not specifically dictate whether companies must take
responsibility via individual or collective means, but in reality most companies join a
collective scheme. 442 There are approximately 450 official collection points managed
by SENS alone (including around 130 municipalities), 9000 retailers that accept takeback,
and more than 30 treatment partners. 443
440 Recycling M@gazine (2007) What if you could Eliminate the Risk? Insurances as a Way of Hedging
Against Future Recycling Costs, Recycling M@gazine 12, 18-21.
441 R. Veit (2005) How do WEEE get it right?, EMSNow, available at
http://www.emsnow.com/npps/story.cfm?id=15184
442 HKTDC (2006) WEEE and RoHS Transposition Update – Norway, Switzerland and Liechtenstein,
Business Alert EU, [Accessed 13 th October 2008], available at
http://info.hktdc.com/alert/eu0615d.htm
443 SENS (2007) Swiss Foundation for Waste Management, [Accessed 13 th October 2008], available at
www.sens.ch
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20.2.1.8 UK
The UK regulations on WEEE came into force in January 2007. Obligated companies
must register with an approved producer compliance scheme (PCS), which submits
WEEE data to the Environment Agency on behalf of its clients and provides logistic
solutions to fulfil collection and recycling obligations. Over 4,000 producers have now
joined one of the 40 producer compliance schemes in the UK (figures from BERR).
There is a network of designated collection facilities (DCFs) that accept WEEE from
UK households free of charge; this network received financial support from retailers
via a distributor take-back scheme which Valpak has been appointed to manage. All
local authority civic amenity sites are designated DCFs. It should be noted that the
level of support that the local authority civic amenity sites receive from Valpak was
one of a number of major hurdles which slowed the implementation of the UK
regulations. Distributors of EEE must accept similar WEEE on a 1:1 basis.
Treatment via accredited treatment facilities is also funded via PCSs. Originally a
national allocation centre was meant to be set up to allocate designated collection
facilities to PCSs, but this has since broken down, and PCSs now seek their own
collection facilities. B2B is managed in similar fashion, but there is no distributor
take-back scheme; most items should be collected free of charge by PCSs and sent to
treatment facilities via funding from obligated companies. However in reality, despite
the B2B arrangements, a large number of companies within the UK are not calling
upon the producer to collect their WEEE, rather they are just paying to have mixed
loads taken off their hands.
20.3 Key Organisations Involved in Implementation and
Management
For the majority of countries listed in Section 20.2.1, varying degrees of both physical
(infrastructure set-up) and financial responsibility exist between the producer,
distributor and municipality. Combinations of responsibility are illustrated in Table
20-1 for countries within the EU. The producer is named as financially responsible for
the WEEE from “at least” collection-point onwards in the WEEE Directive; this leaves it
open as to the extent to which responsibility for collection itself might rest with the
municipality, the distributor or producer. There is clearly a need to finance the
containers, storage space and collection-system required to collect WEEE from
households. In countries such as Sweden and Finland, the producer is financially
responsible for all aspects of WEEE collection, whereas in Germany the municipality
takes on some of this financial responsibility and in Belgium, any additional financial
responsibility rests with the distributor.
Various combinations of physical responsibility also exist, with Germany again placing
a greater degree of this responsibility on the municipality compared to countries such
as Finland and Sweden, which require the producer and distributor to have greater
responsibility for the set-up of WEEE collection infrastructure.
In addition to the producer, distributor and municipality, various organisations provide
both re-use and recycling support to WEEE policies. A number of organisations such
as the previously mentioned EAR foundation in Germany and El Kretsen in Sweden
facilitate collective responsibility for the recovery and disposal of WEEE in these
countries. Furthermore, a number of organisations focus specifically on the re-use of
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particular streams of WEEE. For example, Fonebak in the UK currently processes
more than 250,000 mobile phones per month, with approximately 80 % being
refurbished and sent to developing countries, and the remaining 20 % being sent for
recycling. Fonebak has been granted licences by the Environment Agency and the
Department for Business Enterprise and Regulatory Reform to operate as a Producer
Compliance Scheme, an approved treatment facility, a designated collection facility
and an approved exporter, thus providing an end-to-end solution for mobile phone
producers. 444 Likewise, Computer Aid International refurbishes laptops and PCs,
which are then used to support e-learning in countries such as Kenya, Madagascar
and Zambia.
Finally, the householder also plays an important role in the success of the WEEE
policy. Householder participation was acknowledged by Sweden as one of the key
reasons for their relatively high WEEE collection rates compared to other EU
countries.
20.4 Pre-implementation / Evaluation Studies Available
Arcadis (2008) Study on RoHS and WEEE Directives, European Commission DG
Enterprise and Industry, March 2008.
Greenpeace (2008) Toxic Tech: Not in Our Backyard, Uncovering the Hidden Flows of
e-Waste.
Ökopol (2007) The Producer Responsibility Principle of the WEEE Directive, Report
produced for the European Commission.
United Nations University (2007) 2008 Review of Directive 2002/96 on Waste
Electrical and Electronic Equipment (WEEE), Final Report produced for the European
Commission.
20.5 Environmental Benefits
Regarding waste prevention, the main aims of the WEEE policy were originally to
provide the following key environmental benefits:
391
� Decline in the waste produced whilst manufacturing WEEE products as well as
the minimisation of waste produced at the end of the product’s life, both of
which lead to a reduction in WEEE heading to landfill;
� Encouragement of the re-use of WEEE by designing products that are reusable,
long-lived, and capable of being readily remanufactured or refashioned;
� Reduction in the leakage of potentially hazardous materials by controlling the
toxicity of the product and ensuring its safe disposal (includes RoHS);
444 Regenersis (2007) ‘WEEE Are Ready’ Say Mobile Phone Reuse and Recycling Leaders, 29 th June
2007, available at:
http://www.fonebak.com/WEEE%20Are%20Ready%20Say%20Mobile%20Phone%20Reuse%20and%2
0Recycling%20Leaders.aspx
International Review of Waste Policy: Annexes

392
� Avoidance of ozone-layer depleting substances. The net environmental gain
from diverting products from disposal is consequently greatest for the
Category 1B (cooling and freezing appliances) and lowest for Category 7 (toys
etc);
� Improvement in the environmental performance of products throughout their
lifetime e.g. by making them more energy efficient or removing the stand-by
mode.
However in reality, it appears that the requirements listed in the WEEE Directive (see
Section 20.1) focus on weight-based targets for recycling and re-use rather than on
prevention; thus recycling has formed a significant driver for the national policies. The
ability to take part in collective systems with financial responsibility based on market
share rather than individual products has also contributed to the reduced incentive
for producers to design their individual products with waste minimisation as a priority.
Only the RoHS has readily provided for a reduction in the leakage of potentially
hazardous materials from WEEE.
Measurement of the effectiveness of WEEE policies as drivers for the prevention of
this waste stream are difficult, given that the only key reporting requirement to date
with such policies has been the amount of WEEE that is collected for re-use, recycling
or safe disposal. According to Arcadis (2008), there are limited conclusions to draw
on the impact of the WEEE Directive on the share of company resources allocated to
R&D within the EU. Direct consultations with industry stakeholders have suggested
that the Directive has had limited influence over decisions to allocate resources to
R&D in order to meet WEEE requirements. The significant number of drivers for ecodesign
further complicates R&D decision-making. 445 In Japan, advances such as the
automated disassembly using smart materials (ADSM) indicate that this policy system
may be providing more incentives for design change and waste prevention, with the
EEE manufacturers closely linked to the recycling installations. 446
Rather than encouraging waste prevention, the WEEE policies in place appear to be
more effective in terms of the recycling and correct disposal of products at the end of
their life, leading to a reduced burden on primary material stores and, in combination
with RoHS, easier ability to recycle products and a reduction in the leakage of
hazardous and polluting substances during the disposal of WEEE. It should be noted
that WEEE is not a homogenous waste stream; its heterogeneity adds to the
complexity of recovery, but also provides a number of materials that can be re-used,
including metals, plastics and glass.
The EU WEEE Directive currently sets a minimum collection target of 4 kg per annum
per inhabitant.
445 OECD (2006) EPR Policies and Product Design: Economic Theory and Selected Case Studies,
Working Group on Waste Prevention and Recycling, Environment Policy Committee.
446 Arcadis (2008) Study on RoHS and WEEE Directives, European Commission DG Enterprise and
Industry, March 2008.
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Table 20-2 gives the amount of each category of WEEE collected according to country;
the collection performance in the listed EU countries is similar to Norway and
Switzerland for Category 1 WEEE, but Norway and Switzerland appear to perform
better when collecting other categories of WEEE, with only Sweden providing
comparable overall collection amounts. However, as noted in the UNU report, the
current 4 kg target will be easier to reach in those countries that produce more EEE in
the first place, rather than truly reflecting the re-use, recycling and safe disposal of all
WEEE produced. The UNU report concludes that there is a rough correlation between
relative affluence and the amount of WEEE generated, suggesting that in Western
Europe WEEE arisings are in the region of 14-24 kg/head, while New Members are
likely to be 6-12 kg/head.
Table 20-2: Collection Performance (kg/inhabitant) by WEEE category
Country
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International Review of Waste Policy: Annexes
WEEE Category Number
1 2 3 4 5 6 7 8 9 10
Japan 2.58 n.d. 0.82 n.d n.d n.d n.d n.d n.d n.d N/A
Totals
Norway 8.15 0.46 2.68 2.01 - - 0.04 0.06 - 0.01 13.41
Switzerland 4.19 1.40 3.52 2.17 0.12 0.04 0.01 0.00 0.00 0.00 11.44
Austria 2.00 0.3 0.1 0.2 0.1 Inc2 Inc2 Inc2 Inc2 Inc2 2.77
Belgium 2.99 1.12 1.16 1.64 0.20 0.14 0.00 0.02 0.00 0.00 7.26
Czech R 0.14 0.00 0.12 0.05 0.00 0.00 0.00 0.01 0.00 0.01 0.33
Estonia 0.48 0.00 0.04 0.10 n.d. n.d. n.d. n.d. n.d. n.d. 0.63
Finland 4.75 0.28 1.44 1.30 0.27 0.03 0.00 0.02 0.01 0.00 8.10
Hungary 0.91 0.04 0.09 0.22 0.01 0.00 0.00 0.00 0.00 0.00 1.27
Ireland 6.68 0.28 0.43 0.67 0.09 0.07 n.d. n.d. 0.00 n.d. 8.22
Netherlands 2.59 0.53 n.d. 1.18 0.03 0.06 0.03 0.00 0.00 0.02 4.44
Slovakia 0.35 0.04 0.05 0.20 0.02 0.00 0.00 0.00 0.00 0.00 0.66
Sweden 5.01 1.41 2.54 2.36 0.74 0.11 0.02 0.02 n.d. n.d. 12.20
UK 7.17 0.54 0.59 1.10 0.04 0.35 0.16 0.00 0.00 0.00 9.95
EU average 3.11 0.42 0.65 0.88 0.14 0.08 0.02 0.01 0.00 0.00 5.31
n.d. no data, Inc2 = included in Category 2 figure
Source: United Nations University (2007) 2008 Review of Directive 2002/96 on Waste Electrical and
Electronic Equipment (WEEE), Final Report produced for the European Commission.
In addition, the 4 kg per household figure does not discriminate in favour of those
products that have the highest economic or environmental relevance; for example,
the collection of refrigerators containing CFCs is more important for meeting
environmental objectives so the targets should be set to reflect this importance. The
rate of CFC extraction from old appliances and disposal without emission to air was
reported in Recycle.co.uk as only 42 % in Germany compared to 91 % in Austria,

stemming from a current lack of incentive to treat products in the most
environmentally-friendly way if it requires further processing and added expense. 447
The recent proposed revision to the EU WEEE Directive includes a change in collection
targets from 4 kg per annum per inhabitant to a 65% collection rate, calculated
according to the average amount of EEE placed on the market in the two preceding
years. This proposed target is more in line with the current Japanese system. In
addition, in order to encourage the re-use of whole appliances, it is proposed that
such re-use be included within the 65 % target. In addition, the proposed revision
presents the possibility of setting a separate collection rate for cooling and freezing
equipment in 2012.
Despite the figures presented in Table 20-2, it is estimated that only 25 % of WEEE
arisings within the EU are currently being collected and treated, with no precise data
available on what happens to the remaining 75%, termed ‘hidden flow’ in one
Greenpeace report. 448 It is considered to be likely that some portion of this ‘hidden
flow’ is being illegally exported to non-EU countries with lower treatment standards,
leading to increased risk of the release of hazardous substances to the environment,
an increase in the direct exposure of workers to hazardous substances associated
with the ‘informal’ recycling of WEEE in countries such as India and Thailand, as well
as the loss of valuable secondary raw materials.
Aside from the aforementioned problems associated with the current 4 kg collection
target in the EU, this target also makes it difficult to analyse the effectiveness of
policy variations on the resultant recycling of WEEE, because it does not determine
the amount of WEEE that is subsequently disposed of as opposed to being re-used or
recycled. In contrast, in Japan, recycling targets are set according to EEE placed on
the market, and the term ‘recycling rate’ in Japan only refers to any material that is
recovered without a negative balance (i.e. where the producer does not then have to
pay a firm to recycle the material). The fact that Japan was, for example, already
exceeding its 55 % target for the recycling of televisions in 2003 suggests that the
Japanese system may be more effective than the current EU system in encouraging
the re-use and recycling of WEEE. Similarly, as reported by Greenpeace (2008), Sony
in Japan are one of the few brands where a recycling rate of 53% has been achieved,
leaving a smaller ‘hidden flow’ than that found in the current EU system.
Notwithstanding these data limitations, it seems reasonable to assume that though
many of the original EU-15 have had little problem meeting a 4kg per inhabitant per
annum target, the proposed 65% collection target is likely to prove far more
challenging. Not only is this likely to require more comprehensive coverage by WEEE
collection and take-back systems, but the need to demonstrate this through formal
channels is likely to put pressure on Member States to reduce the export of WEEE
through informal channels. This might not imply an end to exports per se, but would
447 S. Flanagan (2008) UK recyclers should not follow German WEEE model, Recycle.co.uk: Don’t Bin
it, Recycle it, available at: http://www.recycle.co.uk/news/614000.html
448 Greenpeace (2008) Toxic Tech: Not in Our Backyard, Uncovering the Hidden Flows of e-Waste.
394
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demand that the receiving facilities in third countries were shown to be operating to
environmental standards broadly equivalent to those applied within the EU.
20.6 Implementation Costs
The financial model for WEEE producer responsibility will provide a key incentive for
the degree to which producers will change the design of their products to try and
minimise waste and facilitate easier recovery. As detailed in Table 20-2, the financial
options available to EU producers vary according to MS; for household WEEE, some
producers finance their responsibility individually via their own products being placed
on the market (new WEEE), with historical WEEE obligations allocated via current
market shares. In these circumstances, the producer is more likely to design their
product with waste minimisation in mind, as they are directly responsible for their own
WEEE. Some producers have the opportunity to take part in collective producer
responsibility organisations (PROs) such as El Kretsen, which then organise the
collection, treatment and disposal on the producer’s behalf. For non-household
WEEE, the producer is financially responsible for any B2B WEEE placed on the market
after 13 th August 2005. The end-user is financially responsible for financing all
historical B2B WEEE in countries such as Germany, France and the Netherlands,
whereas the producer is also financially responsible for historical WEEE in the
remaining EU countries, so long as the customer is replacing old historical WEEE for
new.
It should be noted that, unlike the EU system, consumers in Japan are notified of any
recycling fees when they purchase EEE products, but are not required to pay the
recycling fee until the point of disposal (typically when returning the WEEE to
retailers). 449 This recycling fee only covers the cost of collection and pre-treatment,
with any remaining costs met by the producer.
Financial Financial Financial guarantees
guarantees
Financial guarantees are required within WEEE policies (particularly for household
WEEE), because it cannot be assumed that all producers that are in the market today
will remain active in the market by the time their products are collected as WEEE
(because some products have life-times of considerable length). Most MSs see
membership in collective schemes as sufficient guarantee for those meeting their
obligations via this channel i.e. producers will be responsible for other producers’
products in the event that one member exits the market. For those producers wishing
to comply individually, a blocked bank account or recycling insurance may also be
used to satisfy the guarantee requirement. As discussed previously in Section 20.2.1,
mechanisms such as recycling insurance vary from country to country, with Germany
calculating premiums according to amounts of WEEE, compared to Sweden where
premiums account for the ease of recycling the product at the end of its life.
449 H. Aizawa, H. Yoshida and S-I. Sakai (2008) Current results and future perspectives for Japanese
recycling of home electrical appliances, Resources, Conservation and Recycling, 52, 1399-1410.
395
International Review of Waste Policy: Annexes

Throughout Europe, the costs of implementing WEEE policies varies widely,
depending on a large number of factors as follows: 450
396
1. Some MS already had legislation in place concerning WEEE prior to the
directive, therefore infrastructures and systems were already actively in place,
reducing set-up costs to comply with the directive (e.g. Austria, Belgium,
Denmark, Sweden and Luxembourg). It should be noted that, according to the
UNU report, estimations for 2007 show costs to be decreasing over time, with
anything up to a 27 % reduction in total costs for specific categories; 450
2. The collection infrastructure currently in place e.g. the number of collection
points that require servicing, the minimum amounts of WEEE to be collected,
the geographical and traffic situation for transport costs, the number of staff at
each collection point;
3. Cost of permits for collection and treatment of WEEE;
4. Treatment standards required by the MS;
5. Enforcement of legislation on the export of WEEE to other countries i.e. how
much WEEE ends up as ‘hidden flow’;
6. Disposal costs e.g. landfill taxes, incineration etc;
7. Possible profits for recovery of materials;
8. Financial guarantee costs;
9. Education/ awareness raising costs;
10. Research and development costs;
11. Reporting requirements; and
12. The market situation: where a monopolistic system exists (as was the
situation in Sweden until recently) there is less competition, resulting in more
costly products for the consumer.
Table 20-3 shows a breakdown of the range of total costs associated with the various
categories of WEEE across the MS and Table 20-4 shows the costs for the longer
running compliance schemes. These tables illustrate the point that where systems
have been in place for longer, the range of costs and the average cost tends to
decline.
450 United Nations University (2007) 2008 Review of Directive 2002/96 on Waste Electrical and
Electronic Equipment (WEEE), Final Report produced for the European Commission.
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Table 20-3: Range of Total Costs for WEEE across the Member States
Category of WEEE
397
Total Costs (€/t)
MIN MAX
1a LHHA - 933.16
1b C&F 194.00 880.37
2 SHA 138.56 1,246.03
3a IT ex CRT 135.38 1,703.56
3b IT CRT 164.00 1,393.65
4a CE ext CRT 138.56 1,328.47
4b CE CRT 164.00 1,393.65
5 Light 555.78 2,568.62
6 Tools 204.09 1,043.99
7 Toys 390.42 610.49
8 Medical 168.35 562.24
9 M&C 253.26 1,382.48
10 Aut. Disp. 254.63 483.99
Source: United Nations University (2007) 2008 Review of Directive 2002/96 on Waste Electrical and
Electronic Equipment (WEEE), Final Report produced for the European Commission.
Table 20-4: Total WEEE costs per product category for long running schemes (fully
operative pre-2005 and having at least 3 data sets for definition of minimum,
maximum and average costs).
Category
Total Costs (€/t)
MIN MAX
AVERAGE
1a LHHA
54.46 457.90 235.31
1b C&F
338.46 811.49 557.70
2 SHA
272.44 499.21 383.13
3a IT ex CRT
272.08 539.23 379.69
3b IT CRT
349.26 621.48 499.29
4a CE ext CRT
254.48 549.37 422.12
4b CE CRT
428.55 621.41 528.01
5 Light
561.15 840.00 662.83
6 Tools
220.83 341.49 300.79
7 Toys
409.56 609.16 495.15
8 Medical
238.64 529.79 409.64
Source: United Nations University (2007) 2008 Review of Directive 2002/96 on Waste Electrical and
Electronic Equipment (WEEE), Final Report produced for the European Commission.
International Review of Waste Policy: Annexes

20.7 Complementary Policies
398
� Directive 2002/95/EC on the Restriction of Hazardous Substances (RoHS)
must also be considered as a policy driver alongside producer responsibility for
WEEE in the EU; the RoHS Directive aims to minimise the use of certain
hazardous materials in newly-produced EEE and to minimise the release of
hazardous substances into the environment by controlling the disposal route
of older equipment at the end of its life. Producers must provide evidence that
the concentrations of hazardous materials are below defined levels. The six
key restricted substances are lead, cadmium, mercury, hexavalent chromium,
polybrominated biphenyls and polybrominated diphenyl. Similar regulations to
the RoHS exist in those non-EU countries that have their own WEEE
regulations e.g. Japan, South Korea;
� The Energy-Using Products (EuP) Directive 2005/32/EC, which came into force
in August 2007 and which provides a framework for the setting of eco-design
requirements for any group of products which use energy (including EEE). This
directive seeks to make energy efficiency improvements rather than having a
direct focus on waste. However, ensuing product designs which make energy
efficiency improvements may also extend the product’s life, thus contributing
indirectly to the prevention of WEEE;
� The EU Batteries and Accumulators and Waste Batteries and Accumulators
Directive (2006/66/EC), which aims to improve the environmental
performance of batteries and of the activities of all economic operators
involved in the life cycle of batteries. A producer of EEE is also regarded as a
battery producer if the appliance placed on the market has a battery inside.
The Batteries Directive limits the use of mercury and cadmium in all batteries
by weight, prohibits the disposal by landfill or incineration of waste industrial
and automotive batteries, and sets recycling rates to ensure that a high
proportion of the weight of waste batteries is recycled (65% of lead acid
batteries, 75% of nickel-cadmium batteries and 50% of other waste batteries).
Batteries that are incorporated in WEEE will be collected on the basis of the
WEEE Directive and then removed from the electronic equipment, counting
towards the collection targets of the Batteries Directive;
� Waste Shipments Regulations: in the EU, for example, the export of WEEE is
only permitted for recovery and is controlled by EU Shipment Regulations. In
addition, the Basel Convention on the Control for the Transboundary
Movement of Hazardous Wastes and Their Disposal, in force since 1992, is
the only global environment agreement on waste, comprising more than 165
national governments. This global agreement regulates trade in hazardous
wastes, including WEEE, looking to ensure its safe disposal and that the
generation of such wastes is minimised.
20.8 Effect of the Policy on Pricing of Resources / Services
The number of collective schemes in operation within a country and the resultant
competition influences the overall cost of implementing the WEEE policy. A report by
Veit compared the current waste management system charges in twelve MS for a
washing machine (38 kg), food processor (3.5 kg), laptop (1.5 kg), DVD player (1.8
29/09/09

kg), and a TV (15 kg), finding the average WEEE cost of these products to be
€5.34. 451 In monopolistic environments, the average product had a €6.33 WEEE
charge attached to it, which was found to be more than double the €2.93 charge in
competitive environments. Nonetheless, monopolistic environments may be the best
way to get new infrastructure in place for the more recent WEEE implementation in
some MS.
According to a report by OECD, 452 there is limited evidence to support the effect of
pricing on the demand for EEE. However, this is difficult to believe. In theory, the
higher product price resulting from WEEE producer responsibility should lead to a
reduction in the quantity demanded, even if only at the margin. The issue, therefore,
is that given the relatively high cost of most EEE compared to the average additional
WEEE cost given above (€5.34), it is likely that price increases are too small to have
any significant influence on demand. In addition, even if the elasticity of demand was
-0.2, a 5 % increase in price gives at most a 1 % reduction in demand, whilst there
remains an overall rising trend in EEE consumption worldwide. Hence, though
difficult to discern, there probably is a pricing effect on the demand for EEE. However,
this effect is simply very small, owing to the relatively small impact on product prices
and the inelastic nature of demand for most EEE items.
20.9 Evasion and Enforcement
The UNU and Greenpeace reports note that there is ‘leakage’ in the current WEEE
system throughout Europe and worldwide, particularly concerning items of value such
as large domestic appliances that contain a lot of metals, and IT and telecoms
equipment such as desktop computers and mobile phones. WEEE may escape the
proper management system via illegal exports or via back-door sales to unlicensed
operators, both less-equipped to manage WEEE in an environmentally-sound manner.
The UNU report gives the following examples:
399
� Shipments of WEEE disguised as goods from Hamburg port (DEUTSCHE
UMWELTHILFE 2007);
� 28 % of businesses found to be exporting WEEE illegally from the Netherlands
(VROM 2007).
As discussed previously in Section 20.5, it is estimated that only 25% of WEEE
arisings within the EU are currently being collected and treated, with no precise data
available on what happens to the remaining 75%. 453 It is considered to be likely that
some portion of this ‘hidden flow’ is being illegally exported to non-EU countries. In
addition, ‘free-riders’ in the system also contribute to the ‘hidden flow, with VROM
451 R. Veit (2005) How do WEEE get it right?, EMSNow, available at
http://www.emsnow.com/npps/story.cfm?id=15184
452 OECD (2006) EPR Policies and Product Design: Economic Theory and Selected Case Studies,
Working Group on Waste Prevention and Recycling, Environment Policy Committee.
453 Greenpeace (2008) Toxic Tech: Not in Our Backyard, Uncovering the Hidden Flows of e-Waste.
International Review of Waste Policy: Annexes

estimating that 15 % of the WEEE stream is not being collected due to free-riders who
sell EEE but do not honour their take-back obligations.
The UNU report suggests specific options to enhance compliance with the policy:
400
� Mandatory hand in of all separately collected WEEE at certified compliance
schemes, to reduce ‘cherry-picking’ of the better quality WEEE prior to reprocessing
and ensure proper treatment. The main disadvantages of this
approach are that WEEE re-use may suffer at the expense of increased
recycling, and that there will be increased enforcement burden on competent
bodies, with the need for validated input/output data from collection points.
Instead of a compensation payment for storage and collection efforts of the
producer, this approach may be reinforced if the producer were handed a
reimbursement or payment for handing over the WEEE.
� Changing the ‘take-back’ mechanism at retail shops so that instead of the oldfor-new
policy, consumers can hand in an old product at any retail shop that is
currently selling equipment in the same category, without having to purchase a
new product. This approach is already in place in Norway and Switzerland and
is applied on a voluntary basis in Denmark. A disadvantage to this approach
could be that certain retailers receive more than others, but this could be
compensated for by a reimbursement or volume-based payment. The use of a
reimbursement approach in Switzerland has led to greater take-back
increases from retailers than from municipality collection sites.
Examples of specific enforcement measures in particular countries are as follows:
� In Sweden, a fine may be imposed on anyone that fails to fulfil obligations of
the WEEE policy, including failure to label EEE items correctly and failure to
supply the required data regarding WEEE. Individuals that infringe the RoHS
legislation may also receive a fine or a term of imprisonment not exceeding
two years. Where the offence is more serious (particularly regarding RoHS) and
could have, or did cause damage, the individual will receive between 6 months
and 6 years imprisonment. Fines are calculated according to the nature of the
infringement, the means of the individual, and the seriousness of the incident.
Under the WEEE legislation, it is possible to impose an environmental fine
when an individual fails to register and still sells EEE products, or fails to
inform the Environmental Protection Agency of how the products are collected
and treated.
� Similar penalties also apply in Austria and Norway. In Austria, failure to comply
with the WEEE regulations generally leads to a fine (ranging from €360 to
€7,270), with a minimum fine of €1,800 where the individual in question is
professionally active in the area of waste management. Administrative fines
may also be applied if the individual fails to provide the necessary
documentation, data or has not registered. In Norway, non-compliance with
the WEEE and RoHS regulations is subject to fines under the terms of the
Product Control Act. Penalties associated with WEEE can include fines,
imprisonment for a term not exceeding three months, or both, unless more
stringent penalty provisions apply. Penalties for infringement of the RoHS will
only be applied if the infringement is shown to be wilful or the result of gross
negligence.
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20.10 Lessons Learned
Administrative Administrative burden
burden
The administrative burden on individual businesses should be considered when
designing producer responsibility systems – the need for reporting to counteract freeriding
is acknowledged, but the requirements should be balanced and should be
considered according to the product in question and the consistency of the markets
for that product. The use of collective compliance schemes reduces the individual
burdens placed on businesses. In addition, the development of and investment in IT
infrastructure would help reduce the economic impact of reporting requirements,
though this possibility is typically unaffordable for SMEs.
According to the UNU report, there are currently large differences in the number of
registered producers according to MS within the EU, resulting from differences in the
‘definition’ of producers, the role of distributors and the impact of SME awareness of
their obligations and the need to be registered. Industry across Europe has raised the
issue of ‘free-riding’, particularly regarding SMEs and their lack of awareness. In
addition, different obligations to register B2B compared to B2C has led to some
producers registering their products only as B2B, even when placing the product on a
B2C channel (especially where no clear definitions of B2B compared to B2C exits) to
avoid these obligations.
Differing reporting requirements (see Table 20-1) also place differing financial
burdens on the overall WEEE system. The higher the frequency of reporting, the
higher the number of hours required to report and, consequently, the higher the
economic and administrative burdens. The majority of registered producers see the
need for reporting (particularly to try and track free-riding), but a high percentage of
stakeholders are experiencing a burden in carrying out such reporting. If financial
obligations are to be decided according to amounts of products placed on the
markets, the frequency of reporting should also be product-specific as some markets
fluctuate throughout the year. In addition, varying definitions of B2B compared to B2C
currently determine different financial obligations in different countries.
The proposed revision to the EU WEEE Directive includes the requirement to
harmonise both the registration and reporting obligations for producers between the
national producer registers, including making the registers inter-operational (i.e.
between countries). In addition, clarification of the distinction between B2B and B2C
WEEE, through a comitology procedure, will further clarify which products fall under
the legislation and the obligations that apply to different EEE producers.
Awareness
Awareness
There is a need to increase the awareness of WEEE regulations for both businesses
(particularly SMEs) and the public. Low WEEE return rates are partly the result of a
lack of awareness and sometimes also a willingness of the consumer/ end-user to
actively participate in WEEE take-back systems. It may also help if consumers were to
know what they are paying for when they buy a product (e.g. visible fees) to ensure
their contribution to take-back system performances. A survey undertaken of more
than 2,000 people in the UK by an electrical retailer (Comet) found that only 2% of
people knew about the WEEE Directive. 71 % had no idea what the logo that is
displayed on new electrical products to show it should be recycled actually meant
401
International Review of Waste Policy: Annexes

(with almost 1 in 5 people thinking it meant “no wheelie bin collection in this area”)
and just under half of the people surveyed had never recycled an electrical product.
Col Collection Col Collection
lection points points
In order to encourage higher collection rates of WEEE, retailers should provide good
accessible collection points as far as possible, forming a strong bridge between
consumers and producers. In addition, the take-back of old products by retailers
without the need for the consumer to purchase something new has been found to be
successful in increasing collection rates in Norway, Denmark and Switzerland.
Municipalities should also enable good accessible collection points alongside retailers
where possible, ideally with no costs falling on the municipality for such collection
(through appropriate payments made to them). The UK system is an interesting one,
but it must be questioned whether payments to local authorities really cover the full
costs of their role in WEEE collection.
Exports
Exports
The large amount of ‘hidden flows’ of WEEE indicate that, despite the current
legislation in place regarding exports of WEEE and hazardous materials, a significant
amount is still being illegally exported, ending up in countries with lower treatment
standards, with workers in these countries within the more informal recycling sectors
ending up exposed to high levels of toxic substances. 454
In order to reduce the ‘hidden flows’ passing between countries, the EU WEEE policy
revision recommends that producers should take full ownership of the collection of
WEEE, particularly the financing of its collection throughout the whole waste chain, to
avoid leakage of WEEE to sub-optimal treatment and illegal exports, as well as
shifting payment for the collection of this waste from the general tax payer to the
consumer. It may well be that this becomes necessary, in any case, in order to ensure
the new 65% collection target is met.
Financial Financial Mechanisms
Mechanisms
Financial mechanisms such as variable recycling insurance premiums associated with
products being easier to recycle, or reduced fees attached to products which when
treated in a certain way are less environmentally-damaging, should be further
explored as ways of delivering the ‘changing design of products resulting in waste
prevention’ aim of WEEE policies. In addition, in allowing producers to pay specifically
for the collection and treatment of their own returned WEEE, rather than meeting
their financial responsibility as part of a collective system based on market shares,
there will also be an increased incentive for producers to design their individual
products with waste minimisation as a priority.
Historical Historical WEEE
WEEE
454 Greenpeace (2008) Toxic Tech: Not in Our Backyard, Uncovering the Hidden Flows of e-Waste.
402
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Historical and ‘orphan’ waste, whose producers have gone out of business, must be
dealt with within the WEEE policy system - for example, by making existing producers
responsible for such WEEE according to their respective market share. 455
Individual Individual Individual or or Collective Collective Take Take-Back Take Back Back Schemes
Although the first generation of WEEE policies have typically involved collective takeback
schemes e.g. El-Kretsen in Sweden, there is now increasing interest in individual
take-back programmes. According to a report by OECD, the increasing focus on
individual schemes has been advocated by some significant market players; for
example, Hewlett Packard has argued that any US state laws aiming to use some
form of collective take-back approach should also allow opt-out by individual
companies that can demonstrate that they have their own take-back and recycling
programmes. 455 This argument is based on the thinking that the company’s own
approaches will be more cost-effective than the collective state-government
sponsored systems, and that where companies take efforts to improve the design of
their products for recycling and re-use, or to minimize materials use, then they will
benefit directly from these efforts (rather than the benefits being spread across all
producers in a collective scheme). Similar thinking has also led to the collective
European arrangement of HP, Electrolux, Braun and Sony, to provide competition to
existing collective organisations in Europe whilst still achieving some economies of
scale.
An individual system may provide more direct incentives for ‘design for environment’
(DfE) activities such as increasing the ability to recycle components within the
products, but it may also be more difficult for the government to monitor the activities
of many individual companies, and it is also likely to be more difficult to achieve
economies of scale than in a collective system. As such, this option is more likely to
be available to major players than smaller ones (though it should be noted that the
electronics sector is, for many product categories, dominated by a relatively small
number of firms). Collective environments may also be the best way to get new
infrastructure in place for more recent WEEE schemes. Nonetheless, as advocated by
Hewlett Packard and many systems currently in place within the EU (see Table 20-1),
it may be prudent to leave the option open for individual take-back schemes to
develop.
Targets
Targets
As noted by Greenpeace (2005), 456 mandatory re-use and recycling targets are a key
element of encouraging the recycling of WEEE. In addition, the stipulation that Energy
from Waste be excluded from ‘recycling’ targets should also be considered, in order to
455 OECD (2006) EPR Policies and Product Design: Economic Theory and Selected Case Studies,
Working Group on Waste Prevention and Recycling, Environment Policy Committee.
456 Greenpeace (2005) Toxic Tech: Pulling the Plug on Dirty Electronics, Extended Producer
Responsibility.
403
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try to provide greater incentives for producers to design products with reuse/recycling
in mind.
The review by the United Nations University (2007) highlights the following key points
regarding WEEE targets in Europe:
404
� The WEEE directive currently sets a minimum collection target target target of 4 kg per
annum per inhabitant; however, this figure does not discriminate in favour of
those products that have the highest economic or environmental relevance;
for example, the collection of refrigerators containing CFCs is more important
for meeting environmental objectives so the targets should be set to reflect
this importance. The rate of CFC extraction from old appliances and disposal
without emission to air was reported in Recycle.co.uk as only 42 % in Germany
compared to 91 % in Austria, stemming from a current lack of incentive to
treat products in the most environmentally-friendly way if it requires further
processing and added expense; 457
� In addition, for some categories of WEEE it appears that the targets are easily
being being met met by a number of European MS – for instance the current shredding
and separation technologies for white goods typically lead to recycling rates in
excess of those prescribed. It would have been appropriate, prior to the
revision in the target, to ask the question whether the targets are high enough
in those countries for which WEEE policy is now well developed, and where
large (and growing) quantities of WEEE are found in the waste stream;
� The final destination of the recycled/ recovered WEEE is not considered in the
targets, and may thus result in discrimination against more environmentallypreferred
options where they require more processing. For example, the use of
cleaned CRT glass for producing new CRTs has been shown to be more
resource and energy efficient than using the glass as road filling material.
However, WEEE policy regards both destinations as having equal footing in
recycling percentages. Thus companies may favour road filling as the final
destination as this requires less cleaning and separation;
� Weight-based recycling targets may divert attention away from ‘prevention’ as
a key policy outcome, by discouraging the design of future EEE to use less
material and to reduce environmental damage in favour of meeting such
targets.
The recent proposed revision to the EU WEEE Directive includes a change in collection
targets from 4 kg per annum per inhabitant to a 65% collection rate, calculated
according to the average amount of EEE placed on the market in the two preceding
years. This proposed target is more in line with the current Japanese system. In
addition, in order to encourage the re-use of whole appliances, it is proposed that
such re-use be included within the 65% target. The proposed revision also presents
the possibility of setting a separate collection rate for cooling and freezing equipment
457 S. Flanagan (2008) UK recyclers should not follow German WEEE model, Recycle.co.uk: Don’t Bin
it, Recycle it, available at: http://www.recycle.co.uk/news/614000.html
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in 2012. Hence, the revision may improve performance in a variety of ways, as hinted
at above.
405
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21.0 Producer Responsibility, WEEE - Germany
21.1 Outline of Policy
According to the Electrical and Electronic Equipment Act (Elektro- and
Elektronikgerätegesetz - ElektroG) producers are obliged to take back waste electrical
and electronic equipment (WEEE) and either reuse, recycle or dispose of the collected
items according to ecological standards. 458
The aims of the ElektroG - being identical to the WEEE-Directive and RoHS – are:
406
� to prevent and reduce the amount of WEEE;
� to reduce waste volumes through reuse and through provisions for collection,
recovery and recycling of WEEE;
� to reduce the content of hazardous substances in equipment; and
subsequently; and
� to reduce the amount of hazardous substances in the residual waste by
banning the disposal of WEEE via the residual waste stream.
The ElektroG contains different regulations for WEEE from the commercial sector
(B2B) compared to from private households (B2C). These are set out below.
Collection Collection of of WEEE WEEE from from commercial commercial sector (B2B)
According to Art. 10 para 2, ElektroG producers are responsible for the disposal of
WEEE from the purely commercial sector, provided it is electrical and electronic
equipment that is placed on the market after 13 th August 2005. End-users are
responsible for equipment placed on the market before 13 August 2005. Producers
and users may reach an agreement which departs from the aforementioned
provisions. The party responsible for disposal shall either reuse WEEE or its
components, treat or dispose of it in compliance with the provisions of the ElektroG,
and shall bear the costs of disposal.
The definition of B2B equipment depends, in practice, on whether the equipment is
used exclusively by businesses, and is determined by the characteristics of the
equipment (e.g. the type and place of use, special pre-conditions for the use of the
equipment, qualified personnel). The distribution channels (e.g. delivery only to
commercial distributors) are not relevant for classification as B2B equipment.
B2B equipment shall not be delivered to local authority public collection sites and
collected with WEEE from private households, and therefore will not profit from the
free of charge take-back obligations. Producers are not obliged to collect B2B
458 Act Governing the Sale, Return and Environmentally Sound Disposal of Electrical and Electronic
Equipment, as of: 23 rd March 2005, Federal Law Gazette BGBl. I, p. 762.
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equipment. Furthermore producers do not have to pay a financial guarantee for the
B2B equipment at the EAR (see Section 21.3).
Collection Collection of of of WEEE WEEE WEEE from from from private private private households households households (B2C)
(B2C)
Since 24 th March 2006, the disposer (consumer) of WEEE has been obliged to
discard their WEEE in a system which is separated from the residual waste stream. 459
Public waste management authorities remain responsible for the collection of WEEE
from private households. The procedure for collection is widely at the discretion of the
local authorities, though they must ensure that private households can return WEEE
free of charge (bring-back system). The number of collection points to be set up and
the combination of bring sites and kerbside collections is based on population
density, other local conditions and the waste management objective of the greatest
possible level of collection. Smaller municipalities may set up a joint collection point.
A dealer that has taken over equipment (e. g. a washing machine) from a private
household may also return this equipment free of charge to the collection point of the
respective local authority. The local authorities may re-finance the costs for collection
via waste charges.
Local authorities are required to hold the WEEE available for collection by producers,
separated into five groups (containers). Classification into the five groups is decided
on the basis of technical disposal considerations. The five categories are:
407
� large household appliances and automatic dispensers (Category 1);
� refrigerating appliances (Category 2);
� IT and telecommunications equipment and consumer equipment (Category 3);
� gas discharge lights (Category 4); and
� small household appliances, lighting equipment, electrical and electronic
tools, toys, leisure and sports equipment, medical, monitoring and control
instruments (Category 5).
Local authorities can also arrange for the disposal of WEEE themselves or can
commission a third party to do so: By providing three months notice to the Clearing
House (see Section 21.3), the local authorities may choose not to make all the WEEE
in a specific group available for collection for a period of at least one year. In this case
they must also ensure that treatment and recovery requirements are met.
The main responsibility for the management of WEEE according to the EletkroG rests
with the producers. ‘Responsibility’ covers the following issues:
� Producers must take back WEEE collected from private households by public
waste management authorities;
459 Users of non-household WEEE - be it historical or WEEE of products sold after 13 th August 2005 -
may arrange solutions for keeping waste out of disposal with producers.
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408
� Producers must provide public waste management authorities with containers
for WEEE to be set up at collection points and must collect the containers in a
timely manner when a certain volume is reached in a WEEE group;
� Organizing the transport and treatment of WEEE from the public collection site
to the treatment facilities;
� Controlling whether old appliances can be reused;
� Removal of certain substances, according to the WEEE and ROHS Directive;
� Meeting recycling and recovery quotas for disposal;
� Informing consumers about the possibilities and the necessity of the sound
management of WEEE; and
� Reporting of relevant data to the clearing house.
21.2 Policy Context and Reason for Introduction
In contrast to most other types of waste, the amount of WEEE in Germany has
increased continuously over recent years. In 2006, 1.8 million tonnes of EEE was put
on the market in Germany (see Table 21-1).
Although collection systems for WEEE were in existence in the cities and counties
prior to introduction of the ElektroG, only 10 per cent of WEEE was collected and
recycled. The rest was mainly landfilled or thermally recovered in waste incinerators.
Across Germany, the collection system before the introduction of the ElektroG was
quite varied, with some cities collecting two types of WEEE-products and others
collecting as many as 20 types, and some cities charging for the collection of WEEE,
with others collecting free of charge.
The timetable for the introduction and development of the ElektroG policy proceeded
as follows:
� 1991: Draft of a German WEEE-Ordinance (Entwurf der Elektronikschrott-
Verordnung), which was updated and replaced by the ElektroG on 27 th
September 1994, with producer responsibility regulated in Art. 22 of the
Closed Substances and Recycling Act (Kreislaufwirtschafts- und Abfallgesetz -
Krw-/AbfG);
� 2003: Directive 2002/96/EC on waste electrical and electronic equipment
(WEEE) and Directive 2002/95/EC 460 on the restriction of the use of certain
hazardous substances in electrical and electronic equipment requires that
Member States comply with the Directive by 13 th August 2004;
� 23 rd March 2005: ElektroG was formally adopted;
460 Directive 2002/96/EC of the European Parliament and of the Council of 27 th January 2003 on
waste electrical and electronic equipment (WEEE) - Joint declaration of the European Parliament, the
Council and the Commission relating to Article 9, Official Journal L 037, 13.02.2003, p. 24.
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409
� 31 st December 2005: Almost all regulations of the ElektroG entered into force;
and
� 24 th March 2006: Free of charge disposal entered into force.
Table 21-1: EEE Put on the Market and Collected in Germany (2006).
Product Product category
category
Large Household
Appliances
Small Household
Appliances
IT & Telecommunications
Equipment
Put Put on on on the
the
Market
Market
Weight
(tonnes)
International Review of Waste Policy: Annexes
Collected Collected Amount Amount
Treated Treated Amount
Amount
B2C B2B Total Germany Other MS
Weight
(tonnes)
Weight
(tonnes)
Weight
(tonnes)
Weight
(tonnes)
Weight
(tonnes)
723,547 447,393 14,673 462,066 455,690 3,235
144,877 41,621 1,206 42,827 36,038 6,138
314,898 86,573 15,762 102,336 89,960 7,196
Consumer Equipment 334,018 108,149 4,607 112,757 111,729 242
Lighting Equipment 90,969 x 375 375 70 192
Gas discharge lamp 25,556 5,551 x 5,551 5,401 150
Electrical and Electronic
Tools
Toys, Sports & Leisure
Equipment
118,695, 10,683 899 11,582 11,001 449
25.172 2.534 2.062 4.596 4.524 36
Medical Products 25.711 741. 2.932 3.673 1.807 1,273
Monitoring & Control
Instruments
18.497 948 231 1,179 869 89
Automatic Dispensers 14,972 5,592 1,366 6,958 5,776 55
Sum Sum
1,836,913 1,836,913 709,787 709,787 44,113 44,113 753,900 753,900 753,900 734,844 734,844 19,055
19,055
Source: BMU, Data on WEEE in Germany in the year 2006 - BMU Explanations for the report to the EU-
Commission, 5.09.2008
21.3 Key Organisations Involved in Implementation and
Management
The Electrical and Electronic Equipment Act designates the responsibilities of
"registering", "coordinating collection" and "issuing instructions for the provision of
containers" to the Federal Environmental Agency (UBA) as the "Competent Authority"
(central register). However, the Act provides for the Competent Authority to transfer

these responsibilities by means of designation to the Clearing House of the
producers.
In August 2004, the business associations ZVEI and Bitcom set up the foundation
“Stiftung Elektro-Altgeräte Register- EAR” (Elektro-Altgeräte Register - WEEE register)
based in Fürth/Bavaria. The EAR foundation was set up to fulfil the responsibilities of
the Clearing House of the producers and was made available for designation by the
Federal Environmental Agency. 461
The role of the EAR as a clearing house is:
410
� Registering producers placing EEE on the market in Germany for B2B as well
as B2C equipment;
� Before producers can place EEE on the market in Germany, they have to
provide a guarantee, i.e. insolvency-proof financial guarantee, independently
of whether the producer complies in a group or individually, that covers the
cost of sound disposal of the household appliances that the producer plans to
sell after 13 th August 2005;
� Based on a formula, the Clearing House determines the collection volumes for
the individual producer and calculates an even temporal and regional
distribution of WEEE collection quotas among all producers;
� It also compiles data inter alia on equipment placed on the market, taken
back and recovered equipment, and it submits the data to the Environmental
Agency (Umweltbundesamt);
� The supervision of the transport of WEEE from the collection site to the
treatment facility.
The EAR has no operational functions, like the take-back, dismantling, sorting or
disposal of WEEE.
Once a certain amount of a category of WEEE has been collected, the municipality
informs the clearing house. The clearing house decides to which of the five categories
the appliance belongs, and calculates the respective volume of WEEE (including
historical WEEE). The volume is important for the financing of WEEE waste
management.
Concerning WEEE from private households (B2C) the ElektroG states:
� From 24 th March 2006, producers must finance the waste management of
“historical” WEEE (equipment put on the market before 13 th August 2005)
calculated on the basis of the producer’s market share at the time that the
WEEE management cost arises; and
461 The EAR is the focal point for information concerning the management of WEEE for public
authorities and the private sector and it supports decision-making. The ElektroG provides that the
clearing house be constituted with a council, whose members are producers, retailers, public entities
responsible for waste management, representatives at the Federal level and from the German Länder
(states), and consumer and environment protection associations.
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411
� Regarding “new” WEEE (equipment put on the market after 13 th August 2005),
producers are only responsible for financing the collection, treatment, recovery
and disposal of their own products. In this respect, the producers have to pay
a financial guarantee.
Concerning business equipment (B2B) the ElektroG states:
� Commencing 24 th March 2006, the end-user of historical WEEE is responsible
for financing the costs of management. Producers are only financially
responsible for the waste management of “new” WEEE (sold after 13 th August
2005).
Furthermore, the clearing house has an obligation to inform the general public of
disposal possibilities. It is not allowed to conclude or arrange contracts with disposal
enterprises.
To raise the awareness of the general public, the ElektroG introduced obligations for
producers, the clearing house and the competent authorities of the region (e.g.
Bavaria) to inform the users of WEEE about the importance of collecting and recycling
WEEE. To increase the efficiency of the treatment of WEEE, the producers have a duty
to inform treatment facilities about the features of their products within a year of their
placement on the market.
As a key instrument to measure the impact of the ElektroG, producers have the
following monitoring obligations, i.e. they must collect and transfer data on the
following aspects of WEEE management:
1. Amount of products introduced to the market on a monthly basis;
2. Annually recovered appliances by public collection site; and
3. Volume of collected, recycled, reused, recovered and exported appliances.
This information concerns the volume, components and materials of WEEE going into
the first-treatment facility, coming out of that facility, and going to recovery facilities.
The so-called ‘first-treatment site’ is obliged to provide this information to the
producers. Furthermore, the first-treatment facility is subject to an annual
certification. This certification will only be issued if the site proves that it can provide
the data required by the producer.
21.4 Evaluation Studies Available
Prior to implementation: Council of Environmental Advisors (SRU) Umweltgutachten
2002, July 2002.
Following implementation: Council of Environmental Advisors (Sachverständigen Rat
für Umweltfragen, SRU) Environmental Report („Umweltgutachten“) 2008, July 2008
(See: http://www.umweltrat.de for further information).
21.5 Environmental Benefits
Prevention Prevention of of waste waste
waste
Since 1 st July 2006, manufacturers of electrical and electronic equipment have been
required to substitute lead, cadmium, mercury, specific chromium compounds and
International Review of Waste Policy: Annexes

ominated flame retardants in any new electrical and electronic equipment that they
put on the market. Since the entry into force of the Electrical and Electronic
Equipment Act (ElektroG), manufacturers have had to take disposal costs of products
into account even in the design stage, as consumers can return old equipment to
local collection points free of charge. Manufacturers and importers have to pick up
waste equipment at these collection sites and take charge of subsequent
management. This has brought about a reduction in the pollutant load of municipal
waste. The volume of waste electrical and electronic equipment from these local
collection points is about 1.8 tonnes per year. 462 Following the introduction of the
ElektroG, less WEEE has since been disposed of in landfills. 463
However, a causal link cannot be drawn between the introduction of the ElektroG and
other impacts, e.g. an improvement in the product lifetime or enhancing the
recyclability of electric and electronic equipment (see lessons learned). Mr Hieronimy
from Hewlett-Packard (Germany) states that for his company, the effect of the
ElektroG producer responsibility system is such that it has led to no changes in their
product design. Improvements in product recyclability at HP have been a result of
product and brand ‘image’ requirements, rather than as a result of producer
responsibility. 464 Mr Hieronimy states that for him, the present implementation of
producer responsibility in the ElektroG does not lead to individual savings for
companies due to the design of their products, but would lead to any benefits being
distributed evenly among all producers. 465 This effectively implies a disincentive to
change product design owing to the free-rider problem created by the shared
responsibility approach.
Recycling Recycling of of waste
Statistics for the first year of ElektroG (2006) concerning recovery, recycling and reuse
of WEEE in Germany are given in Table 21-2.
Statistics show that for B2C equipment, the German collection amount of 8 kg WEEE
per person per year is double that of the EU collection target of 4 kg per person per
year. 466
Nevertheless, it remains questionable as to whether or not the main aims of the
ElektroG have so far been achieved. According to Art. 1 ElektroG, the law aims to
prevent waste from electrical and electronic equipment and to promote reuse,
recycling and other forms of recovery to reduce both the volume of waste. The
recovery and re-use of used equipment is hampered by the demolition of WEEE during
collection or transport. The waste management branch claims that the demolition
462 Federal Environmental Ministry, Fewer hazardous substances in electrical and electronical
equipment, press statement from 30.6.2006.
463 Sabine Enzinger, Bilanz ElektroG, Umweltmagazin, July-August 2007, p. 18.
464 EUWID from 17 th October 2008, p.3.
465 EUWID from 17 th October 2008, p.3.
466 Federal Environmental Ministry (BMU), Data on EEE in Germany in the year 2006 - BMU
Explanations for the report to the EU-Commission, 5.09.2008, p. 2.
412
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ate of WEEE collected after the introduction of the ElektroG has increased
significantly, whilst the re-use quota fell from 10 % before 24 th March 2006 to 3% in
2007, resulting from the diverging duties and responsibilities for the collection and
further treatment of WEEE. While the local authorities are responsible for the local
collection and sorting of WEEE, producers are ultimately responsible for the re-use
and recovery of WEEE. Moreover as a consequence of the ElektroG, many traditional
and well-rehearsed business relationships between local authorities and waste
management companies were cancelled. Instead, producers are commissioning
supra-regional companies, with local companies losing their ‘influence’ on the
collection and transport of WEEE. 467
Table 21-2: WEEE Recovered, Recycled and Re-used in Germany 2006.
413
Amount
Recovery
Recovery
International Review of Waste Policy: Annexes
Recovery-
Quota
Re Re-use Re use (components) (components) and
and
Recycling
Recycling
Amount
Recycling-
Quota
Re Re-use Re use use of of the
the
whole whole appliance
appliance
Product Product category category Weight (tonnes) % Weight (tonnes) % Weight (tonnes)
Large Household
Appliances
Small Household
Appliances
IT &
Telecommunications
Equipment
417,507 91.0 385,725 84.0 3,141
38,646 91.6 28,362 67.2 651
92,602 95.3 75,562 77.8 5,179
Consumer Equipment 106,225 94.9 86,900 77.6 786
Lighting Equipment 262 100 231 88.2 113
Gas discharge lamp 5,331 95.7 5,296 95.4 0
Electrical and
Electronic Tools
Toys, Sports & Leisure
Equipment
9,615 84.0 8,000 69.9 132
3,773 82.7 3,168 69.5 37
Medical Products 2,929 95.1 2,524 81.9 593
Monitoring & Control
Instruments
663 69.1 565 58.9 220
Automatic Dispensers 5,506 94.4 3,731 64.0 1,126
Sum Sum
683,038 92.1 92.1 92.1 600,062 600,062 80.9 80.9 80.9
11, 11,978 11, 978
Source: BMU, Data on EEE in Germany in the year 2006 - BMU Explanations for the report to the EU-
Commission, 5.09.2008
467 Sabine Enzinger, Bilanz ElektroG, Umweltmagazin, July-August 2007, p. 18.

21.6 Implementation Costs
Producers have to guarantee the financing of the collection and treatment of their
products by participating in a collective system or by setting up an individual
compliance scheme.
The ZVEI (German Electrical and Electronic Manufacturers' Association) estimated
that the WEEE policy would cost industry €5,000,000 per annum. In 2007, the
members of the BVSE (“Bundesverband Sekundärrohstoffe und Entsorgung e.V.”)
registered a cut in prices for the collection and recycling of WEEE of up to 30 %. With
the second amendment of the “Ordinance on fees regarding the ElektroG” (Zweite
Änderungsverordnung zur Kostenverordnung zum ElektroG) having entered into force
on 1 st January 2008, the Federal Environmental Ministry has proposed a further
decrease in fees of up to 40%. Nonetheless, for 2008, the Federal Environmental
Ministry predicts that the overall costs of the system, as financed by fees from
producers, to be approximately €5,800,000. 468 Using the total tonnes of WEEE
collected in Table 21-1, the estimated cost per tonne of WEEE collected is therefore
€7.69.
21.7 Effects on Technical Change / Innovation
In the “Business to Consumer” sector, producers are obliged to finance the WEEE
costs associated with all products; there is no direct link to the recycling cost of the
specific product that has been made by the individual producer. The shared
responsibilities thus result in reduced interest by individual producers to produce
products of high quality, which have a long lifetime, and which would lead to a
reduction in collection and recycling costs. The picture is slightly different in the
“Business-to-Business” sector, as here products have to be taken back in clearly
defined ways by the producers.
21.8 Complementary Policies
The Electrical and Electronic Equipment Act (ElektroG) complements the general
regulation on waste - the Closed Substances and Recycling Act (Kreislaufwirtschafts-
und Abfallgesetz). The producer responsibility regulated in Article 22 of the Closed
Substances and Recycling Act commits producers and distributors to design their
products in a way that prevents waste in the manufacture and usage of a product.
A further complementary policy in place is the Landfill Ordinance (Deponie-
Verordnung - DeponieV); this policy still contains loopholes which weakens the landfill
ban of, inter alia, the WEEE-derived shredder light fraction (SLF).
468 Second Amending Ordinance on the Cost Ordinance on the Electrical and Electronic Equipment Act,
in the version of 6 July 2005 (Federal Law Gazette I year 2005 p 2020), last amended by Article 1 of
the 2nd Ordinance Amending the Cost Ordinance on the Electrical and Electronic Equipment Act of 5
December 2007 (Federal Law Gazette I year 2007 p. 2825).
414
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A serious problem is the illegal export of WEEE which, according to some estimations,
ranges from 10 to 15 % in Germany, and which adds pressure to recycling prices. 469
Governments should ensure that the WEEE streams will reach recycling facilities
operating to appropriate standards and that recycling capacities are being fully
utilised. Here, the minimum and insufficient border control of WEEE exports appears
to be a significant problem.
21.9 Effect of the Policy on Pricing of Resources / Services
The consequences and behaviour of business and communities after two years
experience with the new regulation can be summarized as follows:
Following the full implementation of free of charge disposal (24 th March 2006),
producers announced that they would re-finance the costs with price increases for
new products. It is still unclear whether this has happened and to what extent.
Gotthard Graß (General Executive Manager of the ZVEI) was reported as saying: "I
expect that the prices for new appliances will increase." For some electric appliances
like washing machines, recycling has probably been cost-neutral due to the high price
received for scrap metal, of which there is a considerable quantity . In contrast the
recycling of fluorescent tubes or energy saving light bulbs is more complicated
because of the mercury content. For the latter product types, the recycling revenue
can amount to 20 to 60 % of the product price. Nevertheless according to Bitkom, 470
the producers of PCs, computer equipment, mobile phones and entertainment
electronics have only small leeway regarding price increases, due to a drop in prices
in those branches resulting from competition in the EEE market, and a general
decline in prices in real terms.
Experts have different opinions on whether the free of charge collection system for
WEEE will lead to falling or even rising waste disposal charges being levied by local
authorities on householders. It is reported that some municipalities will increase
waste disposal charges, arguing that they will have to enlarge and reconstruct their
collection points in order to comply with the ElektroG. By contrast, the German
Environmental Ministry and the Bitkom-expert Mario Tobias, are of the opinion that
waste disposal charges should fall, because following the new regulations,
communities no longer have to pay for the transport and recycling of the WEEE
anymore, they only have to collect it. A speaker of the German Environmental Ministry
is cited as saying that waste disposal charges are not very transparent anyway, as it is
not known which other costs are covered as part of the charges.
21.10 Evasion and Enforcement
The problem of free-riders is believed to be a significant one in Germany. Although all
affected companies according to the ElektroG should have been registered since
469 EUWID from 21 st January 2008, p.4.
470 BITKOM represents 1,300 companies, some 700 of which are direct members. These include
almost all of the leading players in the industry, as well as more than 500 smaller, medium-sized and
new businesses, see: http://www.bitkom.org/ .
415
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November 2005, as of March 2006, only half of the companies thought to be
obligated to register had done so.
Regulatory offences listed in Art. 23 ElektroG are aimed at producers placing
electrical and electronic equipment on the market. Contravening the regulations of
the ElektroG can result in fines. Producers failing to register can be subject to a fine
up to €50,000. Other offences, like failing to collect containers, can result in a fine of
up to €10,000.
In order to investigate violations of the regulations, an initiative of recycling
companies led to the setting up of a control body called ÜWEG e.V.
(Überwachungsverein zur Wahrung des ElektroG – www.ueweg.de ).
Except for the EAR, the enforcement authorities of the Länder (German states) are
spared the responsibility of monitoring and controlling to any large degree.
21.11 Lessons Learned
Key factors that determine the success of the producer responsibility for WEEE
include:
416
� That industry designs its products for the purpose of reuse and recyclability;
� That there are no free-riders. In other words, all companies need to register
with the EAR;
� That the collection and treatment infrastructure is tailored to the amount of
WEEE disposed; and
� That consumers find the take-back system comfortable and are not
encouraged to dispose of WEEE illegally. This is particularly a problem for
small electric appliances, which may find their way into the residual waste
stream.
21.12 Prerequisites for Introduction
The essential elements that are required for this particular policy to be introduced
are:
1. “Willingness” of the industry to devise and implement its producer
responsibility, e.g. organising the recycling system;
2. Capacity to build up a recycling infrastructure, e.g. sufficient personnel in the
communities for collection points, transport capacity, collection containers).
3. No legal obstacles against a take-back system that is run by industry, e.g. antitrust
law.
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22.0 Producer Responsibility, ELVs - Ireland
22.1 Outline of Policy
An end of life vehicle (or ELV) is a car or light commercial vehicle, which is to be
disposed of by the registered owner (in other words, a car or small van which is to be
scrapped) as waste. Vehicles normally reach the end of their useful lives, either due
to age (typically around 12-14 years), or because of heavy damage following an
accident. Therefore, there is no fixed age at which a vehicle can be considered an
ELV. The European Parliament and Council Directive 2000/53/EC 471 on End of Life
Vehicles (known hereafter as the ‘ELV Directive’) sets out specific measures to be put
in place by Member States in relation to the collection, storage, treatment,
dismantling, reuse, recycling and disposal of ELVs. Under the ELV Directive, each
Member State is required to:
417
� Achieve new recovery and recycling targets of 85% reuse/recovery by average
weight per vehicle deposited for appropriate treatment by 1 January 2006 (to
include 80% materials recycling), and 95% reuse/recovery by 1 January 2015
(to include 85% materials recycling);
� Ensure that all ELVs are dismantled, treated and recovered by industry at no
extra cost to the final holder/owner of that vehicle and in a manner that does
not cause environmental pollution;
� Introduce new systems whereby certificates of destruction (CoD) are notified to
the competent vehicle registration authorities on the deposit of ELVs by their
registered owners at authorised treatment facilities (ATFs) for appropriate
treatment and recovery; and
� Minimise the use of specified hazardous substances in vehicles.
The ELV Directive was transposed into Irish law on the 8 June 2006 through the
Waste Management (End of Life Vehicles) Regulations 2006 472 (known hereafter as
the ELV Regulations). The ELV Regulations place obligations on producers to establish
national collection systems for the recovery and treatment of ELVs and require
treatment facilities to meet specific environmental standards. A producer covers not
only any vehicle manufacturer located in Ireland but extends to “any person” who
imports vehicles into the state. As no vehicles are built in Ireland, it follows that the
obligations for compliance with the legislation fall on vehicle importers. The producer
is required to develop a network of treatment facilities that is ‘reasonably’ accessible
to all and that can meet the demand associated with that producer’s ELVs. Each
producer is required to develop a national collection system consisting of one ATFin
every city and council area where the population of the functional area is less than or
471 European Parliament and Council Directive 2000/53/EC on End of Life Vehicles.
472 S.I. No. 282 of 2006, Waste Management (End of Life Vehicles) Regulations 2006.
International Review of Waste Policy: Annexes

equal to 150,000 with one supplemental facility provided for each additional
150,000 persons. The producer is obliged to establish a formal relationship with
ATFs, but an agreement must not last longer than 3 years. This is a producer
responsibility initiative based on the Polluter Pays Principle. Producers were required
to register with each local authority by the 21 July 2006. They are required to apply
for renewal of registration on 31 January each year.
Since 1 st January 2007, owners of intact end of life cars and vans must deposit such
vehicles at an ATF. When an ELV is deposited at an ATF, the owner will receive a CoD.
If an ELV is deposited at an unauthorised facility, the owner will not receive a CoD and
may remain recorded as the registered owner of the vehicle on the Department of
Transport’s National Vehicle and Driver File.
ATFs provide a free take-back service for vehicles of that producer’s brand. An ATF
that forms part of a producer’s network is bound to accept any specified vehicle of
that producer’s brand. If essential parts of the vehicle (for example, engine, gearbox,
transmission and catalytic converter) are missing, or the vehicle contains waste, then
a charge may apply. An operator of an ATF is obliged to:
418
� Issue the registered owner with a CoD;
� Ensure the facility is operated under an appropriate waste licence or permit;
� Meet the minimum technical requirements for the storage, treatment and
recovery of ELVs and the storage of components containing fluids, spare parts
etc.;
� Keep records of end of life vehicle materials for reuse, recycling, recovery and
disposal and report these records to local authorities annually;
� Use component and material coding to facilitate identification of components
that are suitable for reuse and recovery;
� Forward the details of the CoDto the National Vehicle and Driver File, maintained
by the Department of Transport; and
� The vehicle must be treated within 10 days of being deposited at the facility.
The ELV Regulations also impose obligations on producers to reduce hazardous
waste produced from cars. About 25% of a vehicle’s weight is classified as hazardous
waste, therefore vehicles account for almost 10% of the total amount of hazardous
waste generated annually in the European Union. 473 Hazardous materials include
lead acid batteries, fluids including lubricating oil, coolant, brake fluid and catalytic
converters, all of which must be disposed of safely in order to prevent pollution. The
treatment of ELVs at dedicated treatment centres, designed to dismantle vehicles in
accordance with environmental best practice, allows hazardous substances to be
removed and segregated from the main vehicle metal mass. Thus there is a welcome
reduction in the volumes of hazardous waste that would have been previously
generated by the shredding of whole vehicles without any pre-treatment. Such a
473 Directive 2000/53/EC on end of life vehicles, (Version 1 – January 2005) – Guidance Document.
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practice previously resulted in the contamination of non-hazardous components with
hazardous components, leading to the generation of greater overall volumes of
hazardous waste. Producers are required to ensure that materials and components of
specified vehicles do not contain lead, mercury, cadmium or hexavalent chromium
other than in specified cases. Producers must maintain appropriate documentation
for a period of seven years to verify that materials and components of vehicles are in
compliance with the provisions of the ELV Regulations.
It is estimated that in some EU member states, up to 7% of all ELVs are illegally
dumped. 474 The ELV Regulations do not encourage random dismantling of ELVs, as
ATFs impose a charge on the vehicle owner if essential parts of the vehicle are
removed prior to delivery. This economic consequence should have the desired effect
of preventing the generation of waste in the form of unsightly redundant vehicles
(prior to the introduction of the Waste Management (End of life Vehicles) Regulations
2006).
22.2 Policy Context and Reason for Introduction
The ELV Regulations were introduced to control the disposal of vehicles, which have
reached the end of their life due to damage or age, because they can pose a threat to
the environment due to the hazardous materials contained in them. In addition the
Regulations are intended to improve the environmental performance of vehicle
dismantling activities and promote additional recycling in this sector.
The ELV Directive sets out objectives relating to the prevention, collection, treatment,
reuse and recovery of ELVs. Article 4 of the Directive sets out objectives in relation to
prevention and encourages limiting the use of hazardous substances to prevent their
release into the environment, making recycling easier and avoiding the need to
dispose of hazardous waste. Article 8 sets out objectives on ensuring that producers
provide information on coding standards and dismantling information for new
vehicles.
The ELV Regulations encourage the development and optimisation of ways to reuse,
recycle and recover ELVs and their components. The Regulations encourage the
development of markets for recycled materials integrating an increase in the quantity
of recycled materials used in vehicles and other products. Product reuse is
encompassed in the Organisation for Economic Co-operation and Development
(OECD) definition of waste prevention.
22.3 When was the Policy Introduced?
Following a period of public consultation, the Waste Management (End of life Vehicle)
Regulations 2006 (S.I. No. 282 of 2006) were introduced in Ireland by the
Department of the Environment, Heritage and Local Government (DoEHLG) and came
into effect on 8 June 2006. The Regulations fully transpose the provisions of the ELV
Directive and are intended to facilitate its implementation in Ireland. The Regulations
474 Commission Proposal COM (97) 358 Final COD 970194 Official Journal C 337, 07.11.1997
Commission of the European Communities.
419
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accompany Part VA of the Waste Management Act 1996 on End of life Vehicles
(inserted by Section 44 of the Protection of the Environment Act 2003).
22.4 Key Organisations Involved in Implementation and
Management
The key organisations involved in implementation and management of the Waste
Management (End of life Vehicles) Regulations 2006 are the following:
420
� Local Authorities;
� EPA;
� Producers;
� ATFs;
� Vehicle Owners; and
� Main Stakeholders:
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• Irish Motor Vehicle Recyclers Association (IMVRA);
• Metal Recyclers Association of Ireland (MRAI); and
• Society of the Irish Motor Industry (SIMI).
� National Vehicle and Driver File; and
� The Scrap Industry.
Local Local Autho Authorities Autho Authorities
rities
Under the Regulations, local authorities are responsible for ensuring the effective
implementation of the system including the enforcement of all relevant provisions
relating to the permitting of ATFs, approval of national collection plans for their area,
receipt of reporting data and where appropriate, producer responsibility provisions
concerning the administration of the system of producer registration within their
functional area.
EPA
EPA
The EPA have a peripheral role in the collation of data and preparation of statistical
reports under the ELV Directive and Regulations.
Producers
Producers
The Waste Management (End of life Vehicles) Regulations 2006 place obligations on
producers (vehicle manufacturers and professional importers) to carry out the
following:
� Establish national collection systems for the recovery and treatment of ELVs.
From 1 January 2007 owners of intact end of life cars and vans can deposit
them free of charge at ATFs. An exception to the free take-back principle is
provided where a vehicle is missing its essential components or where waste
has been added to the vehicle.
� Each producer's national collection system is required to have at least one ATF
in every city and county council area that will provide free take back for vehicles

421
of that producer's brand or for which that producer has responsibility. Producers
are required to have additional ATFs in place in those counties and cities with a
larger population base (i.e. one additional facility for each additional 150,000
persons in the relevant county or city);
� Each producer is required to register with each local authority identifying the
level of ELVs they anticipate being responsible for and the ATFs they plan to
make use of in that area;
� To ensure that the materials and components of specified vehicles do not
contain lead, mercury, cadmium or hexavalent chromium other than in cases
specified in the Fourth Schedule of the Regulations and that technical
documentation must be made available by the producer to verify compliance
with these requirements;
� To compile and maintain appropriate documentation, for a period of seven
years, to verify that the materials and components of vehicles are in compliance
with the provisions of the Regulations. Each year they must submit an annual
report to the local authority on the treatment of ELVs, including steps taken to
encourage recycling and reuse;
� Each producer, in liaison with vehicle material and equipment manufacturers,
use component and material coding standards to facilitate the identification of
those components and materials which are suitable for reuse and recovery; and
� Producers are also obliged to make available to ATFs dismantling information for
each type of new specified vehicle put on the market in Ireland within six
months of these vehicles being put on the market in Ireland.
Authorised Authorised Treatment Treatment Facilities
Facilities
ATFs must operate under a waste licence or as appropriate a waste permit and meet
the minimum technical requirements for the following:
� Storage (including temporary storage) of ELVs prior to their being the subject of
appropriate treatment and recovery;
� Appropriate treatment and recovery of ELVs; and
� Storage of components containing fluids, recoverable components and spare
parts.
ATFs must keep records of the aggregate weight of materials for reuse, recycling,
recovery and disposal arising from ELVs and report to local authorities on an annual
basis.
From the 1st January 2007 and onwards, on the deposit of an ELV at an ATF for
appropriate treatment and recovery, the owner or operator of that facility must:
� Issue a CoDto the registered owner, an authorised person of a local authority or
a member of An Garda Síochána; and
� Allow all relevant information relating to that CoDto be noted on the National
Vehicle and Driver File;
No charge may be imposed by the ATF on the registered owner of the ELV in respect
of the CoD.
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Vehicle Vehicle Vehicle Owners Owners
Owners
An obligation is also imposed on vehicle owners, where the registered owner of a
specified vehicle intends to discard that vehicle as waste; he or she is required to
deposit that vehicle at an ATF.
Main Main Stakeholders
Stakeholders
Stakeholders
422
� Irish Motor Vehicle Recyclers Association (IMVRA),
� Metal Recyclers Association of Ireland (MRAI), and
� Society of the Irish Motor Industry (SIMI).
These stakeholders were actively engaged with the DoEHLG in regard to the effective
transposition and implementation of the ELV Directive.
National National Vehicle Vehicle and and Driver Driver File
File
The Department of Transport’s National Vehicle and Driver File maintains records of
registered owners of vehicles. All information relating to CoDare forwarded to the
National Vehicle and Driver File.
The The Scrap Scrap Industry
Industry
The scrap industry, divided in simple terms between the dismantlers, who
disassemble the car for parts, and the shredders, who crush the remaining hulk, and
are required to implement higher reuse rates and stricter anti-pollution stipulations to
ensure further materials recycling of ELVs.
22.5 Monitoring and Measurement Techniques Applied
The EPA is responsible for collecting data through the National Waste Report project.
The Core Prevention Team of the EPA engages with the different sector players to
ascertain how waste management data for ELVs might be best compiled. The EPA
are currently conducting shredder trials to assess the material content of ELVs
recovered in Ireland. This information is due to be published later this year.
There are obligations on all ATFs to keep records of the aggregate weight of materials
for reuse, recycling, recovery and disposal arising from ELVs and report to local
authorities on an annual basis.
Given that the Regulations were only implemented relatively recently in Ireland
reliable statistics cannot be identified on current recycling levels. 475 Reliable reporting
systems have to be put in place to allow firm conclusions to be drawn as to the
percentages of material that are being reused or recovered in some way. Delays are
also being experience in assembling definitive data.
With the arrival of the ELV Directive, it became important for information on the
arisings and management of ELVs in Ireland to be made available, in order that
475 European Parliament 2007: End of Life Vehicles (ELV) Directive - An Assessment of the Current
state of Implementation by Member States.
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Ireland would be able to meet the requirements of the Directive in the best manner
possible. In the absence of a system of de-registration, several methods of estimation
were used in an EPA study carried out in 2002. 476 These studies consisted of both
direct and indirect methods. The direct methods involved surveying metal recovery
operators and the single metal recycler in Ireland, which was in operation until June
2001. The indirect methods consisted of using formulae developed by the European
Topic Centre on Waste. Statistics provided by the DoEHLGs Vehicle Registration Unit
were also used. Two methods were considered to provide the most accurate
estimates. The survey of the metal shredding facilities provided an estimate of
176,632 ELVs in 2000. The adjusted ETC/W method provided an estimate of
217,203 ELVs in 2000.
22.5.1 Evaluation Studies Available
In the absence of any existing published information on ELVs in Ireland, the EPA
carried out a study in 2002 (as outlined above) highlights the situation at the time
with regard to the arisings and management of ELVs in Ireland. 477
A Statement on Regulatory Impact Waste Management (End of Life Vehicles)
Regulations 2006 was published by the DoEHLG in May 2006. 478 This document
assessed the likely impacts, effects and costs associated with implementation of the
ELV Directive.
The European Parliament issued a report in 2007 assessing the current state of
implementation of the ELV Directive by Member States. 479 This document suggests
that it is too early to draw definitive conclusions as to whether targets for recycling
and recovery have been widely met or not.
A paper was circulated by Duncan Laurence Environmental in February 2007. This
paper provides a legislation summary of the ELV Regulations. 480
22.6 Environmental Benefits
The uncontrolled disposal of end of life vehicles can pose a serious threat to the
environment due to the materials contained in them and the method in which they
are managed. The overriding aim of the Regulations is to protect the environment and
human health.
476 EPA (2002) End of Life Vehicles – A Sectoral Report.
477 EPA (2002) End of Life Vehicles – A Sectoral Report
478 Department of the Environment, Heritage & Local Government (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
479 European Parliament 2007: End of Life Vehicles (ELV) Directive - An Assessment of the Current
state of Implementation by Member States.
480 Duncan Laurence Environmental (February 2007) Waste Management End of Life Vehicles
Regulations 2006, Legislation Summary.
423
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Arising from the free take back of end of life vehicles, qualitative environmental
benefits arguably grow in society, by reducing the numbers of vehicles being
abandoned in public places and by increasing awareness amongst the general public
in relation to the proper treatment and disposal of end of life vehicles. The system
whereby authorised treatment facilities (ATFs) will issue Certificates of Destruction
(CoDs) will contribute to the improvement of Ireland’s vehicle registration system and
may also help combat certain forms of anti-social behaviour associated with end-oflife
vehicles.
Storage and treatment standards will be improved in line with the requirements of
Annex 1 of the ELV Directive. These new standards will reduce the risk of negative
environmental impacts on both the environment and human health.
The Waste Management (End of Life Vehicles) Regulations 2006 transpose the aim of
the Directive on prevention of waste arisings from end of life vehicles and promoting
the collection, re-use and recycling of their components. Vehicles are to be treated in
an environmentally sound manner resulting in higher environmental standards across
all facilities involved in the collection, storage and treatment of end of life vehicles.
22.6.1 Environmental Benefits – Prevention
The Regulations promote the prevention of waste through specific provisions such as
restrictions on the use of specified hazardous substances in the manufacture of new
vehicles. While motor manufacturing does not take place in Ireland, the Regulations
transpose the provisions in the Directive on the restriction of hazardous substances
in motor vehicles and the Irish environment will benefit from this restriction on the
future use of these substances 481 . Restricting and reducing the use of hazardous
substances prevents their release into the environment, thereby avoiding the need to
dispose of future hazardous waste arisings and further facilitating the recycling of
specified vehicles at end of life.
The Regulations place eco-design obligations on vehicle producers introducing the
prohibition of heavy metals for materials and components of specified vehicles.
Vehicles that a producer places on the market cannot contain lead, mercury,
cadmium or hexavalent chromium other than in the cases specified in the Fourth
Schedule of the 2006 Regulations. These restrictions thereby encourage the motor
manufacturing industry to design and produce more reusable and recyclable
parts/components and hence adopting more environmentally friendly practices in the
use of materials.
Waste prevention is defined as the eliminating and reduction at source of material in
terms of waste arisings and harmful substances. By virtue of the above, the End of
Life Vehicles Regulations result in hazardous waste prevention and minimisation.
481 Department of the Environment, Heritage & Local Government (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
424
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22.6.2 Environmental Benefits Associated with Recycling
The Regulations introduce new environmental standards to ensure that as much
material as possible is re-used, recovered and in particular recycled from an ELV and
that this process is carried out in a way that does not harm the environment. Under
the Regulations, producers and ATFs are required to meet new recovery and recycling
targets for ELVs of:
425
� 85% reuse / recovery by average weight per vehicle deposited for appropriate
treatment by 1 st January 2006 (to include 80% materials recycling); and
� 95% reuse / recovery by 1 st January 2015 (to include 85% materials recycling).
The Regulations identify treatment operations for the depollution of ELVs and further
affirm that the removal of any article or material from a vehicle, shall be carried out in
such manner so as to best promote it’s recycling. The provisions relating to designing
for recycling in Part IV of the Regulations will encourage the motor manufacturing
industry to produce more recyclable parts, design for reuse and adopt more
environmental friendly practices in the use of materials. The ambitious reuse,
recovery and recycling targets that Ireland is now required to achieve in respect of
ELVs, will have a consequential result in that significant volumes of automotive
shredder residues (ASR) will be diverted from landfill. The Directive will facilitate the
environmental management of 100,000 ELVs which arise annually in Ireland. 482
22.7 Implementation Costs
The introduction of the ELV Directive in Ireland has cost implications for both industry
and State bodies involved, in particular local authorities.
Local authorities will have responsibility under the Regulations for administering and
enforcing the scheme in their functional areas. This will impose significant costs. As
this is a producer responsibility initiative based on the polluter pays principle, the
Regulations provide for a fee-based registration system which will go towards meeting
local authority costs in administering and enforcing the Regulations in their functional
areas. In making an application for registration to each local authority, producers
must pay the following registration fees to each local authority:
� €1,000 for producers whose annual turnover was less than or equal to
€50,000,000;
� €2,500 in respect of producers whose annual turnover was greater than
€50,000,000 but less than or equal to €100,000,000; and
� €6,000 in respect of producers whose annual turnover was greater than
€100,000,000.
The registration fee system will have cost implications for industry estimated at
€3.4m on an annual basis, but will result in cost recovery for local authorities for
482 Department of the Environment, Heritage & Local Government (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
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expenditure incurred in implementing and enforcing the Regulations for this producer
responsibility based scheme. These fees are based on estimates provided by local
authorities. Article 11(7) of the Regulations allow the Minister to review the fees after
the 1 st October 2007 and empowers the Minister to adjust the fees set upwards or
downwards.
The Regulations impose administrative responsibilities on producers in terms of the
preparation and submission of implementation plans to local authorities and data
compilation and reporting, the latter also applying to ATFs who in addition will incur
some costs in managing the system of CoDs. Permitted facilities have to report data
to local authorities and the extra administrative burden on ATFs should not give rise
to significant costs.
While there is no accurate information available on the establishment and upgrading
of ATFs, the initial investment in Ireland to ensure a national network of 43
contracted ATF’s to the standards required by the Regulations could cost in the range
of €1.7m. 483 The National Hazardous Waste Management Plan 2008-2012 states
that approximately 82 ATFs were confirmed to be in operation in Ireland. This plan
suggests the need for the number of ATFs to increase in order to ensure that all ELVs
are managed according to the Regulations and EU Directive.
22.8 Response from Public and Industry
We are not aware of any document, which highlights these. 484
The vehicle manufacturers business strategy is based around selling new vehicles
and supplying new parts for these vehicles. The ELV Regulations state that all
information required for the appropriate treatment and recovery of end-of-life vehicles
shall be made available to authorised treatment facilities by vehicle producers and
vehicle component manufacturers. This effectively allows for the availability of
professional and technical information to the car dismantling industry.
22.9 Effects on Technical Change / Innovation
The EU Directive on ELVs aims to improve the environmental performance of all
economic operators involved in the life cycle of vehicles. Bearing in mind that cars,
vans, etc. driven on Irish roads are manufactured outside of Ireland, it is decided to
consider technical change and innovation on an international context.
The impact of economic instruments, induced by the EU Directive on end of life
vehicles, on innovation paths in car manufacturing is addressed in a paper produced
by Massimiliani Mazzanti and Roberto Zoboli (University of Ferrara). 485
483 Department of the Environment, Heritage & Local Governement (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
484 The EPA were contacted in relation to responses from public and industry.
485 Massimiliano Mazzanti and Roberto Zoboli (May 2005) Economic Instruments and Induced
Innovation: The Case of End of life Vehicles European Policies, University of Ferrara, Italy.
426
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According to this paper:
427
� The creation of networks of dismantlers linked to individual car companies has
been a major organisational innovation given the previously existing limited
relationships between the car industry and post-consumer ELV treatments.
However, contractual arrangements between the main actors (carmakers,
dismantlers, shredders, and recyclers) differ from country to country.
� Innovative developments concerning design for dismantling (DFD) are taking
place in all car companies. DFD may consist of small changes in the partassembling
systems or it may imply changes and adaptations of components
and parts. The boundaries between DFD and design for recycling (DFR) are not
clear-cut.
� DFR requires definition and measure of “recyclability”. European carmakers
work on the development of “recyclability coefficients” for materials and
components and include lists of not admitted or undesired
substances/materials in the technical specifications imposed to component
suppliers. Thus, a “responsibility transfer” between industries takes place. DFR
is also increasingly linked to Life-Cycle Analysis (LCA). Most carmakers are
investing in recycling-oriented LCA at the research & development (R&D) level
and, in some cases, they are transferring results to practice. LCA is generally still
limited to specific materials or car components. DFR pushes most carmakers to
pursue a simplification of the material regime. “Easily” (i.e. economically)
recyclable materials are favoured and, as a consequence, the trend towards the
use of certain polymers and composite materials is weakening. There is a
propensity to reduce the number of polymers in favour of those having the best
recycling possibilities and a process of inter-polymer substitution is underway.
The legislation not only transposed into Irish law the EU Directive on End of Life
Vehicles (Directive 2000/53), it also made a significant amendment to the Waste
Management (Permit) Regulations 1998. This amendment enlarged the decisionmaking
criteria under which all types of waste permit application received since 8
June 2006 are considered 486 .
22.10 Social and Distributional Consequences
The Regulations are designed to allow competition to operate effectively and should
not lead to market distortions, particularly in relation to existing small businesses
operating in the scrap-vehicle dismantling sector.
Each producer is required to establish a national system for the collection and
treatment of negative value ELVs for which they are responsible. While the national
network, which a producer puts in place for the collection and treatment of ELVs,
must be a minimum of 43 ATFs nationally, there is no maximum limit; hence there will
be opportunities for the existing operators to compete for this business.
486 Duncan Laurence Environmental (February 2007) Waste Management End of Life Vehicles
Regulations 2006, Legislation Summary.
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Anti-competitive practices are addressed by the inclusion in the Regulations of a
maximum period of three years for any agreements made between producers and
ATFs. The requirement to meet common minimum treatment standards will also
encourage a level playing field and facilitate the market to operate efficiently 487.
It is suggested that the system whereby ATFs issue CoDs contributes to the
improvement of Ireland’s vehicle registration system and can also help combat
certain forms of anti-social behaviour associated with ELVs. 488
22.11 Complementary Policies
Both the End of life Vehicle Regulations and the Batteries Regulations 489 contain
substance restrictions. The substance restrictions in Part I of the Batteries
Regulations (for the use of mercury and cadmium) indicate that these apply without
prejudice to the ELV Regulations, which means that the prohibitions contained in Part
II of the Batteries Regulations do not apply to batteries covered by the ELV
Regulations. 490
The ELV Regulations restrict the use of mercury, cadmium and lead in cars. However
it allows a maximum concentration of mercury of up to 0.1% by weight and per
homogenous material. There is an exemption for the use of cadmium in batteries for
electric vehicles, which expires on the 31 December 2008, and an exemption for lead
in batteries without expiry date.
Both the ELV and the Batteries Regulations establish the principle of producer
responsibility. A car producer is also regarded as a battery producer in a Member
State under the Batteries Regulations if it places the battery on the market (inside the
car) for the first time in that Member State on a professional basis. This is to ensure
that there is a producer responsible for all batteries placed on the market. However,
the Batteries Regulations states that Member States should avoid any double
charging of producers when car batteries are collected under the ELV Regulations.
The focus of the RoHS (Restriction of Hazardous Substances) Regulations 491 is to
limit the amount of hazardous metals contained in electrical and electronic
components. The list includes lead, mercury, hexavalent chromium, cadmium and
certain organic compounds. In a similar manner, the ELV Regulations is primarily
targeted toward hexavalent chromium content in automotive components. The goal of
487 Department of the Environment, Heritage & Local Government (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
488 Ibid.
489 Waste Management (Batteries and Accumulators) Regulations 2008 (S.I No. 268 of 2008)
490 Commision Services Document (April 2008) Questions and Answers on the Batteries Directive
(2006/66/EC)
491 Waste Management (Restriction Of Certain Hazardous Substances in Electrical and Electronic
Equipment)(Amendment) Regulations 2008 (SI 376 of 2008)
428
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oth pieces of legislation is to restrict, or eliminate, the use of hazardous materials in
manufactured goods sold overseas.
22.12 Effect of the Policy on Pricing of Resources / Services
It is difficult to determine the actual costs for the treatment of ELVs, however, it has
been estimated to be in the region of €60 to €80/vehicle. These costs could accrue
to circa €6.6m annually.
KPMG carried out two studies with a view to determining the appropriate levy to be
paid to authorised treatment facilities for the depollution of ELVs. 492 The first report in
May 2002 recommended that a levy be set at €153/ELV excluding VAT; in a
subsequent report completed in 2003 KPMG recommended a revised figure of
€120/ELV excluding VAT. These figures included the costs of depollution. The reports
were based on an analysis of the costs and revenues associated with dismantling an
end-of-life vehicle, taking account of the labour / administration costs. The reports
noted the volatile nature of the market for hulks and scrap metal and the
susceptibility of this market to price fluctuations. The second KPMG report noted that
there was scope for the price of any proposed levy to fall to €60 to €70 per vehicle.
It is reasonable to suggest the manufacturing cost of vehicles has been affected by
the specific requirements imposed on vehicle manufacturers. The reduction of
hazardous components, the labelling of components for recycling, design for
dismantling has, most likely, imposed upward pressure on vehicle manufacturing
costs. However, as technologies develop the cost of such change may diminish. As a
result of the competitive nature of vehicle sales and the numerous variables involved,
it is difficult to determine if additional costs have been passed on to the end
user/customer.
22.13 Evasion and Enforcement
It is an offence for an individual or an ATF to fail to comply with the law on the
disposal of ELVs. In particular, it is an offence not to obey the rules concerning vehicle
CoD, or not to deposit at an ATF a vehicle intended to discard as waste.
Penalties for offences set out under the Waste Management Acts apply. On summary
conviction a fine of up to €3,000 and/or 12 months imprisonment can be imposed.
For conviction on indictment a fine of up to €15,000,000 and/or 10 years
imprisonment is available to the court.
492 Department of the Environment, Heritage & Local Government (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
429
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22.14 Lessons Learned
22.14.1 General Lessons
The National Hazardous Waste Management Plan 2008-2012 493 states that
approximately 82 ATFs were confirmed to be in operation in Ireland. Two companies
(Hammond Lane Metal Company and Hegarty Metal Recycling) operate three vehicle
shredders in the Republic of Ireland. The National Hazardous Waste Management
Plan 2008-2012, suggests the need for the number of ATFs to increase in order to
ensure that all ELVs are managed according to the Regulations.
Part IV to the ELV Regulations sets out design requirements in respect of waste
prevention and the use of hazardous substances in new motor vehicles. Obligations
for compliance with these provision rests not only on vehicle manufactures, they
apply also to vehicle importers located in Ireland. Manufacturers and vehicle
importers are also charged with the requirement to inform “the competent authority
prescribed by the Minister for this purpose” of non-complaint vehicles in instances
where vehicle components contain hazardous substances above specified thresholds.
These provisions came into effect immediately on the 8th June 2006, despite the fact
that no enforcement body has been prescribed at the time of writing. 494
The absence of data on performance thus far suggests that data reporting is not as
good as might have been expected.
493 EPA (2008) National Waste Prevention Programme, Prevention Plan 2009 – 2012, Wexford: EPA.
494 Duncan Laurence Environmental (February 2007) Waste Management End of Life Vehicles Regs
2006, Legislation Summary.
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23.0 Producer Responsibility, ELVs - International
23.1 Outline of Policy
End of Life Vehicle (ELV) policies have the general aim to reduce the environmental
impacts associated with vehicles that have come to the end of their life, through
mechanical failures, accident or other economic factors. They explicitly aim to
increase the quantity of vehicles legally scrapped, increase the recovery rates of
materials from those vehicles, reduce the impact of hazardous materials by enforcing
depollution standards at authorised treatment facilities (ATF), and promote innovation
in vehicle design in order to make components eminently more recyclable.
In essence, the structures of the policies are based on producer responsibility; hence
the vehicle manufacturers finance the cost of treatment net of revenue from the sale
of recycled materials. However, the costs of some systems are financed directly by
levies imposed on the consumer at the point of sale of all new vehicles.
The main driver behind the policy in the EU, for example, was the level of waste
generated from ELVs and disposed of in landfill, and the need to reduce the
associated environmental impacts. Alternatively, in countries like Japan and Korea,
the policy has been developed to both implement ideals of ‘shared responsibility’ but
also to ensure that cars produced in those countries maintain international approval
by complying with the tough standards set out in the EU ELV Directive. This Directive
appears to be the most substantial and recognised around the globe, and one that
other international policies aspire to, both in terms of purpose, and specific recovery
rates.
Many policies are developed so that there is zero cost to the final owner of the
vehicle. Free take back of vehicles is a key element to ensuring that ELVs are not
abandoned when the cost of recovery is high. This is, in part, driven by the value of
metals in the recycling markets. When the value of recycled metals is low the systems
implemented by the policies will fund the continued operation of the ATFs that have
been set up to manage the recycling and recovery of ELVs. If this system was not in
place and the final owner had to ‘foot the bill’ one would see a sharp increase in
abandoned vehicles that would be directly related to peoples’ willingness (or
unwillingness in this case) to pay for the final disposal of their vehicle.
In the EU the EC has evaluated the effectiveness of the EU ELV Directive and found
that, notwithstanding the variation in compliance with the Directive across member
states, the policy has substantial environmental and economic benefits associated
with the increased recycling and recovery of materials from ELVs, in addition high
targets increase recycling and promote investment in eco-innovation to further
increase marginal recycling rates, mainly through innovations in post-shredder
technologies that mechanically sort additional materials from the automotive
shredder residue (ASR).
431
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23.2 Where Has the Policy Been Applied and Why?
23.2.1 Europe
National policies have been applied in all European countries following the
implementation of the EU ELV Directive, which came into force in 2000. 495 Member
States were obliged to implement national policies by 2002. The directive was to: 496
432
� Ensure that all ELVs are only treated by authorised dismantlers;
� Provide free take-back of all ELVs for new vehicles put on the market after
2002; from 2007 provide free take-back for all vehicles including those put on
market before 2002;
� Restrict the use of heavy metals in vehicles from July 2003; and
� Ensure that a minimum of 85% of vehicles are reused or recovered (including
energy recovery) and at least 80% are reused or recycled from 2006 These
rates increase to 95% and 85%, respectively, by 2015.
It also requires the 'de-pollution' of vehicles before being recycled. This involves
extracting petrol, diesel, brake fluid, engine oil, antifreeze, batteries, airbags, mercurybearing
components and catalysts.
The scope of the Directive includes cars with no more than 8 seats and goods
vehicles less than 3.5t only.
A small number of well administered countries with early experience of operating a
highly regulated system of car disposal have been able to implement the Directive
relatively smoothly. 497 The Netherlands and Sweden are good examples in this
respect, with Sweden having enacted its first vehicle scrappage law in 1975 and
implemented producer responsibility from 1998. Many, however, have experienced
significant difficulties, delays and setbacks in implementing the Directive. Reflecting
this, the Commission has taken some form of legal action against most of the EU-15
Member States in relation to this Directive, in particular for late implementation. The
EU-10, new Member States, have also experienced additional problems. Some
examples are given in Section 23.12.
23.2.2 Asia
Policies have also been applied in Japan, Korea and China. However, the data and
evaluation of these policies is less thorough than in the EU. These countries,
especially Korea, have historically had large car manufacturing industries that have
495 The End of Life Vehicles (ELV) Directive (2000/53/EC).
496 A. Doran (2003) POLICY DISCUSSION: End of Life Vehicle Directive (ELV), Policy discussion by Andy
Doran from LARAC, http://www.larac.org.uk/pdf/elvbrief.pdf
497 M. Fergusson and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
Economic and Scientific Policy.
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driven the reclamation industry to a much greater extent than other states in Asia /
Indonesia.
23.2.3 North America
Certain Canadian provinces have regulations in place, or planned, but it is reported
that there is minimal effect on waste prevention or recovery. 498 In Ontario there are
municipal by-laws to govern the motor recycling industry, although, consistent
monitoring of auto recycling sites (classed as ‘waste disposal sites’) is abysmal and a
relevant certificate of approval has not been issued since 1979. In British Columbia
there is a strong awareness of the issue and trade associations have helped devise a
strategy with preventing pollution in mind. Despite these efforts, the regulations have
not been enacted to date and there is no indication of when this may occur.
No federal ELV polices are in place in America. Instead the largest vehicle
manufacturers have formed vehicle recycling infrastructure partnerships, and actively
promote the correct recovery of ELVs as part of their corporate social responsibility
(CSR). In fact several of the large US companies quote the EU Directive and the ‘tough
targets’ they are helping EU dismantlers to achieve. Interestingly, change in the
design of vehicles to facilitate the recycling and recovery of materials by American
automotive manufacturers has been directly driven by their desire to sell vehicles in
the EU. This is because the legislation requires any vehicle manufacturer – whether
based in the EU or not – to contribute to the final cost of recovering their own models
of vehicles. Thus implementation of policy in one part of the world can have
significant implications for international markets around the globe.
23.2.4 Country-specific Characteristics: The Netherlands
There are around 8 million cars in the Netherlands, but only 0.4% of new cars sold in
2005 were manufactured domestically, with the majority being imported from
Germany and France. 499 Annual sales of new cars have been declining, reflecting an
increase in average life. There are no significant quantities of scrapped cars imported
or exported for dismantling.
The implementation of the Directive was actually inspired by the pre-existing Dutch
system that was developed by the main business organisations in the car industry.
The organisation ‘Auto Recycling Nederland’ (ARN) was previously established to
manage the ELV treatment system. Unlike other Member States, the system operates
by generating revenue from discreet fees levied on all new car registrations and used
to fund the unprofitable parts of certified car scrapping and recycling firms. The
system is fully self-financing, so it could be said that the car producers and importers
pay the cost of ELV management, but the cost will inevitably pass to the consumer.
498 1877 End of Life Vehicles.com (2008) Legislation, Accessed 15 th October 2008,
http://1877endoflifevehicles.com/legislation.cfm
499 M. Fergusson and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
Economic and Scientific Policy
433
International Review of Waste Policy: Annexes

23.2.5 Country-specific Characteristics: Sweden
The car industry is Sweden’s greatest exporting sector, accounting for more than 15%
of total exports in 2004 (Volvo being the most common brand). 500 The total number of
cars has been increasing, but the proportion of cars scrapped has been declining.
Sweden has a long history of legislation relating to ELVs. From the first scrappage
laws in 1975 (based on a deposit refund system) to the wide-ranging ordinance on
producer responsibility in 1998, both laws already covered all aspects of the EU
Directive. Similarly to the Netherlands, a charge for the disposal of ELVs is levied on
the sale of all new vehicles.
The reporting of the targets required by the directive is controlled by the Swedish
Environmental Protection Agency (SEPA). Vehicle producers must submit data which
allows SEPA to assess the degree of reuse/recovery/recycling of vehicles. This is then
published in annual reports on how waste subject to producer responsibility is dealt
with, and includes recommendations by SEPA that address any emerging problems.
In addition, the Swedish Car Recyclers Association (SBR) carries out an annual survey
of its members to produce data on the number of scrapping certificates issued and
quantities of waste for a number of selected materials derived from the scrap.
23.2.6 Country-specific Characteristics: England
The UK implemented separate parts of the ELV regulations in both 2003 and 2005.
Like many other Member States, it was late doing so. 501 The implementation of take
back for all cars was left until 2007 – the final date for which producers would be
responsible for all vehicles placed on the market under the Directive.
Under the Directive, authorised treatment facilities (ATFs) have to obtain a permit
from the regulatory agencies in order to legally dispose of vehicles to a minimum
technical standard. The two main service providers in the UK are Autogreen and
Cartakeback. They work as industry associations to manage the network of
dismantlers and recyclers. The network has grown extensively, from approximately
650 facilities in 2003 to 1,400 by 2006.
The growth in the network has been pushed by additional regulations being
implemented in the UK whereby an average 75 % of last owners should be within 10
miles of the nearest ATF, and no one should be more than 30 miles (or else free take
back from the home applies). 502
500 M. Fergusson and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
Economic and Scientific Policy.
501 M. Fergusson and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
Economic and Scientific Policy.
502 In remote areas where this is not possible, one service contractor (Cartakeback) has established
collection points to which vehicles can be delivered for onward transportation to an Authorised
Treatment facility for de-pollution.
434
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23.2.7 Country-specific Characteristics: Japan
In Japan, the Ministry of International Trade and Industry passed legislation in
October 1996 that adequately addressed the management and treatment of ELVs. 503
It stipulated that vehicle manufacturers must decrease the amount of lead used in
newly produced vehicles and also set clear targets for the recycling of ELVs. 504
The Recycling Law of 2005 further substantiates the legislation to include take back
responsibility for producers. It is based on a ‘shared responsibility’ principle. This is to
be paid for by the implementation of a recycling fee, added on to the cost of each
saleable unit. The different fees relate to the following vehicle types:
435
� Small and compact car;
� Medium-sized car;
� Tracked; and
� Large bus.
This fee is paid before the initial registration of the vehicle. It is collected by the Japan
Automobile Recycling Promotion Centre (JARC) and is tracked through electronic
manifests until the vehicle’s end of life.
Reuse, recycling and recovery rates for ELVs have been set so that they mirror the
European targets set out under the EU ELV Directive.
If a vehicle is exported for sale or dismantling then the fee is refundable to the owner
disposing of the vehicle. In the first year of introduction of the policy the number of
ELVs decreased by a half to around 4.8 million. However, the export of used cars also
increased dramatically, indicating that cars were being exported before they were
classed as ELVs to take advantage of the refundable recycling fee.
23.2.8 Country-specific Characteristics: South Korea
There has been an obligation to take back ELVs in Korea since 1982. 505 However, in
2007 the Act for Resource Recycling of Electrical and Electronic Equipment and
Vehicles diversifies manufacturer’s responsibilities to include: 506
� Restrictions on the use of hazardous materials;
503 C. Kim (2007) A comparison of ELV system in Japan and Korea, Presentation for The Centre for
Business Relationships Accountability, Sustainability and Society,
http://www.brass.cf.ac.uk/uploads/elv_kim_c.pdf
504 1877 End of Life Vehicles.com (2008) Legislation, Accessed 15 th October 2008,
http://1877endoflifevehicles.com/legislation.cfm
505 C. Kim (2007) A comparison of ELV system in Japan and Korea, Presentation for The Centre for
Business Relationships Accountability, Sustainability and Society,
http://www.brass.cf.ac.uk/uploads/elv_kim_c.pdf
506 RJS Technical Consulting (2007) Act No. 6319 Resource Recycling, Accessed 20 th January 2008,
http://www.rsjtechnical.com/WhatisKoreaRoHS.htm
International Review of Waste Policy: Annexes

436
� Improvement of materials and structure in products so that they are easy to
recycle;
� Separate collection of waste products so that there is no cost to the person
disposing of them. This includes the need for vehicle producers/importers to
contract with recyclers for ELV processing;
� Producers/importers of vehicles are prescribed an annual recycling target by
Presidential Decree. However, since the implementation of the Act, such a
Decree and hence national recycling rates have not yet been set; and
� Recycling Information Network database that vehicle producers/importers can
use to provide recyclers with information about material composition and
recycling methods for their products, “to the extent confidential business
information is not disclosed”.
There is significant vehicle manufacturing in Korea, but the reprocessing industry is
much larger. The number of ELVs dismantled in the country is 3 times is the number
produced. Thus, nationally, the demand for ELVs exceeds the supply. This has allowed
for ELVs to be sold to dismantlers on an open market and thus the obligation to take
back vehicles was only required in the minority of cases.
National legislation was further developed because Korea wished to develop the
same high standards that are set out in the EU ELV directive. The 2007 Act provides
for four different types of recyclers that process end-of-life vehicles:
� Vehicle recyclers dismantle vehicles and recycle its parts to the maximum
extent possible; then transfer the vehicle body and "residues" to shredders;
� Vehicle shredding recyclers recover metallic materials from the residues and
shred the rest of the dismantled vehicle; then transfer "shredder residues" to a
residue recycler;
� Vehicle shredder residue recyclers recover metallic materials from shredder
residues; then recycle and/or recover energy from the residues to the
maximum extent possible; and
� Discarded gas recyclers who segregate and store substances that cause
climate change.
In several countries in the EU - notably Sweden and the Netherlands - as recycling
rates increase further R&D is being undertaken into processes that recover material
from the shredder residue. So it is a forward thinking part of the policy that Korea
includes shredder residue recyclers in its structure.
The previously poor reporting and control over standards of the recycling network in
Korea has resulted in stricter mechanisms of enforcement, such as quarterly reports
from the recyclers, recycling associations and vehicle producers, that are to be
submitted to the Ministry of Construction and Transport. Furthermore, under the Act,
any public official can inspect any of the processing facilities with only 7 days prior
notice to ensure that standards are being maintained.
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23.2.9 Country-specific Characteristics: China
The volume of in-use vehicles in China will reach 55 million by the end of 2008 and
the volume of ELVs will top 2 million this year. 507 In 2001, China passed a law
regulating the disposal and recycling of ELVs, but progress has been slow, with the
rate of dismantling just 10%. China has also established some ELV dismantling and
disposal enterprises since 2005, but they are mostly mixed with used car sales
networks, and many ELVs were resold through various channels after simple
remolding.
China's industry authorities have started to amend the country's rules for the recycling
of ELVs. The new standards regulating the disposal and recycling of ELVs are said to
be in the pipeline and will published later this year. There are expected to be modeled
on a market based system, as in the EU, and require similar targets. 508
23.3 Key Organisations Involved in Implementation and
Management
Table 23-1 shows that the main types of organisation involved are environmental
agencies, car licensing authorities and some kind of network or association of
recyclers.
Table 23-1: Key Organisations Involved in ELV Policies
437
Country Country
Key Key Organisations
Organisations
The Netherlands ‘Auto Recycling Nederland’ (ARN)
Sweden
England
International Review of Waste Policy: Annexes
Swedish Environmental Protection Agency (SwEPA)
Swedish Car Recyclers Association (SBR)
Driver Vehicle License Authority (DVLA)
AutoGreen / Cartakeback
Japan Japan Automobile Recycling Promotion Centre (JARC)
South Korea
Ministry of Environment
Ministry of Construction and Transport
Vehicle Recycling Associations
507 Gasgoo (2008) China to issue new standards of ELV recycling, Accessed 15 th October 2008,
http://www.gasgoo.com/auto-news/6899/China-to-issue-new-standards-of-ELV-recycling-in-2008.html
508 C. Kim (2007) A comparison of ELV system in Japan and Korea, Presentation for The Centre for
Business Relationships Accountability, Sustainability and Society,
http://www.brass.cf.ac.uk/uploads/elv_kim_c.pdf

23.4 Pre-implementation / Evaluation Studies Available
In addition to the individual references given throughout this section, the following
specific evaluation studies give useful information on the performance of ELV
policies:
438
� Fergusson, M. and IEEP (2006) End of Life Vehicles (ELV) Directive: An
assessment of the current state of implementation by member states, Report
for The European Parliament: Policy Department Economic and Scientific
Policy,
http://www.europarl.europa.eu/comparl/envi/pdf/externalexpertise/end_of_li
fe_vehicles.pdf
� GHK, and Bio Intelligence Service (2006) A study to examine the benefits of
the End of Life Vehicles Directive and the costs and benefits of a revision of
the 2015 targets for recycling, re-use and recovery under the ELV Directive,
Final Report to DG Environment, May 2006,
http://ec.europa.eu/environment/waste/pdf/study/final_report.pdf
� Cassells, S., Holland, J. and Meister, A. (2005) End-of-life vehicle disposal:
Policy proposals to resolve an environmental issue in New Zealand, Journal of
Environmental Policy & Planning, Volume 7, Number 2, June 2005 , pp. 107-
124(18).
23.5 Environmental Benefits
23.5.1 Waste Prevention
Current trends show that, both the production 509 and weight 510 of vehicles are set to
increase over time. However, it is possible that people will choose smaller cars or
vehicle producers, under pressure to reduce GHG emissions per mile, will reverse the
trends and average vehicle weight will actually fall. Furthermore, some policies, such
as in Korea, are designed to promote innovation in vehicle design so that some
components are eminently more recyclable, thus preventing the final disposal of the
previously unrecycled component.
Alternatively, waste prevention can be achieved by reducing the hazardousness of the
materials that make up the vehicle. Policies in both the EU and Asia include a phase
out of heavy metals used in the manufacture of vehicles. 511
509 World Watch Institute (2008) Vehicle Production Rises, But Few Cars Are “Green”, Accessed 15 th
October 2008, http://www.worldwatch.org/node/5461
510 GHK, and Bio Intelligence Service (2006) A study to examine the benefits of the End of Life Vehicles
Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and recovery
under the ELV Directive, Final Report to DG Environment, May 2006,
http://ec.europa.eu/environment/waste/pdf/study/final_report.pdf
511 Fergusson, M. and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
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In addition to the benefits associated with a reduction in heavy metals the depollution
of vehicles before dismantling provides additional environmental benefits. These
processes are all required by law in the countries that have implemented ELV polices
and are best practice (though not necessarily widespread) in those that have not i.e.
America. These processes prevent the following hazardous materials / products from
causing environmental damage: 512
439
� Batteries;
� Explosive components of airbags;
� Oils, cooling liquids, anti-freeze and other liquids; and
� Any parts containing mercury, cadmium etc.
23.5.2 Recycling
A main aim of all the ELV policies considered in this report is to increase reuse,
recycling and recovery rates. This section will firstly describe the processes involved in
the treatment system (including some narrative on post-shredder technologies),
describe the benefits of increased recycling and recovery of materials from ELVs,
highlight how the targets – and the policies in general – can be measured, and finally
indicate constraints to the recycling of ELVs in terms of the markets for recyclable
materials.
Figure 23-1 highlights the treatment processes involved in the management of ELVs.
As can be seen, reuse and reprocessing from the depollution of the vehicle at an ATF
is the first step involved. Further reuse of materials occurs when the vehicle is
dismantled. This dismantling process has been simplified due to component coding
standards and knowledge exchange promoted by the policies (See Section 23.7).
Recycling of materials can occur from the following steps:
� Initial dismantling of the vehicle;
� Recovery of metals when the vehicle body is processed in an automotive
shredder; and
� Further separation of materials from the automotive shredder residue (ASR) -
otherwise known as flock or fluff. For example, plastics separation using near
infrared technology.
In the EU, baseline recycling and reuse rates are around 80%, and can be obtained
with little additional technology being implemented. The majority of this figure
comprises of metals recycling (this level was occurring before the implementation of
the policy because of the high price of recycled metals) with the remainder of the
Economic and Scientific Policy,
http://www.europarl.europa.eu/comparl/envi/pdf/externalexpertise/end_of_life_vehicles.pdf
512 US Commercial Service (2006) International Market Insight, End-of-Life-Vehicles – EU Legislation,
Accessed 20 th October 2008, http://www.buyusa.gov/auto/end_of_life_vehicles_eu_design.html
International Review of Waste Policy: Annexes

ecycling and reuse activity being attributed to products such as tyres, glass, and a
minimal quantity of plastics.
Figure 23-1: Treatment Process for ELVs
Source: GHK, and Bio Intelligence Service (2006) A study to examine the benefits of the End of Life
Vehicles Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and
recovery under the ELV Directive, Final Report to DG Environment, May 2006,
http://ec.europa.eu/environment/waste/pdf/study/final_report.pdf
Countries like the Netherlands, Switzerland and Japan, are finding that the marginal
cost of recycling rapidly increases above around 80% because of the labour costs
involved in separating the material from the vehicle body, especially plastics, which
comprise the majority of the material left after the metals, tyres and glass have been
recovered post dismantling. They are increasingly using post-shredder technologies to
mechanically recover additional material from the shredder residue. The norm is for
this residue to be landfilled, because the cost of landfilling is currently cheaper than
alternatives. Alternatively the residue can be recovered by thermal processes, but the
benefits are not deemed as great as if recyclable materials can be extracted first. Two
440
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key reports highlight the importance of increased innovation in this type of technology
to meet the high recycling / recovery rate of 95% by 2015 (See Section 23.7). 513514
The benefits of recycling, over final disposal, of the waste materials arising from ELVs
can be summarised as:
441
� A reduction in GHG emissions associated with offsetting virgin materials and
avoided emissions from landfilling;
� Reduced pollution of the natural environment from hazardous substances
such as coolants and oils;
� A reduction in the marginal cost of recycling as infrastructure and efficiency
increases; and
� Reduced levels of abandoned vehicles and associated costs to the public
sector.
What factors can be used to measure the achievement of recycling rates? Firstly, it is
important to note that before a vehicle can be recycled it has to be legally scrapped.
Illegal dumping of vehicles is being reduced, in part, as a result of the use of
Certificates of Destruction (CoD) that make the last registered owner of a vehicle
responsible for it’s handling at the end of its life. However, the data regarding
scrapping rates in Europe is sparse and of low quality, and elsewhere non-existent.
The EU Directive is helping, in some respects, to provide better statistical data, but
reliable time series information is not yet available. It is likely that scrappage rates
are increasing, but it is not possible to directly relate this to the quantity of vehicles
that are actually recycled. 515 Compounding this are other factors that affect
scrappage rates such as; the average lifetime of a vehicle; vehicle sales; and the
import/export of ELVs for treatment.
To measure the success of the policies, one could use figures for the average
recycled, recovered and reused content of a vehicle. Average recycled content rates in
Japan are known to be high due to stricter targets, however, no data was found
relating to the changes in actual recycling rates over time.
The effect of the EU ELV Directive on recycling rates in Europe is unclear. In the most
up-to-date report on the Directives’ effectiveness it is concluded that although some
countries have obtained the targets early (mainly due to previous existing policies)
513 M. Fergusson and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
Economic and Scientific Policy,
http://www.europarl.europa.eu/comparl/envi/pdf/externalexpertise/end_of_life_vehicles.pdf
514 GHK and Bio Intelligence Service (2006) A study to examine the benefits of the End of Life Vehicles
Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and recovery
under the ELV Directive, Final Report to DG Environment, May 2006,
http://ec.europa.eu/environment/waste/pdf/study/final_report.pdf
515 Scrappage rates are the number of vehicles entering authorised treatment facilities out of the total
fleet in a country, per annum.
International Review of Waste Policy: Annexes

many are expected to fall short of the 2006 and 2015 targets. 516 A further restriction
to measuring recycling rates is that many Member States have not yet implemented
reliable reporting systems to allow correct measurement of how much of a vehicle is
recycled or reused. Thus at the moment there are no reliable indicators to measure
the performance of the ELV policies, but this will change as reporting increasing.
The cost of treating ELVs is closely linked to the price of recycled metals, because a
large proportion of the recycled material from ELVs will be ferrous or non-ferrous
metal, both of which are relatively easy to separate for reprocessing.
The recent collapse in the price of recycled metals is a situation that the ELV policies
were implemented to deal with. 517 In many European countries, if the costs of
recovery exceed the revenue generated from the sale of recyclates the differential is
funded by the vehicle producers, and in Japan, Sweden, and the Netherlands by the
levy on all new vehicle registrations. Consequently, the cost to the final owner of
discarding the vehicle remains zero and illegal dumping is avoided. If the value of
recovered materials remains low, producers will need to provides additional funds to
support the scheme, and this is likely to increase the cost of vehicles, at the margin.
Hence, consumers will likely pay some additional amount for the increased cost of
recycling ELVs.
GHK, and Bio Intelligence Service (2006) also concluded that the enforcement of
standards at ATFs increases the quality of depollution and quantity of recyclable
materials recovered from the vehicle body. Consequently this is a key element to
accruing the potential environmental benefits aimed for following the implementation
of the Directive. Therefore, some measure of poor performing states can be made in
relation to how many treatment facilities are operating illegally. For example, the
following list shows some indicative figures for the proportion of dismantling facilities
that operate illegally in several EU Member States:
442
� France – 40%
� Hungary – 80%
� Poland – 90%
23.6 Implementation Costs
There will be costs involved with preliminary compliance and also with annual charges
for the administration of the policy.
For example, in England the preliminary compliance cost assessment estimated the
cost of meeting the Directive as £360 to £520 million. This includes a cost to
516 M. Fergusson and IEEP (2006) End of Life Vehicles (ELV) Directive: An assessment of the current
state of implementation by member states, Report for The European Parliament: Policy Department
Economic and Scientific Policy,
http://www.europarl.europa.eu/comparl/envi/pdf/externalexpertise/end_of_life_vehicles.pdf
517 London Metal Exchange (2009) Steel & Non-Ferrous Metals Prices, Accessed 17 th January 2009,
http://www.lme.co.uk/home.asp
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Government in the form of additional running costs for the DVLA at £2 million to £7
million per annum. 518 This equates at around £1 - £4 per car currently scrapped in
the UK. An additional fund to cover the increase in abandoned vehicles was also
provided by the Department of Trade and Industry to help Local Authorities with
increasing clear up costs.
Costs in setting up trade associations and for applying standards for ATFs and
recovered materials can also imply further costs for a State implementing such
policies, as can the cost of providing adequate reporting systems so that recycling
targets can be measured, and developing administrative systems to manage CoD.
23.7 Effects on Technical Change / Innovation
The policies should drive manufacturers to design vehicles that are easier to recycle
and recovery materials from. However, GHK, and Bio Intelligence Service (2006)
conclude that, notwithstanding manufacturer’s legal obligation to design vehicles in a
way that they meet the recycling and recovery targets set out in the EU Directive,
there is limited evidence of any significant change in vehicle design. This could be
due to:
443
� Historic trends showing that vehicle construction materials are moving away
from ferrous metals to plastics (that are harder to recycle) so industry is taking
time to find novel ways to design new components with recyclability in mind; 519
� The marginal costs of recycling replacement components being high, due to
the labour costs involved in manual dismantling; or
� A greater level of R&D into post-shredder technologies being undertaken, thus
negating the need for further design improvements to the vehicles to meet
higher targets. Estimates are that new processes could generate capture rates
of up to 75% from the ASR. 520 This would allow for the 95% target to be met
with little extra being done above the current 80% baseline. Hence if this is a
more cost effective option than to redesign components to be easily recycled
at the dismantlers, producers may be relying on this technology to meet the
recycling and recovery targets.
As highlighted in Section 23.5.2, marginal recycling and recovery rates are potentially
only achievable if R&D is invested into post-shredder technologies (that can
mechanically sort recyclables from the residue) in order to make further recycling
cost-effective. All the main studies considered in this report indicate that the ELV
518 A. Doran (2003) Policy discussion by Andy Doran from LARAC, Accessed 15 th October 2008,
http://www.larac.org.uk/pdf/elvbrief.pdf
519 Waste Online (2004) End of life vehicle and tyre recycling information sheet, Accessed 15 th October
2008, http://www.wasteonline.org.uk/resources/InformationSheets/vehicle.htm
520 GHK and Bio Intelligence Service (2006) A study to examine the benefits of the End of Life Vehicles
Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and recovery
under the ELV Directive, Final Report to DG Environment, May 2006,
http://ec.europa.eu/environment/waste/pdf/study/final_report.pdf
International Review of Waste Policy: Annexes

policies are directly driving this R&D. GHK, and Bio Intelligence Service proposes that
Member States might consider banning ASR from landfill in order to further send a
signal to the industry and speed up R&D. 521
In the EU the ELV Directive includes a coding standards obligation whereby the
producers must, in concert with material and equipment manufacturers, use the
nomenclature of ISO component and material coding standards for the labeling and
identification of components and materials of vehicles, and in Korea, for example, a
Recycling Information Network has been set up to make it easier for dismantlers to
identify the parts of the vehicle that can be either reused or recycled.
This is most relevant to plastics that are difficult to separate due to the wide variety of
polymer types. Kvist also indicates that to achieve the high recycling rates designs
should be modified to include materials codings to ease identification of parts
(especially plastics) and to avoid risk substances. 522
GHK, and Bio Intelligence Service points out that there is a strong dialogue between
producers, dismantlers and automotive shedding facilities in relation to what
components or materials are causing issues in the recovery and shredding processes.
For example, some adhesives that affix textiles and plastic components to the vehicle
body cause problems when it comes to separating materials from the ASR. Therefore
tests are being performed as to what adhesive will meet the standards of the
producers, but also enable the highest capture rates of materials from the ASR.
Finally, in Sweden, where the population density is low, there were some problems
with illegal dumping because people were unwilling to transport their vehicles to an
ATF. So to continue to increase their recycling and recovery rates, mobile depollution
and dismantling units have been developed to travel around the country to capture
vehicles that may otherwise have been dumped.
23.8 Social and Distributional Consequences
There are not thought to be any distributional consequences as the Directive applies
to a wide range of vehicles. The policy may in fact help to alleviate distributional
issues where, without producer responsibility, the cost of disposal previously fell to
the final owner of vehicles – individuals who (by nature of owning lower priced cars)
might be expected to be less able to afford disposal fees, and hence were more likely
to abandon them illegally.
In addition, in many countries (including the UK) the incidence of car ownership is low
in the poorest sections of society. Hence, even if it was the case that some costs had
to be born by the final owners, the very poorest sectors of society might not be heavily
521 GHK and Bio Intelligence Service (2006) A study to examine the benefits of the End of Life Vehicles
Directive and the costs and benefits of a revision of the 2015 targets for recycling, re-use and recovery
under the ELV Directive, Final Report to DG Environment, May 2006,
http://ec.europa.eu/environment/waste/pdf/study/final_report.pdf
522 K. Kvist (2006) Car Recycling and Producer Responsibility – Sweden, Accessed 15 th October 2008,
http://www3.gov.ab.ca/env/waste/eprw/pubs/Karin_Kvist.pdf
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affected. In any event, the effect on new car prices is likely to be very limited in most
cases when considered as a proportion of total costs.
23.9 Complementary Policies
The following policies may all be considered to help deliver (or potentially deliver) the
objectives of ELV producer responsibility:
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� Producer responsibility policies – ELV policies tend to be a subset of more
general producer responsibility policy;
� Landfill Directive – For tyres;
� Landfill bans i.e. on ELVs or ASR;
� The Waste Incineration Directive – for setting limit values and other conditions
on co-incineration of waste tyres / ASR;
� EU Batteries Directive – batteries fall under the directive when they are
removed from the vehicles for reuse / reprocessing;
� Controlled Waste Act 1990 (tyres) – the recycling network for cars made the
recycling of tyres more cost effective;
� Vehicle Licensing – as stricter licensing will discourage people from
abandoning cars in the first place; and
� Vehicle Laws – in Asian countries these are in place to limit vehicle
abandonment etc.
23.10 Effect of the Policy on Pricing of Resources / Services
As discussed in Section 23.5.2, the price of new vehicles will go up in the long term
as producers pass the cost of managing ELVs through to the consumer.
At the margin, plastics are the next material to be focused on as current recycling
rates are low compared with those for metals. Therefore, the boost in investment for
automotive shredder and plastics recycling processes (see Section 23.7) could see a
fall in the marginal cost of treatment at these types of facilities, and also a reduction
in the price for recycled plastics as more material is available in the market.
23.11 Evasion and Enforcement
It is an offence to fail to comply with the law on the disposal of ELVs. Failure to comply
can results in fines or convictions resulting in custodial sentences.
There is no information regarding evasion and enforcement from the Asian countries.
The following points indicate some European examples:
� CoD were not needed in England if a tick box on the vehicle registration
document was marked indicating that the owner had scrapped the vehicle
themselves. This may have led to increased illegal activity so the DVLA is
considering whether this alternative means of notification should be
withdrawn;
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446
� Action has been taken against The Netherlands because of issues concerning
the definition of ‘treatment’ and the promotion of certified environmental
management systems in treatment plants; and
� In 2003, the European Court of Justice condemned the UK for non
transposition of the Directive by the time required (21 April 2002) and
condemned the UK government to pay the costs of judgment.
GHK, and Bio Intelligence Service (2006) concluded that neither the environmental or
economic benefits are fully realised because of the lack of full implementation and
enforcement of the Directive.
Some mitigation of illegal activities could be provided if the country implements an
‘own marque’ scheme. 523 It is believed that this responsibility will mean that vehicle
manufacturers will have more of a direct interest in their own vehicles, from, as it
were, ‘cradle to grave’, and thus will have an incentive to minimise the likelihood of
their vehicles ending up being used illegally, where they can exercise some control
over this. However, in the UK, for example, producers may discharge their obligations
by contracting with authorised treatment facilities (ATFs) or by entering into
arrangements with the motor insurance industry and/or vehicle salvage operators
directly. Hence, no strong evidence exists to support the argument either way.
Additionally, the European Union Network for the Implementation and Enforcement of
Environmental Law (IMPEL) is concerned about the level of illegal shipments of ELVs.
Czararnomski et al note that some enforcement issues have arisen because of the
disparity in definitions between ‘waste’ and ‘second hand goods’. 524 Furthermore, a
final conclusion is that the ELV directive has had the likely effect of increasing illegal
exports, particularly to Africa and Eastern Europe. To further clarify these issues a
paper is being prepared by Ireland with the aim to carry out a threat assessment on
the Transfrontier Shipment of waste (TFS) from the European Union. This study was
still included on IMPEL’s 2008 work programme, so it is not thought that it has been
published to date.
23.12 Lessons Learned
As an EU Member State Ireland is obligated to meet the requirements and targets set
out in the ELV Directive. The following points highlight the main issues that could be
useful to a country aiming to both meet these targets on time, and improve
environmental performance from the treatment of their ELVs:
� Effective Effective phase phase out out of of heavy heavy metals: metals: The phase out of heavy metals has been
effective due to the clear signal given to the industry that this was going to
523 DTI (2005) Full Regulatory Impact Assessment (RIA) for the Department of Trade and Industry’s
Statutory Instrument, The End of Life Vehicles (Producer responsibility) Regulations 2005, Transposing
Articles 5 and 7 of Directive 2000/53/EC1 of the European Parliament and of the Council on End of
Life Vehicles in the UK, Report for DTI.
524 S. Czararnomski, A. Holmes and B. Webb (2006) IMPEL_TFS THREAT ASSESSMENT PROJECT: The
Illegal Shipment of Waste Among IMPEL Member States, Project Report for IMPEL.
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447
happen and because a reasonable amount of time was provided to allow
vehicle producers to comply;
� Potential Potential for for phase phase out out of of other other materials: materials: materials: Further phase out of additional
materials (such as certain plastics that are difficult to recycle) could therefore
be effective based on this evidence if a clear signal and adequate time was
given for producers to comply;
� Regulation Regulation Regulation of of of all all all dismantling dismantling dismantling operations operations operations is is is crucial: crucial: crucial: The prevention of
hazardous wastes, such as coolants and oils, from entering the environment is
also a key result of the policy, and is maintained by the strict depollution
regulations. However, these regulations are only enforced at authorised
treatment facilities (ATFs). Hence the regulation and control of any dismantling
operation is a key element to maintaining environmental performance;
� Control Control of of ATFs ATFs increases increases efficiency: efficiency: efficiency: The control over ATFs has been shown to
promote efficiency and therefore increase the average recycled content of the
ELVs being processed. Therefore, this is also a key element to obtaining high
recycling and recovery rates;
� Presence Presence of of industry industry associations associations supports supports the the ELV ELV treatment treatment system: system:
In all
the countries where the policies have had the most success, such as Japan,
Sweden and the Netherlands, there are industry associations governing the
operation of the ATFs, managing free take back of ELVs and liaising with
vehicle producers. The emergence of associations can be related to the size of
the vehicle producing industry in that country. Conversely, in countries such as
Hungary and Poland, where there are still many illegally operating facilities and
the overall recycling rates are low, there are no significant industry
associations. Thus an important aspect of any successful ELV reprocessing
system is a well engaged industry association willing to take on some
responsibility and promote best practice; and
� Use Use of of mechanical mechanical separation separation separation technologies technologies to to recover recover material material from from ASR ASR is
is
considered considered the the most most cost cost effective effective way way to to meet meet future future recycling recycling and and recov recovery recov recovery
ery
targets: targets: Countries such as Japan, Korea, Sweden, Switzerland and the
Netherlands are all finding that the marginal cost of recovery from manual
dismantling increases sharply after a baseline of 80% to 85% is achieved.
Little headway has been made by manufacturers in designing components to
be easily dismantled and recycled. Thus investment is being made in postshredder
technologies whereby additional mechanical sorting of the
automotive shredder residue (ASR) is made to recover a greater range of
materials (general consensus is that mechanical sorting of the ASR is more
beneficial than energy recovery in terms of environmental performance and
the attainment of recycling and recovery rates). Investment in this type of
technology should therefore be promoted, whether it is through direct grants
from government or the EC, or by implementing regulatory drivers such as a
ban on landfilling of ASR. Furthermore, a strong link between the technology
providers / operators and vehicle manufactures is recommended to optimise
the whole system.
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24.0 Producer Responsibility, Batteries - Ireland
24.1 Outline of Policy
Ireland’s Waste Management (Batteries and Accumulators) Regulations (S.I No. 268
of 2008) transposes the EU Directive 2006/66/EU on waste batteries into national
legislation. The EU Directive aims to minimise the negative impact of waste batteries
and accumulators on the environment, and to harmonise the heavy metal content
and labelling of batteries and accumulators across the European market.
The EU Directive aims to recycle 25% of portable batteries by 2012 with a target of
45% of all waste batteries to be recycled by 2016. WEEE (Waste Electrical and
Electronic Equipment) Ireland, the authorised compliance scheme for electronic and
battery recycling in Ireland, is currently rolling out its battery recycling programme
which will see 50,000 waste battery drop-off boxes being delivered to 10,000 retail
outlets throughout the country.
According to the Batteries Directive there are three distinct battery classifications –
industrial, automotive and portable (usually defined as sealed and hand carried).
Whilst it is clear to which sector of the economy industrial batteries belong, portable
batteries are used across consumer, commercial and industrial sectors (though the
vast majority are used in consumer applications). Automotive batteries also straddle
all three sectors.
As noted in the Directive, “batteries” is used to mean single-life batteries (sometimes
also referred to as ‘primary’ batteries), and “accumulators” to mean rechargeable
batteries (sometimes also referred to as ‘secondary’ batteries). In this report
“batteries” is taken to mean both batteries and accumulators, unless otherwise
specified.
It is estimated that in addition to automotive batteries, which are mostly recycled,
around 2,000 tonnes of portable batteries are sold in Ireland each year with the vast
majority being discarded as residual waste instead of being recycled due their small
size. 525 The regulations provide for the free take-back of all waste batteries and
accumulators, otherwise known as rechargeable batteries, in-store and at designated
locations.
Taken with the continued implementation of the WEEE and RoHS Directives,
transposition of the new Batteries Directive will complete a comprehensive corpus of
EU and national legislation for the EEE (Electrical and Electronic Equipment) sector.
The Directive will facilitate the effective environmental management of waste
batteries.
525 WEEE Ireland, News Release, 13 th August 2008, “Countdown Underway to New Battery Recycling
Scheme”.
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24.2 Policy Context and Reason for Introduction
The Batteries Directive is a Producer Responsibility Initiative (similar to WEEE, RoHS,
packaging, end of life vehicles and tyres) whereby the person who places the product
on the market has responsibility for financing the collection, storage, recycling and
treatment of the product when it becomes waste.
Any person who supplies batteries to the Irish market, whether as retailers, importers
or manufacturers has obligations.
For example:
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� Retailers must now take back waste batteries free of charge of the type that
they sell – for instance, if one sells portable batteries such as types AAA, AA,
Cell C, Cell D, or PP3. Retailers who only see portable batteries one will not be
obliged to take back automotive, industrial or small sealed lead acid batteries
for alarms;
� Retailers of automotive and industrial batteries must register with their local
authority; and
� Retailers may deposit waste portable batteries free of charge at local authority
civic amenity facilities. 526
Consumers should not throw waste batteries into the household waste or recycling
bin, but avail of the free recycling that will be available at all retail outlets that supply
batteries, and at civic amenity sites. 527
Automotive and industrial batteries are much more homogenous in composition than
portable batteries, nearly all consisting of lead acid batteries. Due to the high
proportion of lead in these batteries and the inherent value of this material recycling
of these battery categories is common practice and as such collection rates are
already very high (in excess of 90%).
While lead prices are subject to fluctuations, the collection infrastructure for these
batteries is well established and as such the main emphasis of the Directive is to
increase the number of portable batteries collected for recycling.
24.3 When was the Policy Introduced?
The Directive was implemented in full in Ireland on the 26 th September 2008 – the
deadline required to transpose the Directive into national law.
526 DoEHLG (2008) Waste Batteries and the Retailer,
www.environ.ie/en/Environment/Waste/ProducerResponsibilityObiligation/Batteries
527 EPA (2008) Waste Batteries and Accumulators, www.epa.ie/whatwedo/resource/battery/
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24.4 Key Organisations Involved in Implementation and
Management
The WEEE Register Society Ltd was set up as a national producer registration body to
assist producers in meeting their obligations for the responsible management of
WEEE. It will also handle this function in relation to the Batteries Directive. The
registration system operated by WEEE Register is self-financing with the necessary
funding coming from the obligated producers. 528 The WEEE Register has a duty to
notify the EPA of any non-compliance.
WEEE Ireland and ERP Ireland are the two approved national compliance schemes
which collect waste batteries for recycling on behalf of their members and reports on
this process to the regulatory bodies. The two companies operate in distinct
geographical areas as follows:
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� ERP Ireland, collect in the functional areas of Limerick City Council and Cavan,
Clare, Fingal, Kerry, Limerick, Meath and Monaghan County Councils; and
� WEEE Ireland, collect in the functional areas of all the remaining local
authorities.
The Environmental Protection Agency (EPA) and local authorities have enforcement
roles under the legislation. In general terms, the EPA is responsible for enforcing
producer obligations and local authorities for distributor obligations. The EPA will be
empowered to order the withdrawal and recall of non-compliant batteries from the
market and seek an injunction against a person failing to comply with a direction to
withdraw or recall non-compliant batteries, in lieu of instigating summary
proceedings. An appeals mechanism will, however, be available to effected
producers.
24.5 Monitoring and Measurement Techniques Applied
No evaluation of policy has been carried out since the recent introduction of the
Batteries Directive in Ireland. The WEEE Register oversees the ‘WEEE Blackbox’ – an
information gathering service whose role includes:
• Receipt and processing of data on market share from registered producers
(per weight, chemistry, category and subcategory);
• Determination of market share based on battery type and producer; and
• Providing management reports for WEEE Register.
Information is submitted to the ‘WEEE Blackbox’ on a monthly basis and began in
February 2009. The purpose of the data input is to determine the financial liability by
market share of individual producers. No information has been made public at the
528 Waste Management (Batteries and Accumulators) Regulations 2008 (S.I. No. 268 of 2008)
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time of writing, though it is understood that an annual review/report of the scheme
will be publicly available.
24.6 Evaluation Studies Available
No evaluation of policy in Ireland has been carried out since the introduction of the
Batteries Directive on the 26 th September 2008. 529 Previous studies were carried out
in order to calculate waste arisings – all battery producers, through their
representative associations, were requested to provide data on the quantities of
batteries placed on the market in Ireland. The quantities reported as being placed on
the market are shown in Table 24-1.
Table 24-1: Quantities of Batteries Placed on the Market
Type Type
Weight Weight (Tonnes)
(Tonnes)
Portable Batteries and Button Cells excluding NiCd 685
Portable NiCd Batteries 4
Lead Acid Automotive and Industrial 8,410
Total Total
9,099
9,099
Source: DoEHLG, RIA Report, 2008
Based on this limited information provided by producers, and the achievement of the
Directive collection rate targets (including incremental progress leading up to and
following the achievement of those estimated targets) quantities of portable batteries
diverted from final disposal would need to be as shown in Table 24-2.
Note that some producers failed to submit information citing reasons of commercial
confidentiality. Therefore quantities, particularly of portable batteries, placed on the
market are believed to be understated.
The UK’s Department of Environment, Food, and Rural Affairs (DEFRA) commissioned
a report in 2008 into life-cycle assessment for separately collecting and recycling
portable batteries in the UK according to the requirements of the new Batteries
Directive. In this study it is estimated that 24,850 tonnes of portable batteries were
placed on the UK market in 2003. The population in the UK in 2003 was 59.55
million. 530 In Ireland the population in 2003 was 3.98 million. Due to similarities in
the Irish and UK markets extrapolation is a reasonable method of calculating the
quantities of batteries placed on the market. Such an extrapolation would suggest
1,660 tonnes of portable batteries were placed on the Irish market in 2003.
529 A telephone conversation with a member of ERP, indicated that monitoring of recycling targets for
batteries will commence in February 2009. Report will be updated as soon as information is made
available.
530 DoEHLG (2008) “Waste Management (Batteries & Accumulators) Regulations 2008 (S.I No.268 of
2008), Screening Regulatory Impact Analysis”.
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Producers of portable batteries are required to achieve collection rates of 25% (415
tonnes) by 26 September 2012 and 45% (747 tonnes) by 26 September 2016.
Table 24-2: Quantities of Portable Batteries Requiring Diversion from Final Disposal
According to Producers
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Date Date
Collection Collection Rate
Rate
Tonnes Tonnes Diverted Diverted from from from Final
Disposal
Disposal
2009 10% 69
2010 15% 103
2011 20% 138
2012 25% 172
2013 30% 207
2014 35% 241
2015 40% 275
2016 45% 310
2017 50% 344
2018 55% 379
Source: DoEHLG, RIA Report, 2008
This estimate extrapolated from the 2008 DEFRA report would suggest that contrary
to the figures quoted in Table 24-2, the quantities of portable batteries requiring
diversion from final disposal could in fact be as high as the figures shown in Table
24-3. Unfortunately no reliable baseline information exists for the portable battery
collection rate prior to the introduction of the Directive, but given the limited collection
infrastructure at that time this is believed to be less than 1%.
Table 24-3: Quantities of Portable Batteries Requiring Diversion from Final Disposal
According to Extrapolation from UK Arisings Figures
Date Date
Collection Collection Rate
Rate
Tonnes Tonnes Diverted Diverted from from from Final
Disposal
Disposal
2009 10% 166
2010 15% 249
2011 20% 332
2012 25% 415
2013 30% 498
2014 35% 581
2015 40% 664
2016 45% 747
2017 50% 830
2018 55% 913
Source: DoEHLG, RIA Report, 2008

24.7 Environmental Benefits
The Batteries Directive aims to minimise the negative impact of waste batteries and
accumulators on the environment, and to harmonise the heavy metal content and
labelling of batteries and accumulators across the European market.
Most batteries contain heavy metals (mercury, cadmium, lead), which are the main
cause for environmental concern. If waste batteries are not disposed of correctly,
heavy metals may leak when the battery corrodes, and so contribute to soil and water
pollution and endanger wildlife. The main environmental objective is to create a
closed-loop system for all batteries to avoid their incineration or disposal in a landfill
(Section 25.5 explores in more detail the environmental benefits of the Directive).
24.8 Implementation Costs
Producers will be required to finance any net costs arising from the collection,
storage, treatment and recovery and/or disposal of waste batteries including those
incorporated into EEE and/or battery packs, any public information campaign on the
collection, storage, treatment and recovery and/or disposal of portable batteries.
Each producer shall be required to collect, as a minimum, no later than 26
September 2012, 25%, and 26 September 2016, 45% of the quantity by type of
portable battery he or she places on the market. 531
Reliable data is not available to accurately estimate the full cost implications of the
new scheme in Ireland. Based on the limited information provided by producers
regarding quantities placed on the market it is estimated that at the very least annual
producer costs for the environmentally sound management of waste portable
batteries would be the lower range shown in Table 24-4.
Based on the extrapolated data from the DEFRA report referenced in section 24.6
and information provided by local authorities concerning costs incurred in having
waste batteries deposited at civic amenity sites collected, an upper range (and
perhaps more realistic) is also shown in Table 24-4. It should be noted that the cost
per tonne for both these scenarios is estimated at €1,710.
Local authorities have indicated that the costs associated with managing waste
batteries deposited at civic amenity sites are minimal. It is also believed that any
additional costs related to enforcing the Regulations would be small given the
synergies with the existing WEEE requirements. The wide variation in the estimated
costs reflects the paucity of reliable information on which to base an accurate
estimation.
531 Waste Management (Batteries and Accumulators) Regulations 2008 (S.I. No. 268 of 2008)
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Table 24-4 Estimated Producer Costs for Waste Battery Disposal
454
12 12 Months Months End End 25
25
September
September
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Collection Collection Collection Rate Rate
Annual Annual Cost
Cost
2009 10% € 117,765 – 283,913
2010 15% € 176,648 – 425,870
2011 20% € 235,531 – 567,826
2012 25% € 294,413 – 709,783
2013 30% € 353,296 – 851,739
2014 35% € 412,178 – 993,696
2015 40% € 471,061 – 1,135,653
2016 45% € 529,944 – 1,277,609
2017 50% € 588,826 – 1,419,566
2018 55% € 647,709 – 1,561,522
Source: DoEHLG, RIA Report, 2008
24.9 Response from Public and Industry
In order to minimise the impact implementation of the Directive will have on
businesses, the Regulations specifically provide for:
� An exemption for retailers from having to have a valid waste collection permit
and valid waste permit;
� Permitting EEE and battery retailers to use composite point of sale / display
signage;
� Producers having the option to establish and maintain their own registration
system; and
� The removal of the burden for individual compliance by permitting producers
to participate in collective compliance schemes.
It is too early to gauge the strength of response from the public and no data is
available as at the time of writing to evaluate performance. It is clear that such an
evaluation will be made more difficult by the lack of quality data regarding the
baseline tonnages of batteries in the market.
24.10 Effects on Technical Change / Innovation
Any innovation on the battery industry, whether linked to evolving battery chemistry
composition or sorting/reprocessing improvements will not be isolated to any
Member State. These technology changes are happening in a global context and are
discussed in Section 25.8.

24.11 Social and Distributional Consequences
The right to free take-back of waste batteries will apply equally to people living in
urban and rural communities. When fully operational, the waste battery recovery
scheme will provide a network of authorised collection facilities spread throughout
the country, thereby providing local access to waste battery take back arrangements.
Members of the public may continue to avail of the free take-back service provided at
Civic Amenity sites. Schools and workplaces may also continue to provide free
convenient collection points for students/employees, but the premises must be
designated by their Local Authority in order to continue providing the collection point.
The changes required as a result the Directive are likely to lead to employment
opportunities of a broad range (from manual to highly skilled) in Ireland. The possible
impacts at the EU level are discussed in Section 25.9.
24.12 Complementary Policies
These are principally other EU Directives and are discussed in section 25.10.
24.13 Effect of the Policy on Pricing of Resources / Services
Due to the only recent transposition of the Directive, it is as yet unknown if an
increase in battery prices will follow as a consequence of the additional financial
commitments on producers.
24.14 Evasion and Enforcement
The EPA and local authorities have enforcement roles under the Batteries Directive.
In general terms, the EPA is responsible for enforcing producer obligations and local
authorities for distributor obligations. As with other directives of this kind the
enforcement agencies tend to take a ‘light-touch’ approach (i.e. raising awareness
rather than using the full-force of the law) during an initial period as those affected by
the regulations become familiar. This position then tends to gradually tighten as
genuine evasion becomes apparent.
24.15 Lessons Learned
Ireland has opted to follow the lead of other Member States who have been able to
deliver high collection rates via a network of collection points (see section 25.6). The
provision of collection points in Ireland is one per every 400 inhabitants, which is
equal to that in top performing countries such as Belgium and Germany indicating a
high level of scheme convenience for the public. 532
Whilst level of service is undoubtedly a key factor in the success of any collection
scheme it is critical the public at large is aware of such services and how to use them.
Given the extremely low starting level of portable battery collection rates in Ireland it
532 Based on 10,000 retailer take-back serving a population of 4 million inhabitants.
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is only to be expected that significant resources will need to be put into an extensive
education and communications campaign that is capable of fundamentally changing
attitudes and behaviour, and that achieving such change may take considerable time.
Evidence is not yet available to indicate whether Ireland is on course to meet its
collection obligations under the Directive. If Ireland’s collection rates remain low in a
scenario of high publicity, it may have to reconsider the ‘one-size-fits-all’ approach of
retailer take-back and consider other collection methods (possibly in specific
geographical areas such as rural communities). These alternatives are discussed in
Section 25.6.
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25.0 Producer Responsibility, Batteries -
International
25.1 Outline of Policy
The foremost piece of international producer responsibility legislation affecting the
waste prevention of batteries is the EU Batteries and Accumulators and Waste
Batteries and Accumulators Directive (2006/66/EC) (hereafter “the Batteries
Directive”). Batteries, along with three other waste streams subject to EC producer
responsibility directives (Packaging, WEEE and ELV), were identified in the EU’s Fifth
Environment Action Programme as a “priority waste stream” due to increasing
concern of the adverse impact of battery waste on the environment. Sustainability is
therefore at the heart of such policies.
Whilst this Directive incorporates elements that could be considered as separate
policies (i.e. outright ban on sending certain types of batteries to landfill or
incineration), the Batteries Directive is principally concerned with producer
responsibility. It should, however, be noted that there are other countries with
producer responsibility policies for batteries, notably Canada, USA, Brazil, Japan and
South Korea and many others are also in the process of considering such legislation.
25.1.1 EU Policy
According to the Batteries Directive there are three distinct battery classifications –
industrial, automotive and portable (usually defined as sealed and hand carried).
Whilst it is clear to which sector of the economy industrial batteries belong, portable
batteries are used across consumer, commercial and industrial sectors (though the
vast majority are used in consumer applications). Automotive batteries also straddle
all three sectors.
As noted in the Directive, “batteries” is used to mean single-life batteries (sometimes
also referred to as ‘primary’ batteries), and “accumulators” to mean rechargeable
batteries (sometimes also referred to as ‘secondary’ batteries). In this report
“batteries” is taken to mean both batteries and accumulators, unless otherwise
specified.
The intended impact of the Batteries Directive is to improve the environmental
performance of batteries and of the activities of all economic operators involved in
the life cycle of batteries.
Key provisions of the Directive are:
457
� Restrictions on the use of mercury (0.0005%) and cadmium (0.002%) in all
batteries by weight (with the exception of button cells at 2%);
� Labelling requirements for new batteries to aid consumer choice and recycling;
� A 25% collection rate for waste portable batteries to be met by September
2012, rising to 45% by September 2016;
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458
� A prohibition on the disposal by landfill or incineration of waste industrial and
automotive batteries – in effect setting a 100% collection and recycling target;
� The introduction of “producer responsibility” obligations;
� The setting of recycling efficiencies to ensure that a high proportion of the
weight of waste batteries is recycled (65% of lead acid batteries, 75% of
nickel-cadmium batteries and 50% of other waste batteries); and
� The setting of waste battery treatment standards.
Member State implementation of the Directive reflects these objectives. The
implementation of the Batteries Directive is broadly similar across Member States,
with mercury and cadmium limits being universal, alongside producer responsibility
policies to cover the costs of campaigns to inform the public, and to implement, the
new arrangements. Producer responsibility requires (article 8 of the Batteries
Directive):
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“distributors to take back waste portable batteries or accumulators at no
charge when supplying portable batteries or accumulators, unless an
assessment shows that alternative existing schemes are at least as effective
in attaining the environmental aims of this Directive. Member States shall
make public such assessments”.
It should be emphasised that the Battery Directive leaves considerable freedom to
the Member States and their national legislation with respect to the organisation of
collection systems. It only specifies that batteries can be collected (1) individually (2)
by way of national battery collection schemes or (3) together with the WEEE collection
schemes. A similar freedom applies to the actual physical infrastructure that is used.
For instance, in Belgium, schools are used as collection points, while in some other
countries this is forbidden. 533 (See Section 15.3.3).
Provided that the objectives set out in this Directive are achieved, Member States
may transpose the provisions on producer responsibility by means of voluntary
agreements between the competent authorities and economic operators concerned.
Article 27 stipulates the requirements these voluntary agreements should meet the
following conditions:
� They shall be enforceable;
� They must specify objectives with corresponding deadlines;
� They must be published in the national official journal and transmitted to the
Commission;
� The results achieved must be monitored regularly, and reported to the
competent authorities and the Commission, and made available to the public
under the conditions set out in the agreement;
533 Arcadis/Eunomia (2008) Optimising Markets for Recycling, Final Report to DG Environment,
European Commission.

459
� The competent authorities shall ensure that the progress made under such
agreements is examined; and
� In cases of non-compliance with the agreements, Member States shall
implement the relevant provisions of this Directive by legislative, regulatory or
administrative measures.
25.1.2 Non-EU Countries
In North America policy has tended to focus on voluntary programmes and outright
bans, while South America and parts of Asia have developed policy more in line with
the EU. These other non-EU countries are described in more detail in the sections that
follow, though little market information is available.
25.2 Where Has the Policy Been Applied and Why?
As mentioned above, producer responsibility policies covering batteries are in place in
the EU and further afield.
25.2.1 Europe
Like other European compliance directives of this kind, the Batteries Directive serves
the dual purpose of promoting better quality of life through a cleaner environment,
while improving the European economy by standardizing technical manufacturing and
marketing practices among European member states. Producer responsibility policies
have been required for batteries because the levels of hazardous materials contained
within them have historically been substantial.
In landfills heavy metals such as mercury, cadmium and lead have the potential to
leach into soil, groundwater or surface water and when incinerated, some heavy
metals such as mercury may vaporise and escape into the air, while cadmium and
lead may typically remain in bottom ash. It is estimated that in 2002 46% of portable
batteries sold in the EU 15 that year were disposed of in landfill or incinerated. 534
Cadmium is a toxic and carcinogenic substance. The International Agency for
Research on Cancer has identified cadmium as a known human carcinogen. Mercury
is known for a variety of documented, significant adverse impacts on human health
and the environment. Mercury and its compounds are highly toxic, especially to the
developing nervous system. The Swedish Government has recently announced that it
will introduce a blanket ban on mercury, meaning that no products containing
mercury may be placed on the Swedish market from June 2009. Lead is toxic to
humans above certain concentrations and continued or acute over exposure can
cause severe and cumulative health problems. 535
534 Bio Intelligence Service (2003) Impact Assessment on Selected Policy Options for Revision of the
Battery Directive, Final Report for EC, July 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
535 EC (2003) Directive of the European Parliament and of the Council on Batteries and Accumulators
and Spent Batteries and Accumulators – Extended Impact Assessment, Commission Staff Working
International Review of Waste Policy: Annexes

Cadmium was, until recently, a component of one of the most widely used
rechargeable batteries and according to the Commission proposal itself, 75% of the
2,638 tonnes cadmium used in the EU-15 are incorporated in batteries and
accumulators. Of these 1,984 tons, between 75% and 80% are used in the
production of portable nickel-cadmium (NiCd) batteries. This corresponds to
quantities between 1,488 and 1,587 tonnes of cadmium.
The Batteries Directive (2006/66/EC) repeals Directive 91/157/EEC on Batteries
and Accumulators Containing Certain Dangerous Substances, which introduced a
limited range of environmental and product design requirements. The previous
Directive was somewhat weak because it only covered an estimated 7% of consumer
batteries on the EU market. In the words of the Commission the original Directive
“has not succeeded in controlling adequately the risks they [batteries] pose”. There
was also heavy resistance from industry and it was acknowledged that more research
on certain substances was needed before more complete regulations were issued.
When the Directive was revised to cover a wider range of batteries, all actors in the
waste management chain became involved, from producer to the consumer through
to collectors and reprocessors, rather than affecting product design with substance
bans that manufacturers claimed were unreasonable.
Consultations to revisions of the first battery Directive started in 1997, giving all
interested parties a voice in legislation and policy, especially in assessing the
directive’s economic, environmental and social impact.
The proposal for a new Batteries Directive was made by the European Commission on
24 November 2003, covering all batteries (for environmental and trade reasons).
Following negotiation, the new Directive was adopted on 6 September 2006 and
came into force on 26 September 2006.
All Member States were required to transpose the Directive into national law by 26
September 2008. At the time of writing only nine have made the transposition;
Austria, Estonia, Hungary, Ireland, Latvia, Malta, the Netherlands, Slovenia and Spain.
Three other Member States (Lithuania, Poland, Finland) have partially transposed the
Batteries Directive, and a warning from the EC that it will take infringement action
against member states if they do not “rapidly implement” the revised Batteries
Directive is likely to spur non-conforming countries into action.
Another principal driver for the policy is the sheer volume of battery waste that is
generated each year, the rate at which this has been growing in recent years and is
predicted to continue to grow. The European Commission’s Extended Impact
Assessment (COM(2003)723 final), (EIA)) which supported the proposal to introduce
the new Batteries Directive, estimated that the consumer battery market in Western
Europe 536 had grown by some 70%, in terms of units sold, between 1985 and
Paper, November 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/exten_impact_assessment.pdf
536 EU 15 plus Norway and Switzerland.
460
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1995. 537 This proliferation is principally explained by the rapid growth of widely
available, low cost consumer electrical goods, such as mobile phones, lap top
computers and MP3 players. It is estimated that in the EU well over 1 million tonnes
of batteries enter the market each year (Table 25-1). The global demand for batteries
is projected to grow by more than 5% annually over the coming years, with the
portable batteries market growing fastest. 538
Table 25-1: Tonnage estimation of batteries placed on the market in the EU in 2002
461
Battery Battery Type Type Type
Tonnage Tonnage placed placed on on market market in in 2002
2002
Portable 160,000
Automotive 800,000
Industrial 190,000
TOTAL TOTAL
1,150,000
1,150,000
Source: EC Press Release IP/03/1596 (2003), Batteries: Commission requires collection and
recycling of all batteries, November 2003.
The extent to which portable batteries are separately collected (and by extension,
waste prevented in terms of reduced amounts of hazardous materials to
landfill/incineration) varies widely across battery types and between Member States.
Differences between countries are explored more closely in section 25.2.2, but
generally speaking the collection rates of portable batteries are low across Member
States, while collection rates for industrial and automotive are considerably higher.
Automotive battery recycling has been taking place in Europe for a long time due to
the inherent value of lead, the principle material contained in these batteries. Until
very recently metal prices have been extremely buoyant, with lead no exception (see
Figure 25-1). As a consequence the economics have pushed collection rates
extremely high. For example in the UK, which is typical of other EU Member States
and beyond, collection rates are currently around 97%. 539 Given that approximately
98% of industrial batteries consist of lead-acid batteries, the situation is almost
identical. Nonetheless, lead prices are subject to fluctuations and as such the
economic incentive to collect and recycle these batteries could also fluctuate. Very
few Member States have taken specific measures to ensure a continued effective
collection of these batteries. In Italy and Germany there is a deposit scheme for
automotive batteries which would still guarantee their return. However, the actual
collection and recycling of those batteries is still largely dependent on the lead price.
537 Bio Intelligence Service (2003) Impact Assessment on Selected Policy Options for Revision of the
Battery Directive, Final Report for EC, July 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
538 Ibid.
539 Arcadis/Eunomia Report for the EC, Optimising Markets for Recycling, due to be published late
2008.
International Review of Waste Policy: Annexes

It should also be mentioned that a recent US Geological Survey study found lead acid
battery consumption has been under-reported in the US by 24%, reducing collection
rates to approximately 80%. 540
The extremely low collections rates of portable batteries in most Member States (for
example, around 3% in the UK at present, with the remainder disposed of in landfill or
incinerated) when compared to other battery types has meant that in practice the
Batteries Directive is fundamentally geared to address this particular issue. 541
Figure 25-1: Lead Price Graph 2003-2008 (US$ per tonne)
Source: London Metal Exchange http://www.lme.co.uk/lead_graphs.asp
25.2.2 EU Specific Characteristics
An important consideration is how developed existing (or baseline) battery
infrastructure is across Member States, as this will clearly have an impact on the
countries’ implementation of the Batteries Directive. Broadly speaking 3 categories of
countries can be distinguished: 542
462
� Countries where separate collection of portable batteries was well developed
before the implementation of the new Directive – Austria, Belgium, Finland,
the Netherlands, Germany and Sweden (45-85% of portable batteries
available for collection are estimated to be collected according to countries);
540 US Geological Survey (2006) Apparent Consumption vs. Total Consumption – A Lead-Acid Battery
Case Study, D.R. Wilburn and D.A. Buckingham, 2006.
http://pubs.usgs.gov/sir/2006/5155/sir20065155.pdf
541 Arcadis/Eunomia Report for the EC, Optimising Markets for Recycling, due to be published late
2008.
542 Bio Intelligence Service (2003) Impact Assessment on Selected Policy Options for Revision of the
Battery Directive, Final Report for EC, July 2003, p9.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
29/09/09

463
� Countries where separate collection of NiCd batteries was well developed –
Denmark and Norway (40-50% of spent NiCd batteries are collected).
� Countries where separate collection was not developed (0-15% of portable
batteries available for collection are estimated to be collected in these
countries).
25.2.3 Non-EU Countries
There are, however, countries outside the EU that adopted similar measures, and
these are evaluated in more detail in the following section.
25.2.3.1 North America
In the 1990s, as proposals were circulating in Europe to ban cadmium in batteries,
several states in the US, including Minnesota and New Jersey, enacted manufacturer
take-back requirements on NiCd rechargeable batteries. In 1994, as the state takeback
requirements were being phased in, a producer responsibility organisation
called the Rechargeable Battery Recycling Corporation (RBRC) was established by the
rechargeable battery industry in response to a report by the Environmental Protection
Agency that NiCd batteries were responsible for more than half the cadmium found in
the municipal waste stream. In 2001 the RBRC began to accept all rechargeable
batteries.
At the time, the scheme, the first industry-wide voluntary take-back programme in the
US and Canada, was hailed as a model of producer responsibility, though by 2000 it
was apparent that it was completely failing to meet the original targets it had set. The
RBRC anticipated collecting 14 million pounds of batteries per year by 2003, but by
2005 only 5 million pounds were being collected, highlighting the lack of clout of what
was a ‘weak’ voluntary system. 543
The US Congress did pass the Mercury-Containing and Rechargeable Battery Act in
1996 and for these regulated batteries, the act requires the following:
� Batteries must be easily removable from consumer products, to make it easier
to recover them for recycling;
� Battery labels must include the battery chemistry, the recycling symbol, and a
phrase indicating that the user must recycle or dispose of the battery properly;
� National uniformity in collection, storage, and transport of certain batteries;
and
� Phase out the use of certain mercury-containing batteries.
Following this, many states passed legislation prohibiting incineration and landfilling
of mercury-based and lead acid batteries.
543 http://www.rbrc.org/docs/ProgramOverview.pdf
International Review of Waste Policy: Annexes

25.2.3.2 South America
Perhaps surprisingly, Brazil has developed a very progressive position on battery
waste. The National Environment Council (Conselho National do Medio Ambiente -
CONAMA) has, in 2008, replaced the country’s 1999 rules on the environmental
management of batteries. There are considerable similarities to the European
Directive – limits on cadmium and mercury in batteries broadly mirror the EU
thresholds, manufacturers and importers are required to register with the Federal
Technical Registry of Potentially Polluting Activities, and labelling requirements are
comparable.
In addition, manufacturers and importers have to present the national environment
enforcement agency (IBAMA) with a report of the chemical composition of batteries
issued by a laboratory accredited by the national technical standards institute
(INMETRO). Furthermore, Article 17 of the Resolution says that IBAMA, “based on
proven and reasoned facts, may request, following its own criteria, sample lots of
batteries, of any kind, produced or imported for marketing in the country” for proof of
compliance with the heavy metal limits, utilizing labs that are a signatory of the
International Laboratory Accreditation Cooperation accords. The costs of such tests
are to be met by the manufacturer or importer.
In addition, under Article 3, all national manufacturers and importers of batteries
must present IBAMA with a waste management plan, defined as an “environmentally
adequate set of procedures for the discard, segregation, collection, transport, receipt,
storage, handling, recycling, reuse, treatment or final disposal”.
Going even further, under Article 19, manufacturers and importers of batteries
covered by the Resolution must conduct studies on substituting or further reducing
“potentially hazardous toxic substances” contained in their batteries.
Other countries in South America have taken steps to follow Brazil’s lead, namely
Columbia, Argentina, Paraguay.
25.2.3.3 Japan
Since the early 1980s Japan became aware of the environmental pollution impacts of
waste batteries in landfill and incineration. The use of mercury in manganese
batteries was stopped in 1991 and in the following year in alkaline batteries. This has
enabled significant reductions to be made in the amount of mercury used in batteries
sold in Japan.
At the same time Japan has established a comprehensive separate collection system
for batteries and associated recycling infrastructure. In fact, Japan imports mercury
containing wastes from several nearby countries including Thailand and the
Philippines. 544 Many municipal authorities now participate in the Liaison Meeting for
the Amalgamated Treatment of Waste Batteries.
544 Law for the Promotion of Effective Utilization of Resources
http://www.meti.go.jp/english/information/data/cReEffectLe.pdf
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This has been possible under a broader policy for the Law for Promotion of Effective
Utilisation of Resources which seeks to reduce the generation of waste and to
contribute to the protection of the environment. This law became effective from April
2001 with respect to batteries includes the following requirements:
465
� Collection of small secondary batteries;
� Recycling of small secondary batteries including recycling efficiency targets;
� Enlightenment and providing information for collection; and
� Acceptance of small secondary batteries collected through municipalities by
manufacturers under producer responsibility.
25.2.3.4 South Korea
In South Korea producer responsibility was extended to batteries (manganese,
alkaline manganese and Ni-MH) in 2008. This is in part to do with the memorandum
of understanding that Korea has signed with a number EU countries which promotes
cooperation in the area of environmental protection through the exchange of human
resources and information. As such, much of Korea’s environmental policy reflects
that of the EU. This also reflects the prominent role of South Korean manufacturers in
some EU markets, for example some WEEE categories.
25.3 Key Organisations Involved in Implementation and
Management
Typically national government environmental and business departments are
responsible for implementing such regulations, with environmental agencies usually
acting as the regulator. This process usually involves significant consultation with
industry and other affected parties.
Producer responsibility policies in the EU impose an obligation on producers,
depending on the amount they put on the market, which they can either discharge
themselves or through a collective scheme of some sort, generally known as
“compliance schemes”. This framework can be delivered by either a single scheme or
a number of schemes (multiple-schemes), both of which would be monitored by
regulators. In the UK multiple compliance schemes (around 40) set up to deal with
WEEE have led to complications in terms of reconciling the data between these
schemes and the regulator. Despite this the UK Government has opted to pursue a
multiple compliance scheme for batteries, stating that it “envisages that a marketdriven
system of this design will provide more flexibility for producers, giving them an
element of choice and potentially resulting in their incurring lower costs”. 545
Proponents of the single scheme claim that competition is possible via this route,
provided that a suitable tendering process is used.
545 http://www.letsrecycle.com/do/ecco.py/view_item?listid=37&listcatid=326&listitemid=10152
International Review of Waste Policy: Annexes

Retailers selling batteries would also be affected as in many Member States takeback
schemes are required at the point of sale. Municipalities are also involved in the
collection process, as of course are consumers.
25.4 Pre-implementation / Evaluation Studies Available
The EC commissioned a report entitled ‘Impact Assessment on Selected Policy
Options for Revision of the Battery Directive’. 546 The purpose of the study was to
perform an analysis of the economic, environmental and social impacts of different
battery policy options. This report led to a Commission Staff Working Paper
Environmental Impact Assessment. 547
Evaluations have also been carried out by industry. For example the European Battery
Recycling Association published a position paper on the economic and social aspects
of collection and recycling of batteries. 548
Similar studies have been carried out at a national level. For example in the UK the
Department for Environment, Food and Rural Affairs commissioned a study on life
cycle assessment of battery waste management. 549 Those countries which have
already established producer responsibility legislation for batteries routinely
undertake annual reviews of the mechanisms in place.
25.5 Environmental Benefits
25.5.1 Environmental Cost
In terms of attempting to attach a monetised cost to the environmental benefit of
recycling waste portable batteries, the UK study referenced above looked at the
environmental implications of increased levels of battery recycling in the UK. By
combining the performance of the best scenario, in terms of the avoided air
emissions per tonne of portable batteries recycled, with unit damage costs for air
pollutants from the Methodex database it is possible to derive a per tonne external
benefit for portable battery recycling (clearly, this is for a mix of such batteries). The
benefits are of the order €330 - €657 per tonne of batteries recycled. Clearly the
environmental benefits of reducing battery waste are potentially significant, and for
546 BIO Intelligence Service (2003) Impact Assessment on Selected Policy Options for Revision of the
Battery Directive, Final Report for EC, July 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
547 EC (2003) Directive of the European Parliament and of the Council on Batteries and Accumulators
and Spent Batteries and Accumulators – Extended Impact Assessment, Commission Staff Working
Paper, November 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/exten_impact_assessment.pdf
548 Economic and social aspects related to the collection and recycling of used general purpose
batteries, EBRA, September 2003. http://www.ebrarecycling.org/
549 Defra (2006) Battery Waste Management Life Cycle Assessment, Final report for publication,
October 2006. http://www.defra.gov.uk/environment/waste/topics/batteries/pdf/ermlcareport0610.pdf
466
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specific battery types, they might exceed the estimate made here (which, in any case,
majors on greenhouse gas and air pollution consequences – some of the effects are
likely to be in reduced hazards of disposal which are more difficult to capture in a
basic analysis).
The next section highlights some analyses which look at the general environmental
benefits of the removal of hazardous substances and increased recycling. Taking the
performance in terms of collection and recycling as a proxy for environmental
performance, we then review the factors which seem influential in driving
improvements in collection rates.
25.5.2 Environmental Consequences of Producer Responsibility for
Batteries
Several of the reports mentioned in previous sections have commented on the
environmental benefits of battery collections.
The Impact Assessment on Selected Policy Options for Revision of the Battery
Directive states the relatively obvious – that the establishment of separate collection
targets are expected to have positive consequences in terms of controls on the
hazardous substances contained within batteries and also in the use of recycled
rather than virgin materials (though these positive benefits may be partially offset by
the environmental impacts due to additional activities required to separate, collect
and recycle batteries). 550 It should be noted however that transport logistics are not,
usually, a decisive factor in determining impacts in environmental terms, especially,
as here, when the external benefits of recycling are potentially so high.
While a lack of LCA data meant that it was not possible to assess the overall
environmental balance of collecting and recycling all portable batteries, an
assessment of NiCd batteries showed that there would be environmental benefits 2.5
to 13 times higher than the baseline scenario. Whilst this is a wide range, since
cadmium batteries are classified as hazardous waste and its substitutes (Nickel-
Metal Hydride and Lithium chemistries) are not, one can conclude that the phasing
out of cadmium batteries would result in decreased environmental impacts in the
future.
The same study estimates the amount of metals which could be recovered from
portable batteries annually across the EU at 66,028 tonnes, the breakdown of which
is shown in Table 19-2. It should be noted that these figures are based on portable
battery sales information from 2002 and as such the levels of the hazardous
substance cadmium are relatively high. With the tight restrictions on the use of
cadmium put forward in the Directive, and the banning of NiCd batteries in all but a
few applications, there has been a significant reduction in the amount of cadmium
being used in portable battery production for the EU market in recent years. For
example, in Germany, from 2003 to 2007, the quantity in tonnage terms of NiCd
550 BIO Intelligence Service (2003).
467
International Review of Waste Policy: Annexes

atteries placed on the market fell by 64%. 551 This trend is likely to be followed
internationally due to the size of the European market relative to the global market.
In addition to the obvious benefit in reduction of cadmium use as a hazardous
material (see Section 25.2.1), research suggests that the replacement of NiCd
batteries by Nickel-Metal Hydride and Lithium batteries would result in decreased
negative environmental impacts. In the case of complete replacement of NiCd
batteries by these alternative chemistries, the lithosphere extraction indicator (LEI 552 )
would decrease by 31%. 553
In addition to the recoverable metals shown in Table 25-2, a range of substances
such as various acids, salts and plastics can be captured by the recovery process and
prevented from entering the waste stream.
As would be expected the use of these secondary metals in battery production in
place of virgin metals has environmental benefits as a result of reduced energy use
and pollution related to the mining of virgin natural resources. For example, using
recycled cadmium and nickel requires 46% and 75% less primary energy respectively,
compared with the mining and refining of virgin sources. 554 These figures are
particularly important in the context of primary metal production accounting for
approximately 10% of global C02 emissions.
Table 25-2: Annual Tonnages of Metals Recoverable in the EU
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Metal Metal
Recoverable Recoverable Quantity Quantity (tonnes/year)
(tonnes/year)
Manganese 20,000
Zinc 20,000
Iron 15,000
Lead 7,500
Nickel 2,000
Cadmium 1,500
Mercury 28
Source: EC (2003), Directive of the European Parliament and of the Council on Batteries and
Accumulators and Spent Batteries and Accumulators – Extended Impact Assessment, Commission
Staff Working Paper, November 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/exten_impact_assessment.pdf
551 Erfolgskontrolle GRS 2007.
552 Ratio of anthropogenic to natural metal flows and the significance of battery production related to
global metal mining.
553 C.J. Rydh, B. Svärd (2002) Impact on global metal flows arising from the use of portable
rechargeable batteries, The Science of the Total Environment, Vol. 302, No. 1-3.
554 C.J. Rydh, M. Karlström (2002) Life Cyle Inventory of Recycling Portable Nickel-Cadmium Batteries,
Resources, Conservation and Recycling.

For automotive and industrial batteries the higher the collection targets, the lower the
environmental damages due to transport (recycling benefits increase more than
transport negative impacts). The total environmental benefits of a ban on landfill for
automotive and industrial batteries are difficult to quantify since the heavy metal
content of leachate is difficult to predict on the basis of current knowledge.
Furthermore, as stated above, recycling rates for automotive batteries are already
high.
25.6 Collection Performance and Key Drivers
It is at this point interesting to consider the relative success of different approaches
to the collection of portable batteries.
Until recently one of the problems when comparing collection rates across different
countries has been the method of calculation for this indicator. Various collection rate
methodologies have been used, including as a percentage of sales, percentage of
spent batteries, and as a percentage of spent batteries available for collection. These
three different methodologies lead to quite different ‘collection rates’ and so it is
important to understand what is actually being reported by a particular country to
avoid misleading claims. Table 25-3 provides a summary of the leading portable
battery collectors in the EU, showing collection rates as a percentage of sales and so
all countries are benchmarked evenly.
Table 25-3: Leading EU Portable Battery Collection Performance in 2002
469
Country Country
Belgium Belgium
France France
Germany Germany Netherland Netherlands
Netherland
Association BEBAT SCRELEC GRS STIBAT
Starting Date 1996 2001 1998 1995
Collection System
Inhabitants per
Collection Point
Bring back –
different types
of collection
points
International Review of Waste Policy: Annexes
Bring back –
point of sale and
municipal
collection points
Bring back –
predominately
point of sale
Bring back
system with
small chemical
waste
500 2,000 - 2,500 410 1,500
Tonnes Collected 2,368 4,139 11,256 1,876
Collection Rate (% of
sales)
60% 16% 38% 32%
Grams/inhabitant/year 228 69 137 116
Source: BIO Intelligence Service (2003), Impact Assessment on Selected Policy Options for Revision of
the Battery Directive, Final Report for EC, July 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
Looking at Table 25-3 it can be seen that all countries have very similar collection
systems in place - consumer bring back collection points of various types. Whilst it is

not possible to evaluate different types of collection systems, there are some
interesting drivers of good performance represented here.
The collection rate in Belgium is significantly higher than in other countries. This
would seem in part to be explained by the relatively low number of inhabitants per
collection point which is an indicator of scheme convenience, which tends to lead to
higher participation (the Irish system is based upon similar high density approaches).
Germany has a very similar number of inhabitants per collection point and has the
second highest collection rate of the four countries in Table 25-3.
Other reasons contributing to Belgium’s success rate include the fact that the
national battery association BEBAT has been in place for some time (since 1996) and
that more money has been spent on publicity and communications than in any of the
other three countries. Linked to this is the fact that a unique way was being used
(though this has since been replicated in Italy and Denmark) in Belgium to finance
waste portable battery treatment. A 1996 law exempted batteries from what was
effectively an environmental tax (€0.50 + VAT per battery) if a return system was
established for the collecting and recycling of portable batteries. This exemption
required specific collection targets to be met (65% by 2004). Funding was met by a
€0.1239 + VAT per battery charge to be paid by the consumer (see Section 15.3.3).
This means that not only is the Belgian system is very well funded, but there are also
high statutory collection targets to meet.
A recent comprehensive portable battery collection trial in the UK 555 is worth
analysing because it compares a wide range of collection methods. The Waste and
Resources Action Programme (WRAP) sought to examine the most cost effective way
of collecting batteries to meet the targets under the forthcoming Directive. The trials
involved assessing a variety of collection methods including kerbside collection,
retailer banks, community drop-off and postal return. These trials ran from April 2005
to March 2008.
25.6.1.1 Kerbside Schemes
In the second year of the trial 12 kerbside collection trials were running across the
UK, servicing approximately 444,000 households in a mixture of high-rise, urban and
rural areas. Householders in the trial areas receive a dedicated collection container
for their batteries (either sealable bags or a small cardboard box). This was set out
with other kerbside materials on the appropriate day of collection (frequency of
collection varies from weekly to quarterly). There was a huge variation between the
tonnages collected per household across individual kerbside schemes due to the
different scheme features as well as the local characteristics of areas served. Overall,
the kerbside systems delivered 0.127kg per household in the second year of the
trials.
555 WRAP (2008) Household Battery Collection Trials: April 2005 – March 2008, Final Report,
November 2008. http://www.wrap.org.uk/downloads/Batteries_report_-_final.c6d1d62e.6153.pdf
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25.6.1.2 Retailer Take-back Schemes
This trial involved 33 major retail stores across three municipal areas serving
approximately 200,000 households. Battery containers were installed in participating
stores and shoppers can drop-off all their used portable batteries. During the second
year of the trial 0.043kg per household were collected.
25.6.1.3 Community Drop-off Schemes
In this scheme householders were able to deposit portable batteries in containers
located across the municipal area (on-street, public buildings, sport centres and local
shops). Again the trial ran across three municipal areas in the second year, serving a
total of 221,000 households. This resulted in 0.026kg per household being collected.
25.6.1.4 Postal Scheme
Targeted at rural areas this scheme supplied strong polythene pre-paid envelopes
into which unwanted batteries could be placed. 38,000 households were served by
the scheme, leading to 0.072kg per household being recovered.
25.6.1.5 Comparisons
Firstly it is worth highlighting that these trials were carried out in a near vacuum of
publicity and so tonnages collected are likely to be considerably higher when
combined with a well funded, coordinated promotion. It is therefore not so much the
actual figures that are of interest, but more the relative performance of these various
schemes.
From these results it can be seen that the kerbside schemes comfortably collected
the most batteries per household served, capturing almost twice the amount of the
postal scheme, three times more than the retailer take-back schemes and five times
more than the community drop-off schemes. This is likely to be attributable to the
convenience factor of a kerbside collection, which is already well developed in the UK
for a range of dry recyclables.
The postal scheme, perhaps surprisingly, was the next most successful. This may be
explained by the fact that all 38,000 households covered by the trial were sent prepaid
envelopes which, as well as scoring relatively highly in convenience terms, would
have also acted as prompt to householders.
The retailer take-back and community drop-off schemes collected the least portable
batteries in per household terms. It would appear that the public preferred to deposit
unwanted batteries at major retail outlets than community sites, despite a higher
number of collection banks per capita at the latter. It could be argued that these
schemes suffered more from a lack of direct engagement than the other schemes.
25.7 Implementation Costs
Indicative costs for collection and recycling across existing bring back collection
schemes are shown in Table 25-4. Whilst this data is slightly dated (2002), it does
show that the most significant costs involved are for the transport and recycling
element.
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In an attempt to add a higher degree of resolution to the broad cost ranges shown in
Table 25-4, the collection trials undertaken in the UK by WRAP can be examined. Due
to the very nature of these trial schemes, coverage in many places was only a few
thousand households, and thus, economies of scale were not achieved. WRAP was
also keen to be able to monitor individual scheme performance to allow a thorough
evaluation. This meant that a premium was paid for collection and reprocessing (the
WRAP report suggests a cost reduction in the order of 40-50% would be possible if
schemes were rolled out nationally). As for the tonnage performance already
discussed the trial costs per tonne shown should not be viewed as indicative of a
widespread national programme, but these costs are interesting from a relative
perspective.
Table 25-4: Cost Ranges for Existing Portable Battery Bring Back Collection Schemes
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29/09/09
Variable Variable Costs: Costs:
Euros/tonne Euros/tonne of of portable portable batteries batteries collected
collected
Collection points (equipment) 50-150
Collection (logistics) 250-550
Sorting 150-250
Transport and Recycling (excluding disposal) 400-900
Fixed Fixed Fixed Costs:
Costs:
Public Relations and communication 50-1,700
Administration 125-900
TOTAL TOTAL
1,115 1,115 – 3,765
3,765
Source: BIO Intelligence Service (2003), Impact Assessment on Selected Policy Options for Revision of
the Battery Directive, Final Report for EC, July 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
Table 25-5 shows that kerbside collections run by third sector organisations were the
most expensive of the WRAP collection trial schemes and more than four times more
expensive than municipal kerbside collection. WRAP suggest the reason for this
significant difference is due to the terms of existing contracts with collection
organisations that municipalities enjoy (i.e. some of these costs can be absorbed
within the existing working day so that the new costs are marginal ones rather then
being wholly additional).
This explanation is supported by a kerbside recycling collection company in the UK
(May Gurney) that collects portable batteries as part of its contracted services to
municipalities. Due to the relatively small amounts of portable batteries collected, the
net additional cost of collecting this material alongside a range of others is quite
negligible, whilst reprocessing costs are offset by the income the contractor receives
from reprocessors for automotive batteries also collected from the kerbside. The
extent of this cost offsetting is, of course, dependant on the state of market.

Table 25-5: Average Cost per Kilogramme of Portable Batteries Collected and
Recycled
Collection Collection Scheme
Kerbside
Kerbside
(Community)
(Community)
Kerbside
Kerbside
(Mu (Municipal) (Mu nicipal)
473
Total Total Cost Cost £ £
£
(ongoing (ongoing (ongoing and and and set
set
up) up)
up)
International Review of Waste Policy: Annexes
Tonnes Tonnes of
of
Batteries
Batteries
Collected
Collected
Average Average Cost Cost per
per
Tonne Tonne of of Batteries
Batteries
Collected Collected and
and
Recycled Recycled (£/tonne)
(£/tonne)
Estimated
Estimated
Cost Cost Cost ( (-45%) ( ( 45%)
for for National
National
Roll Roll-out Roll out
(£/tonne)
(£/tonne)
208,297 12.67 16,440 9,042
169,051 43.87 3,853 2,119
Retailer Retailer Take Take-back Take back 83,653 8.5 9,842 5,413
Community Community Community Drop-
Drop
off
off
55,210 5.74 9,618 5,290
Postal Postal
43,487 2.72 15,988 8,793
Postal scheme costs are almost as expensive as the community sector collections,
namely due to the significant costs associated with production and distribution of
robust envelopes and the pre-paid postage of returns.
The retailer take back and community drop-off costs are almost identical as the
schemes are very similar in nature. Relative to the other forms of collection, their
costs per tonne fall between municipal kerbside collections and community sector
kerbside / postal.
One area the UK can make further cost improvements to bring back portable battery
schemes is in the area of reverse-logistics, particularly from large retail outlets that
have substantial transport infrastructure in place. Not only will cost savings be made
but the environmental benefits associated with recycling waste batteries will increase
as collection rounds become more efficient, with shorter distances per pick up.
25.8 Effects on Technical Change / Innovation
Batteries can be divided into two families: primary and secondary. Primary batteries
are designed to be used only once, whereas secondary batteries are rechargeable.
Product innovation has led to significant battery advancements in recent years,
particularly in respect of lithium-ion batteries. These secondary batteries are
increasingly used in consumer electronics, replacing the more traditional chemistries
such as NiCd. Their principal advantage is an extremely high energy-to-weight ratio,
though they also experience little memory effect and a slow loss of charge when not
in use. As a result of these key attributes and environmental considerations, NiCd
batteries have more or less been consigned to history.
An even more recent development is the silver-zinc battery, which it has been claimed
will provide 40% more power than a lithium-ion battery of the same size. Those
developing this new rechargeable battery chemistry claim it will be 95% recyclable by

weight and contain no heavy metals or toxic chemicals (though silver is regulated as
hazardous waste by the US Environmental Protection Agency). It is expected that
silver-zinc batteries will start to be used in laptop computer manufacturing from mid-
2009.
In the developed world, manufacturers are producing more secondary batteries each
year relative to the number of primary batteries produced. For example, the National
Electrical Manufacturers Association has estimated that US demand for secondary
batteries is growing twice as fast as demand for single use batteries. 556 The
increased demand for personal consumer electronics is the principal cause of this
trend, rather than public awareness of environmental issues leading to switches
across battery types.
Industry has commented that improvements can be made to existing processing
technologies, and these will be driven by further research and development on the
back of the Directive efficiency targets, the greater volumes of batteries requiring
recycling, and increased competition. At times when the price of metals is high, this
will also tend to encourage a greater separation of materials and a drive for higher
levels of purity.
H J Enthoven & Sons, as the only lead acid battery reprocessor in the UK, noted, that
improvements in battery technology continue to lead to reduced battery weights, and
so this can be expected to have an impact on the growth rate of industrial battery
wastes, expressed in tonnage terms.
A number of Mechanical Biological Treatment (MBT) plants now exist across Europe
and this number is expecting to grow considerably in the future as Landfill Directive
targets become increasingly challenging. Some of these are being designed with pretreatment
specified in such a way (for example, using x-ray technology) that would
allow the batteries to be separated from the residual waste at an early stage in the
process.
25.9 Social and Distributional Consequences
Due to the current high collection rates across Europe for automotive and industrial
batteries there is unlikely to be any discernable price change in these battery types as
a result of the Directive.
Annual household expenditure on portable batteries is low (in the UK the average
household uses 21 portable batteries per annum) as a proportion of overall spending
so any producer responsibility costs reflected in pricing are unlikely to have an
adverse effect on low-income households in a significant way. 557 In Belgium
collection and recycling schemes are funded by a 0.1239 EUR + VAT per battery tax
charged to the consumer, a tax which has not caused social unrest. Supposing similar
usage figures to the UK, the suggestion is that a high collection rate scheme can
556 http://www.epa.gov/osw/partnerships/stewardship/products/batteries.htm
557 WRAP, Battery Facts & Figures
http://www.wrap.org.uk/local_authorities/batteries/battery_recycling_information/battery_facts_.html
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effectively be financed at a cost of around €2.5 per household per year. Few
households would be expected to notice this in their budgeting.
The increased level of regulation, the need for additional collection/recycling and the
research and development required to deliver altered/new battery chemistries is
likely to lead to a widening of employment opportunities. Bio Intelligence calculated
the potential job creation opportunities in the EU for different collection rates. These
are shown in Table 25-6.
Table 25-6: Estimation of Job Creation with Portable Battery Collection Rates across
the EU
Collection
Collection
Rate Rate (%
(%
annual
annual
sales)
sales)
Tonnes of
batteries
collected
(‘000s)
Total
Jobs
Created
475
10 10- 10
20%
20%
1,238-
1,444
20 20- 20
30%
30%
30 30- 30
40%
40%
International Review of Waste Policy: Annexes
40 40- 40
50%
50%
50 50- 50
60%
60%
60 60- 60
70%
70%
70 70- 70
80%
80%
80 80- 80
90%
90%
90 90- 90
100%
100%
25 41 58 74 91 107 125 140 157
2,063-
2,406
2,888-
3,369
3,713-
4,331
4,538-
5,294
5,363-
6,256
6,188-
7,219
7,013-
8,181
7,838-
9,144
Source: BIO Intelligence Service (2003), Impact Assessment on Selected Policy Options for Revision of
the Battery Directive, Final Report for EC, July 2003.
http://ec.europa.eu/environment/waste/batteries/pdf/eia_batteries_final.pdf
25.10 Complementary Policies
Directive (2002/96/EC) on Waste Electrical and Electronic Equipment (WEEE) has
been implemented with the purpose of, preventing WEEE, and in addition the re-use,
recycling and recovery of WEEE, thereby reducing the need for its disposal. As many
items of WEEE contain batteries, there are clearly policy inter-linkages. Indeed
clarifying responsibilities for WEEE producers who are also battery producers is one of
the key issues facing Member States as they implement the Battery Directive.
Directive 2002/95/EC on the Restriction of Hazardous Substances (RoHS) must also
be considered as a policy driver alongside producer responsibility for batteries in the
EU; the RoHS Directive aims to minimise the use of certain hazardous materials in
newly-produced EEE and to minimise the release of hazardous substances into the
environment by controlling the disposal route of older equipment at the end of its life.
Producers must provide evidence that the concentrations of hazardous materials are
below defined levels. The six key restricted substances are lead, cadmium, mercury,
hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl.
The Energy-Using Products (EuP) Directive 2005/32/EC, which came into force in
August 2007, provides a framework for the setting of eco-design requirements for any
group of products which use energy (including EEE). This directive seeks to make
energy efficiency improvements rather than having a direct focus on waste. However,
ensuing product designs which make energy efficiency improvements may also
extend the product’s life, thus contributing indirectly to the prevention of WEEE.

Directive 2000/53/EC on End of Life Vehicles (ELV) aims to reduce the amount of
waste from vehicles when they are finally scrapped. It also sets higher reuse, recycling
and recovery targets and limits the use of hazardous substances in both new vehicles
and replacement vehicle parts. This Directive therefore has a direct impact on the
automotive battery industry.
25.11 Effect of the Policy on Pricing of Resources / Services
The policy is intended to reflect the relative environmental performance in the price of
the product, e.g. secondary (recyclable) batteries will be cheaper. Higher cost will be
attached to the more polluting products.
Belgium has achieved high collection rates through a 1996 law that exempted
batteries from what was effectively an environmental tax (€0.50 + VAT per battery) if
a return system was established for the collecting and recycling of portable batteries.
Funding was met by a €0.1239 + VAT per battery charge to be paid by the consumer.
Whilst substitutes for portable NiCd batteries are developing rapidly (see section
25.8), these replacement chemistries are generally more expensive at the current
time. Some attempts have been made to estimate these additional costs, but given
the speed of technological advancement in this area it is inherently difficult to offer a
cost that is not either a broad range, or one that becomes outdated extremely quickly.
25.12 Evasion and Enforcement
Substantial enforcement will be required in order to create a level playing field for
battery manufacturers and reprocessors. There is concern within the industry of
illegal practice and this is likely to intensify as more players enter the market as
Member States strive for higher targets.
G&P Batteries, a battery collector and reprocessor in the UK, carried out research into
the mercury content of portable alkaline batteries found on the UK domestic market.
This analysis showed that a kilogram of European branded batteries fell well within
the proposed legal limits of cadmium and mercury levels, though astonishingly a
kilogram of batteries from the Far East revealed mercury levels of 255 ppm (The EU
Batteries Directive prohibits levels >5ppm), as well as elevated levels of cadmium
and benzene. These findings clearly show that for the Directive targets to be met, a
greater consideration may need to be given to the control of batteries imported from
countries where similar standards are not routinely applied.
If illegal practices are not squeezed out of the system, not only will there be
significant environmental risks, but the legitimate businesses will suffer as those
operating illegally will be able to undercut their prices. Illegal practice is also likely to
feedback to risk aversion from the market. National and international policing by
regulators is therefore crucial to the long-term viability of the industry.
25.13 Lessons Learned
Producer responsibility as a voluntary measure has had limited success as the
industry has protected its financial interests as far as possible. This has led to
compulsory measures that are now starting to bite in Europe and beyond.
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Collection methods in Europe have predominately focused on networks of bring back
systems that become increasingly beneficial in cost and environmental terms as
collection rates increase. Reprocessing costs for batteries remain high (with
significant variation according to chemistry), though these may fall as the collected
quantities grow in the face of statutory targets.
Whilst the UK is yet to make its intentions clear in terms of a national collection
infrastructure, experience there suggests that batteries can be efficiently collected as
additions to existing kerbside networks though this may depend upon the nature of
the collection system used. Consumer awareness of the issues around battery waste
is low throughout much of the world. This is the case despite the hazardous nature of
many batteries, which one might have expected to lead to a greater understanding of
the need to reduce and recycle. To overcome this knowledge gap, significant efforts
will need to be made on publicity material to the general public, as their involvement
will be crucial if battery collection targets are to be achieved.
25.14 Prerequisites for Introduction
Producer responsibility is now widely accepted as a vital part of moving towards a
green economy. For those countries who have introduced producer responsibility for
portable batteries, this has tended to come as a ‘second phase’ of products after the
initial establishment of the policy for packaging, WEEE and ELVs. This is not, however,
a prerequisite and the Battery Directive is likely to shift European states to perceive
batteries as a product requiring greater attention than, in many cases, they have
achieved hitherto.
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26.0 Producer Responsibility, Batteries - Germany
26.1 Outline of Policy
According to the Battery Decree (Batterieverordnung - BattV) all producers/importers
and retailers are obliged to collect free of charge used portable batteries and
accumulators of the kind they have sold. 558 Consumers are not allowed to dispose of
spent portable batteries in the residual waste and instead have to return them to
retailers selling batteries, other retail collection points or local municipality collection
points , e.g. town hall (Articles 5 and 15 BattV). Retailers have a duty to inform
consumers of the possibilities to return batteries to the retailer (Articles 12 and 15
BattV) and are required to take back used batteries regardless of whether these were
purchased in their store. The producers/importers have to organize the recycling, or if
not possible, the safe disposal of batteries. 559 The collection system has to guarantee
the following conditions:
478
� Be available to all manufacturers under the same terms and conditions;
� Collect all batteries, regardless of their type, brand or origin;
� Collect batteries free of charge from the collection points agreed with the
retailers or at the collection points provided by the municipalities, and proceed
with recycling or disposal;
� Provide suitable collection containers at the collection points free of charge;
� Issue invitations to tender for collection and treatment/disposal services such
as logistics, collection, transportation, sorting, battery recycling and the
disposal of non-recyclable batteries in a procedure which ensures a
competitive allocation, for a maximum of three years;
� Secure funding by ensuring that the costs remaining after collection, recycling
and disposal, including sales tax and other necessary overheads, are divided
among the individual manufacturers in proportion to the share of the
respective previous year's sales (according to the volume of batteries
subdivided by type), and that appropriate contributions are made by the
individual manufacturers; and
� Publish, at least once a year, the costs of collection, sorting, recycling and
disposal of the collected batteries, subdivided by type.
558 Batterieverordnung (BattV) as of: 27 March 1998 (Federal Law Gazette BGBl. I, p. 658).
559 A different regulation is in force for automotive batteries. To achieve a maximum return rate of used
automotive batteries the consumer has to pay a compulsory deposit of 7.50 EUR when buying a new
battery without returning a used battery in its place (Article 6 BattV).
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26.2 Reasons for the Policy
According to the German Government 33,000 tonnes of portable batteries are sold in
Germany each year, of which 85% are non-rechargeable batteries (primary) and 15%
are rechargeable batteries (accumulators). 560 Until April 1998 the retailers in
Germany were taking back batteries containing toxic substances according to a
voluntary agreement. Due to the fact that under the voluntary agreement only one
fifth of the sold batteries were collected, the “Federal Decree Regarding the Collection
and Disposal of Used Batteries and Accumulators – BattV” was implemented in
Germany transposing the EU Battery Directive.
The aim of the decree is to reduce the amount of hazardous substances in waste
batteries in the following manner:
479
� Batteries containing certain hazardous substances may not be put into
circulation;
� Used batteries are taken back and recycled safely and properly in accordance
with the provisions of the German Waste Management and Recycling Act, or
non-recyclable batteries are disposed of in a manner compatible with public
health; and
� Batteries should be manufactured in such a way to make them reusable and
technically long-lasting.
In its second programme on the reduction of environmental pollution caused by
batteries, the German Government aimed at a collection rate of 60% by the end of
2006, 561 particularly through improved information to the public. 562
The timetable for the introduction of the policy was as follows:
� 18 th March 1991: EU Directive 91/157/EEC regarding batteries and
accumulators containing hazardous substances; 563
� Until 1998 in Germany: Voluntary agreement on the take back of batteries;
� 27 th March 1998: German Battery Decree serves to implement the Council
Directive 91/157/EEC the Commission Directive 93/86/EEC; 564
560 EUWID from 06.005.2003, p. 17.
561 Compare, the adapted collection quota according to the proposed new Battery regulation in
Germany of only 35%, in Chapter 1.1.11.
562 Programm der Bundesregierung zur Verminderung der Umweltbelastungen aus Batterien und
Altbatterien entsprechend Art. 6 der Richtlinie 91/157/EWG über gefährliche Stoffe enthaltene
Batterien und Akkumulatoren, 30. April 2003.
563 OJ EC No. L 78, p. 38.
564 Commission Directive 93/86/EEC of 4 October 1993, by way of amendment of the Council
Directive 91/157/EEC regarding batteries and accumulators containing hazardous substances in
technical progress, OJ EC No. L 264 p. 51,
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480
� 1 st September 2001: Revision of the Battery Decree 565 transposing the
Directive 98/101/EC 566 on the maximum mercury content of lead acid
batteries (0.0005%); and
� The transposition of the EU Directive 2006/66/EC 567 had not been completed
in Germany at the time of writing.
26.2.1.1 Country-specific Characteristics
The collection and recycling system of the Gemeinsame Rücknahmesystem Batterien
(GRS) for portable batteries operates throughout Germany, although, the amount of
batteries returned per capita differs significantly between states. Compared to the
average portable battery collection rate of 171g per capita in 2007, the return rate in
two of the eastern states of Germany was below 101g per capita, as Figure 26-1
shows.
Figure 26-1: Battery Collection in Germany 2007
Source GRS, Annual Review/Documentation 2008
565 First Decree amending the Battery Decree as from 26.06.2001, Federal Law Gazette BGBl. I,
p. 1361.
566 Commission Directive 98/101/EC dated 22 December 1998 by way of amendment to the Council
Directive 91/157/EEC regarding batteries and accumulators containing hazardous substances in
technical progress, OJ EC No. L 1 , p. 1.
567 Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on
batteries and accumulators and waste batteries and accumulators and repealing Directive
91/157/EEC, OJ EC No. L 266, p. 1.
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26.3 Key Organisations Involved in Implementation and
Management
Manufacturers and retailers are only allowed to put portable batteries (including
those incorporated into appliances) on the market if they ensure that the consumer
can return the batteries free of charge (Article 3 BattV). To that aim the
manufacturers must ensure the collection of used portable batteries by establishing a
common collection and recycling system, or by participating in such a system. As a
consequence the GRS was established, providing a fund for the uniform and nationwide
collection of spent portable batteries in Germany. GRS was founded in May
1998 by leading battery manufacturers and the German Electrical and Electronic
Manufacturers' Association (ZVEI). The fund is financed by contributions from its
users. Manufacturers and importers pay contributions to the foundation for the
services rendered, through a trustee, and in accordance with the quantity and type of
batteries sold in Germany. At the end of 2007 901 producers and importers were
members of the GRS, compared to only 432 members in the year 2000.
In accordance with Article 10 of the Battery Decree, the GRS prepares a report by 31
March every year, which includes information on:
481
� Batteries put into circulation, volume of batteries collected, sorting of spent
portable batteries, recycling and disposal results;
� Summary of the operating procedures;
� Total prices paid for sorting, recycling and disposal;
� Quality assurance and environmental protection; and
� Public relations.
Besides the GRS, other producers (e.g. producers of special batteries) have set up
separate take-back systems, like the Bosch Recycling Centre for Accumulators in
Electronic Tools (drilling machines etc) or the Organisation for Recycling of Secondary
Materials (Vereinigung für Wertstoffrecycling - VFW), which is empowered by many
producers to collect and recycle their batteries.
26.4 Evaluation Studies Available
The following evaluation studies have been undertaken:
� GRS, Annual Review/Documentation 2007, Performance Review in
accordance with the German Battery Decree, March 2008.
� Sachverständigen Rat für Umweltfragen (SRU) Umweltgutachten 2004, Mai
2004, p. 564, see: http://www.umweltrat.de
� BOSCH (2003): Recyclingzentrum Elektrowerkzeuge: Erfolgskontrolle 2002
gemäß § 10 Batterieverordnung. Robert Bosch GmbH.
� German Government (2003): 2. Programm der Bundesregierung zur
Verminderung der Umweltbelastungen aus Batterien und Altbatterien
entsprechend Artikel 6 der Richtlinie 91/157/EWG über gefährliche Stoffe
enthaltende Batterien und Akkumulatoren, see:
http://www.bmu.de/files/zweite_programm.pdf [as from 06.04.2003].
International Review of Waste Policy: Annexes

482
� GRS Batterien (2003): Erfolgskontrolle 2002. Hamburg: GRS Batterien, see:
http://www.grs-batterien.de/facts/pict/erfolg02.pdf [as from 20.08.2003].
� Vfw AG (2003): Vfw-REBAT. Erfolgskontrolle für das Jahr 2002 gemäß § 10
Batterieverordnung. Köln. Not published.
� BOSCH (2000): Recyclingzentrum Elektrowerkzeuge: Erfolgskontrolle 1999
gemäß § 10 Batterieverordnung. Robert Bosch GmbH.
� Vfw AG (2000): Vfw-REBAT. Erfolgskontrolle für das Jahr 1999 gemäß § 10
Batterieverordnung. Köln. Not published.
26.5 Environmental Benefits
Concerning NiCd Batteries, the amount of batteries (including those in appliances)
put on the market in Germany decreased from 1,967 tonnes in 2003 to
approximately 1,253 tonnes in 2007. 568 In 2007 this equates to 4 % of the total
amount of portable batteries put on the market in Germany. It seems quite unlikely
that this decrease has been significantly influenced by the Battery Decree, as this
offers no incentives for consumers to change consumption habits. The decrease in
market share of the NiCd batteries does appear to be due more to technological
innovations, although producers may have been becoming more aware of the desire
to see significant reductions in cadmium in batteries under the Batteries Directive.
Experience in the UK, where not equivalent to the German Regulations were in place
(refer to Section 25.0), seems to supports this.
The waste stream in 2007 was composed of 82% primary batteries and 18%
secondary batteries (see Figure 26-2). In 2007, as in the year before, almost 1.5
billion portable batteries were put into circulation (33,000 tonnes). The collection
rate achieved was 43% and the recycling rate achieved was 38% (see Figure 26-3). Of
the 13,645 tonnes of portable batteries entering GRS sorting plants in 2007, 8%
were disposed of (92% recycling efficiency) compared to 81% (19% recycling
efficiency) in 1999 (see Figure 26-3). 569
160,000 collection sites are run by the GRS, of which 140,000 are retail outlets. The
data in Figure 26-3 shows that 47% of portable batteries collected by GRS came from
collections at retail outlets, 23% from waste collection local authorities and 30% from
industry. This shows that whilst retail take-back delivers the highest proportion of
portable batteries, the contributions from local authorities and industry are still
significant.
568 GRS 2003, 2002, 2001; BOSCH, 2003, 2000; VfW-REBAT, 2003, 2000, Erfolgskontrolle GRS
2007.
569 Data from GRS, Recycling Magazin from 6.10.2008, p. 12 (13).
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Figure 26-2: German Battery Composition Breakdown, 2007
Source GRS, Annual Review/Documentation 2008
Figure 26-3: German Portable Battery Collection Routes, 2007
Source GRS, Annual Review/Documentation 2008.
26.6 Implementation Costs
According to the EU Battery Directive producers have to bear all net costs and as
previously stated the GRS (and other similar schemes) is financed by contributions
from its users.
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26.7 Effects on Technical Change / Innovation
Regarding the influence of the Battery Decree on the sales figures of rechargeable
batteries, 22% of batteries put into circulation in 2007 were rechargeable (see Figure
26-4). Although the number of rechargeable batteries in the sales figures has
increased slightly since 2003, the Öko-Institut concludes that there has neither been
a relevant shift of consumers to buy rechargeable batteries, nor is the increase
attributable to the Battery Decree.
Figure 26-4: Batteries in Circulation in Germany, 2007
Source GRS, Annual Review/Documentation 2008.
26.8 Social and Distributional Consequences
See Section 25.9.
26.9 Complementary Policies
See Section 25.10. In addition, one might argue that, regarding the share of 22%
secondary batteries in the sales figures, complementary policies would be necessary
to increase their share. Possible instruments to be considered should address the
higher sales prices of secondary batteries compared to that of primary batteries. Such
policies are not in place in Germany.
26.10 Effect of the Policy on Pricing of Resources / Services
It is not felt that an increase in battery prices followed as a consequence of the
Battery Decree.
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26.11 Evasion and Enforcement
The collection system may charge manufacturers who do not belong to the collection
system for the costs of the sorting, recycling or disposal of the sorted batteries (Article
4 Battery Decree).
Infringements of the regulations, for the purposes of Article 61, Para 1, No. 5 of the
German Waste Management and Recycling Act, are deemed to have been committed
by parties who, for example, put batteries on the market contrary to the Battery
Decrees provisions or do not take back batteries.
26.12 Lessons Learned
According to the Battery Directive 2006/66/EC, Member States must reach a
collection quota of 45 % of portable batteries and accumulators put into circulation by
2016. In Germany the increased awareness and participation of consumers in a free
of charge collection system for used batteries has – after a period of about eight
years – led to a total amount of 14,132 tonnes of portable batteries being collected
in 2007, or around 42 % of the amount of portable batteries put on the market.
The widespread and easy accessibility of collection boxes for end of life batteries is a
prerequisite for the participation of consumers in the collection system and avoids
disposal of household batteries into the residual waste stream.
However, the battery decree has no incentives for producers and consumers to shift
the consumption in favour of secondary batteries.
The discussion on the revision of the Battery Decree in Germany covers the following
points:
485
� Producers and importers of Batteries shall register with one central body
before they may put batteries into circulation;
� Adoption of the collection rates of the new Battery Directive for used portable
batteries and accumulators of 25% by 2012 and 45% by 2016;
� Collection and recycling systems run by producers need an authorisation
which should only be granted if concrete collection and recycling targets are
met;
� Extended labelling duty; and
� Marketing prohibition for portable batteries with more than 0.0002% cadmium
per weight.
Key issues for the policy are:
� Avoidance of free riders / all battery producers participate in take-back
systems, like GRS (Gemeinsame Rücknahmesystem Batterien);
� Collection and treatment infrastructure is tailored to the amount of GRS
disposed;
� Consumers need to find the take-back system convenient so they do not
illegally dispose of batteries in the residual waste;
International Review of Waste Policy: Annexes

486
� A key problem for the successful return of batteries is consumers hoarding
70% of batteries at home for over 3 months; and
� It is argued that a high quota of returned batteries can be only achieved
through a collection close to the households. 570
26.13 Prerequisites for Introduction
Essential elements required for this particular policy to be introduced are:
� “Willingness” of the industry to come up with its producer responsibility, e.g.
organizing the recycling system;
� Cooperation between the retailers and manufacturers concerning the
collection and recycling of batteries;
� Capacity to build up a recycling infrastructure (e.g. sufficient collection points
and personnel to service these etc);
� No legal obstacle for a take-back system run by industry, e.g. anti-trust law;
and
� Existence of a central institution for organizing and monitoring the system, and
to enforce in cases of non-compliance.
570 Bundesverband der Deutschen Entsorgungswirtschaft e.V. (BDE), EUWID from 06.005.2003, p. 9.
29/09/09

27.0 Plastic Bag Levy - Ireland
27.1 Outline of Policy
The plastic bag levy targets disposable plastic carrier bags with the specific intention
of reducing their consumption. A tax of €0.15 per bag was introduced in Ireland on
the 4th of March 2002 under the Waste Management (Environmental Levy) (Plastic
Bag) Regulations 2001. On 1 st July 2007 the levy was increased from €0.15 to €0.22
per bag. There are exemptions for smaller plastic bags that meet specific conditions
and are used to store non-packaged goods such as dairy products, fruit and
vegetables, nuts, confectionary, hot or cold cooked food and ice. These are known as
levy-free bags. Re-usable plastic bags are also exempt as long as the charge for the
bag exceeds €0.70.
The levy is applied at the point of sale, and retailers are obliged to pass on the levy to
the customer. The Department of the Environment, Heritage and Local Government
(DoEHLG) recently initiated a Regulatory Impact Analysis (RIA) on the proposed
legislation to increase levies on plastic shopping bags in August 2008. It is proposed
that the existing rules governing the level of the levies (on landfill and plastic bags)
(Sections 72 and 73 of the Waste Management Act) are amended to allow the
Minister sufficient flexibility to increase the levy without frequent recourse to primary
legislation. The outcomes of the RIA are not yet published (as of October 31 st 2008).
27.2 Policy Context and Reason for Introduction
The decision to introduce the plastic bag levy followed a 1999 study on behalf of the
DoEHLG documenting the issues of plastic bags and their environmental impact. 571
The report recommended a levy as the most appropriate means of reducing
consumption of plastic shopping bags and thereby reducing consequent
environmental problems.
The levy was introduced primarily as an anti-litter measure, with plastic bags a highly
visible component of litter, strongly associated in the public mind with the problem of
litter pollution. The materials used to make most plastic bags do not biodegrade
(within any reasonable timeframe) and therefore persist in the environment unless
collected. Plastic bags are often caught in trees, along river banks, in parks and other
public spaces and can pose a danger to wildlife. This problem is often more acute in
rural areas where local authorities do not have the capacity to provide regular
street/road cleaning.
The litter reduction objective is an important one to recognise. To the extent that
plastic was deemed more problematic in this regard, switching to bags made of other
571 Fehily, Timoney & Company (1999) Consultancy Study on Plastic Bags, Report prepared for the
Department of Environment and Local Government, Dublin. Press Release March 2002.
487
International Review of Waste Policy: Annexes

materials might not have been deemed to render the levy unsuccessful if those
materials are less problematic in, or less likely to find their into, the litter stream.
27.3 When was the Policy Introduced?
The plastic bag levy was introduced on the 4 th March 2002.
27.4 Key Organisations Involved in Implementation and
Management
The key organisations involved in implementation of the plastic bag levy are:
488
� Department of the Environment, Heritage and Local Government (DoEHLG);
� Local Authorities who are in charge of enforcement;
� The Controller and Auditor General; and
� Retailers.
A Service Level Agreement between the Revenue Commissioners and the DoEHLG
provides that the Revenue Commissioners have responsibility in relation to collection
of the levy and for ensuring that businesses are aware of their obligations in relation
to making returns. This includes carrying out checks/audits on retailers, and other
related activities.
27.5 Monitoring and Measurement Techniques Applied
The key instruments for measurement of the impact of the levy include the sales data
kept by the Revenue Commissioners, and industry data on sales of plastic bags.
Table 27-1 details the Environment Fund Income generated from the plastic bags levy
since its introduction in 2002. The income from the levy increased steadily from
2002 to 2007. The introduction of the plastic bag levy in 2002 had an immediate
effect on consumer behaviour – with plastic bag per capita usage decreasing from an
estimated 328 bags to 21 plastic bags per capita per annum. However, the results of
the 2006 census indicated that plastic bag usage had risen to 31 bags per capita
over the course of 2006. Consequently the levy was increased to 22 cents on 1 st July
2007. 572
Table 27-1: Plastic Bag Levy Income 2002 - 2007
Plastic Plastic
Plastic
Bag Bag
Bag
Levy
Levy
29/09/09
2002* 2002* 2003 2003 2004 2004 2005 2005 2006 2006 2006 2007
2007
€10,428,413 €12,883,408 €15,278,107 €17,484,551 €19,947,315 €22,577,535
*Accounts for the period from the period from 17 th July 2001 to 31 st December 2002
Source: Environment Fund Accounts from 2002 to 2007
572 Press Release, 21/02/07 by the DoEHLG, “Plastic Bags Levy to be increased to 22c from the 1st of
July”.

27.5.1 Evaluation Studies Available
489
� Fehily Timoney & Company (1999) “Consultancy Study on Plastic Bags”, Report
prepared for the Department of Environment and Local Government
� S. McDonnell (2003) An Enquiry into the Use of Taxation on Environmentally
Harmful Products: “A Case Study of the Irish Plastic Bag Levy” UCD Unpublished
Thesis
� The National Litter Pollution Monitoring System, Department of Environment,
Heritage and Local Government (2002 to present) (www.litter.ie)
� Irish Business Against Litter (IBAL) and An Taisce (National Trust of Ireland)
produced a number of litter surveys, January 2002 and April 2003;
� Simon McDonnell and Susana Ferreira (2007) “The most popular tax in Europe?
Lessons from the Irish plastic bags levy” Environmental and Resource
Economics, September 2007, vol. 38, no. 1, pp. 1-11(11).
27.6 Environmental Benefits
The plastic bag levy has reduced consumption of plastic bags, which are highly visible
components of litter and are very much associated in the public mind with the
problem of litter pollution. It is not clear whether, and to what extent any
environmental benefits have been offset by switching to use of other bags.
The effects of the tax on the use of plastic bags in retail outlets and in the landscape
have been dramatic, with usage falling by more than 90%. 573 Since the introduction
of the levy, the number of bags entering the consumption stream has been reduced
by approximately 94% according to McDonnell. 574
A combined project by Irish Business Against Litter (IBAL) and An Taisce (National
Trust of Ireland) produced a number of litter surveys. These have found that between
January 2002 and April 2003 the number of “clear” areas (i.e. areas in which there is
no evidence of plastic bag litter) has increased by 21%, while the number of areas
without “traces” has increased by 56%. 575
The National Litter Pollution Monitoring System quantifies the composition of litter
pollution in Ireland using litter quantification surveys (for further information please
refer to www.litter.ie ). This Monitoring System allows the impact of the plastic bag
levy to be evaluated; an illustration is given in Figure 27-1. Note that the DoEHLG
573 Simon McDonnell and Susana Ferreira (2007) The most popular tax in Europe? Lessons from the
Irish plastic bags levy, Environmental and Resource Economics, September 2007, vol. 38, no. 1, pp. 1-
11(11).
574 S. McDonnell (2003) An Enquiry into the Use of Taxation on Environmentally Harmful Products: A
Case Study of the Irish Plastic Bag Levy, UCD, Unpublished Thesis.
575 http://www.antaisce.org/projects/ibal.html.
International Review of Waste Policy: Annexes

estimated the figure of 5% in their first Annual National Litter Pollution Monitoring
Systems Annual Report, May 2003. 576 Consequently, one cannot be certain that the
decline in litter quantities has been as dramatic as the figure would appear to
suggest.
Figure 27-1: Plastic Shopping Bags as a % of Litter
490
29/09/09
5.00%
4.50%
4.00%
3.50%
3.00%
2.50%
2.00%
1.50%
1.00%
0.50%
Plastic Bags (Shopping Bags)
5%
0.32% 0.25% 0.22%0.22%
0.52% 0.29% 0.32%
0.00%
Prior to Levy 2002 2003
1
2004 2005 2006 2007 2008
Source: National Litter Pollution Monitoring Systems, Annual Reports, www.litter.ie
Prior to the introduction of the plastic bag levy in March 2002, it was estimated that
1.3 billion shopping bags were issued annually, and that they contributed a visually
very intrusive form of litter pollution. 577 The National Litter Pollution Monitoring
Systems Survey results in Figure 4-1 show a significant decrease in the percentage of
plastic bags, from 5% prior to the Plastic Bag Levy to 0.32% in 2002. A further
decrease to 0.22% followed in both the 2004 and 2005 survey periods. In 2006 the
number of plastic bags, constituted 0.52% of the National Litter Composition.
However in 2007 the percentage of plastic bags subsequently decreased to
0.29%. 578 This decrease in 2007 may be attributable to the increase in the plastic
bag levy to 22 cents on 1 st July 2007. In 2008, the percentage of plastic bags
increased slightly to 0.32%.
As part of the research for the paper on “The most popular tax in Europe? Lessons
from the Irish plastic bags levy”, an evaluation of the impact of the levy on
householders and retail sector was completed. This involved interviewing seven
leaders in the retail sector and conducting random telephone interviews with
consumers, the results being as follows:
576 National Litter Pollution Monitoring Systems, Annual Report May 2003, www.litter.ie
577 This further highlights, perhaps, the significance of ‘visibility’ as opposed to ‘counts’ in considering
litter-related disamenity (as discussed in Section 16.6.3 of these Annexes).
578 National Litter Pollution Monitoring Systems, Annual Reports, www.litter.ie

491
� Retailers find the effects of the tax on their well-being neutral or positive, closely
related to the fact that the additional costs of implementation were generally
less than the savings resulting from not having to purchase plastic bags.
Implementation costs were low because bookkeeping was integrated with VAT
returns; and
� Overall, consumers were very much in favour of the levy. The majority felt that
the impact of the levy in terms of convenience at checkouts and more generally
was enhanced, but that the levy had added to their expense. Virtually all
respondents responded that they felt the impact on the environment was
positive, producing a noticeable reduction in plastic bags ‘in the environment’.
Fehily Timoney et al carried out an ex ante study on the impact of the tax on the
plastic bag industry. 579 This study included a Life Cycle Assessment (LCA) of plastic
and paper bags using a weighting system, based on how far away each impact was
from a sustainable target level. Using this approach, plastic bags were shown to have
a lower total impact score of 7.9 compared to paper bags with a score of 8.9. 580
In this context, it is worth noting that it has been suggested that since the introduction
of the plastic bag levy that paper shopping bags are more prevalent (though we can
find no data on the consumption of paper bags before or after the ban, usage is
expected to have increased). 581 Figure 27-2 below illustrates the percentage of paper
bags as a percentage of the National Litter Composition from 2003 to 2008. The
Litter Quantification Survey results available from the National Litter Pollution
Monitoring System show that paper bags as a constituent element of litter pollution
appear to be more or less stable, but crucially, as with plastic bags, no pre-levy data is
available so one cannot assess whether the proportion of paper bags in litter has
increased or not. Further study is needed to assess how bag consumption (both paper
and plastic) has changed and what the resulting environmental impacts of the policy
have been.
In a study dated September 2004 completed by EuroCommerce which analysed
plastic bags in an Integrated Product Policy (IPP) context the main conclusion stated
that:
“Little or negative gain was found to be derived from the shift from single use
bags to other single use bags such as biodegradable bags and paper bags,
with potential litter gains offset by negative resource use, energy and
greenhouse outcomes” 582 .
579 Fehily, Timoney & Company (1999) Consultancy Study on Plastic Bags, Report prepared for the
Department of Environment and Local Government, Dublin.
580 Ibid.
581 Sales figures for paper bags in the period before and after the Levy was requested from the
DoEHLG, but this information does not exist.
582 EuroCommerce, Environment & Logistics (September 2004) “The Use of LCAs on Plastic Bags in an
IPP Context”.
International Review of Waste Policy: Annexes

Also, the report stated that there is a higher incidence of "double bagging" (people
using two bags instead of one) for strength. The EuroCommerce report is based on
Life Cycle Analysis (LCA), but no clear information is provided in the report. This report
also suggests that paper bags have meant increased transport and storage costs, but
no supporting information is offered on this.
Figure 27-2: Paper Bags as a Percentage of the National Litter Composition
492
29/09/09
0.70%
0.60%
0.50%
0.40%
0.30%
0.20%
0.10%
0.00%
0.60% 0.57%
Paper Bags
0.40%
0.61%
0.42% 0.43%
1
2003 2004 2005 2006 2007 2008
Source: National Litter Pollution Monitoring Systems, Annual Reports, www.litter.ie
27.6.1 Environmental Benefits – Prevention
In 2007, of the €57,725,535 generated in income from the Environmental Fund
(€22,577,535 of which was generated in income from the plastic bag levy), the
following was spent on Prevention Initiatives:
� “Waste Prevention and the National Market Development Group”, €1,518,213
� “Producer Responsibility Initiatives”, €905,793
� “Environmental Awareness”, €1,615,332
The above figures illustrate that a large number of Environmental Awareness
Campaigns and Waste Prevention Programmes have been put in place in local
authorities, due to the monies available from the Environmental Fund. Therefore this
levy has influenced preventative initiatives in Ireland.
The Irish Plastic Bag Levy has caused an estimated 90% reduction in plastic bag
production in Ireland. Prior to its introduction approx. 1.2 billion disposable plastic
bags were given away free by retailers. There is no information on the quantity of
paper bags used in Ireland prior to the levy and following its implementation.
As mentioned above, it has been suggested that since the introduction of the plastic
bag levy, that paper shopping bags are more prevalent (though we can find no data
on the consumption of paper bags before or after the ban, usage is expected to be
increased). Surveys indicated, however, that up to 90% of shoppers used long-life

ags in 2003, compared with 36% in 1999, which suggests that the switch to paper
bags was a far from universal switch. 583
27.6.2 Environmental Benefits Associated with Recycling
In 2007, of the €57,725,535 generated in income from the Environmental Fund
(€22,577,535 of which was generated in income from the plastic bag levy), the
following was spent on Recycling Initiatives:
493
� “Waste Management including Recycling Projects”, €17,246,428, this
represents payments made to local authorities to assist in costs associated
with the provision of waste management infrastructure.
� “Recycling Operational Costs”, €11,914,847, this represents payments made
to local authorities to assist in costs associated with the operational costs of
waste management.
The above figures illustrate that a large number of recycling facilities/infrastructure
have been put in place due to the monies available from the Environmental Fund.
Therefore, although the direct effect of the levy on recycling appears to have been
zero, indirectly, the plastic bag levy can be said to have had a positive impact on
recycling in Ireland as it provides local authorities with the funding to develop
recycling facilities. In addition, it would be easy to understate the potential influence
on public awareness that such a policy may have had in making some citizens more
aware of ‘waste’ as an issue of legitimate concern.
27.7 Implementation Costs
The set up (establishment) costs were €1.2 million. This included purchase of new
computer systems and additional resources needed to administer the levy. Annual
administration costs are in the order of €350,000. Advertising costs arising from the
publicity campaign to launch the levy amounted to €358,000 584 .
Receipts from the plastic bag levy amounted to €9.6 million in the first year. Taking
into account start-up and ongoing administrative costs, total net receipts from the
plastic bag levy amounted to around €8 million. The levy was expected to generate
around €11 million in a full year; however the latest figure from the Environment Fund
Accounts 2007 show the income from the levy was €22,577,535 in 2007, of this the
Environmental Levy Collection Costs (the annual service fee agreed with the Revenue
Commissioners for the operation of the plastic bag levy), amounted to €388,025 585 .
This equates to approximately 17% of the revenue received.
583 Department of Environment, Heritage & Local Government, Press Release, 21/07/2007
584 Simon McDonnell and Susana Ferreira (2007) The most popular tax in Europe? Lessons from the
Irish plastic bags levy, Environmental and Resource Economics, September 2007, vol. 38, no. 1, pp. 1-
11(11).
585 Environment Funds Account (2007)
International Review of Waste Policy: Annexes

Enforcement costs borne by the Irish Government were minimal, as the tax receipts
were provided to the Government along with revenues from the national Value Added
Tax (VAT).
27.8 Response from Public and Industry
Much of the response from public and industry is described in Section 27.5. The
plastic bag levy has had an immediate effect on consumer behaviour, creating a
strong anti – litter awareness initiative and influencing behavioural change of
consumers by encouraging them to change their shopping practices and to buy reusable
shopping bags. A national survey on the Environment "Attitudes and Actions
2003" found that 91% of those surveyed believe the Plastic Bag Levy is a good idea.
Among the many reasons given are that it is better for the environment, there are no
plastic bags visible in the streets (it was also a rural problem with bags snagged in
fences, hedgerows and trees) and that re-usable bags are more convenient for
holding shopping. This is a major change in attitude as during the course of the
previous survey in 1999, 40% of those surveyed stated they would not be willing to
pay a levy. The 6% who did not believe that the levy was a good idea in the later
survey cited the fact that they missed having plastic bags about the house and were
also frustrated when they forgot to bring-usable bags into the shop. The survey also
indicated that 90% of shoppers use reusable/long life bags, 6% use cardboard boxes,
4 % plastic bags and 1% other means.
After initial opposition to the tax, retailers ended up strongly supporting a bill, which
saves €50million per year from reduced disposable grocery bag stocking costs whilst
increasing sales of re-usable bags.
The levy encourages people to think more about the products and services that they
are using more broadly and raises an awareness of reuse and recycling in general.
27.9 Effects on Technical Change / Innovation
Data from levies remitted and the results of the 2006 Census indicate that plastic
bag usage rose to 31 bags per capita during the course of 2006 compared to 21
bags per capita when the levy was introduced in 2002. (as highlighted above) To that
effect the levy was increased to 22 cents on the 1 st July 2007. The aim of the
increase is to reduce the per capita usage to the level achieved in 2002 or lower. This
increase in the levy illustrates the desire to generate continuous incentives for
improvement.
It has also been seen that the manufacture of paper bags has increased since the
introduction of the levy. One study reported that one paper bag manufacturer
reported a 20 fold increase in sales, meaning they now produce ten million bags a
year.
The policy encourages people to think more about the products and services they are
using and raise an awareness of reuse and recycling in general. There may have been
effects on behaviour and technical change, which are not directly related to the levy
itself.
494
29/09/09

27.10 Social and Distributional Consequences
In principle, the levy may be said to have a disproportionate economic impact on
those on lower incomes. However, since the cost is low and readily avoidable this is
not likely to be a significant issue, and the survey results would appear to bear this
out.
As regards bag producers, the producers of plastic bags will have been negatively
affected, whilst those producing paper bags and ‘bags for life’ will have been
beneficiaries. The structure of production of plastic bags suggests, however, that the
prevalence of overseas production of bags may have implied that the negative impact
on bag producers was felt mostly overseas. Fehily et al (1999) carried out an ex ante
study on the impact of the tax on the plastic bag industry. 586 They estimated that in
1999, 79% of the plastic bags consumed were imported (from the rest of the EU and
certain Southeast Asian countries). Four plastic manufacturing firms operating in the
Republic produced the remaining 21%. Since then, however, one has apparently gone
out of business causing the loss of 26 jobs, but it is not clear whether this was as a s
direct consequence of the levy.
As the tax is imposed at the retail level on Irish shoppers, it does not introduce
competitiveness concerns. The Republic of Ireland shares a land border with Northern
Ireland, where there is no levy, but the costs to the consumers are such a minor
proportion of the total shopping bill, and the levy has proved, in any event, to be so
popular with the public, that it is highly unlikely that there has been any leakage of
trade across the border caused by the levy. 587
27.11 Complementary Policies
Shopping bags are packaging waste under the 2004/12/EC (Packaging and
Packaging Waste Directive). Hence, there is some complementarity with the policy on
packaging more generally.
27.12 Effect of the Policy on Pricing of Resources / Services
The policy effectively implies the elimination of a practice – the issuing of plastic bags
free of charge – which will have led (as the policy’s effects suggest) to overconsumption
of plastic bags. Whether the pricing is optimal is unclear, and the fact
that other bags may be being issued free of charge might be said to imply some
distortion of the market. Plastic bag manufacturers argue, for example, that plastic
bag production is more energy efficient (in terms of use per quantum of ‘bag
packaging’).
586 Fehily, Timoney & Company (1999) Consultancy Study on Plastic Bags, Report prepared for the
Department of Environment and Local Government, Dublin.
587 Simon McDonnell and Susana Ferreira (2007) The most popular tax in Europe? Lessons from the
Irish plastic bags levy, Environmental and Resource Economics, September 2007, vol. 38, no. 1, pp. 1-
11(11).
495
International Review of Waste Policy: Annexes

The plastic bag levy has led to more expensive, long-life bags being developed in the
market. These are considered to be more environmentally friendly as they are
capable of being reused on an ongoing basis.
27.13 Evasion and Enforcement
Some anecdotal evidence of slippage in the application of the plastic bag levy has
been reported. Local authorities carry out inspections of retail outlets with a view to
improving current practices in relation to the implementation of the plastic bag levy
regulations. An enforcement network of local authority officers has been established
to monitor and co-ordinate the enforcement drive for the plastic bag levy.
A number of actions are undertaken by local authorities in ensuring compliance by
retailers with the requirements of the levy regulations. These include visiting retail
outlets and talking to retailers, carrying out initial spot checks and monitoring
implementation.
The role of the Revenue Commissioners relates to the collection of the levy. Revenue
Commissioners are responsible for:
496
� Identification of accountable persons;
� Processing returns and payments received from accountable persons;
� Carrying out verification checks relating to the accuracy of returns;
� Pursuing accountable persons who fail to deliver returns and payments within
the statutory time limits;
� Raising estimates where returns are not received or where liability is under
stated;
� Dealing with appeals against estimates raised.
It is intended that, so as to minimise compliance costs on retailers, checks carried out
by Revenue Commissioners will, insofar as possible, be incorporated with checks
carried out in relation to tax liabilities.
Retailers who fail to correctly implement the levy regulations are liable to the following
sanctions:
� 0n summary conviction, a fine not exceeding €3,000, or imprisonment for up
to 12 months, or both; or
� 0n conviction on indictment, a maximum fine of €15 million, or to
imprisonment for up to 10 years, or both.
� A system of daily fines applies where an offence continues to be committed
after conviction i.e. up to €1,000 per day for a summary conviction, or up to
€130,000 for conviction on indictment.
29/09/09

27.14 Lessons Learned
27.14.1 General Lessons
The plastic bag levy has been deemed a successful policy in Ireland, resulting in an
estimated 90% reduction in plastic bag use in Ireland. Particular effects include:
497
� A decrease in the percentage of plastic bags as a littering item, from 5% prior
to implementation of the levy to 0.29% in 2007, while the percentage of paper
bags remained relatively constant at an average of 0.6% of all litter items
nationally. It should be considered, however, that the pre-levy figure of 5% was
an estimate;
� More money in an environmental fund for environmental projects such as
bring banks and new civic amenity sites which are contributing to the much
improved recycling performance; and
� The legislation encourages people to think more about the products and
services they are using and raise an awareness of reuse and recycling in
general.
There are obvious advantages of this levy in terms of the significant decrease in the
percentage of plastic bags as a littering item. What seems less clear is whether the
benefits unrelated to litter, in particular, whether those associated with use of bags,
have been beneficial in net terms. In other words, has there been a waste prevention
effect, and what has been the net environmental impact of the reduction in plastic
bag usage, and the increased use of alternatives? All product levies can be expected
to have ‘output’ and ‘substitution’ effects. In the absence of further analysis, net
effects might be assumed to be positive, but one cannot be absolutely certain of this.
It must be said that the Irish plastic bag levy has been something of an inspiration
worldwide. Many jurisdictions are now seeking to implement similar levies or have
already done so. The rationale for such levies is gaining increasing support from those
concerned with marine pollution. 588
588 See, for example, Ljubomir Jeftic, Seba Sheavly and Ellik Adler (2009) Marine Litter: A Global
Challenge, Report for UNEP, April 2009,
http://www.unep.org/regionalseas/marinelitter/publications/docs/Marine_Litter_A_Global_Challenge.
pdf
International Review of Waste Policy: Annexes

28.0 Packaging Taxes - International
28.1 Outline of Policy
Packaging taxes are typically measures used to affect the production and
management of packaging wastes. In most instances, packaging taxes are classified
as an example of a ‘consumption’ tax whereby a levy is applied with the aim to
discourage excess consumption and waste generation. Such levies can affect supply
and demand of packaging through influencing the use of packaging materials,
generally seeking to shift consumption towards packaging with lower environmental
impacts.
Levies are applied to materials used for packaging containers (normally in the retail
sector). Varying rates are applied depending upon the materials used. These
materials include (amongst others) different types of plastic, cardboard, aluminium,
glass and wood. The levy is normally applied as a weight based incentive, but can also
based on volume when concerned with liquid packaging, especially where the
intention is to encourage re-use. 589
28.2 Where Has the Policy Been Applied and Why?
Within the EU, Denmark, Belgium and the Netherlands have each applied a form of
packaging tax. Product taxes in Belgium are discussed in further detail in Section
30.0.
Denmark has had a packaging tax in operation since 1978, with significant changes
made over the last decade. 590 Between 1999 and 2001, Denmark introduced a more
sophisticated version of the tax which removed fiscal equality between different
packaging materials. The revised taxes are now determined through reference to life
cycle-based assessment of the environmental damages associated with the different
materials.
The most recent country to adopt a packaging tax is the Netherlands, adopting their
packaging tax in January 2008. The tax in the Netherlands is known as the Carbon-
Based Packaging Tax. The tax considers the life cycle impact of materials based on
greenhouse gas emissions and is applied using a relevant metric to each material.
It appears that in both the Netherlands and in Denmark, the tax has been
implemented for a variety of objectives including:
498
� Waste prevention;
589 National Environmental Research Institute, Denmark (2006) The Use of Economic Instruments in
Nordic and Baltic Environmental Policy 2001-2005, Final report for Nordic Council of Ministers, 2006.
590 ECOTEC in association with CESAM, C. U. (2001) Study on Environmental Taxes and Charges in the
European Union and its Member States, Final report for the European Commission, April 2001.
29/09/09

499
� Higher rates of recycling; and
� Reduced environmental / climate change impacts.
28.2.1 Country-specific Characteristics
Packaging taxes have been implemented in different ways in different countries.
These variations include the materials to which the tax applies, the minimum
threshold applied, exempt items and the rate of tax itself. Table 28-1 demonstrates
the variations between tax rates on packaging material in Denmark and the
Netherlands.
Table 28-1: Primary Packaging Tax Rates 2008 (weight-based)
Packaging Packaging Packaging
Denmark Denmark ( (€/kg) ( €/kg)
Virgin Cardboard and Paper 0.13
Recycled Cardboard and Paper 0.07
International Review of Waste Policy: Annexes
€/kg) 591 Ne
Ne Netherlands Ne therlands ( (€/kg) (
€/kg)
0.06
Virgin Plastics (except
polystyrene and PVC) 1.74 0.36
Recycled Plastics (except
polystyrene and PVC) 1.04
Filled Plastics (except
polystyrene and PVC) 1.04
Plastics (except polystyrene and
PVC) UN-approved 1.39
Polystyrene and PVC 2.73
Aluminium 4.47 0.57
Tinplate and Steel 1.24
Tinplate and Steel, UN-approved 0.99
Glass and Ceramics 0.25 0.05
Wood 0.07 0.02
Other Metals No comparable levy 0.11
Bioplastics No comparable levy 0.18
Other Materials No comparable levy 0.10
€/kg) 592
The scope of the schemes can also vary widely. In the Netherlands the scheme is
believed to cover 95% of all packaging materials, whilst in Denmark only 20% of
packaging is covered within the scheme. 593 The Danish system covers products such
591 The Danish Ministry of Taxation (2008) Packaging Tax Rates, consulted October 2008
http://www.skm.dk/foreign/english/2087.html
592 The Dutch Tax and Customs Administration (2008) Packaging Tax Rates, consulted October 2008
http://www.belastingdienst.nl/zakelijk/verpakkingenbelasting/
593 Ernst and Young Indirect Tax Alert, January 2008.

as drinks, oils, vinegar, sauces, dairy products, detergents, paints, cosmetics and pet
food. 594 Currently the levy does not cover other items such as general foodstuffs and
household goods and only applies to retail containers up to 20 litre capacity. 595
The rates for beverage packaging in Denmark implied by the above levies are shown
in Figure 28-1.
Figure 28-1: Tax on Beverage Packaging in Denmark
Source: Christian Fischer (2008) Producer Responsibility Schemes Versus Deposits
and Taxes- Danish Experiences, PRO Europe Congress, 15 May 2008
28.3 Key Organisations Involved in Implementation and
Management
In both Denmark and the Netherlands, the Ministry for Taxation is responsible for
setting the levy and recovering the funds from the scheme. An Environmental
Protection Agency is normally responsible for the monitoring of the data relating to
the scheme, whilst the initial legislation forming the scheme normally originates from
the Ministry of Environment.
Key organisations in the Danish implementation are shown in Table 28-2.
594 The Danish Ministry of Taxation (2008) Packaging Tax Rates, consulted October 2008
http://www.skm.dk/foreign/english/2087.html
595 Ibid.
500
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Table 28-2: The Organisation of the Danish Packaging Tax
Transposition of directive into national
legislation
501
Activity Activity
Responsible Responsible body
body
Monitoring of meeting targets (national +
directive)
International Review of Waste Policy: Annexes
Ministry of the Environment (Danish EPA)
Danish EPA
Monitoring and control of compliance Danish EPA/Local authorities
Information on management of packaging
waste
Local authorities and Dansk Retursystem
Supplier of packaging data Danish EPA
Collection Collection of of packaging packaging waste:
waste:
— from households
Local authorities and Dansk Retursystem
(disposable beverage packaging)
— from industry/commerce Mainly private operators
Recycling and treatment of packaging waste
Expenditure on packaging system covered by
Source: EEA Report No 3/2005
Private operators (recycling) and local
authorities (treatment)
Local authorities (via fees paid by
households) and private enterprises
28.4 Pre-implementation / Evaluation Studies Available
In Denmark, the modern version of the packaging tax (post 2001) was conceived
from the Danish Action Plan for Waste (1993-1997). This action plan called for an
assessment of the possibilities for taxing packaging as a means of influencing
consumer behaviour. 596 Alongside this, there was also a desire to examine the
environmental impact of different types of packaging and relate the levy to those
findings.
Before implementation of the modern version of the levy in Denmark, initial studies
were conducted in 1993/94 to assess the feasibility of the packaging tax. 597 These
initial studies concluded that the levy was not to be taken forward due to poor data
and a lack of methodology for developing a comprehensive, environmentally
beneficial, taxation system. In addition, it was perceived that the administrative
burden of the tax was too high.
596 ECOTEC in association with CESAM, C. U. (2001) Study on Environmental Taxes and Charges in the
European Union and its Member States, Final report for the European Commission, April 2001
597 Ibid.

In 1996, the Danish Parliament required the Government to again examine
possibilities for the introduction of a tax. 598 The Government completed a review at
the end of 1997, which recommended that:
502
� The tax should seek to reduce the weight of packaging for each particular
material;
� The tax should be based on a life cycle assessment of environmental impacts
in order to promote the most environmentally friendly materials;
� The tax should be based on weight of packaging and be differentiated by
material; and
� For ease of administration, only the heaviest product groups should be
included, and it should be easy to distinguish the products and packaging on
which the tax is imposed;
Following the review, these findings were utilised in the framework for the levy in
Denmark.
In the Netherlands, two studies were used to assess the potential tax rates:
• First, in 2007, approximate calculations were carried out by CE Delft for the
Ministry of Finance on environmental differentiation of the packaging on a limited
number of product groups. Some of the environmental data used in that study for
the materials in question were outdated;
• Second, again in 2007, with the decision having been taken to use the tax to
cover all packaging, a second study was prepared though with only limited
differentiation as to material subcategories (to keep things compatible with
the existing Dutch monitoring system for packaging materials) It was known
that the plan was to levy the packaging tax as a surcharge per kilo of
packaging material. 599
28.5 Environmental Benefits
The use of life cycle assessment has been used by both Denmark and the
Netherlands to seek to link the packaging taxes to a measure of environmental
impacts. In principle, basing a tax on these grounds ought – if the analysis is robust
over time – to make evaluation of impacts simple. In principle, one would like to see
revenues decline, or at least to see the trend in any revenue increase which would
have occurred had the tax been applied earlier, reduced.
From 1997 to 2001 packaging waste generation in Denmark only grew 2%, as
opposed to the 8.4% rate for the EU-15, and against a backdrop of GDP growth in the
598 Ibid.
599 CE Delft (2007) Environmental Indices for the Dutch Packaging Tax, Delft: CE Delft, November
2007.
29/09/09

same period of 9.8%. 600 The Danish EPA hopes that by taxing materials that are
deemed more environmentally damaging, packaging manufacturers will shift away
from these materials to the less damaging materials. As even those materials that
are less environmentally damaging still carry taxation it is hoped that total packaging
use will be minimised by the tax. There has been no study conducted on the shifts in
behavioural patterns caused by the tax but it may be hypothesised that the above
mentioned changes could be expected at the margin. An increase in the price of
heavily packaged materials and media coverage of the taxation, may help to induce
the producer to use, and the consumer to purchase, lightly packaged products.
Due to the nature of the levy and its connection with consumption, the primary
environmental outcome of the levy is anticipated to be waste prevention. According to
the Nordic Council, the tax on packaging in Denmark has led to an annual 400,000
tonnes reduction in packaging. 601 Figure 28-2 suggests that the total number of units
consumed for beers and carbonated soft drinks have declined over time. There has
been a switch away from refillable to one-way packaging over this period.
Figure 28-2: Beers and Carbonated Soft Drinks in Denmark Related to Refillable and
One-way Packaging
Source: Christian Fischer (2008) Producer Responsibility Schemes Versus Deposits
and Taxes- Danish Experiences, PRO Europe Congress, 15 May 2008
600 European Topic Centre on Resource and Waste Management (2005) Effectiveness of packaging
waste management systems in selected countries: an EEA pilot study, European Topic Centre on
Resource and Waste Management, Copenhagen.
601 The Nordic Council (2008) Extension of environmental taxes, consulted October 2008
http://www.norden.org/webb/news/news.asp?id=6237
503
International Review of Waste Policy: Annexes

Because the packaging tax is new in the Netherlands, no post-implementation studies
are available to date. It is interesting to note, however, the relative rates applied in
the Danish, Dutch and Belgian systems (see Table 28-3). These highlight the fact that
in all systems, aluminium is deemed to be the material which should attract the
highest tax rate. One problem with both approaches is that they do not appear to take
into account whether the material is primary or secondary in origin.
Table 28-3: Relative Environmental Scores of Packaging Materials in Belgium,
Denmark and the Netherlands (per kilogram and with glass set to 1)
504
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Material Material Material
Belgium Belgium Belgium
Denmark Denmark Denmark Netherlands
Netherlands
Netherlands
Paper & board 0
0.3 recycling
0.5 no recycling
Glass 1 1 1
Steel 5 5 2.5
Aluminium 18 18 12.6
Plastics 7 PS & PVC
4-7
11 EPS & PVC
Source: CE Delft (2007) Environmental Indices for the Dutch Packaging Tax, Delft: CE
Delft, November 2007.
28.6 Implementation Costs
When considering the scheme in Denmark, the Tax and Customs Administration
Ministry invested 1.9 MDKK (~€0.25m) in information and technology systems in
order to collect and administer the tax. 602 The operating cost for 1999 was 0.2 MDKK
(~€300k), with an additional 5 full-time equivalents per annum required to operate
the scheme. 603
In many instances, the packaging tax is perceived to be more difficult to collect than
other taxes due to there being a number of definitions to be checked and
assessments to be made in relation to the products covered by the list of customs
codes. Furthermore, the tax is collected from quite a large number of producers
rather than being specific to just a few companies.
In the Netherlands, although 95% of packaging products / materials are covered by
levies, the first 15,000kg of packaging for each business is exempt from tax. This
means that 98% of businesses will incur no liability for packaging tax. It is believed
602 ECOTEC in association with CESAM, C. U. (2001) Study on Environmental Taxes and Charges in the
European Union and its Member States, Final report for the European Commission, April 2001.
603 Ibid.
1.5
7.8

that only 8,000-10,000 businesses will be liable for the tax. 604 Businesses that
supply packaged products on the Dutch market are also liable to the tax. This
includes manufacturers, importers, wholesalers and retailers.
28.7 Effects on Technical Change / Innovation
Material based taxes such as this may be anticipated to drive technical change for
the production industry to use alternative packaging materials (where the costs of
more environmentally damaging materials become more expensive than alternatives).
Of course packaging minimisation (with material use efficiency balanced against
product protection) is also stimulated by increased costs of using materials which
constitute packaging.
28.8 Social and Distributional Consequences
The Danish EPA is not aware of any studies carried out on the distributional effects of
the tax. In principle, the tax is rather small and is unlikely to affect product prices
significantly. Hence, although it has the potential to be regressive, its impacts are
unlikely to be significant in and of themselves.
Waste management industries involved with final treatment are expected to see
some decline in activity whereas those involved with recycling, re-use and
minimisation should see their sector grow.
The policy could have a strong impact on industries such as steel and aluminium, i.e.
they are subject to the highest taxation rates, since they are deemed more
environmentally damaging. Conversely, those taxed at lower rates could benefit from
material switching. The unit rates, however, are not necessarily representative of the
strength of incentive to switch from one material to another since the functional units
of packaging require different weights of the different materials.
28.9 Complementary Policies
In Denmark, the packaging tax is designed to compliment other existing marketbased
instruments. In particular, the scheme compliments the deposit refund scheme
for drinks containers. Within the Danish system, drinks containers are subject to a
levy based upon their volume rather than their weight. This variation in the tax
encourages containers to be reused many times, because payment of the tax is only
required on new containers entering the market – reuse is thus encouraged over
recycling by this scheme.
In the Netherlands, the tax effectively complements the voluntary agreement between
central and local government in respect of packaging collection.
604 Ernst and Young Indirect Tax Alert, January 2008.
505
International Review of Waste Policy: Annexes

28.10 Effect of the Policy on Pricing of Resources / Services
Where the packaging tax has been implemented in co-ordination with a life cycle
analysis, resources are valued in relation to the damage they impact upon the
environment. In principle, this should be a positive development and is aligned with
standard economic theory in terms of improving the efficiency of the functioning of
markets. Arguably, the Danish approach is more ‘correct’, since it does not confine
itself to climate change-based externalities only.
Even so, this pricing has drawn criticism by some groups (e.g. Beverage Can Makers
Europe) as the life cycle analysis is seen as having the ability to ‘distort’ decisionmaking.
Industry does, however, have a habit of criticising instruments which seek to
bring about change in materials use on the basis of their being ‘distorting’ even where
they set out earnestly to reflect – however imperfectly – the externalities associated
with material use. The system has also been criticised in Denmark, where there is no
distinction between recycled aluminium and virgin product. 605 This would seem to
ignore the benefits of recycling aluminium in this tax system.
In the Netherlands, the relative tax rates seek to account for the way in which a given
material is managed in the country’s waste management system. This itself presents
problems since, in principle, as the management routes change, so the relative tax
rates ought to change too. If, on the other hand, the measure is not intended to
change these management routes, then arguably, it loses its potency as an
instrument, although it still raises revenue.
This brief discussion highlights two points:
506
29/09/09
a) the intention of packaging taxes is to “distort” decision making, if by this,
one understands the intention to change decisions on packaging
b) a critical issue is the boundaries for the analysis and how the tax rates are
met. Clearly, applying uniform rates for virgin and recycled materials does
not reflect the environmental impacts of the packaging
28.11 Evasion and Enforcement
In Denmark the packaging tax has created some issues for importers of packaged
products in that they need to know the packaging material and packaging weight of
all the goods which they import. Some importers have found it difficult to obtain
accurate information from their suppliers and have struggled to comply with the
regulations. The de minimis level applied in the Dutch tax should make enforcement
relatively more straightforward since this reduces the number who are targeted by the
policy.
605 ECOTEC in association with CESAM, C. U. (2001) Study on Environmental Taxes and Charges in the
European Union and its Member States, Final report for the European Commission, April 2001.

28.12 Lessons Learned
The Danish scheme is considered by many to be successful. Success factors for the
system are:
507
� Good coverage of materials covered by the tax;
� A switch from weight based taxation to LCA tax; and
� Tax levels set high enough to have an impact.
International Review of Waste Policy: Annexes

29.0 Tyre Charge - International
29.1 Outline of Policy
A charge on the purchase of new tyres is an example of a technique used to
encourage the use of retreaded tyres, and in some cases, also fund the recycling and
safe disposal of waste tyres.
Although waste tyres are relatively inert and decompose over a long period of time,
they can pose a risk to the environment. Predominantly, the most oft-cited problem
with waste tyres are uncontrolled fires – these can occur if large numbers of waste
tyres are stockpiled. Whilst tyres are difficult to ignite, once alight, tyre fires can be
extremely difficult to control and can cause both air and water pollution. 606 There are
also problems with the disposal of waste tyres. Landfilling tyres is problematic as
tyres are large and bulky, therefore occupying a large amount of space. Within the EU,
the landfill directive has effectively banned the landfilling of tyres.
Schemes aimed at combating and treating waste tyres can vary in both scope (types
of tyres) and size (spatial coverage). Many, however, do have the common
characteristic of targeting the larger part of the waste stream - car tyres. A common
aim of nearly all of the schemes appears to be to a desire to reduce the amount of
tyres in the waste stream and to help fund and enable recycling/re-use/recovery of
waste tyres that do arise.
In general, there are two main types of product levies used for waste tyres. The first
type of product levy is the most simple and is not widely utilised. This type is
effectively a simple product tax. Applied to waste tyres, the tax incentivises the use of
lower cost alternatives – notably, retreaded tyres - over new tyres. By discouraging the
consumer from buying new tyres, the authority is able to ‘promote’ the reuse of waste
tyres. The promotion of retreated tyres and alternatives to landfill are important aims
of the tax. Importantly, the tax revenue accrued is not normally ‘ring-fenced’ and
therefore, not used solely for the maintenance of the scheme (strictly speaking, if the
revenue is used in the scheme it is a hypothecated tax, or if the revenue is used top
provide a service proportionate to the payment, it would be a charge).
Drawing comparisons to other product taxes, this simple scheme is very similar to the
way taxes are used on plastic bags in some countries. There is, however, an exception
whereby the price elasticity of new tyres is perhaps smaller than for plastic bags as
consumers seem less willing to resort to alternatives, even where these are available
and where the cost is comparable.
The second type of charge differs in that revenue accrued from the charge is
managed differently. In these schemes, revenues accrued from the product charge
are only directed towards the recycling or reuse of waste tyres. Normally operated by
606 http://www.ciwm.co.uk/pma/1579 consulted January 2009.
508
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a government body, the revenue is ‘ring-fenced’ and only spent on the scheme. It is,
however, unlikely that there would only be government involvement in to the scheme.
In some cases, industry has requested more involvement in the management of the
schemes. Consequently some schemes have evolved into ‘enhanced producer
responsibility schemes’ or ‘extended producer responsibility schemes’. These
schemes differ in their operation in that, as inferred by their name, a group of
producers take responsibility for the scheme. Collection of the revenue is operated
through a not-for-profit organisation owned and operated by industry. Typically in
these schemes, the charge levied on the consumer becomes an ‘advanced disposal
fee’.
29.2 Where Has the Policy Been Applied and Why?
Implementing a product levy for new tyres has been common practice throughout
Europe and North America over the last couple of decades. Most uses of charging
have occurred where car use is highest, and thus, waste tyre arisings are also high.
In both Europe and North America, revenue raised by levies has been used to prevent
the mass storage and/or landfilling of tyres. In some instances, schemes have been
benchmarked against a target, most often a recycling target, in order to assess
performance. In Denmark, for example, at least 80% of waste tyres are required to be
captured for recycling.
In Europe, a range of policy options have been used to tackle problems with waste
tyres. The most notable Member States using a product levy are Denmark 607 and
Hungary. 608 In some other member states, producer responsibility schemes are used
without the addition of a product levy per se, but where the scheme probably implies
an increase in the price of tyres as a consequence of fees paid to schemes.
In North America, the use of product levies is common place across states and
provinces on the continent. Some notable localities that have introduced product
levies include Texas and Rhode Island in the USA, and the provinces of British
Columbia and Ontario in Canada. In the case of Rhode Island, the product levy is used
in conjunction with a deposit-refund scheme.
In both Texas (1997) and Ontario (1993) the product levy schemes have ceased
operation. In Ontario, however, a new replacement scheme is due to be launched as
there is still a significant problem with the storage and disposal of waste tyres. The
preceding product levy scheme was originally managed by the government and
received much adverse attention as the revenue generated was not re-allocated in to
607
http://www2.mst.dk/common/Udgivramme/Frame.asp?http://www2.mst.dk/Udgiv/publications/200
1/87-7944-519-5/html/kap11_eng.htm
608
http://www.magyarorszag.hu/english/keyevents/a_vallalk/a_adopenz/a_vallalkadok/a_kvtermekdij2
0080425.html#paragr1
509
International Review of Waste Policy: Annexes

tackling problems with tyres. The proposed new scheme is intended to be an
enhanced producer responsibility scheme.
29.2.1 Country-Specific Characteristics
Variations in the type, use and magnitude of the levy occur throughout the differing
countries, states and provinces that have implemented a charge. Table 29-1 shows
the magnitude of the charge in a selected number of examples. Please note that
unlike other governments, Hungary has opted to use a weight based charge instead
of a charge on each individual tyre.
Table 29-1: Characteristics of Different Charging Regimes for Car Tyres
Country/Sta
Country/State/Province
Country/Sta te/Province Operating Operating period period Nature Nature of of charge charge Charge Charge Charge per per tyre tyre tyre ( (€) ( €)
Denmark 1995 - current 8 DKK per tyre 1.07
Hungary unknown 110 HUF/kg * 2.56
Rhode Island, USA 1993 – current $0.50 per tyre 0.38
British Columbia, Canada 1991 - current C$3.00 per tyre 1.85
Texas, USA 1992 - 1997 $2.00 per tyre 1.52
Ontario, Canada 1989 - 1993 C$5.00 per tyre 3.11
*Note: Average tyre weight is 6.5kg according to
www.wrap.org.uk/downloads/UK_Used_Tyre_Market_Report_2004_Report.dd09e6dd.2904.pdf
Variations also exist in the types of tyres involved in the schemes. Whilst most
schemes seem to exclude smaller bicycle tyres, some schemes choose to include
larger agricultural and industrial tyres. This report, however, focuses upon passenger
car tyres, reflecting the main target of these levies.
29.3 Key Organisations Involved in Implementation and
Management
The organisation responsible for the management of the levy can vary dependent on
the type of scheme implemented, and in particular, the intended destination and use
of the levy. In the cases of product taxes, the management of the scheme is normally
undertaken by a government agency or government body.
Where an enhanced producer responsibility scheme is utilised, revenue accrued is
usually managed by a not-for-profit organisation, normally operated by industry. The
organisation is also responsible for facilitating recycling activities by utilising the
revenue accrued through the fund. In these cases, however, depending upon the way
in which the initiative emerges, government agencies are typically involved in
enforcement and in target setting.
Selected examples of different schemes follow.
29.3.1 Rhode Island - Hard-to-Dispose Materials
In 1993 the ‘Hard to Dispose Material’ tax was introduced by the Rhode Island
Division of Taxation. The tax covers all new tyres, but also includes varying rates of
taxation for other, difficult to dispose materials. These include:
510
29/09/09

511
� Lubricating oil;
� Antifreeze; and
� Organic solvents
The Rhode Island Division of Taxation is also responsible for the administration of the
revenues accrued. Unlike most other schemes in the USA, there is no involvement
from the State Environmental Agency (Rhode Island Department of Environmental
Management) in the management of the fund. The scheme is also used in
conjunction with a deposit-refund scheme to ensure the maximum capture of waste
tyres.
29.3.2 British Columbia - FIRST
The Financial Incentives for Recycling Scrap Tires (FIRST) Programme was first set up
as a simple product levy scheme but has now evolved into an enhanced producer
responsibility scheme. Initiated in 1991, the programme was managed by the
Ministry of Environment. The Ministry were also responsible for the funding of
recycling initiatives from the revenue accrued from the programme. The provincial
government was responsible for the overall compliance and enforcement of the
programme.
In 2007, the programme changed hands, and has now become an enhanced
producer responsibility scheme. It was believed that the revenue accrued from the tax
was not successfully directed to meet the programme’s aims, which were combating
the large scale storage of waste tyres and assisting with the recycling of waste tyres.
The programme is now operated by ‘Tire Stewardship British Columbia’ - a not-forprofit
organisation operated by the tyre industry. Key changes to the programme
include a change in the magnitude of the charge - from $3 to $4 per tyre for most
customers - and the utilisation of all of the revenue raised by the scheme as directed
by the organisation itself.
29.3.3 Texas – Waste Tire Recycling Fund
Although no longer functioning, Texas operated a product charge on new tyres from
1992-1997. The charge was used in conjunction with a ban on landfilling waste tyres.
The formation of the programme, the ‘Waste Tire Recycling Fund’, was the
responsibility of the State Legislature. The State Legislature was also responsible for
overseeing the scheme and ultimately made the decision to close the programme.
Whilst operational, the day-to-day management of the fund was undertaken by the
Texas Commission on Environmental Quality (TCEQ) – the State Environmental
Agency. TCEQ also ensured that retailers of tyres paid in to the fund.
The fund closed in 1997 as the programme was deemed unsuccessful. Although
closing over 700 illegal tyre storage sites and helping develop the recycling industry,
the scheme left behind a large stockpile of shredded tyres as an emerging recycling
industry was unable to process all of the tyres.
International Review of Waste Policy: Annexes

29.3.4 Denmark
In 1995, the Ministry of Environment and Energy entered an agreement with the
Danish Motor Trade Association and the Association of Danish Recycling Industries to
implement a charge on the purchase of new tyres. The agreement also included a
minimum recycling target of 80% by 2004. The charge is used to help implement the
ban on the landfill of tyres (through the Landfill Directive).
The enhanced producer responsibility scheme is operated by the Danish Tyre Trade
Environmental Foundation, which uses the revenue accrued by the scheme to fund
the transport and recycling of waste tyres.
29.4 Pre-implementation / Evaluation Studies Available
Our research has yet to discover any pre or post implementation studies.
29.5 Environmental Benefits
Dependant on the locality, and therefore the scheme aims, the main environmental
benefits delivered through this policy can vary. Many programmes have the common
aim of promoting the recycled tyres industry and reducing the overall total number of
tyres stockpiled. Stockpiling tyres can give rise to major fires.
Another additional environmental benefit might be assumed to be the increased takeup
of retreaded tyres over new tyres. This, however, has not been quantified as yet. In
any case, the retreaded tyre market is strongly influenced by the price of purchasing
primary tyres, and these have become more competitive over the last decade.
Table 29-2 demonstrates the performance of the Danish product charge from 1995-
2000. Set against a target of an 80% collection rate, the scheme appears to have
achieved and bettered its target rate from 1995-2000. Table 29-3 below highlights
how collected materials have been dealt with.
Table 29-2: Performance of the Danish Product Charge 1995 - 2000
Used tyres covered by
the scheme (tonnes)
Collected tyres
(tonnes)
512
29/09/09
2nd 2nd 2nd half
half
1995
1995
1996 1996 1997 1997 1998 1998 1999 1999 2000
2000
8,725 16,705 18,405 19,378 19,816 34,776
7,600 12,670 17,229 16,926 17,314 34,418
Collection Rate (%) 87% 76% 94% 87% 87% 99%
Source: Adapted from:
www2.mst.dk/common/Udgivramme/Frame.asp?http://www2.mst.dk/udgiv/publications/2002/87-
7972-027-7/html/kap03_eng.htm
29.6 Implementation Costs
Again, as most schemes are over 10 years old, information on the implementation
costs for each scheme has been unavailable for this study. Implementation costs of
the policy are dependent on the scale and remit of the scheme chosen.

Considering the impact on the consumer, authorities who have implemented a charge
previously have kept the charge below €4 for each tyre. To the extent that in many
schemes, revenue is used to fund the collection and recycling/recovery of tyres, this
would seem to be an indication of the costs of ensuring adequate treatment takes
place. Evidently, this revenue must also cover costs for administration of the scheme.
29.7 Effects on Technical Change / Innovation
The main aim of many product charges on tyres is to promote the alternative use of
waste tyres and to encourage technical change and innovation. In many cases,
alternative products are created from waste tyres, some of which include:
513
� Retreading of tyres (reuse);
� Conversion into carpet underlay;
� Conversion into a soft cushioning material for children's play areas;
� Reprocessed into rubber mats and other goods; and
� De-vulcanised and re-converted into rubber.
Examining the exact change in a particular country can be difficult. Table 29-3 shows
the broad uses of collected tyres in Denmark from 1995-2000. It can be shown that
as the supply of tyres has increased, the majority of tyres have been converted in to
rubber powder, or incinerated. There has also been a relatively constant level of tyre
retreading undertaken during this period, representing a declining share of the total.
Table 29-3: Use of Collected Tyres in Denmark 1995-2000
Retreading or
continued use (tonnes)
Rubber powder or
incineration (tonnes)
2nd 2nd half
half
1995 1995
1995
International Review of Waste Policy: Annexes
1996 1996 1997 1997 1998 1998 1999 1999 2000
2000
3,300 5,477 4,581 5,472 3,508 6,690
3,345 6,060 12,648 11,454 13,806 27,728
Source: Adapted from:
www2.mst.dk/common/Udgivramme/Frame.asp?http://www2.mst.dk/udgiv/publications/2002/87-
7972-027-7/html/kap03_eng.htm
29.8 Social and Distributional Consequences
In principle, as with most product taxes, tyre levies could be regressive in their
impact. However, patterns of car ownership tend to be such that poorer households
simply do not own cars. In addition, the magnitude of the levies concerned is minimal
when compared with the costs of cars, though they might be of the order 1% of the
cost of new tyres.
As regards industry, clearly this may benefit recyclers and re-treaders, as well as, in
the case of Denmark, incineration facilities, whilst landfill site operators may lose a
material which is occasionally problematic, though possibly useful in assisting
drainage at the base of cells.

29.9 Complementary Policies
A number of complementary policies have been used in conjunction with this policy.
The majority focus on disposal outcomes with the most common policy being a landfill
ban. In some cases this is a complete ban on all tyres, however, in some instances it
may only apply to complete tyres. More generally, policies to increase the costs of
disposal are likely to enhance the likelihood of tyres not being disposed of, though the
problem of storage may still remain.
Another complimentary policy sometimes utilised is a deposit-refund scheme.
29.10 Effect of the Policy on Pricing of Resources / Services
One effect of the policy is to make retreated tyres more economically viable than new
tyres. To the extent that these are less environmentally damaging than new tyres,
then the pricing may shift pricing towards a more efficient outcome, though no
example exists of a levy being set on the basis of estimated externalities.
The measure may encourage the reuse and recycling of waste tyres. However, there
has been rather less examination of the relative merits of landfilling and incinerating
waste tyres. It is not obvious that incineration of tyres would be justified on the basis
of the balance of costs and benefits.
29.11 Evasion and Enforcement
Unknown – no evidence was uncovered or made available.
29.12 Lessons Learned
It appears from our research that many of the schemes that started out as simple
product charges have now converted into enhanced producer responsibility schemes.
The main reasoning for this appears to be a need for industry to be involved in the
recycling of waste tyres. In essence, industry’s involvement is appropriate if “proper
treatment” of collected material is to take place. The Texas example provides one
instance where the success of the measure in collecting tyres was compromised by
the absence of appropriate treatment facilities.
29.13 Prerequisites for Introduction
In principle, the imposition of levies presumes the political inclination to implement
these. The collection of levies requires an authority to administer the levy, whilst
some body with powers of inspection is required to ensure that the levy is being
implemented as planned.
In the schemes where targets are applied, data collection is required, whilst some
sanction might be applicable for non compliance.
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30.0 Product Taxes - Belgium
30.1 Outline of Policy
Belgium was one of the first countries to introduce levies on environmentally
damaging products. The initial aim was to influence producer and consumer
behaviour. Taxes are now levied on:
� beverage packaging,
� disposable cameras and cutlery,
� batteries,
� ink,
� glues and solvents, and
� kitchen foil (see Table 30-1).
However, the tax only applies if there is a reasonable alternative available on the
market. Exemptions are given for disposable cameras, batteries, ink, glues and
solvents where these are separately collected and treated in an environmentallysound
way, or where are collected through a deposit-refund system and effectively reused.
Table 30-1 Ecotax in Belgium
Product Product
Levy
Levy
Re-usable beverage packaging €1.41 /hectolitre
Non re-usable beverage packaging €9.86 /hectolitre
Batteries €0.5 /unit
Disposable cameras €7.44 /unit
Packages of certain types of glue for
€0.62
professional use
for every started quantity of 10 litres
Packages of certain types of ink for
€0.62
professional use
for every started quantity of 2.5 litres
Packages of certain types of solvent for
€0.62
professional use
for every started quantity of 5 litres
Disposable plastic bags €3 /kg
Disposable cutlery €3.6 /kg
Kitchen foil (plastic), etc. €2.7 /kg
Kitchen foil (aluminium), etc. €4.5 /kg
Source: Gewone wet van 16 juli 1993 tot vervollediging van de federale staatsstructuur, Boek III
Milieutaksen
30.2 Where Has the Policy Been Applied and Why?
The initial aim of the policy was to influence producer and consumer behaviour.
However, the ecotax policy in Belgium has suffered considerable teething problems
mainly due to political disputes and, as a result, has had to be adapted on several
occasions. The levies were first introduced in the legislation on the reform of the
Belgian state. In order to achieve a two thirds majority, which is needed in Belgium to
realise a state reform, the Flemish and Walloon green parties have requested the
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introduction of the ecotax. When the state structure was finalised, the
implementation of the ecotax was postponed and the measures were weakened
somewhat, as the green parties did not constitute any part of the ruling majority.
Levies have been applied with some caution in order not to upset unduly the producer
sectors, and so as not to increase costs to the consumer too dramatically.
The federal ecotax law introduced an environmental tax on 6 product groups:
beverage packaging, single use cameras, batteries, industrial packaging containing
inks, glues and solvents. Initially pesticides, plant based pharmaceuticals, and paper
and cardboard were included as well. However, beverage packaging and paper and
cardboard were initially exempt on the condition that strict recycling targets were met
by industry.
In 2003, the exemption for disposable beverage packaging came to an end and the
concept of an eco-premium was introduced to generate a sufficient price difference
between reusable and non-reusable packaging. Re-usable packaging enjoyed a VAT
reduction from 21% to 6%, resulting in a lower price for the consumers.
In 2005, the VAT differential was abolished and since 2006, all beverage packaging
(including re-usable packaging) has been the subject of a levy, although the levy for
re-usable packaging is considerably lower, at €1.4 per hectolitre re-usable packaging,
than the levy for non re-usable packaging, at €9.9 per hectolitre.
In 2007 environmental levies were introduced for products that cause exaggerated
CO2 emissions in their production process. The measure was considered by the public
as a way to solve problems in the national budget of 2008 and not as an
environmental measure, as the taxes were not expected to shift consumption
patterns. It was therefore withdrawn, except for taxes applied to some more symbolic
and visible issues such as plastic bags, single use cutlery and household foil, where
there is expected to be an effect on the market.
30.3 Key Organisations Involved in Implementation and
Management
The federal government is the only competent authority for product regulation and
taxes. In the Ordinary Law of 1993 on Changing the Belgian State Structure,
regulating the ecotax, reference is made to recycling targets and acceptable waste
treatment methods, referring to the independent waste legislation in the three
Belgian regions. 609
The ecotax law needs to be implemented by Royal Decisions and Ministerial
Decisions. The Decisions need to be endorsed mutually by the Minister of Finances
609 Gewone wet van 16 juli 1993 tot vervollediging van de federale staatsstructuur, Boek III
Milieutaksen.
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and the Minister of Economic Affairs. For some issues supplementary endorsement is
requested by the Minister of Environment or by the Minister of Public Health. 610
The decision on which products are to be submitted to the ecotax is taken by the full
federal Belgian government, presided by the prime minister. This partly explains the
difficult genesis of the ecotax law.
The collection of ecotaxes is the responsibility of the Ministry of Finance, Department
of Customs and Excise Duties. The ecotax is considered to be an excise duty.
Maintenance of the scheme is the responsibility of the Ministry of Finance.
30.4 Pre-implementation / Evaluation Studies Available
The following reports are of particular relevance:
� A. Heyerick, B. Mazijn and R. Doom (2003) Study in preparation of the evaluation
of the federal environment-oriented production policy, Final report, Centrum voor
duurzame ontwikkeling, University of Ghent, 2003.
� R. Patesson (2001) Beverage packaging and containers, survey conducted with
Belgian families –survey with across-the-border purchasers: The most important
results, Université Libre de Bruxelles, CREATIC-CPSO.
30.5 Environmental Benefits
30.5.1 General Environmental Benefits
30.5.1.1 Evaluation
The impact of the ecotax on consumer behaviour remains unclear. A study
undertaken in Wallonia regarding packaging/container methods used for milk and
water products (2003) found that a large majority of the respondents (> 90%) were
prepared to switch over to more eco-friendly packaging and containers at a price
differential of €0.20. However, it should be kept in mind that this refers only to
expressed preferences, not to actual consumer behaviour.
Another survey arrived at the opposite conclusion, reporting that only a limited
number of families would be prepared to change their consumption habits where a
relative price differential existed between re-usable packaging/containers and
disposable packaging/containers. 611 Other studies conducted on the topic of the ecopremium
also appear to demonstrate that the levy has not been capable of
significantly influencing consumer behaviour. For instance one study revealed that
610 It should be considered that the Belgian federal Minister of Environment has only limited
competences; on product standards (eg pesticides) and on waste transit. The majority of competences
are attributed to the three regional ministers of environment.
611 R. Patesson (2001) Beverage packaging and containers, survey conducted with Belgian families –
survey with across-the-border purchasers: The most important results, Université Libre de Bruxelles,
CREATIC-CPSO.
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the sale of water in glass bottles dropped by almost one percent; for soft drinks, the
reduction was half of one percent, indicating a marginal impact.
30.5.1.2 Choice of the Submitted Products
An environmental rationale for the choice of product subject to an ecotax is not
always clear. As explained above, the introduction of the ecotaxes has known a rather
turbulent legislative history, where competing interests and changing political
configurations have played an important role. The products submitted to the ecotax
tended to be rather visible, mainly household or consumer oriented products, usually
linked to a well known waste issue. They do correspond, in large part, with the waste
types that were defined as priority waste streams in the process of the fifth
environmental action programme. The result is a set of waste streams subject to the
ecotax for which also European legislation, and especially EPR mechanisms, have
been established later (such as packaging and packaging waste and batteries). A
more scientific approach, with an exercise to prioritise waste streams in respect of
environmental impact, could be useful either in the definition of waste streams for
which a take-back obligation should be implemented, or for which an ecotax would be
beneficial.
30.5.1.3 Sales Evolution of Products Submitted to Ecotaxes
It is statistically not possible to prove a relationship between sales figures of products
and the effects of the introduction of ecotaxes. However, some trends can be
observed in which the ecotax might have played a role.
FOST-Plus shows that the quantity of single use packaging is still increasing, but
suggests that a decoupling between this increase and the growth in the economy has
taken place between 1995 and 2006. Figure 30-1 shows that the amount of single
use packaging increased in the Belgian market by 55, 000 tonnes over this period. A
large part of the single use household packaging consists of beverage packaging
submitted to ecotax. An important year is 2004, when the exemption from ecotax for
beverage packaging was abolished. This coincides with the stabilisation of the market
of single use packaging (see Figure 30-1), though this does not necessarily prove a
causal relationship between the two. It might simply suggest some support for any
ongoing measures to encourage use of reusable packaging.
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Figure 30-1: Market Data on Single Use Packaging Expressed in kTon Packaging (data
FOST-Plus)
Translated: ‘Verpakkigen’ is ‘Total Packaging and ‘BBP’ is ‘GDP’
The volume of collected batteries is represented in Figure 15-4 in chapter 15.5.3.2.
Diane Roos mentions in the electronic periodical Retail 612 the following figures on the
evolution of markets for single use and for rechargeable batteries for 2007:
519
� In 2007 more than 22 million single use batteries were sold in Belgium. These
were mostly alkaline batteries (only 115,000 zinc-carbon batteries were sold);
� The market for single use batteries shows a slight decline of – 4.8% in volume
terms. By value, the market increased by 3.1%;
� The total Belgian market for single use batteries is 38.5 million euro;
� The market for rechargeable batteries is clearly growing (by 8.1%) in value;
and
� The total Belgian sales of rechargeable batteries are 6.51 million euro.
These figures do not necessarily indicate the success of the eco-tax since this may
reflect trends for which the eco-tax alone was not responsible. No figures on the
Belgian market evolution of disposable cameras has been found.
612 http://www.convenience.be/dossiers/tabid/1172/default.aspx?_vs=0_N&id=ERT0126n01.mth
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30.5.1.4 Destination of the Revenue Collected.
The ecotax is an excise levy for which the revenue is not ear-marked for
environmental or other purposes. The revenues are destined for the Belgian federal
treasury. For this reason, the regulatory aspect of the tax and the lack of ear-marking
makes that the instrument most attractive in times when budgetary shortages
emerge and increasing other taxes becomes unpopular.
30.5.2 Links with Producer Responsibility
Ecotaxes can be avoided for batteries and for single use cameras if a functioning
collection system can be set up that reaches specific targets in terms of collection
efficiency, and ensures that the treatment of the waste takes place in facilities which
are considered to deploy Best Available Techniques, as defined on a regional basis.
30.5.2.1 Single Use Cameras
For single use cameras the levy of €7.44 /camera can be avoided if a collection
system ensures that at least 80% of the cameras collected by the photo development
laboratories are reused, or recycled in Belgium, or abroad.
30.5.2.2 Batteries and BEBAT
For batteries 613 the levy of €0.5 /battery can be avoided if a deposit system is
applied, or if a collection system is already established. No deposit system has been
realised in Belgium. The collection system was established right from the outset of
the ecotax legislation, following the establishment of BEBAT (see Section 30.5.2.2).
Ecotax and the later imposed EPR and take-back obligation, are effectively reinforcing
each other (see also Sections 15.3.3, 15.5.3 and 15.6.3). The ecotax was introduced
in 1993, while the take back obligation dates from 1997.
Batteries were to be exempted from the ecotax once a (first voluntary) collection and
recycling scheme was set up, under the condition that the system had to be financed
by the battery industry, and that following target percentages for recycling had to be
met:
520
� For the year 2002: 60 %;
� For the year 2003: 62.5 %; and
� For the year 2004 and subsequent years: 65 %
All batteries need to be treated in accordance with best available techniques for
disposal or recycling, in accordance with the regional legislation. Accordance with the
take-back obligations included in VLAREA and in the MBO (see Section 15.3.3) also
needs to be undertaken. The collection percentages are raised to 75% and a recycling
percentage of 65% is introduced.
613 Excl accumulators in cars.
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In order to achieve these targets, the battery industry set up a non-profit organisation
called BEBAT to co-ordinate the collection and recycling of batteries, and to ensure
that the target percentages were reached. The financing of the 'collection and
recycling contribution' is paid by members of the organisation (i.e. battery producers
and distributors). This contribution is passed on to the consumers through a price
increase.
Prior to the voluntary collection system for batteries in Belgium, only a small
percentage of batteries were recycled. The public waste companies considered them
to be hazardous waste, and consumers were supposed to collect them separately,
but there were no incentives in place. Of the small number of batteries that were
collected separately, only the nickel-cadmium batteries were being recycled.
According to BEBAT, the efficiency of the BEBAT collection system currently stands at
86 % (88.5 % in the Flemish region).
30.6 Implementation Costs
Ecotaxes translate into income for the government and represent an expense for the
consumer or for the producer. These may lead to a relatively cost-effective
instrument. This, however, relies on the condition that there exists an efficient
collection system for the tax; otherwise the whole system will turn into a costineffective
instrument for both the government and the enterprises. 614
30.6.1 How the Cost of Collection Relates to Revenues Generated
The revenues of the ecotax are principally not related to the costs of the collection.
Both the ecotax and the cost of the collection have to be carried by the involved
companies. The ecotax has to be paid by the producer of the product. The collection
cost has to be paid by the generator of the waste. Both apply unless the producer has
submitted to an accompanying take-back obligation.
The ecotax is indirectly connected to the collection costs in the cases where an
exemption is allowed for those wastes for which a well- performing collection system
is set up (e.g. batteries, single use cameras, professional packaging of glue, ink,
solvents). In case of professional packaging of certain fluids, the concept of a
‘packaging credit’ is introduced. This is a system in which an amount is credited by
the seller on the invoice of the client, equal to the real costs for the collection and
legal treatment of the waste by a waste collector appointed by the seller. When a
system of packaging credit is in place, an exemption from the ecotax obligation can
be obtained.
30.7 Social and Distributional Consequences
An ecotax might be considered to be a measure with the potential for regressive
impacts: low-income individuals or large families might be more affected than those
614 OVAM (2007) Analysis of innovative environmental policy instruments towards the realisation of
environmentally responsible production and consumption.
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with higher disposable incomes, although this also depends upon consumer
behaviour. The tax can be avoided through changing consumption patterns, and it is
important to note that the ecotax applies to products only where there are viable
substitutes. Indeed, it may be cheaper, in the longer-term, to pay for more durable
products, or alternatives having other characteristics, but here, the question is more
one of cashflow / access to credit (and the cost of credit).
There is some limited risk of an increase in across-the-border purchases, resulting in
an economic loss for Belgian producers / distributors. However, the products and
sums introduced make it very unlikely that journeys would, arguably, be made
specifically for this purpose.
Some industry sectors could be seen to benefit, at the margin, relative to others. For
example, disposable cameras would have become marginally more expensive, but
these shifts are expected to have been marginal, with the demise of disposable
cameras being far more bound to the rise in the phenomenon of digital cameras than
to the ecotax.
30.8 Complementary Policies
30.8.1 Take-Back Obligations and Waste Prevention Programmes
While the direct effect of the ecotax regulation is not always clear, it has been the
driving force for the implementation of different EPR and take-back systems. The
strength of the ecotax can be found in the possibility to link an exemption with the
implementation of a well-performing collection system.
EPR systems require a well-performing collection system. Driven by the ecotax,
industry has organised itself into bodies to realise and finance the collection logistics
for their products. BEBAT, as mentioned above, is a clear example, as it originated as
an industry initiative. A few years before the EPR, the take-back obligation and the
MBO on batteries came into force (see Section 15.3.3). On packaging waste, no
exemption procedure for improved collection was introduced, and thus the link with
EPR systems is less obvious. The ecotax system has nevertheless lead to prevention
programmes and the stimulus of reusable packaging, which has a much lower ecotax
than non reusable packaging. Some exemption procedures for packaging waste
proved counter-productive and have been abolished. See also Section 30.10 for
evasion mechanisms for the price differentials.
30.8.2 Collection Targets
Ecotax legislation imposes targets for collection systems that could lead to an
exemption of the ecotax for certain, above mentioned, waste streams. No targets are
imposed on recycling or treatment of the waste, but reference is made to the
Regional legislation and the regionally defined best practices that have to be
applied. 615 The reason why the legislation on ecotaxes does not include explicit
615 Except for single use cameras where a recycling percentage of 80% is imposed.
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ecycling targets is partly linked to the fact that the complex state structure of
Belgium, where taxes are Federal competence, and recycling and waste policy are
exclusively Regional competences.
30.8.3 Differential Tariffs (DIFTAR)
DIFTAR (see Sections 8.0 through 10.0) is a method to stimulate especially private
persons to sort their household waste into different fractions. This does enhance
performance of separate collection schemes. There is, however, no link with ecotax,
because ecotax exemptions for better collected waste streams are applied on
batteries and professional packaging of certain liquids. Both streams are not covered
by the usual DIFTAR regimes. Batteries belong to the hazardous household waste
scheme for which a separate sorting obligation exists independent of different
tariffication, and the professional packaging does not belong to the household waste
fraction.
30.8.4 Information Campaigns and Public Awareness
The implementation of ecotaxes needs to be coupled to an extensive information
campaign. Awareness raising and education are very important factors to create
support for the policy.
30.9 Effect of the Policy on Pricing of Resources / Services
The aim of eco-taxes is to improve the efficiency of operation of markets by
internalising externalities associated with products. However, few taxes are set by
direct reference to the externalities of the products themselves. The rates are set
based on the desired regulatory effect of discouraging undesired products or waste.
The level is based upon the desire to intervene in the market, but again referring to
the awkward development of the legislation, political horse-trading could not have
been completely excluded. In addition, the ecotax is not applied where certain targets
are met, so that the aim might be taken to have been delivery of the outcomes which
an ecotax might have achieved had it been implemented.
30.10 Evasion and Enforcement
The production sector can put a spoke in the ecotax / eco-premium wheel, as
demonstrated by an example taken from Coca-Cola. Coca-Cola introduced a price
increase for re-usable bottles, whereby the relative price differential between, on the
one hand, re-usable bottles, and on the other, single use PET-bottles and cans was
erased.
An increase in cross-border purchases may possibly be occurring, but no statistics are
available to confirm or reject this.
30.11 Lessons Learned
A sufficiently large levy or, in other words, an adequate price differential between
regular products and their eco-friendly variants is crucial. However, the optimal price
differentiation between eco-friendly products and less eco-friendly products still
needs to be determined.
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In the implementation of the regulation, a ‘trial and error’ method to determine this
optimal price is clearly not a good system for industry and for the distribution sector
since the sector needs to have sufficient security about the required investments. If
such a trial and error method was to be used, it might be more preferable for this to
be used in the context of targets for behavioural shifts.
Finally, it would be preferable to have an objective basis for the introduction of
ecotaxes. The choice of products has not always been rational, but neither has
opposition to the choice.
30.12 Prerequisites for Introduction
It is important to develop an optimised mix with other instruments like recycling
targets or EPR-mechanisms. There is clearly a ‘mix’ in Belgium, but it is not clear that
this optimised.
Ecotax and the possibility to obtain an exemption on the ecotax can serve as a driving
force for useful industry initiatives. Industry must be offered a possibility to find a
constructive way to avoid the taxes which they probably will not back, instead of the
less constructive ways of policy influencing or lobbying, or the establishment of
evasion techniques (see the example for Coca-Cola in Section 30.10).
It is likely to be useful to clearly explain to industry what the ecotax will be used for.
Full transparency on the way the rates are calculated might also be desirable. Some
stronger rationale for the ecotax would also improve acceptance.
Awareness raising and education are very important factors to create support for the
policy from consumers.
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31.0 Plastic Bag Bans – International
31.1 Outline of Policy
This policy seeks to prohibit the production, distribution and use of polythene bags –
known commonly as plastic bags. The raison d'être for the need of ban can vary from
country to country or region to region, but most commonly, a ban is implemented due
to adverse environmental damage imposed upon landscapes. Issues surrounding soil
degradation, loss of soil fertility and health impacts are often cited as reasons for
implementing bans. 616 In addition, plastic bags are considered by some to be an
unsightly component of litter.
Implementation of plastic bag bans can vary widely depending on which
authority/regulator is authorising the ban. In some instances, authorities will only
have the power to implement prohibitions in the distribution of bags. These tend to
be undertaken by municipalities on the city-wide or town-wide scale. In some
instances, these are community driven and operate under a voluntary code of
practice.
More comprehensive bans, which include the manufacture, distribution and use of
bags, are most often undertaken by nation-states. In most instances, bans are
subject to a number of exemptions. These include exemptions for products that
require polythene packaging because no alternative materials are available on the
market (particularly healthcare goods).
This policy seeks to remove polythene bags from the collected waste stream, and
prior to that, from streets and drains. The main actors in the economy affected by the
ban are the manufacturers and retailers of bags.
31.2 Where Has the Policy Been Applied and Why?
Bangladesh was the first nation-state to impose a nationwide ban on plastic bags on
1 st March 2002. 617 Other small nation-states have subsequently imposed bans.
These include:
525
� Bhutan
� Rwanda; and
� Eritrea.
A complete ban on the production, distribution and use of plastic bags is rare.
However, there is a trend for more and more countries to consider outright bans. For
616 http://news.bbc.co.uk/1/hi/world/south_asia/1329600.stm consulted August 2008.
617 Ministry of Environment and Forests, Bangladesh (2008) Major Policy Initiatives, consulted October
2008 http://www.doe-bd.org/policy.html
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example, both Italy and France have proposed to ban plastic bags in 2010. 618 Wales
is known to be considering a ban.
Elsewhere, bans have been imposed on a state-wide, city-wide or town-wide basis.
These tend to be bans on the distribution of plastic bags, as these are the only
powers available to the relevant authorities. Some of the most high profile cases
include;
526
� San Francisco, USA;
� Coles Bay, Tasmania, Australia;
� Maharashtra, India;
� Leaf Rapids, Manitoba, Canada; and
� Modbury, Devon, UK
In Bangladesh and other countries faced with monsoon rains, plastic bags are
believed to cause havoc with drainage systems. In some instances, plastic bags have
been identified as a key cause of urban flooding. Specifically in Bangladesh, it is
believed that plastic bags contributed to the magnitude of the 1998 floods, where
75% of the country was submerged.
31.3 Key Organisations Involved in Implementation and
Management
In Bangladesh, the Department of Environment is the regulator of the ban.
Implementation of legislation was keyed by the Cabinet, via the Ministry of
Environment and Forests. Review of the policy is directed by the Department of
Environment. Elsewhere a similar model is utilised.
31.4 Pre-implementation / Evaluation Studies Available
31.4.1 Bangladesh
Through the Sustainable Environment Management Programme (SEMP), a task force
was commissioned to study the effects of phasing out polythene bags. The task force
fashioned a report which outlined the implications of imposing a ban. After a change
in government in 2001, a ban was imposed in Dhaka City on 1 st January 2002.
Within three months, the ban had been extended to the whole country. 619
618 http://www.endseurope.com/11239 and http://www.rte.ie/news/2008/0527/plasticbags.html
consulted October 2008.
619 Bangladesh Centre for Advanced Studies (2006) A Step Forward to Promoting Environmentally
Sustainable Development in Bangladesh, available at http://ekh.unep.org/?q=node/2220
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31.5 Environmental Benefits
Environmental outcomes targeted by bans on plastic bags include the following:
527
� To reduce the amount of polythene in the waste stream;
� To reduce the possibility of plastic bags blocking drains and exacerbating
flooding in urban areas; and
� To reduce the presence of plastic bags in litter; plastic bags are highly visible
components of litter and are very much associated in the public mind with the
problem of litter pollution.
Quantification of these effects has not been forthcoming but the impact in terms of
overall reduction in municipal waste is anticipated to be minimal (due to the low
relative weight of plastic bags in the total waste stream and substitution by other
carriers).
31.6 Implementation Costs
Unknown – no evidence was uncovered or made available.
Costs may include compensation to industry involved in making and distributing
plastic bags.
31.7 Effects on Technical Change / Innovation
In order to replace polythene, suitable alternative materials are required. The most
common of these alternatives that have emerged as substitutes are jute and paper
bags.
In Bangladesh, it was found that jute bags were the best alternative to polythene. Jute
is grown throughout Bangladesh, and the Bengal delta plain is considered to be one
of the world’s finest growing areas.
31.8 Social and Distributional Consequences
None found. However, it might be expected that in Bangladesh, for example, the jute
industry may have been a major beneficiary of a ban.
31.9 Effect of the Policy on Pricing of Resources / Services
The aim of the policy was to eliminate specific bags identified as having potential to
do harm, and in Bangladesh’s case, significant damage. The ban does not work
through the price mechanism per se.
The policy has led to more alternative bags being used in the market. These are more
expensive to purchase, but tend to be longer lasting, although plastic bags may have
had additional uses. The alternatives are considered to be more environmentally
friendly and importantly, are locally sourced. The net effect might be some increased
cost to customers, though in the round, the net effect is not entirely clear. Even “free
bags” must incur some cost somewhere in the distribution system, so the issue is one
of relative cost, taking in to account re-usability.
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31.10 Evasion and Enforcement
Upon enacting the ban in Bangladesh there have been some problems with illegal
polythene bags entering the country and being used by consumers. No evidence is
available of measures that have been taken in order to combat this issue.
31.11 Lessons Learned
Evaluation studies assessing the effectiveness of the ban and from which lessons
learned could be drawn are not available, despite the fact that the ban is no longer in
its infancy.
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32.0 Levy on Waste Paints - International
32.1 Where Has the Policy Been Applied and Why?
Across North America, a levy on new paints is applied in a number of localities.
Specifically a charge can be found in California in the USA and in British Columbia,
Alberta, Saskatchewan, Nova Scotia and New Brunswick in Canada.
The reasoning for implementing a charge varies in each area. In California, the ecofee
on spray cans has been in existence since 1990 and is used to fund graffiti cleanup
activities. In Canada the fee is applied to whole host of household paints and is
collected as part of ‘enhanced producer responsibility schemes’ or ‘extended
producer responsibility schemes’. These schemes differ in their operation in that, as
inferred by their name, a group of producers take responsibility for the scheme.
Collection of the revenue is operated through a not-for-profit organisation owned and
operated by industry.
The reasoning for creating the schemes in Canada is also different than that in
California. As highlighted in the ‘Greener Homes, Cleaner Communities’ report in
1994, Canadian householders were unable to access a sufficient network of paint
collection facilities. This led to the development of the regulatory framework for
enhanced producer responsibility schemes where the polluter pays principle was
implemented.
32.1.1 Country-specific Characteristics
There are a number of minor variations in the type, use and magnitude of the charge
in the different states and provinces. Some of these are outlined in Table 32-1.
Table 32-1: Characteristics of Different Charging Regimes for Paints
100 ml to
250 ml
251 ml to 1
litre
1.01 litres to
5 litres
5.01 litres to
23 litres
Aerosol paint
(any size)
529
British
British
Columbia
Columbia
International Review of Waste Policy: Annexes
Alberta Alberta Saskatch
Saskatch
ewan ewan
ewan
New
New
Brunswick Brunswick
Brunswick
Nova Nova
Nova
Scotia
Scotia
California
California
€0.06 €0.06 €0.06 €0.12 €0.06 N/A
€0.15 €0.15 €0.15 €0.22 €0.15 N/A
€0.25 €0.31 €0.25 €0.43 €0.31 N/A
€0.62 €0.62 €0.62 €0.92 €0.62 N/A
€0.06 €0.06 €0.06 €0.12 €0.06 €0.07

In addition to variations in the magnitude of the charge, there are also variations in
the visibility of the charge. In some areas the ‘eco-fee’ is visible and can be identified
by consumers. There are, however, areas where the fee is hidden and simply
included in the price of the paints.
32.1.2 Key Organisations Involved in Implementation and Management
The organisation responsible for the management of the charge can vary dependent
on the type of scheme implemented.
Where enhanced producer responsibility schemes are utilised, revenue accrued is
usually managed by a not-for-profit organisation, normally operated by industry. The
organisation is also responsible for facilitating recycling activities by utilising the
revenue accrued through the fund. A selected example follows.
32.1.2.1 Product Care Scheme - Canada
The Product Care scheme is a not-for-profit producer responsibility scheme which
manages product stewardship programs for household hazardous and special waste
on behalf of its members across Canada. The scheme manages stewardship
programs in British Columbia for paint, flammable liquids, pesticides and gasoline,
and in Nova Scotia, Saskatchewan and New Brunswick for paint only. 620
In British Columbia, Product Care was enabled and created as a result of the Post-
Consumer Paint Stewardship Program Regulation (British Columbia Regulation.
200/94), which was enacted in 1994 under the Waste Management Act.
The Act requires paint producers take cradle-to-grave responsibility for the
management of the products that contribute to the household hazardous waste
stream. To maintain a "level playing field" amongst paint producers, the regulation
was amended on June 26, 1997 to include all paints sold in pressurized containers
(aerosols). In 2004, this regulation was replaced by the Recycling Regulation. 621
32.2 Pre-implementation / Evaluation Studies Available
In British Columbia, the pre-implementation report ‘Greener Homes, Cleaner
Communities’ noted that legislation would be required to increase the capture in
household hazardous waste, which includes paint. We have been unable to obtain a
copy of this report but note that its findings were an important factor in the
development of the regulations in British Columbia.
Considering the evaluation studies in British Columbia, Gardner Pinfold Consulting 622
conducted an economic assessment of the Product Care scheme in British Columbia.
620 Adapted from: http://productcare.org/about.html [Accessed March 2009]
621 Adapted from http://www.ec.gc.ca/epr/default.asp?lang=En&n=3A0FB78D-1#programdetails
[Accessed March 2009]
622 Gardner Pinfold Consulting (2008) Economic Impacts of the BC Recycling Regulation, Report for
Ministry of Environment Environmental Quality Branch. Available at:
http://www.env.gov.bc.ca/epd/recycling/resources/reports/econ.htm
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The report concluded that total employment generated by recycling paints,
flammables including gasoline and pesticides is estimated at just over 73 FTEs based
on information provided by Product Care.
The collection Depots account for about 68% (50 FTEs). The rest is spread across
Product Care administration (8%, 5 3/4 FTEs), Product Care consolidation plant (18%,
13 FTEs), and transportation (6%, about 4.5 FTEs).
32.3 Environmental Benefits
There are a number of direct environmental benefits associated with the recycling of
paint. Benefits include avoided contamination and avoided subsequent remedial
clean up costs from improperly disposed products. There are also greenhouse gas
benefits in recycling the paint container, whether it may be steel or plastic.
The policy also provides a number of associated environmental benefits. As the
schemes in Canada are managed by producers, it is in their interest to ensure that all
costs associated with the recycling of paints are reduced as far as possible (as the
required revenue to cover costs would be reflected in the price of goods sold). This
driver has undoubtedly influenced technology innovation/change and aided
additional environmental benefits.
32.4 Implementation Costs
Comprehensive studies on implementation costs have been unable to be found thus
far.
32.5 Effects on Technical Change / Innovation
Probably, the involvement of the paint suppliers in the recycling of paint by the use of
producer responsibility schemes has been a key driver in the innovation towards
production, sale and use more environmentally friendly paint products. We have
been, however, unable to discover any direct evidence linking these factors together
thus far.
32.6 Social and Distributional Consequences
The impacts of the policy are likely to be regressive. Here, it is worth noting that the
levies used to cover costs tend to be proportionately higher for smaller volumes of
paint. There may be good reasons for this where the costs of recovery of paints and
the containers are concerned. However, the environmental issues associated with
paints might be expected to be linked to volume if there is a considerable amount of
unused paint being discarded. On the other hand, if the paint containers are more
often than not empty, then the charge structure might be appropriate.
In some schemes operating at a community level, old paints are made available to
social projects and low income households to help reduce the costs of paint.
32.7 Complementary Policies
A number of complementary policies have been used in conjunction with this policy,
most notably the use of a producer responsibility scheme. The majority of other
531
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policies focus on disposal outcomes with the most common policy being a landfill
ban.
32.8 Effect of the Policy on Pricing of Resources / Services
Section 32.6 highlights some issues related to social and distributional
consequences. There, it was noted that pricing might not necessarily be in line with
expected impacts. As with many policy measures, the pricing probably improves
matters relative to the ‘no policy’ situation, but the pricing is not efficient and few
studies have sought to understand what the externalities associated with the use of
different paints / the disposal of paints might be.
32.9 Evasion and Enforcement
Only anecdotal evidence has been provided on evasion and enforcement issues thus
far. Conversations with Product Care in Canada have highlighted only minimal
evasion of the scheme. According to Product Care, minimal enforcement is required
to operate the scheme.
32.10 Lessons Learned
Anecdotal evidence suggests that the use of enhanced producer responsibility
schemes in Canada have greatly aided the recycling of waste paints. Placing these
observations in context, one of the fundamental problems with recycling waste paints
in Canada has been the (in)ability of householders to access a collection point, which
is largely attributed to the sparsely distributed population of the country. The policies
have tended to enhance the prospects for proper collection of unused paints and
paint cans at their end of life.
32.11 Prerequisites for Introduction
As with other producer responsibility mechanisms, key pre-requisites appear to be:
� The political willingness to legislate to deal with the issue; and
� Working with industry to develop an agreed mechanism to ensure the
development of adequate infrastructure to address the problem being highlighted.
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33.0 Circular WPPR 17/08 - Ireland
33.1 Outline of Policy
The Circular WPPR 17/08 on the Implementation of Segregated ‘Brown Bin’
Collection for Biowaste and Home Composting was issued on 31 July 2008 to all City
and County Managers. In it, the Minister requests local authorities to -
533
� accelerate the implementation of the National Strategy on Biodegradable
Waste and in particular the roll-out of the ‘brown brown brown bin bin’ bin source-segregated
collection systems for organic waste in order to drive the diversion of
biodegradable municipal waste from landfill, through -
• Direct provision of such services;
• Consultation with the collectors;
• Imposition of conditions on Waste Collection Permits across each
region;
• Introduction and modification of local bye-laws;
• Provision of composting/biogas infrastructure;
• Educational Awareness campaigns;
• Targeted enforcement.
� Promote home composting in suitable areas through ongoing awareness and
education/training campaigns, including the provision of home composting
units to householders at reduced prices.
It goes on to state that:
The Minister intends to require source segregation of commercial
biodegradable waste and local authorities’ waste planning should take
account of this.
More specifically, the Circular states:
Local authorities should provide for, as a matter of urgency:
� The implementation of source-segregated collection for organic waste in
urban areas (i.e. urban agglomerations of greater than 1,500 persons –
the Census of Population 2006 reports that 61% of the population in
Ireland reside in urban areas of greater than 1,500 persons);
� The promotion of home composting and/or community composting outside
of these areas.
33.2 Policy Context and Reason for Introduction
The Circular was issued in the wake of a growing concern regarding Ireland’s ability to
meet the targets for reducing the quantity of biodegradable waste sent to landfill set
International Review of Waste Policy: Annexes

out under Article 5 of the EU Landfill Directive (see Annex 51.0). It followed the
development of a National Biodegradable Waste Strategy.
33.3 When was the Policy Introduced?
As mentioned above, the Circular was issued 31 July 2008. However, it does not
appear to set a deadline for implementation of what is proposed. Indeed, response to
the Circular appears to have been patchy. Some authorities are in the process of
rolling out brown bin collections, but several authorities and private sector operators
have tended to drag their feet somewhat. The private sector collectors might be
expected to maintain this approach in the absence of changes to their collection
permits. Some collectors’ permits have been changed to reflect this Circular.
33.4 Key Organisations Involved in Implementation and
Management
Key players are expected to be local authorities, since they have the power to
introduce measures, through the Waste Management (Collection Permit) Regulations
2007, which require collection of specific materials, and also, the power to introduce
bye-laws which place obligations on the waste producers (households or businesses)
to segregate specific wastes.
The Regions, of which the local authorities are part, are expected to report progress in
annual progress reports submitted to the Department regarding their waste
management plans. They are also expected to ensure that they identify capacity (or,
presumably, ensure that such capacity can be provided) where separate collections
are to be introduced.
The EPA is also expected to play a role through disseminating best practice, not least
in the area of home composting as part of its lead in the National Waste Prevention
programme. It also has a key role in the collection of data, although this data tends to
appear a time lag of the order one year.
Cré, the Composting Association of Ireland, is also expected to play a role since, in
partnership with the Institute of Technology Sligo and FÁS, it has developed a training
course aimed at facility operators, regulators, planners/designers, which the Circular
promotes engagement with.
33.5 Monitoring and Measurement Techniques Applied
A key mechanism for monitoring progress would be expected to be the EPA’s National
Waste Reports and, at present, the annual reports on progress regarding
implementation of the regional waste management plans. However, regarding the
latter, we note that few regions have issued such reports thus far. We also note that
the recommendations in the Main Report include the proposal to effectively do away
with the regions for the purpose of waste management planning.
33.6 Evaluation Studies Available
None available (insufficient time elapsed). Even so, anecdotal evidence suggests that
progress has been slow. This is not entirely unexpected. Both local authorities and
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private sector operators incur costs when unplanned changes to services are
introduced and so even where the actors involved are willing participants in the
change, there may be reluctance to make the switch quite as quickly as might be
desired. Finally, we note that there appears to be no sanction proposed for
application to those City and County Managers who do not follow the Circular’s
recommendations, let alone to those private sector operators who might be reluctant
to change their collection service before they have to.
33.7 Environmental Benefits
The aim of the Circular is to ensure that biodegradable waste which might otherwise
be landfilled is dealt with through alternative means. In environmental terms, reports
elsewhere suggest that the net benefits of such an approach will depend considerably
on: 623
535
� The design of the collection system;
� The choice of treatment system for collected biowaste; and
� The charging system applied in the context of the collection system used.
The reason environmental benefits may not be secured by the policy relate to the way
in which the two principal fractions of the targeted organic waste – food waste and
garden waste – behave when they are targeted for collection. Studies in the UK and
elsewhere highlight the potential for considerable quantities of garden waste to be
collected where garden waste services are offered free of charge. One report refers to
this as the problem of a ‘latent garden waste fraction’, lending itself to the possibility
that collected organic waste increases significantly in tonnage terms.
Data in Figure 33-1 shows two years of total waste arisings tonnage data for a UK
authority where a free garden waste collection service was put in place. In our
experience, this is a typical outcome in temperate countries such as the UK and
Ireland. The difference between the two lines of data represents the quantity of
garden waste that was separately collected. The service was trialled for a limited
number of households in the first year before being provided to all households in the
second year. Several important characteristics of garden waste generation and the
impacts of collection services can be observed in the data:
• Firstly, the impact of providing a new and free collection service is seen to
increase total waste arisings; this can largely be attributed to a reduction in
home composting and a potential encouragement of harvesting a latent
garden waste fraction (i.e. the new outlet for garden waste brings
additional material into the waste management system that was either not
created or previously managed at source – material from hedge cutting for
instance);
623 Eunomia (2007) Managing Biowastes from Households in the UK: Applying Life-cycle Thinking in
the Framework of Cost-benefit Analysis, Banbury, Oxon: WRAP.
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• Second, the fact that the blue line falls slightly in the second year indicates
that some garden waste – but rather less than the total collected - is
diverted from residual waste collection in addition to material that may
have been diverted from existing management options. However, it is
arguable in this case that much of the reason for this material being
disposed in the first year was due to the zero cost nature of UK residual
waste collection services. This type of activity is more effectively
discouraged where PBU systems are in place;
• Third, and most importantly, the data for the second year shows the
seasonal nature of garden waste generation. In the UK the growing season
and active gardening period runs through the warm spring and summer
months with generation falling nearly to zero through the winter. A similar
seasonal pattern might be expected in Ireland.
Figure 33-1: Waste Arisings Before and After Free Garden Waste Collection in a UK
Municipality
Tonnes Collected
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
-
Limited trial of
free garden waste
collection service
Apr-02
May-02
Jun-02
Jul-02
Aug-02
Sep-02
Oct-02
Nov-02
Dec-02
Jan-03
Feb-03
Month
Full coverage
of free garden
waste
Mar-03
Apr-03
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct-03
Nov-03
Dec-03
Jan-04
All Waste Excl Kerbside Garden
All Waste Incl Kerbside Garden
Although food waste does not tend to exhibit observable seasonality, the variable
pattern in garden waste generation has implications for the treatment systems
operated. This is especially the case where food and garden waste are collected
together. Seasonal garden waste generation will mean that the relative concentration
of food to garden waste will vary throughout the year. This can make it difficult to
optimise the treatment system and will also have a potentially negative impact on
treatment economics since capacity has to be provided for peak flows, potentially
giving rise to redundancy in treatment capacity. We explore this issue further in the
following subsection.
Experience also highlights the fact that food waste is often captured rather poorly by
systems which focus principally on garden waste, particularly where the collection of

the organic waste fraction is no more frequent than that for residual waste.
Notwithstanding these points, environmental benefits are expected to flow from the
avoidance of landfilling.
33.7.1 Environmental Benefits – Prevention
The effects in terms of waste prevention are not unequivocally positive. Experience
elsewhere suggests that even where home composting schemes are promoted, if a
biowaste collection is offered to households free at the point of use, then the
possibility arises whereby households will set out far more waste for collection than
had hitherto been the case (see above). Once again, therefore, details of
implementation would need to be considered before one could pronounce on the
merits or otherwise of the Circular. If there is no increase in collected quantities, for
example, where charges are applied to garden waste collections, or where food waste
is targeted for collection (or both), then the preventative effect could be significant.
Some anecdotal evidence suggests that households who are more engaged in
recycling will tend to be more sensitised to food wasting habits. 624
The EU Environmental Impact of Products study suggested that the food, drink
tobacco and narcotics group of products accounted for 20-30% of the environmental
impact of most environmental impacts of consumption for all products (this is higher
for eutrophication). The highest proportion of impacts come from meat and meat
products, and from dairy products. 625 A recent review of literature also highlights
potentially significant environmental impacts from food production. Other literature
tends to support the view that rankings follow this pattern, though they highlight some
exceptions to these rules (for example, it may be that where rice cultivation leads to
methane releases from rice fields, climate change impacts are very significant). 626
Significantly, WRAP estimates that for every tonne of food waste avoided, around 4.5
tonnes of CO2 equ. are avoided. 627
To put this into context, the greenhouse gas benefits of reducing food waste by some
50kg per household (around 25% of the total) would deliver similar greenhouse gas
benefits as the energy generated from combusting all of Ireland’s household waste
(and would far exceed them one the emissions from the combustion itself were
considered).
It might be noted that the reference, in many places in the document, to ‘brown bin’
collections might not necessarily be helpful. Experience in some countries suggests
dedicated food waste collections might possess some features, which certainly make
624 See Exodus Market Research (2008) The Food We Waste, Report for WRAP, April 2008.
625 Tukker et al (2005) Environmental Impacts of Products (EIPRO) Analysis of the Life Cycle
Environmental Impacts Related to the Total Final Consumption of the EU-25, IPTS/ESTO, 2005.
626 See, for example, Danish Institute of Agricultural Sciences (2003) Life Cycle Assessment in the Agrifood
Sector, Proceedings from the 4 th International Conference, October 6-8, 2003, Bygholm,
Denmark; Manchester Business School (2006) Environmental Impacts of Food Production and
Consumption, Report for Defra, December 2006.
627 Personal communication with Andrew Parry, WRAP.
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them worthy of consideration, and that conventional ‘brown bin’ schemes, collecting
both garden and food waste, might have some drawbacks. This is especially true
where the issue of home composting, and maintaining activity in this respect, is
concerned, and where the intention is to seek to sensitise households to the issues of
food wastage (although clearly other possibilities for this exist). 628
33.7.2 Environmental Benefits Associated with Recycling
The effects of the Circular in terms of recycling will allow Ireland to pursue its
recycling rates for food and garden waste. In 2006, 64,725 tonnes of organic (food
and garden) waste was recycled. This comprised 40,539 tonnes of garden and park
waste, 14,806 tonnes of biodegradable kitchen and canteen waste (of which 7,888
tonnes was commercial and 6,918 tonnes was household waste) and 9,381 tonnes
of cooking oil. The majority of this organic waste was composted. 629 In 2007, the
quantity of organic municipal waste recovered had increased to 78,617 tonnes, but
the quantity collected from households fell in the year from 23,708 tonnes to 19,611
tonnes. 630 A feature of organic collections which focus on garden waste is that their
apparent success or failure is, of course, partly determined by the weather, so that
year to year fluctuations are to be expected.
Benefits are likely to be maximised where collection systems target food waste, and
where the collected organic waste is treated through anaerobic digestion (and
composting) rather than through composting alone. This latter message – regarding
the superiority of anaerobic digestion from the perspective of treatment - is almost
universally voiced by those who have conducted comparative assessments, including
ourselves. 631 The possibilities for doing this, and the efficiency with which capital
628 Eunomia (2007) Managing Biowastes from Households in the UK: Applying Life-cycle Thinking in
the Framework of Cost-benefit Analysis, Banbury, Oxon: WRAP to be published in 2007.
629 EPA (2008) National Waste Report 2006, Wexford: EPA
630 EPA (2009) National Waste Report 2007, Wexford: EPA
631 See, for example, Werner Edelmann and Konrad Schleiss (1999) Ecologic, Energetic and Economic
Comparison of Treating Biogenic Wastes by Digesting, Composting or Incinerating, Paper written for
R99, Geneva, Switzerland; Konrad Schleiss (1999) Grüngutbewirtschaftung im Kanton Zürich aus
betriebswirtschlaftlicher und ökologischer Sicht: Situationsanalyse, Szenarioanalyse, ökonomische
und ökologische Bewertung sowie Synthese mit MAUT, Dissertation ETH No 13,746, 1999; W.
Edelmann and K. Schleiss (1999) Ökologischer, energetischer und ökonomischer Vergleich Vergärung,
Kompostierung und Verbrennung fester biogener Abfallstoffe, Final report for BFE/BUWAL, BFE, CH-
3003 Bern; and W. Edelmann and K. Schleiss (2002) Products, Impacts and Economy of Anaerobic
Digestion of OFMSW, in in J. Mata-Alvarez (ed) (2003) Biomethanization of the Organic Fraction of
Municipal Solid Waste, London: IWA Publishing, pp. 265-301; R. Vogt, F. Knappe, J. Giegrich and A.
Detzel (2002) Okobilanz Bioabfallverwertung Untershung zur Umweltvertraglichkeit von Systemen zur
Verwertung von biologisch-organischen Abfallen. Initiativen zum Umweltschutz 52, Berlin; Regine Vogt,
Florian Knappe and Andreas Detzel (2001) Environmental Evaluation of Systems for the Recovery of
Biogenic Waste, Proceedings from the ORBIT 2001 Conference; F. Knappe, R. Vogt and B. Franke
(2004) Biowaste Management from an Ecological Perspective, in P. Lens, B. Hamelers, H. Hoitink and
W. Bidlingmaier (2004) (eds.) Resource Recovery and Reuse in Organic Solid Waste Management,
London: IWA Publishing, pp. 71-9; D. Hogg et al (2002) Economic Assessment of Options for Dealing
with Biodegradable Waste, Report to DG Environment, European Commission, by Eunomia, Scuola
Agraria del Parco di Monza, HDRA Consultants, ZREU and LDK; J-O Sundqvist et al (2002) Hur Skall
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investments are utilised, will be influenced by the nature of the collection system.
Where the system encourages a high set out of garden waste (see above) and where
the material is treated through composting, then the costs of the collection and
treatment of additional material may outweigh benefits of the approach (although
should the levy proposed for residual waste in the Main Report be adopted, it seems
highly unlikely that system costs should increase – see also Annex 64.0). 632 It is
important, therefore, to consider the optimisation of collection and treatment to
deliver the most beneficial outcome.
It is important also to re-iterate the point made above regarding the potential for food
waste prevention to arise as a consequence of the introduction of separate collection.
The market aspect of the output from composting and anaerobic digestion is
important in securing benefits. A forthcoming report suggests that greenhouse gas
benefits of compost use vary significantly according to use, being potentially as high
as a net saving of 700kg/tonne of waste. The actual figure depends upon a variety of
factors, and poorly operated systems with limited displacement effects can indeed
perform far worse (a net emission of 200kg per tonne of waste). 633
The suggestion is that the benefits from use of compost / digestate may well benefit
from targeted activity. Development of markets for the recovered biodegradable
municipal waste is central to the success of the National Strategy on Biodegradable
Waste. A Market Development Group of key stakeholders was established in 2004,
under the guidance of the Department, with the objective of driving forward the
development of existing markets for recyclables and identifying new applications and
markets for recyclables and secondary recycled products. The recent proposal for a
standard for compost is a welcomes step in this regard (see, in this context, Annex
36.0). 634
hushallsavfallet tas omhand – Utvardering av olika behandlingsmetoder (How Shall Municipal Solid
Waste be Disposed – Assessment of Different Treatment Methods) Stockholm February 2002. IVL
report B 1462; Danish EPA (2003): Skal husholdningernes madaffald brændes eller genanvendes?
Samfundsøkonomisk analyse af øget genanvendelse af organisk dagrenovation (Is the food waste
from the households to be incinerated or recycled? A welfare-economic analysis of increased recycling
of organic household waste.) Environmental project no. 814.
www.mst.dk/udgiv/publikationer/2003/87-7972-685-2/html/; Nolan-ITU (2004) TBL Assessment of
Garden Organics Management, Final Report to the NSW Dept of Environment and Conservation,
Sustainability Programs Division, May 2004; Eunomia (2007) Managing Biowastes from Households in
the UK: Applying Life-cycle Thinking in the Framework of Cost-benefit Analysis, Banbury, Oxon: WRAP.
632 It is always the case that the financial case for separate collection for recycling / composting /
digestion are given impetus by rsing costs for dealing with residual waste. A levy such as that proposed
thus supports the logic of separate collection.
633 A. Boldrin, J. K. Andersen, J. Møller and T. H. Christensen (forthcoming) ’Composting and compost
utilization: Accounting of greenhouse gases and global warming contribution’, Waste Management &
Research.
634 See Munoo Prasad and Percy Foster (2009) Development of an Industry-led Quality Standard for
Source-Separated Biodegradable Material Derived Compost (2006-WRM-DS-26), STRIVE Report No.
22, Wexford: EPA.
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33.8 Implementation Costs
The costs of implementing this Circular and its requirements are not known. Scope
clearly exists in the Irish context, however, for net costs of service provision to be
lower as a consequence of this measure than in a counterfactual system where
biodegradable waste is landfilled. This is for the simple reason that landfill gate fees
are very high, and biowaste treatment costs are likely to be lower. This suggests the
potential for the measure to be of an ‘invest to save’ nature, especially if the levy
proposed for residual waste in the Main Report is adopted. The issue of collection
costs is examined further in Annex 64.0.
The reality will depend on the details of implementation. A critical issue will be how
the development of infrastructure can be made such that capacity grows in line with
expected quantities of waste captured for treatment. Furthermore, the lack of any
clear link between collectors and their method, and the treatment of the waste,
suggests there may be some difficulties whereby treatment systems which are
developed are not ideally suited to the materials being collected.
33.9 Response from Public and Industry
We are not aware of any document which highlights the response from public and
industry. Anecdotally, it is known that some private sector operators are not well
disposed to the prospect of being required to roll-out ‘brown bins’. It is interesting to
note, in this respect, that whilst such operators might perceive this as an unnecessary
infringement from the Irish Government, Ireland may yet have its hand forced anyway
through measures highlighted in the Waste Framework Directive. In this context, the
reluctance of operators becomes less straightforward to understand.
There appears to be some misunderstanding regarding the role of MBT and what it
might be capable of achieving. MBT is a pre-treatment for residual waste. It is
intended to complement, not replace, separate collection of biowaste. The outputs
from MBT processes are unlikely to be of equivalent quality to those derived from
source separation, and the associated benefits are likely to be considerably reduced.
33.10 Effects on Technical Change / Innovation
The expected changes are as highlighted in the document itself, though as also
hinted above, the detailed outcomes depend upon approaches to collection of waste,
and choices of treatment technology. Currently, the most likely approach to collection
and treatment is likely to be co-collection of food and garden waste with the material
being composted. This might not deliver the best outcome for society.
33.11 Social and Distributional Consequences
These are unclear as yet and will depend upon the detailed manner of
implementation. In principle, given Ireland’s relatively high landfill gate fees, if
collection systems are designed efficiently, householders might pay less owing to the
high avoided cost of disposal. However, much depends upon charges levied at
biowaste facilities, and on the behaviour of households (and how this is incentivised).
This question is intimately bound up with the design of the collection system, and the
background costs of residual waste treatment / disposal.
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33.12 Complementary Policies
Complementary policies are the landfill levy and its proposed expansion in scope, and
the requirement to implement pay-by-use. The National Waste Prevention Programme
also has a role to play, as does the proposal for a standard for composting. 635 Finally,
the pace and ease with which the relevant treatment capacity can be developed will
depend upon the manner of implementation of the Animal By-products Regulation.
33.13 Effect of the Policy on Pricing of Resources / Services
This is unclear and will be affected by the collection systems used, and the charging
systems applied. The effect will also be influenced by the nature of the
counterfactual. With the proposed residual waste levy in place, it seems likely that the
change in system costs would be negative, implying savings for households.
33.14 Evasion and Enforcement
The arrangements for enforcement are unclear as there is no deadline as such.
However, the DoEHLG would be expected to play a role through its monitoring role in
respect of regional waste management plans in the short term. In addition, any
revision of waste collection permits ought to reflect the Circular, though exactly how
this is to be checked is unclear.
33.15 Lessons Learned
Probably the key lessons from the Circular thus far are that:
541
� The introduction of the desired collections has, understandably, not taken
place ‘over night’;
� There appears to be some resistance to the measure, supposedly on grounds
that the approach will be expensive. It is not clear why this should necessarily
affect the roll-out if the costs are recovered through charges. More
fundamentally, there appears to be much for Ireland to learn with regard to
optimising the design of collection services, specifically, taking advantage of
the possibilities for optimising logistics that biowaste collections might allow;
and
� Several companies appear wedded to ‘mixed waste’ biowaste treatments.
Experience suggests that such approaches will tend to deliver low quality
outputs which have the potential to damage the fledgling market for compost
and digestion residuals. Mixed waste treatments might be more appropriately
viewed as complements to, not substitutes for, separate collection of
biowaste. Indeed, this may yet be made a requirement in Ireland through EU
635 See Munoo Prasad and Percy Foster (2009) Development of an Industry-led Quality Standard for
Source-Separated Biodegradable Material Derived Compost (2006-WRM-DS-26), STRIVE Report No.
22, Wexford: EPA.
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legislation (so developing infrastructure on the basis that such legislation will
not materialise may be an ill-fated strategy).

34.0 Minimum Recycling Standards (Household
Waste) - International
34.1 Outline of Policy
A number of countries currently employ a minimum recycling standards policy for
householders, commerce and industry, and construction and demolition wastes. This
section presents those minimum standards for the household waste stream.
Minimum household waste recycling policies require the separate collection of a
number of waste materials either at the kerbside or via civic amenity sites, with the
key goals of diverting waste away from landfill and increasing material recovery.
Within the EU, the implementation of such recycling standards falls under Article 3 of
Directive 2006/12/EC, which specifies that Member States shall take the appropriate
measures for the recovery of waste via recycling, re-use and reclamation. In Asia,
countries such as Taiwan and South Korea have also implemented minimum
recycling standards, driven by a lack of space in these countries and the need to
move away from reliance on landfill.
Within the EU, there are current proposed revisions to the Waste Framework
Directive. 636 Regarding recycling, Member States will be required to take necessary
measures to reach 50 % re-use and recycling of waste materials such as paper,
metal, plastic and glass from households and similar waste streams by 2020. The
revisions recommend that
543
“Member States shall set up separate collection of waste where technically,
environmentally and economically practicable and appropriate to meet the
necessary quality standards for the relevant recycling sectors. By 2015
separate collection shall be set up for at least paper, metal, plastic and glass.”
Hence the proposed revision to the framework will, in effect, require that an obligation
be placed on the municipality to provide separate collections of recyclable materials.
In addition to the main Waste Framework Directive, the use of minimum recycling
standards is also designed to meet the targets stipulated in a number of more
specific EU Directives, namely the Landfill Directive, the Packaging Directive (Section
13.0), the Batteries and Accumulators Directive (Section 25.0), the WEEE Directive
(Section 20.0) and the ELV Directive (Section 23.0).
34.2 Where Has the Policy Been Applied and Why?
The European countries that use a minimum recycling standard for the household
waste stream include Austria, Belgium (particularly Flanders and Wallonia), the Czech
636 ACR+ and IBGE (2008) Focus on EU Waste Legislation, Agreement Reached on a New Framework
Directive, Journal for Sustainable Waste Management Warmer Bulletin 115, 4-5.
International Review of Waste Policy: Annexes

Republic, Denmark, England and Wales, Finland, Germany, Hungary, Italy, the
Netherlands, Portugal, Slovenia, Sweden and Switzerland. In addition, both South
Korea and Taiwan have also implemented minimum recycling standards in recent
years, and several locations within the US also have a minimum recycling standard for
their household waste, including the city of Portland, and the state of New Jersey.
These minimum standards vary in the types and number of materials that must be
source-separated, the way in which the materials must be collected and the way that
they are funded. The main country-specific policy details are discussed in Section
34.2.1.1.
A minimum recycling standard has been implemented in these countries in order to
push waste up the hierarchy, away from landfill, and to increase the recovery of
materials, so reducing the need for primary material consumption. Its implementation
in Switzerland for example is considered “Environmentally sound”, with the use of
secondary aluminium instead of primary aluminium saving up to 95 % of the energy
required to manufacture aluminium from raw materials. 637
34.2.1.1 Country-specific Characteristics
Table 34-1 summarises the key materials that must be collected separately in those
countries that implement recycling mandates. A key source of information for
summarising EU policies was via the European Topic Centre on Resource and Waste
Management (EIONET). 638 Additional references are provided throughout the
document. The main driver behind the majority of separate collections appears to be
the implementation of laws on packaging and associated producer responsibility
measures, which have driven the separate collection of most materials except food
and garden waste. The separate collection of food/garden waste is mainly linked to
the development of compost standards, in order to create sufficient markets through
standardising the products of biological treatment. Specific details for each country
follow.
Austria
The Ordinance on the Separate Collection of Organic Wastes (Law Gazette II no.
68/1992) and the Ordinance on Compost (Law Gazette II no. 292/2001) dictates
that provision is made by the municipality for a separate collection of biowaste (food
and garden waste) from Austrian households, and that the householder also has an
obligation to separately collect and present their biowaste for collection. In addition,
the Ordinances on Packaging (Law Gazette II No. 1996/648 and 1992/646) place
responsibility on producers to ensure that a certain percentage of each type of
packaging material be delivered for recycling –the Altstoff Recycling Austria (ARA)
green dot scheme facilitates a separate household collection of glass, plastics,
637 Federal Office for the Environment (2008) Guide to Waste [Online] (Updated 28 th February 2008).
Available at: http://www.bafu.admin.ch/abfall/01472/index.html?lang=en [Accessed 10 th September
2008].
638 European Topic Centre on Resource and Waste Management [Online],
http://waste.eionet.europa.eu/facts/factsheets_waste/Instruments [Accessed 8th September 2008].
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paper/cardboard, metals (aluminium and steel), and composites for beverages. The
legal obligation under the Ordinance is only for packaging, but there is an agreement
between ARA and the municipalities that they will also collect other types of, for
example, paper and cardboard than just the packaging fraction. 639 The collections
mainly consist of a comprehensive kerbside service as well as bring bank systems.
Table 34-1: Materials Requiring Separate Collection According to Country
Country Biowaste Glass Plastics Paper
/ card
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International Review of Waste Policy: Annexes
Aluminium Steel/
tin
AT � � � � � � �
BE VFG and all
food waste
� Plastic
bottles
Beverage
Composite
s
� � � � �
CH � � PET � � Tin �
CZ � � � �
DE � � � � � tinplate �
DK � �
England&
Wales
Any two recyclables
FI � � � � � �
HU � � � � � �
Textiles Wood
IT* � � � � � � � �
NL � � � �
PT � � � � � �
SI Garden and
vegetable
food waste
� � � �
SE � � � � � �
South
Korea
� � � � � � � �
Taiwan � � � � � � � �
USA (New
Jersey)
� � � �
*separate collection specified as requirement for Waste Management Regional Plans, with targets in
place for the various materials, but does not directly state that source-separation is mandatory.
Source: Table compiled from a variety of sources including the Federal Office for the Environment
(2008), the European Topic Centre on Resource and Waste Management, Fogarty et al. (2008), the
Ministry of the Environment of the Czech Republic, ECOTEC Research and Consulting Limited (2000),
Taiwan Government Information Office, and OECD (2006).
639 Federal Ministry of Agriculture and Forestry, Environment and Water Management (2006) Federal
Waste Management Plan 2006: Suitable for Nature and Mankind. Available at:
http://www.bundesabfallwirtschaftsplan.at/

Belgium (particularly Flanders)
The provision of separate collections of certain household waste streams by the
municipality has been required since the 1990s. At the kerbside, separate collection
of paper/cardboard, vegetable, fruit and garden waste (VFG), biowaste (including food
but excluding meat), glass, plastic bottles, metal packaging, drink cartons, other
metals and textiles is the responsibility of the provinces. This provision follows Article
16 in Chapter 4 of the Belgian Decree concerning Prevention and Management of
Waste Materials. In addition, one bring bank each for bottles and paper must also be
provided for every 20,000 individuals. 640 The householder does not have a legal
obligation to separately collect their waste, but is encouraged to do so by the Pay-As-
You-Throw system that operates in Belgium, which charges a lower rate for
separately-collected recyclables than for residual waste.
Czech Republic
A recent amendment to Waste Act 127/1997 in the Czech Republic now stipulates
that by the end of 2010, municipalities must allow their householders to sourceseparate
the following waste materials – paper/cardboard, plastics, glass, drinks
cartons and biodegradable waste. 641 Packaging Act 477/2001 previously only
encouraged such separation. The collections are organised by the local authority with
both financial and public relations support from the Czech Republic’s producer
responsibility organisation, Eko-Krom. No legal responsibility is placed on the
householder to ensure that they separately collect recyclable materials. However,
households and companies are incentivised to recycle, as they receive money for
sorting their waste when they otherwise have to pay to dispose of their unsorted
waste. 642
Denmark
Denmark has employed a minimum recycling policy since 1990, when it introduced
the separate collection of packaging glass. In 2004, the separate collection of
paper/cardboard via kerbside collection schemes was also made mandatory for those
municipalities with private built-up areas of greater than 1,000 inhabitants that were
collecting less than 55 % of their total paper/cardboard potential in 2002. In addition,
the householder in Denmark has a duty to sort their waste for separate collection. 643
640 H. Fogarty, L. Reid and H. Sprott (2008) International Review of Recycling Policies, Scottish
Government Social Research. Available at
http://www.scotland.gov.uk/Resource/Doc/231872/0063356.pdf
641 Ministry of the Environment of the Czech Republic (2008) [Online] Amendment to Waste Act- For
Better Sorting and Recycling, [Accessed on 26 th September 2008], available at
http://www.mzp.cz/__C12571F40024D359.nsf/$pid/mzpjkfohsria
642 Resource Recovery Forum (2006) The Czech Republic – Improvement in Waste Sorting, Second in
EU.
643 Waste Centre Denmark (2007) Waste from Households, available at
http://www.wasteinfo.dk/waste+and+collection+companies/sources+types+and+fractions/waste+fro
m+households
546
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England and Wales (United Kingdom)
The Household Waste Recycling Act (2003) states that collection authorities in
England and Wales must collect at the kerbside any two recyclable materials, either
together or individually separated, from the remainder of the household waste
stream. In addition, Barnet Borough Council provides one example where, alongside
the Household Waste Recycling Act, additional responsibility for recycling is also
placed on the householder. Barnet Borough Council introduced a compulsory
recycling scheme in 2004, undertaking monitoring of household participation in the
scheme and providing further contact and the threat of prosecution to households
that failed to participate. This scheme has since been replicated in a number of other
local authorities in England, and is discussed further in Section 34.4.
Finland
The separate collection of materials from the household waste stream is specified for
paper and packaging in producer responsibility decrees 883/1998 and 962/1997
respectively. The systems for collection and recovery of paper and packaging are
predominantly funded via producers, but provided by municipalities. However, where
the separate collection of packaging is not justified from either an environmental or
economic standpoint, the municipality also becomes financially responsible for the
collection and may levy charges accordingly.
Germany
Producer responsibility for the separate collection of all types of packaging has been
in place in Germany since 1991. The ‘Green Dot Scheme’ funds and provides local
collection services for glass, paper/cardboard, plastics, tinplate, aluminium and
composites (see Section 14.0). In addition, the Biowaste Ordinance (1998) sets out
the requirement for municipalities to provide a separate collection of food and garden
waste for householders to ensure that, following composting or fermentation, only
material whose content of contaminants and potentially toxic elements is negligibly
low can be used as a soil improver / amendment / potting medium. Householders in
Germany are not strictly obligated to use the recycling services that are provided, but
are encouraged to do so due to the Pay-As-You-Throw system (see Section 9.0).
Hungary
The separate collection of metals, plastic, paper, glass and food/garden waste from
households began in Hungary in 2001. Such collections were linked to the ban on
landfilling of organic waste and the environmental taxes (producer responsibility)
placed on packaging. The local authority provides the collection service on behalf of
the producers, though the majority of collection is via bring sites in Hungary rather
than a kerbside collection.
Italy
Decree 22/97 and more recently Decree 152/06 set out specific targets for the
collection of different waste streams in Italy, as well as the re-design of the packaging
system towards producer responsibility. The waste streams to which targets apply,
and which are thus heading towards mandatory source-separation, are
paper/cardboard, glass, plastic, metal, biowaste, waste wood and textiles. In
developing Waste Management Regional Plans, Local Administrations must define
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local intentions regarding separate collection. The collection system in Italy is funded
pre-dominantly by the municipal waste charge. 644 There is no householder obligation
to recycle, but the variable portion of the Pay-As-You-Throw waste charge encourages
participation in sorting schemes (see Section 8.2.2).
Netherlands
According to Section 10.12 of the Environment Management Act for the Netherlands,
municipalities must provide householders with the ability to source-segregate their
biowaste (food and garden waste), though there is no obligation on the householder
to separate their waste at source. In 2001, according to the Ministry of Housing,
Spatial Planning and the Environment, approximately 75 % of the population
separated their biowaste. 645 In addition, separate collection of paper/cardboard,
glass and textiles is specified in the provincial environmental ordinances. These
requirements have been in place since 2001. 646
It should be noted that there is only limited separate collection of metals in the
Netherlands due to the large amount of incineration in the country, whereby a
significant proportion of metals can be removed from ashes post-incineration for
subsequent recycling. 646 This is linked to the ban on landfilling of household waste,
which has led to incineration becoming the major means for dealing with residual
waste, as well as the high tax on landfilling.
Slovenia
Under its Environmental Protection Act (2001), municipalities in Slovenia separately
collect the following wastes from the householder: paper, plastic, metal (and
packaging in general), garden waste and vegetable food waste (there is no
specification for collection of Animal By Products).
South Korea
South Korea introduced its Volume-based Waste Fee (VBWF) in 1994. This ‘pay-byuse’
based service was established in order to provide an economic incentive for
waste reduction by households and also to generate revenue for the provision of a
mandatory recycling service. Recyclable waste (paper, cans, bottles, metal, plastics,
textiles) and food waste are all separately collected for free from the
644 European Topic Centre on Resource and Waste Management (2006) Country Fact Sheet: Italy,
available at http://eea.eionet.europa.eu/Public/irc/eionetcircle/etc_waste/library?l=/country_fact_sheets/italypdf/_EN_1.0_&a=d
645 Ministry of Housing, Spatial Planning and the Environment (2001) Kitchen and Garden Waste,
available at http://www.vrom.nl/Docs/internationaal/14277_174kien_garden%20was.pdf.
646 ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The Economics of Waste
Management Options, Report produced for Friends of the Earth, UK Waste and Waste Watch. Available
at http://www.foe.co.uk/resource/reports/economics_waste_options.pdf
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householder/small commercial sector at the point of delivery, with householders
required to purchase sacks to dispose of their remaining ‘residual’ waste. 647
Sweden
Mandatory source separation of paper and packaging (plastic, metals, cardboard,
glass, wood and beverage containers) was introduced in Sweden in 1997. Both the
financial and physical responsibility for this separate collection is placed firmly on the
shoulders of the producers, leaving producers to design the collection systems that
they must provide, as long as they reach the national recycling targets. Hence the
majority of source separation in Sweden is via lower cost bring sites. In addition,
Ordinance (1997:185) on Producer Responsibility for Packaging also requires the
householder to separate packaging materials from other household refuse and to
deliver it to the collection systems provided by the producers.
Switzerland
Under the Technical Ordinance on Waste, the cantons (regions) must try to recover,
as far as possible, the recyclable fractions of municipal waste. Article 6 of the
Ordinance of the Treatment of Waste prescribes the separate collection of the
recyclable fraction by the cantons, and this includes kitchen waste that cannot be
home composted. In addition to kitchen waste, a collection of paper/cardboard, tin,
beverage containers, glass, PET and aluminium is also required, falling under the
Ordinance on Beverage Containers. Household collections of these waste streams are
provided by the local authority at both kerbside and via bring banks. A large part of
the collection system is funded by producer responsibility schemes (both statutory
and voluntary). The Pay-As-You-Throw scheme that exists in the cantons provides the
incentive for the householder to recycle their waste streams.
Taiwan
Taiwan introduced the country-wide mandatory separate collection of recyclables and
food waste in 2006 as part of their ‘Zero Waste Program’. There are currently 14
categories of mandatory recyclables which the municipality must collect and which
the householder is obliged to separate, including steel and aluminium containers,
paper, plastic, small WEEE and textiles. 648 In addition, municipalities must provide for
the separate collection of food waste at the kerbside, with local government currently
subsidised by the Environmental Protection Administration (EPA) for providing this
service.
City of Portland, Oregon (USA)
The city of Portland (population approximately 575,000) in Oregon, USA, currently
requires that the waste collection service providers supply weekly kerbside recycling
647 S.D. Lee (2003) Waste Reduction and Recycling Law in Korea, International Environmental Law
Committee - Newsletter Archive 5, February 2003, available at
http://www.abanet.org/environ/committees/intenviron/newsletter/feb03/korea/
648 R. Dobson (2005) Taiwan Sets Sights on Zero Waste Policy, available at
http://www.bullnotbull.com/special/special-2.html.
549
International Review of Waste Policy: Annexes

collections and fortnightly kerbside collections of garden waste for every resident,
with residents encouraged to recycle due to the Pay-As-You-Throw system in place for
residual waste. 649 The current required list of materials for which collection provision
must be made includes cans, paper and card, glass, used motor oil and garden or
‘yard’ waste.
New Jersey (USA)
The state of New Jersey was the first state in the USA to require that local authorities
provide mandatory recycling services for all households, businesses and institutions.
In 1987, the New Jersey Statewide Mandatory Source Separation and Recycling Act
came into force, with householders in New Jersey also obliged to recycle leaves, and
at least three of the following materials: paper, metal, glass, plastic containers and
food waste.
In order to help finance this Act, the tax on landfilled waste was also increased almost
fourfold, yielding a State Recycling Fund intended to support the county recycling
systems within New Jersey. This fund expired in 1996, and has only recently been
replaced by the Recycling Enhancement Act in 2008 – re-establishing a source of
funding for recycling with a $3 per ton (1.02 tonnes) tax on solid waste for disposal,
though such a small tax will not provide sufficient funding to fully compensate
mandatory recycling schemes.
34.3 Key Organisations Involved in Implementation and
Management
For the majority of countries listed in Section 34.2.1.1, the local local local government
government is
charged with the implementation and management of the recycling collection system.
In addition, in the majority of countries, the producer producer producer also plays a key role in the
delivery of separate collection systems, because these systems are frequently linked
to the requirement to recycle packaging material e.g. the Packaging Directive. The
producer role is typically predominantly financial in nature, though in Sweden the
producer is required to design, provide and fund all collection systems for packaging
wastes. The system appears to work well when the producers and municipalities
support each other – for example, in Austria, although the legal obligation under the
Ordinance is only for packaging recycling, there is an agreement between the
country’s green dot scheme coordinator ARA and the municipalities that ARA will also
support the collection of other types of, for example, paper and cardboard than just
the packaging portion.
In the Netherlands, the decision was made to leave the recyclables collection function
in the hands of the local government, since the municipal collection infrastructure
presented the strongest opportunities to achieve recycling targets. It was also felt that
having competitive industry-led collection schemes might make life more confusing
for the public, thereby reducing response rates. Hence in the Netherlands, local
649 Office of Sustainable Development, City of Portland (2008) Administrative Rules, Residential Solid
Waste & Recycling, available at http://www.portlandonline.com/osd/index.cfm?a=217303&c=41472
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government is responsible for the waste until the point where materials are
transferred to an agreed point (e.g. depot, transfer station), following which the
producers producers become responsible for the material. 650
Unlike packaging materials, it should be noted however that no such producer
responsibility system exists to support the collection of biowaste (food and garden
waste) by those countries tasked with doing so according to their waste policies. Thus
the responsibility for, and management of, the collection of biowaste in those
countries which stipulate its separate collection lies with the local administration.
Finally, the householder
householder also plays a significant role in the implementation of
minimum recycling policies. Behavioural changes of the population towards their
waste are fundamental in driving source-separation collection schemes. 651
34.4 Pre-implementation / Evaluation Studies Available
We have drawn on a number of evaluation studies in order to assess the impacts of
minimum recycling standards across a number of countries. These studies include
the following:
551
� ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The
Economics of Waste Management Options, Report produced for Friends of the
Earth, UK Waste and Waste Watch. Available at
http://www.foe.co.uk/resource/reports/economics_waste_options.pdf
� Environmental Protection Administration (2008) Taiwan’s Zero Waste Policy to
Meet 2008 Goal in Advance, available at
http://www.epa.gov.tw/en/epashow.aspx?list=112&path=11972&guid=c26a
a5d0-a280-4e72-9a38-a0b4f1e2bdff&lang=en-us
� Eunomia (2009) Compulsory Recycling Scheme Review and Second Phase
Roll Out Plan, Final Report to the London Borough of Barnet.
� Federal Ministry of Agriculture and Forestry, Environment and Water
Management (2006) Federal Waste Management Plan 2006: Suitable for
Nature and Mankind.
� H. Fogarty, L. Reid and H. Sprott (2008) International Review of Recycling
Policies, Scottish Government Social Research. Available at
http://www.scotland.gov.uk/Resource/Doc/231872/0063356.pdf
� Green Alliance (2002) Creative Policy Packages for Waste: Lessons for the UK,
Available at
650 ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The Economics of Waste
Management Options, Report produced for Friends of the Earth, UK Waste and Waste Watch. Available
at http://www.foe.co.uk/resource/reports/economics_waste_options.pdf
651 Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU) (2006) Waste
Management in Germany: A Driving Force for Jobs and Innovation, available at
http://www.bmu.de/files/pdfs/allgemein/application/pdf/broschuere_abw_deutschland_en.pdf
International Review of Waste Policy: Annexes

552
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http://www.greenalliance.org.uk/uploadedFiles/Publications/CPPWDenmark.
pdf
� D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W.
Devliegher, W. Brinton and S. Antler (2002) Comparison of Compost Standards
within the EU, North America and Australasia, report produced for WRAP.
� Resource Recovery Forum (2006) The Czech Republic – Improvement in
Waste Sorting, Second in EU.
� G. W. Shaumburg and K. T. Doyle (1994) Wasting Resources to Reduce Waste:
Recycling in New Jersey, Cato Policy Analysis, 202.
34.5 Environmental Benefits
The main environmental benefits from the mandatory requirement for separate
collection and subsequent recycling/reuse of waste materials are likely to be:
� Increased diversion of waste away from landfill or other residual waste
treatments that might otherwise be required; and
� The potential to re-process and consequently recycle the source-separated
materials, saving on raw materials (and hence energy) in commercial and
industrial processes.
In most countries, it is difficult to attribute a specific increase in recycling and
composting / digestion to this policy alone. This is because in most countries a policy
of mandatory recycling of specific materials exists alongside other policies, including,
for example, pay-by-use for households, and, as mentioned in this review, producer
responsibility schemes implying provision of varying degrees of service on the part of
producers.
To this end, the benefits of mandatory separate collection of recyclables would be
assumed to be related to the benefits which studies attribute to recycling and
composting / digestion more generally. For example, the Switzerland Federal
Administration notes that the use of secondary aluminium instead of primary
aluminium saves up to 95 % of the energy required to manufacture aluminium from
raw materials. 652 In Austria, glass recycling in 2007 saved 155,000 tonnes of quartz
sand, 50,000 tonnes of limestone and dolomite, 39,000 tonnes of soda, 212 million
kWh of electrical energy and 5,650,000 m 3 of gas. 653 There is also the possibility of
generating energy from waste (via processes such as anaerobic digestion, where both
energy from biogas and a digestate product are generated).
652 Federal Office for the Environment (2008) Guide to Waste [Online] (Updated 28 th February 2008).
Available at: http://www.bafu.admin.ch/abfall/01472/index.html?lang=en [Accessed 10 th September
2008].
653 Federal Office for the Environment (2008) Guide to Waste [Online] (Updated 28 th February 2008).
Available at: http://www.bafu.admin.ch/abfall/01472/index.html?lang=en [Accessed 10 th September
2008].

Indeed, there are clearly synergies across these policies. For example, mandating the
separate collection of a wide range of materials enhances the prospects for positive
outcomes from the application of Pay-As-You-Throw (see Section 8.0). Similarly, in the
context of producer responsibility schemes, the provision of services may have to be
entirely funded by producers. This leaves municipalities to concentrate on the
provision of biowaste collection services and refuse collection. It does not seem to be
a coincidence that those countries where Pay-As-You-Throw is most widespread are
also those that mandate the provision of separate collection for a wide range of
materials.
Having said that, it seems reasonable to believe that such a policy does in fact play a
role in increasing separate collection. The example of compulsory recycling in Barnet
illustrates a 10 % additional increase in recycling of household materials from those
households forming part of the compulsory scheme (see below). 654 Similarly, a report
by Schaumburg and Doyle (1994) acknowledged that the mandatory recycling policy
in New Jersey also had a direct effect on increasing recycling rates (low disposal tax
ruled this out as a possible additional impact on recycling rates in this instance); for
example, the recycling of glass increased from 6 % in 1980 (pre-mandate) to 31 % in
1990 (post-mandate), and recycling of paper increased from 24 % in 1980 to 62 % in
1990. 655 The remainder of this Section looks at examples of the potential
environmental benefits of introducing mandatory recycling within individual countries.
Austria
Figure 34-1 illustrates the impact of the introduction of separate collections of
various materials on the recycling rates in Austria. Driven by the Ordinance on the
Separate Collection of Biowaste, Austria is one of the top performing countries in
Europe for biowaste recycling, with a recycling rate of approximately 75-80 % of the
total collectable biowaste fraction. 656 The overall municipal recycling rate (dry
recyclables and biowaste) was similar to that of the Netherlands and Germany in
2006 at 61 %. 657
654 Eunomia (2009) Compulsory Recycling Scheme Review and Second Phase Roll Out Plan, Final
Report to the London Borough of Barnet.
655 G.W. Shaumburg and K.T. Doyle (1994) Wasting Resources to Reduce Waste: Recycling in New
Jersey, Cato Policy Analysis, 202.
656 D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W. Devliegher, W. Brinton and S.
Antler (2002) Comparison of Compost Standards within the EU, North America and Australasia, report
produced for WRAP.
657 H. Fogarty, L. Reid H. and Sprott (2008) International Review of Recycling Policies, Scottish
Government Social Research. Available at
http://www.scotland.gov.uk/Resource/Doc/231872/0063356.pdf
553
International Review of Waste Policy: Annexes

Figure 34-1: Waste Generation, Recovery and Disposal from Households and Similar
Establishments in Austria
Source: Federal Ministry of Agriculture and Forestry, Environment and Water Management (2006)
Federal Waste Management Plan 2006: Suitable for Nature and Mankind.
Czech Republic and Germany (report by RRF) 658
The 2006 RRF report highlights Germany as the European leader in the separate
collection of waste materials, having sorted 60 kg of waste per capita in 2005. The
well-established recycling systems in Germany produce an overall municipal recycling
of rate of over 60 %. The report also highlights the Czech Republic as coming up fast
through the ranks due to their recently adjusted recycling policy that stipulates the
required separate collection of a number of materials. The recycling rate for municipal
waste in the Czech Republic leapt up 10 % between 2004 and 2005, with the
separate collection of 36 kg recyclable waste per capita in 2005. Success has been
attributed to the following: first, towns and companies receive money for sorting their
waste when they would otherwise have to pay to dispose of their unsorted waste.
Second, there has been excellent publicity to increase recycling, with endorsement
from a number of famous celebrities. Third, the market for recyclable materials has
658 Resource Recovery Forum (2006) The Czech Republic – Improvement in Waste Sorting, Second in
EU.
554
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strengthened as the increased costs of raw materials push commerce and industry to
look to secondary materials. This situation may, however, be changing in the wake of
recent collapses in the price of some secondary materials. It remains to be seen
whether this price collapse is long-lived, or a short-lived over-correction to the price of
these commodities.
Denmark
The 29 % household waste collection rate was far short of the 2000 target of 49 %.
According to Green Alliance, 659 the principle reasons for this shortfall are a lack of
mandatory separate collection of biowaste and a heavy reliance on bring sites for the
collection of glass and paper/cardboard, as opposed to door-to-door collections.
Danish waste management policy is heavily influenced by fixed investments made in
the past in incineration capacity.
England (Barnet Compulsory Recycling)
As mentioned in Section 34.2.1.1, alongside the requirement that collection
authorities in England and Wales must separately collect at the kerbside any two
recyclable materials, Barnet Borough Council also implemented a compulsory
recycling scheme to 25,000 households in 2004. Participation by householders
involved in the scheme was monitored over a number of weeks, with those
households found not to be participating subsequently sent a letter further advising
them of the scheme and alerting them as to the legal basis of the scheme. Continued
lack of participation resulted in further postal contact, followed by an eventual doorknocking
campaign. By the end of this monitoring stage, only 9 households were still
not participating.
Following introduction of the compulsory scheme, the year on year increase in
recycling rate for the whole of Barnet (113,000 households) rose from 10 % in 2003
to more than 20 % the following year, indicating the affect of media attention on the
scheme in increasing recycling across the Council, not just for the 25,000 trial
households. This higher recycling rate was, however, only sustained longer-term from
the 25,000 households for which recycling was compulsory, where official contact
from the council reinforced the message of the requirement to recycle. More than
three-quarters of a survey of 500 residents in Barnet (both those on, and not on, the
compulsory scheme) considered compulsory recycling to be a good idea, with support
higher in those areas already forming part of the compulsory scheme, though
confusion remains regarding exactly which materials form part of compulsory
recycling, and even which households are part of the current scheme. 660
It should be noted that the Barnet scheme incorporates the threat of legal action as a
last resort in the event of non-compliance with the scheme. It remains uncertain,
however, as to whether the justification which the council uses in order to stipulate
659 Green Alliance (2002) Creative Policy Packages for Waste: Lessons for the UK, Available at
http://www.greenalliance.org.uk/uploadedFiles/Publications/CPPWDenmark.pdf
660 Eunomia (2009) Compulsory Recycling Scheme Review and Second Phase Roll Out Plan, Final
Report to the London Borough of Barnet.
555
International Review of Waste Policy: Annexes

that the specified materials are not placed into the residual waste bin (i.e. reference
to sections 45 and 46 of the Environmental Protection Act 1990) would stand up in a
court of law. A similar case in Exeter in 2006 saw the council lose against a
householder, as the council was not able to prove, beyond all reasonable doubt, that
it was indeed that individual who had put the offending material in the bin. 661
Hungary
According to EIONET 662, the introduction of separate collections for a number of
waste streams (predominantly at bring sites) has led to a change in the attitude of the
population towards their waste and the engagement of the private sector into the
separate collection process. So far, separate collection has led to the recovery of
approximately 10 % of the generated municipal solid waste.
The Netherlands
According to ECOTEC, 663 research was undertaken in the Netherlands between 1993
and 1995 to see whether a national, broadly uniform, separate collection system
could be undertaken for the dry recycling components of household waste. The
system that was developed consisted of the collection of glass at bring banks (1 per
every 650 inhabitants), kerbside collection for paper and board at least once a month
and textiles collection at least once a quarter (plus in bring banks). Discussions
around the model led to the decision to leave the collection function to the
government in the Netherlands, with the municipal collection infrastructure offering
the best opportunities for reaching recycling targets. Collection of plastics at the
kerbside was also studied, but was found to be uneconomic. 664 Several additional
enhancements to the service were proposed, such as the use of can banks, plastic
bottle banks and drinks cartons collections. The relatively simple model gave a strong
guideline for local authorities to follow. As a result, even as far back as 1996 the
Netherlands was achieving separate collection rates for recycling/reuse of 44 %. In
2006, this rate had increased to 64 %. 665
South Korea
As a consequence of the introduction of the Volume-based Waste Fee (VBWF)
combined with a mandatory recycling service, the recycling rate in South Korea rose
661 LetsRecycle.com (2006) Exeter Loses Court Case over Recycling Contamination.
662 European Topic Centre on Resource and Waste Management [Online],
http://waste.eionet.europa.eu/facts/factsheets_waste/Instruments [Accessed 8th September 2008].
663 ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The Economics of Waste
Management Options, Report produced for Friends of the Earth, UK Waste and Waste Watch. Available
at http://www.foe.co.uk/resource/reports/economics_waste_options.pdf
664 Resource Recovery Forum (2004) High Diversion of Municipal Waste: Is It Achievable?
665 H. Fogarty, L. Reid and H. Sprott (2008) International Review of Recycling Policies, Scottish
Government Social Research. Available at
http://www.scotland.gov.uk/Resource/Doc/231872/0063356.pdf
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from 15.4 % in 1994 to 49.2 % in 2004. 666
Switzerland
Statistics provided on the Federal Office for the Environment (FOEN) 667 website
indicate that the municipal waste recycling rate in Switzerland has been over 40 % for
a number of years, with capture rates in 2006 for individual materials as follows:
paper at 77 %, aluminium cans at 90 %, PET bottles at 76 %, biowaste at 34 % and
glass particularly high at 95.6 %.
Taiwan
The original recycling target linked to the introduction of mandatory recycling in 2006
was to reach 28.75 % by 2008; Taiwan had already exceeded this rate by 2007 with
a recycling rate of 38.7%. 668
New Jersey (USA)
The total municipal (including businesses and institutions) recycling rate in New
Jersey in 2006 was reported as 54.8 %. 669 A report by Schaumburg and Doyle (1994)
condemned the mandatory recycling scheme in New Jersey due to the high cost of
administering and running such a system, whilst acknowledging that the policy has
had a direct effect on increasing recycling rates. 670
34.6 Implementation Costs
In countries such as Austria, the Czech Republic, Germany and Switzerland, the
minimum recycling standards for packaging materials are principally funded by
producer responsibility schemes (which are in turn supported by pre-paid disposal
fees). This means that in, for example, Switzerland, the producer fully funds
aluminium collection, mostly funds glass collection and partly funds paper/cardboard
collection. Such schemes are discussed in more detail in Section 13.0.
By contrast, countries such as the UK and Denmark pay for their recycling collection
schemes predominantly via local taxes. In Denmark, in some situations, pay-by-use is
also used in some municipalities in order to promote source separation of waste (see
Section 8.0). In the UK, in the past, the costs of implementation and running of door-
666 OECD (2006) Impacts of Unit-Based Waste Collection Charges, Working Group on Waste Prevention
and Recycling, Environment Policy Committee.
667 Available at http://www.bafu.admin.ch/abfall/01517/01519/index.html?lang=en
668 Environmental Protection Administration (2008) Taiwan’s Zero Waste Policy to Meet 2008 Goal in
Advance, available at
http://www.epa.gov.tw/en/epashow.aspx?list=112&path=11972&guid=c26aa5d0-a280-4e72-9a38a0b4f1e2bdff&lang=en-us
669 New Jersey Department of Environmental Protection (2006) New Jersey Generation, Disposal and
Recycling Statistics, available online at
http://www.state.nj.us/dep/dshw/recycling/stat_links/06%20Disposal_%20Rates_%20County.pdf.
670 G.W. Shaumburg and K.T. Doyle (1994) Wasting Resources to Reduce Waste: Recycling in New
Jersey, Cato Policy Analysis, 202.
557
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to-door source-separation schemes have tended to be higher than collection based
around refuse collection for disposal only. This has been because the cost of disposal
has been so low. However, past increases in landfill tax are already making separate
collection more economically favourable longer-term, this already being the case for
many materials such as paper and card, and where refuse frequency is reduced at
the same time, for food waste also. 671 The financial rationale for recycling is likely to
strengthen as landfill taxes are set to increase in future years.
The Netherlands provides an example of increasing costs resulting from minimum
recycling standards. Its system of municipality responsibility from collection until the
transfer station, followed by the shift of responsibility to the producer incurred a per
capita waste levy increase. The levy more than doubled between 1991 and 1997,
standing at 377 guilders (£122) in 2000. 672 However, it should be stated that this
was a period during which the cost of disposal also increased as a consequence of
landfill taxes and bans, so the increase in costs could not be attributed to the
changes in the collection system alone.
It should be noted that no such producer responsibility systems exist to support the
collection of biowaste by those countries tasked with doing so according to their
waste policies. Nonetheless, costs for the collection of biowastes need not be
enormous: a large amount of any additional cost has been linked to the tendency to
pull out of the waste stream materials which might otherwise not have been collected
at all (e.g. garden waste) or would otherwise have been delivered to bring sites. As a
result, countries with biowaste collections, notably Belgium, Austria and Germany,
strongly promote home composting alongside the biowaste collection and Italy and
parts of Catalunya have designed collection systems to specifically target kitchen
waste only. 673 A detailed modelling study undertaken by Eunomia on food waste
collection systems in the United Kingdom found that collection operations were more
or less cost-neutral where residual waste collection frequencies were reduced at the
same time. Recent shifts in the cost of treatment and disposal of waste are making
the separate collection of food waste increasingly cost effective. 674 Likewise, at higher
disposal costs and/ or higher participation rates, recycling schemes overall will begin
to pay for themselves (particularly once reaching a 12.5 % diversion rate), though the
degree to which this will be the case will rely on the market price of the recyclable
671 Eunomia (2008) Mid Devon District Council Kerbside Collection Report, Report produced for WRAP;
Eunomia (2007) WRAP REP.
672 ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The Economics of Waste
Management Options, Report produced for Friends of the Earth, UK Waste and Waste Watch. Available
at http://www.foe.co.uk/resource/reports/economics_waste_options.pdf
673 Eunomia (2001) Costs for Municipal Waste Management in the EU, Final Report to Directorate
General Government, European Commission.
674 Eunomia (2008) Food Waste Collection: Update to WRAP Cost Benefit Study, Report produced for
WRAP.
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materials. 675 Thus complementary policies have a key role to play in determining the
implementation costs of such a service.
Cost-Benefit Analysis of separate collection and recycling of waste materials in New
Zealand
A recent study (2007) delivered by Covec on behalf of the Ministry for the
Environment in New Zealand 676 examined the costs and benefits of recycling paper,
plastics, glass, organics (food and garden waste), C&D waste, tyres and used oil. The
study compared the cost of disposal to landfill to the delivery of a kerbside collection
and subsequent recycling of the materials. The costs of recycling include the cost of
collection and sorting minus the value of the materials in the end-user markets.
Analysis for each material used three sets of assumptions:
559
� An initial recycling rate based on benefit estimates that include savings in
landfill costs but ignore external costs associated with emissions, leachate
and direct consumer benefits;
� A low benefit estimate where the savings were assigned low values per tonne
and included external costs; and
� A high benefit estimate where the savings were assigned higher values per
tonne and also included external costs.
Analysis showed that there is the potential to increase recycling rates at a positive
net-benefit for all waste streams using the high-benefit estimates. However, when
lower values were assigned for the savings, separate collections of PVC, LDPE and
organics (combined food and garden waste) showed a negative net-benefit. For the
organic material, this cost was particularly associated with a shift in garden waste
tonnage from civic amenity sites to the co-mingled collections at the kerbside.
34.7 Effects on Technical Change / Innovation
As with environmental benefits, it is difficult to trace technical changes and
innovations to one specific policy. However, the push to increase recycling is likely to
have had the effect of encouraging collectors/reprocessors to ensure that the
material which they are collecting/delivering to the market is high-quality.
Key areas of technical change/ innovation associated with the implementation of
minimum recycling standards are the development of vehicles in order to collect
separated waste efficiently from households, the development of markets for the
recyclable materials and the development of biowaste treatment infrastructure. The
increasing collection of biowaste has seen an increase in the development of both
675 ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The Economics of Waste
Management Options, Report produced for Friends of the Earth, UK Waste and Waste Watch. Available
at http://www.foe.co.uk/resource/reports/economics_waste_options.pdf
676 Covec (2007) Recycling: Cost Benefit Analysis, prepared for the Ministry of the Environment, New
Zealand.
International Review of Waste Policy: Annexes

composting and anaerobic digestion facilities in countries such as Germany and
Austria.
34.8 Complementary Policies
Key complementary policies applied in conjunction with minimum recycling standards
are as follows:
560
� Financial support to the collection systems:
29/09/09
• Producer responsibility; particularly that associated with packaging
decrees;
• Deposit refund schemes;
• Pay as you throw (where residual waste collection cost exceeds that of
recycling and biowaste collections to encourage householders to
separate and recycle their waste).
� Policy measures that discourage disposal:
• Landfill tax - increases in tax support the increasing cost-effectiveness
of collection systems;
• Landfill bans – for example the ban of biowaste means that such waste
must be separated from the remaining waste for disposal via other
methods or that the waste must be pre-treated before going to landfill;
• Pay as you throw (where residual waste collection cost exceeds that of
recycling and biowaste collections to encourage householders to
separate and recycle their waste).
� Product standards e.g. compost standards for use in agriculture require that
the biowaste is source-segregated (in Austria and many other countries) 677 ;
and
� Recycled content requirements, e.g. the Green Public Procurement policy in
Italy requires that a minimum of 30 % of the goods/products purchased by
local government must be made from recycled materials, thus helping to
develop an end-user market. 678
In addition to the above, targets for recycling, or for the amount of residual waste
collected, tend to reinforce the requirement to separately collect materials.
677 D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W. Devliegher, W. Brinton and S.
Antler (2002) Comparison of Compost Standards within the EU, North America and Australasia, report
produced for WRAP.
678 European Topic Centre on Resource and Waste Management [Online],
http://waste.eionet.europa.eu/facts/factsheets_waste/Instruments [Accessed 8th September 2008].

34.9 Effect of the Policy on Pricing of Resources / Services
Residual waste treatment and disposal typically have associated with them external
costs. Collection of residual waste is typically relatively cheap. Recycling, on the other
hand, can incur higher collection costs, even though the avoided costs of treatment /
disposal of residual waste may justify the activity from the perspective of overall
system costs. Recycling typically implies positive externalities relative to the
production of material from primary resources. 679 However, governments rarely
provide subsidies for recycling.
In the absence of a high landfill tax and of direct pay-by-use (which would directly
deliver the economic stimulus to better manage resources), mandatory recycling can
imply some extra costs for the consumer to fund recycling schemes. Although the
policy does not directly align the costs of purchasing goods with the environmental
damage costs, it can force the ‘polluter to pay’ to have their waste recycled.
Contributions made by producer responsibility schemes, and the degree to which they
cover the costs of the collection scheme in each individual country will also impact
the overall cost of the provision of mandatory recycling schemes.
34.10 Evasion and Enforcement
In Switzerland the current producer responsibility schemes that facilitate the majority
of recycling are working well. However, if retailers should start to jeopardise the
financing of collection via free-riding, the government proposes to introduce a
mandatory charge, as is provided for in the Environmental Protection Law. 680
34.11 Lessons Learned
Denmark
As previously discussed, the 29 % household waste collection rate fell far short of the
2000 target of 49 % in Denmark despite the minimum recycling standards. According
to Green Alliance, 681 the principle reasons for this shortfall are a lack of mandatory
separate collection of biowaste and a heavy reliance on bring sites for the collection
of glass and paper/cardboard, leading to poor capture rates.
When the government subsequently proposed the kerbside collection of paper, the
public voted against it due to the perceived increase in expense to the
679 See, for example, ECOTEC Research and Consulting Limited (2000) Beyond the Bin: The Economics
of Waste Management Options, Report produced for Friends of the Earth, UK Waste and Waste Watch.
Available at http://www.foe.co.uk/resource/reports/economics_waste_options.pdf; D. Hogg (2006)
Impact of Unit-based Waste Collection Charges, Report for the OECD Environment Directorate, Working
Group on Waste Prevention and recycling, May 2006.
680 Federal Office for the Environment (2008) Guide to Waste [Online] (Updated 28 th February 2008).
Available at: http://www.bafu.admin.ch/abfall/01472/index.html?lang=en [Accessed 10 th September
2008].
681 Green Alliance (2002) Creative Policy Packages for Waste: Lessons for the UK, Available at
http://www.greenalliance.org.uk/uploadedFiles/Publications/CPPWDenmark.pdf
561
International Review of Waste Policy: Annexes

householder. 682 According to Lone Lykke Nielson “Systems are needed but many
municipalities are reluctant to act and the collection of organic household waste has
not been made mandatory”. Only four per cent of organic domestic waste is being
recovered in biogas plants. Henrik Wejdling also pointed out that Denmark already
has incineration plants to feed and is reluctant to put much money into alternatives,
whilst the disposal cost is too low to incentivise further source-separation. 682
For similar reasons, Denmark was a fairly vociferous opponent of proposals at the EU
level to introduce a Biowaste Directive that would mandate biowaste collection in all
municipalities. Part of the reason was that, recognizing that the marginal benefit of
avoided disposal would be close to zero because such a move would simply free up
incineration capacity, there would be little cost saving on the disposal side.
The lesson appears to be that where minimum standards are set, they should be
sufficiently specific in terms of the quality of service they envisage. In addition, the
Danish experience suggests that countries that have already invested heavily in
residual waste treatment infrastructure are less likely to look favourably upon such
standards precisely because of the sunk costs in existing infrastructure.
United Kingdom (England and Wales)
It should be noted that the recycling targets that typically complement minimum
recycling standards can have negative as well as positive impacts. The collection
authorities in England and Wales must collect at the kerbside any two recyclable
materials, with minimum recycling targets also set without reference to specific
material types. Thus, local authorities habitually pursue the collection of garden
waste, which typically increases the overall amount of this waste ending up in the
waste system (where it might previously have been home-composted or left in-situ),
proving costly to the authority in question. 683
34.12 Prerequisites for Introduction
As stated in the Federal Waste Management Plan, 684 Austria recommends the
following for the separate collection of waste materials:
� Requirement for strong promotion and motivational campaigns to get the
public involved and participating in effective source-separation (i.e. high
recognition rates);
� The periodic analysis of the residual waste composition in order to improve the
separate collection of waste materials – with particular focus on problematic
materials;
682 H. Fogarty, L. Reid and H. Sprott (2008) International Review of Recycling Policies, Scottish
Government Social Research. Available at
http://www.scotland.gov.uk/Resource/Doc/231872/0063356.pdf
683 WRAP/Eunomia (2008) Food Waste Collection: Update to WRAP Biowaste Cost Benefit Study,
October 2008.
684 Federal Ministry of Agriculture and Forestry, Environment and Water Management (2006) Federal
Waste Management Plan 2006: Suitable for Nature and Mankind. Available at:
http://www.bundesabfallwirtschaftsplan.at/
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� Strong industrial support via producer responsibility schemes; and
� Careful specification of residual waste treatment capacity so as not to
undermine potential future recycling initiatives.
It is also useful to understand the relative costs and benefits of mandating the
collection/treatment of specific waste streams.
563
International Review of Waste Policy: Annexes

35.0 Minimum Recycling Standards
(Commercial and Industrial Waste) - International
35.1 Outline of Policy
A number of countries currently employ a minimum recycling standards policy for
householders, commerce and industry, and construction and demolition wastes. This
section presents those minimum standards for the commercial and industrial (C&I)
waste stream. Minimum recycling policies require the separate collection of a number
of waste materials, with the key goals of diverting waste away from landfill and
increasing material recovery.
Within the EU, the implementation of such recycling standards comes under Article 3
of Directive 2006/12/EC, which specifies that Member States shall take the
appropriate measures for the recovery of waste via recycling, re-use and reclamation.
Outside of the EU, several places within the US have also implemented or are
currently moving towards mandatory C&I recycling (see Section 35.2.1).
In addition to the main EU Waste Framework Directive, the use of minimum recycling
standards in Europe is also designed to meet the targets stipulated in a number of
more specific EU Directives, namely the Landfill Directive, the Packaging Directive
(Section 13.0), the Batteries and Accumulators Directive (Section 25.0), the WEEE
Directive (Section 20.0) and the ELV Directive (Section 23.0).
35.2 Where Has the Policy Been Applied and Why?
The countries that currently use a minimum recycling standard for the C&I sector
include Austria, Denmark, Finland, Germany, the Netherlands, Poland, Portugal,
Slovenia and Switzerland. In addition, the city of Portland and the state of New Jersey
also require a minimum recycling standard from their businesses. California (USA) is
also looking to implement a mandatory commercial recycling programme. The
minimum standards for C&I vary in the types and number of materials that must be
source-separated, the way in which the materials must be collected and in the way
that they are funded. The main country-specific policy details are discussed in Section
35.2.1.
A minimum recycling standard for C&I has been implemented in these countries in
order to push waste up the hierarchy away from landfill, and to increase the recovery
of materials and hence reduce the need for primary material consumption.
35.2.1 Country-specific Characteristics
Austria
The Ordinance on the Separate Collection of Organic Wastes (Law Gazette II no.
68/1992) and the Ordinance on Compost (Law Gazette II no. 292/2001) dictate that
provision is made by the municipality for a separate collection of biowaste from
Austrian commercial and industrial properties (that fall under the remit of the
564
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municipality) unless it is composted/treated onsite. In addition, these Ordinances
stipulate that C&I operators are obliged to separate, where applicable, plant residues
from C&I processing and from the distribution of agricultural and forestry products,
and vegetable food waste from commercial enterprises. In addition, the Ordinances
on Packaging (Law Gazette II No. 1996/648 and 1992/646) place financial
responsibility on producers to ensure that the separate collection of glass, plastics,
paper/cardboard, metals (aluminium and steel) and composites for beverages occurs
from C&I as well as households.
Denmark
Municipalities have an obligation to provide a collection service for the following C&I
waste streams: food waste from catering centres, paper/cardboard from commercial
properties and transport packaging waste. In turn, C&I operators in Denmark have a
responsibility to ensure that they separate out their food, paper, cardboard, and
plastic transport packaging waste streams where applicable. There are also some
specific-industry examples where certain additional streams must be sourceseparated
such as steel drums and impregnated wood.
Finland
Paper must be separately collected by C&I waste producers. In Helsinki, any premises
comprising more than four dwellings and any major C&I generators of paper and
cardboard are provided with a collection service by the municipality. 685
Germany
The separate collection of glass, paper/cardboard, plastics, tinplate, aluminium and
composites has been required from C&I waste in Germany since 2002. In addition,
the Biowaste Ordinance (1998) sets out the requirement for the separate collection
of biowaste from C&I waste where applicable, to ensure that only biodegradable
waste with a low pollutant content is used in fertiliser following composting or
fermentation. Companies are obliged to either separate their own waste and have it
collected, or commit their waste to special commercial waste sorting facilities.
The Netherlands
The Separate Collection of Commercial/Industrial Waste Programme sets out that
paper, cardboard and packaging must be separated by C&I waste producers for
recycling in the Netherlands. Companies must arrange for these waste streams to be
separately collected. In addition, glass, plastic, organics, wood, textiles and metals
must also be collected where it is ‘reasonably practicable’ to do so. The obligation to
separate is currently specified in the C&I Environmental Licence, though this Licence
685 J. Saarela (2004) Wastes In Finland and Waste Management Strategies in Helsinki Metropolitan
Area, available at http://www.ymparisto.fi/download.asp?contentid=80498
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is being replaced by more general rules relating to particular C&I sectors, following
Section 8.40 of the Environmental Management Act. 686
Poland
Packaging must be separately collected from retailer shops with a trading area
greater than 2,000 m 2. Retailers must organise their own collections.
Slovenia
Under the Environmental Protection Act (2001), C&I that produce both garden waste
and vegetable food waste must ensure that this waste stream is separately collected.
Switzerland
Under the Technical Ordinance on Waste, the cantons (regions) must try to recover,
as far as possible, the recyclable fractions of municipal waste (including SME as well
as larger C&I wastes that come under the jurisdiction of the canton). Article 6 of the
Ordinance of the Treatment of Waste prescribes the separate collection of the
recyclable fraction, and includes biowaste that cannot be home composted. In
addition to biowaste, a collection of paper/cardboard, tin, beverage containers, glass,
PET and aluminium is also required, falling under the Ordinance on Beverage
Containers. C&I waste producers are obliged to ensure the separate collection of
these waste streams where the authority considers it technically and economically
viable to do so, and must arrange for the collection of these waste streams either via
the local authority, or via private collections for larger C&I, which are facilitated by prepaid
disposal fees.
California (USA)
The California Air Resources Board (ARB) voted to apply a mandatory commercial
recycling programme as part of the ‘AB 32 Scoping Plan’, which is the blueprint for
implementing California’s global warming legislation. The state has identified
recycling as one of the key strategies in helping California to achieve its targets in
reducing greenhouse gas emissions going forward. In addition, the Scoping Plan also
recognises that the provision of financial incentives will be critical to the success of
the recycling programme; the ARB will work with, among others, the California
Department of Food and Agriculture and the Department of Transportation, to provide
direct incentives for the use of compost in agriculture and landscaping. Furthermore,
the use of incentives in order to encourage the collection of both household and
commercial food waste for both composting and anaerobic digestion processes will
also be explored by the California Integrated Waste Management Board. 687
686 Ministry of Housing, Spatial Planning and the Environment (2001) Commercial/Industrial Waste
and Compulsory Separation, available at
http://www.sharedspaces.nl/docs/internationaal/14274_174com_indwaste.pdf.
687 S. Smithline (2008) Recycling to Play Critical Role in State's Landmark Global Warming Plan,
Available at http://www.cawrecycles.org/node/3200, [Accessed on 2 nd January 2009].
566
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City of Portland, Oregon (USA)
The city of Portland in Oregon, USA, currently requires that all businesses separate
out a minimum of 75 % of their waste for recycling. Those failing to do so are required
to demonstrate why they are unable to meet this requirement. All paper and
cardboard is to be recycled, and organic material is to be recycled where the Office of
Sustainable Development determines that the amount produced is sufficient to
warrant separate collection. Where glass forms part of the recyclable materials, this
should be collected separately from any other materials. This measure is intended to
maintain the quality of the collected paper and card. Free government assistance, in
the form of a ‘’Recycle at Work’’ programme, is also provided to help businesses
achieve this rate. 688
The regional government in Portland area, known as Metro, is looking to expand this
current policy to the wider Portland region (population approximately 2 million), and
also to increase the recycling rate required to 90 % for paper, cardboard and
containers. Metro analysts have estimated that this mandate would boost recycling by
55,000 tons a year, particularly for paper. The wider mandate would allow the
government to inspect the estimated 14 % of businesses that currently do little or no
recycling.
New Jersey (USA)
The state of New Jersey was the first state in the USA to require mandatory recycling
from all households, businesses and institutions. In 1987, the New Jersey Statewide
Mandatory Source Separation and Recycling Act came into force, with all households
required to recycle leaves and at least three of the following materials: paper, metal,
glass, plastic containers and food waste. In addition to these materials, the
commercial sector is also required to recycle its office paper and corrugated
cardboard waste.
35.3 Key Organisations Involved in Implementation and
Management
C&I separate collections are typically funded by the businesses themselves in the
majority of countries listed in Section 35.2. The collection systems are predominantly
privately co-ordinated and funded in Austria, Finland, Germany, Poland, Switzerland
and the USA. Local government provides the collection service itself for C&I waste
recycling in Denmark, Slovenia, for biowaste collections in Austria, and for SMEs
under the jurisdiction of the municipality in Switzerland.
35.4 Pre-implementation / Evaluation Studies Available
Federal Office for the Environment, 2008, Guide to Waste [Online] (Updated 28 th
February 2008). Available at:
688 Office of Sustainable Development, City of Portland (2008) Fall 2008 Revisions, Administrative
Rules, Commercial Solid Waste, Recycling and Compostables, available at
http://www.portlandonline.com/osd/index.cfm?c=41472&a=218220
567
International Review of Waste Policy: Annexes

http://www.bafu.admin.ch/abfall/01472/index.html?lang=en [Accessed 10 th
September 2008].
Shaumburg, G. W. and Doyle, K. T. (1994) Wasting Resources to Reduce Waste:
Recycling in New Jersey, Cato Policy Analysis, 202.
Waste Centre Denmark, [Online], Waste from Industry and Commerce. Available at
http://www.wasteinfo.dk/waste+and+collection+companies/sources+types+and+fra
ctions/waste+from+industry+and+commerce [Accessed 29 th September 2008].
35.5 Environmental Benefits
The main environmental benefits from the mandatory requirement for separate
collection and subsequent recycling/reuse of waste materials are likely to be:
568
� Increased diversion of waste away from landfill or other residual waste
treatments that might otherwise be required; and
� The potential to re-process and consequently recycle the source-separated
materials, saving on raw materials (and hence energy) in commercial and
industrial processes.
In most countries, it is difficult to attribute a specific increase in recycling and
composting / digestion to this policy alone. This is because in most countries a policy
of mandatory recycling of specific materials exists alongside other policies, including,
for example, producer responsibility schemes, implying provision of varying degrees of
service on the part of producers. Having said that, it seems reasonable to believe that
such a policy does in fact play a role in increasing materials recycling. For example,
approximately one third of the total biowaste collected in Switzerland is from private
industry (notably horticulture and landscaping). 689 Similarly, the total municipal
(including businesses and institutions) recycling rate in New Jersey in 2006 was
reported as 54.8 %, reaching the target set by the state for its municipal solid waste
stream. 690
Not much information appears to exist on the specific contribution of C&I to overall
recycling rates in the countries listed. In Denmark, for example, only certain industries
must keep a register or their waste generation. Thus it is difficult to obtain a complete
picture of increases in recycling rates due to mandatory separation requirements.
However, from the Waste Statistics available in Denmark, approximately 65 % of
689 Federal Office for the Environment, 2008, Guide to Waste [Online] (Updated 28 th February 2008).
Available at: http://www.bafu.admin.ch/abfall/01472/index.html?lang=en [Accessed 10 th September
2008].
690 New Jersey Department of Environmental Protection (2006) New Jersey Generation, Disposal and
Recycling Statistics, available online at
http://www.state.nj.us/dep/dshw/recycling/stat_links/06%20Disposal_%20Rates_%20County.pdf.
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waste from manufacturing industries was recycled in 2005, and approximately 45 %
of waste from institutions, trade and offices. 691
C&I waste constitutes approximately 16% of, for example, the German waste arisings;
a contribution which is comparable to that of the householder, thus highlighting the
importance of targeting the recycling of this waste stream for overall recycling rates
and diversion from landfill.
35.6 Implementation Costs
A significant proportion of the implementation costs for C&I recycling will be covered
by pre-paid disposal fees that are used to facilitate producer responsibility systems.
Any additional costs will be the responsibility of the company, except where the
municipality is required to provide separate recycling collections, though even in this
instance the company will be likely to have to pay via business rates, or through a
charging system.
35.7 Complementary Policies
See Section 34.8.
35.8 Effect of the Policy on Pricing of Resources / Services
See Section 34.9.
35.9 Lessons Learned
New Jersey currently requires businesses to arrange for the separate collection of
their waste streams, but does not provide sufficient financial support, leaving a large
burden on businesses (as well as on the municipality as a whole). Landfill tax in New
Jersey is only at $3 per ton (1.02 tonnes), providing insufficient funding to fully
compensate mandatory recycling schemes. High landfill tax, and policies such as payby-use
and producer responsibility schemes would provide additional financial
support to the overall development of mandatory recycling schemes.
35.10 Prerequisites for Introduction
569
� Willingness of collectors to collect (including local authorities as collectors
where it might be cost-effective to do so);
� Supportive infrastructure such as Commercial and Industrial materials
recovery facilities and facilities for composting / digestion for biowaste; and
� An appreciation of why it is important to source-separate C&I waste (e.g.
California).
691 Waste Centre Denmark, [Online], Waste from Industry and Commerce. Available at
http://www.wasteinfo.dk/waste+and+collection+companies/sources+types+and+fractions/waste+fro
m+industry+and+commerce [Accessed 29 th September 2008].
International Review of Waste Policy: Annexes

36.0 Product Standards: Biowaste Treatment
Products - International
36.1 Outline of Policy
Standards are applied to the production of compost and digestate (hereafter referred
to collectively as Biowaste Treatment Products or ‘BTPs’) in order to protect human
health and the environment and in addition, to reduce transaction costs associated
with compost sales through improving consumer confidence. Large quantities and
repeated applications of BTPs, combined with the use of arable land for fodder
production, ensures that the question of risk plays an important role in shaping
regulation of compost production and use. 692 Alongside the setting of statutory
standards associated with health and environmental protection, voluntary quality
standards also exist in a number of countries that go beyond the precautionary
requirements of the regulators, to ensure that the quality of the product meets the
demands of the market i.e. is tailored to the end-user requirements. 693
Standards are typically set according to a number of criteria including the feedstocks
used, potentially-toxic elements (PTEs), organic contaminants, hygienisation
principles and physical impurities. Underpinning the production of BTPs in the EU is
the Animal By-Products Regulation (EC) n o 1774/2001 (the ‘ABPR’), notably amended
by Regulation 208/2006, which provides detailed hygienisation rules (timetemperature
regimes, process validation requirements, biological tests) for
composting and biogas plants that treat animal by-products as part of their input
material.
36.2 Where Has the Policy Been Applied and Why?
Standards for BTPs exist throughout the EU, as well as in other parts of the world
such as Australia, Canada, USA and New Zealand. Only Germany, Austria, the
Netherlands, Italy, Switzerland, Sweden, and the Flemish region of Belgium can
currently claim a mature compost market situation, though the situation in the UK is
also developing rapidly. Despite their small number, these countries account for more
than 2/3 of the biowaste treatment capacity in Europe. 692
692 D. Hogg, D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of Compost in
Agriculture in Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.703534d2.6993.
pdf .
693 J. Barth, F. Amlinger, E. Favoino, S. Siebert, B. Kehres, R. Gottschall, M. Bieker, A. Löbig and W.
Bidlingmaier (2008). Compost Production and Use in the EU. Report for the European Commission
DG/JRC.
570
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36.2.1 Country-specific Characteristics
Table 36-1 Standard measures/requirements that apply to the production of BTPs
in Europe [S = Statutory measure, V = Voluntary measure].
Compost Production Standards
Country
Feedstock PTEs Organic Contaminants Hygienisation Physical Impurities
s
AT S S S (mixed waste only) S S
BE S S S S
BG
CH S S S S
CY
CZ S S S S S
DE S S S S
DK S S S S
EE S
ES S S S S
FI S S S S
FR S S S S
GR S
HU S S S
IE S S S S
IT S S S S
LT S S
LU S S V S S
LV S S
MT
NL S S S S
PL S S S
PT S
SE V V S
SI S
SK V
UK V S/V S V
Canada S S V
USA S S
Australia S S
New Zealand S S
Source: Summarised from Hogg, D., Barth, J., Favoino, E., Centemero, M., Caimi, V., Amlinger, F.,
Devliegher, W., Brinton, W. and Antler, S. (2002). Comparison of Compost Standards Within the EU,
North America and Australasia. Report for the Waste and Resources Action Programme and D. Hogg,
D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of Compost in Agriculture in
Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.703534d2.6993.
pdf .
571
International Review of Waste Policy: Annexes

Due to the large number of countries that currently implement standards relating to
BTPs, Table 36-1 summarises which countries apply which standard
measures/restrictions as part of their policy on BTP production; the section is then
broken down into a summary of country-specific characteristics for each of the
measures that form part of the overall compost standard. Two key reports have been
used in order to summarise policies related to compost quality worldwide. 694 695
Additional references are provided throughout the document.
Feedstocks
The ABPR limits the materials that can be used in composting and biogas plants.
572
� Category 1 materials cannot be dealt with in composting or biogas plants;
� Category 2 materials can be dealt with in composting or biogas plants if they
are treated in a particular manner as identified in Article 13. Manure, digestive
tract content separated from the digestive tract, milk and colostrums can be
treated in composting and biogas plants in accordance with Articles 15 and
18;
� Category 3 materials can be dealt with in composting and biogas plants in a
manner consistent with Article 15. Catering waste which is not of international
origin can be dealt with in biogas and composting plants in line with rules of
national origin until rules are established under Article 33(2). This is an
important exemption which most Member States have chosen to use to their
advantage.
Following on from these general guidelines, the majority of European countries have
drawn up a positive list of materials that can be included as input materials, rather
than listing which materials are excluded. In setting feedstock requirements, it can be
expected that the resultant compost is more likely to consistently achieve the desired
quality. In theory, this list should be different for composting plants compared to
biogas plants, as biogas plants can accept wetter materials such as grease-trap fats.
However in reality, such a split only exists in Austria, where a number of specified
materials, such as rendered fats and glycerine residues, are restricted to anaerobic
digestion plants. 696 Within the EU (plus Switzerland), 16 countries currently have
statutory standards for those feedstock materials that can be used for BTPs, and a
further 2 countries (Sweden and the United Kingdom) have voluntary standards. The
most prominent waste groups excluded from the production of BTPs are municipal
sewage sludge, mixed (not source-separated) municipal solid waste, paunch and
manure. Source-separated MSW, in particular, is seen by a number of countries as a
694 D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W. Devliegher, W. Brinton and S.
Antler (2002). Comparison of Compost Standards Within the EU, North America and Australasia.
Report for the Waste and Resources Action Programme.
695 D. Hogg, D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of Compost in
Agriculture in Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.703534d2.6993.
pdf .
696 Communication with Josef Barth (Informa Organic Waste Consultants, Germany) 07/07/2008.
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solid pre-requisite for the production of BTPs, including in Flanders (Belgium),
Germany, the Netherlands and Sweden, with sewage sludge also excluded from use
as a feedstock in each of these countries.
Potentially-Toxic Elements
As detailed in Table 36-1, the majority of countries currently set limits on the amount
of cadmium, chromium, copper, mercury, nickel, lead, zinc and arsenic present in
compost. For most countries and most applications of compost, the following
combination of heavy metals is allowed:
573
� ≤ 4 mg/kg d.m. cadmium
� ≤ 400 mg/kg d.m. chromium
� ≤ 600 mg/kg d.m. copper
� ≤ 4 mg/kg d.m. mercury
� ≤ 100 mg/kg d.m. nickel
� ≤ 300 mg/kg d.m. lead
� ≤ 1500 mg/kg d.m. zinc
� 10-20 mg/kg d.m. arsenic
Regarding PTEs, it is worth noting that following 10 years of experience in composting
in the Netherlands, a change in legislation in 2007 resulted in less strict heavy metal
thresholds, with experience instead recognising that nutrient content rather than
heavy metal content was proving the limiting factor on compost use within the
Netherlands. 697
Organic Contaminants
Several countries within the EU have established specific standards associated with
organic contaminants in compost. In Austria and the Czech Republic, these limits
relate to non-agricultural composts only, whereas in Belgium and Denmark the limits
relate to compost/digestate produced from treated biowaste; in Luxembourg, the
guide values are for both fresh and matured compost. Limit values are assigned for
combinations of the following contaminants: polychlorinated biphenyls (PCB),
polychlorinated dibenzofuran (PCCD/F), dioxins, polycyclic aromatic hydrocarbons
(PAH), absorbable organic halogens (AOX), hydrocarbons, linear alkylbenzene
sulphonates (LAS), nonylphenol (NPE) and di (2-ethylhexyl) phthalate (DEHP).
Countries such as Germany, the Netherlands and Italy do not currently impose any
organic-contaminant restrictions on their composts, due to the low levels of such
697 F. Amlinger, E. Favoino, M. Pollak, S. Peyr, M. Centemero and V. Caima (2004) Heavy metals and
organic compounds from wastes used as organic fertilisers, Study on behalf of the European
Commission, Directorate-General Environment, ENV .A.2,
http://europa.eu.int/comm/environment/waste/compost/index.htm
International Review of Waste Policy: Annexes

contaminants found in their composts 698 which they relate, at least in part, to the
source-separated biowaste collections in their countries.
Hygienisation
Annex VI of the ABPR provides detailed hygienisation rules for composting and biogas
plants that treat animal by-products in the EU. The general rules for Category 3
material according to Annex VI are:
574
� The maximum particle size before the material enters the unit/composting
reactor is 12 mm;
� The minimum temperature for all material in the unit/reactor is 70°C; and
� The minimum time at which all material must be at 70°C is 60 min.
However, as stated in the ABP regulation, process validation may be used as an
alternative treatment to fixed time-temperature regimes as long as it ensures the
minimisation of biological risk for Category 3 materials. The process must result in a
reduction of 5 log10 of Enterococcus faecalis or Salmonella Senftenberg (775W, H2S
negative) and infectivity titre of thermo-resistant viruses such as parvovirus by at least
3 log10, whenever such viruses are identified as a relevant hazard. In addition
Escherichia coli or Enterococcae are to be used as indicator organisms for approval
of the process and final BTP. A maximum number of bacteria in 1 g is set at 1,000 for
4 out of 5 samples and only in 1 sample can the bacteria number can be between
1,000 and 5,000. For the hygiene status of the product, Salmonella must be absent
in 25 g.
Annex VI does, however, show some deviations to the above rules. When manure or
digestive tract content are the only ABP material being treated, the competent
authority may also authorise the use of different specific requirements from those
stated above, provided that they do not consider that the material presents a risk of
spreading disease and that the residues/compost are considered to be unprocessed
material.
In addition, the case of catering waste has always been a special one as far as the
ABPR is concerned. Catering waste is defined in the ABP as all food waste originating
in both commercial and household kitchens/facilities. From the outset, the ABPR
effectively allowed Member States to set their own rules regarding Category 3
catering waste which was not from means of transport operating internationally
(Article 6(2)(g)). Thus, where catering waste is the only ABP being used as raw
material in the composting or AD plant, the competent authority may authorise
specific requirements other than those laid down in Annex VI of the ABPR.
However, although the Articles in the ABPR exempt Category 3 catering waste that is
not from means of transport operating internationally, Annex VI nonetheless
comments on this waste category, stating:
698 B. Deller, R. Kluge, M. Mokry, R. Bolduan and A. Trenkle (2008) Effects of Mid-Term Application of
Compost on Agricultural Soils in Field Trials of Practical Importance: Possible Risks. Compost and
Digestate: Sustainability, Benefits, Impacts for the Environment and for Plant Production, Proceedings
of the International Congress CODIS February 27-29, 2008.
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575
However, pending the adoption of rules in accordance with Article 6(2)(g), the
competent authority may, when catering waste is the only animal by-product
used as raw material in a biogas or composting plant, authorise the use of
processing standards other than those laid down in paragraphs 12 and 13
provided that they guarantee an equivalent effect regarding the reduction of
pathogens.
Annex VI thus adds confusion to the processing requirements for Category 3 catering
waste, particularly given that the amending Regulation 208/2006 inserted the
process validation tests discussed above just before this paragraph, which had
previously, in Regulation 1774/2001, followed paragraphs discussing temperature,
time and particle size. Thus it is not clear to what the term ‘equivalent effect’ refers,
and thus how it should be established and to what it is that ‘equivalence’ should be
demonstrated.
It is important to note that the ABP Regulation is currently being amended, with a
draft proposal and a working document with annexes currently under discussion
among stakeholders within the European community. Some commentators suggest
that it is likely that the existing exemption for catering waste, giving Member States
the possibility of setting national processing rules for catering waste, will be
maintained. 699
A number of countries have subsequently chosen the option of national regulations
for catering waste rather than adopting the ‘70°C for 1 h’ processing standard set out
under the ABPR. National regulations have been maintained mainly because in
practice, composting and digestion plants have found it difficult to implement the
Annex VI standard, particularly the 12 mm particle size requirement in composting
plants. All EU MSs have some test for pathogens; however, with the exception of the
Netherlands, the tests are set in terms of the presence of a given pathogen rather
than in terms of the level of reduction in the presence of the pathogen. Annex VI of
the ABPR concentrates on the latter, but it is difficult to see why this should be the
case from the perspective of the risks of using BTPs on land.
Denmark, France, Germany and Italy have all maintained their pre-ABPR timetemperature
regimes for catering waste. In addition, following amendment
208/2006, the Netherlands has developed its own process validation and
corresponding sampling regime which allows the spot test method to be used, in
order to show a 5 log10 pathogen reduction in the BTPs produced from the plants.
Only Belgium, Hungary, Latvia and Poland make use of the 70ºC for 1 h ABPR
hygienisation process for all ABP input materials, including catering wastes. For
Belgium/Flanders, however, the catering waste regulation is not considered relevant
for the majority of plants whose feedstock is vegetable, fruit and garden (VFG) waste,
with animal by-products excluded in the separate collection of biowaste.
For the remaining Category 3 waste (i.e. plants not solely accepting catering wastes),
the majority of EU MS have fully-implemented the Annex VI ABP regulations (i.e. 70ºC
699 F. Amlinger (2008) Implementation of the Animal By-Products Regulation (EC) no 1774/2001 in EU
Member States, Presentation at Orbit2008, 13-15th October 2008, Wageningen, The Netherlands.
International Review of Waste Policy: Annexes

for 1 h or equivalent process validation), including Belgium, Germany, Italy, the
Netherlands, Sweden and the United Kingdom. Likewise for manure, the ABP
regulations are followed in Belgium, the Czech Republic, Hungary, Latvia, the
Netherlands and Sweden; in the UK the 70ºC for 1 hour standard has to be followed
only where the manure is to be exported from the farm.
Outside of the EU, Canada has a statutory time-temperature regime for compost,
requiring 55ºC for 3 days in an in-vessel composting plant or aerated static pile, and
55ºC for 15 days in open windrow. The USA also requires a temperature of 55ºC, but
for either 5 days in an in-vessel facility or 15 days in open windrow. In Australia, three
turns of the windrow are required, with the requirement that the temperature reaches
55ºC for 3 days prior to each turn.
Physical Impurities
Plastics, metals and glass are the three main impurities limited in compost standards.
The majority of EU countries impose limits of some kind on physical impurities, but
the limits may vary from a combined maximum concentration of plastics, metals and
glass greater than a given particle size (Germany, Latvia and Spain), to individual
limits set for each type of impurity (Austria, Italy).
Land Application
The main restrictions on the use of compost relate to the amount of nutrients and/or
PTEs that can be applied to land in any one year. In Europe, the amount of nutrients is
governed to a large extent by the EU Nitrate Directive, with a maximum application of
170 kg N/ha/y, and 30-40 kg P/ha/y in Nitrate Vulnerable Zones (NVZ) in most
countries. In addition, countries such as Austria, Belgium and Italy are increasingly
taking account of the availability of nitrogen and phosphorus in their application
rates. This would tend to allow higher applications of compost than might otherwise
be the case, for the simple reason that nitrogen in compost is not as readily-available
to plants (or for leaching into groundwater) compared with nitrogen in synthetic
fertiliser.
In a number of countries, restrictions on compost use have also been determined
according to the class of compost produced. For example, in Austria there are three
classes of compost that can be produced:
576
� Category 1 material (Biowaste) of A+ quality (lowest heavy metal limits);
� Category 1 material and Category 2 material (quality sewage sludge
determined by heavy metal limits) of A+ and A quality (low heavy metal limits);
and
� Category 3 material (mixed MSW) of Quality B (highest heavy metal limits).
Only the former two classes can be used on agricultural land (with the first class being
suitable for organic farming as well); the final class can only be used for nonagricultural
applications such as landscaping and land reclamation.
Quality Assurance Schemes
In addition to the regulations listed above regarding compost standards, the use of
Quality Assurance Schemes (QASs) within a number of European countries has played
a key role in improving the status of compost in the eyes of the end users. QASs ‘start’
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where the abovementioned statutory standards that follow the precautionary principle
usually end, 700 looking to address issues related to the marketing of BTPs and
improve end-user confidence in the products. QASs can include public relations work,
detailed declarations of compost characteristics so that end users understand the
appropriateness of a given BTP for their purposes and verification/monitoring of
standardised products by independent organisations. QASs are well-established in
countries such as Austria, Belgium, Germany, Italy and Sweden. Though not
specifically a policy, QASs further increase the recycling potential for biodegradable
material by strengthening the markets for BTPs.
36.3 Key Organisations Involved in Implementation and
Management
The key organisations involved in implementing this policy are:
Department of Environment/Agriculture (National Government)
577
� Setting ‘precautionary’ compost standards and limit values.
Quality Assurance Schemes
� As stated above, QASs ‘start’ where the statutory standards that follow the
precautionary principle usually end, looking to address issues related to the
marketing of BTPs and improve end-user confidence in the products.
Laboratories
� Analysing the samples from the compost and AD plants to ensure they meet
the required statutory / voluntary standards as applicable.
Compost and AD plant operators
� Ensure that the compost/AD standards are met, particularly regarding
feedstock materials and hygienisation requirements.
� Implement new advances in technology to improve the composting/AD
process, and ensure that issues such as odours associated with plants are
kept to a minimum.
Organic waste collectors
� Arrange collection of municipal biodegradable waste feedstock for composting
and AD. Typically involves the local government.
Organic waste sources
� Source-separation of biowaste by householders and businesses for collection
to ensure quality input materials for composting/AD.
End-users
700 D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W. Devliegher, W. Brinton and S.
Antler (2002). Comparison of Compost Standards Within the EU, North America and Australasia.
Report for the Waste and Resources Action Programme.
International Review of Waste Policy: Annexes

Others
578
� In order that agricultural land in particular becomes a viable market, farming
communities must be convinced that the use of BTPs is beneficial to them and
does not bring adverse health or environmental consequences.
� Farmers often set up AD plants on their own farms at a smaller-scale to
process slurries and to provide energy. In Austria, for example, more than 110
farm-based biogas plants were in operation in 2002. It should be noted that
biogas plants in Austria that use organic waste have a higher return on the
electricity that they produce than those which ferment only agricultural
feedstock. In addition, farm-based AD plants are also regulated by the Green
Electricity Act 2002 for 13 years, ensuring certainty for long-terms strategies
on plant investments. 701
� Farmers must also abide by application limits imposed on their land.
� Other markets that use BTPs e.g. horticulture and landscaping.
� Scientific community undertaking studies to test the ‘risk’ associated with use
of BTPs, particularly in agriculture e.g. the strategic Miljøforsknings programme
in Denmark. 702
36.4 Pre-implementation / Evaluation Studies Available
F. Amlinger, S. Peyr, J. Geszti, P. Dreher, K. Weinfurtner and S. Nortcliff (2007)
Beneficial Effects of Compost Application on Fertility and Productivity of Soils:
Literature Study. Report produced for the Federal Ministry of Agriculture and Forestry,
Environment and Water Management, Austria.
J. Barth, F. Amlinger, E. Favoino, S. Siebert, B. Kehres, R. Gottschall, M. Bieker, A.
Löbig and W. Bidlingmaier (2008). Compost Production and Use in the EU. Report for
the European Commission DG/JRC.
D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W. Devliegher, W.
Brinton and S. Antler (2002). Comparison of Compost Standards Within the EU, North
America and Australasia. Report for the Waste and Resources Action Programme.
D. Hogg, D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of
Compost in Agriculture in Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.7
03534d2.6993.pdf .
701 C. Walla and W. Schneeberger (2003) Survey Of Farm Biogas Plants With Combined Heat And
Power Production In Austria, International Nordic Bioenergy 2003 Conference.
702 Center for Bæredygtig Arealanvendelse og Forvaltning af Miljøfremmede Stoffer, Kulstof og
Kvælstof, Aalborg Universitet. (2002). Det Strategiske Miljøforskningsprogram 1997-2000,
Slutrapport. Http://Info.Au.Dk/Smp/Smp_Dk/Publikationer/Slutrapport/KH%20-%20Slutrapport.Pdf
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36.5 Environmental Benefits
The environmental benefits associated with the implementation of standards for the
production of compost and digestate are several fold, ranging from the key
requirement of minimising risk to both human and animal health associated with the
application of BTPs to land, to the positive benefits related to the use of BTPs as a
fertiliser. In limiting the presence of contaminants such as PTEs and organic
contaminants in BTPs, these contaminants are also subsequently limited/ prevented
from building up in both the soil and surrounding water supplies when applied to the
land, and are thus prevented from building up within crops and animals based on that
land. Regarding positive soil-related benefits, these include the following: 703
579
� An increase in soil organic matter, and hence in soil quality during long-term (6
years or more) compost application trials, particularly when applying mature
rather than fresh compost to the soil ;
� After 3 to 6 years of application, a positive yield effect on a variety of crops
and a more stable yield (with compost able to balance yearly climatic
variations) compared to unfertilised and mineral-fertiliser control plots;
� A constant increase in total and available stock of macro-nutrients and
calcium in the soil, enabling the substitution of mineral fertilisers for compost;
and
� Suppression of soil-born plant diseases by mature compost application.
Compost must be mature (i.e. sufficiently stabilised) to ensure that pathogens
are not stimulated by readily assimilable carbon.
In addition to the benefits to land such as enhanced soil quality and to the reduction
in the need for mineral fertilisers, the use of compost standards and the resultant
increase in organic waste recycling diverts organic waste away from landfill. This
diversion is important, because it leads to a reduction in the production of
greenhouse gases from landfill sites, as well as producing BTPs and energy in the
composting and AD processes. The use of organic waste to produce energy via
anaerobic digestion also thus reduces our reliance on primary fuel sources.
Regarding the current collection and recycling of organic waste, a study by Barth et al.
(2008) 704 looking at compost production and use within the EU, found that the
collected and treated amounts of organic material vary widely from country to country.
The study found that, of the estimated 80 million tonnes of potentially-recoverable
organic waste, around 30 % is currently source-separated and treated via
composting/AD, resulting in the production of 10.5 million tonnes of compost
703 F. Amlinger, S. Peyr, J. Geszti, P. Dreher, K. Weinfurtner and S. Nortcliff (2007) Beneficial Effects of
Compost Application on Fertility and Productivity of Soils: Literature Study. Report produced for the
Federal Ministry of Agriculture and Forestry, Environment and Water Management, Austria.
704 J. Barth, F. Amlinger, E. Favoino, S. Siebert, B. Kehres, R. Gottschall, M. Bieker, A. Löbig and W.
Bidlingmaier (2008). Compost Production and Use in the EU. Report for the European Commission
DG/JRC.
International Review of Waste Policy: Annexes

throughout Europe. In addition, some MS also produce around 1.4 million tonnes of
compost from sewage sludge and a similar amount of compost from mixed waste.
Due to a general lack of consistently reported data on organic waste arisings, the
potentially-recoverable organic waste calculation is based on 150 kg per inhabitant
per year and includes source-separated kitchen and garden waste from households,
park and garden waste from public estates and industrial wastes. This figure appears
to be realistic given the amounts already collected in well-established biowaste
management systems such as Austria, Germany and the Netherlands, though
particularly for parks and non-household garden waste, data is not sufficient to be
able to say with any certainty the amount of this collected waste that will end up in
composting/AD facilities.
Table 36-2 illustrates how effectively the EU MSs separately collect the available
organic fraction of their national waste arisings for recycling purposes; the
Netherlands exceeds their potential according to the 150 kg per inhabitant per year
calculation, and Austria, Germany, Denmark, Finland and Luxembourg are all
relatively successful in terms of reaching their potential. These countries all have
reasonably well-developed compost/AD industries with statutory regulations
surrounding compost production; in addition, all except Denmark and Finland also
have a QAS to support the statutory framework. It should be noted that Denmark,
Finland and the Netherlands owe a large proportion of their success to extensive
garden waste collection and composting.
The success of minimum compost standards can also be measured by examining
whether any perception issues related to the use of compost have arisen in the enduser
markets for BTPs. The end-user market shares for compost (Table 36-3)
illustrate that a notable portion of compost is used in the higher-price markets such
as horticulture and greenhouse production, illustrating confidence of the market in
the product. In addition, Table 36-3 illustrates the dominant use of compost in
agriculture across the EU. Hogg et al. (2008) 705 recently acquired information on
perception issues related to use of BTPs in the agricultural sector via a series of
questionnaires sent to national experts across the EU. In those countries with mature
composting markets and a solid statutory compost quality base, perception issues
have been minimal both from the perspective of the farmer and of the householder.
For example, in Austria, householders have taken a very positive approach to organics
recycling, and open discussions between the Ministry and Chamber of Agriculture on
heavy metal and nutrient loads in agricultural soils have ensured that the market has
confidence in the thresholds that have been set. Following introduction of the ABPR,
farmers were actually offended at the implied need for additional requirements,
particularly as a large amount of composting takes place on-farm in Austria, with
farmers sometimes also being involved in the collection of household biowaste for
their facilities.
705 D. Hogg, D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of Compost in
Agriculture in Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.703534d2.6993.
pdf .
580
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Table 36-2 Amount (‘000 tonnes) of separately collected and composted/digested
biowaste and green waste in the EU (2005)
Potential Potential Potential quantities
quantities
Separately Separately Separately collected
collected
[without [without home home home composting] composting] (3)
Separately Separately
Separately
Collected
Collected
MS
Tot Total Tot al MSW
(1) Bio-
waste
waste
Green
Green
waste
waste
Total
Total
(2)
Biowaste Biowaste
Biowaste
Green
Green
waste waste
waste
Total
Total
Biowaste
Biowaste
[% [% of of of total
total
potentially-
potentially
recoverable]
recoverable]
recoverable]
AT AT
3,419 750 950 1,700 546 950 1,496 88%
BE 4,847 n.d. n.d. 2,573 n.d. n.d. 885 34%
BG* BG* 3,593 n.d. n.d. 1,164 0 0 0 0%
CY* CY* 554 n.d. n.d. 112 0 0 0 0%
CZ CZ
3979 1354 180 1534 10 123 133 9%
DE DE
37,266 8,000 8,000 16,000 4,084 4,254 8,338 52%
DK 3,988 433 750 1,183 38 737 775 66%
EE EE
556 195 130 325 0 0 0 0%
ES* ES* 25,694 n.d. n.d. 6,456 n.d. n.d. 308 5%
FI* 2,451 n.d. n.d. 785 350 100 450 57%
FR* FR* FR* 46,000 n.d. n.d. 9,378 300 2,400 2,700 29%
GR* GR* 4,854 n.d. n.d. 1,662 0 2 2 0%
HU* HU* 4,446 n.d. n.d. 1,515 n.d. n.d. 127 8%
IE IE (2007) (4) 3,174 n.d. n.d. 918 n.d n.d 79 8.6%
IT 31,687 n.d. n.d. 8,700 2,050 380 2,430 28%
LT* 1,295 n.d. n.d. 514 0 0 0 0%
LU* LU* 321 n.d. n.d. 68 n.d. n.d. 52 76%
LV* LV* 715 n.d. n.d. 346 0 0 0 0%
MT* MT* 246 n.d. n.d. 60 0 0 0 0%
NL* NL* 10,900 n.d. n.d. 2,446 1,656 1,700 3,356 137%
PL* PL* 9,353 n.d. n.d. 5,726 n.d. n.d. 70 1%
PT 4,696 n.d. n.d. 1,579 24 10 34 2%
RO* RO* 8,274 n.d. n.d. 3,249 0 0 0 0%
SE* SE* 4,343 n.d. n.d. 1,352 125 250 375 28%
SI* 845 n.d. n.d. 300 0 0 0 0%
SK* SK* 1,558 n.d. n.d. 808 5 68 73 9%
UK* UK* 35,075 n.d. n.d. 9,009 n.d. n.d. 1,872 21%
EU27 EU27 257,947 80,101 23,598 23,598 29.5%
(1) Source: Eurostat website (http://epp.eurostat.ec.europa.eu)
(2) In most cases individual estimations by national experts were missing. For all MS marked with an
‘*’ the realistic potential of biowaste and green waste collection is based on the assumption of 150
kg/Inh*y
(3) The estimation of currently collected biowaste and green waste has been provided by national
experts contacted during the elaboration of this study. The reference year was 2005.
(4) Environmental Protection Agency (2009) National Waste Report 2007.
Source: Barth, J., Amlinger, F., Favoino, E., Siebert, S., Kehres, B., Gottschall, R., Bieker, M., Löbig, A.
and Bidlingmaier, W. (2008). Compost Production and Use in the EU. Report for the European
Commission DG/JRC.
581
International Review of Waste Policy: Annexes

Table 36-3 Compost Market Shares of Various Sectors within the EU (%)
582
Country Country AT AT BE/Fl BE/Fl BE/Fl DE DE ES
29/09/09
ES 1) FI
FI FR
FR
FR 2) HU
HU IE IE IT
NL
NL
bio bio- bio
waste
waste
NL NL 1)
green
green
waste waste PL
PL
PL 2) SE
SE UK
Sect Sector Sect or 2003 2005 2005 2006 2005 2005 2005 2006 2003 2005 2005 2005 2005 2005 %
Mean
Mean
EU
EU
Agriculture Agriculture 40.0 1.0 53.4 88.0 20.0 71.0 55.0 37.0 51.0 74.8 44.4 - - 30.0 48.0
48.0
Horticulture Horticulture Horticulture &
&
green green house
house
production
production
10.0 1.0 3.9 8.0 - 25.0 15.0 3.0 - - 15.5 - 5.0 13.0 11.3
11.3
La Landscaping
La ndscaping 15.0 22.0 15.9 4.0 20.0 - 10.0 6.0 6.0 3.6 12.3 - 20.0 14.0 12.4
12.4
Blends Blends 15.0 6.0 13.6 - 10.0 - - 16.0 15.0 5.1 - 2.0 10.3
10.3
Soil Soil mixing
mixing
companies
companies
2.0 21.0 - - - - - - - - 9.4 - 10.0 - 10.6
10.6
Wholesalers Wholesalers - 9.0 - - - - - - - - 5.2 - 15.0 - 9.7
Hobby obby
gardening
gardening
Land Land resto resto- resto
ration ration and
and
landfill landfill landfill cover
cover
15.0 20.0 11.9 - - 4.0 5.0 - 27.0 1.1 2.3 - 10.0 25.0 11.0
11.0
2.0 1.0 - - 50.0 - 15.0 38 2.0 - - 100.0 40.0 16.0 26.4
26.4
Export Export 1.0 7.0 - - - - - - - 5.5 5.0 - - - 4.6 4.6
Others Others Others - 2.0 1.3 - - - - - - - 0.8 - - - 1.4 1.4
1) Green waste compost; 2) Mainly mixed waste compost
Source: Barth, J., Amlinger, F., Favoino, E., Siebert, S., Kehres, B., Gottschall, R., Bieker, M., Löbig, A.
and Bidlingmaier, W. (2008). Compost Production and Use in the EU. Report for the European
Commission DG/JRC.
In Denmark, the key perception issue has been to ensure that all consumers are
happy that they are not purchasing anything which poses a risk to human or animal
health, with policy around compost standards designed to address these concerns.
Additional obstacles to further increases in composting have mostly related to the
successful collection of source-separated biowaste, and in overcoming the short-term
slower release of nitrogen from compost compared to from mineral fertilisers. 706 It is
interesting to note that the overall proportion of sewage sludge being used in
composting/AD plants in Denmark is decreasing over time in favour of source-
706 J. Luxhøi, P.H.B. Poulsen, J. Møller and J. Magid (2008). Quality Parameters of Compost Amended
with Chitin. Compost and Digestate: Sustainability, Benefits, Impacts for the Environment and for Plant
Production, Proceedings of the International Congress CODIS February 27-29, 2008.

separated kitchen and garden waste, because the outputs achieved from sewage
sludge no longer achieve the standards that farmers demand to maintain an
ecologically safe farm.
In Germany, once it was made clear that composts were no longer to be derived from
mixed wastes, a positive perception of compost was formed in those BTP markets
other than agriculture, especially in the landscaping and growing media sector.
Representatives from business sectors such as landscaping and growing media were
substantially involved in the foundation of the German Compost Quality Assurance
Organisation and the development of standards and application recommendations. In
the agricultural sector, the agricultural branch organisation and authorities were
initially typically against the use of compost in agriculture, with political rivalry
between the Ministry of the Environment (pro- compost use) and the Ministry of
Agriculture (against compost use) fuelling the debate. Nevertheless, personal
relationships between compost producers and farmers helped to build up the
necessary confidence for the use of compost in agricultural practice.
Continuing development of trust between compost producers and farmers, success
stories within the farming sector, and the strictly quality-oriented work of the German
QAS all helped build confidence within the agricultural sector on the use of compost.
Nevertheless, it took nearly 10 years before the first generally available brochure for
compost application in agriculture was published. Confidence was, nonetheless,
sufficient that even when animal protein was found in sugar beets and the sugar beet
organisation subsequently forbade their member farms to use compost (a loss of
30% of the German compost market), the sugar beet industry remained open to
discussions with the compost sector, and to the outcomes of research, which finally
identified the source of the protein as coming not from compost, but from rodents
living on the sugar beet storage piles at the border of the fields.
There has been a particularly strong focus on AD technology in Sweden due to
national support and a demand for upgraded biogas as a vehicle fuel. There is a
positive awareness of the need to recycle and re-use organic waste to reduce fossil
fuel requirements and climatic impacts. The majority of BTP standards in Sweden are
based on voluntary agreements rather than statutory regulations, due to the high
quality BTPs that are produced in Sweden, which in turn, are related to input material
controls. Farmers have used 98 % of digestate outputs on agricultural land in 2008,
illustrating the faith that farmers have in this product as being ecologically safe; in
contrast, the majority of compost outputs are used by the growing media/substrate
market due to economic viability.
36.6 Implementation Costs
A variety of factors contribute to the implementation costs of composting/AD
standards; these will include;
583
� Feedstock collection costs to ensure minimal contamination;
� Monitoring costs of composting/AD process and product;
� Technology used (composter/AD plant type); and
� Marketing costs for the product.
International Review of Waste Policy: Annexes

Within the compost industry, implementation costs across the EU are predominantly
met via income from gate fees and energy production, rather than reflecting the
‘actual’ value of the compost in relation to market demand and production costs.
Only very few companies have developed their local market sufficiently in order that
their compost sales actually contribute to their economic success.
36.7 Effects on Technical Change / Innovation
584
� The development of separate collection systems in order to increase the
material available for composting/ AD and reduce the presence of
contaminants and physical impurities in the feedstock for BTP production, The
aforementioned example of Denmark (Section 32.4) illustrates a move away
from the use of sewage sludge as an input material and the move instead
towards source-separate collection of biowaste in order to meet the required
quality for end-user markets.
� Development of laboratory testing/procedures to ensure that the BTPs meet
the desired quality requirements for the end-user.
36.8 Complementary Policies
� Landfill Directive; specifies the requirement to divert biodegradable waste
from landfill, hence promoting the need for the separate collection of biowaste
and subsequent compost/AD processes.
� Nitrate Directive; specifies maximum application rates of nitrogen in nitratevulnerable
zones, hence limits the application of BTPs accordingly.
� Mandates to separate organic wastes at source (see Annexes 34.0 and 35.0);
� Energy tariffs and the Renewables Obligation Certificate (ROCs); as noted in
Section 36.3, those AD plants in Austria that use organic waste as well as
agricultural feedstocks have a higher return on the electricity that they
produce than those which ferment only agricultural feedstock. In addition,
farm-based AD plants are also regulated by the Green Electricity Act 2002 for
13 years, ensuring certainty for long-terms strategies on plant investments. 707
In the United Kingdom, Renewables Obligation Certificates are offered to
renewable electricity generators for every MWh of electricity generated which
can then be sold to other energy suppliers in order to help them fulfil their
renewable energy obligation. Double ROCs are currently being considered for
the production of electricity from anaerobic digestion plants. 708
707 C. Walla and W. Schneeberger (2003) Survey Of Farm Biogas Plants With Combined Heat And
Power Production In Austria, International Nordic Bioenergy 2003 Conference.
708 UK Trade and Investment Services (2007) UK Government Builds on Renewable Energy Incentives,
available at http://www.ukinvest.gov.uk/feature/4014905/en-GB.html.
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36.9 Effect of the Policy on Pricing of Resources / Services
The use of minimum standards and QASs associated with BTPs has allowed countries
to market waste as a product following treatment, thus allowing it to compete in
markets with synthetic fertilisers. However, as already discussed in Section 36.6,
implementation costs across the EU are predominantly met via income from gate fees
and energy sales rather than reflecting the ‘actual’ value of the compost in relation to
market demand and production costs. Several companies have, nonetheless,
developed their local market sufficiently in order that their compost sales actually
contribute to their economic success. In addition, particularly in those countries that
have a more mature compost market, there is greater economic incentive to enter
into the revenue-oriented higher price markets. In order that the end-user has
sufficient confidence in the product, these markets require that stringent QAS
standards are met. Without such standards, the majority of trading would only occur
on a more personal basis between, for example, farmers and the local community.
Prices differ quite significantly from country to country, depending mainly on the
marketing strategies of the plants. A number of plants (predominantly municipalityowned)
obscure the market, because they exist not to make profit, but to encourage
and facilitate organics recycling of municipal waste. According to Barth et al.
(2008) 709 , detailed evaluation of German and Belgian compost markets found that
compost prices ranged from €0 to €29 per tonne for most end-user markets.
36.10 Evasion and Enforcement
Monitoring of compost/AD plants to ensure that they deliver the required standards is
typically undertaken directly by local government bodies; for example, in Germany, the
local EPAs are the competent authorities for the approval, control and monitoring of
the operation of the treatment plants. 710 In Denmark, the Danish Plant Directorate
supervises the quality of products from public plants and the municipalities are
charged with supervising the land-use of those products. In addition, for QAS
schemes there typically exists additional monitoring; using Germany as an example,
there is a step-by-step mechanism for applying sanctions where:
585
Step1: Step1: Non-fulfilment is registered: Following registration, written notification
will be sent to the treatment plant, giving a time period (e.g. 3-months) for
rectifying problems;
Step Step 2: 2: Demands are still not fulfilled: The quality label is suspended for a
limited time, in which the treatment plant may not use the quality
label/certification. The monitoring system continues and the treatment plant
has to fulfil all requirements over a further period. If there are no problems in
709 J. Barth, F. Amlinger, E. Favoino, S. Siebert, B. Kehres, R. Gottschall, M. Bieker, A. Löbig and W.
Bidlingmaier (2008). Compost Production and Use in the EU. Report for the European Commission
DG/JRC.
710 International Solid Waste Association. (2006) Biological Waste Treatment Survey. Edited by W.
Rogalski and C. F. Schleiss.
International Review of Waste Policy: Annexes

586
29/09/09
this respect, then after this period has elapsed, the quality label can be regranted;
Step Step Step 3: 3: 3: If there are still any problems: The Quality Label will be withdrawn. If
the plant wishes to participate again in the QAS, they have to re-apply for the
Quality Label and re-submit to the approval procedure.
While Step 1 can be an automatic procedure, the second step might be discussed
and decided within the committee of independent experts of the QAS. The quality
assurance/certification has to have a kind of an official status, as withdrawal affects
the economic prospects of the compost plant. 711
36.11 Lessons Learned
Feedstocks and maximum environmental benefits
A study undertaken by Eunomia illustrates that the ability to maximise environmental
benefits associated with the collection of household kitchen and garden waste is
most effective when these are collected separately, with the majority of kitchen waste
able to be processed via anaerobic digestion to produce energy and digestate (which
could subsequently be applied to land as a nutrient source), and the garden waste
treated via windrow composting to minimise costs. 712 This example illustrates the
importance of defining input materials and collection systems in determining the
subsequent environmental benefits associated with compost production.
Hygienisation requirements
The default 12 mm particle size required prior to material entering the reactor/unit
according to the ABPR 208/2006 has created difficulties in practice for many
composting plants. In Finland, for example, the compost had to be screened after 10
days and the composting process then started again on the finer material in order to
meet this requirement. Finland has subsequently changed its hygienisation process
for catering wastes, allowing a maximum particle size of 40 mm and timetemperature
requirements of 60 ºC for 14 days or 65 ºC for 7 days, with a growing
number of plants opting to meet their hygienisation requirements via process
validation.
End-User confidence in the product
Switzerland provides an example of the need to ensure confidence of farmers in BTPs
in order for the closed-loop recycling of organic wastes to work effectively. Back in
2002 and 2003, the agricultural sector was becoming nervous regarding the use of
sewage sludge on their land because of Bovine spongiform encephalopathy reports;
many long-term users of sewage sludge rapidly lost their confidence in the quality the
711 D. Hogg, J. Barth, E. Favoino, M. Centemero, V. Caimi, F. Amlinger, W. Devliegher, W. Brinton and S.
Antler (2002). Comparison of Compost Standards Within the EU, North America and Australasia.
Report for the Waste and Resources Action Programme.
712 Eunomia (2007) Dealing with Food Waste in the UK, Final Report for WRAP.

product, especially when bioactive organic compounds were found to be present in
the sludge. As is written in Hogg et al. (2008). 713
587
“Big retailers such as MIGROS and COOP requested that their suppliers stop
using sewage sludge. Consequently, the use of sewage sludge in agriculture
dropped drastically, even before any restrictive regulation was in force. The
government had to find emergency solutions for the elimination of sewage
sludge; a wide-ranging research project about compost was started,
particularly to try to understand the degree to which fears regarding the
quality of BTPs were justified. Results of two research studies demonstrated
that the composts in Switzerland were of good quality, but also identified
further improvements that were desirable. The research clearly demonstrated
the positive effects of the use of compost in preventing plant diseases in
agriculture and horticulture. It appears that, rather than having too much
biowaste for composting / digestion and a resultant surplus of BTPs,
Switzerland now faces a shortage of supply, with energy companies turning to
waste as a potential renewable energy supply, and interest in anaerobic
digestion growing significantly as a result.”
Livestock Pathogens
A recent survey suggests that the existing approaches in those countries with most
experience of composting and anaerobic digestion have generated no obvious
problems in respect of livestock pathogens. The study notes: 714
In conclusion, empirical evidence provides little support to the view that the
use of BTPs in agriculture poses an unacceptable level of risk to farmers, their
crops or their livestock, provided that systems are in place which seek to
assure the quality of the BTPs. This does not mean there is zero risk
associated with the use of compost. Hence, one could not suggest that the
apparent absence of such a problem in the past is evidence of the
impossibility of problems arising in future. It does however suggest that these
risks are minimal and that the systems in place may be providing appropriate
means to manage them.
Furthermore, in some countries with longer experience with the use of BTPs in
agriculture, the existence of quality assurance schemes has apparently led to
an increase in confidence in the use of BTPs in agriculture over time,
sometimes in the wake of what were, initially, distinctly unenthusiastic
responses to such possible use.
713 D. Hogg, D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of Compost in
Agriculture in Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.703534d2.6993.
pdf .
714 D. Hogg, D. Lister, J. Barth, E. Favoino and F. Amlinger (2009) Frameworks for Use of Compost in
Agriculture in Europe, Final report for WRAP, January 2009
http://www.wrap.org.uk/downloads/Eunomia_compost_in_agriculture_final_report.703534d2.6993.
pdf .
International Review of Waste Policy: Annexes

37.0 Animal By–Products Regulations – Ireland
37.1 Outline of Policy
Animal by-products (ABP) include bodies of animals, parts of animals or products of
animal origin that are not intended for human consumption. A large amount of
catering waste and former foodstuffs also fall within the definition of ABP. Some
animal by-products are used in animal proteins such as meat and bone meal, fats,
gelatine, collagen etc. Each year around 550,000 tonnes of raw ABP is produced in
Ireland. 715 The use or disposal of this material has to be strictly controlled, in order to
protect both public and animal health.
On the 3 October 2002 the EU adopted Regulation EC 1774/2002 716, which lays
down strict rules concerning the collection, transport, storage, handling, processing
and use or disposal of all ABP not intended for human consumption. This regulation
defines animal by-products as “entire bodies or parts of animals or products of
animal origin… not intended for human consumption”.
The EU Animal By-Products Regulation aims to ensure that all meat and other
products of animal origin, which are processed by composting, must meet specific
treatment standards, to ensure sufficient pathogen removal in order that the treated
compost may be safely applied to land. This Regulation permits the treatment in
approved composting and biogas premises of low-risk animal by-products including
catering waste. For the purpose of this review the focus is on composting. Biogas is
not considered in detail as these facilities are primarily concerned with the treatment
of industrial waste in Ireland at present.
The Regulations classify ABP into 3 categories depending on their potential risk to
animals, the public and the environment and sets out how each category must or may
be disposed of.
588
� Category Category Category 1 1 material is very high risk material consisting of Specified Risk
Material (SRM), animals suspected or confirmed of being infected with
Transmissible Spongiform Encephalopathies (TSE) or Scrapie, animals killed in
the context of TSE controls, carcasses of pet animals and international
catering waste. Category 1 ABPs may only be disposed of by incineration, coincineration
or rendering in a plant approved to handle Category 1 ABP.
Category 1 catering waste from international transport may be disposed of in
an approved landfill.
� Category Category 2 2 material is of medium risk and includes materials such as
condemned meat, fallen stock, manure or animal by-products presenting a
715 Department of Agriculture, Fisheries and Food – Information Notes.
716 EC No 1774/2002 of the European Parliament and of the Council – Laying down health rules
concerning Animal By-Products not intended for human consumption.
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589
risk of contamination with other animal diseases. This includes animals, which
die or are killed in the context of disease control measures on a farm.
Permissible disposal routes for Category 2 material include incineration, coincineration
and rendering. Provided that the material comes from wild
animals, which were not killed or did not die as a result of a disease
communicable to humans or animals, use of feed is allowed under
authorisation to recognised species of animal. Some Category 2 ABPs can also
be treated in composting or biogas plants, or can be used in oleochemical
plant.
� Category Category Category 33
3 3 material is the lowest risk category and includes material which
has previously been fit for human consumption, including catering waste, raw
meat and fish, hides and skins, animal by-products derived from the
processing of products and by-products which do not show signs of
transmissible disease. Category 3 ABPs may be disposed of by various means
including at biogas plants and composting facilities.
Catering waste is defined in the EU Regulation as ‘all waste food including used
cooking oil originating in restaurants, catering facilities and kitchens (including central
kitchens and household kitchens).
Under the EU Regulation, a composting plants is defined as follows:
‘A plant in which biological degradation of products of animal origin is undertaken
under aerobic conditions’.
Animal by-products are to be collected and transported by approved licensed hauliers
and can only be stored and processed at approved licensed facilities. The Department
of Agriculture, Fisheries and Food (DAFF) must approve all premises involved in the
treatment of ABP. Pet food facilities also require a licence to operate.
Annex 5 of the Regulation requires ‘complete separation of building between a
processing plant and a slaughterhouse’. This is to ensure no cross contamination or
substitution (voluntary or otherwise) between material intended for human
consumption, material intended for animal consumption and material destined for
disposal or recovery. An approved establishment must meet the required level of
separation.
37.2 Policy Context and Reason for Introduction
The purpose of the legislation is to safeguard humans and animal health by providing
controls for the safe use and disposal of animal by-products hence avoiding
contamination of the food chain.
The scientific basis for the ABP Legislation is to prevent the risk of disease, as
epidemiological studies carried out on Bovine Spongiform Encephalopathy BSE, the
dioxin scare, animal diseases such as Foot and Mouth Disease and Classical Swine
Fever have all identified animal-by products as the source. It is believed that the
outbreaks in the UK in recent years of both foot-and-mouth and swine fever were
caused by contaminated catering waste and therefore Ireland needs to ensure that all
ABP are disposed of properly.
International Review of Waste Policy: Annexes

37.3 When was the Policy Introduced?
Regulation EC 1774/2002 was transposed into Irish Law on May 1 2003 by the
Animal By-Product Regulations 2003 (S.I. No. 248 of 2003) 717 and by the Animal By-
Products (Amendment) Regulations 2005 (S.I. 707 of 2005) 718 . The legislation
permitted Member States to introduce national legislation to complement and
enforce the EU rules. EU Regulation No. 208/2006 719 provides for composting plants
to operate to other standards subject to appropriate validation and a full risk
assessment of the standards. Ireland introduced the following legislation to
complement the EU rules:
590
� S.I. No. 612 (Transmissible Spongiform Encephalopathies and Animal By-
Products) Regulations 2006 implements EU Regulation No. 181 of 2006; and
� S. I. No. 615 (Diseases of Animals Act 1966) (Transmissible Spongiform
Encephalopathies) (Fertilisers and Soil Improvers) Order 2006 applies stricter
national rules for organic fertilisers and soil improvers under EU Regulation
No. 181 of 2006.
Following a consultation process, these statutory instruments were subsequently
amended in 2008 to the following:
� S.I. No. 252 of 2008 (European Communities (Transmissible Spongiform
Encephalopathies and Animal By-Products) Regulations 2008; and
� S.I. No. 253 of 2008 (Diseases of Animals Act 1966 (Transmissible
Spongiform Encephalopathies) (Fertilisers and Soil improvers) Order 2008.
In addition milk and dairy products can be fed to animals, subject to the restrictions
set out in EU Regulation 79/2005 720 . The Swill Order (S.I. 597/2001) 721 bans the
feeding to farm animals of ‘any broken or waste foodstuff (including table, catering or
kitchen refuse, scraps or waste)’. However, the order makes an exception for cereal
grains, edible material of plant or vegetable origin, bread and dough (including
biscuits) and chocolate that has not been in contact with an animal or animal
product. On January 20 2009, S.I. No. 12 of 2009 722 amended Statutory Instrument
No. 597/2001 permitting the collection, assembly, processing and storage of swill at
approved composting plants.
717 S.I. No. 248 of 2003, Animal By-Product Regulations 2003.
718 S.I. No. 707 of 2005, Animal By-Products (Amendment) Regulations 2005.
719 EC No.208/2006 of the European Parliament and of the Council as regards processing standards
for biogas and composting plants and requirements for manure.
720 EC No. 79 of 2005 of the European Parliament and of the Council implementing Regulation (EC)
No 1774/2002 of the European Parliament and of the Council as regards the use of milk, milk-based
products and milk-derived products, defined as Category 3 material in that Regulation.
721 S.I. No. 597 of 2001. Diseases of Animals Act, 1966 (Prohibition on the Use of Swill) Order, 2001.
722 S.I. No. 12 of 2009 Diseases of Animals Act, 1966 (Prohibition on the Use of Swill) (Amendment)
Order 2009.
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37.4 Key Organisations Involved in Implementation and
Management
Implementation of ABP Regulations is handled by a number of bodies. The
Department of Agriculture Fisheries and Food (DAFF) is the central competent
authority with its primary role as regulator. All premises involved in the composting
treatment of animal by-products must be approved by DAFF. Such approval is
additional to any planning or other licensing approval that may be required. DAFF
support the development of a quality compost industry and focus specifically on the
safe use of ABP as a compost feedstock. DAFF’s main aim is to promote an
environment friendly and sustainable process. DAFF also provide veterinary
inspectors to carry out monthly, quarterly or annual inspections on facilities
depending on the terms of the licence or in the instance of a complaint. The Local
Authority Veterinary Service is responsible for ABP issues in smaller local abattoirs;
and the Health Service Executive, deals with retail outlets handling ABP, such as
butchers 723.
37.5 Monitoring and Measurement Techniques Applied
Compost plants treating Category 3 animal by-products and catering waste must meet
certain time/temperature treatment standards as set out in Annex VI of EU Regulation
1774/2002. The EU standard for treatment of animal by-products (including milk and
manure) is treatment at 70°C for 1 hour with a maximum particle size of 12mm.
Catering waste (with or without manure and/or digestive tract content) may be
treated to the Irish National Standard: 60°C for 48 hours (twice) with a maximum
particle size of 400mm. This is allowable owing to the exemption afforded to catering
waste which is not of international origin under Article 6 of the EU ABP Regulations.
SI 253/2008 permits that the spreading of organic fertiliser/soil improvers derived
from the list of feedstocks given below is permissible provided farmed animals do not
have access to the land concerned for at least 21 days following application. The 21
day period is extended to 60 days in the case of pigs because of their susceptibility to
disease. The restriction applies mainly but not exclusively to pastureland. In addition,
ensiled crop or hay can also be made after 21 days of landspreading compost on that
land.
The permissible feedstocks are as follows:
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� Catering waste as defined in Article 6 1 (l), EU Regulation 1774/2002;
� Former foodstuffs as defined in Article 6 1 (f), EU Regulation 1774/2002,
including raw materials;
� Manure and digestive tract content;
� Raw milk from animals not showing signs of any communicable disease as
defined in Article 6 1 (g), EU Regulation 1774/2002;
723 Department of Agriculture, Fisheries and Food – Frequently Asked Questions.
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592
� Fresh by-products from fish as defined in Article 6 1 (i), EU Regulation
1774/2002;
� Fish or other sea animals caught in the open sea for the purpose of fishmeal
production as defined in Article 6 1 (h), EU Regulation 1774/2002 ;
� Shells, hatchery by-products and cracked egg products from animals not
showing signs of any communicable disease, as defined in Article 6 1 (j), EU
Regulation 1774/2002; and
� Feathers.
37.5.1 Evaluation Studies Available
There are no ex post evaluation studies available. The Department of Agriculture,
Food and Fisheries was contacted in relation to studies carried out on the progress of
the ABP Regulations in preventing the risk of disease and epidemiological outbreaks.
They are unaware of any such evaluation studies.
� Cré – Composting Association of Ireland Teo, Irish Bioenergy Association, Irish
Waste Management Association, October 2007 - Submission to the
Department of Agriculture, Fisheries and Food on ABP Regulations;
� Cré – Composting Association of Ireland Teo, November 2008 - Submission to
the Department of Agriculture, Fisheries and Food on Draft ABP Compost
Guidance Document;
� Cré – Composting Association of Ireland Teo, February 2009 - Submission to
Eunomia on Review of Policies for Composting/Digestion in relation to the
International Review of Waste Management Policy in Ireland;
� EPA National Waste Report 2007; and
� EPA Report published in 2002 “Assessment and Evaluation of Outlets of
Compost Produced From Municipal Waste. 724 ” This document provides a
national strategy to develop adequate and reliable compost market and nonmarket
outlets for the putrescible fraction of biodegradable waste.
37.6 Environmental Benefits
Under the National Strategy on Biodegradable Waste, the Government has
established targets to meet for the recycling or composting of household waste for
Ireland. By 2010, 25% of all household waste must be recycled or composted. Under
the EU Landfill Directive, Ireland also has to meet targets for the reduction of
biodegradable municipal waste sent for landfill. By 2010 the amount of
biodegradable municipal waste sent for landfill must be reduced to 25% of the
amount produced in 1995. The development of composting and biogas plants will be
necessary for achieving these targets.
724 Paul van der Werf, Caitríona Carter, Gene Browne, Mac Dara Hosty (2002) Assessment and
Evaluation of Outlets of Compost Produced From Municipal Waste, Report to the EPA.
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37.6.1 Environmental Benefits - Prevention
Waste prevention falls under the definition of minimising the quantity and
hazardousness of waste generated. The ABP Regulations ultimately prevent the risk
of disease caused by contaminated ABP and catering waste by introducing controls
for the safe use and disposal of animal by-products hence avoiding contamination of
the food chain.
37.6.2 Environmental Benefits Associated with Recycling
The manner of implementation of the ABP Regulations, although not completely a
‘recycling policy’, will determine the costs of meeting, and the ease of meeting,
specific targets for ensuring biodegradable waste is not landfilled. It has been
commented elsewhere in the UK for example) that it is anomalous that the Directive
does not address the issue of potential transmission of livestock diseases at landfills.
Consequently, few rules apply to landfilling ABP, but rules apply to composting and
biogas plants.
Studies elsewhere suggest that, in particular where biogas plants are used, the
environmental benefits of recycling biodegradable waste are positive relative to
residual waste treatment / disposal. Hence, a rational and proportionate
implementation of the ABPR has the potential to a) enhance the sustainability of
management of biodegradable wastes whilst b) giving confidence to end-users of
compost that the end product is adequately hygienised. On the other hand, an
onerous and disproportionate approach would risk undermining the potential benefits
to be derived (not least in agriculture itself).
37.7 Implementation Costs
The Department of Agriculture, Food and Fisheries incurred a number of costs in
relation to the administering of the policy. DAFF were contacted in relation to
implementation costs and were unable to provide information on this. Facility
operators do not pay fees in relation to the regulations. They do, however, have to
ensure their facility is operated in line with DAFF requirements (see below).
37.8 Response from Public and Industry
The outbreak of foot-and-mouth disease in the country in 2001 led to the introduction
of rigorous legislation in Ireland, which greatly restricted the siting, reception, and
processing of animal by-products and the beneficial uses permissible for the treated
products. To provide clarity on the veterinary requirements, the Department of
Agriculture and Food issued draft information notes Conditions for Approval and
Operation of Composting Plants Treating Animal By-Products in Ireland and Guidance
for Applicants Wishing to Treat Animal By-Products in Composting and Biogas Plants
in Ireland.
A number of submissions were received from industry, citing concern in relation to the
legislation. Issues in relation to the requirements of double fencing, compost end-use
labelling, compost end-use recording to horticulture, hygiene and validation were
highlighted in the submissions. The latest draft of the conditions has taken these
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concerns into consideration allowing less stringent and more workable regulations for
composting.
The ABP Regulations establish a quality assurance scheme for the production of
compost which should reassure end users of the hygienic nature of the end product.
This ought to help stimulate demand and hence instil a confidence amongst potential
users and the public.
A number of food businesses have been affected by the implementation of the policy.
These include food manufacturers, butchers, fishmongers, bakers, retailers, caterers
and distributors. Waste from all of these premises must be disposed of in accordance
with the Regulations.
Existing research on the potential outlets for compost derived from biodegradable
waste, which suggested outlets for 447,750 tonnes of compost per annum, may be
considered quite optimistic. 725 Animal by-products legislation imposes some
landspreading restrictions on compost derived from specific materials. The advent of
the Nitrates Directive may also mean that farmers may be reluctant to accept
nutrients from off-farm sources. Regulations on the nutrient availability and spreading
of sludge will restrict the economic viability of landspreading, and more generally
there is public opposition to landspreading of treated waste. 726
Development of markets for the recovered biodegradable municipal waste is central
to the success of the National Strategy on Biodegradable Waste. A Market
Development Group of key stakeholders was established in 2004, under the
guidance of the Department, with the objective of driving forward the development of
existing markets for recyclables and identifying new applications and markets for
recyclables and secondary recycled products 727 . Given a high-quality sourceseparated
feedstock, it is important to ensure that the composting process will result
in compost that has similar qualities to existing organic amendments, as well as the
ability to develop unique and potentially marketable attributes. Reasonable process
management requirements, monitoring and end-product requirements should be
developed. It may be useful to develop a guide to assist producers of compost in
making a high-quality product. 728
37.9 Effects on Technical Change / Innovation
The Regulations will clearly affect, directly, the operation of composting and biogas
facilities. The intention of the Regulations is to ensure that techniques render the
outputs unproblematic when they are spread on land.
725 Paul van der Werf, Caitríona Carter, Gene Browne, Mac Dara Hosty (2002) Assessment and
Evaluation of Outlets of Compost Produced From Municipal Waste, Report to the EPA.
726 EPA (2008) Hitting the Targets for Biodegradable Municipal Waste: Ten Options for Change,
Wexford: EPA, January 2008.
727 Department of the Environment, Heritage and Local Government, July 2008 - Circular WPPR 17/08.
728 Paul van der Werf, Caitríona Carter, Gene Browne, Mac Dara Hosty (2002) Assessment and
Evaluation of Outlets of Compost Produced From Municipal Waste, Report to the EPA.
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For proposed new composting facilities wishing to process animal by-products
including catering waste, the approval process is separated into two stages. The first
stage is a notification of intention to build a facility. The second stage is a formal
application for approval when the facility is built. The first stage application provides
information on the location, plant layout and processing technology/parameters, as
well as intended feedstock and end use of compost/digestate. The Department’s
Veterinary Inspectors advise of any technical change in relation to processing
technology and parameters ensuring that plant design and processing procedures are
in accordance with the regulations, and to help identify and correct potential
problems prior to capital expenditure. The DAFF also encourage alternative
commercially viable uses of such ABP products in Ireland which are consistent with
the Regulations.
In June 2006, the Minister for Agriculture, Fisheries and Food introduced a Scheme of
Investment Aid for Demonstration On-Farm Waste Processing Facilities. This scheme
provided grant-aid for up to 10 projects throughout the State for the introduction or
development of on-farm waste processing facilities such as anaerobic/aerobic
digestion and fluidised bed combustion systems. The criteria for selection of projects
included the potential of the proposed project for the creation of a renewable energy
source.
37.10 Social and Distributional Consequences
In principle, the approach shifts additional costs on to the waste management sector
in favour of reducing risk for the agricultural sector. Within the waste management
sector, to the extent that costs are increased for the management of biowaste
through composting and digestion, the policy shift matters slightly in favour of
disposal and residual waste treatment.
Waste management companies say that it is not financially viable for them to collect
catering waste as a single waste stream. There is significant cost associated with this
to ensure that the waste is not contaminated with feedstocks that do not form part of
the permissible feedstocks list. The cause of this problem is regulatory uncertainty
that affects investment decisions, not solely economics. There are a few waste
management companies now collecting household biodegradable waste as a
separate waste stream.
37.11 Complementary Policies
Circular (WPPR 17/08) was issued on the implementation of Segregated ‘Brown Bin’
Collection for Biowaste and Home Composting. This Circular was issued in the wake
of a growing concern regarding Ireland’s ability to meet the targets for reducing the
quantity of biodegradable waste sent to landfill as set out in the EU Landfill Directive.
The Minister for the Environment, Heritage and Local Government is currently working
on a Statutory Instrument (SI) for Commercial Organic Waste to be Segregated. The
aim of the SI is to ensure that, where in the commercial sector a significant source of
organic waste arises, it will be segregated at source and presented for collection. This
sourced separated material is then suitable for downstream processing in approved
composting and anaerobic digestion facilities. This will give security of feedstock
supply to existing facilities and encourage new facilities to be built. The SI is not
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extended to householders, but is intended to catch all other non-household sources
of significant quantities of the organic fraction of biodegradable municipal waste. The
introduction of this statutory instrument would rapidly divert large volumes of
biodegradable waste from landfill and is easily achievable in the commercial sector.
This legislation will be available for comment via a consultative group.
In addition, the work of the Market Development Group, and the development of
standards will assist in making compost more acceptable to end-users.
37.12 Effect of the Policy on Pricing of Resources / Services
There has been no systematic evaluation of the effect on costs of the Regulations in
their final form. Cré commented on the Draft regulations and highlighted some of the
potential cost implications of the Regulations in Draft form. The approach does have
the effect of increasing costs in line with what one might call a precautionary
approach. It is not, here, the intention to internalise externalities, rather it is the
intention to prevent the incidence of new outbreaks of animal pathogens.
Biological treatment facilities can contribute significantly to diverting material from
landfill and achieving Ireland’s recycling targets. Ireland remains the most expensive
of the benchmark countries for biological waste treatment gate fees and, following
increases in gate fees from €80 per tonne in 2005 to €90 in 2006, is now
significantly above the benchmark of the other countries in terms of prices. 729 The
higher gate fee for biological treatment in Ireland can in part be attributed to the
relatively small scale and limited number of facilities in operation, leading to less
competition, as well as relatively restrictive legislation. Currently there are seven
approved ABP facilities in Ireland. The supply of these facilities is slow due to
regulatory uncertainty, and where demand exists, arguably, prices can be set high
owing to an absence of competition.
37.13 Evasion and Enforcement
Under the relevant ABP legislation the Department of Agriculture, Food and Fisheries
veterinary inspectorate is empowered to take suitable action to protect public and
animal health at approved plants where the operators of plants fail to comply with the
requirements of the legislation. Each composting plant must have its own laboratory
or make use of an external laboratory. The laboratory must be equipped to carry out
the necessary analyses and approved by the competent authority. Sampling must be
done in accordance with the approval as issued to a plant. In cases where noncompliance
occurs where samples result in a serious hygiene risk the following
applies:
596
• The Department of Agriculture and Food must be notified immediately
• The operator of the plant must establish the cause of the failure.
729 Forfás (2008) Waste Management Benchmarking Analysis and Policy Priorities, May 2008.
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597
• The contaminated batch and any in-contact material must be re-processed or
disposed of under the supervision of the Department of Agriculture and Food.
In the case of facilities where the only animal by-product being processed is
catering waste, contaminated batches may be sent directly for landfill or
recycled through the plant. For facilities using Category 3 animal by-products,
material may either be recycled through the plant or sent for processing in an
approved Category 3 processing plant.
• No material suspected of being contaminated must be removed from the plant
without the prior approval of the Department of Agriculture and Food.
• The frequency of sampling and testing will be increased in line with the
recommendations in place at the time
• Records relating to the contaminated material must be investigated
• Appropriate decontamination and cleaning procedures must be followed.
Failure to comply with the conditions of the notice may result in the closure of the
plant and possible prosecution.
37.14 Lessons Learned
The Regulations have been changed over time, shifting to what one might call a more
proportionate approach to final implementation.
The EPA is responsible for collecting data through the National Waste Report project.
The EPA, National Waste Report 2007 highlighted that less than 9% of organic wastes
were recovered in 2007. This is disappointing considering the looming landfill
diversion targets for biodegradable municipal waste and the fact that the organics
fraction is where attention must be focused. 730
It was noted in the National Waste Report 2006 that the separate collection and
diversion from landfill (by recycling or other means) of organic waste needs to be
accelerated. Stringent legislation including strict validation and hygiene requirements
has limited the number of private sector investments. Over time however this
legislation has become more workable and the ABP Regulations have occasioned a
stronger partnership approach. This has been successful, yet arguably, it should have
been adopted from the outset.
730 EPA, National Waste Report 2007.
International Review of Waste Policy: Annexes

38.0 Policies For Dealing With Junk Mail
38.1 Description
Junk mail can be defined as direct mail (both to potential and existing customers),
door to door materials, inserts included with magazines and newspapers, and free
newspapers. Some of these materials are not delivered to householders but picked
up by potential customers “on the go” (flyers and free newspapers).
The size of the junk mail waste streams has been estimated, in the UK for example,
at 3-5% of household arisings, 731 whilst according to the French environment ministry
the average French household receives 40kg of unsolicited printed materials each
year.
38.2 Possible Measures to be Taken
There are various measures that could be taken to reduce these waste streams,
which range from an opt-out, application of producer responsibility to an outright ban.
An opt-out – already available in the form of the mailing preference service – requires
action by individual householders, is relatively cumbersome and only covers some
categories of junk mail. A ban may be seen as restricting the right to advertise
products, and so also is only applicable to certain defined categories of materials. A
number of measures that have been considered are listed in Table 38-1, which is
taken from a 2007 waste prevention report. 732
Whilst not all of these might be directly construed as ‘policies’, such as campaigns for
tighter targeting of recipients, they can complement policies which set the economic
climate for prevention, or they might be initiatives which are pursued with additional
vigour as a consequence of some form of producer responsibility.
731 National Resource & Waste Forum (2004) Household Waste Prevention Toolkit, Part C. Marketing
Behaviour Change.
732 Eunomia, The Environment Council, Oko Institut, TNO and Atlantic Consulting (2007) Household
Waste Prevention: Policy Side Research Programme, Final Report for Defra, April 2007.
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Table 38-1: Junk Mail Policies
Name Name
Description Description
Typ Type Typ
Exists Exists Exists in
in
Activist
campaign
599
Pressure on mailers or on listproviders
to limit junk mail
Ban, specific Prohibition on delivering
unstamped or unfranked items to
letter boxes
Opt-out A service that allows consumers
to have their names and home
addresses removed from or
added to mailing lists used by
mailers
Postage
increase (on
bulk mail)
Levy (with
producer
responsibility)
Higher tariffs for bulk mailing, in
order to discourage junk mail
Waste levy on direct mail / free
newspapers. This would have
similar impact to postage
increases but would use a
different legislative mechanism.
Suppression Removal of records from a
mailing file or database that are
no longer accurate or current, or
records of people who have opted
out.
Notification of
MPS on mail
Legislative
reinforcement
of ‘No Junk
Mail’ stickers
All junk mail could be required to
have details of MPS and the
householders rights printed in the
material (similar to food labelling).
A requirement to encourage
recycling of material could also be
included.
Legal obligation on distributors of
junk mail to not put items in
boxes displaying ‘No Junk Mail’
stickers. This requires a firm
definition of junk mail and good
enforcement structures.
Licensing Distributors of junk mail are
licensed to ensure they abide by
industry codes. Businesses using
unlicensed distributors could be
liable for fines.
International Review of Waste Policy: Annexes
Executive or
ministerial decision
Legislation or
administrative rule
Voluntary
agreement or
mandatory
legislation
Numerous regions in
the UK and other
countries
USA
Voluntary opt-outs
available in the UK,
Germany, other EU
countries and the
USA.
Legislation No postage increases
to limit junk mail are
known.
Legislation
Voluntary
agreement or
legislation
Legislation
Voluntary agreement
in the UK
Legislation Australia (legislation
and schemes vary by
state)
Legislation
Brussels

38.3 Examples
38.3.1 French Unwanted Mail Decree
The French government took decisive action in 2006 in the form of an extended
producer responsibility scheme to attempt to reduce the volume of junk mail sent to
households each year. Distributors of junk mail have to pay for the recycling of the
resultant waste under a decree agreed by the council of ministers. This sector has
been informed that if it fails to comply with the decree, the government will introduce
a tax on junk mail.
The decree states that the participants can either pay into a fund that will be used to
pay for recycling by local authorities or they can pay for advertising to encourage
consumers to recycle. Payment levels were set in late 2006 after meetings between
the government and interested parties.
38.3.2 Voluntary Agreements
The UK has had a voluntary agreement between DEFRA and the Direct Mail
Association since 2003, aimed at increasing recycling rates. They increased from
13% in 2003 to 28% in 2005, although this should be seen in context of a general
increase in recycling levels. The amount of addressed direct mail has fallen by around
5% since 2003, according to DEFRA.
The mailing preference service (MPS) is a significant part of the industry’s response to
concerns and allows householders to register to opt out of receiving direct mail. One
way in which a policy could be designed to increase the effectiveness of the service
would be to mandate the promotion of it on direct mail items.
38.3.3 Enforcing the ‘No Junk Mail’ Sticker
In Australia, the opt out has been strengthened by legislative reinforcement: it is
legally binding to respect the no junk mail sticker on householders’ doors. The
Distribution Standards Board maintains a database of all known addresses that carry
a restrictive sign on the letterbox.
38.3.4 Postage Levy
An increase in the cost of postage, or a waste level on bulk mailings would increase
the cost of direct mailings, with the aim of increasing the targeting, and the decrease
in waste. There may be a question mark over the price elasticity of demand, and this
policy would only impact mailed items, rather than hand delivered. There do not
appear to be any examples of this policy having been implemented.
38.3.5 Extended Producer Responsibility
Extended producer responsibility would oblige the direct mail industry to cover the
cost of separate collection and recycling of junk mail. The revenue from such a policy
would be redistributed to local authorities to support the costs of junk mail. Making
the real cost of these marketing materials fall on those responsible would incentivise
600
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them to increase efforts at suppression (keeping mailing lists up to date), and
targeting.
The UK’s current DMA voluntary agreement is titled a producer responsibility scheme
and refers to the pledge by the Association to 733 :
601
“Work with local authorities to promote kerbside collections of paper to be
recycled, and to make sure the collections have the capacity to meet recycling
targets”
This pledge has translated into the Association promoting the mail preference service
with local authorities. However, no financial help is built into the agreement. This does
not correspond with the OECD’s definition of producer responsibility 734:
“OECD defines EPR as an environmental policy approach in which a
producer’s responsibility for a product is extended to the post-consumer stage
of a product’s life cycle. An EPR policy is characterised by: (1) the shifting of
responsibility (physically and/or economically; fully or partially) upstream
toward the producer and away from municipalities; and (2) the provision of
incentives to producers to take into account environmental considerations
when designing their products.”
The voluntary approach is weakened by virtue of the absence of any incentives for
producers other than those which already exist as a consequence of ongoing
activities.
38.4 Possible Impacts
A report written for Defra in the UK estimated the waste prevention impacts of the
measures and Table 38-2 shows the resulting changes in percentage of total direct
mail annual tonnage prevented: 735
733 Section on the Defra website entitled Producer Responsibility Voluntary Agreements,
http://www.defra.gov.uk/environment/waste/producer/voluntary/index.htm
734 Taken from the Organisation for Economic Co-operation and Development, Environment Directorate
website , http://www.oecd.org/document/19/0,3343,en_2649_34281_35158227_1_1_1_1,00.html
735 D. Hogg et al (2007) Household Waste Prevention Policy Side Research Programme, Report for
DEFRA, April 2007.
International Review of Waste Policy: Annexes

Table 38-2: Direct Mail Policies and Their Estimated Impact
Policy Description
Existing Suppression
Enhanced Opt-outs
Postage Levy
Producer Responsibility
Levy
Enforcement of no junk
mail stickers
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Existing Direct Mail
Agreement
Promotion of Mailing
Preference Service
Increase in costs of
direct mail-related
post (by 10% of price)
Targets for recycling
supported by cost
recovery from users of
direct mail
Legal support for
rejection of junk mail
Impact on Direct
Mail
(%)
Impact on Free
Newspapers etc.
(%)
2 n/a
6 - 9 n/a
4 - 8 n/a
1 - 9 Potentially similar
15 15
The percentages sometimes have a wide range as they take into account not only the
range of estimates of the size of the direct mail sector in terms of tonnage, but also
estimates of the elasticity of demand for it. It is worth noting that only two policies –
producer responsibility and enforceable no junk mail stickers - have an impact on
non-mailed items such as free newspapers.
Measures to limit the number of free flyers and newspapers could also have an
impact on the litter situation. Indeed, it was litter legislation that was enacted in
Australia to outlaw junk mail delivered to houses with a “no junk mail” sticker. Part of
any financial support to local authorities given as a part of a producer responsibility
scheme could be used to fund street cleansing operations to tackle the issue of
discarded flyers and newspapers.
The percentages of waste prevention were translated into tonnages and cost savings
as seen in Table 38-3. 736 Postage levy is excluded as it would be difficult to ensure
that only direct mail was affected by it.
736 Original amounts were in UK Sterling: these have been converted at a rate of 1.25 Euros to the
Pound.

Table 38-3: Cost Savings from Junk Mail Policies
Policy Impact (tones)
603
International Review of Waste Policy: Annexes
Avoided Collection
and Disposal
Cost Savings
Low High Low High Low High
Existing Suppression 7,860 13,100 €123 €150 €962,850 €1,965,000
Enhanced Opt-outs 36,500 36,500 €123 €150 €4,471,250 €5,475,000
Postage Levy 15,000 50,000 €123 €150 €1,837,500 €7,500,000
Producer Responsibility Levy 6,400 35,400 €123 €150 €784,000 €5,310,000
Enforcement of junk mail stickers 112,500 187,500 €123 €150 €13,781,250 €28,125,000
Total Total New New New Policies Policies (excl (excl postage postage levy) levy)
€19,036,500 €38,910,000
38.5 Conclusions
Junk mail is a significant though not massive part of the waste stream at 3-5% of
household waste arisings. The industry in Ireland was recently estimated by the
chairperson of the Irish Direct Mail Association to account for 3% of GDP. 737
The waste stream concerned is particularly amenable to being addressed through
producer responsibility, which would incentivise the industry to target customers more
accurately to reduce the costs of recycling/disposal, and would be expected to visit
the costs of managing the direct marketing (and free newspaper) stream through
seeking to ensure that the costs of managing the associated wastes were visited
upon producers. Indeed, in this way, households would be expected to be faced with
lower charges for their waste collection services (at the margin).
A policy to respect the preference of householders would result in a virtuous cycle of
behaviour: householders would be more inclined to express their preference if they
were confident that it would be respected, and direct mailers would gradually change
their volumes (or methods) to reflect the number of households opting out. To the
extent that this might reduce the nuisance experienced by householders and avoid
their resulting alienation, there may be a collateral (difficult to quantify) external
benefit.
The measures such as those outlined can also be used as a lever to encourage the
industry to do things that are not amenable to direct policy intervention, such as
enhanced mail targeting.
737 Taken from the IDMA website: http://www.directbrand.ie/idma/newsdetails.aspx

CONSTRUCTION AND DEMOLITION WASTE
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39.0 Review of Irish Policy, Construction &
Demolition Waste
39.1 Background:
The National Waste Database defines C&D Waste as ‘all waste that arises from
construction, renovation and demolition activities and all waste mentioned in Chapter
17 of the European Waste Catalogue (EMC). The C&D wastes listed in Chapter 17 of
the catalogue include 44 waste types, 16 of which have been classified as hazardous
wastes. The treatment, collection, transfer and disposal of hazardous material are
subject to additional regulatory controls under the Waste Management (Hazardous
Waste) Regulations 1998.
Construction and Demolition (C&D) waste is a very significant component of the
overall waste stream in Ireland, particularly with the high levels of building and
development in recent years.
C&D waste management in Ireland has historically been characterised by an overreliance
on landfill as a disposal route.
According to the 2007 National Waste Report published by the EPA, Construction and
Demolition waste generation increased by 5.8% since 2006 to an all-time high of
almost 18 million tonnes, including approximately 4 million tonnes of waste other
than soil and stones. The data on this huge and important waste stream is sparse
and reported recycling rates are down on previous years.
New momentum is required if the construction industry is to demonstrate its progress
towards the targets and objectives set out in national policy and in the industry’s own
voluntary initiative (discussed below) for the improved management of C&D waste.
The downturn in the Irish construction industry experienced from late 2007 onwards
has no doubt influenced the quantities of C&D waste generated in 2008 and 2009.
This downturn coupled with the recent financial crisis experienced worldwide will
most likely impose a downward pressure on the quantities of C&D waste generated in
the short to medium term. It is probable that a downward trend in C&D quantities will
appear in 2008 and 2009, and will be validated, subsequently, in the 2008 National
Waste Report to be published by the EPA. Effects of possible reduced government
spending on the delivery of the National Development Plan may further impinge on
the generation of C&D waste into the future.
It is reasonable to relate the current uncertainty and challenges in the Irish economy
to an uncertainty in quantities of C&D waste to be generated in the coming years.
Irrespective of the quantities of waste that will be generated in the future, continued
progress must be made in C&D waste prevention, minimisation, reuse and recycling.
39.1.1 Prevention of C&D Waste – General Overview
While recycling of C&D waste has the benefit of controlling the extent of waste
disposal and reducing overall transportation costs, prevention is the most desirable
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approach to waste management, since the elimination of waste removes the need for
subsequent handling, transportation and treatment of discarded material.
Furthermore waste prevention alleviates pressure on limited natural resources.
The management of C&D waste should reflect the waste management hierarchy, with
waste prevention and minimisation being the first priority succeeded by reuse and
recycling. Prevention is financially advantageous as it reduces the purchase of
construction materials and obviates the need to remove wastes from site. By
examining ways of eliminating or reducing waste, the construction industry can
achieve significant improvements in profitability at a time when pressure to hold
down costs has never been greater.
Conscious efforts by players in the construction industry can lead to improved waste
prevention in this area. For instance, certain purchasing procedures can greatly
contribute in the prevention of C&D waste. Examples include:
606
� Ensuring materials are ordered on an “as needed” basis to prevent over
supply to site;
� Purchasing coverings, panelling or other materials in shape, dimensions and
form that minimises the creation of excessive scrap waste on site;
� Ensuring correct storage and handling of construction materials to minimise
generation of damaged materials/waste;
� Ensuring correct sequencing of operations;
� Assigning individual responsibility to sub-contractors for the purchase of raw
materials and for the management of wastes arising from their activities,
thereby ensuring that available resources are not expended in an extravagant
manner at the expense of the main contractor;
� Renovation which retains and repairs existing structural and decorative
elements, with the introduction only where necessary of new items, also
contributes greatly to a reduction in C&D waste arisings.
� Material that is generated should be reused on site or salvaged for
subsequent reuse to the greatest extent possible and disposal should only be
considered as a last resort. Excavated spoil/topsoil should be carefully set
aside and used as landscaping material in completed developments.
With the exception of developments where planning conditions impose certain waste
management policies, the above basic principles of waste prevention are largely at
the discretion of construction and demolition contractors, and while some of the
measures outlined present economic benefits, it seems likely that the high demand
for developments in recent years, and associated aggressive construction/demolition
project programmes may have drawn the focus away from such waste prevention
measures.
The boom in the construction industry driven by a high demand for development over
recent years and the associated lucrative prices leveraged by contractors for
construction projects might also have overshadowed any policies in place.
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39.1.2 Recycling of C&D Waste – General Overview
The National Construction and Demolition Waste Council was set up as a voluntary
industry body. The objective of the Council was to implement the recommendations of
Task Force B4 'Recycling of Construction and Demolition Waste' in particular the
following key areas:
607
� Organise, monitor, report, research, promote and demonstrate best practice.
� Implement the recommendations and action plan from Task Force B4.
� Develop schemes to motivate and reward companies who commit themselves
to reducing waste going to landfill.
� Organise regional and national training programmes.
� Develop and encourage support for demonstration projects.
� Issue Annual and appropriate Interim reports on progress
� To achieve in a tiered approach the targets set out in "Changing Our Ways".
� To gather and issue relevant statistics.
� To set up an appropriate scheme to identify those companies or groups
engaged in successful best practice schemes.
� To advise Government on policy issues.
� To seek fiscal support at National & EU Level for Waste / Recycling infrastructural
projects.
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects were published by the Minister for the
Environment, Heritage and Local Government in 2006. The purpose of these
Guidelines is to promote an integrated approach to construction and demolition
(C&D) waste management, throughout the duration of a project for example:
� Excavated spoil/topsoil can be used as landscaping material;
� Waste timber can be recycled as shuttering or hoarding;
� Waste concrete as fill material for roads or in the manufacture of new concrete
when arising at source.
Some of the policies that influence C&D waste management are presented in
subsequent Annexes. All of the policies outlined have influenced C&D waste
prevention and recycling in some manner, albeit, in some cases, marginally.
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40.0 National Construction and Demolition Waste
Council - Ireland
40.1 Outline of Policy
The National Construction and Demolition Waste Council was set up as a voluntary
industry body. The role of the Council is to provide a framework to achieve compliance
with the targets as set out by the Minister for the Environment and Local Government
in the Policy Document 'Changing Our Ways (1998) 738 and such other policies as may
be set from time to time by the Government 739. The objective of the Council was to
implement the recommendations of Task Force B4 'Recycling of Construction and
Demolition Waste'. The Council also carries out research, prepares action plans and
gives advice and guidance in relation to all matters of Construction and Demolition
Waste and makes recommendations on the measures/steps that might be taken to
ensure compliance with statutory requirements.
40.2 Policy Context and Reason for Introduction
The Department of Environment and Local Government published “Changing our
Ways” in September 1998. The document addressed the substantial increase in
waste generation in Ireland and the over dependence on landfill as a waste
management vehicle. The document acknowledged the lack of progress in the more
desirable options including prevention and minimisation
minimisation.
minimisation
The document identified the construction sector as having the primary responsibility
to ensure the environmentally sound management of C&D waste. In May 2001, the
Forum for the Construction Industry through Task Force B4 released its final report
entitled Recycling of Construction and Demolition Waste 740 . This document contained
66 recommendations on C&D waste management. These recommendations
identified the need for the industry to develop environmental sustainability policies
addressing C&D waste prevention or reduction. One of these recommendations was
the formation of a national council for C&D waste management.
In December 2001, the Minister for the Environment, Heritage and Local Government
accepted the recommendations of Task Force B4 and authorised the establishment
of the National Construction and Demolition Waste Council.
738 DoEHLG (1998) Waste Management - Changing our Ways, September 1998.
739 Previous examples include: DoEHLG (2002) Preventing and Recycling Waste – Delivering Change;
DoEHLG (2004) Waste Management – Taking Stock and Moving Forward.
740 Construction Industry – Task Force (2001) Recycling of Construction & Demolition Waste, B4
Report.
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40.3 When was the Policy Introduced?
The National Construction and Demolition Waste Council (NCDWC) was established
on June 20th 2002.
40.4 Key Organisations Involved in Implementation and
Management
The National Construction and Demolition Waste Council has been established by the
Forum for the Construction Industry on the recommendation of the Task Force B4
(Recycling of Construction and Demolition Waste) as approved by the Minister for
Environment and Local Government in his letter dated the 11th December 2001.
In September 2004, a Voluntary Industry Initiative was launched which called on each
participant in the construction industry to commit to a series of actions, to promote
waste prevention, reduction, reuse and recycling. The initiative received 100%
endorsement from all key stakeholders involved in the Council and its voluntary
approach was seen as a positive step towards achieving the targets outlined in
“Changing Our Ways”.
The National Construction and Demolition Waste Council liaises with Government and
regulatory bodies on policy issues.
The Council originally established five Sub Committees to assist with major bodies of
work:
609
� Sub Committee A - Infrastructure & Facilities;
� Sub Committee B - Markets for Recycled Materials & Specifications;
� Sub Committee C - Project Best Practice & Waste Management;
� Sub Committee D - Review of the Regulatory Framework;
� Sub Committee E - Information, Public Awareness & Funding
The Council has since rearranged the Sub Committees as follows:
� Sub Committee A – Infrastructure, Facilities and Marketing;
� Sub Committee B - Regulatory Framework and Project Best Practice;
� Sub Committee E - Information, Public Awareness & Funding
In the National Waste Prevention Programme (NWPP) ‘Outline Work Plan 2004 to
2008 741, the construction and demolition sector being a significant generator of
waste was highlighted. It was further stated that the NWPP would collaborate with the
National Construction and Demolition Waste Council in developing improved
recording and reporting mechanisms for construction and demolition waste
management, as good data is a prerequisite for a waste prevention programme. It
741 EPA (2004) National Waste Prevention Programme (NWPP) Outline Work Plan 2004 to 2008, April
2004, Wexford: EPA.
International Review of Waste Policy: Annexes

was further proposed that in addition to the EPA’s participation on the NCDWC,
additional input will be provided under the NWPP.
40.5 Monitoring and Measurement Techniques Applied
Data pertaining to performance monitoring in terms of waste prevention and recycling
is sparse. No conclusive data was found relating the efforts of the National
Construction and Demolition Waste Council to metrics on C&D waste prevention and
recycling.
However, the National Waste Reports published by the EPA contain data and findings
on C&D waste management. Estimated annual quantities of C&D waste generated in
Ireland are provided in such publications. Commentary is also provided on the affect
of principle waste management policies on C&D waste arisings. There has been an
upward trend in the generation of C&D waste in Ireland up to 2007 (latest National
Waste Report published by the EPA 742). This does not necessarily indicate that waste
prevention measures have not been successful; rather it is reasonable to suggest that
C&D waste prevention has not equalled C&D waste growth over the period of
economic boom in Ireland.
40.5.1 Evaluation Studies Available
The National Construction and Demolition Waste Council have published annual
reports as follows:
610
� NCDWC Annual Report 2002/2003; 743
� NCDWC Annual Report 2003/2004; 744 and
� NCDWC Annual Report 2004/2005. 745
An annual report has not been published for 2006/2007, due to discontinuity in
resources available to the Council.
These annual reports are available to the public (can be downloaded from the
National Construction and Demolition Waste Council’s website).
Furthermore, the Waste Reports published by the EPA provide data on C&D waste
arisings and comments on the effect of waste policies.
The 2006 Waste Report includes the following statement -“The capacity of the
National Construction and Demolition Waste Council to make rapid progress towards
these objectives should be reviewed”. The objectives referred to being the targets set
742 EPA (2009) National Waste Report 2007, Wexford: EPA.
743 NCDWC (2003) Annual Report 2002/2003, Dublin: National Construction and Demolition Waste
Council.
744 NCDWC (2004) NCDWC Annual Report 2003/2004, Dublin: National Construction and Demolition
Waste Council.
745 NCDWC (2005) NCDWC Annual Report 2004/2005, Dublin: National Construction and Demolition
Waste Council.
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out in national policy and in the industry’s own voluntary initiative for the improved
management of C&D waste.
The following paragraph has also been taken from the 2006 Waste Report published
by the EPA:
611
“The National Construction and Demolition Waste Council launched a
voluntary construction industry initiative to prevent, minimise and recycle
construction and demolition waste 2004. The initiative set out a number of
objectives to be achieved by a range of stakeholders. While making good
progress in certain areas, it is clear that the Council suffers from a lack of
dedicated resources and has been supported to date by a part-time
secretariat at the Construction Industry Federation. Based on the findings
presented in chapter 7, and given the lack of reliable data on the generation
and management of construction and demolition waste, it is recommended
that the voluntary mandate of the National Construction and Demolition Waste
Council be independently and impartially reviewed, with a view to ensuring
that the Council represents the best possible model for achieving best
practise in resource efficiency and waste management in the large and
economically important construction sector. The onus should be placed on the
Council to demonstrate that the industry has achieved “substantial progress
(on recycling) through voluntary effort” and to make the case for continued
financial support by Government and public bodies”
It is clear from the above extract that the structure and resourcing of the National
Construction and Demolition Waste Council needs streamlining to facilitate necessary
continued progress in C&D waste management and in particular the more desirable
approach of waste prevention.
40.6 Environmental Benefits
The establishment of the National Construction and Demolition Waste Council has
promoted construction and demolition waste prevention, minimisation, reuse and
recycling. The Best Practice Guidelines on the Preparation of Waste Management
Plans for Construction and Demolition Projects, which were drawn up following
recommendations made by two sub-committees of the National Construction and
Demolition Waste Council. The NCDWC had a very high level of support from all
organisations and professional bodies involved in the construction industry and all
took a proactive role in contributing to the consultative process which led to the
delivery of the C&D Waste Management Plan guidelines. The NCDWC called upon all
involved in the construction industry to support and implement the guidelines on
projects.
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects were published by the Minister for the
Environment, Heritage and Local Government in 2006 and formally endorsed by the
National Construction and Demolition Waste Council. These guidelines are designed
to influence the management of C&D waste on construction sites.
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40.6.1 Environmental Benefits – Prevention
The scale of the environmental benefits provided as a result of the work of the
National Construction and Demolition Waste Council is difficult to judge due to the
lack of sound available information on C&D waste management in Ireland.
In terms of C&D waste prevention and minimisation; one of the objectives of the
NCDWC was the preparation of a manual titled ‘C&D Waste Minimisation Guide’. A
Public tender to procure a company to undertake this work was conducted in early
2006. It has since been reported that a ‘C&D Waste Minimisation Guide’ has been
completed, however the manual has not received the approval of all the Council’s
Sub-Committees. As a result the ‘C&D Waste Minimisation Guide’ has not been
published by the Council. Had this guide/manual been published, it is likely that it
would have impacted positively on C&D waste prevention and thus the environment.
This guide/manual will now need to be revised to take account of the new Waste
Permit Regulations.
It is hoped that the issue of more accurate site management reducing the necessity
for returned concrete surpluses can be addressed through the publication of the ‘C&D
Waste Minimisation Guide’ 746.
40.6.2 Environmental Benefits Associated with Recycling
Again, the scale of the environmental benefits provided as a result of the work of the
National Construction and Demolition Waste Council is difficult to judge due to the
lack of sound available information on C&D waste management in Ireland.
The National Construction and Demolition Waste Council has promoted and
accelerated the recycling and recovery of C&D waste thus reducing the industry’s
previous dependence on landfill as a waste management tool. In particular, Subcommittee
B within the NCDWC was formed to examine the issues associated with
Markets and Specifications for C&D waste.
In June 2004, new specifications were introduced by the NRA, which allow the use of
recycled materials for sub-base applications. Sub-Committee B worked with the NRA
in the promotion of the revised specifications. This was a major development as it
provided an incentive for recycling concrete. Designers can now specify to the
EN13242 standard thereby assuring clients that recycled materials are subject to a
similar production control system as virgin aggregates.
In 2004, the Council produced a non-technical report of the revised specifications for
distribution to relevant organisations. This correspondence included a request that
consideration be given to the use of recycled aggregate.
The Homebond House Building Manual was identified by Sub-Committee B as a
further source for highlighting the potential for reusing recycled concrete in non
structural applications. The National Construction and Demolition Waste Council is
746 Irish Concrete Federation, Annual Report 2007.
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currently working in this area and intend to execute some case studies pertaining to
the use of recycled concrete in house building projects.
The Irish Concrete Federation remains an active member of the National Construction
and Demolition Waste Council and Sub Committee A which is researching the barriers
to and incentives required for improving recycling/recovery of inert C&D waste
streams. 747
40.7 Implementation Costs
The costs associated with the establishment, operation and management of the
National Construction and Demolition Waste Council are borne directly by the
Construction Industry Federation and other Council members. The Department of the
Environment, Heritage and Local Government has also provided financial support.
However, the Council has experienced funding problems since its establishment. It
has been reported that a number of members have defaulted on funding
commitments. Lack of funding has been reported as a significant factor which has
adversely affected the continued success of the Council in recent years.
40.8 Response from Public and Industry
The NCDWC has received support from all organisations and professional bodies
involved in the construction industry and all have appeared to take a proactive role in
contributing to the development of guidelines such as those related to C&D Waste
Management Plans.
However, it has been reported that the response from industry has deteriorated in
recent times. The lack of funding coupled with the downturn in the construction
industry may have contributed to this deterioration.
40.9 Effects on Technical Change / Innovation
The NCDWC is a voluntary industry body, funded and driven by the Construction
Industry and other council members. It is thereby ideally placed to align its core
objectives (improved C&D waste prevention, minimisation, reuse and recycling) with
the latest technical changes and innovation in the construction industry. Indeed it is
probable that the focus of the National Construction and Demolition Waste Council on
waste prevention, minimisation, reuse and recycling has encouraged the use of new
technologies and innovation in construction and demolition activities, aimed at
improving waste management in the industry.
40.10 Social and Distributional Consequences
The National Construction and Demolition Waste Council represents the efforts of the
entire construction industry. Information and publications are available to all actors in
the industry, as is membership and attendance at workshop events to promote C&D
747 Irish Concrete Federation, Annual Report 2007.
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waste prevention, minimisation, reuse and recycling. It is therefore considered that
there are no distributional consequences associated with this C&D waste policy.
40.11 Complementary Policies
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects were published by the Minister for the
Environment, Heritage and Local Government in 2006 and formally endorsed by the
National Construction and Demolition Waste Council.
40.12 Effect of the Policy on Pricing of Resources / Services
The effect of the establishment of the National Construction and Demolition Waste
Council on the cost of construction and demolition to the public and industry is
difficult to measure due to the other variables (e.g. supply and demand) that
influence construction and demolition costs. The NCDWC has contributed to improved
management of C&D waste through the preparation of guidelines, workshops and
continuous consultation with the industry. It is likely that any cost savings associated
with improved C&D waste management have percolated through to customers in a
now significantly more competitive sector.
40.13 Evasion and Enforcement
The establishment of the National Construction and Demolition Waste Council is a
voluntary initiative by the construction industry and as such evasion and enforcement
are not relevant.
40.14 Lessons Learned
It is likely that the National Construction and Demolition Waste Council would have
had more success in delivering its objectives, as set out in the industry voluntary
initiative, had it not experienced problems relating to lack of funding and dedicated
human resources.
Improved data collection in terms of waste arisings and in the success of measures
implemented on construction sites to prevent, minimise, reuse and recycle C&D is
required going forward in order to evaluate the performance of the NCDWC.
Further mechanisms need to be built into the Council so that differences of opinion of
the Sub-Committees can be resolved in a timely manner in the interests of the
delivery of C&D waste prevention, minimisation, reuse and recycling targets. As
mentioned earlier, differences of opinion have affected the delivery of a ‘C&D Waste
Minimisation Guide’, work that is completed but not published.
The NCDWC is part funded and driven by the construction industry; the downturn in
the construction industry may have a negative effect on the activity of the council in
the continued pursuit of its goals (prevention, minimisation, reuse and recycling of
C&D waste) due to a decrease in funding, energy and enthusiasm.
In the future, greater strides could be made in the validation of measures, by way of
pilot projects, to prevent C&D waste generation by improved focus on the common
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goals that are shared by the National Construction and Demolition Waste Council and
The National Waste Prevention Programme run by the EPA.
Finally, the funding problems and the lack of strong support could perhaps be
overcome if the NCDWC’s work was in support of objectives which were made binding
upon the industry. The absence of any binding requirements has possibly led to
industry taking the view that firm action is not actually necessary.
In summary, in light of the recent turbulence in the construction industry and the
financial difficulties faced by the National Construction and Demolition Waste Council,
significant restructuring is required to invigorate this voluntary body to further improve
C&D waste management in Ireland. Members of the Council have reported that their
founding objectives have been achieved. However there is significant research
needed on the barriers and incentives required for improving recycling /recovery of
C&D waste streams, and momentum has essentially stalled.
615
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41.0 Landfill Levy - Ireland
41.1 Outline of Policy
The Government introduced a levy of €15 per tonne on the landfill of waste on 1 June
2002 under the Waste Management (Landfill Levy) Regulations 2002. On the 1 July
2008, the landfill levy rate was increased to €20 per tonne of waste disposed of at
authorised landfill facilities.
In relation to Construction and Demolition waste there are a number of disposal
activities that are exempt from the landfill levy charge, (although a gate fee will still be
in effect, albeit a reduced gate fee in most cases), provided the material is not
destined for disposal and is used for landfill site engineering, restoration or
remediation purposes. These are:
616
� Non-hazardous waste from C&D activity comprising concrete, bricks, tiles, road
planning’s etc. with a particle size of 150mm or less;
� Excavation spoil comprising clay, sand, gravel or stone;
� Dredge spoil from inland waterways and harbours.
41.2 Policy Context and Reason for Introduction
The landfill levy was introduced to encourage the diversion of waste away from landfill
and generate revenues that can be applied in support of waste
prevention/minimisation and recycling initiatives. The Irish Waste System operates a
“waste hierarchy” whereby waste is preferably not produced in the first place
(prevention), re-use or recycling is the next favourable option, then if this is not an
option waste is incinerated (with energy recovery) and finally landfill is the least
favoured option and currently the only option taxed.
The landfill levy emerged, and has evolved in the following way:
� 1998 1998 - Changing Our Ways, published in 1998, sets out the Government policy
on waste management. It focuses on the need for a very significant reduction
in our reliance on landfill, in favour of integrated waste management services
and infrastructure that will deliver ambitious waste recycling and recovery
targets. Changing Our Ways also emphasises the need for producers of waste
to bear the full costs of waste collection, treatment and disposal, in
accordance with the Polluter Pays Principle. The target set in the Changing Our
Ways policy document for C & D waste was 50% recycled by 2003 and 85% by
2013. In response to this the Government decided to introduce a landfill levy
in 2002, to encourage the diversion of waste away from landfill.
� 2002 2002 2002 – A levy of €15 per tonne on the landfill of waste was introduced on 1
June 2002 under the Waste Management (Landfill Levy) Regulations 2002.
The levy was designed to encourage the diversion of C&D waste away from
disposal at landfill and generate revenues that can be applied in support of
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617
waste minimisation and recycling initiatives. All levies are remitted to the
Environment Fund.
� 2006 2006 - As a penalty for those who illegally deposit waste, the Waste
Management (Landfill Levy) (Amendment) Regulations 2006 introduced a levy
of €20 per tonne for each tonne of waste disposed of at unauthorised facilities
on and from 28 July 2006. This means that persons responsible for the illegal
deposition must pay the levy and remove the waste, as required by Section 60
Policy Direction, and remediate the land, apart from any other penalties that
may be imposed through the courts.
� 2008 2008 2008 - As of 1 July 2008, the Minister for the Environment, Heritage and Local
Government increased the landfill levy, using the power available to him under
the Waste Management Acts. The Waste Management (Landfill Levy) Order
2008 amends section 73(3) of the Waste Management Acts 1996 to 2008 to
allow for the landfill levy to be increased from €15 per tonne to €20 per tonne
for each tonne of waste disposed of at an authorised landfill facility.
� 2008 2008 2008 (August) (August) (August) – Regulatory Impact Assessment (RIA) was undertaken on the
introduction of a Waste Facility Levy (WFL). This would include a significant
immediate increase to the landfill levy, with the upper limits of the levy also to
be significantly increased. Furthermore, the landfill levy is to be broadened to
a waste facility levy – encompassing incineration. The ‘broadened’ levy is to be
known as a “waste facility” levy. The RIA for a Waste Facility Levy (WFL) was
forwarded to interested parties on the 29th of August for comment; the results
of the RIA are not currently available to the public.
41.3 When was the Policy Introduced?
The policy was introduced in 2002.
41.4 Key Organisations Involved in Implementation and
Management
� The Department of Environment, Heritage and Local Government;
The Department introduces draft and final regulations pertaining to the
continued operation of the landfill levy provided for in the Waste Management
Acts. The Department controls and manages the Environmental levy generated
by the landfill levy and plastic bag levy;
� Relevant Local Authorities;
The relevant local authority is simply the local authority in whose functional
area the disposal activity concerned is carried out. The relevant local authority
is responsible for enforcing and implementing the landfill levy regulations in
their functional regions, including collection of the landfill levy arising from
disposal activities;
� Local Government Auditor;
The Local Government Auditor is appointed by the Minister of the Environment
Heritage and Local Government to carry out, or to assist in the carrying out of,
audits of the accounts of local authorities or other bodies;
International Review of Waste Policy: Annexes

618
� Operators of Disposal Activities;
Operators of disposal activities are the accountable people who pay the levy.
Disposal activities include landfill facilities. A landfill facility means a waste
disposal site on which the disposal of waste has taken, or is taking, place.
41.5 Monitoring and Measurement Techniques Applied
A landfill operator is required to maintain a written record in respect of each vehicle
load of waste accepted into a landfill facility for the purpose of disposal, and such
records must include:
� the date;
� the name of the carrier;
� the vehicle registration number;
� a description of the waste, (with reference, where practicable, to the relevant
code set out in the European Waste Catalogue);
� the quantity of the waste in tonnes;
� other information with respect to the calculation of the quantity of waste
concerned, in the absence of a weighbridge; and
� a written daily record of the quantity of waste (if any) disposed of which is
considered to be exempt from the levy.
Local Authorities implement the landfill levy, to the extent that they operate landfills,
and are required to remit their levy liability directly to the Department of Environment,
Heritage and Local Government (DoEHLG).
Operators of private landfill facilities are required to remit their levy liability to the
relevant local authority in whose functional area the facility is located, the authority
will then transfer the revenue to the DoEHLG.
The DoEHLG publishes an Environment Funds Account Report. This report details the
income from the environmental levy on the landfill of waste and also from the
environmental levy on plastic bags.
The income from the Landfill levy is a direct measure of all waste being disposed of in
landfill. This allows the DoEHLG to examine if this levy actually disincentives waste
contractors (public and private) from disposing of waste in landfills. However, the
income from the Landfill levy is not a measure of C&D waste used for engineered
purposes at landfill facilities.
41.6 Evaluation Studies Available
The effect on prevention of C&D waste has not been possible to measure. Indeed, the
quality of the available data would make such an estimation extremely difficult, and
no survey based work has been undertaken to understand how the levy may have
changed behaviour.
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41.7 Environmental Benefits
The revenues generated from the Landfill Levy are paid into an Environment Fund
which was established by the Waste Management (Amendment) Act 2001 (No.36 of
2001) and is managed and controlled by the Minister for the Environment, Heritage
and Local Government. The fund was established with effect from 17 July 2001. It is
not clear to what extent these funds are derived from landfilling mixed construction
and demolition waste.
Table 41-1: Landfill Levy Income
Income Income
2002 2002 2003 2003 2004 2004 2005 2005 2006
2006
Environmental Levy
on the Landfill of
Waste
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International Review of Waste Policy: Annexes
€17,868,726 €29,359,585 €26,765,514 €27,798,605 €30,750,433
Source: Department of Environment, Heritage & Local Government, 2006
41.7.1 Environmental Benefits – Prevention
It is apparent from Table 41-1 above that the revenue earned from the landfill levy
increased between 2005 and 2006. In 2006, of the €30,750,433 generated in
income from the levy on the landfill of waste, €1,725, 866 was spent on “Waste
Prevention and National Market Development Group”, €408,304 was spent on
“Producer Responsibility Initiatives” and €3,649,342 was spent on “Environmental
Awareness” all of these aid waste prevention strategies.
The Landfill levy may have been an effective instrument for influencing C&D waste
management practices. However due to the exemption of the majority (70-80% on a
weight basis) of C&D waste (soils, concrete, brick, stones, etc.) from the Landfill levy,
this policy has probably been rather ineffective in preventing the overall generation of
C&D waste. In principle, the policy may have been effective in preventing and
reducing certain elements of C&D waste (including plastics, cardboard and metals)
going to landfill. However, the emphasis is likely to have been on improved
segregation.
41.7.2 Environmental Benefits Associated with Recycling
The landfill levy exemption which covers the majority (by weight) of C&D waste (soils,
concrete, brick, stones, etc.) has almost certainly encouraged the processing of C&D
waste in Ireland in order to separate the exempt fractions from those which are not
exempt. A by-product of this processing activity has probably been the separation of
metals and plastics which have been sent to re-processors for recycling, although
many operators will have been separating metals well in advance of the levy reflecting
the value of these materials.
The 2007 EPA Waste Report does not provide any figures to quantify the recycling of
these materials. This is possibly due to the shortfall in the submission of annual
reports by permitted facilities, a fact highlight in recent EPA Waste Reports. Indeed,
the EPA Waste Report figures are somewhat misleading if read at face value in that

they probably understate the quantities of C&D waste still dealt with via disposal
routes.
Engineering applications at landfill sites have provided an available market for the
recovery of the soil and stone fractions produced by C&D waste recovery plants
developed by local authorities and private operators. During 2007, the EPA reports
that 12,774,774 tonnes (71.8% of C&D waste collected) of construction and
demolition waste was recovered and 974,934 tonnes (5.4% of C&D waste collected)
was disposed at authorised landfills and at waste permitted facilities. The remaining
23% represents the gap between collection and management of waste (of the order 4
million tonnes). In the words of the EPA: 748
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There continues to be a large discrepancy between the reported collection of
construction and demolition waste and its reported disposal and recovery. In
2007, there was a gap of 4,042,037 tonnes. Local authorities have stated
that of 3,686 collection permit holders active in their areas, only 2,414
provided an annual environmental report for 2007, a 65% reporting rate.
Local authorities estimate that non-reporting collection permit holders
collected up to 633,000 tonnes of construction and demolition waste. Of
active permitted (recovery) sites, only 770 reported from a total 1,688 active
sites, a reporting rate of 45%. Local authorities estimate that non-reporting
facility permit holders handled over 1,300,000 tonnes. This still leaves a gap
of over 2,000,000 tonnes of waste and this in all likelihood represents a
general lack of attention by the construction and demolition industries, and
elements of the waste industry serving it, of the need to keep good records
and provide reports to local authorities.
Of the 12,774,774 tonnes recovered, 2,864,045 tonnes (16% of C&D waste
collected) was recovered at EPA licensed landfills. This tonnage would have been
exempt from the landfill levy.
The EPA does report on different recovery rates for C&D waste with data including,
and excluding, soil and stones. Although the basis for the calculation is not entirely
reliable (as discussed above), the differences in the recovery rates – 80.5% and 44%,
respectively – highlights the relative ease, and cost, with which different materials
can be recovered from the C&D stream.
41.8 Implementation Costs
The landfill levy in Ireland is charged per tonne of waste arriving at landfill sites.
Waste is weighed upon arrival at landfill sites. Liability for the levy falls on the
operator of the landfill facility and the disposal of waste at a landfill triggers the
requirement to pay. This cost however is ultimately borne on the waste producer
through increases in waste collection costs.
For the purpose of defraying expenses incurred in the enforcement and collection of
the levy within its functional area, a relevant local authority may deduct and retain up
748 EPA (2009) National Waste Report 2007, Wexford: EPA.

to 2 per cent of the landfill levy, but any such deductions can not exceed a total of
€50,000, or any amount specified in writing by the Minister, per year.
The Environment Fund Accounts 2007 indicate an expenditure of €388,025 for
“Environmental Levy Collection Costs”. This equates to approximately 1% of the total
income from the levy on the landfill of waste.
41.9 Response from Public and Industry
There is a general acceptance of the landfill levy from the public and industry, as its
aim was to encourage the diversion of waste away from landfill and generate
revenues that can be applied in support of waste minimisation and recycling
initiatives.
41.10 Effects on Technical Change / Innovation
The landfill levy was increased in July 2008 to further discourage the use of landfill as
a treatment option. The aim of the increase is to reduce the quantity of waste being
disposed of in landfill and to increase recovery and recycling rates. This increase in
the levy of €5 per tonne may not be effective in reducing the rate of waste being
treated at landfill as at the same time the landfill gate fee has decreased by an
average of €27.50 per tonne, when comparing 2007 figures with 2005.
Increased landfill levies have encouraged a change in work methods or the
sequencing of work elements on site such that C&D waste produced is segregated
such that soil, stone and concrete fractions can be disposed of to landfills (exempt
from the landfill tax) for engineering purposes.
41.11 Social and Distributional Consequences
This policy, by way of the exemption afforded to the heavier fraction of C&D waste, is
more sympathetic to C&D waste generation as opposed to other waste streams such
as municipal waste. This partly reflects the view that as long as landfills are required,
then if C&D wastes are not arriving at sites, alternative materials would be required
for site engineering, hardstanding, and other similar uses.
It has been the case that large C&D waste producers/processors and those located in
close proximity to landfill facilities, or indeed those who operate landfills, have been in
a position to develop markets for the exempt fraction of C&D waste, which has in turn
provided them with a competitive advantage from a financial perspective. Other
smaller C&D waste producers/processors may not have been able to develop such
markets. Consequently, the landfill levy exemption afforded to certain elements of
C&D waste may have favoured larger companies over smaller companies.
41.12 Complementary Policies
The C&D Waste Management Plan policy is complemented by the landfill levy policy.
Avoidance of the landfill levy, through waste prevention, minimisation, reuse and
recycling is facilitated by the preparation of a C&D Waste Management Plan, at
project design stage, in accordance with the guidelines published.
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41.13 Effect of the Policy on Pricing of Resources / Services
In principle, a landfill levy presents opportunities to internalise externalities. We are
not aware of any assessment undertaken in recent years to assess these on the part
of Government (though see Annex 63.0). In principle, the structure of the tax – in
particular, the exemptions which apply – are likely to reflect the relative externalities,
but in the case of other materials, the levy may be too low. Even so, it is the nature of
this type of levy, and reflecting what is feasible in terms of implementation, that
simple levy structures are likely to be applied.
It is reasonable to suggest that the landfill levy has encouraged actors in the
construction industry to segregate the heavy soil and stone fractions of C&D waste,
either through source segregation on sites of origin or post processing at material
recovery facilities. In many cases, the soil fraction has been used for engineered
purposes in landfills, while the stone fraction (following further crushing and
screening) has been recycled and used in road construction. In summary, the above
activities have probably encouraged improved management of this waste stream thus
contributing to reduced construction costs for roads, buildings and other
infrastructural services. The data available, however, makes it difficult to demonstrate
this conclusively.
With regard to the generation of C&D waste by householders through the execution of
DIY projects, there is a temptation to discard C&D waste in the residual bin. Residual
bin ‘pay by volume’ mechanisms (and the absence of any form of PBU) and the high
cost of hiring skips (which will be influenced by the level of the levy), may have
encouraged C&D disposal by this means. As a result the landfill levy has been
powerless to influence the management of a certain portion of C&D waste generated
by householders in such a way that it is readily recycled. This is not ‘evasion’ per se,
but it highlights one way in which C&D waste may ‘shift’ into different management
routes as a consequence of the prices facing households.
41.14 Evasion and Enforcement
It is the function of each Relevant Local Authority to enforce and audit compliance
with the landfill levy regulations within its functional area. The levy is payable by
weight which is recorded using weighbridges at the landfill facility. A relevant local
authority may at any time require a landfill operator (referred to as an “accountable
person” in the regulations) to calibrate a weighbridge in an authorised landfill facility.
A landfill operator, when other than a local authority, must provide the relevant local
authority with a full and true return of the amount of levy due not later than four
weeks following the end of an accounting period. Payment of the levy must also be
executed within this time frame.
A landfill operator, that is a local authority, must provide the Minister with a full and
true return of the amount of levy due not later than four weeks following the end of an
accounting period. Payment of the levy to the Environmental Fund must also be
executed within this time frame.
A return shall include, as a minimum, the following information in respect of each
landfill facility concerned:
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623
� the name of the accountable person;
� the location of the landfill facility;
� the accounting period to which the return relates;
� the weight of waste disposed of during the relevant accounting period;
� the weight of such waste disposed of that is subject to the levy;
� the weight (if any) of such waste disposed of that is considered to be exempt
from the levy;
� the amount of levy payable in respect of the accounting period;
� the method by which the amount of levy payable was determined;
� in the case of a landfill facility equipped with a weighbridge, any period in the
relevant accounting period during which the weighbridge was not operational,
and the weight of waste disposed of during such period that is subject to the
levy;
� a declaration that the information specified in the return is correct;
For the purpose of ensuring compliance with these Regulations, a landfill facility is
subject to inspection and audit by, as the case may be, a relevant local authority, a
Local Government Auditor or any other auditor appointed by the Minister or a local
authority for that purpose.
A relevant local authority, or any auditor appointed by the Minister or a local authority
may:
� enter any landfill facility;
� require the production of, inspect and take copies of any records and
documents required to be maintained under a relevant waste licence;
� remove for the purpose of inspection or examination or any proceedings any
records and documents;
� A landfill operator must comply with any requirements and furnish all
reasonable assistance to an auditor.
A waste disposal activity operated by a private company or a body that is not a local
authority is audited by the relevant local authority, or an auditor appointed by that
local authority, in respect of at least two accounting periods per year, or at a greater
frequency as may be requested by the Minister.
A local authority must furnish to the Minister a report on each inspection and audit
carried out and must comply with any direction of the Minister arising from such
audits.
41.15 Lessons Learned
The landfill levy has probably influenced waste management practices for
construction and demolition wastes (C&D) more than household waste.
The levy changes behaviour of producers, as they are responsible for paying for
treatment or disposal (to landfill) of materials which they produce. In this respect it is
International Review of Waste Policy: Annexes

easonable to assume that the landfill levy would encourage C&D waste prevention
and minimisation. However, significant quantities of the heavier fraction of C&D
waste (70 - 80% of overall), exempt from the landfill levy, are used for engineered
purposes at landfills. In addition, in many cases this exempted material is charged
into landfills at significantly reduced gate fees. According to practitioners in the waste
management industry, the majority of the lighter fraction of C&D waste (plastics,
cardboard, etc.) extracted in waste recovery facilities continues to be disposed of in
landfill. 749
The current availability of landfill capacity is driving gate fees down and an increase in
the landfill levy may be appropriate to ensure that relatively low gate fees do not
undermine the ongoing progress in waste prevention and minimisation. It is proposed
that the landfill levy be examined with a view to making landfill more expensive. This
would be expected to make economically marginal waste prevention measures (in
relation to the lighter fraction of C&D waste) more attractive to waste producers. It is
clear that waste management practices for the heavier fraction of C&D waste are
immune to an increase in the landfill levy due to the exemption afforded to the stone
and soil fractions.
The use of C&D waste fines, exempt from the landfill levy, for engineered purposes
(as landfill cover) has intensified odour problems at certain landfill facilities. The high
content of sulphur, originating from plasterboard, in the C&D fines can contribute to
the generation of hydrogen sulphide. Many facilities have curtailed the use of C&D
waste fines as landfill cover for this reason. It is worth noting that many countries
have banned, or are in the process of banning, gypsum from landfills.
Key Success Factors of the Landfill levy include:
624
� Simple measure and easy to enforce; and
� Political backing for implementation.
Future Changes/ Modifications to the landfill levy are likely to include:
� Increase in landfill levy rates;
29/09/09
• It is proposed that the landfill levy be examined with a view to making
landfill more expensive. This would be expected to make economically
marginal waste prevention and minimisation activities, particularly in
relation to the lighter fraction of C&D waste, more attractive to C&D
contractors.
• As mentioned earlier, certain C&D waste is exempt from the landfill levy
charge, (although a gate fee will still be in effect), while these materials
are used positively for engineered purposes on landfill sites this
arrangement may have negatively influenced C&D waste prevention
749 It should be noted that this is not entirely in line with the reporting by the EPA, though neither is it
completely inconsistent with it if one takes into account the difficulties the EPA faces in reconciling
figures on the collection and management of waste (see EPA (2009) National Waste Report 2007,
Wexford: EPA and also above).

625
initiatives. In other words, the landfill levy may have had an even
greater positive influence on C&D waste prevention had the above
exemption not been in place. However, such a hypothetical scenario
would possibly have an overall negative affect due to reduced levels of
C&D waste recovery. What might be appropriate is a lower levy rate for
such materials, though the existing situation in terms of reporting
suggests one should be cautious in making such a recommendation. In
the first instance, there appears to be a need to understand better the
current situation.
International Review of Waste Policy: Annexes

42.0 C & D Waste Management Plan Guidelines
- Ireland
42.1 Outline of Policy
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects, published by the Minister for the Environment,
Heritage and Local Government, provide guidance on the preparation of Project
Construction and Demolition Waste Management Plans for certain classes of project,
which exceeds specified threshold limits. The requirement for such Plans extends
equally to both public and private sector developments. They provide clients,
developers, designers, practitioners, contractors, sub-contractors and competent
authorities with an agreed basis for determining the adequacy of C&D Waste
Management Plans.
Project C&D Waste Management Plans should be prepared for projects in excess of
any of the following thresholds and in certain cases are a condition of the planning
consent for a particular development:
626
� New residential development of 10 houses or more;
� New developments other than above, including institutional, educational,
health and other public facilities, with an aggregate floor area in excess of
1,250 m 2 ;
� Demolition/renovation/refurbishment projects generating in excess of 100m 3
in volume, of C&D waste;
� Civil Engineering projects producing in excess of 500m3 of waste, excluding
waste materials used for development works on the site;
It is considered that all construction industry stakeholders – including in particular
Clients and all professionals such as Architects, Engineers and Quantity Surveyors –
should be pro-active in relation to the systematic reduction and proper management
of C&D waste, a matter which is clearly in the public interest. Project C&D Waste
Management Plans should, therefore, be prepared for all but minor site
developments.
42.2 Policy Context and Reason for Introduction
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects are a by-product of a Voluntary Industry
Initiative launched by the construction industry in September 2004. This initiative
called on each participant in the construction industry to commit to a series of
actions, to promote waste prevention, reduction, reuse and recycling.
The purpose of the Best Practice Guidelines on the Preparation of Waste
Management Plans for Construction and Demolition Projects is to promote an
integrated approach to construction and demolition waste managed throughout the
duration of a project. They are designed to promote sustainable development,
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environmental protection and optimum use of resources. The guidelines introduce the
concept of project based waste management planning for construction and
demolition waste.
42.3 When was the Policy Introduced?
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects were published by the Minister for the
Environment, Heritage and Local Government in 2006.
42.4 Key Organisations Involved in Implementation and
Management
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects came about as a result of work between the
Department of the Environment, Heritage and Local Government (DoEHLG) and the
National Construction and Demolition Waste Council (NCDWC). The guidelines were
published by the Minister for the Environment, Heritage and Local Government and
approved by the NCDWC.
42.5 Monitoring and Measurement Techniques Applied
It recommended that construction and demolition contractors prepare, and submit to
the client, appropriate summary reports detailing the extent of waste prevention,
reuse, salvage and recycling on a project by way of implementation of the C&D Waste
Management Plan.
The client should also carry out independent periodic inspection and monitoring of
the implementation of the C&D Waste Management Plan.
Furthermore, it is recommended that C&D waste management plans prepared under
these guidelines be considered by the construction and demolition sector as a
potential source of data on the generation and management of construction and
demolition waste.
42.6 Evaluation Studies Available
Evaluation studies of C&D Waste Management Plans prepared and implemented for
completed construction and demolition projects were not available for this review.
The intention to design and implement a C&D Waste Management Plan is included in
Environmental Impact Statements for a wide range of developments including roads,
hotel and office developments, residential developments, etc. For example, the
Environmental Impact Statement for the Luas A1 line from Belgard to Saggart
contains a commitment to prepare a C&D Waste Management Plan to minimise the
impact on the environment.
42.7 Environmental Benefits
The implementation of the C&D Waste Management Plans on construction and
demolition projects should deliver clear environmental benefits. However, as
mentioned above, no systematic evaluations are available.
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Good waste management practice - prevention, minimisation, recycling and
appropriate disposal as a last resort – is an integral part of plans and actions at each
phase of the construction and demolition process developed through the C&D Waste
Management Plan. The promotion of sustainable development, environmental
protection and optimum use of resources are key underpinning principles. As such,
the development of such plans should improve management of wastes where the
aims of the plan are delivered.
42.7.1 Environmental Benefits – Prevention
C&D Waste Management Plans introduce the concept of project based waste
management planning for projects above certain thresholds and are based on an a
cradle-to-grave approach to C&D waste management. The ultimate objective of C&D
Waste Management Plans is to organise waste management activities on a
construction or demolition site in accordance with proven and best practices so as to
prevent waste generation in the first instance and increase on-site re-use of material.
Successfully implemented C&D Waste Management Plans, which contribute to the
prevention of C&D waste, could also result in a reduction in C&D waste related
nuisances (dust, windblown litter, visual impressions, etc).
42.7.2 Environmental Benefits Associated with Recycling
Similarly, successfully implemented C&D Waste Management Plans should result in
planned-for recycling of materials which will arise in the demolition and construction
phases. In principle, the approach could also encourage the use of materials from
secondary sources as a means to boost the development of markets for these.
42.8 Implementation Costs
In many cases the developer employs an engineering consultancy to prepare a C&D
Waste Management Plan for a particular project. The plan is included in the tender
documents issued to prospective contractors for quotation. According to an
engineering consultancy source, a typical C&D Waste Management Plan would cost in
the region of €5,000 to prepare, though this is likely to vary with size and complexity
of the development.
While there is a cost associated with the formulation and implementation of C&D
Waste Management Plans, significant financial incentives are available by way of
resultant waste prevention when current gate fees at waste management facilities,
haulage and labour costs are taken into consideration. It is recognised in the industry
that high transport and disposal costs serve to make the implementation of C&D
Waste Management Plans financially justifiably even from the perspective of a
developer.
42.9 Response from Public and Industry
The Guidelines, which were drawn up following recommendations made by two subcommittees
of the National Construction and Demolition Waste Council in relation to
construction and demolition waste management plans, have gone through a detailed
consultative process. The National Construction and Demolition Waste Council
(NCDWC) co-ordinated this work.
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The NCDWC had a high level of support from all organisations and professional
bodies involved in the construction industry and all took a proactive role in
contributing to the consultative process which led to these C&D Waste Management
Plan guidelines. The Guidelines were formally endorsed by the Council as a key driver
in improving the way in which the C&D waste stream is managed at a time of high
activity in the construction sector. The NCDWC called upon all involved in the
construction industry to support and implement the guidelines on their own projects.
42.10 Effects on Technical Change / Innovation
The C&D Waste Management Plan is prepared by the team delivering the project, and
the plan is prepared specific to each project. Therefore any technological changes or
new innovations, available at project design stage, are introduced and the benefits
offered are exploited to achieve the objectives of the waste management plan, thus
contributing to the prevention, minimisation and recycling of C&D waste.
The C&D Waste Management Plan Guidelines focus on the cornerstones of
prevention, minimisation, reuse and recycling and are not specific to any construction
related technologies, thus allowing the guidelines to remain in vogue with the
introduction of new technological innovations in the industry.
42.11 Social and Distributional Consequences
A planning authority may impose planning conditions on a developer. Certain
conditions may relate to C&D waste management during the construction stage. The
extent of the planning conditions imposed may depend on the scale and/or sensitivity
of the development. In this regard, the C&D Waste Management Plan to be prepared
for various developments may have different levels of restriction imposed whereby
developers are affected differently.
In summary, a large development (above a certain threshold as described in an
earlier section) is likely to be conditioned by a Planner to require the preparation and
implementation of a C&D Waste Management Plan, however a small scale
development such as the construction of a domestic house is likely to evade this
requirement.
42.12 Complementary Policies
Both the establishment of the National Construction and Demolition Waste Council
(NCDWC), the Waste Facility Permit Regulations and the Landfill Levy are related to
this policy (C&D Waste Management Plan Guidelines). As previously mentioned, the
NCDWC were involved in the delivery of the guidelines by way of consultation with the
construction industry. The preparation and implementation of C&D Waste
Management Plans encompasses the establishment of the need to acquire a Waste
Facility Permit for the activities envisaged and highlighted by the plan. The ultimate
objective of the plan will be to eliminate/minimise the quantities of C&D waste
destined for conventional disposal (not recovery) in landfill, thus avoiding the Landfill
Levy.
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42.13 Effect of the Policy on Pricing of Resources / Services
There is no direct effect of the policy on the price of resources. Rather, the potential
for generating financial savings through improved management of wastes is likely to
become more highly valued.
Clearly, it is of particular benefit to contractors when all cost components associated
with waste production are identified and highlighted at an early stage. This will be
effective in enhancing internal cost control procedures for the contractor and helping
to ensure that unproductive and readily avoidable costs of C&D waste management
are reduced. The implementation of the C&D Waste Management Plans will increase
ability to control/reduce waste management costs. Accordingly, the cost of
construction/demolition services should reflect the reduced waste management
costs secured by waste prevention, minimisation and reuse.
It has been established by Skoyles and Skoyles that some 18%/19% of construction
materials purchased from merchants are in addition to the quantities outlined in the
project contract specification (materials may be damaged in storage or by weather,
incorrectly positioned/constructed, used in greater quantities than intended, lost or
stolen). 750 C&D Waste Management Plans, through adherence to the guidelines
provided, can play a vital role in reducing this figure thereby reducing construction
costs. Clearly this would represent significant savings through reduced materials
consumption. The minimisation of waste, otherwise generated on construction sites
as a result of poor inventory management, impacts positively on maintaining natural
resources.
42.14 Evasion and Enforcement
The Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects were given a statutory footing by the
Development Management Guidelines issued by the Minister for the Environment,
Heritage and Local Government in 2007 under Section 28 of the Planning and
Development Act 2000. Planning Authorities must have regard to guidelines issued
under Section 28 in performance of their functions under the Act.
When a planning permission includes a requirement to prepare and implement a C&D
Waste Management Plan, the developer is required to submit the plan to the planning
authority prior to Commencement Notice Stage.
Waste auditing forms an integral part of C&D Waste Management Plans as a means
of ensuring ‘on the ground’ enforcement at construction/demolition sites. A Waste
Audit represents a systematic study of the waste management practices in the
project. Waste auditing allows the success of a waste management plan, in realising
the goals of waste prevention and minimisation, to be evaluated. An Audit Plan should
be clearly defined in the Project C&D Waste Management Plan. Summary audit
reports should be sent to the appropriate local authority.
750 E.R. Skoyles and J.R. Skoyles (1987) Waste Prevention on Site; London: Mitchell.
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42.15 Lessons Learned
For the purpose of this review, a number of local authorities were contacted in an
effort to get feedback on the success of the inclusion of the condition to prepare and
implement C&D Waste Management Plans in certain planning permissions. It was
reported that definite enforcement is required to ensure that C&D Waste
Management Plans are actually implemented on site, and not just a paperwork
exercise.
The preparation of a Project Waste Management Plan should involve all parties,
including client, designers, contractors and competent authorities. In particular the
plan should be considered at the design stage such that any necessary changes can
be made to the site layout and/or landscaping of the site to accommodate the
primary objectives of the Plan (waste prevention, minimisation and recycling).
Designers should provide the Client at an early stage with clear advice in relation to
the prevailing policy, legislation and best practice in C&D waste management. By
securing agreement from the Client on the implementation of environmentally sound
management of C&D waste (prevention, minimisation and recycling) at the outset of
the project, this commitment can be imposed on all construction industry
stakeholders over the entire duration of the scheme. This ‘cradle to grave’ approach
optimises the delivery of best practice in the management of C&D waste.
A clear requirement would appear to be to place the preparation of Plans on a firmer
footing. Many other countries have already made moves to do this (see Annexes 43.0
and 48.0).
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43.0 Site Waste Management Plans -
International
43.1 Outline of Policy
Construction and demolition site management plans are a tool used to address
issues of resource efficiency on site. Waste Management Plans 751 (WMPs) aim to:
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� encourage effective waste management on construction and demolition
sites through adequate planning, monitoring and reporting of waste in order to
increase prevention, re-use and recycling; and/or;
� reduce illegal transportation and disposal (fly-tipping) of construction and
demolition waste.
Construction and demolition site management plans can be implemented as a
mandatory requirement or as a voluntary option. Given the discussion focuses solely
on policy, countries which have set up a voluntary site waste management planning
systems are excluded from the following discussion.
Waste management plans are required before the project begins and are working
documents that need updating throughout the project. The system is basically a
waste data planning and reporting requirement. It is normal for document templates
to be provided, either by the enforcement body or a trade body, which the contractors
can choose to use, or alternatively they can submit the required information in their
own format. As part of the data collection, there is usually a central database to which
contractors must submit recorded quantities of C&D waste materials generated and
disposed of over a particular time period. Alternatively information received from the
contractors will then be input to a database by the enforcement body, thereby
creating an up-to-date source of C&D waste data. Enforced reporting promotes
foresight and planning prior to the project in order to minimise and recycle site waste.
In some countries, reporting on greenhouse gas balances is also tending to support
the use of secondary materials rather than primary ones.
43.2 Where Has the Policy Been Applied and Why?
There is a clear trend for Waste Management Plans to become policy following the
implementation of a voluntary agreement, which is often made between national or
local government and the construction and demolition construction and demolition
industry. This is still currently the situation in many countries, for example, the
Netherlands, but evidence has been found to show that WMPs have been made
751 Throughout this document Waste Management Plans are generally referred to as WMPs, although
in country specific examples they cited their country-specific name.

mandatory to varying degrees in England, Australia, Singapore, Ontario, California,
Hong Kong, Japan and Brazil.
43.2.1 Country-specific Characteristics
England
In England, Site Waste Management Plans (SWMPs) have been mandatory (therefore
considered a policy) since 6 th April 2008. 752 They have been implemented under the
Clean Neighbourhoods & Environment Act 2005 in line with the Code for Sustainable
Homes (which is voluntary) and Planning Regulations. They are also an extension of
Duty of Care which is contained in the Environmental Protection Act 1990 and the
Environmental Protection (Duty of Care) Regulations 1991.
SWMPs are essential for projects worth more than £300,000 (excluding VAT).
However, some local authorities throughout the UK require a SWMP for smaller
projects through their Supplementary Planning Documents. 753 A SWMP should detail:
633
� the types of waste to be removed from the site;
� the waste carrier who will transport the waste away from the site; and
� the site to which the waste is going to be taken.
If the project is estimated to be worth over £500,000 then the following additional
information is required:
� the waste carriers’ registration numbers;
� a description of the waste; and
� details of the environmental permit or exemption held by the site where the
material is to be taken. 754
Australia
In Australia WMPs are also integral to the planning process but their main objective is
to reduce fly-tipping. 755 However, the requirements are very similar to the UK SWMP
and include details on the quantity and type of waste produced, and proposed
methods of disposal for each. When tendering for major construction or demolition
752 HM Government & Strategic Forum for Construction (2008) Strategy for Sustainable Construction,
http://www.berr.gov.uk/files/file46535.pdf
753 These are documents which are part of the development plan in a given local authority area.
754 The UK Statue Law Database (2008) The Site Waste Management Plans Regulations 2008
(No.314), Accessed 16 th January 2009,
http://www.statutelaw.gov.uk/legResults.aspx?LegType=All+Legislation&title=Site+Waste+Manageme
nt+Plans+Regulations+&Year=2008&number=314&searchEnacted=0&extentMatchOnly=0&confersP
ower=0&blanketAmendment=0&TYPE=QS&NavFrom=0&activeTextDocId=3448878&PageNumb
755 New South Wales Government, Department of Environment and Climate Change, Know Your
Responsibilities: Managing Waste From Construction Sites, Accessed 15th October 2008
http://www.environment.nsw.gov.au/waste/manbuildingwaste.htm
International Review of Waste Policy: Annexes

projects for either national, state or local government a WMP is required to be
submitted as part of the tendering process. 756
Ontario, Canada
The Ontario Regulation 102/94 & 103/94 was introduced in 1994. It is applicable to
construction and demolition projects with a floor area greater than 2,000 square
metres. Contractors working on these projects are required to submit a Waste
Reduction Work Plan which outlines how site waste reduction, reuse and recycling will
be implemented, when it will be implemented, and the expected results of this. 757
California, USA
Within the State of California there are many examples of cities that have mandated
the use of site plans. For example, the City of Oakland requires contractors to submit
a Job Site Recycling (JSR) and Waste Reduction Plan (WRP) for any authority-led
construction or demolition project worth more than $150,000. The JSR and WRP
must include the following elements:
634
� Type of waste materials likely to be produced by the project;
� Quantity of waste materials likely to be produced by the project;
� Procedures for site management of waste; and
� Processors which have been identified to accept the site waste.
The Californian Government has stipulated an overall recycling rate of 50%. However,
the Oakland authorities have not enforced this within the C&D sector believing the
stream to be highly variable, thereby allowing their JSR & WRP policy to be flexible. 758
Hong Kong
In Hong Kong WMPs have been mandatory for all public construction projects since
2000. In 2003 the requirements of the WMP were strengthened. They now must
include:
� Key types of waste to be reduced;
� Waste reduction targets;
� Waste reduction programmes;
� Waste disposal procedures; and
756 AEA Technology (2007) Developing a Strategic Approach to Construction Waste, Final Report for
Defra (BREW), Accessed 15 th October 2008
http://www.bre.co.uk/filelibrary/rpts/ConstructionWasteReport240906.pdf
757 Government of Ontario (1994) Environmental Protection Act – O.Reg. 102/94, Accessed 16 th
January 2009, http://www.search.e-laws.gov.on.ca/en/isysquery/fe3d3ba6-a68c-4eaa-8354-
08abf6806286/1/frame/?search=browseStatutes&context=
758 Gruzen Samton LLP with City Green Inc. (2003) Construction and Demolition Waste Manual,
prepared for New York City Department of Design and Construction, Accessed 19 th January 2009,
http://www.nyc.gov/html/ddc/downloads/pdf/waste.pdf
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Japan
635
� Monitoring and auditing procedures. 759
In Japan the Construction Waste Recycling Law requires submission of a site plan
prior to construction and/or demolition commencing in order to outline the intended
management plan for separating and recycling site waste. 760
Singapore
In Singapore a Site Environmental Control Programme must be submitted to the
National Environment Agency. An additional requirement is to appoint an
Environmental Control Officer (ECO). They are necessary on site for the following
projects:
� If the project cost is estimated to exceed $10 million a part-time ECO (15
hours a week) is required; and
� If the project cost is estimated to exceed $50 million a full-time ECO (40 hours
a week) is required.
This has been mandatory since November 1999 under the Environmental Public
Health Regulations. However, the ECO’s role covers the following with respect to
waste:
� Site management of waste; and
� Ensuring construction wastes are properly disposed of. 761
43.3 Key Organisations Involved in Implementation and
Management
Throughout all the countries where mandatory WMPs apply, it is the C&D industry’s
responsibility to implement and administer WMPs for their projects. Management and
enforcement of the policy takes place at varying levels of government depending on
the country. Sometimes this occurs through the planning function, in other cases, it is
the responsibility of the environmental agencies.
In the UK the responsibility of enforcement of the SWMP is mainly local authorities
but over-arching responsibility is held by the Environment Agency. There is a similar
situation in Australia where all three levels of Government have included WMPs in
strategies, but where local government is responsible for its implementation. In the
USA, local government, often at the town or city level, assesses the submitted JSR
759 Environment, Transport and Works Bureau (2005) Technical Circular (Works) No.19/2005,
Accessed 20 th January 2009, http://www.devb-wb.gov.hk/UtilManager/tc/C-2005-19-0-1.pdf
760 Government of Japan’s Ministry of Environment (2001) Construction Material Recycling Law,
Accessed 16 th January 2009, http://www.env.go.jp/en/laws/recycle/09.pdf
761 Singapore National Environment Agency, Responsibilities of Occupier of Construction Site and
Submission of Reports, Accessed 16 th January 2009,
http://app.nea.gov.sg/cms/htdocs/article.asp?pid=1238
International Review of Waste Policy: Annexes

and WRPs. It has been highlighted that the implementation of the WMP policy is likely
to require a greater amount of staff time, than for example a deposit refund system in
conjunction with mandatory recycling rates. 762
43.4 Pre-implementation / Evaluation Studies Available
There is a lack of available research which has effectively evaluated and made crosscountry
comparisons of the implementation of WMPs. Information obtained for this
report has mainly come from Government websites, industry feedback and research
relating specifically to WMPs in one country. The following list outlines the key reports
used (references to Government and industry websites are shown as footers only):
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� AEA Technology (2007) A Review of international Approaches to Waste
Prevention, and Minimisation, Final Report to Defra (BREW).
� AEA Technology (2007) Developing a Strategic Approach to Construction
Waste, Final Report to Defra (BREW)
� AEA Energy & Environment (2007) Survey of Three Stakeholder Groups on
Site Waste Management Plans, Report to The Construction Resources and
Waste Platform.
� Building Research Establishment (2008) A cost-benefit analysis of the
introduction of site waste management plans for the construction and
demolition industry, Report to Defra.
� B. Baetz & T. Saotome (2007) Development of Construction and
Demolition Waste Recycling in Ontario.
� S. Coventry, B. Shorter & M. Kingsley (2001) Demonstrating Waste
Minimisation Benefits in Construction, Construction Industry Research and
Information Association, Publication C536
� V.W.Y. Tam (2007) On the Effectiveness in Implementing a Waste-
Management-Plan Method in Construction.
43.5 Environmental Benefits
In qualitative terms the main positive environmental outcomes delivered by the policy
are to:
� reduce C&D waste to landfill;
� reduce overall quantity of C&D waste due to greater planning leading to
waste prevention;
� increase levels of re-use and recycling of C&D waste; and
� reduce fly-tipping.
762 Gruzen Samton LLP with City Green Inc. (2003) Construction and Demolition Waste Manual,
prepared for New York City Department of Design and Construction, Accessed 19 th January 2009,
http://www.nyc.gov/html/ddc/downloads/pdf/waste.pdf . See also Appendix 48.0.

Hong Kong
Industry surveying and interviews undertaken in Hong Kong on the effectiveness of
WMPs showed that the two main environmental benefits were thought to be:
1. Increased on-site reuse of materials, and
2. Increased waste reduction. 763
However, there was no actual quantification of these benefits in the associated
report.
England
Data available on the effectiveness of WMPs comes from the results of research
published by the Construction Industry Research and Information Association (CIRIA)
which found that implementation of a SWMP in England results in 15% less waste
onsite and 43% less waste to landfill. 764
Singapore
Waste statistics from 2007 show construction debris recycling rates in Singapore to
be 98%. Clearly this achievement is mainly driven by the severe lack of landfill
capacity but this was likely to have been influenced also by the requirement to
prepare management plans and the mandated role of ECOs. Unfortunately
quantifying the effect of ECOs in isolation is not possible.
With few country specific examples it is clear that there is an overall lack of data in
order to prove that the main outcomes listed above are actually taking place as a
result of WMPs.
This issue regarding lack of data could in part be related to the lack of policy
enforcement, which is discussed in Section 43.11. In addition, the data regarding
construction and demolition waste has tended, by and large, to be of poor quality in
many countries. The nature of the material is such that the re-use of material on-site,
or the management of material across multiple sites, tends to make quality data
gathering somewhat difficult. On the other hand, the plans themselves ought to be a
means of achieving better quality data, albeit perhaps only for projects covered by the
requirement.
43.6 Implementation Costs
The cost of implementation falls to the construction/demolition contractor who in turn
will pass some of the cost onto their customer.
763 V.W.Y. Tam (2007) On the Effectiveness in Implementing a Waste-Management-Plan Method in
Construction.
764 S. Coventry, B. Shorter & M. Kingsley (2001) Demonstrating Waste Minimisation Benefits in
Construction, Construction Industry Research and Information Association Publication C536.
637
International Review of Waste Policy: Annexes

Evidence from both the UK and Hong Kong suggests that implementation of a SWMP
can be a costly process. 765 This is especially true during early stages of adoption of
the policy when the administrative burden is likely to be greater (even more so for
those companies who manage their waste poorly and who have to set up on site
sorting facilities). Staff training would be required to gain skills in writing WMPs and to
gain a detailed understanding of the policy in order to comply. 766 In the UK both
WRAP and the Buildings Research Establishment (BRE) have set up Site Waste
Management Plan templates which should increase the efficiency of the
process. 767768
Prior to mandated SWMPs the BRE undertook a cost-benefit analysis for Defra. This
report had to make many assumptions regarding costs due to the lack of specific
information available. During analysis, it combined desk-based research with the
results of a small survey and extrapolated from this. The data the project did collect
related to very high budget projects, being undertaken by large companies. The
analysis undertaken covered domestic and non-domestic new builds, refurbishment
and demolition projects. These costs had to be scaled down in order to estimate the
costs and benefits to smaller companies. Output regarding the cost of SWMP
introduction for domestic new builds is shown in Table 43-1. High level SWMP refers
to those projects more than £500,000.
Although implementation of a WMP can be a costly process in the short-term it can
bring significant financial benefits to the construction company through savings from
reduced waste disposal. The BRE report goes on to highlight estimated cost-savings
(Table 43-2), though it could not accurately consider transport costs due to the
variation from one project to another. Comparing the two Tables, it can be seen that
particularly at the higher end of the project range, costs were deemed likely to be
covered by savings, but that this is viewed as being less likely in small projects. This
seems to be a consequence of the fact the benefits are broadly scale dependent, but
implementation costs, in particular, are estimated to be less sensitive to scale.
765 V.W.Y. Tam (2007) On the Effectiveness in Implementing a Waste-Management-Plan Method in
Construction,
766 AEA Technology (2007) Developing a Strategic Approach to Construction Waste, Final Report for
Defra (BREW), Accessed 15 th October 2008,
http://www.bre.co.uk/filelibrary/rpts/ConstructionWasteReport240906.pdf
767 WRAP (2009) Site Waste Management Plans Tools and Guidance,
http://www.wrap.org.uk/construction/construction_waste_minimisation_and_management/site_wast
e_managemen.html, accessed 12 th February 2009.
768 Building Research Establishment’s SmartWaste Website (2008) http://www.smartwaste.co.uk/,
Accessed 12 th February 2009
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Table 43-1: Estimated Total Cost of Introducing SWMPs for Domestic New Build
Projects
Project
Project
Cost
Cost
639
Ass Assumed Ass umed
Average
Average
Cost Cost
Cost
Within Within
Within
Band
Band
Time Time to to Prepare
Prepare
and and Write Write the
the
SWMP
SWMP
Basic
Basic
Level
Level
SWMP
SWMP
High High
High
Level
Level
SWMP SWMP
SWMP
International Review of Waste Policy: Annexes
Implementation
Implementation
Basic
Basic
Level
Level
SWMP
SWMP
High
High
Level
Level
SWMP
SWMP
Monitoring Monitoring and
and
Auditing
Auditing
Basic
Basic
Level
Level
SWMP
SWMP
High
High
Level
Level
SWMP
SWMP
Total Total SWMP SWMP Cost Cost
Cost
Basic
Basic
Level
Level
SWMP
SWMP
High
High
Level
Level
SWMP SWMP
SWMP
£500k £1,600k £200 £300 -£2,300 -£4,600 £500 £1,900 -£1,600 -£2,400
Source: Building Research Establishment (2008) A cost-benefit analysis of the introduction of site
waste management plans for the construction and demolition industry, Report to Defra.
Table 43-2: Estimated Total Cost Savings from SWMPs for Domestic New Build
Projects
Project
Project
Cost
Cost
Assumed
Assumed
Average
Average
Cost
Cost
Within
Within
Band
Band
Waste Waste Disposal Disposal
Disposal
Reduction
Reduction
Basic
Level
SWMP
High
Level
SWMP
Resource
Resource
Efficiency Efficiency Gains Gains
Gains
Basic
Level
SWMP
High
Level
SWMP
Total Total Estimated
Estimated
Cost Cost Cost Savings
Savings
Basic
Level
SWMP
High
Level
SWMP
£500k £1,600k £1,200 £2,400 £4,000 £8,000 £5,200 £10,400
Source: Building Research Establishment (2008) A cost-benefit analysis of the introduction of site
waste management plans for the construction and demolition industry, Report to Defra.

CIRIA research found that implementation of a WMP could result in 50% savings in
waste handling charges and 40% savings on disposal costs. Although this research
was published several years ago, when WMPs were a voluntary practice, it still shows
in very approximate terms that the savings can be significant. 769
More recent evidence from a NetRegs survey, published 6 months after WMPs were
mandated in England, showed that construction companies are saving at least
£2,637 per year under the WMP system. In addition to this, 25% of companies
implementing WMPs believed it to have helped them win new contracts by increasing
their environmental credentials. 770
Although it can be argued, and is shown from the BRE, CIRIA and NetReg evidence,
that in the long-term, implementing WMP will benefit C&D companies with cost
savings from reduced waste disposal costs, in the short-term they require investment
and could affect tendering prices. Feedback from the construction industry in Hong
Kong suggests that during the early stages of implementation, levels of productivity
can be impacted upon significantly. However, when all companies reach the required
level of skill and expertise needed to efficiently implement a WMP, then the costs are
likely to fall back, with the benefits then being more likely to exceed the costs. 771
43.7 Effects on Technical Change / Innovation
Mandatory WMPs bring the issue of waste management on C&D sites to the forefront.
As a result of this, and possibly the general heightened awareness of environmental
issues, there is currently much discussion surrounding waste prevention initiatives in
the C&D sector. For example, the current EU Eco-design Directive (2005) purely
focuses on energy efficiency at this stage but it is thought that future revisions may
cover a much wider remit, including waste. Initiatives are also being introduced such
as WRAP’s Plasterboard Programme, being run in the UK, which focuses on waste
minimisation and recycling. This is closely linked to the ban on landfilling of gypsum
introduced recently in the UK. The use of prefabricated building components is
thought to be instrumental in preventing waste during construction in Hong
Kong. 772773
769 S. Coventry, B. Shorter & M. Kingsley (2001) Demonstrating Waste Minimisation Benefits in
Construction, Construction Industry Research and Information Association, Publication C536.
770 Construction News Portal (2009) Construction Business Still Unaware That SWMPs Are Mandatory
For Projects Over £300,000, Accessed 16 th January 2009,
http://www.constructionnewsportal.com/construction_article6511.html
771 S. Coventry, B. Shorter & M. Kingsley (2001) Demonstrating Waste Minimisation Benefits in
Construction, Construction Industry Research and Information Association, Publication C536.
772 WRAP (2008) Accessed 15 th October 2008)
http://www.wrap.org.uk/construction/plasterboard/index.html
773 V.W.Y. Tam (2007) On the Effectiveness in Implementing a Waste-Management-Plan Method in
Construction.
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43.8 Social and Distributional Consequences
The effect of the policy on businesses depends on how it has been implemented (as
described in Section 43.2.1). Countries which apply limitations of size/value of the
development, which denote whether or not the policy should be applied, will most
likely affect the larger C&D companies because they are most likely to take on these
projects. Equally, the BRE research discussed above suggests that these are the
projects which are most likely to generate benefits which exceed the costs of the
implementation of WMPs.
However, as an industry which faces many challenges in reducing their impact upon
the environment, implementing WMPs is one way that C&D companies can improve
their reputation through potentially improving their levels of work efficiency and
increasing their environmental credentials.
Given the potential for generating benefits that exceed costs, the net costs of the
approach are unlikely to be significant for large projects. Smaller construction
projects might be affected disproportionately if the policy is extended to cover a wide
range of projects.
43.9 Complementary Policies
The most significant drivers complementing this policy are disposal levies and other
forms of policy which make disposal more expensive. Where there is a cost to dispose
of C&D waste an incentive is provided for companies to reduce the volume of waste
they are producing. One way of doing so is to implement a WMP on site.
WMPs increase awareness of waste on site and so initiatives and policies regarding
product standards (Annex 47.0) and demolition protocols (Annex 45.0) help
complement work towards the goal of reducing site waste, and its disposal. Finally, in
countries where they exist, taxes on primary aggregates support such a policy, though
as discussed in Annex 46.0, the approach has probably been less effective than
levies on disposal.
43.10 Effect of the Policy on Pricing of Resources / Services
There is no direct effect of the policy on the price of resources. Rather, the potential
for generating financial savings through improved management of wastes is likely to
become more highly valued.
Given the greater amount of resources needed to properly implement an effective
WMP, a C&D company’s costs may increase and this cost could initially be reflected in
the price of their service as it is passed onto their customers. However, as discussed
in Section 43.6 this is likely to be a short-term effect. Waste management plans help
companies to save money through resource efficiency and this will either be reflected
in the reduced prices for which they offer their services, or in the company’s profit
margins.
43.11 Evasion and Enforcement
A major problem with WMPs is the lack of enforcement associated with them which
ultimately leads to non-compliance. A report to Defra concluded that compliance is
641
International Review of Waste Policy: Annexes

lacking in Australia, Singapore and the Netherlands where WMPs are very poorly
monitored despite them being a mandatory requirement of the planning process. 774
In England, where WMPs are a legal requirement for projects estimated to cost more
then £300,000, the WMP does not have to be approved, just kept on site and made
available if requested. The only exception to this rule is when some local authorities
require the plan to be submitted as a Supplementary Planning Document. There is,
however, an incentive to comply because in cases of non-compliance those convicted
can receive fines of up to £50,000. A survey undertaken by NetRegs, 6 months after
WMPs were mandated, showed that 51.2% of construction businesses were still
unaware of this new policy requirement. 775
In Ontario, the Ministry of the Environment Enforcement Branch of Operations
Division, and Regional and District Offices, are responsible for visiting sites, checking
the plans and ensuring that the plan is being put into practise. In 2006 the Ministry of
the Environment undertook inspections which revealed 90% of Industrial /
Commercial / Institutional organisations were not complying with these regulations. It
is thought that the main reason for lack of compliance is because although it is
mandatory for a waste audit and waste reduction plan to be prepared it does not
have to be submitted. 776 The regulations require the documents to be made available
upon request therefore relying upon a self-regulatory approach. However, there is
currently no incentive for companies to comply since there is no sanction for cases of
non-compliance.
As part of the 2003 revision in Hong Kong, the issue of evasion was tackled by
increasing the enforcement of WMP implementation, increasing levels of site
monitoring and control. This included a requirement from the contractor to complete
and submit the WMP within 14 days of receiving acceptance of their tender for the
project. 777
43.12 Lessons Learned
Where the policy has been introduced using self-regulatory approaches, then uptake
will be lower than hoped for as long as there is no sanction in place if a case of noncompliance
is identified. England has introduced the policy in this way but due to the
774 AEA Technology (2007) International Approaches to Waste Prevention and Minimisation, Final
Report for Defra (BREW), Accessed 15 th October 2008,
http://www.crwplatform.co.uk/conwaste/assets/Publications/2006-7-Reports/International-
Approaches-to-Waste-Prevention-and-Minimisation.pdf
775 Construction News Portal (2009) Construction Business Still Unaware That SWMPs Are Mandatory
For Projects Over £300,000, Accessed 16 th January 2009,
http://www.constructionnewsportal.com/construction_article6511.html
776 B. Baetz and T. Saotome (2007) Development of Construction and Demolition Waste Recycling in
Ontario. Accessed 15 th October 2008,
http://msep.mcmaster.ca/publications/Development_of_C&D_recycling_in_Ontario.pdf
777 Environment, Transport and Works Bureau (2005) Technical Circular (Works) No.19/2005,
Accessed 20 th January 2009, http://www.devb-wb.gov.hk/UtilManager/tc/C-2005-19-0-1.pdf
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short time frame over which it has been mandatory to prepare WMPs, there is
currently no evidence of fines which have been administered due to lack of
compliance at this stage, despite evidence suggesting around 50% of construction
companies are not aware of, and may not be complying with, the law.
Enforcement and penalties are vital to the success of a policy which relies upon
investments of money and time from the C&D sector. Also, current evidence to show
the payback period of implementing a WMP could prove to be an important financial
incentive to companies to comply with the requirement. If experience and estimates
thus far are indicative, then this might show that although in the short-term, there is a
cost for preparing WMPs (including, potentially, in terms of productivity on site), this is
likely to be more than offset by savings from reduced waste disposal costs over the
life of the project and in the longer term. The likelihood of benefits exceeding costs
may diminish as the project size declines, suggesting, perhaps, a more basic
alternative to a ‘full blown’ plan for smaller projects.
Industry opinion in England identifies the main problem with the implementation of
site waste management plans as their lack of integration within the tendering
process. 778 The underlying problem is that clients’ main concern is cost, and if a
company which has spent time including a WMP in the tender document is competing
with a company which haven’t, they may lose the work. This effect is thought to be
very short-term due to the inherent savings made through implementing a WMP due
to reduced disposal fees.
43.13 Prerequisites for Introduction
Section 43.2 highlighted that many mandatory WMPs began initially as voluntary
agreements with strong involvement from industry. This is thought to be fundamental
to the success of the policy since the responsibility is placed fully with them from the
implementation stage through to regulation.
As identified in Section 43.9, the introduction of WMPs is given impetus by policies
which make disposal expensive. These can provide the incentive to the C&D sector to
ensure more waste is prevented, and less waste is sent for disposal. The likelihood
increases that the savings will exceed the costs under these circumstances.
778 C. Mitchell (2008) Home Truths: Waste Management, Building,
http://www.building.co.uk/regen_story.asp?sectioncode=327&storycode=3122152&c=3 Accessed
15 th October 2008.
643
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44.0 Waste Facility Permit Regulations - Ireland
44.1 Outline of Policy
The Waste Management (Permit) Regulations 1998 provide for the granting of waste
permits by local authorities in respect of specified waste disposal and recovery
activities in lieu of a licence by the Environmental Protection Agency under section 39
(1) of the Waste Management Act, 1996.
The Waste Management (Facility Permit and Registration) Regulations 2007 and
Waste Management (Facility Permit) (Amendment) Regulations 2008 amend and
replace the Waste Management (Permit) Regulations 1998 and set out procedures
for the making of permit and registration applications, public consultation,
consideration by local authorities of submissions in relation to permit or registration
applications, and the grant, refusal and review of facility permits and registration by
local authorities.
The waste facility permit Regulations encourage C&D waste prevention and
minimisation due to the tonnage limitations attached to the various recovery activities
permitted. The prevention of C&D waste generation on a site such that the tonnage of
C&D waste (intended for recovery) is below a waste facility permit threshold, thus
avoiding the need for a waste licence, offers advantages from both a financial and
operational perspective.
In this respect, the application fee for a waste licence for the recovery of waste is
€10,000 779 compared to an application fee of €2,000 for a waste facility permit for
C&D applications. Furthermore, past experience in the industry has dictated that
waste licence holders can expect a more rigorous enforcement regime than waste
facility permit holders for a similar activity.
44.2 Policy Context and Reason for Introduction
The primary purpose of the waste facility permitting system is to facilitate appropriate
controls on commercial activities so as to ensure good and consistent waste
management practice and the implementation of high standards of environmental
protection.
Waste permits are granted by local authorities in respect of specified waste recovery
and disposal activities which, because of their scale or nature, do not warrant
integrated licensing by the EPA.
44.3 When was the Policy Introduced?
The Waste Management (Permit) Regulations, 1998, were introduced in 1998
providing for the granting of waste permits by local authorities.
779 EPA Website – www.epa.ie
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In December 2007, Mr. John Gormley, Minister for the Environment, Heritage and
Local Government signed the Waste Management (Facility Permit and Registration)
Regulations 2007.
In March 2008, the Minister for the Environment, Heritage and Local Government
amended the Waste Management (Facility Permit and Registration) Regulations 2007
by way of the Waste Management (Facility Permit) (Amendment) Regulations 2008.
The Waste Management (Facility Permit and Registration) Regulations 2007 and
Waste Management (Facility Permit) (Amendment) Regulations 2008 came in to
effect on the 1st June 2008 and replaced the Waste Management (Permit)
Regulations, 1998.
The new Regulations (2007/2008) introduce the following primary
changes/differences:
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� There is more definition on the different classes of activity for Waste Facility
Permits and Certificates of Registration;
� The timescales to be adhered to upon receipt of valid applications are defined;
� Permits may be reviewed, revoked, transferred and decisions made may be
appealed to a competent court;
� Procedures to deal with abandoned applications are provided;
� Planning permission or a certificate of exemption must be obtained for all
permitted activities; and
� An activity that has no authorisation of any kind will be regarded as landfilling
and hence the landfill levy will apply. This levy will be channelled through each
individual Local Authority for transmission to the Environmental Fund.
44.4 Key Organisations Involved in Implementation and
Management
The Waste Permit Regulations were introduced by the Minister of the Environment,
Heritage and Local Government. The waste permit application process is controlled by
the local authorities that issue the waste permits to applicants.
The latest waste permitting Regulations (2007/2008) enable the EPA to decide on
whether, having regard to particular circumstances, the facility requires a waste
licence or permit.
Following the introduction of the new waste permitting Regulations (2007/2008), the
EPA produced and published guidance literature for the assistance of local authorities
in carrying out their functions under the Regulations. However, the literature is for the
benefit of all stakeholders including private waste operators and the general public.
Furthermore the EPA facilitated a briefing session for industry on the new permitting
Regulations in May 2008.
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44.5 Monitoring and Measurement Techniques Applied
The following section provides an overview of the tonnage thresholds applicable to
the treatment of C&D waste for both the old and new waste facility permit
Regulations.
Waste Waste Waste Management Management Management (Permit) (Permit) Regulations Regulations 1998 1998 1998 (Now (Now superseded)
superseded):
superseded)
As part of the application process, the applicant identified the relevant activities from
the Third and Fourth Schedules of the Waste Management Act which relate to
disposal and recovery activities. The activities that could be permitted were outlined
in Part I and Part II of the First Schedule of the Regulations.
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� C&D waste recovery operations (other than hazardous waste) (First Schedule
Part I - Class 5)
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There were no upper limits set in the Regulations for the recovery of waste
(other than hazardous waste) provided 100% recovery is achieved although
the local authority would usually specify a maximum permissible quantity
under the conditions of the waste facility permit.
� Disposal of C&D waste (other than hazardous waste) at a facility (other than a
landfill facility) where the annual intake does not exceed 5,000 tonnes per
annum. (First Schedule Part I - Class 6)
� A contractor was required to apply for a Certificate of Registration from the
local authority when intending to temporarily store quantities of hazardous
material on-site (on the premises where it is produced) which exceeds the
limits of 25,000 litres liquid waste or 40m 3 non-liquid waste. (First Schedule
Part III)
The operator of a waste facility permit is required to maintain specified records for the
activity to which the waste permit relates and must provide such details to the local
authority by the 28th day of February each year.
Waste Waste Management Management (Facility (Facility Permit Permit and and Registration) Registration) Regulations Regulations 2007 2007 and and Waste
Waste
Management Management (Facility (Facility Permit) Permit) (Amendment) (Amendment) Regulations Regulations 2008:
2008:
These latest Regulations came into effect on the 1st June 2008. As part of the
application process, the applicant identifies the relevant activities from the Third and
Fourth Schedules of the Waste Management Act which relate to disposal and
recovery activities. The activities that can be permitted are outlined in Part I and Part
II of the Third Schedule of the Regulations. If the application relates to a number of
classes of activities, the principal activity must be identified.
� Recovery of Inert C&D waste - less than 50,000 tonnes per annum can be
recovered, under the scope of a waste permit, provided that the maximum
quantity of residual waste consigned for collection, onward transport and
disposal is less than 15% of the total annual waste intake. (Third Schedule
Part I - Class 7)
� Recovery of Inert waste (other than excavations or dredgings comprising
natural materials of clay, silt, sand, gravel or stone) through deposition for the
purposes of the improvement or development of land, where the total quantity

647
of waste recovered at the facility is less than 50,000 tonnes (Third Schedule
Part I - Class 6).
� Recovery of excavation of dredge spoil, comprising natural materials of clay,
silt, sand, gravel or stone and which comes within the meaning of inert waste,
through deposition for the purposes of the improvement or development of
land, where the total quantity of waste recovered is less than 100,000 tonnes
over the life of the activity (Third Schedule Part I - Class 5).
A contractor can temporarily store quantities of hazardous material on-site (on the
premises where it is produced). There is now no cap on the quantities of liquid and
non-liquid hazardous wastes stored.
The operator of a waste facility permit is required to provide the local authority with
an Annual Environmental Report (AER), containing summary information in relation to
the preceding calendar year in respect of the activities concerned, by the 28th day of
February each year.
44.6 Evaluation Studies Available
Waste permits have been issued for numerous sites since their introduction in 1998.
According to practitioners in the construction industry, the process has proved most
successful for the control of specified waste reuse/recovery and disposal activities
which, because of their scale or nature, did not warrant integrated licensing by the
EPA.
However, no detailed evaluation studies on particular cases were found during the
research conducted in the preparation of this review document.
44.7 Environmental Benefits
44.7.1 Environmental Benefits – Prevention
The environmental benefits provided by the Waste Permit Regulations (1998
Regulations & 2007 Regulations /2008 Amendment Regulations) include a reduction
in C&D waste generation and C&D waste sent to landfill.
44.7.2 Environmental Benefits Associated with Recycling
The Regulations facilitate the reuse/recovery of excavated materials on the site of
origin and the use of excavated materials for the improvement and development of
land on other sites.
Furthermore, the issue of a waste permit facilitates the control and monitoring of C&D
waste reuse and recovery activities. The local authority, by way of monitoring,
inspection and auditing, enforces compliance with the regulation requirements.
Accordingly there are reduced environmental nuisances on sites that are in
compliance with their waste permit conditions.
44.8 Implementation Costs
The implementation cost of a waste permit is borne by the facility/site operator. The
payment for a waste permit is made to the relevant local authority. The initial
International Review of Waste Policy: Annexes

application fee is consistent from local authority to local authority; however the
monitoring fee can vary from local authority to local authority.
A primary aim of the new Regulations is to introduce consistency among local
authorities with respect to all aspects of the waste permit process, including
implementation cost. The new Regulations empower local authorities to recover all or
part of the reasonable costs incurred by ongoing monitoring of compliance with a
facility permit, including the costs of inspections and investigations.
44.9 Response from Public and Industry
The latest Regulations (2007 Regulations /2008 Amendment Regulations) which
were subject to wide scale public consultation took a considerable time to progress
due to the complexity of the issues needing to be addressed and will assist in:
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� Facilitating recovery activities to the greatest extent practicable.
� Minimising the considerable administrative and cost burden on applicants.
� Harmonising administration and implementation of the permitting and
registration system.
44.10 Effects on Technical Change / Innovation
The applicant provides a comprehensive description of the proposed site and
intended C&D waste reuse/recovery operations at the application stage. The
applicant can avail of the latest technologies available to the market by including
descriptions of improved processes and innovations in the waste permit application.
The application will then be assessed by the relevant local authority and subject to
the new technology/process not presenting any unwanted environmental
consequences; the application may be approved by the local authority.
44.11 Social and Distributional Consequences
All operators are subjected to a similar application process through the relevant local
authority. However, in the past the application period experienced by applicants has
varied from Local Authority to Local Authority. The effect of the waste permit
regulations on a site or a facility is dependent on the scale of the recovery operation
proposed. As outlined above, the nature and tonnage of the intended recovery
operation will result in a site or facility qualifying or not qualifying for a waste permit.
44.12 Complementary Policies
The C&D Waste Management Plan guidelines complement this policy. The generation
of the C&D Waste Management Plan at the project outset identifies the need for a
permit or otherwise. The quantities of waste estimated at the design stage, following
prevention and minimisation measures, feed into the application process for the
waste facility permit. A judgement on whether the site qualifies for a permit is then
made.
Furthermore, the C&D Waste Management Plan provides the necessary framework
required for recording and reporting of data to support the waste facility permit
conformance conditions.
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44.13 Effect of the Policy on Pricing of Resources / Services
The Regulations (1998 Regulations & 2007 Regulations /2008 Amendment
Regulations) encourage waste prevention, minimisation (in order to satisfy tonnage
thresholds) and reuse on site as well as waste recovery. Hence, it is reasonable to
suggest that there is a reduction in the quantities of C&D waste being hauled off site
to landfill facilities. This effect translates to a cost reduction in the waste
management element of a project. In theory, the cost of construction to the client or
public should reduce accordingly, however such is at the discretion of the
construction industry or is dependent on the buoyancy of the construction industry at
the time in question.
44.14 Evasion and Enforcement
The relevant local authority attaches such conditions as are necessary to ensure the
proper enforcement of the waste permit.
Once a waste facility permit is granted, compliance with the relevant legal
requirements are checked and enforced. Checks take place through monitoring,
inspection and auditing and by taking relevant enforcement action where necessary.
The local authorities provide enforcement in accordance with the Environmental
Enforcement Network (EEN) Guidance Manual, launched in 2005. The manual
provides comprehensive guidance on environmental enforcement and in particular it
provides specialist guidance on waste enforcement.
Audit programmes are conducted by the local authorities to verify the data provided
by holders of waste facility permits on waste acceptance, waste recovery and waste
disposal.
44.15 Lessons Learned
The provision of the latest Waste Permit Regulations is based on lessons learned and
experiences gained during the issuing and monitoring of waste permits under the
1998 Regulations. For example, Sub-Committee D of the National Construction and
Demolition Waste Council sought a simplification of the permitting process and a
reduction in the time period needed for determination of applications.
Draft Waste Management Regulations were issued for public consultation with a view
to simplifying and streamlining the existing system and propose a number of
amendments to existing Regulations. The proposals attempted to resolve a number of
issues raised by the construction industry stakeholders and have the objective, where
feasible, of making authorisation applications for reuse and recycling of C&D wasterelated
activities a more attractive proposition for developers.
By means of a discussion with the Irish Waste Management Association (IWMA), a
view was expressed that the draft regulations published for consultation were
significantly different than the final Waste Permit Regulations published. While the
nature of consultation is to gather stakeholder input and reflect it in final publication,
a review of the consultation process and the methods used to keep stakeholders
informed of progress may be beneficial for future regulation amendment.
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45.0 Demolition Protocol - UK
45.1 Outline of Policy
The Institute of Civil Engineers, with support from the Waste and Resources Action
Programme (WRAP), has developed a Demolition Protocol. It provides a framework for
sustainable resource management within the demolition industry (although
refurbishment is also included as part of the Protocol) which can be implemented
through contractual conditions or the planning system. It provides methodologies for
delivery of resource efficiency through a framework ‘for the assessment and recovery
of demolition material and the potential for specifying recovered (recycled and
reclaimed) material in the new build’. 780
In practise, the Demolition Protocol requires the contractor to undertake a demolition
audit prior to demolition occurring which characterises and identifies quantities of
materials being produced through the demolition process, identifies the potential for
resource recovery, set targets for material recovery and verifies the targets are
reached. A similar process of measurement takes place throughout the new build
phase of the project.
The Protocol is currently not made mandatory through a centralised planning
requirement, and so therefore, in-line with this review, it is not considered a policy.
However, to-date there is one example where it was enforced throughout a project,
and due to the general lack of clear policies implemented within the C&D sector, it
was thought beneficial to draw from this example, albeit on a small-scale.
45.2 Where Has the Policy Been Applied and Why?
The London Borough of Brent Council incorporated the Protocol through their
Supplementary Planning Document on Sustainable Design, Construction and
Pollution Control because it ensured that resource efficiency would be prioritised
throughout development. 781 Implementing the Demolition Protocol was, therefore, a
mandatory requirement of the Wembley Link development project.
45.3 Key Organisations Involved in Implementation and
Management
The key organisation is the planning authority that has the power to mandate this
Protocol within planning regulations and drive forward sustainable construction and
demolition. During the project the principal contractor is responsible for both
780 WRAP (2007) ICE Demolition Protocol Case Study Wembley Link, Accessed 21st October 2008,
http://www.wrap.org.uk/downloads/WRAP_Case_Study__Wembley_Link_formatted_2_.e66b89c1.46
51.pdf
781 Sonnervera International Corporation (2006) Construction, Renovation and Demolition Waste
Materials: Opportunities for Waste Reduction and Diversion.
650
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implementing and managing the Protocol, which in the case of the Wembley Link
development, was Edmund Nuttall.
45.4 Pre-implementation / Evaluation Studies Available
This case study is outlined in 2 documents:
651
� WRAP (2007) ICE Demolition Protocol Case Study Wembley Link, Accessed
21 st October 2008, http://www.wrap.org.uk/downloads/WRAP_Case_Study_-
_Wembley_Link_formatted_2_.e66b89c1.4651.pdf
� Sonnervera International Corporation (2006) Construction, Renovation and
Demolition Waste Materials: Opportunities for Waste Reduction and Diversion.
45.5 Environmental Benefits
With regards to waste prevention, implementing the Protocol led to reclamation of
approximately 3,800 tonnes of aggregate material which were reused within other
areas of the project. The WRAP case study estimates that if site and material planning
had been used to its full advantage, 384 lorry journeys could have been prevented.
If materials could not be re-used on site they were sold on to be re-used, e.g. bricks.
Furthermore all wood and metal was site separated and sent to reprocessing
facilities.
Other less quantifiable waste prevention benefits were identified through a predemolition
audit which led to reclamation of mechanical plant, carpet, fixtures, fittings
and traditional bricks. Procurement for construction materials focused on sourcing
recovered materials. This was achieved through setting targets for recycled material
procurement. 782
45.6 Implementation Costs
This section is considered not applicable because at this stage the Demolition
Protocol is not broadly a policy, therefore implementation costs are unknown and are
not detailed in the case study.
45.7 Effects on Technical Change / Innovation
Waste recovery websites were utilised in order to enable others to re-use items that
were being removed from the demolition works. Many of these websites exist but it is
thought to be an immature market and under-used due to lack of awareness that
such a service exists. However, it was successful in finding new users for the air
conditioning units and carpet tiles. The case study also highlights that work was
undertaken to find ‘creative outlets for the materials identified’.
782 WRAP (2007) ICE Demolition Protocol Case Study Wembley Link, Accessed 21st October 2008,
http://www.wrap.org.uk/downloads/WRAP_Case_Study__Wembley_Link_formatted_2_.e66b89c1.46
51.pdf
International Review of Waste Policy: Annexes

Due to the relative small-scale of the implementation of this Protocol this section is
considered not applicable.
45.8 Social and Distributional Consequences
Not applicable
45.9 Complementary Policies
In the UK, landfill tax is a key driver for this policy by increasing disposal costs
therefore encouraging alternative solutions to disposal, such as on-site recovery,
which is central to the Demolition Protocol.
Also, product standards are likely to increase confidence in recycled materials and
encourage more wide-spread on-site re-use and marketing / use of secondary
materials (Section 47.0)
45.10 Effect of the Policy on Pricing of Resources / Services
There are financial benefits to be gained from by re-using aggregate arising from
demolition for new on-site construction. Although cost savings have not been
quantified in the case study, an approximate calculation can be done, taking the
average price for one tonne of aggregate and multiplying this by the 3,800 tonnes of
aggregate re-used in other areas of the development project. This results in a saving
of £59,200. 783 This is a significant saving but without knowing the value of the project
as a whole it is hard to know exactly how significant this saving has been.
45.11 Evasion and Enforcement
No issues were identified in this isolated example.
45.12 Lessons Learned
The Sonnervera International Corporation highlights the following 5 lessons learned
from the implementation of the Protocol for the Wembley development:
652
� Planning authorities have the power needed to enforce this Protocol;
� Enforcing the Protocol across all planning authorities would be more effective
in ensuring a level playing field;
� Stakeholder buy-in (construction and demolition companies and local/national
government) is essential;
� To this end, carrying out a stakeholder consultation would seem appropriate;
and
� Ensure that effective guidance documents are provided.
783 The average price for one tonne of aggregate material was calculated as £15.60. Data was taken
from the Cardigan Sand & Gravel Co Ltd, http://www.cardigansand.co.uk/pricelist.html
29/09/09

46.0 Tax on Aggregates - International
46.1 Outline of Policy
Sand, gravel and rock are commonly known as aggregates and are essential
materials for the construction industry. A tax on aggregates is an example of a natural
resource based tax. It is a market-based instrument with both fiscal and
environmental motivations. Such taxes aim to raise revenue without distorting a
country’s economic activity.
The objectives for introducing a tax on aggregates vary depending upon the country in
which it is being implemented. The policy can have four main effects on aggregates:
653
� Reduce the amount of virgin aggregate material extracted (reduced
consumption leads to less disposal);
� Increase the amount of aggregate re-use;
� Increase the use of substitutes for primary aggregate; and
� Increase the recycling of, and use of, secondary aggregates
A tax on aggregates is a fiscal measure which usually works by shifting the price
differential against virgin, and in favour of secondary aggregates, making it financially
more beneficial to recycle aggregate and use secondary aggregate. The recycled
aggregate is mainly derived as waste from the construction and demolition industry.
46.2 Where Has the Policy Been Applied and Why?
Denmark, Sweden, the UK, Belgium (Flanders) and Italy (at a regional level) have all
implemented a pure aggregate levy. 784 The main policy objectives and the year in
which the policy was introduced are outlined in Table 46-1.
In Denmark, the tax applies to raw materials that are commercially extracted and
consumed in Denmark, or commercially imported. These include sand, gravel, stones,
peat, clay and limestone.
In Sweden, gravel is a very important resource due to necessity for aquifers on which
much of the country relies for drinking water. It was also recognised that gravel is an
easily extractable finite resource. This was leading to a shortage of gravel in some
parts of Sweden. The tax was therefore introduced for environmental reasons and
aimed to make gravel-alternatives more cost-competitive, therefore increasing use of
recycled aggregates, and reducing consumption of gravel.
784 R. Bleischwitz and b. Bahn-Walkowiak (2007) Aggregates and Construction Markets in Europe:
Towards a Sectoral Action Plan on Sustainable Resource Management, Minerals and Energy, Raw
Materials Report, 22:3, 159-176.
International Review of Waste Policy: Annexes

Table 46-1: Main Aggregate Levy Policy Objectives
Name of
Policy
Year Policy
Introduced
Objective 1
Objective 2
654
29/09/09
Denmark Denmark
Sweden Sweden
UK UK
Tax on Waste and
Certain Raw
Materials
The Law Concerning Tax on
Natural Materials
1990 1996 2002
To reduce
resource
extraction
To increase
aggregate
recycling
To safeguard gravel
resources and water quality
To increase material
substitution to crushed rock
and recycled material
Aggregate Levy
To reduce demand for
aggregates and encourage
recycling
To compensate for
environmental externalities
caused by quarry activities
In summary, the levy aims to reflect environmental costs in the price of aggregate
extraction and encourage the use of alternative materials such as recycled aggregate.
Recycled materials (if not commercially extracted again) do not fall under the tax
regime in any country where an aggregate tax has been implemented.
46.2.1 Country-specific Characteristics
46.2.1.1 Material Variations in the Scope of the Levy
Denmark’s ‘Tax on Waste and Certain Raw Materials’ applies to raw materials that
are commercially extracted and consumed in Denmark, or commercially imported.
These include sand, gravel, stones, peat, top soil, clay, chalk and limestone. The
following are described by the ECOTEC report as being exempt from the tax: 785
� Raw materials extracted for coastal projects to protect the beaches against
erosive action;
� Sea bed materials, which originate from maintenance and capital dredging
projects and which are utilised as raw materials;
� Residual products and waste products, which are extracted from already
closed depots;
� Top soil and peat, which are delivered without payment; and
� Raw materials commercially extracted or imported by a business, when the
annual amount is less than 200 m 3 of raw materials.
Sweden’s ‘Tax on Natural Materials’, commonly referred to as ‘Gravel Tax’, applies to
gravel, which consists mainly of sand, gravel, cobble and boulder size fractions.
785 ECOTEC Research and Consulting (2001) Economic and Environmental Implications of the Use of
Environmental Taxes and Charges in the EU and its Member States, Accessed 21 st October 2008,
http://ec.europa.eu/environment/enveco/taxation/pdf/ch11_aggregated_taxes.pdf

The UK’s ‘Aggregate Levy’ applies to aggregate which in the UK is deemed to consist
of sand, gravel and rock, with the following exceptions:
655
� Materials such as clay, slate and shale, which are not strictly aggregates but
which are used for similar purposes;
� Minerals (mainly for industrial use) whose extraction necessarily involves the
extraction of stone, gravel or sand; and
� Coal, metals and peat.
The levy is applied to materials which are:
� Quarried in the UK;
� Mined underground in the UK;
� Dredged from UK waters; or
� Imported into the UK.
46.2.1.2 Variations in the Level of the Tax and the Basis for the Tax
The tax in Denmark is based on volume (m 3) of material extracted and the tax
currently stands at €0.67 per m 3 . The revenue generated goes directly to the State’s
general budget as well as towards subsidy schemes, which support waste-related
initiatives in the fields of waste prevention, recovery and recycling. 786
In Sweden the tax is levied on the basis of weight and the current level of tax is €1.43
per tonne of extracted material. 787
In the UK the aggregate levy is also levied on a weight basis and currently stands at
£1.95 (€2.34) per tonne (increased from £1.60 (€1.92) per tonne in April 2008 to
account for inflation). 788
At the time of introduction of the UK tax, there was some concern regarding imports
and exports between Northern Ireland, which was due to implement the aggregate
levy, and the Republic of Ireland, which was not. The discontinuity across countries
was likely to have a negative impact upon the profitability of the industry in Northern
Ireland relative to those in the Republic. This resulted in Northern Ireland setting up
an aggregate levy tax relief scheme whereby 80% relief from the tax was granted
(meaning the levy costs £0.32 or €0.38) where a business registers with Customs
and Excise (now HM revenue and Customs) and commits to undertaking
environmental improvements on their site 789 .
786 Converted using an exchange rate of €1.2 = £1.
787 Converted using an exchange rate of €1.2 = £1.
788 Converted using an exchange rate of €1.2 = £1.
789 Department of the Environment, Northern Ireland, Aggregates Levy Credit Scheme, Accessed 20 th
January 2009,
http://www.doeni.gov.uk/index/protect_the_environment/local_environmental_issues/aggregates_lev
y_credit_agreement_scheme.htm
International Review of Waste Policy: Annexes

The UK has adopted an approach whereby revenue from the tax is put into an
Aggregate Levy Sustainability Fund (ALSF). This is used to deliver environmental
benefits through awareness raising campaigns and promoting use of recycled
aggregates, demand for which is being increased through development of quality
standards for secondary aggregates (Section 47.0). Revenue is also recycled to
industry through a 0.1% reduction in employer National Insurance Contributions. 790
The level of tax implemented is considerably higher in the UK, as a proportion of
price, than elsewhere. In the UK the tax on aggregates equates to 20% of the average
price for sand, rock and gravel compared to the case of Sweden, where the tax
equates to only 12% of the average price.
The UK recently saw an increase in the rate of the levy, but generally, the level of
aggregate tax has been fairly stable over time. Sweden, however, has introduced
incremental increases in the tax over time.
46.3 Key Organisations Involved in Implementation and
Management
In all three cases, central government is responsible for original implementation,
management and administration of the policy. Specific country details are described
below:
656
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� The Danish Ministry of Taxation designed an amended law in 1992 and is
currently responsible for the implementation and administration of the tax. In
doing so they monitor the levels of extraction taking place;
� The Gävle Tax Authority is responsible for the implementation of the tax in
Sweden; and
� HM Revenue and Customs, the revenue collecting arm of UK Government,
implements and manages the UK aggregate levy.
The systems rely upon commercial extractors being registered with the above
organisations. These companies must account for the amount of raw material they
use in order to calculate the amount of tax they must pay.
46.4 Evaluation Studies Available
This ECOTEC study compares the Danish, Swedish and UK aggregate taxes.
� ECOTEC Research and Consulting (2001) Economic and Environmental
Implications of the Use of Environmental Taxes and Charges in the EU and its
Member States, Accessed 21 st October 2008,
http://ec.europa.eu/environment/enveco/taxation/pdf/ch11_aggregated_tax
es.pdf
790 Defra (2006) Aggregates Levy Sustainability Fund in England 2002-2007, Accessed 20 th January
2009, http://www.defra.gov.uk/environment/waste/aggregates/pdf/agglevy-summary.pdf

The following study is a comparison of aggregates taxes that have been introduced in
the Czech Republic, Italy, Sweden and the UK. 791
� European Environment Agency (2008) Effectiveness of Environmental Taxes
and Charges for Managing Sand, Gravel and Rock Extraction in Selected EU
Countries, Accessed 23 rd October 2008,
http://reports.eea.europa.eu/eea_report_2008_2/en/Effectiveness_of_envir
onmental_taxes_final_low.pdf
Other notable references include:
� R. Bleischwitz & B. Bahn-Walkowiak (2007) Aggregates and Construction
Markets in Europe: Towards a Sectoral Action Plan on Sustainable Resource
Management, Minerals and Energy – Raw Materials Report, 22:3, 159-176.
657
� P. Soderholm (2006) Environmental Taxation in the Natural Resource
Extraction Sector: Is it a Good Idea?, European Environment 16, pp. 232 –
245.
� S. Speck, >. Skou Andersen, H. O. Nielsen, A. Ryelund and C. Smith (2006) The
Use of Economic Instruments in Nordic and Baltic Environmental Policy 2001-
2005, TemaNord 2006:525, Nordic Council of Ministers, Denmark.
� HM Customs & Excise Consultation (1998) Aggregates Levy Regulatory Impact
Assessment, Accessed 16th February 2009,
http://customs.hmrc.gov.uk/channelsPortalWebApp/downloadFile?contentID
=HMCE_CL_001429
46.5 Environmental Benefits
The first main environmental benefit of the policy is shifting the balance between
virgin and recycled aggregate consumption such that an increasing proportion of the
market is accounted for by recycled aggregate. This may reduce energy use and
associated carbon dioxide emissions with primary material extraction. 792
Denmark
In Denmark 90% of demolition waste is recycled but ECOTEC (2001) believe this has
little to do with the tax on aggregates, and that the principle driver is the waste tax.
The tax had little impact on raw material extraction as demonstrated by the continued
demand for raw material, reflecting the low price elasticity of demand for virgin
791 Czech Republic and Italy are not included in this review because these taxes are mining charges,
not aggregate product taxes, and do not impact upon aggregate waste and recycling in any significant
way.
792 European Environment Agency (2008) Effectiveness of Environmental Taxes and Charges for
Managing Sand, Gravel and Rock Extraction in Selected EU Countries, Accessed 23 rd October 2008,
http://reports.eea.europa.eu/eea_report_2008_2/en/Effectiveness_of_environmental_taxes_final_lo
w.pdf
International Review of Waste Policy: Annexes

aggregate (and the fact that the tax accounts for only a small proportion of the
primary aggregates price). 793
Sweden
Sweden has a low recycling rate but this can be explained through reference to the
fact that there is very little demolition taking place, and therefore, less material to
recycle. The main material used for recycling is mining waste. The proportion of
aggregate production from secondary material is 11%. 794 Sweden has seen a shift
away from the use of gravel, but given the range of policies that have been
implemented, it seems unlikely that the relatively small tax on aggregates could be
the main reason for the shift. Sweden does have a substantial tax on waste disposal
by landfill, currently at €47/tonne, which is likely to be influential. A far more detailed
analysis than is available would be required to estimate the proportion of the change
accounted for specifically by the tax on aggregates, compared to the tax on waste
disposal.
UK
The UK has the highest recycling rate for aggregate materials in Europe. They account
for 25% of the UK aggregates market (the largest market share for recycled
aggregates in Europe). 795 The situation here is similar to that of Sweden where
unpicking the direct impact of implementing the tax on aggregate is very difficult
when waste disposal is also taxed, albeit at a lower rate for construction and
demolition wastes than for non-inert fractions.
Evidence suggests, although cannot be conclusive, that the tax on aggregates is
generally a weak policy which strongly relies on the accompanying presence of a
disposal tax as an incentive to recycle. Soderholm (2001) cites Ecotec (2001) who
find that disposal taxes generally provide a much stronger economic incentive than
the tax on aggregates. Recycling would therefore be an expected consequence of
wanting to avoid disposal costs (evidence from Denmark exemplifies this point). In
other words, the shift in the market is likely to be more supply driven than demand
driven, but demand can be strengthened through use of standards and other
demand-side measures, and this may become more necessary as supply increases.
Figure 46-1 shows the percentage of the market accounted for by recycled aggregate
over time, during the introduction of both the landfill tax and the tax on aggregates in
the UK.
793 ECOTEC Research and Consulting (2001) Economic and Environmental Implications of the Use of
Environmental Taxes and Charges in the EU and its Member States, Accessed 21 st October 2008,
http://ec.europa.eu/environment/enveco/taxation/pdf/ch11_aggregated_taxes.pdf
794 D. Legg (2007) Presentation: Evaluation of Aggregate Taxes, European Environment Agency.
795 European Environment Agency (2008) Effectiveness of Environmental Taxes and Charges for
Managing Sand, Gravel and Rock Extraction in Selected EU Countries, Accessed 23 rd October 2008,
http://reports.eea.europa.eu/eea_report_2008_2/en/Effectiveness_of_environmental_taxes_final_lo
w.pdf
658
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The intention to implement a landfill tax was announced in 1994 and this is
seemingly the beginning in a sharp rise in market share of recycled aggregate, before
the introduction in 1996. The impact of the tax on aggregate is less noticeable, but a
slightly sharper increase in recycled aggregate market share can be noticed in line
with the introduction of the tax. Broadly speaking, the impacts that the two taxes have
had on production of recycled aggregate are relative to the level at which the tax has
been set therefore reinforcing the argument that the landfill tax is the driving force
behind increased recycling rates for aggregate.
Figure 46-1: Effects of Landfill Tax and Aggregate Levy Introduction in the UK
£/tonne
659
35
30
25
20
15
10
5
0
Introduction of
landfill tax
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
Year
International Review of Waste Policy: Annexes
Introduction of
tax on aggregate
30
25
20
15
10
5
0
%
Landfill Tax (£/tonne)
Aggregate Tax (£/tonne)
Recycled Aggregates as a % of
the Total Aggregates (%)
Implementation of a tax on aggregate policy as part of a package which includes a
disposal tax is very important, despite the difficulties involved with attributing any
positive outcome to a specific measure. There appear to be no examples where
aggregates tax have been shown, in the literature, to single-handedly impact upon the
recycling rate of C&D waste in a significant manner. This is likely to be a reflection of:
� The low levels at which the tax is set, as a percentage of the product price; and
� Low elasticities where implemented.
In light of this it is possible to see a situation where aggregate tax could be influential,
without an underpinning disposal tax. However, raising the level of aggregate tax
could result in the level of tax being equal to or greater then the value of the product
which policy makers are likely to be tentative about.
Secondly, at the margin, to the extent that primary aggregate consumption is reduced,
the extent of quarrying operations may also be reduced. This implies that the
associated environmental costs are tackled, for example, the effect on local
biodiversity and communities though noise, dust and visual intrusion.

46.6 Implementation Costs
The compliance costs for the UK are estimated in a Regulatory Impact Assessment
which was undertaken prior to implementation of the tax. It divided the costs into
start-up costs and continuing costs as listed below:
660
� Start-up costs include:
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• time to plan and prepare for the new tax
• make changes to administrative and computer systems to account for
the tax;
• staff training; and
• consequential printing costs.
These were thought to range between £750 for small businesses to £50,000 for
large businesses and up to £100,000 for large businesses with multi-site operations.
� Continuing costs include:
• maintaining records for Customs;
• completion of 4 tax returns per year; and
• dealing with visits from Customs officers.
These were estimated to range from £1,500 per annum for small businesses and up
to £10,000 per annum for larger players. 796
The administration cost of the tax varies considerably depending on how it is
implemented. For example, in the UK the administrative cost of the tax on aggregate
costs Customs and Excise €1.5 million per year (0.33% of total revenue raised), and
in Sweden it costs €0.38 (1.7% of total revenue raised) million per year. 797
46.7 Effects on Technical Change / Innovation
A direct result of implementing the policy is improvement of measurements and
monitoring systems regarding primary aggregate extraction because measurement of
extraction is an essential part of the mechanism through which the tax is levied.
The EEA report (2008) describes how in the UK the increasing use of recycled
aggregate material has encouraged aggregate producers and those in the
construction and demolition industry to diversify into the recycling market. In turn this
796 HM Customs & Excise Consultation (1998) Aggregates Levy Regulatory Impact Assessment,
Accessed 16 th February 2009,
http://customs.hmrc.gov.uk/channelsPortalWebApp/downloadFile?contentID=HMCE_CL_001429
797 European Environment Agency (2008) Effectiveness of Environmental Taxes and Charges for
Managing Sand, Gravel and Rock Extraction in Selected EU Countries, Accessed 23 rd October 2008,
http://reports.eea.europa.eu/eea_report_2008_2/en/Effectiveness_of_environmental_taxes_final_lo
w.pdf

has encouraged innovation in recycling techniques, improving the product range of
recycled aggregates.
Each year a fixed sum of £35 million is diverted to the Aggregate Levy Sustainability
Fund (ALSF). This is out of a total revenue of €454, which as reported by the EEA
(2008). The ALSF has, amongst other things, funded research by the Waste and
Resources Action Plan (WRAP), which led to the establishment of an aggregates
forum. Achievements to date are as follows:
661
� improved quality standards for aggregate that is recycled from waste. WRAP
developed the Waste Quality Protocol which has significantly lowered barriers,
such as stigma, attached to using aggregates derived from waste materials
and encouraged the expansion of demand for secondary aggregates and other
substitute recycled materials;
� raising awareness and increasing end user confidence by organising seminars
to encourage local authorities to use recycled aggregate materials in local
infrastructure projects;
� providing cheap access to capital for reprocessing infrastructure to increase
quality of supply of substitute aggregates from recycled materials;
� delivering accessible robust information, e.g. Aggregain web-based information
service (www.aggregain.org.uk ), which has over 260 registered users.
46.8 Social and Distributional Consequences
46.8.1 Social Consequences
Anecdotally, a rise in the cost of aggregate due to a tax could affect first-time buyers
looking to buy new builds, where the increased cost in aggregate is reflected in the
sale price of the property. Those with lower incomes are thought to be far less
affected because they are more likely to be renting property or in social housing.
It is possible that the implementation of the tax could disproportionately affect
smaller companies, which in the worst case could lead to closures. This will result in a
more sparsely populated network of quarries and distributional consequences
relating to the distance from the quarry due to the high transportation costs and
environmental impacts associated with aggregate transportation. 798
In Sweden when the tax was first implemented in 1996 it was kept low so as to
reduce economic pressure on smaller gravel pits. There was initially some concern
that a higher level of tax would cause closure of small pits which contained gravel
reserves that had not been fully exploited. As such the effect of the tax was thought to
provide both and informative and incentive effect. However, in 2003 the tax was
raised in order to further strengthen the incentive for material substitution 799.
798 British Aggregates Association (2002) Briefing Note on the Quarrying Industry and the Aggregates
Levy, Accessed 5 th January 2009, http://www.british-aggregates.co.uk/documentation/doc13.pdf
799 P. Soderholm (2006) Environmental Taxation in the Natural Resource Extraction Sector: Is it is good
idea? European Environment 16, 232 – 245.
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The impact of the tax was unevenly distributed throughout the country. In the South of
the country, where natural gravel is scarce, natural gravel deposits were maintained
therefore the tax achieved its main goal. However, in the North of the country, where
natural gravel is more abundant, costs were greatly increased. The overall effect was
unfair to those in the North and had a distorting effect on the market.
Introduction of a tax must always be preceded by consideration of the elasticity of
demand of the product. Aggregate is usually priced at a low rate, but is an expensive
material to transport over any great distance. The higher the level of tax the greater
the likelihood of material being imported from areas where there is no tax. For
example, in the UK trade distortions between Northern Ireland, where a reduced rate
of the tax on aggregates does apply, and Ireland, where there is no tax on aggregates,
have been identified. Coordination across country boundaries would reduce the risk
of this occurring across country borders. 800 Alternatively, if possible, implementation
of border tax adjustments may be feasible but probably only possible at the border of
the EU.
46.9 Complementary Policies
In general terms the tax on aggregates works in conjunction with varying types of
policy throughout the various stages of aggregate use, beginning with extraction all
the way through to disposal.
662
1. At the aggregate extraction stage permit rules work alongside the tax on
aggregates;
2. At the end-use stage, road building standards and material standards (see
Section 47.0 for aggregate standards) work in conjunction with the tax on
aggregates. Public procurement rules could also influence demand for
secondary materials through specifying their use, or using an evaluation
method for tenders which rewards bidders making use of secondary
aggregates. Finally, it might be possible to incentivise secondary aggregate
use in specific projects (see below), though this would seem to be a less
efficient way of addressing the matter;
3. At the aggregate disposal stage, landfill taxes strengthen the economic
viability of recycling so working to achieve the same goal as the tax on
aggregates. In addition, policies which prevent ‘sham recovery’ of demolition
materials will help improve the prospects for recycling of aggregates.
800 European Environment Agency (2008) Effectiveness of Environmental Taxes and Charges for
Managing Sand, Gravel and Rock Extraction in Selected EU Countries, Accessed 23 rd October 2008,
http://reports.eea.europa.eu/eea_report_2008_2/en/Effectiveness_of_environmental_taxes_final_lo
w.pdf
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46.9.1 Quality Standards
European Standards for Aggregates, which are derived from natural, recycled and
manufactured materials, were introduced in 2004. 801 They facilitate the use of
recycled aggregate by increasing confidence in the quality and consistent nature of
the product. In support of this, WRAP funded a programme of work in the UK which
provides guidance for producers of recycled aggregate. 802
In Sweden the National Roads Administration (NRA) has been raising standards in
road quality since 1994. In order to cope with the frost, thick roads are needed and
crushed rock was found to withstand these conditions far better than gravel. In light
of this, the NRA supported road construction companies that were proposing to use
secondary crushed rock. It is difficult to measure the impact of the NRA’s road
standards compared to the gravel tax since the effect of one could be obscuring the
effects of the other (see Section 47.0 for aggregate standards).
46.9.2 Waste Disposal Tax
In Denmark the raw material tax was implemented in conjunction with a waste
disposal tax, the key aim being that the combination of the taxes would reduce use of
resources and encourage substitution of recycled materials. The effects of the raw
material tax therefore must be considered in conjunction with the waste tax.
In 1996 a fixed charge on excavation and dredging was applied to raw materials. The
revenue from this fund was intended to fund research into alternative construction
materials within the industry – but this has not yet happened.
As previously discussed in Section 46.5, a landfill tax is in place in both Sweden and
the UK which is likely to encourage aggregate recycling at the disposal stage, but
quantifying the direct impact upon aggregate recycling from both taxes is complex. It
is expected though that in both the UK and Sweden landfill tax does work in
conjunction with the tax on aggregates because the landfill tax provides an incentive
to re-use material at the end of life. In light of this, waste from the C&D sector is being
used as an aggregate resource to avoid both landfilling of waste, and the costs of
extracting new material, made higher by the tax on aggregates.
46.9.3 Incentives
The Netherlands Government incentivises the use of secondary aggregate, to
discourage the use of virgin materials, when construction projects for the public
sector are being undertaken. 803
801 WRAP (2008) European Standards for Aggregates (2004), Accessed 23 rd October 2008,
http://www.aggregain.org.uk/quality/aggregates_standards/european.html
802 WRAP (2005) The Quality Protocol for the Production of Aggregates from Inert Waste, Accessed
October 23 rd 2008, http://www.wrap.org.uk/downloads/0083_Quality_Protocol_A4.21d89729.87.pdf
803 AEA Technology (2007) International Approaches to Waste Prevention and Minimisation, Final
Report for Defra (BREW), Accessed 15 th October 2008,
663
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46.10 Effect of the Policy on Pricing of Resources / Services
A tax on aggregates should encourage use of recycled aggregate by shifting demand
in favour of secondary materials, and reducing demand for virgin materials.
Influencing the behaviour of supply and demand relies on the elasticity of demand in
the market. However, the following three points suggest that the supply and demand
may be intrinsically more inelastic due to:
664
1. the lead time required on obtaining new sources of aggregate can be up to 4
years, in which time the price will rapidly rise until availability improves;
2. aggregate suppliers do not account for the rush on material when it does
become available by curbing sales in order to even out demand; and
3. the aggregate production sector will be greatly influenced by a recession due
to their close ties with the housing and construction industry. 804
The extent to which the tax has the ability to change the pricing structure between
virgin and secondary material depends upon the level at which they are set. In
principle, the efficient tax rate is that which internalises the externalities associated
with primary aggregates extraction. However, from the perspective of economic
efficiency, externalities associated with secondary aggregates preparation should also
be taxed.
Notwithstanding the theoretical principles, few countries have sought to set the level
of taxes on aggregates through reference to some measurement of the externalities
associated with aggregates extraction. The UK provides an exception, the level of the
tax being based upon a study that estimated the total external costs of aggregate
extraction as €380 million per year which is comparable to the current levels of
revenue from the tax of €428. 805
46.11 Enforcement
As a tax or levy, the enforcement is undertaken by central government departments
and lack of compliance can result in court action. The enforcement procedure for the
UK includes initial auditing to identify potential businesses which may not be
complying, and as such, their audit frequency greatly increases. Following this, failure
to comply can lead to financial penalties which include:
� if one fails to register at the correct time they may be liable to a £250 penalty
or 5% of the levy involved, whichever is greater;
http://www.crwplatform.co.uk/conwaste/assets/Publications/2006-7-Reports/International-
Approaches-to-Waste-Prevention-and-Minimisation.pdf
804 R. Bleischwitz and B. Bahn-Walkowiak (2006) Sustainable Development in the European
Aggregates Industry, Wuppertal Institute for Climate, Environment and Energy, Accessed 20 th January
2009, http://web.fu-berlin.de/ffu/akumwelt/bc2006/papers/Bleischwitz_Bahn-W_Aggregates.pdf
805 Converted using an exchange rate of €1.2 = £1.
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665
� if one fails to deregister, comply with regulations, produce records and
information, or render returns or full payment on time they may be subject to a
£250 penalty;
� if one is a non-resident tax payer and fails to obtain Customs’ approval to
appoint a tax representative they may be subject to a £10,000 penalty;
� if discovered that one had under-declared or over-claimed credit on the return
they may be liable to pay a penalty equal to 5% of the amount of levy underdeclared
or over-declared;
� if one is an unregistered customer and a genuine error resulting in an under
declaration by the registered supplier results, one may be liable to a penalty of
105% of the value of the levy; or
� if one evades the levy, one takes or omit to take any action, and the conduct
involves dishonesty, one will render themselves liable to a penalty equal to the
amount of levy evaded or sought to be evaded plus the actual amount of levy
evaded’. 806
In Denmark possible sanctions are fines and ultimately withdrawal of registration
which would result in immediate termination of trading rights. It is also thought that
the success of the system is due to an element of self-discipline where those who are
found to have evaded the policy are considered negatively by the general public. 807
46.12 Lessons Learned
When designing the policy, consideration has to be given as to the price differential to
be established. Few countries have based this on environmental damages, though
such an assessment is less than straightforward where aggregates are concerned. 808
In the Czech Republic (where the tax was not introduced with respect to waste) the
tax on aggregates was introduced at a low level creating very little price differential
between virgin and recycled aggregate. As a result, as might have been anticipated,
there has been very limited impact upon behaviour, and hence, recycling rates. 809
806 Sonnevera International Corporation (2006) Construction, Renovation and Demolition Waste
Materials: Opportunities for Waste Reduction and Diversion,
http://environment.gov.ab.ca/info/library/7703.pdf
807 Danish Environmental Protection Agency (1999) Economic Instruments in Environmental Protection
in Denmark.
808 The experience of the UK in this context was that a contingent valuation study was undertaken
which was re-done, and then criticised by some well known environmental economists for failing to
understand, for example, the difference between marginal and total impacts. It can be argued that the
impact of reducing aggregates extraction are, at the margin, likely to be rather small because much of
the externality caused is associated with the disamenity of ‘the quarry’ rather than the impact of the
marginal tonne.
809 European Environment Agency (2008) Effectiveness of Environmental Taxes and Charges for
Managing Sand, Gravel and Rock Extraction in Selected EU Countries, Accessed 23 rd October 2008,
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A lesson from the case in Ireland (as explained in Section 46.2.1.2) is that a tax must
be considered in respect of bordering countries in order to avoid illegal trade in
aggregate materials.
46.13 Prerequisites for Introduction
The Danish Ministry of Taxation were monitoring levels of raw material extraction prior
to the implementation of the tax. This is not a pre-requisite as such, but if such a
system were in place already, then implementation of the tax would be a more
straight-forward process. In addition, a meaningful assessment of the policy’s impact
is made much more straightforward (arguably without this, evaluation is not possible).
666
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47.0 Product Standards for Aggregates -
International
47.1 Outline of Policy
Product standards ensure that recycled materials meet minimum quality
requirements. For aggregates these requirements are in relation to environmental
and engineering safety standards. The introduction of product standards increases
confidence in secondary materials through certification of the recycled product. It is
more common for non-legislative standards to have been introduced. However,
several examples are given where standards have been mandated at either a
national or regional level.
47.2 Where Has the Policy Been Applied and Why?
In 1998 Mandate 125 introduced European standards for aggregates related to their
end-uses, under the Construction Products Directive (89/106/EEC). This meant that
aggregate types were assigned a standard reference.
Following this European Standards for Aggregates were introduced in 2004. They
include a grading classification system and categories which are used to describe
performance. They are applicable to natural, recycled and manufactured aggregate.
The system involves use of a CE marking system, which is an easily recognisable
symbol of quality. Although this legislation is in place and is valid across all EU
countries, it is not mandatory is most countries. However, voluntary use of the system
could be beneficial to secondary aggregate markets. 810
The following countries have mandated standards for aggregate using the European
Standards for Aggregates framework, and the CE marking:
667
� Austria;
� Belgium (Wallonia);
� Czech Republic;
� France;
� Italy;
� The Netherlands;
� Poland;
� Slovakia; and
810 WRAP (2004) European Standards for Aggregates, Accessed 21 st January 2009,
http://www.aggregain.org.uk/quality/aggregates_standards/european.html
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668
� Spain. 811
Voluntary standards apply across many countries, including:
� Australia, where the Department of the Environment and Heritage have
developed a recycling guide for aggregates in partnership with several
stakeholder groups. As a result of this publication state governments have
produced similar guides.
� Belgium (Flanders) for recycled aggregates;
� Denmark, where the Danish Society of Civil Engineers has set up a standard
for the use of crushed concrete and stones as an aggregate material in new
concrete;
� Germany, for recycled materials as aggregates in concrete, recycled aggregate
and recycled soil; development of ‘RAW’ standards
� Sweden, where the National Roads Administration (NRA) has been raising
standards in road quality since 1994. In order to cope with the frost, thick
roads are needed and crushed rock was found to withstand these conditions
far better than gravel. In light of this, the NRA supported road construction
companies that were proposing to use secondary crushed rock;
� UK, where a Quality Protocol for Aggregates has been developed by WRAP in
partnership with the Quarry Products Association, the Highways Agency and
the Environment Agency.
47.2.1 Country-specific Characteristics
There is a lack of evaluation studies and reviews regarding this policy. The majority of
information throughout this report therefore either relates specifically to the
Netherlands, or to the European standards in general. Additional information is added
where possible.
The Netherlands
The Dutch Building Material Decree came into effect in 1999. It was introduced to
overcome barriers to reusing waste materials in construction. At the time there was
concern with regards to the impact of primary and secondary building materials upon
soil and surface water.
It applies to stony materials and earth in construction and aims to:
� restrict pollution of soil and surface waters due to leaching; and
� reduce the use of primary raw materials. 812
811 Union Europeenne des Producteurs de Granulats (UEPG) (2005) UEPG Statement on CE Marking
and European Aggregates Standards, Accessed 20 th January 2009,
http://www.asfaltskolan.se/metoddag_05/MET05pdf/UEPG%20Statement%20on%20ce%20Marking
%20and%20European%20Aggregates%20Standards-%20February%202005.pdf
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It lays down regulations and standards, applicable to primary and secondary
materials, which ensure quality standards are met. The final products are certified in
order to provide increased levels of confidence in the recycled materials.
Belgium and the Czech Republic
In Belgium and the Czech Republic introduction of the standards has been specifically
in relation to aggregate standards for road construction only.
UK
As an example of voluntary implementation of aggregate standards, in the UK those
waste re-processing facilities accepting recycled aggregate and wishing to abide by
the standards are key to the process implementation. Testing of the material must be
undertaken and records of the output kept. Upon delivery of the aggregate, a quality
statement will state that the product conforms to the protocol and if required
evidence including test results, test procedures and outline details of the factory
production control manual should be supplied.
47.3 Key Organisations Involved in Implementation and
Management
The Netherlands
Those involved in the construction process will all have to be aware, and abide by, the
material standards set in the Building Materials Decree. This includes contractors,
individuals, manufacturers and suppliers of building materials and laboratories
employed to test the material quality.
UK
As a voluntary measure in the UK WRAP and the QPA have been central to driving
forward the implementation of aggregate standards within industry. This has involved
awareness raising through production of documentation available on their websites,
including checklists for producers and purchasers. WRAP have run several free ‘Good
Practice’ workshops for producers and purchasers in order to provide advice and
training.
Producers of recycled aggregate are responsible for implementation of the quality
standard within their facility. Awareness amongst purchasers is also important,
especially where standards are voluntary.
47.4 Pre-implementation / Evaluation Studies Available
The following study highlights the pre-implementation discussions regarding the likely
impact of the policy. There was concern that due to the blanket application of
standards that were applicable to primary and secondary materials, the use of
812 Netherlands Ministry of Housing, Spatial Planning and the Environment (1999) Building Materials
Decree Text and Explanatory Notes, Accessed 22 nd January 2009,
http://www.sharedspaces.nl/docs/internationaal/BMDtexts.pdf
669
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secondary materials may suffer in the short-term. This line of thinking was attributed
to the ease at which the different sources of aggregate would reach the required
standards, assuming it would be more straightforward for primary aggregate.
670
� OECD & Dutch Working Party on National Environmental Policy (2002) Case
Studies on Policy Instruments for Environmentally Sustainable Buildings,
www.olis.oecd.org/olis/2001doc.nsf/LinkTo/NT00000C46/$FILE/JT0012820
2.PDF Accessed 21st January 2009.
� S. Böhmer, G. Moser, C. Neubauer, M. Peltoniemi, E. Schachermayer, M.
Tesar, B. Walter & B. Winter (2008) Aggregates Case Study, Report to the
Institute for Prospective Technological Studies (part of the European
Commission’s Joint Research Centre).
The Quarry Products Association, WRAP and the Highways Agency have been at the
centre of the development of the voluntary standards in the UK. The following reports
and websites highlight these key sources:
� WRAP (2004) European Standards for Aggregates, Accessed 21st January
2009,
http://www.aggregain.org.uk/quality/aggregates_standards/european.html
� WRAP’s Aggregate Programme website,
http://www.aggregain.org.uk/wrap_aggregates/index.html, accessed 16 th
February 2009.
� QPA’s website, http://www.qpa.org/prod_agg01.htm, accessed 16 th February
2009.
47.5 Environmental Benefits
Creating standards for aggregates aims to ensure that recycled aggregate can be
competitive with primary aggregate. Certification aims to break down negative
perceptions regarding the standard of recycled aggregate. An increased market share
of recycled aggregate means the demand for aggregate recycling increases, which
results in less going to final disposal facilities. Also, the harmful effects of
transportation may be reduced where recycled aggregate is consumed within the
locality of where it is produced. As shown in Section 46.0, the supply of material may
be expected to grow in the wake of combined aggregate tax/disposal tax policies.
All of the countries listed with mandatory aggregate product standards have disposal
taxes or bans in place. It is thought that the importance of product standards may be
more prominent in their effect if introduced to countries without such taxes in place.
European Standards
Application of one standard to aggregates, irrespective of their source, enables
secondary aggregate to compete to higher grade applications, which in turn is likely to
increase their market share.
The Netherlands
The Netherlands has achieved diversion rates of more than 95% of C&D waste from
landfill and final disposal. However, despite the introduction of quality standards it
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has been recognised that recycled or reused aggregate is often used in low grade
applications as a result of poor sorting. 813
47.6 Implementation Costs
The review undertaken by the Dutch Working Party on National Environmental Policy
was unable to identify exact administrative costs of implementation of the policy.
However, it was recognised that cost was likely to be more significant at the beginning
of the supply chain. The policy requires proof of quality to be submitted to local
authorities by owners of the project which should be provided to them by the
contractor, who in turn should receive them from the manufacturer.
47.7 Effects on Technical Change / Innovation
The introduction of quality standards for recycled aggregate is a relatively new
initiative, and as shown above, has infrequently been implemented as a policy. It has
become feasible to introduce this as a policy due to the advanced aggregate testing
technologies that have been developed, e.g. laboratory testing to assess the size and
shape of aggregate particles. 814
It is thought that the development of such standards is an innovative approach which
can be complementary to, as well as offering a (weaker) alternative to, more
established policies such as waste disposal taxes, aggregate taxes, and bans. 815
47.8 Social and Distributional Consequences
The main aim of the introduction of aggregate standards is to reduce stigma attached
to the recycled product, therefore encourage increased use. In principle, this should
take place at the expense of primary aggregates, so that the primary industry would
be expected to be affected if the policy is successful.
Reports reviewed have not highlighted any specific distributional issues as a direct
result of the policy (and the differing implementation).
47.9 Complementary Policies
Aggregate quality standards are considered to be at the end of a chain of policies
effective within the C&D sector. They work to increase confidence in aggregates
813 AEA Technology (2007) International Approaches to Waste Prevention and Minimisation, Final
Report for Defra (BREW), Accessed 15th October 2008,
http://www.crwplatform.co.uk/conwaste/assets/Publications/2006-7-Reports/International-
Approaches-to-Waste-Prevention-and-Minimisation.pdf
814 B. Schouenborg and A. Akesson (2004) Aggregate Research in Support of European Standardisation,
Accessed 21 st January 2009,
http://www.springerlink.com/content/2ul0qchmepkkbffh/fulltext.pdf?page=1
815 OECD & Dutch Working Party on National Environmental Policy (2002) Case Studies on Policy Instruments for
Environmentally Sustainable Buildings, Accessed 21 st January 2009,
http://www.olis.oecd.org/olis/2001doc.nsf/LinkTo/NT00000C46/$FILE/JT00128202.PDF
671
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derived from waste materials and aim to encourage the demand for secondary
aggregates. This alone would be unlikely to be effective at increasing the market
share of recycled aggregate, and strongly relies on fiscal measures such as the
landfill tax and tax on aggregates, in order to have an impact through encouraging the
supply of the material and demand for it.
47.10 Effect of the Policy on Pricing of Resources / Services
Due to a lack of evidence this can only be answered speculatively. It is thought that
ensuring standards are the same across all types of aggregates will encourage a shift
towards greater use of recycled aggregate. This is because the price which recycled
aggregate can attract in the market will no longer be so heavily discounted relative to
primary material (since it would be considered as being of an equivalent standard to
primary aggregate). This economic assessment makes the assumption that the social
stigma associated with recycled aggregate is removed by introduction of the product
standard.
47.11 Evasion and Enforcement
At this relatively early stage implementing product standards as a policy there is very
little information regarding enforcement, and any potential action that may be taken if
non-compliance is detected. It is only known that, as is the case in the Netherlands, it
is most likely to be local authorities who are responsible for enforcement of the
standards.
47.12 Lessons Learned
Going forward, the International Recycling Federation is striving towards harmonising
quality standards for recycled materials. There are varying levels of implementation of
product standards throughout the countries mentioned, many of which are purely
voluntary initiatives. However, there seems to considerable support from industry
which ought to help to drive forward the standards onto a firmer, statutory footing.
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48.0 Minimum Recycling Standards
(Construction and Demolition Waste) - International
48.1 Outline of Policy
A number of countries currently employ a minimum recycling standards policy for
householders, commerce and industry, and construction and demolition wastes. This
section presents those minimum standards for the construction and demolition (C&D)
waste stream. These policies require the separate collection of a number of waste
materials, with the key goals of diverting waste away from landfill and increasing
material recovery.
As noted in Annex 1.0, the revised Waste Framework Directive now requires C&D
waste to meet 70% recycling targets:
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2. In order to comply with the objectives of this Directive, and to move towards
a European recycling society with a high level of resource efficiency, Member
States shall take the necessary measures designed to achieve the following
targets:
a) by 2020 the preparing for re-use and the recycling of waste materials such as at
least paper, metal, plastic and glass from households and possibly from other
origins as far as these waste streams are similar to waste from households,
shall be increased to a minimum of overall 50% by weight;
b) by 2020 the preparing for re-use, recycling and other material recovery,
including backfilling operations using waste to substitute other materials, of
non-hazardous construction and demolition waste excluding naturally occurring
material defined in category 17 05 04 in the European Waste Catalogue (EWC)
shall be increased to a minimum of 70% by weight.
The use of minimum recycling standards is generally designed to improve resource
recovery from the C&D sector and to reduce waste sent to landfill.
48.2 Where Has the Policy Been Applied and Why?
The countries that currently use a mandatory minimum recycling standard for the
C&D sector include Austria, Belgium, Denmark, Finland, Germany, Slovenia, the
Netherlands, USA and Japan. A minimum recycling standard for C&D has been
implemented in these countries in order to push waste up the hierarchy away from
landfill, and to increase the recovery of materials and hence reduce the need for
primary material consumption.
The main country-specific policy details are discussed below.
International Review of Waste Policy: Annexes

48.2.1 Austria
Under the Ordinance on the Separation of Materials Accumulated during Construction
Work (Federal Law Gazette no. 259/1991), C&D companies are obliged to separate
their waste into groups of materials (mineral construction waste, excavated soil,
concrete waste, broken asphalt, wood, metal and plastic waste, as well as
construction site waste) if they exceed certain threshold levels as shown in Table
48-1.
Table 48-1: Threshold Quantities for Mandatory Separation & Recovery in Austria
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Waste Waste Waste Fraction Fraction
Threshold Threshold Quantities Quantities (tonnes)
(tonnes)
Waste of mineral origin 40
Excavated soil 20
Waste concrete 20
Non separated C&D
waste
Road construction waste 5
Waste wood 5
Plastic waste 2
Scrap metal 2
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10
Source: C. Pladerer (2006) ‘Towards Sustainable Plastic Construction and Demolition Waste
Management in Europe’ Initiatives for a Sustainable Plastic C&D Waste Management in Europe; The
Case of Austria, Presentation by the Okologie Institut for the European Workshop – Brussels, 24 th April
2006.
48.2.2 Germany
The Ordinance on the Management of Municipal Wastes of Commercial Origin and
Certain Construction and Demolition Wastes (Commercial Wastes Ordinance) came in
effect from 1 st January 2003. This stipulated the separate collection of C&D waste
where the waste had been produced separately for the following materials:
� glass;
� plastic;
� metals; and
� concrete.

Companies are obliged to either separate their own waste and have it collected or
commit their waste to special commercial waste sorting facilities. 816 Where on-site
separation is not possible, due to technical or economical constraints, mixed site
waste consisting of wood, glass, plastic, metal, concrete, bricks, tiles and ceramics
must be sent to pre-treatment facilities which have a recovery rate of at least 85%.
Other mixed waste must also be sent to a pre-treatment facility but a recovery rate is
not stipulated.
48.2.3 California, USA
The California Integrated Waste Management Board (CIWMB) encourages cities to
adopt a C&D Materials Recycling Ordinance and as a result there are many cities that
have mandated this. An ordinance requires that at least 50% C&D material generated
from a project is reused or recycled, and at least 75% inert material is diverted from
landfill.
The system requires a permit to be applied for, a non-refundable administration fee to
be paid, and a deposit, or bond, to be paid for performance security which is refunded
if the minimum recycling requirements of the Ordinance are met. A reporting system
is in place so that checks can be carried out after project completion. The
administration fee is based on 0.3% of the project value and the performance security
fee is between 1.5-2% of the project value.
Implementation throughout California varies slightly by country, but the mechanism is
broadly the same. Different authorities have different criteria for the projects which
must comply. The City of Concord, California, is an example of where this policy
mechanism uses project value. Projects which must comply with the Ordinance are:
675
1. a residential or commercial project worth $50,000 or more;
2. a city-owned or sponsored project worth $150,000 or more; and
3. a residential or commercial roofing/re-roofing project worth $10,000 or
more. 817
(a more complete list of Californian Ordinances can be found on the CIWMB
website). 818
Alternatively authorities can use size of the project, as the City of Menlo Park,
California has done, where projects of the following sizes must comply with the
Ordinance:
816 Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (2002) Ordinance on
the Management of Municipal Wastes of Commercial Origin and Certain Construction and Demolition
Wastes (Commercials Wastes Ordinance-CWO), Accessed 30 th October 2008,
http://www.bmu.de/files/pdfs/allgemein/application/pdf/gewerbeabfallv_engl.pdf
817 City of Concord (2008) Accessed 24 th October 2008,
http://www.cityofconcord.org/living/recycle/cdordinance.htm
818 California Integrated Waste Management Board (2008) Accessed 24 th October 2008,
http://www.ciwmb.ca.gov/ConDemo/SampleDocs/
International Review of Waste Policy: Annexes

676
1. for residential construction and demolition, projects that are 1,000 square
feet or greater; or
2. for commercial construction and demolition, projects that are 5,000 square
feet or greater. 819
Several cities in California have adopted mandatory recycling ordinances with a
refunded compliance bond based approach which provides an incentive to
successfully reach the targets. In places where recycling mandates apply it is normal
for a permit scheme to be in place – permits must be obtained in order to undertake
the construction/demolition project. Where the refunded compliance bond scheme is
also applied, the bond is paid when the permit is received, and returned, when proof
of meeting the mandated recycling standards is received, by the enforcement body.
The size of the bond required is calculated in various ways but is usually relative to
the size of the construction/demolition project. The following examples from San
Diego, San Jose and San Francisco illustrate this policy mechanism.
48.2.4 San Diego, California, USA
The requirements for recycling and disposal of construction and demolition debris
were introduced in San Diego in July 2008. The size of the project relates to the size
of the bond required as shown in Table 48-2.
Certified Recycling Facilities must be allocated to a project via documentation known
as the ‘Waste Management Form I’ which must be submitted to San Diego’s
Environmental Services Department along with the required bond. The overall
recycling rate was set at 50% for the first six months, after which time it will be
increased to 75%. However, this does include a 90% recycling requirement specific to
inert waste. Recycling, reuse and disposal receipts need to be submitted in order to
retrieve the bond alongside a ‘Waste Management Form II’. 820
819 City of Menlo Park (2008) Construction and Demolition Debris Recycling and Salvage
Requirements, Accessed 24 th October 2008,
http://www.menlopark.org/departments/bld/condemor.pdf
820 The City of San Diego Environmental Services Department (2008) Requirements for Recycling and
Disposal of Construction and Demolition Debris Information Bulletin 119, Accessed 16 th January 2009,
http://www.sandiego.gov/development-services/industry/pdf/infobulletin/ib119.pdf
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Table 48-2: Construction and Demolition Debris Recycling Deposits / Bonds
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International Review of Waste Policy: Annexes
Deposit/Sq.
Deposit/Sq.
Ft.
Ft.
Mi Minimum Mi
nimum nimum
Sq.Ft.
Sq.Ft.
Maximum
Maximum
Sq.Ft.
Sq.Ft.
Subject Subject to to
to
Deposit Deposit
Deposit
Residential new construction – detached $0.40 500 125,000
Residential new construction - attached $0.40 500 100,000
Non-residential new construction –
commercial
$0.20 1,000 25,000
Non-residential new construction –industrial $0.20 1,000 75,000
Non-residential alterations $0.70 286 No
maximum
Residential demolition $0.70 286 No
maximum
Non-residential demolition $0.20 1,000 No
maximum
Flat Rate
Range Range of of
of
Depos Deposits Depos ts
(bonds)
(bonds)
$200 -
$50,000
$200 -
$40,000
$200 -
$5,00
$200 -
$15,000
$200 and
up
$200 and
up
$200 and
up
Roof project with tear-off -- -- $200
Residential alterations -- -- $1,000
Source: City of San Diego Development Services, Information Bulletin 119 August 2008, Requirements
for Recycling and Disposal of Construction and Demolition Debris,
http://www.sandiego.gov/development-services/industry/pdf/infobulletin/ib119.pdf
48.2.5 San Francisco, California, USA
San Francisco’s recycling mandate applies only to mixed construction and demolition
waste in order to ensure it gets processed and diverted from landfill as efficiently as
possible. This requires the contractor to have the mixed waste removed from the site
by a Registered Transporter who must deliver the waste to a Registered Facility. A
Registered Facility must be capable of recycling 65% of mixed C&D waste. Receipt of

proof from the Registered Facility that a minimum of 65% of the waste has been
recycled enables the contractor to receive their bond back. 821
48.2.6 City of San Jose, California, USA
San Jose introduced its Construction and Demolition Diversion Deposit (CDDD)
Program in 2001. Projects being undertaken for the city authority and private new
construction, alteration and demolition projects all require a permit. Contractors
running these projects must also pay a deposit which is calculated according to
project size and value. Private permitted projects must comply with 50% recycling
requirements and city authority projects must meet a 75% target in order to receive
their deposit back. Projects that do not require a permit and deposit must still comply
with recycling reporting requirements. Processing facilities receiving C&D waste must
be certified and those receiving source separated recyclate must have a proven
recycling rate of 90% or more. 822
48.2.7 City of Portland, USA
The City of Portland’s Office for Sustainable Development (OSD) implemented
minimum recycling standards for construction and demolition projects which were
effective from 14 th November 2008. Where a construction or demolition project is
valued at $50,000 or more the project contractor is required to recycle at least 75%
of the total waste materials produced on site. However, the following materials must
all be recycled:
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� wood;
� corrugated cardboard;
� metal;
� rubble; and
� land clearing debris.
Containers must be made available to assist with separate collection of the above
materials.
As part of the policy, contractors must complete Recycling Plan Forms on which the
materials to be recycled must be identified, and the collector for each material. These
are returned to the OSD.
821 City and County of San Francisco (2006) Construction and Demolition Debris Recovery Program
Ordinance No.27-06, Accessed 16 th January 2009,
http://sfenvironment.org/downloads/library/canddinformation.pdf
822 Gruzen Samton LLP with City Green Inc. (2003) Construction and Demolition Waste Manual,
prepared for New York City Department of Design and Construction, Accessed 19 th January 2009,
http://www.nyc.gov/html/ddc/downloads/pdf/waste.pdf

Construction and demolition projects worth less than $50,000 are asked to
voluntarily commit to recycle the maximum amount possible from the site. 823
48.2.8 Chicago, USA
A construction and demolition recycling requirement was introduced to the City of
Chicago in 2004 which required 25% of construction and demolition debris produced
on site (as measured by weight) to be recycled. In 2007 the requirement was
increased to 50%. 824 Projects must adhere to 50% recycling if they are:
679
� residential projects of four or more units; or
� a construction project which requires a certificate of occupancy to issue
from the department of buildings; or
� any demolition project costing over $10,000.
Construction debris, as defined in the requirement, includes the following materials:
� bricks, concrete, and other masonry materials;
� rock;
� wood, including non-hazardous painted, treated and coated wood;
� scrap metal;
� plaster;
� gypsum drywall;
� plumbing fixtures and piping;
� non-asbestos insulation;
� roofing shingles and other roof coverings;
� reclaimed asphalt pavement;
� glass;
� plastics; and
� landscape waste.
48.2.9 Ontario, Canada
Source separation for C&D projects greater than 2,000 square metres is obligatory
under Ontario’s Regulation 103/94, which is an associated regulation of the
823 City of Portland Office of Sustainable Development (2008) Administrative Rules Commercial Solid
Waste, Recycling and Compostables, Accessed 15 th January 2008,
http://www.portlandonline.com/osd/index.cfm?a=218220&c=41472
824 City of Chicago, Ordinance 11-4-1905 Construction or Demolition Site Waste Recycling, Accessed
16 th January 2008,
http://egov.cityofchicago.org/city/webportal/portalContentItemAction.do?contentOID=536932617&co
ntenTypeName=COC_EDITORIAL&topChannelName=HomePage
International Review of Waste Policy: Annexes

Environmental Protection Action (1990). Mandatory separation is required for brick
and concrete, steel and wood. 825
48.2.10 Alberta, Canada
The Alberta government in Canada are currently out to consultation on a similar
scheme and aim to have mandatory recycling for the construction industry by 2010,
backed with the use of a refunded compliance bond system. A preliminary agreement
has been made between the Government of Alberta, the Alberta Construction
Association and the Canadian Home Builders’ Association-Alberta. 826
48.2.11 Japan
Under the Construction Material Waste Recycling Law, which came into effect in
2000, contractors must be responsible for source separation and recycling. Due to
the small size of an average property in Japan to which the Recycling Law does apply,
the regulations imply that almost all demolition projects must source separate
wastes. The Law is applied to:
680
1. demolition projects equal to or greater than 80 square metres;
2. construction/extension projects of at least 80 square metres;
3. renovation projects of at least $870,000; and
4. construction or demolition projects for other than buildings at least
$43,000. 827
In 2001 the Law was updated in order to stipulate a 95% recycling rate for specified
construction materials to be achieved by 2010. Government projects were expected
to be producing zero waste by 2005. 828
48.2.12 Other Countries
It is known that the following countries have minimum recycling standards in place,
but little detail has been identified about each policy.
825 Ontario Ministry of the Environment (2007) A Guide to Source Separation of Recycling Materials for
Industrial, Commercial and Industrial Sectors and Multi-Unit Residential Buildings As Required Under
Ontario Regulation 103/94, Accessed 24 th October 2008,
http://www.ene.gov.on.ca/publications/2478e01.pdf
826 Government of Alberta (2008) Landmark Agreement Means Less Construction Waste in Landfills,
News Release 23 rd October 2008, Accessed 16 th January 2009,
http://www.alberta.ca/acn/200810/246242B8DDAEB-C525-C785-A11A71CAA4E916AE.html
827 R. Tanaka (2007) Waste Reduction in Japan, Science and Innovation Section, British Embassy
Tokyo, Accessed 30 th October 2008, https://ukinjapanstage.fco.gov.uk/resources/en/pdf/5606907/5633507/071030WasteReduction.pdf
828 Government of Japan’s Ministry of Environment (2001) Construction Material Recycling Law,
Accessed 16 th January 2009, http://www.env.go.jp/en/laws/recycle/09.pdf
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Belgium
Following Article 16 in Chapter 4 of the Belgian Decree concerning Prevention and
Management of Waste Materials, there must be separate collection of C&D waste.
Denmark
The separation of C&D waste into clean fractions has been mandatory in Denmark
since 1997. This applies to sites where more than 1 tonne of waste is being
produced.
Finland
The separate collection of materials from the C&D waste stream is specified in decree
295/1997. C&D waste in Finland must be separated into four categories:
681
1. concrete, brick, ceramic and gypsum;
2. non-impregnated wood wastes;
3. metal wastes; and
4. soil, rocks and dredging wastes. 829
Slovenia
Under its Environmental Protection Act (2001), Slovenia requires separate collection
of C&D wastes. 830
48.3 Key Organisations Involved in Implementation and
Management
C&D separate collections are predominantly privately co-ordinated and funded, with
the C&D companies taking responsibility for source-separation to attain their recycling
rates.
Where refunded compliance bond schemes are in place, the administration required
is somewhat more complex than were basic requirements to sort are in place. 831 In
order to implement this policy the key organisation will be the permitting authority.
They will be responsible for the following:
� administration of certification of waste transporters and recycling facilities.
It is fundamental that these services must be accredited in some way in order
829 Ministry of the Environment, Finland (2000) Environmental Protection Act (86/2000), Accessed
20 th January, http://www.environment.fi/default.asp?node=17869&lan=en#a0.
830 Government of the Republic of Slovenia (2004) Environment Protection Act (ZVO-1) SOP-2004-01-
1694, Accessed 20 th January 2009,
http://www.mop.gov.si/fileadmin/mop.gov.si/pageuploads/zakonodaja/okolje/en/zvo_s.pdf
831 Actually, checking that all companies do what they say they will is not straightforward. Indeed, the
refunded compliance bond approach effectively makes it possible to track C&D waste more effectively,
whilst also allowing for a more direct check over companies’ activities.
International Review of Waste Policy: Annexes

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to ensure that the mechanism for checking waste works efficiently, i.e. that
paperwork received can be used as proof of recycling;
� sending out permit application forms and the administration involved with
receipt of completed permit application forms;
� receiving the administration fee;
� receiving, and holding, the deposit;
� send out permits to allow work to commence; and
� implementation of a checking mechanism to decide if the deposit can be
returned, or not.
48.4 Pre-implementation / Evaluation Studies Available
� Federal Ministry of Agriculture and Forestry, Environment and Water
Management, 2006, Federal Waste Management Plan 2006: Suitable for
Nature and Mankind. Available at:
http://www.bundesabfallwirtschaftsplan.at/Austria
� R. Tanaka (2007) Waste Reduction in Japan, Science and Innovation
Section, British Embassy Tokyo, Accessed 30 th October 2008,
https://ukinjapanstage.fco.gov.uk/resources/en/pdf/5606907/5633507/071030WasteReduc
tion.pdf
� Gruzen Samton LLP with City Green Inc. (2003) Construction and
Demolition Waste Manual, prepared for New York City Department of Design
and Construction, Accessed 19 th January 2009,
http://www.nyc.gov/html/ddc/downloads/pdf/waste.pdf
There is an overall lack of evaluation studies with regards to this policy in the
construction and demolition context. The majority of resources were located on
individual city, county or country websites which lay down the specifications of the
policy but do not generally make comparisons to other similar policies, or evaluate
their own.
48.5 Environmental Benefits
The main environmental benefits from the mandatory requirement for separate
collection and subsequent recovery of C&D waste materials are:
� the recovery of homogenous building materials for use as secondary raw
materials and/or fill materials, typically at lower cost than if primary material
was used;
� the diversion of waste away from landfill (thereby reducing the utilisation of
landfill volumes and saving companies costs associated with sending waste to
landfill);
� the saving of primary materials, thereby protecting the landscape by removing
less material and improving groundwater protection; and
� the savings, in terms of embodied energy, from materials recycling.

The UK Environment Agency have built a carbon calculator for buildings which helps
to estimate the potential for carbon savings through increased use of recycled
materials in buildings. Carbon emissions for several different building materials are
shown in Table 48-3.
Table 48-3: Environmental Impact of Selected C&D Materials
Aggregate
Aluminium
Copper
Steel
683
Material
Material
International Review of Waste Policy: Annexes
Carbon Carbon footprint footprint
footprint
(tCO (tCO2/t) (tCO (tCO /t) /t)
0% recycled 0.008
100% recycled 0.004
Virgin 12.65
Predominantly recycled 1.02
Virgin 5.57
100% recycled (high grade/low grade) 3.98 / 1.39
Virgin 2.90
Predominantly recycled 0.97
Source: Environment Agency, Carbon Calculator for Construction Industries, Accessed 17 th February
2009, http://www.environment-agency.gov.uk/static/documents/carbon_calculator_2_1883909.xls
It can be seen that using 100% recycled material always reduces the carbon
emissions but the benefit varies greatly between material. There is great potential for
decreasing the environmental impact of construction and demolition projects through
focusing on materials other than aggregates. Although aggregates are the majority of
the C&D waste stream by weight, it is apparent that there are disproportionate
environmental benefits to be gained through focusing policy on the other materials. In
particular, the benefits from recycling the material arise through the differentials
between the figures in the above Table for the primary and secondary material.
Recycling of aluminium, high grade copper, low grade copper and steel, therefore,
generate benefits of the order 11.63 tonnes CO2, 1.59 tonnes CO2, 4.18 tonnes CO2
and 1.93 tonnes CO2 respectively.
Quantifying the environmental benefit as a result of mandatory recycling is at this
stage hard. For example, the Netherlands has a high C&D recycling rate (90%+) but it
was relatively high (74%) before the implementation of any focused C&D waste policy
instruments in 1990. Following this they implemented 4 policies:
1) separation of recyclable materials from demolition projects was announced in
1993;
2) landfill tax in 1996;
3) the building material decree in 1999 (see Section 47.0); and

4) landfill ban for specific recyclable and combustible materials, which impacted
upon C&D waste, in 2000. 832
The evolution in recycling rates is shown in Figure 48-1, where the rate of recycling is
seen to increase to over 90% during 1995, when the impending implementation of
the landfill tax was announced, and before the other policies had been formally
implemented. 833 This suggests that the requirement to sort may have had a
significant impact, which was supported by the announcement of the landfill tax.
Figure 48-1: Proportion Waste to Landfill and C&D Recycling Rates in the Netherlands
(%)
684
100
90
80
70
60
50
40
30
20
10
0
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1980 1985 1990 1995 2000 2005
Year
Recycling Rate
Proportion Waste to Landfill
Source data: OECD (2002) Case Studies on Policy Instruments for Environmentally Sustainable
Buildings, Accessed 21 st January 2009,
http://www.olis.oecd.org/olis/2001doc.nsf/LinkTo/NT00000C46/$FILE/JT00128202.PDF
The Federal Ministry of Agriculture and Forestry report that the annual generation of
C&D waste and excavated soil in Austria is estimated to be approximately 28 million
tonnes, therefore accounting for approximately 52 % of the total waste generated in
Austria each year. Since the Ordinance on the Separation of Materials Accumulated
832 Although the ban covers construction and demolition waste, in practice, the way the ban is
implemented tends to imply that such wastes are still likely to be accepted at Dutch landfills since the
ban is implemented through reference to a density threshold.
833 OECD (2002) Case Studies on Policy Instruments for Environmentally Sustainable Buildings,
Accessed 21 st January 2009,
http://www.olis.oecd.org/olis/2001doc.nsf/LinkTo/NT00000C46/$FILE/JT00128202.PDF

during Construction Work came into force, recycling of C&D waste has increased from
15 % in 1985 to more than 70 % in 2006. However, it is unknown how much of this
increase can be apportioned to this policy mechanism. 834
Positive feedback from the scheme in San Jose shows that 98% of contractors
produce the relevant documents in order to allow them to receive their deposit back.
Depending on whether the project is public or private, this means that recycling rates
of 75% and 50% respectively are being achieved. 835 That having been said, these
targets are not so challenging, so that these may have already been being met in the
pre-existing situation. Even so, a useful attribute of the refunded compliance bond
policy is that it is flexible with respect to the target setting which should be achieved.
48.6 Implementation Costs
Costs will mainly be incurred by the contractor who will have to ensure that they are
adhering to the policy either through setting up source separation containers on site,
arranging collection by registered transporters or ensuring material is delivered to
certified sorting and reprocessing facilities.
The enforcing authority will also have costs for administration of the permit system,
production of awareness campaigns and resources, and enforcement officers, but no
information could be found to quantify this cost.
In the case of refunded compliance bonds, the administrative fee is expected to cover
all such costs. As stated above, in California, this is estimated as 0.3% of project
costs.
48.7 Effects on Technical Change / Innovation
As contractors have to undertake source separation of recyclables on site they may
also begin to consider the following:
685
� on-site separation practices;
� demolition methods which allow for the materials to be source separated more
easily (see Annex 45.0);
� re-using the material from demolition projects in construction projects;
� using products with recycled content in the construction phases, for example
recycled aggregate; and
� constructing buildings in such a way that allows for straightforward
disassembly, material sorting and recycling, at the end of their life, e.g.
834 Federal Ministry of Agriculture and Forestry, Environment and Water Management (2006) Federal
Waste Management Plan 2006: Suitable for Nature and Mankind. Available at:
http://www.bundesabfallwirtschaftsplan.at/
835 Gruzen Samton LLP with City Green Inc. (2003) Construction and Demolition Waste Manual,
prepared for New York City Department of Design and Construction, Accessed 19 th January 2009,
http://www.nyc.gov/html/ddc/downloads/pdf/waste.pdf
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Singapore’s use of prefabricated concrete slabs. 836 There are many examples
of voluntary codes of practice which encourage sustainable construction and
demolition which have not been included in this review as they are not
considered a policy. For example, the Code of Practice on Buildable Design in
Singapore and the Code for Sustainable Homes in Scotland, England and
Wales. However, it is possible that in the future these may be mandated, as
has been the trend for other initiatives or schemes which are now considered
to be policies.
48.8 Social and Distributional Consequences
Social and distributional consequences would only be expected where:
� either, the policy differentiated between companies; or
� the costs introduced by the policy had a significant impact on the price of
construction projects targeted by the policy.
In reality, the policies seem either to impose minimal costs (companies may even
reduce waste management costs, depending upon the other policies in place).
In cases where refunded compliance bonds are in place, the bond is typically related
to the size of the project. The bond itself can be refunded on achievement of the
required target. In principle, those with more pressing cash-flow problems would find
it more difficult to put up the compliance bond in advance.
Clearly, a beneficiary should be the reprocessing sector, in particular, accredited
facilities.
48.9 Complementary Policies
Unlike the minimum recycling standards for household and C&I waste materials, the
recycling standards of waste streams in C&D are not underpinned by financial
support policies such as producer responsibility and pay-by-use. However, examples
of refunded compliance bonds have been seen in the USA which provide a financial
incentive to reach the set recycling targets. Also, in Austria there is a reduction in
waste management fees for separately collected demolition waste. 837
An alternative policy to mandatory recycling is to mandate the use of recycled
products, thereby forcing recycling rates up to ensure the recycled material is
available. Due to the close association between the two policy mechanisms it is
possible that both could be simultaneously implemented in one policy. It has been
common in the past for such guidelines to be included in green public procurement
836 AEA Technology (2007) International Approaches to Waste Prevention and Minimisation, Final
Report for Defra (BREW), Accessed 15 th October 2008,
http://www.crwplatform.co.uk/conwaste/assets/Publications/2006-7-Reports/International-
Approaches-to-Waste-Prevention-and-Minimisation.pdf
837 European Topic Centre on Resource and Waste Management [Online],
http://waste.eionet.europa.eu/facts/factsheets_waste/Instruments [Accessed 8th September 2008].

codes. For example, Korea introduced ‘The Act on the Promotion of Construction
Waste Recycling’ in 2005 which mandated use of recycled aggregate for construction
work contracted by a public agency. 838 Similarly, in Australia, state projects often
mandate the use of recycled materials for pavements, earthworks and drainage. 839
C&D recycling is also strongly incentivised by policy measures which discourage
disposal such as landfill tax, landfill bans and, specific to C&D, aggregates tax (see
Section 46.0). Without these policies providing such strong economic drivers for
construction and demolition companies to recycle it is unlikely that such high
recycling rates would be achieved within the sector. It is notable that in the US, where
disposal costs have tended to remain low, the targets being set are less ambitious
than those in Europe and Asia, possibly reflecting a concern that the measures might
imply additional costs to developers, rather than implying savings, as might be more
common in EU countries (where higher disposal costs apply).
The continuing problem in analysing the policies is how to attribute cause and effect
directly to one policy when they are working in parallel towards the same goal. The US
cases are of particular interest in this respect since there are fewer complementary
policies.
48.10 Effect of the Policy on Pricing of Resources / Services
The cost of demolition is likely to increase due to greater care that has to be taken
when source separating the demolished materials. However, savings are likely to be
made due to decreased disposal costs, especially in those countries where a landfill
tax is in place. In the case of Austria, one study compares the cost of treatment and
disposal of mixed/non separated waste with separated waste. The results show an
overall reduction of €11.5/m 3 in the cost of treatment and disposal of separated
waste, compared to mixed waste. 840
48.11 Evasion and Enforcement
For the deposit schemes in California fines can range from $100/day to $1,500/day
relative to the size of the development. Enforcement in these cases is undertaken by
the relevant city authority and no evidence was identified which indicated how
effective the enforcement of the system is.
838 Ministry of Environment Republic of Korea (2007) Act on the Promotion of Construction Waste
Recycling, Accessed 16 th January 2009,
http://eng.me.go.kr/docs/laws/laws.html?topmenu=D&cat=400
839 AEA Technology (2007) International Approaches to Waste Prevention and Minimisation, Final
Report for Defra (BREW), Accessed 15 th October 2008,
http://www.crwplatform.co.uk/conwaste/assets/Publications/2006-7-Reports/International-
Approaches-to-Waste-Prevention-and-Minimisation.pdf
840 C. Pladerer (2006) ‘Towards Sustainable Plastic Construction and Demolition Waste Management
in Europe’ Initiatives for a Sustainable Plastic C&D Waste Management in Europe; The Case of Austria,
Presentation by the Okologie Institut for the European Workshop, Brussels, 24 th April 2006.
687
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In San Diego, where the mandatory recycling system is incentivised by a deposit
refund system, refunds for projects recycling less than the required amount will be
pro-rated according to the recycling rate achieved by the project. This system is
administered by the City of San Diego’s Environmental Services Department.
The City of Portland has the authority to inspect a site, whether or not a complaint has
been made. Following the inspection a letter of non-compliance will be issued if this
was the case. The letter gives the contractor 30 days in which to resolve the problem.
Further non-compliance leads to court action. 841
In Ontario, lack of enforcement issues have been raised due to the self-regulatory
approach that has been taken. Although the Ontario Ministry of the Environment
Enforcement Branch of Operations Division and Regional and District Offices do visit
sites, check plans, and monitor recycling activities being undertaken, it is more often
self-regulated. 842
In Chicago enforcement is undertaken by the Department of the Environment but
permits must be applied for, and documentation must be submitted to the
Department of Buildings, in order to prove compliance with the recycling standards.
Provision of misleading information in documentation regarding levels of recycling
that have been achieved can result in personal fines of $200 to $500 and potential
revocation of the contractor’s license. Contractors are subject to fines as shown in
Table 48-4. 843
Table 48-4: Fines Implemented Under the City of Chicago's Recycling Ordinance
688
Size Size Size of of Construction Construction or or Demolition Demolition Project Project
Fine Fine
Fine
10,000 square feet or more
10,000 square feet or less
29/09/09
$1,000 for each percentage point of difference
between the amount required to be
recycled/reused and the amount actually
recycled/reused.
$500 for each percentage point of difference
between the amount required to be
recycled/reused and the amount actually
recycled/reused.
841 City of Portland Office of Sustainable Development (2008) Administrative Rules Commercial Solid
Waste, Recycling and Compostables, Accessed 15 th January 2009,
http://www.portlandonline.com/osd/index.cfm?a=218220&c=41472
842 The Recycling Council of Ontario (RCO) (2006) Let’s Climb Another Molehill: An Examination of
Construction, Demolition and Renovation (CRD) Waste Diversion in Canada and Associated
Greenhouse Gas Emission Impacts, Accessed 24 th October 2008
http://www.recycle.nrcan.gc.ca/documents/Full%20Molehill%20report%20-%20ENG.pdf
843 City of Chicago, Ordinance 11-4-1905 Construction or Demolition Site Waste Recycling, Accessed
16 th January 2008,
http://egov.cityofchicago.org/city/webportal/portalContentItemAction.do?contentOID=536932617&co
ntenTypeName=COC_EDITORIAL&topChannelName=HomePage

In Japan, the lead contractor is responsible for source separation and recycling, even
if this will be carried out by one or many subcontractors. This resulted in any
additional cost being carried by the lead contractor and subsequently resulted in flytipping
when they could not recover the full cost.
48.12 Lessons Learned
The potential for mandating recycling rates can be highlighted by a Japanese
construction company, Sekisui House, which voluntarily achieved zero waste at their
construction sites in 2005. Materials were source separated in 27 categories on site
which were further sorted into 60 categories at a MRF. They report that the average
waste from site was reduced from 2.9 tonnes to 1.8 tonnes, which went on to be
reused or recycled. In one month they reported savings of U.S.$350,000. 844 Since
2005, all Government construction and demolition projects must be zero waste but
no evaluation reports regarding this requirement could be found.
48.13 Prerequisites for Introduction
Firstly, as already mentioned in Section 48.9, policies which make disposal more
expensive are thought to be the underlying driver for this policy by enabling
contractors to make a financial saving through increasing recycling rates from their
construction and demolition projects.
Also, industry support is important since the cost of complying with the policy falls
with them. Success from the implementation of the scheme in San Jose has shown
that processors have been positive about becoming certified in order to ensure they
retain their customer base. The City of San Jose reports that obtaining documentation
from the processors in order to prove mandatory recycling rates are being achieved
was straightforward. 845
Furthermore, a permitting authority needs to be assigned in order to monitor and
enforce the policy. Further details regarding the expected role of the permitting
authority are outlined in Section 48.3.
Finally, there is likely to be merit in setting a clear target for recycling of construction
and demolition waste, this being necessary for projects where the refunded
compliance bond is the policy of choice.
844 Resource Recovery Forum (2006) Japan – Sekisui House Achieves Zero Waste at New Construction
Site, Accessed 16 th January 2008,
http://www.resourcesnotwaste.org/members/private/news/view.php?newsItem_ID=1662
845 Gruzen Samton LLP with City Green Inc. (2003) Construction and Demolition Waste Manual,
prepared for New York City Department of Design and Construction, Accessed 19 th January 2009,
http://www.nyc.gov/html/ddc/downloads/pdf/waste.pdf
689
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49.0 Incentives Affecting Construction and
Demolition Waste - Belgium
The past 10 years, policy regarding construction and demolition waste (C&D waste)
was mainly focused on attaining high recycling rates. In 1995, a target was set for the
recycling rate that should be achieved by 2000, i.e. 75% of C&D waste. This goal was
achieved rather easily, with a recycling rate of more than 85% in 2000.
By comparison, no clear goal was set for the reduction of C&D waste; a reduction was
sought by awareness rising campaigns like guides on good practice, and the PRESTI
programme (Prevention Stimulating Programme) that financed studies and pilotprojects
on waste prevention. Initiatives and programmes such as these are
discussed in Annex 60.0.
In 2007, a new Construction and Demolition Waste Master plan 2007-2010 was
implemented. Emphasis again was put on recycling and especially re-use of C&D
waste, with e.g. high environmental standards and certification of aggregates, and
specifications for selective dismantling. With regard to the prevention of C&D waste, a
study is currently being performed analysing the feasibility of establishing
environmental performance requirements with respect to material use in
construction.
690
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50.0 Minimum Recycling Standards (Construction
and Demolition Waste) - Germany
The Commercial Waste Ordinance 846 regulates the recovery and disposal of
commercial municipal waste, and construction and demolition waste. The principal
aim of the Commercial Waste Ordinance (GewAbfV) is the segregation of waste
fractions (four fractions for building and demolition waste: metallic waste, glass,
plastics and concrete) in order achieve greater feedstock or energy recovery (i.e. the
aim is to remove wastes which are not readily combustible to allow for use of the
residual in energy recovery facilities).
Particular attention should be paid to two aspects:
691
1. the approach employed by the ordinance with regard to recovery quotas; and
2. the special regulations for building and demolition waste.
The recovery quotas apply to the recovery of waste in pre-treatment plants. However,
not all accumulated (and recoverable) waste arrives at such plants; consequently, the
question arises whether the recovery quota as an instrument actually achieves its
intended effect.
The period between the accumulation of the waste (demolition of a house) until
transport to a pre-treatment plant, that is, the period in which the selection,
segregation and collection of recyclable waste takes place, is generally defined by the
KWTB voluntary commitment declaration. In this regard the question also arises
whether the Commercial Waste Ordinance only achieves the effect intended by the
legislator by means of an additional timely voluntary commitment declaration.
Prior to this, the building industry was fulfilling the recycling quotas imposed by the
voluntary commitment declaration. Accordingly, the instrument is functioning, and
legislative regulations (to be integrated in the Commercial Waste Ordinance) are
currently not absolutely necessary.
On the other hand, the specifications already given for building and demolition waste
in the Commercial Waste Ordinance must be studied in more detail. For example, the
list of building materials (e.g. plastics, glass, concrete) does not include such things
as insulating materials or high-quality building materials (concrete from structural
engineering). However, there are reservations regarding insulating materials due to
heavy soiling because recovery of soiled (usually mixed with other building materials)
insulating materials is only possible with restrictions. In practice, the problem of
mixing occurs for insulating materials in particular. Insulating materials are therefore
explicitly mentioned as mixed waste in the LAGA implementation notes.
846 (2002) Ordinance on the Management of Municipal Wastes of Commercial Origin and Certain
Construction and Demolition Wastes of 19.06.2002, Federal Law Gazette, pp.1938.
International Review of Waste Policy: Annexes

Due to the failure to list these materials in the Commercial Waste Ordinance,
however, the limited existing potential for the recovery of insulating materials during
demolition is not being exhausted. Wood, in turn, does not come under the regime of
the Commercial Waste Ordinance, but is covered by the Waste Wood Ordinance
(AltholzV); this divides wood waste from the building sector into several waste wood
categories (see Annex III of the Waste Wood Ordinance). 847 The requirements placed
on treatment prior to reuse then depend on the category.
The LAGA implementation notes put into concrete terms the principal regulations
contained in the Commercial Waste Ordinance. 848 In parts they contain information
which could not be included in the Ordinance for fear of bloating the text or because it
represents background information only.
The structure employed by the ordinance follows two routes:
692
1. the system of principles applying to commercial municipal waste is also
adopted for the explicitly emphasised building and demolition waste listed
using a separate system; and
2. the building and demolition waste, in turn, is differentiated into discrete and
mixed waste fractions
� new-build (in particular structural engineering);
� refurbishment, modernisation and renovation; and
� demolition, where individual components or building materials are
removed separately (selective demolition).
In the case of demolition, the LAGA points out that selective demolition may be
obligatory depending on the Federal state involved. However, regulations involving
Federal state laws have not yet been identified.
Beside this, the implementation notes also address mixed waste and briefly describe
the situation surrounding the origin and types of accumulating waste mixtures in
order to clarify fields of action for the executive agency. This shows that mixed
building and demolition waste primarily occurs where no selective demolition is
practiced. In most cases, these types of waste consist of mineral building waste
fractions and, in addition, bitumen mixtures, insulating materials or gypsum-based
building materials.
It is felt that the current framework in place for dealing with C&D waste is insufficient.
Not least because of numerous problematic substances (e.g. asbestos, heavy metals)
and incompatible substances (e.g. gypsum in concrete recycling, insulation materials
manufactured from fibres, etc.) contained in the building material stock, which in
practice make successful high-quality recycling more difficult or even hinder it
completely, it is felt that a means of optimal material segregation by selective
demolition should be sought.
847 Ordinance of 15.08.02, Federal Law Gazette, pp.3302.
848 Implementation notes of the Working Group of the Federal States on Waste (LAGA) to the
Commercial Waste Ordinance, passed on 26.03.03.
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POLICIES FOR RESIDUAL WASTE
693
International Review of Waste Policy: Annexes

51.0 The Landfill Directive – Current Situation
Meeting the targets under Article 5 of the Landfill Directive is a major challenge for
Ireland. Some detailed consideration is given to how Ireland might meet these targets
in this Section, taking into account the current situation and the potential for change
in the time available.
First, we review data for municipal waste. We then consider progress towards the
Directive targets, and plans in place to meet these. We discuss the potential for
meeting these targets, first in an ‘unconstrained’ manner, and then, taking into
account the institutional constraints currently in place.
By way of reminder, Article 5 (2) of the Landfill Directive states, regarding national
strategies for reducing the landfilling of biodegradable waste: 849
694
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2. This strategy shall ensure that:
(a) not later than five years after the date laid down in Article 18(1),
biodegradable municipal waste going to landfills must be reduced to
75 % of the total amount (by weight) of biodegradable municipal waste
produced in 1995 or the latest year before 1995 for which
standardised Eurostat data is available
(b) not later than eight years after the date laid down in Article 18(1),
biodegradable municipal waste going to landfills must be reduced to
50 % of the total amount (by weight) of biodegradable municipal waste
produced in 1995 or the latest year before 1995 for which
standardised Eurostat data is available;
(c) not later than 15 years after the date laid down in Article 18(1),
biodegradable municipal waste going to landfills must be reduced to
35 % of the total amount (by weight) of biodegradable municipal waste
produced in 1995 or the latest year before 1995 for which
standardised Eurostat data is available.
Two years before the date referred to in paragraph (c) the Council shall reexamine
the above target, on the basis of a report from the Commission on
the practical experience gained by Member States in the pursuance of the
targets laid down in paragraphs (a) and (b) accompanied, if appropriate, by a
proposal with a view to confirming or amending this target in order to ensure a
high level of environmental protection.
Member States which in 1995 or the latest year before 1995 for which
standardised EUROSTAT data is available put more than 80 % of their
collected municipal waste to landfill may postpone the attainment of the
targets set out in paragraphs (a), (b), or (c) by a period not exceeding four
years. Member States intending to make use of this provision shall inform in
849 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999 pp. 1 – 19.

695
advance the Commission of their decision. The Commission shall inform other
Member States and the European Parliament of these decisions.
51.1 Municipal Waste – Quantities and Growth Rates
In Ireland, municipal waste is defined as follows:
household waste as well as commercial, industrial and street cleansing waste
which because of its nature and composition is similar to household waste.
In statistical reporting by the EPA, there appears to be:
1) no commercial waste which is not deemed part of municipal waste;
2) no street cleansing waste which is not deemed part of municipal waste; and
3) no industrial waste which is deemed part of municipal waste.
Indeed, municipal waste appears to be defined as:
Household waste plus street sweepings plus commercial waste,
where the following definitions apply
1) Household Household waste waste is waste produced within the curtilage of a building or selfcontained
part of a building used for the purposes of living accommodation.
2) Commercial Commercial waste waste is the waste that is produced from a number of diverse
sources, including shops, offices and commercial premises, such as paper and
cardboard, plastics, organics and glass etc.
Figure 51-1shows the evolution of the total quantity of municipal waste and its subcomponents
have changed over the last twelve years. It is clear that the quantities
have generally increased.
The total quantity of municipal waste has increased at a compound rate of 5.6% per
annum. This growth rate masks the differences seen in the sub-streams.
As can be seen from Figure 51-1, the contribution to total MSW from street sweepings
is very small. The more important streams are commercial waste and household
waste.
51.1.1 Household Waste
Growth rates for household waste is as follows:
� Household waste 3.8% per annum over the last 12 years;
� Household waste 2% per annum over the last 6 years
� Per capita household waste flat over the last 6 years
Ireland has experienced significant changes in population in recent years. This is
shown in Figure 51-2. The country is effectively returning to population levels of the
1860s, from a low point achieved in the 1960s. Net migration, which has been
negative in every intercensal period bar one since before the 1920s, turned strongly
positive from the 1990s onward.
International Review of Waste Policy: Annexes

Figure 51-1: Evolution of MSW and its Components, 1995-2007
Tonnes Waste
696
4,000,000
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
0
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1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Year
Household Waste
Commercial Waste
Street Sweepings
MSW
Source: EPA National Waste Report 2001, EPA National Waste Report 2007
Figure 51-2: Changes in Population in Ireland
Source: CSO (2008) Statistical Yearbook of Ireland 2008.
The strong growth in municipal waste is, of course, driven in part by household waste,
but this does not seem to be the strongest driver. Per capita household waste arisings

have stabilised over the last six years. It would appear, therefore, that the rate of
population growth is an important driver of household waste growth.
Curtis et al have sought to estimate determinants of household waste growth in
Ireland. 850 This work is of interest since it is one of few attempts to elicit such
parameters in Ireland. The authors derive an income elasticity of demand for waste
services of 1.08. They themselves note that figures in excess of 1 are highly unusual
in the literature. This is the figure used in the ISus model to predict future waste
growth. This, coupled with estimates of growth for the economy going forward,
suggests considerable – one might say, worryingly high - growth in household waste,
increasing to around 3.2 million tonnes in 2025.
It seems likely that countries experiencing rapid growth from relatively low levels
(compared with the most wealthy nations), as Ireland has done, would tend to exhibit
high income elasticities of demand for waste services. However, these might well
show some decline as consumption patterns adjust to higher levels of real per capita
disposable income. Generally, constant elasticity models become less reliable over
non marginal changes in prices or incomes. We doubt that this parameter would
remain at this level in the future (and one might doubt the data where it suggests it
has been this high, even in the past).
51.1.2 Commercial Waste
697
� Commercial waste 9% per annum over the 12 year period
� Commercial waste 8% per annum over the last 6 years
Commercial waste growth has been a staggering 9% per annum over the same 12
year period. It is difficult to explain this rapid growth solely through appeal to
economic growth, especially given the flat ‘per household waste’ quantity over recent
years.
This could reflect problems, referred to in EPA Reports and in discussion with EPA
officials, of classification of waste types. However, it seems irregular misclassification
could lead to such a (consistently) large growth rate, not least since some
classification problems might be expected to move waste in and out of one
classification from one year to the next.
The stark fact remains that according to the available data, commercial waste has
more than tripled over a twelve year period. There must be questions to be asked
regarding the accuracy of the growth rates reported above. To what extent are these
genuine, or do they suggest inconsistencies, across time periods, in reporting? Is
commercial waste increasingly being mixed with other materials? Is this leading to
over-reporting of commercial waste?
In 1995, commercial waste was only around 35% of household waste. Now, the
quantities are converging. The growth in commercial waste is well above reported
850 John Curtis, Seán Lyons and Abigail O’Callaghan-Platt (2009) Managing Household Waste in
Ireland: Behavioural Parameters and Policy Options, ESRI Working Paper 295, July 2009.
International Review of Waste Policy: Annexes

GDP growth (in real terms) whilst per capita household waste has remained constant
in recent times, even during a period (to 2007) in which per capita GDP continued to
rise. 851 There is at least a hint that the growth rate which is derived from past
statistics is misleadingly high.
51.1.3 Implications of Different Growth Rates
The different growth rates for the two streams have led to a situation in which
commercial waste, having accounted for only 26% of municipal waste in 1995, now
accounts for 46% of municipal waste.
This is significant for a number of reasons:
698
� First, under market oriented conditions, where dry recycling is concerned,
commercial waste tends to be recycled to a greater extent than household
waste. The increased proportion of commercial waste in municipal waste will
have had the effect of helping to increase recycling rates for municipal waste
(and so, over the last decade, it has proven in Ireland);
� Second, in respect of institutional issues considered in this review, a move to
give unequivocal control over delivering collection services to the local
authorities is likely to affect household waste only. This would mean that as far
as municipal waste is concerned, the proportion of the waste which would be
subject to clear local authority control is only approximately half the total
municipal waste, as currently defined;
� Third, and as a related point, a substantial proportion of biodegradable
municipal waste (BMW) – the subject of Landfill Directive targets – has no
obvious single type of ‘addressee’ in terms of ensuring targets cascading down
from the national level. Probably the only addressee could be the collector, but
if such a policy proved difficult to enforce, then the approach to meeting
landfill directive targets would need to be based on a different, probably
regulatory approach; and
� Fourth, as a consequence of this, even if institutional changes were made to
ensure local authorities could be made fully responsible for the management
of household waste, with targets applied to them, a different approach would
be required for the commercial waste.
This has implications for the design of policy. Since the commercial waste stream is,
and is proposed to continue being, more responsive to market-oriented policies,
policy has to give certainty to the market regarding the requirement to deal with
biodegradable municipal waste in ways other than landfilling, either through market
851 It can perhaps be appreciated, from this discussion, why the projections made in the ISus model
with regard to waste quantities are unlikely to be accurate. The ISus model assumes that the
generation of waste per household, with respect to real disposable income, is perfectly elastic. It
assumes also that the waste generation by commerce and industry is perfectly elastic with respect to
real output and turnover (presumably in real terms), respectively. It would be a mistake to make
forward plansd on the basis of these projections.
29/09/09

ased instruments, or through regulatory mechanisms, or through a combination of
both.
51.2 Recycling of Municipal Waste
The recycling rate for household waste was 7% in 2001. It has increased to 26% in
2007. These rates can be compared with commercial waste recycling rates of 24%
and 48% in 2001 and 2007, respectively.
It is important to understand the differences between the two and the potential for
performance to improve in both streams.
The most recent EPA Waste Report 2007 shows the estimated captures for different
components of the waste stream. 852 These are greater in the commercial stream for
all materials other than textiles (see Table 51-1 and Table 51-2). These figures are
shown diagrammatically in Figure 51-3 and Figure 51-4.
Table 51-1: Quantities and Captures for Recovery, Household Waste
Total Total Landfilled Landfilled % Recovered Recovered %
Paper 385,074 187,350 48.7 197,724 51.3
Glass 131,300 38,759 29.5 92,540 70.5
Plastic 195,881 153,662 78.4 42,219 21.6
Ferrous 23,590 17,188 72.9 6,402 27.1
Aluminium 22,213 16,876 76 5,337 24
Other Metals 2,218 1,513 68.2 705 31.8
Textiles 199,571 188,680 94.5 10,891 5.5
Organics 444,579 406,182 91.4 38,397 8.6
Wood 23,261 15,051 64.7 8,210 35.3
Others 197,803 175,719 88.8 22,085 11.2
Total Total
1,625,490 1,200,980 1,200,980 73.9 73.9 424,510 424,510 26.1
26.1
Source: EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.
What is striking, from the graphic representation, given the objectives of the Landfill
Directive, is the fact that:
1) The capture of the single largest stream in municipal waste – the organics – is
very low, at around 9%. It seems quite likely that this is heavily concentrated on
the garden waste fraction;
2) Very large quantities of paper (and card) remain uncaptured, although capture
rates are estimated as being above 50% in both streams; and
852 A problem with this data appears to be the lack of correspondence between the assumed
composition of waste in the EPA report, and the estimated composition of waste, as set out in the
EPA’s Waste Characterisation Study. The composition of household waste in the EPA Waste report is
not the same as the composition of household waste in the Characterisation Study. The way in which
the data has been derived is worthy of some closer examination.
699
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3) Very large quantities of textiles remain uncaptured in the household waste
stream.
These streams are the key biodegradable municipal waste streams and policy clearly
needs to be developed to ensure these materials are better captured.
Table 51-2: Quantities and Captures for Recovery, Commercial Waste
Total Total Landfilled Landfilled Landfilled % Recovered Recovered %
Paper 528,995 196,895 37.2 332,100 62.8
Glass 51,255 9,316 18.2 41,939 81.8
Plastic 92,879 70,093 75.5 22,786 24.5
Ferrous 70,768 3,889 5.5 66,878 94.5
Aluminium 10,290 8,003 77.8 2,286 22.2
Other Metals 4,421 2,531 57.3 1,890 42.7
Textiles 45,353 45,353 100 0 0
Organics 473,844 433,624 91.5 40,220 8.5
Wood 217,413 1,942 0.9 215,471 99.1
Others 53,857 42,171 78.3 11,686 21.7
Total Total Total
1,549,075 813,818 813,818 52.5 52.5 735,257 735,257 47.5
47.5
Source: EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.
Figure 51-3: Materials Captured (recovered) and Uncaptured (landfilled), Household
Waste
Tonnes
700
500,000
450,000
400,000
350,000
300,000
250,000
200,000
150,000
100,000
50,000
0
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Paper Glass Plastic Ferrous Aluminium Other Metals Textiles Organics Wood Others
Material
Material Captured Material Uncaptured
Source: EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.

Figure 51-4: Materials Captured (recovered) and Uncaptured (landfilled), Commercial
Waste
Tonnes
701
600,000
500,000
400,000
300,000
200,000
100,000
0
Paper Glass Plastic Ferrous Aluminium Other Metals Textiles Organics Wood Others
International Review of Waste Policy: Annexes
Material
Material Captured Material Uncaptured
Source: EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.
As an additional observation, the fraction termed ‘other’ includes the ‘fines’ fraction.
The fines fraction is composed of waste which falls through a screen with 20mm
mesh size. This material frequently contains significant quantities of food waste. A
plot of the organic matter (as % dry matter) versus the moisture content of food waste
indicates some correlation between the two, although a relatively weak one. Moisture
content of fines averages around 50%, with several samples exceeding 60% moisture
content. At the same time, organic matter content averages 50%, with several
samples above 60% organic matter (as a proportion of dry matter). Our hypothesis
would be that, as a conservative estimate, 50% of fines are composed of food waste
or other putrescible material. 853 This would suggest that the estimated capture of
organics is overstated at present, and that the presence of food and grass clippings in
the waste stream is underestimated because of the significance of fines in the waste
853 It is increasingly common, in the context of the development of MBT facilities, to come across waste
characterisation studies which incorporate a size assay element. This has helped to inform
understanding of how to design facilities to extract ‘sub-streams’ of material. As a result, most facilities
incorporating an anaerobic step employ a mesh size of around 40-80mm to seek to target a
‘predominantly biodegradable’ fraction. This is because the putrescible wastes are mostly to be found
in the ‘small size’ categories, including ‘fines’.

stream (estimated at 8% in the Waste Characterisation report carried out on behalf of
the EPA. 854)
Finally, it is important to comment on why the commercial and household captures of
dry recyclables are so much higher than the capture of organics. In principle, the
economics of both both the source separation of dry recyclables, and the collection and
treatment of source segregated organic materials, are driven by the avoided costs of
disposal. In principle, therefore, the two might be expected to develop in parallel.
Clearly, this has not happened.
One reason for this is that the separate collection of biowaste presumes the existence
of a treatment facility which is capable of handling the materials as collected by the
collecting entity. Not only does this require a degree of certainty in terms of the
direction of travel in respect of separate collection of biowaste, but it also presumes
that the approach to licensing facilities is not unduly onerous, and facilitates
investment by developers of such facilities. It can be argued that the absence of any
certainty in terms of the direction of travel of policy – at least until recently – has
made it difficult to justify investments in both additional collection infrastructure, and
the treatment of collected materials. 855 The matter of treatment of organic waste has
been further hindered by a lack of clarity over the implementation of the Animal Byproducts
Regulation in Ireland, though this now shows signs of being resolved (see
Annex 37.0).
51.2.1 Potential Treatment Capacity for Organic Wastes from the Municipal
Stream
A report by InterTradeIreland suggests that on the island of Ireland (i.e. including
Northern Ireland), capacity at licensed and permitted sites which have the capability
for treating animal by-products is of the order 718,000 tonnes, of which, facilities of
capacity around 313,000 tonnes are currently operational. These facilities have
around 135,000 tonnes of spare capacity.
It is estimated that of the unbuilt, but licensed / permitted capacity, around 235,000
tonnes could be built by early 2010. In addition, there are sites in the planning
process at present. 856
The picture is not completely clear from this report regarding the situation in the
Republic of Ireland. Our own brief attempt to generate relevant data suggests that
currently operational capacity for facilities capable of treating animal by-products is of
the order 86,000 tonnes, but that there is ‘latent’ capacity which may be of the order
854 RPS (2009) Municipal Waste Characterisation Surveys 2008, Final Report for the EPA, March
2009.
855 This review clearly has not helped add to the certainty, and one aim of the review must be to give
greater certainty to investors regarding the nature of alternatives to landfill required, and regarding the
flow of materials into non-landfill facilities without at the same time undermining the desirability of
delivering on high recycling rates.
856 InterTradeIreland (2009) Market Report on the Composting and Anaerobic Digestion Sectors,
Report for Cre and WRAP, May 2009.
702
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200,000 tonnes, though some of this may be being earmarked for the biological
treatment of residual waste (i.e. MBT facilities). This would only become clear with a
more thorough investigation. However, the suggestion is that if market conditions
improve, that capacity might be developed relatively swiftly. This is important for
reasons which will be explained below.
Some stakeholders have mentioned the amount of capacity available at rendering
plants in Ireland. It is far from clear to us that rendering plants would be suitable for
dealing with much of the biodegradable waste in Ireland. Rendering may be
appropriate for dealing with some biowastes, notably animal parts, but the process
would give rise to residues requiring subsequent treatment. The EPA, on the other
hand, appears to be confident that rendering facilities could deal with biowaste which
is collected, at least in the short term.
One clear problem for Ireland, facing up to the urgency of the current situation, is that
as collectors roll out biowaste collection infrastructure, the demand for biowaste
treatment infrastructure has the potential to exceed supply. This could lead to
relatively high prices (composting gate fees are already estimated to be at high levels
by European standards) in the short-term whilst the infrastructure develops. The
availability of capacity at rendering plants would, therefore, be useful as much from
the perspective of setting a price ceiling as from the desirability of the treatment per
se.
51.3 Treatment of Residual Municipal Waste
As regards the treatment of residual municipal waste, there is very little by way of
facilities currently operating in Ireland. There are facilities in development and others
with planning permission and permits already in place.
51.3.1 Thermal Treatment
The last meaningful review of the status of Regional Waste Plans was provided in
‘Taking Stock and Moving Forward’. 857 As of the end of 2003/early 2004, the
document reported that of the ten regions, all but two provided for thermal treatment
in their plans, though Wicklow indicated a preference to use capacity developed
elsewhere. Of the two without thermal treatment in their plans, one of them, Cork, is a
region in which proposals for such a facility are already advanced.
Since the publication of ‘Taking Stock’, many Regions have revisited their Regional
Waste Plans. A recent report suggests, however, that only Donegal, Wicklow and
Kildare do not recommend the use of thermal treatment within their Regional Waste
Plans, but these regions suggest that they will look at developments in neighbouring
regions. 858
857 DoEHLG (2004) Taking Stock and Moving Forward, April 2004.
858 Fehily Timoney and Co (2008) Critical Analysis of the Potential for Mechanical Biological Treatment
for Irish Waste Management: Volume 2, Research Report for the EPA, September 2008.
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In respect of incineration, the EPA notes: 859
704
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In November 2005, the EPA granted licences1 for two commercial incinerators.
The licences provide for the operation of waste incineration facilities by
Indaver Ireland at Carranstown, Co. Meath (W0167-01) and Ringaskiddy, Co.
Cork (W0186-01). In November 2008, the EPA granted a licence for a third
municipal waste incinerator at Ringsend in Dublin (W0232-01). None of these
facilities are operating as of end-2008 and only the Carranstown facility has
commenced construction.
The capacity of these facilities is 150,000 tonnes in the case of Carranstown,
600,000 tonnes in the case of Dublin and 200,000 tonnes in Cork (of which half
might be used for municipal waste). 860 The South East region is also in the midst of
procuring treatment capacity. The original plan in the South East proposed a facility
limited to 150,000 tonnes.
Other regions have expressed intentions to develop incineration (or other thermal
treatment facilities) and some have set recovery targets:
� Connaught 33% of all waste
� Clare / Kerry / Limerick 41% of household and commercial waste
� Midlands 58% of household waste
30% C&I waste
The EPA also notes that in 2007, 107,205 tonnes of non-hazardous waste was
reported by recovery operators to have been used for combustion (see Table 51-3). Of
this, some 32,695 tonnes were exported for use as a fuel.
Table 51-3: Non-hazardous Waste Used as a Fuel, 2007
Material Material
Total Total Tonnes Tonnes
Of Of Of which, which, which, packaging
packaging
Wood 71,774 24,781
Refuse derived fuel 32,695 6,963
Edible oil and fats 2,736
Total Total
107,205 107,205
31,744
31,744
Source: EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.
51.3.2 Cement Kilns
Consultations have highlighted that Lagan Cement is also already co-incinerating
Solid Recovered Fuel at its facility following a review of its PPC license. Approximately
50,000 tonnes of SRF are likely to be utilised at the facility on an annual basis. Along
with the other cement companies (Irish Cement and Quinn Cement) the Irish cement
industry is likely to have a combined capability to receive SRF of around 140,000
859 EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.
860 Indaver is applying for a review of the Carranstown licence to increase the capacity of the waste-toenergy
plant from 150,000 tonnes per annum to 200,000 tonnes per annum. The Carranstown facility
commenced construction in September 2008.

tonnes early in 2010, and as much as 280,000 tonnes per annum later in the year.
The SRF would be displacing coal at Lagan cement and Quinn Cement, and petcoke
at the Irish Cement facilities. Studies suggest that this will make the overall
environmental effect
Given the fuel specification is of the order 16MJ/kg and above, with defined limits on
ash content, chlorine, moisture and heavy metals, mixed residual MSW is likely to
require pre-treatment so that the 280,000 tonnes capacity is likely to be derived from
a larger quantity of residual MSW. The exact quantity depends upon the waste
stream, but the quantity might be expected to be no less than 300,000 tonnes, and
as much as 600,000 tonnes.
The degree to which cement kilns might deal with biodegradable material might
appear, at first glance, to have been compromised by the EPA’s specification of pertreatment
in that this tends to suggest that SRF should be derived principally from
non-biodegradable waste streams. The Guidance document appears to push MBT
suppliers towards a ‘splitting approach’ since landfill site operators would, in
principle, not be allowed to accept waste at landfills without it having been dealt with
in such a way. 861 However, we are informed by the EPA that this arises from a too
literal interpretation of the document, and that in principle, the approach to
generating SRF is not constrained.
51.3.3 Mechanical Biological Treatment
Regarding mechanical biological treatment (MBT) facilities, this is rightly described in
a STRIVE report as being in its infancy in Ireland. 862 The report states that at least two
facilities export a refuse-derived fuel (RDF) for thermal treatment abroad. There are
also some facilities which have potential to be deployed as MBT facilities, some of
these described in a 2008 report. 863 These may be capable of delivering reductions in
the biodegradability of waste which they handle, so contributing to meeting targets in
due course.
It remains to be seen how the EPA’s Guidance on Pre-treatment and Residuals
Management will affect the development of MBT in Ireland. Discussions with EPA
officials suggest that the Guidance Document is not a full reflection of the way in
which the Pre-treatment requirement will be implemented. 864
861 EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Johnstown Castle Estate: EPA.
862 Fehily Timoney & Company / Veolia Environmental Services / Ramboll (2008) Critical Analysis of
the Potential for Mechanical Biological Treatment for Irish Waste Management: Volume 2, Report for
the Environmental Protection Agency, September 2008.
863 Eunomia with Tobin (2008) Meeting Ireland’s Waste Targets: The Role of MBT, Final Report to
Greenstar.
864 If one takes the Guidance at face value, then it would difficult to understand why the EPA made the
decisions which it appeared to have made. In addition, the Guidance document does not give sufficient
detail concerning how the Guidance is to be operationalised, and there are several decisions made
where the justification is through appeal to the need to demonstrate BAT, though this is not clearly
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51.4 Existing Targets
Several targets apply to Ireland through the application of EU legislation, whilst others
have been set at the national level in support of the delivery of EU targets. A brief
review of these is offered below.
51.4.1 Landfill Directive
In 1995, Ireland landfilled 1.29 million tonnes of biodegradable municipal waste
(BMW). 865 The Landfill Directive targets imply, therefore, that:
706
• No more than 967 thousand tonnes of biodegradable municipal waste may be
landfilled in 2010;
• No more than 645 thousand tonnes of biodegradable municipal waste may be
landfilled in 2013; and
• No more than 451 thousand tonnes of biodegradable municipal waste may be
landfilled in 2016.
The targets imply successive reductions in absolute quantities of BMW being
landfilled. For Ireland, the most worrying fact is that despite improvements in
recycling of household and commercial waste, the rate of growth in BMW has nullified
these efforts in terms of their contribution to Landfill Directive targets. The country
appears to be ‘running to stand still’, with landfilled BMW still higher in 2007 than it
was in 1995 (see Figure 51-5).
This re-iterates the points made earlier concerning:
� the need to be clear about whether what is classified as commercial waste
really is commercial waste. The growth in what is reported as BMW, and the
actual quantity of BMW may be two completely different things. 866 Given the
potential ramifications (in terms of cost and timing) of over-estimating MSW,
and hence (through applying composition data derived from Characterisation
Studies related to specific waste streams), BMW, some detailed investigations,
and potentially, even measures to keep waste streams separate, might be
desirable; and
� the need to step up activity in respect of source separation of the major
components of biowaste.
elaborated. The EPA is clearly – on the basis of communications with them - confident that the
Guidance will achieve what it sets out to. However, confidence in this regard might have been
enhanced had the document been clearer on a number of matters which are of material significance.
865 EPA (2003) National Waste Report 2001, Johnstown Castle Estate: EPA.
866 The EPA recognises that the basis for understanding the composition of BMW in the waste stream
is not ideal from the perspective of what is reported as municipal waste by landfill operators. According
to personal communications, the supposition is that ‘genuine’ municipal waste is frequently mixed with
other materials, such as C&D waste, before being sent to landfill, where all the material is declared as
MSW.
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We discuss the matters further below.
Figure 51-5: Evolution in BMW Managed and BMW Landfilled
Tonnes
707
2,500,000
2,000,000
1,500,000
1,000,000
500,000
0
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Source: EPA National Waste Reports.
International Review of Waste Policy: Annexes
Year
BMW Landfilled BMW Managed
Note: Managed BMW is interpolated for years between 1995 and 2001. BMW
landfilled is interpolated for 1996, 1997, 1999 and 2000. In both cases, evolution
between known data points is assumed to be linear.
51.4.2 Existing National Targets
The key targets at the national level in Ireland are found essentially in two
documents:
� Changing Our Ways – this document contains the key targets for Irish waste
management; 867 and
� The National Biodegradable Waste Strategy (NBS), which identifies the ‘gap’
which must be closed if Ireland is to meet Landfill Directive targets. 868
However, it is acknowledged that this ‘gap’ may change as projections change.
The ‘gap’ is derived from the Landfill Directive Article 5 targets and the
projections for waste growth.
867 DoELG (1998) Waste Management: Changing our Ways, September 1998.
868 DoELG (2006) National Biodegradable Waste Strategy, April 2006.

51.4.2.1 ‘Changing Our Ways’
Changing Our Ways set out the following quantitative targets of relevance to the
Landfill Directive, to be achieved over a 15-year period (i.e. to 2013): 869
708
1. a diversion of 50% of overall household waste away from landfill;
2. a minimum 65% reduction in biodegradable wastes consigned to landfill;,
3. the development of waste recovery facilities employing environmentally
beneficial technologies, as an alternative to landfill, including the development
of composting and other feasible biological treatment facilities capable of
treating up to 300,000 tonnes of biodegradable waste per annum,
4. recycling of 35% of municipal waste,
5. recycling at least 50% of C&D waste within a five year period, with a
progressive increase to at least 85% over fifteen years,
6. an 80% reduction in methane emissions from landfill, which will make a useful
contribution to meeting Ireland's international obligations.
With the exception of target 2, there is little by way of supporting rationale or evidence
provided to justify the choice of these particular targets. In the case of target 2, there
does not appear to be monitoring of progress towards this target (which covers all
waste, not just biodegradable municipal waste, which is monitored).
These targets remained unchanged in a 2002 policy document. 870 In addition there
was a stated aim of recovering 50% of packaging waste by 2005 (which follows from
the Packaging Directive).
The 35% recycling target, which had been regarded as ‘particularly challenging’ as
late as 2004, 871 was more or less achieved by 2005, illustrating the rapidity of
progress, but also, the scope for further increases in recycling. The recovery rate
reported by the EPA (which approximates very closely to a recycling rate) was 36.5%
in 2007. 872
As suggested above, precisely because Ireland’s definition of municipal waste
includes commercial waste, the target might have been made somewhat easier to
achieve than it might have been in countries where the definition of municipal waste
is more closely aligned with household waste (given that much commercial waste
arises in relatively clean streams of material, notably paper and card). This may
explain why progress on recycling has been quicker than expected. At the same time,
869 DoELG (1998) Waste Management: Changing our Ways, September 1998.
870 DoELG (2002) Preventing and Recycling Waste: Delivering Change, March 2002.
871 DoEHLG (2004) Managing Waste: Taking Stock & Moving Forward, April 2004.
872 EPA (2009) National Waste Report 2007, Johnstown Castle Estate: EPA.
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as was made clear above, the inclusion of commercial waste in the definition of
municipal waste makes Landfill Directive targets more difficult to meet.
51.4.2.2 National Biodegradable Waste Strategy
The National Biodegradable Waste Strategy (NBS) sets out a range of ‘targets’. We
use the term in parentheses since it is not always clear whether these really are
targets or not, or at least, who the targets are to fall upon. They have the character
more of calculations and projections as to ‘what might be required’ to meet the
Landfill Directive under a particular set of assumptions. Targets are set for particular
actors to achieve, but it is not always clear who has responsibility for meeting a given
target from the document, still less, what might be the implications of failure to
deliver these.
Amongst these assumptions are that municipal waste generation will first of all stop
growing, and then reverse, as a so-called waste reduction factor of 3% is applied from
2005, rising to 6% by 2016. The projection is shown in Figure 51-6 below. This
projection is important for the analysis since it establishes the magnitude of the
expected performance gap.
Figure 51-6: Projections for BMW Generation and Quantity Landfilled
Source: DoEHLG (2006) National Biodegradable Waste Strategy, April 2006.
Second, the assumption implicit in the calculation of recycling rates is that the
proportion of commercial and household waste in municipal waste remains constant
for the period to 2016. It clearly has not been constant thus far, and no justification is
offered for the assumption.
The report sets targets for managing biodegradable waste in ways other than landfill
as follows:
709
• 2010 required 1,412,083
International Review of Waste Policy: Annexes

710
• 2013 required 1,729,585
• 2016 required 1,817,262
In terms of what this might mean and for whom, the report states:
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The assessment of capacity requirements, as indicated in Table 3.2, for
alternative treatment methods to cater for the diversion of biodegradable
municipal waste in the years 2010, 2013 and 2016 represents the national
position. The various waste management planning regions / counties should
assess their individual needs for BMW management. This approach will
enable the gap or ‘indicative target diversion capacity’ for each region /
county to be outlined.
Targets were set for recycling of municipal waste paper and cardboard. These are set
in terms of the capture of paper and cardboard:
� 45% for households and 61% for commerce in 2010, corresponding to 55% of
overall paper / cardboard generation within BMW;
� 55% for households and 71% for commerce in 2013, corresponding to 65% of
overall paper / cardboard generation within BMW; and
� 60% for households and 73% for commerce in 2016, corresponding to 67% of
overall paper / cardboard generation within BMW.
Targets were set for home composting, the aim being to ensure this takes place at
20% of urban households and 55% of rural households – equivalent to some 35% of
all households - by 2010. It was anticipated that potential yield from this would be
between 10% to 12% of available organic waste in the years 2010 and 2016.
For organic waste, the targets were:
� 40% coverage for households and 60% coverage for commerce in 2010 at an
estimated average yield of 45% to 60% respectively, corresponding to 25% of
overall organic waste generation within BMW;
� 45% coverage for households and 70% coverage for commerce in 2013 at an
estimated average yield of 50% to 65% respectively, corresponding to 33% of
overall organic waste generation within BMW; and
� 50% coverage for households and 70% coverage for commerce in 2016 at an
estimated average yield of 55% to 70% respectively, corresponding to 36% of
overall organic waste generation within BMW.
The above targets were assumed, in the NBS, to lead to a requirement for residual
BMW treatment capacity as follows:
� an estimated 308,904 tonnes of residual waste treatment will be necessary in
2010;
� an estimated 438,190 tonnes of residual waste treatment will be necessary in
2013; and
� an estimated 499,762 tonnes of residual waste treatment will be necessary in
2016.
These figures are couched as ‘targets’, and extraordinarily precise ones as that.

51.4.2.3 Comment on Targets
A concern with the targets from ‘Changing Our Ways’ would be that because the
targets which were set were not given detailed consideration, it could not have been
entirely clear which targets were truly challenging and which were not. Whatever the
source of the caution being exercised, it is worth considering the drawbacks of a lack
of ambition where target setting is concerned. Ireland is, in some ways, fortunate (in
other ways, rather less so – see below) that major infrastructure provision has not
progressed as quickly as might have been hoped. If regions and local authorities had
instated infrastructure on the basis that such recycling rates really were ‘challenging’,
they might have seriously over-provided capacity for residual waste treatment and
infrastructure, though much would depend upon the growth rate they chose to base
capacity estimates upon.
This has been the experience with many local authorities in England following the
publication of Waste Strategy 2000, which set a household waste recycling target of
33% for 2015. The target in the most recent strategy, Waste Strategy for England
2007, is 50%. In the interim period, many local authorities have procured
infrastructure which will make it difficult for them to justify the expenditure on source
separation to achieve recycling rates of 50% when costs have already been sunk into
residual waste treatment infrastructure. Essentially, the experience of England is
similar to that of Ireland – that ‘challenging’ recycling rates have been met and
surpassed far faster, and far more easily, than was thought possible. English data
shows the recycling rate for household waste in England was 34.5% for 2007/8,
implying the target set in 2000, to be met by 2015, had already been met. 873
As regards the NBS targets, the first point to make is that these are not entirely clear.
They are buried within a lengthy document, and it is not clear what ‘targets’ really are
targets, and who has to meet them. The NBS repeatedly makes reference to the
regions and their plans. It suggests that they have to meet these targets, but it is not
clear how the regions should construe the targets.
Regarding national diversion targets, the NBS states:
711
These national targets for BMW diversion for the years 2010, 2013 and 2016
represent the national position. As indicated in Section 3.4 of the Strategy, the
various waste management planning regions / counties should assess their
individual needs for BMW management in order to obtain an ‘indicative target
diversion capacity’. Regions / counties must then decide how their Waste
Management Plans can address these requirements.
These figures should be kept under continuous review and updated regularly
by each region / county, in order to ensure that sufficient capacity is available
to facilitate the achievement of the required BMW diversion targets.
Regarding the targets for residual waste, it states:
873 Statistics from Department of the Environment Food and Rural Affairs (Defra).
International Review of Waste Policy: Annexes

712
29/09/09
There will be a certain amount of biodegradable municipal waste for which it
is not feasible to achieve a sufficient level of segregated collection to satisfy
the required landfill diversion targets. Accordingly, there will also be a need to
collect this material as residual BMW and to provide treatment – either
thermally or through some form of stabilisation – to reduce the biological
activity to imperceptible levels and thereby ensure achievement of the
mandatory diversion targets.
Regions / counties must decide how their Waste Management Plans can
address these requirements.
Finally, it states:
Each Waste Management Plan should meet the targets of this Strategy,
identifying the combination of collections and treatment types that suit local
conditions and objectives. Each Plan should be reviewed on that basis.
Each Annual Implementation Report to be prepared by local authorities on the
implementation of the Waste Management Plan, as required under Key Point
13 of Waste Management: Taking Stock and Moving Forward, should record
progress made in relation to the National Strategy on Biodegradable Waste
over the previous year. The format to be followed in the Annual
Implementation Report will be specified in a Circular letter issued to all local
authorities by the DoEHLG.
What might not be clear to any of the planning regions is which targets really apply to
them, and how should they implement the requirements to deliver the NBS? Do they
all know, for example, how much BMW they should consider they were landfilling in
1995? What is their ‘quota’ of the national allowance? If this is not known, how could
the relevant calculations be performed? 874 Do the BMW projections imply ‘targets’?
Who do any of the targets actually fall upon? If some local authorities do not collect
any waste, is it reasonable to assume that they will take up the challenge of such
targets seriously? Would it be appropriate to apply sanctions to them if they don’t,
and if sanctions are not to be applied, how realistic is it to expect targets to be met?
In short, whilst the document seeks to chart a way forward for Ireland to meet Landfill
Directive targets, and whilst it contains some interesting targets in terms of home
composting and source separation, the manner in which these should cascade down
(to the regional level) is not always clear. The presumption appears to have been that
the regions will implement these, even though the regions simply do not have the
competence to deliver – in and of themselves – the outcomes.
Interestingly, most of the Annual Implementation Reports for the Regional Waste
Management Plans make little or no reference to targets that the NBS suggests they
should be implementing. Since there are very few Annual Implementation Reports
which have been produced by the Regions, and since the NBS was completed only
after most of the Regional Waste Management Plans were updated, then it would
874 The Draft NBS did actually apportion the national allowance to the regional level, which would have
been a starting point for implementation at the regional level.

seem that there is little or no basis to be confident that the Regions are seeking to
implement the NBS as it stands.
In summary (see also Annex 59.0):
713
� Some of the older targets were lacking in ambition. In particular, the recycling
targets have probably been met substantially as a consequence of the hike in
landfill gate fees which has increased the benefits associated with avoided
disposal. All of the targets should probably have been revisited at the latest in
2002, long after the full shape of the Landfill Directive was widely known.
Other targets have lacked force – and would probably not be met in the
absence of further significant policy change - since there has been no
mechanism to implement them. The presumption has been that the regions
will integrate these into their plans. However, the regions have generally
lacked the competence and tools to ensure that these targets are met, whilst
no sanction is on the horizon to incentivise compliance on their behalf; and
� The newer targets in the NBS – like many of the older targets – are not
addressed at anyone in particular. Since no sanctions are to be applied
(because it is not clear to whom the targets attach, and hence, who would be
the subject of any sanction), then it seems reasonable to question whether
any targets set out in the NBS will be met, let alone, how they would be
considered by the Regions. The lack of any ‘cascading downwards’ of the
targets is effectively confirmed through the absence of evidence that Regions
have adapted their Waste Management Plans to align them with the NBS
(since, presumably, had they done so, this would have been made clear in
Annual Implementation Reports, which few regions have actually prepared).
51.5 Current and Proposed Policy Measures
As regards residual waste treatment, there are no targets which fall upon
organisations who might be deemed appropriate addressees for such targets. There
are three policy instruments in the offing which may serve to enhance the prospects
of Landfill Directive targets being met.
51.5.1 Waste Levy
Following a Consultation on a Waste Levy, a Regulatory Impact Analysis has been
developed for both a levy on plastic bags, and ‘a levy on certain waste facilities’. 875
The principal objective of the proposed Waste Facility Levy (WFL) is to support the
Government’s goal of meeting the biodegradable municipal waste diversion targets
under the EU Landfill Directive. Furthermore, it was a defined constraint of the RIA
that the WFL should be structured such that, in accordance with the commitment
outlined in the Programme for Government (2007), the Landfill Levy will not be
altered in such a way as to give competitive advantage to incineration. Thus the WFL
875 AP EnvEcon (forthcoming) Regulatory Impact Analysis on Proposed Legislation to Increase Levies
on Shopping Bags and Certain Waste Facilities, Final Report.
International Review of Waste Policy: Annexes

is proposed not to be set at a level that represents environmental costs of each
option, as per the original intention of, for example, the UK’s Landfill Tax, but primarily
with a focus on the distinct policy goal of encouraging development of alternatives to
landfill, without giving competitive advantage to incineration.
Regarding financial costs, the RIA states: 876
714
The model assumed marginal costs (excluding levies) for the alternative
treatments as follows:
29/09/09
� Landfill €50 per tonne
� Incineration €105 per tonne
� MBT Medium €110 per tonne
� MBT High €120 per tonne
This means that the model assumes that these cost levels are required to operate
the treatment options. If tariffs are higher than these costs, owners will receive a
profit higher than necessary. If tariffs are lower than these costs, owners will have
a financial loss.
The RIA effectively assumes that landfill operators are generating significant rents
from their activities, and that levy increases might have the effect of squeezing these
rents, but with gate fees, as a consequence, rising by a figure which is below that of
the levy itself.
The RIA proposes the following levy structure:
The recommendation of the RIA with respect to the WFL levy is that an
announcement and commitment to the following tariff increases is proposed.
An increase in the existing levy on landfill from €20 in 2008 to €40 in 2010
and €75 in 2011. A levy on incineration of €22 from 2011. No levy for the
landfill of suitably stabilised biowaste from 2010.
It also proposed a maximum levy for landfill of €85 per tonne, for incineration of €45
per tonne, and of €20 per tonne for stabilized biowaste.
The study suggests that with this levy, Landfill Directive targets may be met by 2014-
2015. This reflects the sorts of lead time expected in terms of investment decisions
and developing and commissioning of facilities:
Specifically, the lead time for investment decisions, the time required from the
decision to having an operational plant and the speed with which investors
decide to invest. The Department can influence this schedule by providing
clear information about future developments of policies and by actions to
diminish procedure time for the setup of new waste treatment technology
capacity.
876 AP EnvEcon (forthcoming) Regulatory Impact Analysis on Proposed Legislation to Increase Levies
on Shopping Bags and Certain Waste Facilities, Final Report.

It acknowledges the role of a number of potential supplementary measures in
reducing the level of BMW sent to landfill and accelerating progress toward the BMW
diversion targets, including:
715
accelerated planning for MBT facilities, minimum standards for MBT waste,
support of composting initiatives, the role of incineration and increased
coverage of pay by unit and ‘three-bin’ systems nationally.
51.5.2 MSW - Pre-treatment and Residuals Management
In the Autumn of 2008, the EPA consulted upon a Technical Guidance Document
entitled Municipal Solid Waste - Pre-treatment and Residuals Management. 877 This
was subsequently finalised and issued in June 2009. 878 The document suggests that
the initiatives set out in the Guidance were intended to assist delivery of Ireland’s
obligations under the EU Waste Framework Directive (2006/12/EC), the EU Landfill
Directive (1999/31/EC), and the EU IPPC Directive (96/61/EC).
Article 6 of the Landfill Directive requires, inter alia, that: 879
Member States shall take measures in order that:
(a) only waste that has been subject to treatment is landfilled. This
provision may not apply to inert waste for which treatment is not
technically feasible, nor to any other waste for which such treatment
does not contribute to the objectives of this Directive, as set out in
Article 1, by reducing the quantity of the waste or the hazards to
human health or the environment;
For existing landfills, this was to take effect ten years after the publication date in the
Official Journal, and for new landfills, the requirement took effect two years after its
publication (i.e. on the date of transposition).
Ireland’s approach to implementing this particular aspect of the Directive appears to
have been somewhat delayed, particularly with regard to new landfills (for which the
requirement to ensure that all waste landfilled has been pre-treated has been in
place, formally, for eight years).
The general thrust of the Pre-treatment Guidelines is positive. The Guidelines have
ambitious objectives, effectively seeking to simultaneously:
1. Comply with Article 6 of the Landfill Directive;
2. Define BAT (though the term is not always applied in the conventional context);
3. Deliver on Landfill Directive targets; and
877 EPA (2008) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Consultation Draft, Johnstown Castle Estate: EPA.
878 EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Johnstown Castle Estate: EPA.
879 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999 pp. 1 – 19.
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4. Effectively push for source separation of dry recyclables and biodegradable
wastes.
Particularly in respect of the last of these four points, it is not clear that the approach
is the best mechanism. However, a reader of the document could be forgiven for
thinking that the Guidance is effectively seeking to become ‘the measure’ by which
Ireland meets its Landfill Directive targets in a fairly encompassing approach.
In general, the Guidance is well intended. However, some issues remain outstanding
on a reading of the document, including:
� It lacks a detailed description of exactly what is expected to happen when the
Guidance enters into force (as, in principle, it already has done). The date
appears to have been set more with regard to the date set for complying with
Article 6;
� It stipulates some requirements which may deliver rather marginal benefit
whilst imposing significant costs. Notable in this regard is the shift from a
stability standard of 10 mg O2/g d.m. down to 7 mg O2/g d.m. The rationale
given is that the approach is in line with continuous improvement outlined
under BAT, but this does open up a range of questions regarding, for example,
whether benefits are commensurate with costs, and how the same approach
is translated to other facilities to which the requirement to demonstrate BAT
also applies; 880
� The targets for operators are set in terms of the proportion of BMW in MSW
accepted at landfills, which might be an awkward way to specify the means to
meet Landfill Directive targets unless the management of Irish waste in future
follows the exact path which seems to have been modelled for it; and
� It would seem to be incredibly difficult (perhaps impossible) to enforce the
targets in a meaningful way, especially in the short term, and it is notable that
no discussion on the issue of regulation and enforcement is to be found within
the document.
Notwithstanding the above comments, the EPA remains confident in its approach,
and that the outcome will be satisfactory, but it is clear that the approach is very
much in the development phase.
880 In communications, the EPA expresses the view that this delivers additional reductions in
biodegradability, which is no doubt true. The problem is that in order to meet the revised target, in
principle, no change in ‘technique’ is necessarily required. Rather, the change is likely to lead to a
considerable increase in the cost of achieving the standard through increasing the necessary retention
time (although, no doubt, additional re-jigging of the facility could be made to achieve the higher
standard, but mid-operation, this would be expensive). The extent to which this benefit could be said to
be worth the additional cost of meeting the amended standard is not clear, but our own research
suggests that the opposite is likely to be the case, possibly with a substantial cost for minimal benefit
(see, for example, Eunomia (2008) ‘Biostabilisation’ of wastes: making the Case for a Differential Rate
of Landfill Tax,
http://www.eunomia.co.uk/shopimages/Eunomia%20Landfill%20Tax%20Paper%20Final.pdf )
29/09/09

The proposed minimum pre-treatment obligations for waste intended to be accepted
at MSW landfills are as follows (see Table 51-4).
Table 51-4: Generic Facility Type – Municipal Solid Waste Pre-treatment Obligations
Principal Principal
Principal Minimum Minimum Minimum pre-
pre
disposal disposal disposal route route
route treatment treatment
treatment
required required
required
Landfill Landfill Landfill 1a. Separated
at source.
Diversion of
BMW from
landfill disposal
stream, (e.g.
home
composting, 2nd and 3rd bin,
Civic Amenity
Sites, etc.,)
(see Note 1)
and
1b. Treatment
of the
biodegradable
element of
‘black bin’ prelandfilling
(See Note 2)
WtE WtE
WtE
Incinerator ncinerator ncinerator
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2. 2 Bin
collection
system
3. Mechanical
treatment of
black bin (in
large urban
centres)
4. Source
separated
collection
system
5. Mechanical
treatment of
incinerator
ashes
International Review of Waste Policy: Annexes
Required Required
Required Date Date
Date
material material
material
diversion diversion
diversion
Biodegradables 2010, 2013 & 2016 for all
landfills accepting MSW to the
extent necessary to achieve the
diversion obligations Note 3. Viz,
� For report years 2010,
2011 and 2012, a
maximum of 40% by weight
of MSW accepted at the
landfill facility for disposal
shall comprise BMW
� For report years 2013,
2014 and 2015, a
maximum of 24% by weight
of MSW accepted at the
landfill facility for disposal
shall comprise BMW;
� For report years 2016,
and subsequent years, a
maximum of 15% by weight
of MSW accepted at the
landfill facility for disposal
shall comprise BMW.
Other
16-7-09 for a landfill existing on
recyclables 16-7-2001
(glass, metals, 16-7-2001 for all other landfills
plastics) (including major extensions)
Metals By 1-1-2016
SRF Note 4
Other
Biodegradables
Other
marketable
recyclables
Metals
Other
marketable
recyclables
Prior to commencement of any
MSW incinerator
Note 1: Where a 3 bin system is not available Treatment 1b will apply to the extent
necessary to achieve an equivalent reduction in BMW.

Note 2: For the first two biodegradable waste diversion obligations (2010 & 2013), a
national 3 bin system (including for catering/ commercial sources of
biowastes) will likely ensure, on its own, that the EU Landfill Directive
diversion/treatment obligations are met through diversion from landfill of the
biodegradable dry recyclables and the organics.
Note 3: This will translate (approximately) to the tonnage of BMW accepted at
landfills in 2010 being less than 25% of the tonnage MSW generated
nationally; falling to < 15% in 2013, and < 9% in 2016.
Note 4: SRF – Solid Recovered Fuel of defined specification for use as a fuel in coincineration
plants, or other energy uses as may be approved, where
available.
Source: EPA (2009) Municipal Solid Waste - Pre-treatment and Residuals
Management: An EPA Technical Guidance Document, Johnstown Castle Estate: EPA.
In the medium- term, the establishment of a stability threshold is to be welcome.
However, the Guidance document does not spell out unequivocally that the meeting
of the stability criterion is intended to imply that the waste will be treated as ‘no
longer biodegradable’ for the purposes of the Landfill Directive. Indeed, if such a
measure had been considered earlier, this would have been the only measure
required to implement the Landfill Directive, though other instruments would have
been necessary to ensure that environmental benefits were realised through the
approach. 881 In practice, it might be preferable for the Guidance to:
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� Establish a pre-treatment requirement independently of the meeting of Landfill
Directive targets, this being specified to allow the requirements to be easily
met. 882 There does not, after all, appear to be any underpinning rationale for
suggesting that what constitutes pre-treatment one day is not pre-treatment
on another, but the Guidance appears to change the requirement for ‘pretreatment’
in line with what is required to deliver Landfill Directive targets. This
would allow the Government to discharge its obligations under Article 6 of the
Landfill Directive; and
� Establish a stability threshold for landfilling of all municipal waste, this
requirement to be met not by 2016, but by 2013. Where, in a given region, the
necessary infrastructure is absent, exemptions would be granted, but only
where applied for in advance, and at additional cost to the holder of the waste.
881 This measure alone would not necessarily have delivered the most desirable outcome. It might,
however, have delivered on the Directive targets since it would have implied that no biodegradable
municipal waste could be landfilled.
882 The UK provides one example of a country which has defined pre-treatment very loosely. Pretreatment
includes most activities which alter the nature of the waste, including sorting of a material
from the waste stream. There are definitely drawbacks in such an approach, but the urgency of
meeting the Article 6 targets might suggest a similarly simple approach. In Scotland, the regulator
effectively assumes that the pre-treatment requirements are met so that the measure implies very little
for waste producers (though some collectors have used the requirements to encourage some
customers to sort materials where they had not been doing so previously).
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The introduction of this measure in 2013 would give greater certainty that
targets under Article 5 of the Landfill Directive – especially for 2013, but also
for 2016 - would be met.
This sequencing would recognise the fact that in the short-term, the potential for
radical change is limited, but that as soon as is prudent, the requirement to pre-treat
waste to ensure that the required stability threshold is met is introduced.
51.5.3 Statutory Instrument
In August 2009, DoEHLG published a Draft of a Statutory Instrument the Waste
Management (Food Waste) Regulations 2009. Regulation 7 states:
7. (1) Subject to paragraphs (3) and (4) and without prejudice to the power of
any local authority to provide for additional policy objectives under a relevant
waste management plan or to apply more onerous conditions under a waste
collection permit or under a waste presentation bye-law, a producer shall
ensure, as a minimum, that -
(a) food waste arising on the producer’s premises is source segregated
and kept separate from non-biodegradable materials, other waste and
contaminants, and
(b) source segregated food waste arising on the producer’s premises is
-
International Review of Waste Policy: Annexes
(i) collected by an authorised waste collector and transferred to
an authorised biological treatment facility, or
(ii) subjected to biological treatment in an authorised facility on
the premises where the food waste was produced, or
(iii) transferred directly by the producer to an authorised facility
for the purposes of biological treatment, subject to the producer
being able to produce satisfactory documentary evidence, in the
reasonable opinion of the local authority, of the acceptance of
the food waste at the facility.
For the purposes of this Regulation, producers are defined under Schedule 1 of the
Draft Regulations.
The Regulations are due to come into operation in January 2010, but the Regulations
of greatest relevance (including Regulation 7) will take effect from 1 July 2010. These
Regulations are clearly well-intended, but the challenge will be to ensure both that the
roll-out of food waste collection is sufficiently rapid, and that the require treatment
capacity will be in place. The latter is the more worrying. In this respect, it is worth
noting that ‘biological treatment’ is defined as:
“biological treatment”, , for the purposes of these regulations, refers to -
(a) an aerobic process, or
(b) an anaerobic process, or
(c) any heat induced digestion process

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used for the treatment of organic waste and which produces a stabilised
output free of pathogens, which can be used as -
- a soil fertiliser and conditioner,
- a replacement for fossil fuel in energy production processes, or
- as a feed constituent in food fed to animals.
It seems clear that this is designed, in part, to facilitate inclusion of rendering. If,
therefore, sufficient rendering capacity exists, and in sufficiently dispersed locations,
the capacity requirement might be eased.
51.6 Non-waste Policies
The waste sector is affected by a plethora of regulations and instruments which affect
either all, or part of, a sector which is becoming increasingly heterogeneous. The
move away from a ‘disposal oriented’ society necessarily moves ‘the waste sector’
into a situation where, as the economy moves ‘waste’ materials into more valuable
applications, the products and services so derived effectively compete in market
sectors for these products and services. Hence, the waste sector is now intimately
affected by policies and influences coming through from the commodity markets, and
the energy / fuel markets.
There is also a development in policy, and a parallel development in the economy,
which also affects the physical size of the ‘waste sector’. This is the trend towards the
prevention of waste at source, which is becoming uppermost in the minds of
businesses, as well as in the minds of policy makers. Moves to decouple waste
generation from economic activity are likely to define a new era of waste and
resources policy. Evidence of the deepening of these trends can be found in the latest
version of the Waste Framework Directive, and in the increased significance being
accorded, within OECD countries, to the theme of Sustainable Production and
Consumption.
In this sense, the ‘waste sector’ is in direct competition with the growing trends to:
� dematerialise,
� improve resource efficiency,
� make use of ‘by-products’, and
� to achieve bottom line gains / improvements in reputational utility through
reducing waste generation.
Underpinning both of these ‘increasing overlaps’ is the growing clamour to address
the issue of climate change. Making deep cuts in emissions will not be possible in the
absence of continuing improvement in the management of resources across the
economy, and it seems likely to lead to increased pressure to:
� reduce waste generation in the first place, and
� increase the extent to which that waste which is generated is valorised, and in
ways which contribute to reducing carbon emissions.

The growing strength of these interactions makes it increasingly challenging to
understand ‘the drivers’ affecting the waste sector. This is for the simple reason that
an increasingly broad array of policies and drivers is likely to exert influence on the
waste sector as it continues to deepen the extent to which it ‘crosses over’ into
productive sectors of the economy. This will be motivated increasingly strongly by
growing concerns around climate change, these concerns themselves giving rise to
new drivers and instruments, as well as changes in existing ones.
51.6.1 Climate Change
The National Climate Change Strategy was first introduced in October 2000 and
detailed the proposed measures to be taken by Ireland to limit the emission of
greenhouse gases from all sectors of the economy. The Strategy was updated in April
2007 by the Strategy for 2007-2012. 883
The Strategy states that waste accounted for 2.5% of GHG emissions as reported
under Ireland’s inventory in 2005. It is worth noting that under the Guidelines for
National Greenhouse Gas Inventories, from the Intergovernmental Panel on Climate
Change, the majority of GHGs from ‘the waste sector’ are associated with the
emissions of the uncaptured portion of methane which is emitted from landfills.
However, it should be noted that under the IPCC Guidelines, other emissions of
relevance to the waste sector are reported in different parts of the inventory. For
example:
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1. Biological treatment processes also lead to emissions of carbon dioxide,
methane and nitrous oxide. The IPCC asks for these to be reported under the
Waste sector;
2. Where incinerators generate no useful energy, the emissions are reported
under the Waste source category;
3. Where incinerators do generate energy, their emissions are reported under the
‘Energy’ sector emissions. Although all GHG emissions should be reported
(including CO2 from non-fossil sources in waste), the emissions of greatest
relevance are taken to be the CO2 emissions from fossil sources in waste, and
the nitrous oxide emissions associated with combustion, as well as any
methane resulting from incomplete combustion;
4. Where stationary combustion of waste occurs in association with the
generation of energy, these are reported under the relevant sector under the
Energy sector. Similar considerations apply (in terms of the way GHGs are
reported) as for incineration. Activities of relevance here are, for example, the
co-incineration of solid recovered fuels or wood wastes in power stations etc.;
5. The ‘Industrial Processes and Product Use’ (IPPU) part of IPCC Guidance
covers industries such as the cement industry, and the production of most
materials and products. These all are of relevance to the waste sector insofar
as their emissions are affected by the degree to which they make use of
883 DoEHLG (2007) Ireland: National Climate Change Strategy, 2007-2012, April 2007.
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secondary materials. There is, as the authors of the IPPU Guidance note, some
difficulty in allocating emissions to the IPPU or Energy Sectors: 884
Allocating emissions from the use of fossil fuel between the Energy and
IPPU Sectors can be complex. The feedstock and reductant uses of
fuels frequently produce gases that may be combusted to provide
energy for the process. Equally part of the feedstock may be
combusted directly for heat. This can lead to uncertainty and ambiguity
in reporting.
The above suggests that although the ‘Waste Sector’ is frequently seen as a relatively
small contributor to GHG inventories, in part, this reflects the nature of the (somewhat
complex) accounting process for reporting these inventories, and that the emissions
which appear under the ‘waste’ heading are principally those from landfilling. It
should also be noted that as the waste and energy / fuel sectors deepen the extent of
their integration, and as the number of more novel processes dealing with waste and
materials continues to grow, so the approach to assigning waste-related emissions to
one or other category is likely to become more, not less, complex.
Finally, it has to be noted that national inventories are based very much on emissions
associated with domestic activity. They do not, for example, attempt to account for
the embodied energy in imported and exported raw materials, goods and services.
From a waste perspective, this raises important questions as to whether the existing
approach to reporting inventories can really motivate the most desirable response
from ‘the waste sector’. This is particularly important in countries like Ireland where
the bulk of primary materials are imported, and where the bulk of secondary
materials are exported. From the national inventory perspective, therefore, recycling
of dry recyclables might not generate much by way of benefits. From the global
perspective, however, the effect has the potential to be of considerable significance
(see Annex 63.0).
In terms of actions in the waste sector, the previous strategy planned to achieve
significant emissions reductions through diversion of biodegradable waste away from
landfill, and the improvement in landfill gas capture and utilisation. This is consistent
with the narrower view of emissions associated with the reported inventory only.
The updated Strategy also discussed the issue of residual waste. It states:
To maximise the recovery of useful materials and energy from residual waste,
the National Strategy on Biodegradable Waste identifies thermal treatment
with energy recovery as the preferred option in most Waste Management
Plans adopted by local authorities. The National Strategy on Biodegradable
Waste also recognises, particularly in the shorter term prior to the
development of adequate thermal treatment capacity, a potential role for
mechanical biological treatment (MBT). MBT should be expected to contribute
to national energy recovery policy. In the absence of energy recovery potential,
884 IPCC (2006) 2006 IPCC Guidelines for National Greenhouse Gas Inventories, Volume 3: Industrial
Processes and Product Use, http://www.ipcc-nggip.iges.or.jp/public/2006gl/vol3.html

It goes on:
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fully stabilised waste may be sent to landfill where alternative and more
suitable treatment solutions are not available.
In accordance with the methodologies developed by the Intergovernmental
Panel on Climate Change (IPCC), the CO2 emissions resulting from the
combustion of biodegradable waste are considered carbon neutral and are
not counted for the purposes of Kyoto obligations. In addition, generation of
heat and electricity from waste in thermal treatment plants reduces the need
to produce this energy from fossil fuels and will therefore displace CO2
emissions from these sources. By exploiting an indigenous energy source,
waste-to-energy plants make a contribution to national security of energy
supply.
In the current process of revising the Waste Framework Directive
(2006/12/EC), mechanisms are being considered which would encourage
waste-to-energy plants to increase efficiency to a level comparable to
conventional power plants, thereby allowing the energy content within waste
to be transformed into electricity and heat for beneficial use in accordance
with Best Available Techniques. The Government supports this approach, in
the context of the waste hierarchy, which will minimise climate impacts
through the sustainable management of waste.
Whilst broadly correct (incinerators do not generate electricity with an efficiency
approaching that of modern power plants), the above paragraphs do not mention the
fact that it rarely the case that waste combustion facilities deal only with waste that is
biodegradable. To that extent, not all the energy generated at such facilities is ‘carbon
neutral’, and the generation of energy is typically accompanied by emissions of fossilderived
CO2 from components of waste which consist of such material (under IPCC
reporting, these emissions would be reported under the Energy). Consequently,
additional GHG emissions would have to be reported under the Irish inventory, but
these do not appear to be acknowledged anywhere in the document.
In this light, one can assess the two new measures outlined in the Strategy, which
are:
� Use of waste biomass in energy production; and
� Support for waste-to-energy projects under REFIT scheme.
These are fleshed out in the document:
Waste biomass encompasses not only the biodegradable component of
municipal and industrial waste, but also the biodegradable fraction of
products and residues from agriculture, forestry and related industries. The
recently published Bioenergy Action Plan sets out an integrated strategy for
harnessing the energy potential of all bioenergy sources, including waste
biomass, to make a contribution to renewable energy.
To assist in the development of waste to energy projects, the Government is
extending REFIT to allow support for the renewable portion of mixed
renewable and nonrenewable generation. This will allow waste-to-energy
projects to obtain support for the renewable portion of the generated
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electricity. This type of hybrid support mechanism is fully consistent with the
overall ‘hierarchy of waste’ treatment approach.
Whilst these measures are well-intended, there is no guarantee that, other than
through avoiding landfilling of untreated waste, there might not be a net contribution
to Ireland’s inventory of greenhouse gas emissions. It is not clear whether the
Strategy has actually appreciated this fact. 885
51.6.2 Bioenergy Action Plan
The Bioenergy Action Plan merely reiterates what is stated in the NBS. However, the
Plan states:
The Strategy seeks to maximise the recovery of useful materials and energy
from residual waste and accordingly suggests thermal treatment with energy
recovery as the preferred option followed by mechanical biological treatment
with energy recovery and with mechanical biological treatment of fully
stabilised residue to landfill as a last resort.
To assist in the development of waste to energy projects, REFIT will be
extended to allow support for the renewable portion of mixed renewable and
non-renewable generation. This would allow, for example, a waste to energy
project to obtain support for the renewable portion of the output. This type of
hybrid support mechanism is common in other EU Member States and is fully
consistent with the overall ‘hierarchy of waste’ treatment approach.
This is a slight misrepresentation of the position in the NBS, which does indeed list
preferred options for dealing with residual waste, but it is not clear from the
document that the ordering of this list necessarily represents an explicit order of
preference.
51.6.3 REFIT
The REFIT program was introduced in 2006 and guarantees power prices for all
registered renewable power generators. Although originally intended for new-build
plants, the programme is now being extended to existing plants to promote co-firing of
biomass. The goal is to attract sufficient confidence for investment finance and loan
capital which may not otherwise be provided.
The Irish government will fund the 15-yr guaranteed feed-in tariff in compliance with
the EU Directive on Electricity Production from Renewable Sources, intending to
generate 15% of electricity consumption from renewable sources by 2010, and 33%
885 The RPS Characterisation study suggest that the contribution of plastics in residual household
waste is of the order 13.6%. Combustion of this material would release approximately 360-400kg of
CO2. If the facility generates only electricity, then even if 650kWh electricity, net, is generated per
tonne of waste (this is a high figure), then the CO2 displaced from CCGT sourced electricity will be of
the order 240-260kg CO2 equ. In other words, it is difficult to see how the conclusion could be reached
that this would benefit Ireland’s position in terms of climate change.

of electricity consumption from renewable sources by 2020. 886 Tariffs for the
schemes initially included ranged from 5.7 eurocents/KWh for large wind farm power
to 7.2 eurocents/kWh for biomass energy (see Table 51-5), with these being indexed
over time in line with changes in the consumer price index. By definition, biomass
includes the biodegradable fraction of MSW. The energy white paper has already
proposed extending REFIT to co-firing. 887 Wave energy was added to the list of
supported technologies in 2008. 888
Table 51-5: REFIT Tariffs for Electricity Categories (2006 prices)
Category Category Category
Tariff Tariff Tariff (eur (eurocents (eur (eurocents
ocents per per kWh) kWh)
Large Scale Wind 5.7
Small Scale Wind 5.9
Hydro 7.2
Biomass – Landfill Gas 7.0
Other Biomass 7.2
Wave 22.0
Note: The above reference prices will be adjusted annually in line with the change in
the consumer price index in Ireland commencing 1 January 2007.
Discussions with Regulators suggest that where mixed residual waste is concerned,
there is, as yet, no clear way of defining the contribution of biomass to the calorific
content of the waste. Hence, it is not yet entirely clear how facilities treating mixed
waste, whether as a whole, or an SRF derived from mixed waste, would be affected by
the scheme. We understand that DCENR is liaising with the EPA on this matter.
51.6.4 Summary Comment on Non-waste Policies
There has always been an overlap between waste and energy policy. The pressing
global issue of climate change, as well as geopolitical considerations of energy
886 Department of Communications, Marine and Natural Resources (2007) Delivering a Sustainable
Energy Future for Ireland: The Energy Policy Framework 2007-2020,
http://www.dcmnr.gov.ie/NR/rdonlyres/54C78A1E-4E96-4E28-A77A-
3226220DF2FC/27356/EnergyWhitePaper12March2007.pdf
887 Department of Communications, Marine and Natural Resources (2007) Delivering a Sustainable
Energy Future for Ireland: The Energy Policy Framework 2007-2020,
http://www.dcmnr.gov.ie/NR/rdonlyres/54C78A1E-4E96-4E28-A77A-
3226220DF2FC/27356/EnergyWhitePaper12March2007.pdf
888 NDP Funded Ocean Energy Initiative Launched, 15 January 2008,
http://www.ndp.ie/docs/NDP_Funded_Ocean_Energy_Initiative_Launched_-
_15_January_200/2034.htm
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security, appear to be increasing the extent, and the significance of the overlap
between policies.
It is tempting for those responsible for policies on energy and climate change to
assume that the best use of waste is to generate energy from it, and to generate as
much as possible. This is not necessarily the case. Furthermore, where climate
change is concerned, the measure of ‘best’ must also consider whether what matters
from the perspective of policy are the emissions reported to the IPCC, or the impact of
the activity from the perspective of the global environment.
In recent work in the UK for Defra, the Committee on Climate Change and the
Environment Agency, Eunomia developed marginal abatement cost curves for
greenhouse gas emissions from the waste sector. Decisions regarding the best
management route were not greatly affected by the choice of perspective. However,
this may be more coincidence than a robust outcome.
It is worth pointing out that in the medium- to long-term, a globally integrated carbon
market would make the distinction less relevant. In our analysis below (see Annex
63.0), partly for this reason, and partly because we are interested in assessing the
impacts of activities in the waste sector (as opposed to their impact on an inventory
under particular accounting rules), we have assumed that what matter is the impact
of the activity from the perspective of the global environment. This is consistent with
general practice in respect of cost benefit analysis. 889
889 It is worth noting, in passing, that the UK has recently issued new Guidance on public sector
projects regarding climate change emissions. In the suggested approach, the social costs of
greenhouse gas emissions are assumed to be different depending upon whether the emissions are
within the traded or non-traded (i.e. EU-ETS) sectors (with the two converging in 2030). So, for
example, the benefits from generating electricity would be valued at the social cost related to the
traded sector, whilst avoided transport emissions from the production of biomethane would be valued
at the social cost for emissions outside the EU-ETS). Eunomia is currently applying this methodology in
the context of a cost-benefit analysis for WRAP on the potential impact of landfill bans as applied to the
UK.
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52.0 Policies Aimed at Discouraging Disposal
In this section the main policy mechanisms that have the primary aim of discouraging
the disposal of waste are considered. The main policy instruments evaluated in this
section are:
727
• waste taxes
• bans on landfilling / incinerating specific waste types; and
• tradable allowances schemes.
We have chosen to look at these instruments in combination, viewed from a countryspecific
(rather than instrument-specific) perspective. This is because the effects of
the individual policies have to be seen in the broader context of the suite of
instruments used to influence the quantity of, and treatment of, residual waste.
There is an English saying which speaks about the desirability of ‘killing two birds with
one stone’. Textbooks in economics have tended to be sceptical about the
possibilities of realising the promises of this allegory in practical policy making ever
since the publication of Jan Tinbergen’s book “On the Theory of Economic Policy” in
1952. Tinbergen emphasised the need for having as many instruments as one has
policy objectives. This is quite important in the context of how one approaches one’s
understanding of the effectiveness of, for example, landfill bans, or landfill taxes, or
allowances for landfilling. For example, the principle objective of a landfill ban is, to
state the obvious, to ban the targeted materials from landfill. Similarly, the principle
objective of a landfill tax is to increase the price of landfill compared with other
alternative management methods.
Neither a ban nor a tax can, in and of themselves, determine how the material which
is no longer landfilled is managed. This will be determined, in general, by what we
might call ‘the background policy environment’, which will affect the relative prices of
the alternative management options. This is important in what follows. Landfill taxes
and bans do not, in and of themselves, lead directly to the promotion of recycling or
waste prevention. They can, however, assist in meeting these objectives where the
background policy environment is aligned with achieving these objectives.
It is important to note that the options available to different actors who might appear
to be targeted by these policy instruments are different depending upon who the
actor is. A householder, for example, at least where most households are connected
to the collection service (as in most countries other than Ireland) only has the choice
to segregate into different waste streams, whereas a municipality has the choice of
altering collection systems available, and procuring treatment facilities for residual
waste other than landfill. A commercial or industrial enterprise can, to some extent,
International Review of Waste Policy: Annexes

make both decisions. 890 Policies of this type do, therefore, affect different agents in
different ways, hence increasing the complexity of any analysis.
The review given here firstly outlines the policies, prior to summarising specifics
within the individual countries, then describes the environmental benefits associated
with a reduction in the quantity of waste disposed.
A caveat around the definition of ‘municipal’ waste is important to note. Differing
countries will include various waste streams in their national definitions making
comparison difficult. This is true, more generally, for statistics concerning municipal
waste derived by e.g. EUROSTAT and the European Environment Agency.
52.1 Outline of Policy
52.1.1 Waste Taxes
Waste taxes are applied to either landfill, or to both landfill and incineration. They are
usually set on the basis of the weight of material sent to the facility, but some taxes,
notably those for incineration, are now being designed with the intention of
addressing the level of air emissions in a direct manner.
Of the two main types of tax applied, landfill taxes are the more widely used of the
two. The main aim of these fiscal measures is to discourage the management of
residual waste through processes that generate significant levels of environmental
pollution, thereby promoting prevention and re-use, recycling, and alternative residual
technologies. In addition they may be implemented to force landfill operators to
upgrade technology and increase measures for pollution reduction.
Economic instruments, such as taxes, are seen as appropriate tools for implementing
the “polluter pays” principle, which has become the widely accepted framework for
internalising environmental externalities. 891 However, relatively few countries have
based their tax rates upon an estimate of the external costs of landfilling or
incineration. Some exceptions are the UK landfill tax 892 , and the Norwegian tax on
pollutants from incineration. 893
Although market based instruments, such as taxes, are deemed to be more efficient
as a mechanism for changing behaviour (because in theory, market based systems
equalize the marginal level of pollution abatement costs among firms, and hence
890 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005
891 European Environment Agency (2005) Market-based instruments for environmental policy in
Europe, EEA Technical report No 8/2005,
http://reports.eea.europa.eu/technical_report_2005_8/en/EEA_technical_report_8_2005.pdf
892 See CSERGE, EFTEC and Warren Spring Laboratory (1993) Externalities from Landfill and
Incineration, London: Her Majesty's Stationery Office.
893 See T H Martinsen and E Vassnes (2004) Waste Tax in Norway, in OECD (2004) Addressing the
Economics of Waste, Paris: OECD.
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promote cost effective means of responding to the incentive), this does depend upon
the level of the tax, and also, upon the extent to which other activities are treated in a
similar manner. In this context, we note that whereas most disposal technologies
have associated with them a net environmental cost, recycling tends to generate net
external benefits. Consequently, taxes on landfill, and to a lesser degree, incineration,
have been used pragmatically to promote recycling and other residual waste
treatments rather than to ‘internalise externalities’.
UK experience with the landfill tax has been interesting in this regard– initially set
through reference to a study on the external costs of landfill and incineration, the tax
has now departed significantly from the initial levels, and no subsequent study of an
equivalent nature has been carried out to justify the change. On the contrary, the
most recent study emerging from government actually suggested the external costs of
landfill were far lower than the tax rate which currently prevails, and lower than those
for incineration, which is subject to no such tax. 894 Although the study was carried out
in the context of a commitment to review the case for an incineration tax, no such tax
exists in the UK.
It is an interesting point that no country has considered all options for residual waste
management with a view to treating them all on an equivalent basis. Some studies
have been carried out which seek to propose alternative instrument designs for
landfill and incineration taxes. 895 However, these tend to be limited to one or other of
the main disposal options (landfill and incineration). Relatively few studies have
assessed the external costs of residual waste treatment other than incineration and
landfill (see also Annex 63.0). 896
Responsibility for fiscal policy generally resides at the level of the nation state. Hence,
taxes tend to be implemented on a national level. They can, however, be
administered, and the revenues collected, at a regional level, where such
competence resides with regions.
52.1.2 Bans and Restrictions on Landfilling and Incineration
All European countries are required to implement bans and restrictions on the
landfilling of waste as a consequence of the Landfill Directive. This outlaws the
landfilling of:
729
• Whole and shredded tyres;
• Liquid wastes;
894 HM Customs & Excise (2004) Combining the Government’s two heath and environment studies to
calculate estimates for the external costs of landfill and incineration, December 2004.
895 See, for example, A. Bjorklund and G. Finnvenden (2007) Lifecycle Assessment of a National Policy
Proposal – the Case of a Swedish Incineration Tax, Waste Management, Vol.27, Issue 8, pp.1046-58.
896 Exceptions are Eunomia and Tobin (2008) Meeting Ireland’s Waste Targets: The role of MBT – Final
Report for Greenstar, Dublin, Ireland, and in respect of climate change impacts only, Eunomia (2008)
Greenhouse Gas Balances of Waste Management Scenarios, Report for the Greater London Authority.
International Review of Waste Policy: Annexes

730
• Wastes which are explosive, corrosive, oxidising, flammable or infectious; and
• Wastes which have not been pre-treated.
Several countries have implemented bans which go beyond this, and seek to ensure
either:
1) That specific materials are not landfilled or incinerated;
2) That specific types of material are not landfilled; or
3) That only materials which meet specific criteria can be landfilled.
We refer to the first two of the above as ‘bans’ the third as ‘restrictions’.
The rationale for bans and restrictions is typically one, or sometimes both, of the
following:
1) To promote upstream changes in material use;
2) To move waste management up the hierarchy;
3) To ensure that the input materials to landfills, and to a lesser degree, incinerators,
do not lead to situations where there is increased likelihood of emissions being
problematic.
Bans and restrictions are generally implemented with fairly significant lead-times. This
reflects the view that if bans / restrictions are to be implemented, then alternative
infrastructure must be developed to enable the banned / restricted materials to be
managed in alternative ways.
52.1.3 Allowances for Landfilling / Incineration
The UK is, as far as we are aware, the only country which makes use of a system of
landfill allowances. The Landfill Allowance Schemes (LASs) operate differently in the
four devolved administrations of England, Scotland and Wales. 897 The LASs were
designed specifically in response to the Landfill Directive and were intended to deliver
compliance with the Article 5 targets under the Landfill Directive at least cost to the
UK. The rationale, therefore, is specifically to reduce the amount of biodegradable
waste being sent to landfill over time.
Allowances are issued to all local authorities with responsibility for waste disposal
(waste disposal authorities, or WDAs). In England, the allowances have been made
tradable. Sanctions are to be applied in the event of non-compliance, these being set
at punitive levels to deliver the required changes in management and infrastructure.
Some discussion has taken place in Wales concerning the possibility of restricting
incineration of municipal waste. The Welsh Assembly Government is in the process of
reviewing its waste strategy and is considering mechanisms to ensure that local
authorities do not exceed a maximum proportion of energy from waste (though where
897 At the time of writing (April 2009), the scheme has been suspended in Scotland.
29/09/09

authorities work jointly on a strategy, it seems likely that they will be able to ‘trade’
their obligations in respect of recycling and energy from waste).
This instrument is discussed in more detail in Annex 55.0.
52.2 Where Have the Policies Been Applied, and Why?
52.2.1 Waste Taxes
There are many waste taxes in place around the world, though mostly to be found in
Europe. A number have been in place for many years, but many countries outside of
the EU have just implemented, or are about to implement, such policies. The only
non-EU countries found to have had a policy in place for a number of years are
Norway and Australia, with Norway being heavily influenced by EU policy
developments.
The basis for, and levels of, waste taxes vary from country to country. The basis for
taxation is usually weight, and in the case of some incinerator taxes, levels of
emissions of specified pollutants.
Where landfills are concerned, most taxes are set on a ‘per tonne’ basis. In Europe,
landfill tax levels vary from €0 per tonne to around €85 per tonne. Some countries
opt for a two tier structure whereby there is a differentiation between inert wastes,
and active, or combustible, wastes, the latter being a net contributor to global
methane emissions if left to degrade anaerobically in landfill.
Incineration taxes range from €3 per tonne to €49 per tonne, though several taxes
are not set with the tonnage as the tax base.
In Europe, some of the policies mentioned in this section have been developed partly
in response to the Landfill Directive, though several countries have taxes which predate
the Directive. 898 In those countries with such policies in place for a longer period
of time, motivations have included:
731
• diminishing landfill void space;
• problems with old landfills (and the desire to generate revenues to address
these);
• internalisation of externalities;
• incentivising a move, in the management of waste, up the hierarchy;
• shifting relative prices between landfill and incineration (in favour of
incineration); and
• arguably (though this is not often so baldly stated), as the taxes have bedded
in, revenue raising for the Finance Ministry concerned.
898 Directive 1999/31/EC on Landfill of Waste.
International Review of Waste Policy: Annexes

Common to these policies is a desire to discourage disposal of (untreated) waste to
landfill.
Not all countries with landfill taxes have chosen to implement incineration taxes.
However, no country with an incineration tax in place does NOT also have a landfill
tax, and this is set, in all countries, at a higher rate than for incineration.
Notwithstanding this point, and reflecting the discussion above, it is by no means
clear that such a treatment is justified on environmental grounds in an unequivocal
manner, especially if what is landfilled is pre-treated to render it less problematic in
the landfill. Following the increased attention on GHG emissions (due to climate
change impacts), and recognising that the emissions from incinerators can vary in
line with input materials and with the nature of flue gas treatment used, incineration
taxes are now emerging which seek to directly address these externalities.
52.2.2 Regulations and Bans
Many countries also operate bans and restrictions. Typical targets for landfill bans
are:
732
• Source segregated materials;
• Biodegradable wastes;
• Combustible wastes
• Household waste; and
• Municipal waste.
Most restrictions of interest to this study (excluding those of a more technical nature)
relate to the biodegradability of waste sent to landfill, sometimes allied to a restriction
on the calorific value of waste that may be landfilled. These are in place in Austria,
Germany, Finland and Italy, whilst the UK includes measures to assess the
biodegradability of waste under the LASs (see below).
52.2.3 Landfill Allowances
The only landfill allowances schemes are those of the devolved administrations of the
UK. These apply to biodegradable municipal waste, with the quantity allowed to be
sent to landfill restricted in line with allowances issued to WDAs. The biodegradability
of waste landfilled is assessed through an accounting mechanism which is based
around an estimate of the biodegradability of municipal waste, and the
biodegradability of specific components of waste which are dealt with through
recycling and composting.
52.2.4 Country Specific Characteristics: Summary
The policies in place vary from country to country. Table 52-1 highlights which policies
are in place in which country.
Note that the rates for commercial and industrial wastes are the same as for MSW in
most countries.
29/09/09

Table 52-1: Summary of Measures by Policy Approach (MSW)
Country Country
Landfill Landfill Tax Tax
Incineration Incineration Incineration Tax Tax
Landfill Landfill Ban
Ban
Year Year Year of
Tax Tax Rate Rate (MSW,
(MSW, Date Date of
of Tax Tax Rate Rate Rate (MSW,
(MSW, (Date (Date of of Announcement)
Announcement)
Implementation
Implementation
Implementation €/tonne)
€/tonne) Impleme Implementation
Impleme Impleme ntation
€/tonne
€/tonne Date Date of of Implementation
Implementation
South Australia 1993 10.8
Western Australia 1998 3.4
New Zealand 2008 4.3 ($10) 899
Austria 1989 87/26 900 1996 7 2004
Finland 1996 30 2005 901
Germany 2001
Hungary 2000
Italy 1996 26902 2003/
2007
Belgium-Flanders 1987 60 7 2005
899 Calculated using an exchange rate of 0.430524 on 24/04/2009.
733
International Review of Waste Policy: Annexes
Scope Scope of of Ban
Ban
Biodegradability and
other criteria
Biodegradable and
compostable waste
Biodegradability and
other criteria
Biodegradability and
other criteria
Unsorted wastes
Sorted and non-sorted
wastes for recovery
Combustible residual
fraction from sorting
900 The €87 per tonne figure was applied for untreated MSW and is now more or less moribund. The €26 per tonne is for material which has undergone
mechanical biological treatment. For MSW to be treated thermally the tax is €7 per tonne which results in a broadly equal position between MBT and
incineration when one considers that the tax applies to the landfilled output from the MBT process, not the input. If 25 – 30 % of the plant input is landfilled,
then the tax on MBT broadly equates to that on incineration.
901 This ban is in revision at present
902 Highest rate is given. Lowest rate set regionally can be €10.

Country Country
Landfill Landfill Tax Tax
Incineration Incineration Tax Tax
Landfill Landfill Ban
Ban
Year Year Year of
Implementation
Implementation
Implementation
Tax Tax Rate Rate (MSW, (MSW,
(MSW,
€/tonne)
€/tonne)
Date Date of
of
Impleme Implementation
Impleme Impleme ntation
Tax Tax Rate Rate Rate (MSW,
(MSW,
€/tonne
€/tonne
(Date (Date (Date of of Announcement)
Announcement)
Date Date of of Implementation
Implementation
Implementation
Scope Scope of of of Ban
Ban
Wastes suitable for
incineration
Belgium-Wallonia 3 2004 Various
Denmark 1987 50 1993 44 1997 Combustible waste
France 1992 9.15 2002 ‘Ultimate Waste Flows’
The Netherlands 1996 85 1996
Various, incl
household waste
Norway 1999 40 Pollutant based From mid-2009 Biodegradable waste
Sweden 2000 43 2006 49
2002
2006
Combustible waste
Organic waste
Czech Republic 1991 16 1997: Paper, 2004: BMW
Estonia 1990 8 2008
Slovakia 1992 7.9
Slovenia 2001 2001
Spain – Catalonia 2003 10 2008 5 None
United Kingdom 1996 45
Under consideration by
devolved administrations
Source: Eunomia
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It is illuminating to note that in all those countries which the EEA categorises as
having ‘high incineration rates’ that incineration is subject to a tax. However, as the
Table also indicates, in all cases, taxes on landfill are higher and /or bans on
landfilling certain materials are in place. It is also interesting to note that in many
nations with landfill bans in place, landfill taxes are also in place, and are at high
levels. The UK has argued against the deployment of an incineration tax on the basis
that incineration is likely to be required to meet landfill directive targets. This position
seems not to adequately appreciate that a tax on incineration is entirely consistent
with the deployment of incineration, with incineration made more likely where the
policy instruments affecting landfilling (e.g. differential tax rates, or the deployment of
bans on landfilling) tip the economic and regulatory balance firmly in favour of
incineration.
Figure 52-1 shows the level of taxes for landfilling of non-inert materials in Europe (as
well as increases already planned).
Figure 52-1: Current and Planned Increases in Non-Inert Landfill Taxation in Europe
Landfill Tax (€ per tonne)
735
90
80
70
60
50
40
30
20
10
0
Netherlands
Belgium (Fl)
Denmark
International Review of Waste Policy: Annexes
UK
Sweden
Norway
Belgium (Wal)
Finland
Austria
Country
Italy
Ireland
Czech Republic
Landfill Tax (Euro/tonne) Planned increases
Source: Table 52-1: Summary of Measures by Policy Approach
Spain - Catalonia
A brief summary of the policy mechanisms will be described in the same order
presented in Table 52-1. This is to so that interesting factors can be easily drawn out
and used to weigh up the different instruments in use. Detailed descriptions for all
the countries concerned follow this in Sections 52.2.4.1 to 52.2.4.20.
� Australia: Both Southern and Western Australia have landfill taxes in place.
Southern Australia levies the tax depending on whether the waste is
Swiss
France
Estonia
Slovakia

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cosmopolitan 903 or not, and Western Australia has rates for putrescible waste
per tonne, and inert waste by volume (in m 3);
� Austria: A differential waste tax was initially implemented with the aim of
encouraging an improvement in the level of technology used at landfills in
order to reduce pollution. Following this, a landfill ban on waste with Total
Organic Content (TOC) above 5% was introduced. Waste which fails to meet
this criterion has to be either incinerated, or treated in mechanical biological
treatment (MBT) facilities. Where the waste is treated in MBT facilities, the
resultant residue – which has to meet a specified threshold for biological
stability - is subjected to a landfill disposal tax of around one quarter of that
untreated waste.
� Finland: A landfill tax was introduced against the backdrop of low waste
management costs. The aim was to stimulate waste minimisation and material
reuse, and to reduce landfilling. Furthermore a ban on landfilling was
introduced in 2005 to reduce landfilling of BMW and to divert any other
materials that could cause environmental damage in the long term through
being landfilled. Two routes can be adopted to comply with the BMW ban:
firstly, by introducing separate food waste collections; secondly, through
stabilising the waste through MBT prior to landfilling.
� Germany: A comprehensive landfill ban was introduced as large quantities of
waste were being landfilled due to its relatively cheap cost. It includes
untreated household waste, and wastes with total organic carbon content
>5%. The ban was known about for 12 years prior to its implementation,
allowing for approaches to adapt in order to manage the regulation.
� Hungary: A landfill ban was introduced in 2000. It covers several material
steams such as hazardous and organic waste. The ban on organic waste has
been staggered over time to 2016, most likely to allow for collection systems
and infrastructure to develop.
� Italy: A waste tax to promote materials and energy recovery was followed by
landfill bans to reduce hazardous materials deposited in landfills. The tax rate
can be set regionally within National limits and the revenue is used to fund
environmental programmes and regional protection agencies.
� Belgium - Flanders: The system in Flanders is the most complex out of all the
policies evaluated in this report, but also one of the most effective. Landfill
bans are in place for; unsorted household waste; waste collected for the
purpose of recovery or that which is fit for recycling; and incinerable residues
from sorting processes. In addition incineration bans are in effect for unsorted
waste and waste fit for material recovery or recycling, except some types of
biowaste that have a calorific value above 11.5 MJ/kg and is used for the
creation of renewable energy. The Flemish landfill and incineration tax regime
includes 37 different regimes and tariffs. In essence, these have been
903 ‘Cosmopolitan’ waste is broadly similar to municipal waste.

737
implemented to make treatment options that are more environmentally
damaging more expensive.
� Denmark: There has been a general waste tax operating in Denmark for over 2
decades now. It is differentiated so that landfilling is expensive, incineration is
less expensive and recycling is untaxed. Since the implementation of the
waste tax, a ban on landfilling combustible waste has also been introduced.
The overall aim is to promote the use of waste as a source of energy for the
extensive public owned district heating systems.
� France: There is a general pollutants tax in force in France that includes
landfilling of waste. Less tax is payable at landfills with environmental
certifications, and more is payable at unlicensed sites. A landfill ban was
introduced due to the slow effect of the tax policy, and covers several
hazardous waste streams, and all biodegradable waste.
� The Netherlands: Landfill bans and a tax were implemented concurrently with
the aim to reduce waste sent to landfill and support capacity of the State’s
incinerators. The instruments are specifically designed to target combustible
waste so that as little as possible is landfilled.
� Norway: A waste disposal tax was introduced in Norway to reduce methane
emissions from landfill and incentivise the recovery of energy produced during
incineration. Environmental objectives are supported by incentivising methane
gas capture at landfills and increasing pollution control technology on
incinerators through a pollutant based taxation system.
� Sweden: There have been a range of policies applied in Sweden over time. The
first was a landfill tax to reduce the amount of material landfilled. Following
this, a ban on landfilling combustible wastes was introduced to reduce
environmental burdens and promote resource efficiency. A few years later a
landfill ban on compostable waste was introduced, but exemptions are in
place for waste with a Total Organic Content (TOC) of less than 10%. The
Swedish energy policy heavily incentivises the use of waste as a source of
energy for district heating systems. Most plants were operating in a heat only
mode, so in 2006 an incineration tax with differentiable rates was introduced
to give plants generating electricity as well a competitive advantage, but also
overall to further promote materials recycling and MBT treatments.
� Czech Republic: All waste landfilled is subject to a basic rate of tax and there is
a higher rate for any hazardous waste. There are also bans on the landfilling of
paper and all BMW.
� Estonia: There is a tax levied on all waste landfilled. This is expected to rise
sharply over the next few years. A ban on unsorted municipal waste is also
expected from 2008.
� Slovakia: There is a slightly different landfill taxation system in place in
Slovakia which would incentivise municipalities to implement separate
collections systems for recyclables. The level of taxation decreases
incrementally as up to 5 separate waste streams are separately collected in
the relevant area. So a municipality that separately collects 5 components will
International Review of Waste Policy: Annexes

738
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pay less landfill tax on the residual stream than one that separately collects
only 1 component.
� Slovenia: A landfill tax is in place to raise revenue for technical improvement of
landfills, improvements in infrastructure and environmental remediation. A
landfill ban has been implemented to restrict hazardous waste from certain
categories of landfill, and to limit the deposition of BMW.
� Spain (Catalonia): There is a landfill and incineration tax in this region of Spain.
Its structure means that areas with separate biowaste collections have a
reduced landfill or incineration tax. The revenue is to be used directly to
improve collection and treatment infrastructure or for awareness raising
campaigns.
� United Kingdom: The main policy in place is a landfill tax. It is differentiated
between inert and non-inert wastes, and for the previous 9 years has been
increased though an escalator whereby increases are announced in the
budget to take effect over future years. Some of the revenue is used to fund
environmental projects and programmes relating to waste management. The
UK has also introduced the Landfill Allowance Schemes for the devolved
administrations. This is described further in Section 55.0.
Data for this review has principally been gathered from European based studies, as
there are many policies implemented in the EU. Landfill levies are in place in many
areas of Australia. However, we have focused on the States of South and Western
Australia as they have both produced evaluation studies, thus some of their effects
can be analysed.
52.2.4.1 South Australia
Zero Waste SA was established on July 1, 2003 with the primary objectives of
promoting waste management practices that, as far as possible, eliminate waste or
its consignment to landfill, advance the development of resource recovery and
recycling, and are based on an integrated strategy for the State. 904 The function of
Zero Waste SA is, amongst other things to, from time to time, advise the Minister
about the amount to be charged by way of the levy under Section 113 of the
Environment Protection Act 1993.
The use of landfill levies is the most prominent economic instrument being used in
Australia to influence waste management behaviour. The levy in South Australia
remained fairly static at around $4-5 per tonne until 2003, since when, it has seen
incremental increases to $23.40 for metropolitan waste and $11.70 for nonmetropolitan
waste. 50% of the revenue is paid into the Waste to Resources Fund
pursuant to the Zero Waste SA Act. Of the remaining 50%, 5% goes to Environment
Protection Fund as outlined in the Environment Protection Act to fund specific
904 Hyder Consulting (2007) Review of Solid Waste Levy, Report for Zero Waste SA,
http://www.zerowaste.sa.gov.au/waste_levy_review.php

environmental projects, and 45% is paid into EPA recurrent funding for operations
and environmental programs.
Objectives for the use of landfill levies internationally and in Australia have variously
comprised:
739
� Revenue generation;
� Reduction in downstream environmental impacts associated with waste
disposal; and
� Promoting volumetric recycling and disposal targets, as a surrogate for
reducing upstream environmental impacts associated with resource
exploitation and material processing.
Decisions in relation to the amount of the landfill levy and how it should be applied
rest with the South Australian State Government.
Recent studies suggest that 65% of waste material is being recycled or put to better
use rather than being disposed of to landfill. However, and despite the many
initiatives aimed at increasing sustainable resource recovery in South Australia,
significant parts of the overall waste stream continue to be landfilled, with about 1
million tonnes of waste going to landfill each year.
52.2.4.2 Western Australia
The Landfill Levy was introduced by the Western Australia State Government in 1998
following an amendment to the Environmental Protection Act 1986. 905 A particular
feature of the Landfill Levy is that the funds generated by the imposition of the levy
are hypothecated, or earmarked, for strategic programs in the areas of management,
reduction, reuse, recycling, monitoring or measurement of waste.
The levy revenues are credited to the Waste Management and Recycling Account and
the funds are disbursed in accordance with approval of the Minister for the
Environment and Conservation on advice from the Waste Management Board of
Western Australia.
The levy has two functions:
� to increase the comparative price for landfill and to make recycling more cost
competitive; and
� to provide resources for the state government to strategically invest in
recycling initiatives.
The Landfill Levy is an important policy instrument for achieving the Waste
Management Board’s vision of towards zero waste, as outlined in the policy
document Towards Zero Waste in Western Australia.
905 Four Scenes (2007) Landfill Levy Review, Prepared for the Waste Management Boards of Western
Australia.
International Review of Waste Policy: Annexes

In 2006 the Government of Western Australia implemented a decision to
progressively increase the landfill levy from AUS $3 per tonne to AUS $9 per tonne for
putrescible waste and from AUS $1 per cubic meter to AUS $9 a cubic metre for inert
waste to by 2010-11. The first increase occurred in October 2006, with unit increases
of $1 for putrescible, and $2 for inert each year from 2008-09.
52.2.4.3 Austria
The Austrian Waste Management Act 2002 includes the basis for both federal and
provincial waste management plans. The policies that are of significance in the
current context are:
740
� The waste disposal fee for inter alia landfilling of waste, first implemented in
1989; and
� The ban on untreated waste going to landfills: Waste with Total Organic
Content (TOC) above 5% has to be either incinerated or treated in mechanical
biological facilities from 2004.
The Austrian landfill tax (‘Altlastensanierungsbeitrag’, or AlsaG for short which refers
to the respective legal matter Al Altlastensa Al
sa sanierungsgesetz sa
- Clean-Up of Contaminated
Sites Act) was introduced to incentivise landfill operators to upgrade the level of
pollution control in place, improve greenhouse gas abatement and clean up
contamination at their sites, with the revenue generated used for investment in waste
management and to reduce waste disposed of at landfills.
The legal basis for the policy was the 1989 Clean-Up of Contaminated Sites Act that
was introduced following the emergence of environmental problems such as those at
the ‘Fischer Deponie’, a waste disposal site where hazardous chemicals had been
dumped, and which threatened the drinking water resources of some 500,000
inhabitants. 906 The proponents of the Act foresaw increased work in surveying and
identification of potentially problematic sites (often, old landfills), and the need to
generate funding to contain and treat any potential or emerging problems.
The tax was introduced in 1989 and since 1996 its rates have been differentiated
according to the technical quality of the landfill site and to the type of waste. 907 In its
most recent form, the tax is applied at a much lower rate where the waste has been
subject to mechanical biological treatment (€26 per tonne) and meets specified
criteria for landfilling, whereas for waste which has not been pre-treated, it is € 87 per
tonne (this is more or less redundant today). There are also further surcharges of €29
per tonne for cases where i) the landfill has no basement seal system or no vertical
906 Umweltbundesamt (2000), Management of contaminated sites in Western Europe, Report for the
European Environment Agency.
http://reports.eea.europa.eu/Topic_report_No_131999/en/topic_13_1999.pdf .
907 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
29/09/09

enclosure; and ii) municipal waste landfills are operated without a landfill gas
collection and treatment system. 908
The legislation clearly states that the aim of the waste tax is to finance the
containment and treatment of contaminated sites. Austria is the only European
country where revenues from a landfill tax are exclusively used for this purpose. 909
The activities supported include:
741
� The identification of problem sites;
� The administration of those sites;
� The direct containment and clean-up of sites;
� The construction, or upgrading, of waste treatment plants at landfill sites; and
� The development of new technologies for containment or treatment.
It is the owner or operator of the landfill site who is responsible for paying the tax, or
anyone carrying out structural work.
The Ordinance on Landfilling was introduced in 1996. This legislation was introduced
with the intention of banning certain materials from landfilling and included wastes
such as:
� Sludgy, pasty and fine-grained waste;
� Liquid waste (except leachate);
� High inflammable and explosive waste;
� Gasses under pressure;
� Substances leaching heavily on contact with water;
� Infectious waste from hospitals or similar medical; and
� Waste for which the content of hazardous substances exceeds certain limit
values.
In addition, the Ordinance set a limit on waste which could be landfilled that stated
that a ban applied to any waste with a carbon content in excess of 5%. This would
have implied an effective ban on all residual waste. However, an exemption was
explicitly designed for waste ‘originating from mechanical-biological pre-treatment,
that is disposed in separated areas within a mass waste landfill site, if the upper
calorific value gained by combustion of the dry matter is below 6000 kJ/kg. The
mixing of waste originating from mechanical-biological pre-treatment with materials
908 EIONET: European Topic Centre on Resource and Waste Management (2007) Austrian Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Austria
909 Umweltbundesamt (2000) Deponieabgaben im europäischen Vergleich, Federal Environment
Agency - Austria, Vienna.
International Review of Waste Policy: Annexes

or waste of low calorific value in order not to exceed the limit value, is not
admissible.’
In order to determine criteria for an environmentally sound process design and the
suitability of MBT material in accordance with the requirements of the Austrian
Landfill Ordinance, a Guideline for the Mechanical Biological Treatment of Waste 910
was elaborated by a working group chaired by the Ministry for Agriculture and
Forestry, Environment and Water Management. For obvious reasons, the focal points
for this guideline are different to those for compost. In particular, attention is given to
the characteristics which represent a desirable treatment from the point of view of
the end-point – the landfill – in particular, the respirometric. Equally, as made clear in
a report for the Umweltbundesamt, the lower limit on calorific value has the effect
that the biodegradable fraction of waste is split from higher calorific fractions which
are generally being used for thermal recovery. 911
The Ordinance, therefore, allows for the landfilling of waste where a fermentability
threshold was not exceeded (replacing the limit on carbon content). The limit value
suggested that the static respirometric index, measured using the AT4 methodology
(giving the cumulative biological activity over 96 hours), should be less than
7 mg O2 / g dm for all landfilled waste. The rationale behind this restriction was to
‘reduce reactions in the landfill body and respective production of landfill gas and
leachate’. 912 Either the carbon content of the waste, or its respirometric activity, could
be reduced by incineration or mechanical biological treatment facilities in order to
satisfy the conditions of the Ordinance.
An incineration tax is also applied in Austria. The level of the tax is set at €7 per
tonne. Because the Austrian Guidelines effectively require a splitting of the
biodegradable and non-biodegradable fractions, the quantity of material being
landfilled from an MBT process might be expected to be of the order 25-30% of the
input. A tax at €26 per tonne on 0.3 tonnes of stabilised waste landfilled is equivalent
to a tax on MBT of €6.50 to €8.66 per tonne of waste input to the MBT plant. This is
more or less equivalent to the €7 per tonne figure applied for incineration.
The Austrian system has been very effective in setting out what it aimed to do and
has evolved to appreciate the environmental externalities associated with landfilling
of waste with and without pre-treatment.
910 Federal Ministry for Agriculture and Forestry, Environment and Water Management (2001)
‘Guideline for the mechanical-biological treatment of waste’, delivered for notification to the European
Commission, 12 October 2001.
911 Lahl, Uwe, Barbara Zeschmar-Lahl and Thomas Angerer (2000) Entwicklungspotentiale der
Mechanisch-biologischem Abfällbehandlung, Monograph M-125, Wien, June 2000.
912 EIONET: European Topic Centre on Resource and Waste Management (2007) Austrian Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Austria
742
29/09/09

52.2.4.4 Finland
In 1993, two years before Finland joined the EU, the Waste Management Act of 1978
was updated and split into two complementary pieces of legislation, the Waste Act
and the Waste Decree. 913 A year later, the Waste Tax Act was implemented requiring
that tax was to be paid on waste deposited at landfills. The tax, on the landfill of
waste, was implemented in 1996 to stimulate waste minimisation and material
reuse, and to reduce landfilling.
Since January 2005, the tax rate has been € 30 per tonne. The tax was introduced
against a background of a low cost of waste management, so that the increases had
a significant impact on the cost of disposal. 914
A landfill ban was introduced following the 2006 amendment (202/2006) to the
Government Decision on Landfills (861/1997). This amended Decision set general
restrictions on the depositing of wastes in landfill. Since that time, in addition to those
wastes banned under the Landfill Directive, household waste, or similar, where the
biodegradable fraction has not been separately collected may not be deposited in a
landfill. The pre-treatment requirement effectively requires the waste to be stabilized
before landfilling. The instrument does, therefore, afford the municipalities some
flexibility giving them the choice to decide whether separate collections or new
treatment infrastructure are most viable, but with the same aim of reducing the
quantity of BMW landfilled.
Anecdotal evidence from waste officers in Finland suggest that the ‘ban’ in current
form is, however, ineffective an unenforceable. An EEA report notes: 915
743
The government enacted a landfill ban for certain waste streams partly as a
result of the EU's debate on the Landfill Directive. The ban prohibits landfilling
biodegradable waste 'from which the major part of the biodegradable waste
has not been collected separately'. The wording is rather vague and does not
refer to the aim of removing a minimum of 80 % organic matter before waste
is landfilled, which features in the country's Waste Plan 2002. As a result, it
leaves room for interpretation of what 'the major part' is. Although, the 2002
Waste Plan provided that more detailed restrictions for the landfill of
biodegradable waste would be passed in 2003, this was not implemented till
2006.
Consequently Finland is redesigning a stricter ban to be implemented in the near
future. The most recent National Waste Plan states: 916
913 EIONET: European Topic Centre on Resource and Waste Management (2007) Finland Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Finland
914 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
915 EEA (2009) Diverting Waste from Landfill: Effectiveness of Waste Management Policies in the
European Union, EEA Report No 7.
International Review of Waste Policy: Annexes

744
29/09/09
4.1.1 4.1.1 4.1.1 The The The legislative legislative legislative instruments instruments instruments used used used in in other other countries countries
for restricting the
disposal of biodegradable waste at landfills (for example, a ban on placing
biodegradable and combustible waste at landfills) will be examined. At the
same time, urgent changes to the Government decision on landfills will be
prepared so that the restrictions concerning the disposal of biodegradable
waste at landfills can be put on a concrete basis, which would make the
practical application of the restriction more efficient. Guidelines will be drawn
up on how to determine the proportion of biodegradable waste of the total
amount of landfilled waste.
No further details are available at this time.
52.2.4.5 Germany
See Annex 53.0 below.
52.2.4.6 Hungary
Hungary has a range of legislation to support its national waste management plan. 917
Of relevance for this section is a ban on landfilling that was introduced in 2000. The
ban includes all materials restricted under the EU Landfill Directive.
Since 2003, the EEA reports landfilling of organic wastes has been partially banned,
and that the amount permitted is gradually reducing in line with the interim targets for
BMW. 918 It is not clear that this is indeed a genuine ban.
52.2.4.7 Italy
The Italian Environment Act covers the waste sector, along with many other
environmental sectors. 919
The two relevant policy instruments here are:
� Tax on waste disposal introduced in 1996. This includes landfilling and
incineration without energy recovery; and
� A ban on landfilling introduced that is to progressively cover 12 material
streams.
916 Ministry of the Environment (Finland) (2009) Towards a Recycling Society: The National Waste Plan
for 2016, Ministry of the Environment, Helsinki, Finland, April 2009,
http://www.environment.fi/download.asp?contentid=102639&lan=EN
917 EIONET: European Topic Centre on Resource and Waste Management (2007) Hungary Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Hungary
918 EEA (2009) Diverting Waste from Landfill: Effectiveness of Waste Management Policies in the
European Union, EEA Report No 7.
919 EIONET: European Topic Centre on Resource and Waste Management (2007) Italy Waste
Factsheet, Accessed 16 th October 2008, http://waste.eionet.europa.eu/facts/factsheets_waste/Italy

The objectives of the waste tax are the prevention of waste production and the
material and energy recovery from waste. The tax is calculated on the basis of the
weight of the waste disposed at landfills or at incineration plants without energy
recovery. The law also established a tax level between a minimum and maximum. For
the first year (1996) the tax level was applied at the minimum level: this tax level is
applied in every case in which the competent regional administration has not yet
implemented a landfill tax. Currently there is a tax on MSW only, and can be set
between 10€ and 50€. At least 20% of the tax revenue is required to be used by the
local administration (the region) to finance environmental projects, such as:
745
1. Waste prevention;
2. Projects on recycling and recovery of materials and energy from waste;
3. Reclamation of contaminated sites and abandoned industrial sites;
4. Recovery of degraded sites;
5. Financing of the regional environmental protection agencies; and
6. Institution and maintenance of protected natural areas.
Only 10% of revenues are destined for the Provincial Government.
The detailed structure of the tax is delegated to the competent regional
administrations, which have the possibility to change three important elements:
1. The tax level;
2. The types of waste to which the tax applies; and
3. Then uses to which the tax revenue will be devoted.
Some regions have established – through regional acts – an increase in the tax if
targets for separate collection are not achieved.
The aim of the landfill ban is to divert certain waste streams from landfill to other
options, and to decrease the amount of waste landfilled. The material streams that
are included are mainly as prescribed under the Landfill Directive, but also include
the following:
� Waste containing or contaminated by PCBs, PCTs, and the like with
concentrations > 25 ppm;
� Waste containing or contaminated by PCDD or PCDF, with concentration > 10
ppb;
� Waste containing Ozone layer depleting substances;
� Waste containing substances from research activities, with unknown effects
on human health and the environment;
� Waste with a Calorific Value > 13,000 kJ/kg, from 1/1/2007, however this
was later postponed.
A particular aspect of the Italian taxation policy is that once the policy had been
implemented regional offices are able to increase the tax level within bands initially
set by central government to suit local circumstances. This gives an indication of the
awareness of local issues and an ability to act flexibly at regional level.
International Review of Waste Policy: Annexes

52.2.4.8 Country-specific Characteristics: Belgium (Flanders Region)
The Flemish policies are described in Annex 54.0 below.
52.2.4.9 Belgium (Wallonia Region)
In Wallonia, , , the Decrees of 18 March 2004 and 30 March 2006 by the Walloon
Government provide for a phased introduction of landfill bans. Table 52-2 presents a
general summary of this phasing. Article 3 of the decree likewise provides that a pretreatment
of waste materials, in order to sorting out of the reusable fractions, must
be carried out before the waste can be landfilled.
Of specific importance is Article 5 of the decree that provides for deviations in case of
force majeure and in exceptional circumstances. The shortage of adequate treatment
facilities in Wallonia is explicitly acknowledged as an exceptional circumstance. The
application for a deviation needs to be sufficiently justified and the licensing
authority, the ‘Office Wallon des Déchets’ (OWD), the Department of Waste Materials,
shall impose demands relating to the landfill and the requirement to look for
alternative treatment possibilities in the future.
Table 52-2: Summary of the Landfill Ban in the Walloon Region
Date Date of of of implementation implementation implementation of of
of
the the landfill landfill ban
ban
1 July 2004
1 January 2007
1 January 2008
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Waste Waste flows flows flows
Comments
Comments
Separated household
waste and non-hazardous
industrial waste, e.g.
organic waste, paper and
cardboard, timber waste.
Packaging waste
Waste from pre-treatment
and sorting facility
Non-pre- treated fine
residual household waste
and non-shredded bulky
waste
1 January 2010 Shredded bulky waste
Art. 2i of the Decree
Source: OVAM (2007) Market Study of the Final Treatment of Residual Household
Waste and Industrial Waste Similar to Household Waste in Flanders and
Neighbouring Regions: a Summary Report, August 2007.

52.2.4.10 Country-specific Characteristics: Denmark
The Danish Environmental Protection Act Consolidated Act No. 753 of 25 August
2001 contains provisions on the regulation of waste. 920 The Act states that the local
(municipal) council shall be in charge of waste management.
The following polices are in place in Denmark:
747
� A tax on waste, implemented 1987. The waste tax is differentiated so that it is
most expensive to landfill waste, cheaper to incinerate it, and tax exempt to
recycle it. No tax is levied on hazardous waste, contaminated soil or waste that
is covered under the Statutory Order on biomass waste; and
� A ban on the landfilling of waste suitable for incineration - implemented 1997.
Each local council is responsible for establishing capacity for waste management and
for providing information on how to dispose of the waste produced within the local
council, irrespective of whether this waste originates at households or trade and
industry.
The incineration of municipal waste has a long history in Denmark; the first waste
incinerator being built in 1903. 921 In 1993 it was decided that waste should be
preferred to other sources of energy when producing heat as a by-product of electric
generation, and in 2005, waste incineration, producing heat and electricity, supplied
4% of the total energy consumption in Denmark. The energy-to-waste facilities are
subject to a cost coverage principle, which means that they show neither a profit nor
a loss. 922
Waste in Denmark is subject to ‘flow control’ and is managed by not for profit
companies that deal with the incineration of waste and operation of district heating
systems. There are approximately 40 inter-municipal waste management companies
in Denmark. The companies operate so that any profit gained from selling waste heat
is used to off-set the costs of operating the plant. The remaining income is generated
from gate fees charged by the plants. Gate fees are amongst the lowest in Europe,
despite the existence of incineration taxes.
The extensive district heating systems that are in place in the country already
purchase heat on the open market, however, there are price ceilings placed on the
sale of heat from EfW plants so as to protect the heat consumers, and to ensure the
heat is generally the lowest regional price so as to encourage its use.
Denmark has a general tax on waste that is split into three tiers and primarily has the
aim of encouraging recycling. The lowest tier is for recycling and set at a zero charge.
An incineration tax has been introduced to discourage its use in preference to
920 EIONET: European Topic Centre on Resource and Waste Management (2007) Hungary Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Hungary
921 European Environment Agency (2007) The road from landfilling to recycling: common destination,
different routes, http://reports.eea.europa.eu/brochure_2007_4
922 RenoSam (2006) The Danish Model, News from DBDH
International Review of Waste Policy: Annexes

ecycling. Initially, the rates for landfilling and incineration were the same, but since
1993, the levy has been differentiated (with a higher rate for landfilling). The tax rate
is now set at € 44 /tonne. To be an effective deterrent from landfilling waste the
landfill tax has been set higher at € 50.7 /tonne.
As with incineration plants and district heating networks, new landfills must be owned
by public authorities, and whoever operates a landfill site must ensure that all costs
related to establishment and operation, including financial security and after-care of
the site of a period of at least 30 years are covered by the payment collected for
landfilling of the waste.
In 1997, landfilling of waste suitable for incineration was banned. The aim was to
move waste from landfill to incineration, and to ease the capacity demand on
landfills. It has been reported that the regulation has been very successful in shifting
waste from landfilling to incineration. 923
The long history of incineration and the widespread district heat networks in Denmark
have provided a context for the development of these policy measures. The view
adopted is that heat is in demand, and where centralised sources are in place, it
makes sense to use waste as the source of energy to generate that heat.
52.2.4.11 France
The French system is based on policies such as the Code de l’environnement (Partie
législative) that defines waste disposal and recycling. 924 The instruments currently in
place in France are:
748
� Landfill Tax implemented in 1992 and included in the General Tax on Polluting
Activities (TGAP) from 1999. The aim is to prevent waste landfilling and to
boost waste reduction and recycling, forms of waste management more
compatible with the environment; and to fight against illegal practices;
� Ban on Landfilling from 2002 - to divert critical waste flows from landfills.
The 1975 law on Waste Disposal and Material Recovery (75-633) first stated the
intention, through the French Waste Management Plan, to ban all but so-called ‘final
waste’ from landfill by 2002. However, no decisive action to implement this policy
was taken.
The policy was also meant to streamline French waste management, increase waste
recovery rates to 50% and become part of a self-financing waste management
strategy. Essentially the aim was to make landfilling totally unpopular on financial
grounds by passing through the ‘price signal’ to landfill users. Indirectly it was also
923 EIONET: European Topic Centre on Resource and Waste Management (2007) Denmark Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Denmark
924 EIONET: European Topic Centre on Resource and Waste Management (2007) France Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/France
29/09/09

meant to finance the Modernisation Fund for Waste Management (MFWM) 925,
created in 1993.
The tax was introduced in 1993 at FRF 20 per tonne. The rate increased to FRF 60 (€
9.15) per tonne in 1995, which is still the standard rate for municipal and
comparable waste. Since 2003, sites with EMAS or ISO 14000 certification pay a
reduced rate of € 7.50 per tonne. Non-authorised landfills pay a rate of € 36.58 per
tonne of municipal waste, which is also the rate for special industrial waste. Since
1999, the tax is part of the TGAP (Taxe Générale sur les Activités Polluantes) 926 .
Initially the revenue was used to promote innovative methods of waste treatment and
to equip local authorities with sufficient funds to;
749
� develop innovative technology for household and assimilated waste treatment;
� install waste treatment facilities, especially those which make use of
innovative technology;
� aid to local authorities on whose territory a new treatment plant for household
and assimilated waste is built; and
� aid the upgrading public landfill sites and restoring contaminated sites.
Perhaps unsurprisingly, given the low rate of the tax, relatively little impact was felt
from the tax measure. Hence, in 2002, a ban on untreated waste to landfills was
introduced as part of the TGAP policy. This was to enable France to meet the EU
landfill directive by reducing the quantity of, and level of biodegradability of, waste
disposed of at landfill.
The ban is intended to cover ‘ultimate wastes’. One study defines these as: 927
ultimate waste flow as a waste flow that is no longer suitable to be treated under
the current technical and ec economic ec onomic conditions, in particular, through recovering
of the component part that can be revalued or by the reduction of its
contaminated character.
The same study notes that the ban is not really enforced in Nord Pas-de-Calais in
France:
Household and equivalent waste flows may, in principle, no longer be disposed of
on the landfill site. However, this ban is not strictly enforced because of the lack
of adequate incineration capacity and the importance that NPDC attaches to the
925 The MFWM was run by the ADEME to support investments in local communities’ related to (1)
innovative household/assimilated waste treatment equipment (development or setting-up); (2) the
upgrading of landfill sites; (3) remediation of contaminated sites; and (4) new treatment facilities.
926 ECOTEC (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
927 OVAM (2007) Market Study of the Final Treatment of Residual Household Waste and Industrial
Waste Similar to Household Waste in Flanders and Neighbouring Regions: a Summary Report, August
2007.
International Review of Waste Policy: Annexes

750
proximity principle. Furthermore, the definition of ultimate residual flow leaves
room for interpretation.
The situation in France is interesting because of the high level of illegal dumping sites
that were present at the time of introduction of the tax. The local authorities
continued to tax them without forcing closure or licensing. The landfill ban,
implemented several years later, may well have been developed to strengthen the
seemingly weak effects of the tax.
52.2.4.12 The Netherlands
The Environmental Management Act (1993) introduced an integrated approach to
environmental issues, and sought to account for their interrelationships. 928 The main
features were that it elaborated a hierarchy of management options based on
Lansink’s Ladder, and made separate collection of organic household waste
compulsory.
In 1996, simultaneously, two instruments were implemented:
� A tax on the landfill of waste – aimed at making disposal the lest attractive
option economically; and
� A ban on landfilling covering 35 categories of combustible or recyclable
wastes.
The sequence of events is set out as below:
Landfill bans;
- 1995: Publication of the Decree on a Ban of Landfill of Waste
- 1995-1999: Ministerial decrees that regulate that the Decree is applicable to
specific waste streams that were exempted when the Decree was first
published. For many waste streams the Decree went into force directly.
However, for some waste streams no treatment technology or enough capacity
was available. Once a relatively cost-effective technology became available,
landfill of a specific stream would be banned.
- 1997: Publication of a Decree on Landfills and Ban on Landfill of Waste, that
combines the Decree of 1995 with another Decree that arranged permitting
procedures for landfills 929 .
- Related EU Directives: 1999/31/EC (L182, 16.7.1999), Directive on Landfill
of Waste and 2003/33/EC (PbEG L11, 16.1.2003) on Criteria and procedures
on the acceptance of waste on landfills
Landfill taxes;
928 EIONET: European Topic Centre on Resource and Waste Management (2007) Netherlands Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Netherlands
929 See: http://wetten.overheid.nl/cgi-bin/sessioned/browsercheck/continuation=29495-
002/session=532342511010954/action=javascript-result/javascript=yes (accessed 23 March 2006)
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751
- 1995: Publication of a regulation on the basis of the Law Environmental Taxes
- 1995-now: various changes in the taxation level to the level in force now
(84,78 Euro per ton for incinerable waste and 13,98 Euro per ton for other
waste) 930
The waste tax covers the disposal of waste to landfill and incineration. 931 The level of
taxation for incineration was, however, set at zero and is remains at this level to this
day. The landfill tax was introduced at a level of NLG 29.20 (€13.25) per tonne.
After 1997 two bands were introduced specifying rates for combustible and noncombustible
wastes. Its current rate, since 2005, is € 84.78 per tonne for
combustible wastes. The rate for non-combustibles is € 13.98 per tonne, the same
rate applying to certain other categories of waste, including hazardous waste and
waste with a density of more than 1,100 kg per m 3 (typically, inert materials). 932 The
evolution in these rates is shown in Figure 52-2.
Figure 52-2: Changes in Dutch Landfill Tax since Implementation
Tax Rate, €
100
90
80
70
60
50
40
30
20
10
0
International Review of Waste Policy: Annexes
Changes in Dutch Landfill Tax since Implementation
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008
Year
Year
Combusitble
Non-combustible
930 See
http://www.minfin.nl/default.asp?CMS_ITEM=MFCWD970934C51F83449B932D1E9D4D61AF6DX22
X55355X16#afvalstoffen (accessed March 22, 2006).
931 European Commission (2008) “Taxes in Europe” database, Accessed 12 th October 2008,
http://ec.europa.eu/taxation_customs/taxinv/welcome.do;jsessionid=LZJpKGQB7ZRrngVLZhhS5cx7w
CkJBrCFL21f5r9t65bYTG6JhKQ5!-966966153
932 ECOTEC (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.

A general ban on recyclable and combustible waste was introduced in 1996. 933 The
ban covers around 35 material streams and includes organic and household waste,
paper & card, tyres, ELVs, batteries and various hazardous wastes. The purpose was
to reduce the amount of waste being landfilled.
The ban was introduced in the context of the dioxin emissions scandal in the late
1980s. The Dutch were rebuilding their incineration capacity with much higher
pollution control mechanisms, and regulatory measures were needed to ensure that
incineration capacity would be used, and hence, that the high investment cost would
not be wasted.
The amount of waste generated in the Netherlands has been reported as ‘decoupled’
from Gross Domestic Product (GDP) since 2000. 934 The amount of waste landfilled
halved from 1995-2003. For incineration, the opposite trend was observed. The total
amount of waste incinerated in 1995 was 4.8 Mt and in 2003 it had increased to 8.2
Mt. As the incineration capacity remained constant over this period, as reported in the
IVM study below, the remaining waste was exported for incineration:
752
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‘In 1995 and 1996 the last incineration plants were built, and from that time
the government maintained a moratorium for ‘traditional’ grate incineration
plants. New plants using more energy efficient technologies (such as coincineration
or gasification) were allowed, but no new incineration plants
became operational until 2003. So, the total number of waste incineration
plants was constant at 11 in the period 1997-2003’.
In certain areas incineration capacity was limited so a number of waste producers
were unable to dispose of their combustible wastes thus exemptions were made so
that operators could continue to landfill waste so that it was not illegally dumped. As
the incineration capacity increased (to around 5.4 Mt), and the export of waste was
unconstrained due to the harmonisation of waste trading via the European Waste
Shipment Regulation (WSR, 259/93), exemptions became harder to obtain.
The main purpose of these policies was to shift waste from landfill and to ensure
continued supply for the national incineration plants so that the capital expenditure
outlaid in upgrading them was not wasted. This is why waste has been categorised
into combustible and non-combustible fractions for the purpose of the ban and the
landfill levy. This classification is meaningless in countries that are not advocating
widespread EfW use, and may be counterproductive from an environmental
perspective.
Other points to note about The Netherlands are; that there is a general good
awareness of the environment and waste related issues will be of social importance;
but also that the swift implementation of the tax and ban led to under-capacity of
933 Eunomia et al (2007) Household Waste Prevention Policy Side Research Programme, Final Report
for Defra.
934 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.

esidual treatments, and thus exemptions were needed to allow licensed disposal in
landfill.
52.2.4.13 Norway
A waste disposal tax was introduced in Norway in 1999. This was to reduce methane
emissions from landfill and incentivise the recovery of energy produced during
incineration, hence reducing the environmental damage caused by final waste
treatment.
The landfill tax was introduced at around 40 € for those landfills with a high
environmental performance, and at a slightly higher rate for those which fell below
this level. The incineration tax was initially set at the same level as for landfilling
where there was no energy recovery. The tax level drops as a greater proportion of
energy is recovered from the process. Since 1999 new laws have been included that
introduce tax rebates for landfill operators who recover and sell energy generated
from the methane gas captured.
The incineration tax has also been changed to reward operators who reduce pollution
below legal limits specified in the EU’s 2001 Waste Incineration Directive. This is
done by changing the mechanism so that it is emissions based and focuses on
pollutants such as CO2, NOx, SOx, particulates and dioxins. The CO2 charge (€4.85) is
per tonne of waste delivered to an incineration plant, and all the additional 14
pollutants are taxed on the basis of the quantity of pollutant emitted. The changes
were introduced in such a way that the overall revenue take would be more or less
unchanged, and so that no major change to the balance of residual waste treatments
would be occasioned by this.
Norway has announced a ban on the landfilling of biodegradable wastes which is due
to take effect very shortly. There was some debate as to whether the policy of choice
should be an outright ban, or whether the policy should be more in line with the
German and Austrian restrictions, but the outcome appears to have favoured a tighter
approach.
52.2.4.14 Sweden
The Swedish policies stem from the Environment Act (1998:808) and the Waste
Regulation (2001:1063). 935 The relevant policies are:
753
� A tax on landfilling of waste from 2000 - to make landfilling a less attractive
option and to increase the economic incentives to reduce waste amounts, and
use waste treatment methods that are preferable from environmental and
natural resources perspectives;
� A ban on landfilling – introduced in 2002 for combustible wastes, and
amended in 2005 to include compostable wastes; and
935 EIONET: European Topic Centre on Resource and Waste Management (2007) Sweden Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Sweden
International Review of Waste Policy: Annexes

754
� A tax on incineration from 2006 - modelled on the fossil carbon content of fuel
and on the level of electrical generation.
The Swedish landfill tax was introduced in 2000 at a rate of about € 27 (250 SEK)
per tonne. The primary aim was to halve the amount of waste landfilled by 2005 from
1994. 936 In 2002 the rate was increased, and also again in 2006, to the current level
of around € 45.5 (435 SEK). The tax is designed so that all waste going to landfill is
taxed. Waste that exits a landfill or is used as construction material qualifies for a tax
reduction. Waste for which no treatment method (other than landfilling) is applicable
is also subject to tax.
Concurrently with the tax increase in 2002, a ban on sorted combustible waste was
introduced. The purpose of this was to reduce the environmental impacts associated
with landfilling and increase resource efficiency. In 2005 the ban was extended to
include all organic wastes. Certain types of waste are exempted from the ban, for
example, waste with a Total Organic Content (TOC) of less than 10% (dry matter).
The capacity of Swedish incinerators increased substantially between 1996 and
2002. 937 Much of this was due to the substantial district heating systems already in
place whereby the source of the heat was switched from fossil fuels to waste-derived
incineration plants, some operating as CHP facilities, others operating with heat-only
boilers (HOB). One of the main drivers for this change was the Swedish energy policy
that gives incentives for the use of energy derived from waste, over fossil fuels, via
the economic instrument of taxation. 938 In total, 30 MSW incineration plants exist in
Sweden; 16 are CHP plants, 13 are HOB, and one plant delivers steam to an
industrial user. 939
A tax on waste-to-energy incineration of municipal solid waste (MSW) was introduced
on July 1, 2006. The was designed to give CHP plants an advantage compared with
HOB, but also to increase the incentive for material recycling, including biological
treatment, and to effectively align the taxation of incineration with the energy taxation
system, where incineration of wastes of fossil origin was not burdened with energy
and CO2 taxation as other fossil fuels are. 940
The amount of the tax is calculated based on a model of the content of fossil material
in the waste. 941 The amount of the tax is dependent on whether the taxable
936 OECD (2004) Environmental Performance Reviews: Sweden. Paris: OECD.
937 European Environment Agency (2007) The road from landfilling to recycling: common destination,
different routes, http://reports.eea.europa.eu/brochure_2007_4
938 T. Ekvall, M. Olofsson, J. Sahlin and J. Sundberg (2005) Driving forces for import of waste for energy
recovery in Sweden, http://www.bvsde.paho.org/bvsacd/cd43/matias.pdf
939 Avfall Sverige (2008) Swedish Waste Mangement,
http://www.avfallsverige.se/se/netset/files3/web/P01.m4n?download=true&id=2371_94867351
940 Swedish Ministry of Finance (2006) Proposition 2005/06:125 Beskattning av visst hushållsavfall
som förbränns, m.m. (Taxation of some household waste for incineration), Ministry of Finance, 2006
941 Avfall Sverige (2008) Swedish Waste Mangement,
http://www.avfallsverige.se/se/netset/files3/web/P01.m4n?download=true&id=2371_94867351
29/09/09

incineration facilities produce electricity and, if so, how efficiently. For facilities
without electrical production, the tax is € 49 (SEK 487) per tonne, which would then
decrease with increased electricity production. At 15 per cent electricity production,
the tax is approx. € 8.3 (SEK 83) per tonne, at 20 per cent approx € 7.6 (SEK 76) per
tonne. After the introduction of the tax material recycling, including biological
treatment, has increased from 34.6 per cent to 48.7 per cent and waste -to-energy
has increased from 38.1 to 46.4 per cent.
As with other Northern European countries there are substantial district heating
systems in place in Sweden. The evolution of the policies have been firstly to reduce
landfilling and to promote the use of RDF as a fuel for the heating systems, then to
incentivise more efficient operation of incinerators and moreover to promote
materials recycling and MBT facilities as they become economically viable. In all
cases the costs of disposal of the least attractive options was made more expensive.
Both the landfill ban of waste with TOC greater than 10% and the incineration tax
based on fossil carbon content require measurements or assumptions to be made
regarding these values. This could make the implementation and monitoring of the
systems more difficult to manage.
52.2.4.15 Czech Republic
Act 188/2004 Coll. Is the implementing policy in the Czech Republic that deals with
the handling and disposal of wastes. 942 Policies in place are:
755
� A levy on landfilling introduced in 1991. The holder of waste pays a levy when
depositing waste in a landfill. This fee consists of two components:
• the basic fee; and
• the risk-based fee.
The basic fee applies to all categories of waste (and is differentiated into two
levels, one for municipal and other non-hazardous waste, and the other for
hazardous waste). The risk component of the fee is paid only for hazardous
waste. The operator of the landfill transfers the collected revenue to the
collectors, i.e. the municipality in whose cadastre the landfill is located (basic
component) and SEF CR (risk component). The basic fee, that includes
municipal waste, has risen steadily since implementation, and is now at €16
per tonne, and is set to rise 25% to €20 in 2009.
52.2.4.16 Estonia
The relevant legislation is the Waste Act (RT1 I 2004, 9, 52) 2004. 943 Its main
features are:
942 EIONET: European Topic Centre on Resource and Waste Management (2007) Czech Republic
Waste Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Czech_Republic
International Review of Waste Policy: Annexes

756
� Landfills are classified according to EU framework (Art 34, Waste Act); and
� A prohibition on the deposit of untreated waste in landfills (Art 35, Waste Act)
The two policy instruments that are important are:
� A levy on municipal waste disposal implemented in 1990. The aim was
promotion of waste recovery, and for the financing of waste management
projects via Environment Investment Centre and local budgets. However, the
rates are very low. At the time of first implementation, the levy was set at only
€ 0.10, per tonne but this has now risen to a current level of €8 per tonne; and
� A ban on unsorted waste from landfilling, was applied in 2008.
There were a large number of small illegal landfills in Estonia in the late 1990’s
mainly due to a lack of sound collection and recycling infrastructure. Since then, most
have closed and several modern, large-scale landfills have opened with EU funding.
However, only one of these is equipped with landfill gas capture.
The levy rates were initially kept low so as to not stimulate an increase in illegal
dumping on ‘waste fields’ (areas covered with 1-2m of residual bin waste). The
municipal infrastructure has increased and now waste generators are charged € 8
per tonne on new landfills and €16 per tonne on ‘old ones’. The landfill tax is thought
to be a ‘very powerful instrument’ and is expected to be raised significantly over the
next few years. 944 The plan is to reduce the number of landfills to 3-4 in the long-term.
The implementation of the ban is not entirely straightforward. The EEA states:
29/09/09
The Waste Act (2004) introduced a ban on landfilling untreated waste
(including mixed municipal waste). However, until 1 January 2008 it only
applied to landfills in counties that had an established facility for treating
municipal waste. In reality, only the landfills in the Harju County (in Tallinn
area) met this requirement.
52.2.4.17 Slovakia
In Slovakia a charge for deposition of waste to landfills was introduced in 1992. 945 It
was updated in 2004 and includes scheduled increases from 2008. The revenues
are earmarked for the protection of the environment in the relevant municipality, and
must be used for waste management purposes only.
943 EIONET: European Topic Centre on Resource and Waste Management (2007) Estonia Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Estonia
944 P. Eek – Waste Depertment, Ministry of the Environment of Estonia (2008) Implementation of EU
Landfill Directive in Estonia, Presentation given in 2008,
www.rec.org/REC/Programs/REREP/PEIP/docs/national_workshop...14/.../waste_2.3_p-eek-landfill landfilldir-impl-ee-_budva-14-05-08.ppt
945 EIONET: European Topic Centre on Resource and Waste Management (2007) Slovakia Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Slovakia

There are several bands in this tax system, which include hazardous, inert and
municipal waste streams. The level of taxation for MSW decreases as components
are removed for recycling i.e., if there is a collection system in place that removes 2
components such as paper and glass, the tax will be lower than for the residual
stream. This is most likely to incentivise the uptake of collection systems for
recyclables. The rates applicable are shown in Table 52-3.
Table 52-3: Landfill Tax Rates in Slovakia
757
Material Material Stream Stream
Tax Tax Rate, Rate, Rate, € per tonne
Hazardous Waste 26.3
Inert Waste 0.26
MSW with no separation 7.89
MSW with 1 component separated 7.10
MSW with 2 components separated 6.32
MSW with 3 components separated 5.53
MSW with 4 components separated 4.74
MSW with 5 components separated 3.95
Other Waste 5.26
Green Waste 10.53
52.2.4.18 Slovenia
The Environment Protection Act provides the basis for the following policies: 946
� A ban on landfilling introduced in 2001 for the purposes of limiting organic
waste going to landfill; and
� A tax on landfill introduced in 2001, for sanitation, technical adjustment of
the landfill, construction or purchasing of equipment. The tax must be paid by
the operator.
The landfill ban currently includes:
946 EIONET: European Topic Centre on Resource and Waste Management (2007) Slovenia Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Slovenia
International Review of Waste Policy: Annexes

758
� Liquid waste, infectious waste, explosive waste;
� Tyres; and
� Waste which does not meet the acceptance criteria depending on landfill type
i.e. regulates biodegradable and hazardous waste.
Since 2001, when the Decree on Environmental Tax for Environmental Pollution
Caused by Waste Disposal was adopted, all landfill operators of hazardous, nonhazardous
and inert landfill are obliged to pay tax on the disposal of waste. If the
operator invests the collected revenue in improved sanitation and technical
upgrading of the landfill, or in construction, or in purchasing of equipment, then the
Ministry for Environmental and Spatial Planning- Environmental Agency of the
Republic of Slovenia confirms the investments, and the operator is not obliged to
transfer the collected tax revenue to the state budget.
Since 2001, the investments in public infrastructure (landfilling of municipal waste)
increased annually to €13 million per annum. The largest share was spent on landfills
for municipal waste and for hazardous waste, with significant investment also into
collection and recycling schemes.
52.2.4.19 Spain (Catalonia)
Taxes for Landfills are not generally implemented in Spain. However, Madrid does
have taxes for hazardous waste (€ 10 per tonne), domestic waste (€7 per tonne) and
C&D waste (€3 per tonne). 947
In the region of Catalonia, there is also a landfill tax. The tax is levied on the sending
of municipal waste to waste disposal facilities controlled by public or private sector
located in Catalonia. The taxpayers are the local authorities that operate, or contract
out the operation of, the municipal waste management service, and municipal waste
producers. The tax is implemented at the time the holder delivers the waste to the
landfill and at the point where the facility operator accepts it.
The tax rate is €10 per tonne of waste sent to landfill for municipalities with separate
biowaste collection, and €20 per tonne for those that do not, and is adjusted annually
by means of the Catalan Finance Act. 948
Also in Catalonia, from 2008, an incineration tax has been implemented, the first of
its kind in Spain. The tax rate will be €5 per tonne. However, there will be an
increased tax rate of €15 per tonne for those municipalities that do not have in place
separate collection of biowaste, but could have introduced it according to the regional
waste strategy.
At least 50% of the revenue generated must be used to reduce the cost for
municipalities of managing biowaste coming from household source separation, or to
947 EIONET: European Topic Centre on Resource and Waste Management (2007) Spain Waste
Factsheet, Accessed 16 th October 2008, http://waste.eionet.europa.eu/facts/factsheets_waste/Spain
948 Agencia de Residus de Catalunya website (2008) Waste disposal tax, Accessed on 23 rd October
2008, http://www.arc.cat/en/municipals/canon/index.html
29/09/09

educe the quantity, or improve the quality of refuse, especially reducing the presence
of organic materials. The remaining revenue must be dedicated to the separate
collection of biowaste, and the separate collection and recycling of other waste
fractions, or to other forms of valorisation or to awareness-raising campaigns.
The rates applicable for refunds (for 2008) are shown in Table 52-4.
Table 52-4: Refund Rates Used in Catalunya
Concept Concept Concept
Rate Rate
Rate
1. Biowaste treatment 33.5 €/tonne
2. Treatments to reduce the quantity or improve the quality of
refuse
5 €/tonne
3. Biowaste separate collection* 12 €/tonne
4. Paper/cardboard separate collection 21 €/tonne
5. Active recycling centre in the municipality
5.1 Per inhabitant:**
5.2 Per tonne:
0.32
€/inhabitant
Wood 12 €/tonne
Flat glass 12 €/tonne
Batteries 160 €/tonne
Vegetal oil
* Quantities are considered net of impurities.
** A correction factor is applied in municipalities with high seasonal population.
80 €/tonne
The rate for concept 3 is multiplied by a coefficient dependent on the level of
impurities in the collected biowaste. In addition, the rates for concepts 3, 4 and 5.1
are adjusted using the coefficients that are based on the size of the municipality.
These criteria are revised annually, and will continue to be so, since the revenue from
the tax depends on waste generation and recycling levels, which vary from year to
year.
52.2.4.20 United Kingdom
The principle instruments of interest in the UK are:
759
� The landfill tax – implemented in 1996 to encourage a reduction in landfill of
waste and promote recycling, and also to raise revenue. The tax on municipal
waste is paid by households and local authorities and the tax on commercial
and industrial waste streams are paid by business sectors;
� The Landfill Allowance Schemes (LAS) – introduced in 2005 to meet the
landfill targets for reduction of BMW (See Section 55.0);
� A ban on landfilling of certain animal wastes as part of the ABP regulations
implemented in 2003 (though this has effectively not been introduced); and
� A ban on hazardous waste disposed of at non-hazardous landfills by 2004, a
ban on the landfilling of used tyres from 2006, and a ban on landfilling of
liquid wastes from Oct 2007 (to meet requirements of the EU Landfill
Directive).
International Review of Waste Policy: Annexes

The UK Landfill Tax was introduced in October 1996. It is a tax on all landfilled waste,
with some exemptions. It is applied at two rates: a standard rate, applied to a range
of materials, including household waste; and a lower rate, applying to specific
‘qualifying materials’, typically, those deemed to be ‘inert’, including materials such
as rubble.
The tax affects all sectors of the economy. As the levels of landfilling at the
introduction of the tax were very high, the tax could be considered a ‘general disposal
tax’, as most residual waste was (and still is) disposed of to landfill.
The aims of the tax as set out in the UK Waste Strategy were:
760
29/09/09
‘to ensure that landfill costs reflect environmental impact thereby encouraging
business and consumers, in a cost effective and non regulatory manner, to
produce less waste; to recover value from more of the waste that is produced;
and to dispose of less waste in landfill sites (DoE and WO 1995, 12).’
From this, it seems clear that the primary aim was, in the early stages, to internalise
external environmental impacts.
Ecotec’s report on taxes and charges in the EU indicates that the tax level and the
proposals for the tax were widely consulted on before being introduced. 949 The initial
rates at which the tax was set were:
� Inert Wastes (lower rate tax) £2 per tonne
� Active Wastes (standard rate tax) £7 per tonne.
Mixed wastes are taxed as active wastes even if much of the material is ‘inert’ if
certain minimal levels of mixing are exceeded.
A report describes how the tax has evolved as follows: 950
� 1993 – The introduction of the Landfill Tax was preceded by an assessment of
the external costs associated with landfill and incineration and by work
assessing waste management options in the UK after the introduction of such
a tax. 951 A proposal for a tax based on a percentage of disposal costs (an ad
valorem tax) emerged, with the order of magnitude of the tax heavily
influenced by the external costs study;
� November 1994 – Government makes clear its intention to introduce the
Landfill Tax;
� March 1995 - a consultation process was undertaken to elicit the views of
industry, environmentalists, and local authorities. Its major outcome, as
949 ECOTEC (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
950 Eunomia et al (2007) Household Waste Prevention Policy Side Research Programme, Final Report
for Defra
951 CSERGE, Warren Spring Laboratory and EFTEL (1993) Externalities for Landfill and Incineration: A
Study by CSERGE, Warren Spring Laboratory and EFTEL. Coopers & Lybrand (1993) Landfill Costs and
Prices: Correcting Possible Market Distortions.

761
announced in the November 1995 Budget, was a change in the tax design,
from a percentage of disposal cost (ad valorem) system, to a weight-based tax.
Furthermore, it was intended that there should be no exemptions from the tax;
and
� November 1995 – Budget announces the tax will be introduced in October
1996.
At the outset typical disposal fees pre-tax for municipal wastes, or non-inert industrial
wastes, were between £7-£25 (approx €11.20-€40.00) per tonne so that the tax
implied an increase in price of between 30-100%. The level of taxation for non-inert
wastes (i.e. those that degrade to produce GHGs) was increased by the method of an
annual price escalator that was first introduced in 1998. Since then the magnitude of
the escalator has increased (initial £1 per tonne escalator over five years to current
£8 per tonne per year over 6 years). As of April 2009, the tax rate is £40 (approx.
€50) per tonne. The tax will rise to a maximum level of £72 per tonne in April 2013.
The tax rate for inert wastes has remained relatively steady with only a 50p increase
to £2.50 per tonne in 2007.
Implemented through central government via the Chancellor of the Exchequer (HM
Treasury) and the annual budget, Figure 52-3 shows the change in tax levels for
active and inert wastes from the implementation of the policy in 1996 to 2013 when
the current escalator expires.
Figure 52-3: English Landfill Tax (£/tonne)
Tax Rate, £
80
70
60
50
40
30
20
10
0
International Review of Waste Policy: Annexes
Changes in England's Landfill Tax since Implementation
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Year
Year
Active Rate
Inert Rate
The revenues generated from the tax were initially used to allow for a decrease in the
national insurance rate, along with a scheme to fund waste management research
and improvement projects around landfills. Those wishing to utilize the funds had to
register as environmental bodies under an organization named ENTRUST.
With the end of this scheme some 4-5 years ago the funds are now directed to the
Landfill Communities Fund, WRAP, LASU, WIP and various other Defra schemes under

the heading of the Business Resource Efficiency and Waste (BREW) programme.
Since its launch, 12 years ago, the landfill tax has raised over £700m for these types
of projects that benefit the environment. 952
52.3 Key Organisations Involved in Implementation and
Management
52.3.1 Levies
Table 52-5 below shows examples for certain countries considered in this section of
the report, to give an indication of the types of organisations involved. These are
generally environmental agencies and also, revenue collection authorities (regional or
national) to ensure collection of revenues. It was not thought necessary to include all
the countries described in this section of the report.
Table 52-5: Organisations Involved in Implementation and Management
762
29/09/09
Country Country Country
Key Key Key Organisations
Organisations
Organisations
� Rate: HM Treasury (input from Defra)
England
� Collection: HM Revenue and Customs
� Rate: Ministry of Finance, Section Excise and Duty
� National Agency for Environment and Energy
France
Management (ADEME)
� Collection:
� Rate:
The Netherlands � Collection:
� VROM (Ministry of the environment)
� Finnish Ministry of the Environment
Finland
� Collection: Finnish Customs Authority (Regional offices)
Sweden � Swedish Environment Agency
Hungary � The Ministry of Environment and Water
� Ministry of the Environment Revenue Collection
Slovakia
� District Environmental Office
� Slovak Environmental Inspectorate
Typically, it is the Finance Ministry or Department which has the power to set the
rates for levies. They may do so in consultation with the Environment Ministry or
Department. Responsibility for collection tends to fall with Customs authorities, often
because these are imbued with powers of inspection and of entry onto premises,
which allow them to check that levies are being accounted for in the correct manner.
52.3.2 Bans
Usually bans are overseen by the regulatory body for waste management or pollution
prevention and control.
952 Edie (2006) Landfill Tax celebrates a decade of environmental support, Accessed on 29 th October
2008, http://www.edie.net/news/news_story.asp?id=12180&channel=0

52.4 Evaluation Studies Available
Information used within this review draws heavily from the following sources:
763
� Eunomia’s Household waste prevention policy side research programme report
for Defra qualitatively describes the effects of the English landfill tax and
Dutch tax and ban. It draws on prior research and comments critically on the
effectiveness of the policies to date. Eunomia, The Environment Council, Öko-
Institut, TNO, Atlantic Consulting (2007) Household Waste Prevention Policy
Side Research Programme, Final Report for Defra.
� Ecotec’s study on taxation and charges in Europe includes an in depth review
of landfill taxes in England, France and Austria. It includes sections on Tax
Design, Process Development, Organisation Roles, Intentionality of the Tax,
Effectiveness, Equity and Distribution, Effect on Producers / Consumers /
Trade / Employment, Internal Market, Competition / Revenue Issues, and
Costs. However, some significant changes have now occurs since the report
was published. Ecotec (2001), Study on the Economic and Environmental
Implications of the use of Env. Taxes & Charges in the EU.
� The Dutch Environmental Ministry produced a report in 2005 with an ex post
assessment of the waste tax and ban. Bartelings, H., P. van Beukering, O.
Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk (2005)
Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by
Ministerie von VROM, November 24, 2005.
� European Environment Agency (2005) Market-based instruments for
environmental policy in Europe, EEA Technical report No 8/2005,
http://reports.eea.europa.eu/technical_report_2005_8/en/EEA_technical_re
port_8_2005.pdf
� European Environment Agency (2007) The road from landfilling to recycling:
common destination, different routes,
http://reports.eea.europa.eu/brochure_2007_4
� German case study compiled by the Öko-Institut
� Flemish case study (Flanders Region) compiled by Arcadis
52.5 Environmental Benefits
The consequences of taxes and bans are difficult to separate out from the effects of
other instruments in place at the same time. As stated previously, a ban on landfill
does not dictate where the material which can no longer be landfilled will be sent.
Other policies, and market conditions, will dictate how this material is managed.
Where levies are concerned, in principle, it would be possible to structure levies so as
to ‘rig’ the waste management market and make specific options more desirable than
others. To some degree, this is reflected in the structure of levies. However, in
practice, most countries use a range of complementary instruments to influence the
relative desirability of competing options. Consequently, whilst levies make specific
options less desirable, other policies will influence how materials subject to a levy are
dealt with.
International Review of Waste Policy: Annexes

Another feature of levies is that they generate revenue. Many of the countries which
deploy levies do so with the intention of using some or all of the revenue for specific
purposes related to waste management (or other environmental purposes).
The environmental impact of levies and bans, therefore, depends upon both:
764
a) the extent to which the structure of levies, or the ban, or both, makes the
activities targeted by the levy and/or the ban less desirable;
b) the way in which other policies affect the desirability of alternative
management routes (i.e., those not subject to levies and bans); and
c) where levies are concerned, the effects of the use of levy revenue in terms of
environmental improvement.
Regarding a) and b), own-price and cross-price effects are important. Other things
being equal, a levy would be expected to have consequences which relate to the size
of the levy. A ban effectively acts like a levy set at infinity for the treatment subject to
the ban. The own- and cross-price effects will be different for different materials and
for different waste streams, the reason being that the range of alternatives, as well as
the costs thereof, vary by material and stream.
The basic premise is that as landfill prices rise, less waste will be disposed to landfill
and more will be minimised (probably very little in the case of municipal waste), reused
and sent to alternative treatments.
The degree to which this occurs relates to the alternatives available and their price
relative to that of landfill. Important here is the cross-price elasticity of demand. This
shows how sensitive recycling or mechanical biological treatments (MBT), for
example, are to changes in landfill tax. Where technologies are widely available and
where they are competitive in cost, the response can be expected to be considerable.
Similarly, where the opposite is true, the shift away from landfill will be more limited.
When the cost of disposal increases above the cost of treatment via an alternative
method, this price, know as the substitution price, will determine the marginal waste
management route, as any rational agent will pursue the most cost effective option
(as long as the risks aren’t to great) unless, for example, they are restricted by lengthy
municipal contracts.
Some studies that have attempted to measure the demand for waste disposal
services in general (rather than specifically demand for landfill), conclude that the
demand for municipal services is inelastic. 953 This implies that a large increase in the
cost of the service would be needed to see any significant change in the quantity of
waste sent for disposal. However, studies also indicate that householder’s attitudes
and the implementation of pay-by-use charging mechanisms strongly affect the
outcome, implying that the cross-price elasticities of demand for waste disposal
services can be relatively elastic. It is not so clear, however, whether changes in
953 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005
29/09/09

disposal costs necessarily would lead to changes in marginal rates being charged for
disposal. Hence, the interaction between pay-by-use and waste taxes cannot be
assumed to be always predictable.
52.5.1 Waste Prevention
The environmental benefits from any waste prevention effects would be expected to
include:
765
� reductions in greenhouse gases and aquatic and soil toxicity effects
associated with less material managed in landfill;
� reductions in energy consumption associated with a lower demand for goods;
and
� less hazardous material in the waste stream.
52.5.2 Reduction in Waste Generated?
As might be expected for policies developed principally to discourage disposal, the
evidence presented suggests there is minimal effect on waste prevention from these
policies on their own, and that any preventative effect ought, probably, to be
attributed to the combination of policies at work in a specific country, and the general
attitude to waste management of the population.
In 2004, almost a decade after the Dutch landfill ban had been implemented, VROM
(2004) stated that: 954
‘A weak point in current waste management is that there is still insufficient
grip on the quantity of waste produced, particularly consumer waste, which is
still increasing. The situation is being exacerbated as these are also the waste
streams for which the level of recovery is lagging behind the targets. A great
deal of combustible and recoverable waste is consequently still being
disposed of in landfills because, when planning incineration capacity, it had
been assumed that the waste supply would be smaller and the degree of
separate collection higher.’
Another study noted, regarding the Dutch ban: 955
the effect on prevention is very indirect and very difficult to measure. One has
to see it as a measure that raises prices in the waste management systems,
and that hence, where there is a system for producer responsibility, indirectly
some incentive is created for re-design of products in such a way that less
waste is created.
954 VROM (2004) The National Waste Management Plan, Ministry of Housing, Planning and the
Environment, The Hague.
955 Eunomia et al (2007) Household Waste Prevention Policy Side Research Programme, Final Report
for Defra.
International Review of Waste Policy: Annexes

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Probably, there is some interaction also with the implementation of DifTar
schemes. If DifTar schemes had been introduced against the backdrop of
lower costs for residual waste treatment, the structure of charges might have
been more difficult for Councils to justify, and the additional costs of
introducing the system would have been higher (making them more
problematic to justify in the political sphere).
This actually highlights two points:
� The (probably) weak effect in terms of waste prevention, associated with the
ban; and
� The difficulties in providing sufficient capacity for treatment of specific waste
streams in the context of an outright ban, especially in cases such as the
Netherlands, where restrictions on exports for incineration, even where
classified as recovery, are tight.
In respect of the first point, this in itself is not evidence of a lack of any effect of waste
prevention. Yet further consideration suggests that the ban probably cannot claim to
have effects which are stronger than the tax for the simple reason that one of the key
objectives of the ban was to shift waste from landfill to incineration, and the design of
the tax was, from 2000, used to make incineration less expensive from landfill. One
could argue that the tax itself might have had an effect, in conjunction with the ban.
Yet a report for the Dutch Ministry of the Environment on the effectiveness of landfill
taxation concluded that ‘The implementation of the tax does not seem to have a
direct effect on the level of household waste’. 956 Evidence is less clear in respect of
non-household waste.
A report by Mazzanti and Zoboli on the effectiveness of polices on waste prevention,
waste disposal and landfill analysed waste arisings and economic data, produced by
the EU 25 from 1995 to 2004, used multi-variant analysis to attempt to find any
decoupling of waste and GDP growth at the European level. 957 Importantly one of its
conclusions is that ‘no landfill or other policy effects seem to provide backward
incentives to waste prevention’. The conclusions also indicate that ‘at all levels other
socio-economic factors were impacting on waste trends; highlighting the importance
of societies’ attitudes in waste management.’
The Swedish waste management report from 2008 indicates that in Sweden, despite
the introduction of landfill taxation and a ban in 2000 and 2002, respectively, from
2003 to 2007, the quantity of municipal waste has increased from 466.4 kg/person
to 513.7 kg/person. 958 Furthermore, as Figure 52-4 shows, there has been no
956 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005
957 M. Mazzanti and R. Zoboli (2007) Waste prevention, waste disposal and landfill policies
effectiveness: A quantitative analysis on delinking at European level, Report for Societa Italiana di
economia pubblica, http://www-1.unipv.it/websiep/wp/200720.pdf
958 Avfall Sverige (2008) Swedish Waste Mangement, Accessed on 23 rd October 2008
http://www.avfallsverige.se/se/netset/files3/web/P01.m4n?download=true&id=2371_94867351

discernible change in the trend in waste arisings before and after the tax and ban
combination. This suggests minimal effects on the part of the combination of the tax
and the ban in terms of municipal waste prevention. There is a weaker basis for
understanding the effects on industrial wastes.
Figure 52-4: Municipal Waste Generated in Sweden
kg per capita
767
600
500
400
300
200
100
0
1996
Source: Eurostat
1998
2000
2002
Year
International Review of Waste Policy: Annexes
2004
2006
Municipal Waste
Generated - kg per
capita
Since 2000, in the Flanders Region of Belgium there has been a ban on the landfilling
of untreated municipal waste. Subsequently, the amount of household waste in
Flanders has ceased increasing. In 2002, it decreased by 0.2% and in 2003 by 3.4%.
Major factors behind these figures are likely to have been the widespread availability
of separate collection facilities and the application in almost all Flemish
municipalities of pay-by-use charges. 959 To the extent that pay by use may have had
some impact, this may prove to be a one-off impact. Furthermore, the apparent
change in trend could also be attributed to the positive attitudes to waste
management of the population.
Bans would be expected to have the strongest influence in those situations where the
costs of landfilling are much lower than the costs of many of the alternatives which
might be expected to be deployed to deal with wastes subject to a ban. Germany
maybe one such case and Wallonia may be another.
Intriguingly, some anecdotal evidence may lend some support to this view. For
example, a recent study for OVAM indicated that Wallonia has the lowest residual
959 A. Sanders, L. Putseys and E. Van Der Putten (2004) Beheer van afvalstoffen. Chapter 2.17. In
Milieurapport Vlaanderen (MIRA), www.milieurapport.be

waste per inhabitant of any of the regions examined in the study (Flanders, Wallonia,
Nord Pas-de-calais, Nordrhein Westfalen, Brussels Region and the Netherlands). 960
In addition, our own work in Germany examining pay-by-use schemes suggests that
the cost differential between landfill and incineration / other pre-treatment
anticipated by some local authorities in the years prior to the restriction on landfilling
being enforced led to them reconfiguring the charging schemes they used to
incentivise households to increase recycling and prevent waste. 961 Figure 52-5 also
demonstrates a quite significant drop off in municipal waste, though the picture is far
less clear in respect of production and commercial waste (equivalent to commercial
and industrial waste in the UK). This has shown a more volatile trend. It should be
noted that in the Figure, the main change in total waste quantities comes through
reductions in construction and demolition waste landfilled, this being affected by
different drivers to the landfill ban.
Figure 52-5: Evolution in Waste Arisings in Germany, 2000-2006
960 OVAM (2007) Market Study of the Final Treatment of Residual Household Waste and Industrial
Waste Similar to Household Waste in Flanders and Neighbouring Regions: a Summary Report, August
2007.
961 See the case of Landkreis Schweinfurt in D. Hogg (2006) Impact of Unit-based Waste Collection
Charges ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD and Eunomia (2003) To Charge or Not to
Charge? Final report to IWM (EB).
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A report on Finnish waste management suggests that waste taxation is considered
not to have contributed much to waste prevention. 962 Figure 52-6 shows that
changes in tax rates have had little effect on waste quantities, with the possible
exception of the rise which took place in 2000. However, other rises do not seem to
have had a significant impact.
Figure 52-6: Waste Quantities and Tax Rates in Finland
Source: Christian Fischer (2008) The Use of Landfill and Incineration Waste Taxes in
Selected EU Countries, Presentation to EU-Asia Sustainable Waste Management
Cycle, CBPIII, 17 April 2008.
A report for the Dutch Ministry of the Environment on the effectiveness of landfill
taxation concluded that ‘The implementation of the tax does not seem to have a
direct effect on the level of household waste’. 963
Since 2000, in the Flanders Region of Belgium there has been a ban on the landfilling
of untreated municipal waste. Subsequently, the amount of household waste in
Flanders has ceased increasing. In 2002, it decreased by 0.2% and in 2003 by 3.4%.
Major factors behind these figures are the widespread availability of separate
962 EIONET: European Topic Centre on Resource and Waste Management (2007) Finland Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Finland
963 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
769
International Review of Waste Policy: Annexes

collection facilities and the application in almost all Flemish municipalities of pay-byuse
charges. 964 To the extent that pay by use may have had some impact, this may
prove to be a one-off impact. Furthermore, the apparent change in trend could also
be attributed to the positive attitudes to waste management of the population.
These results could also be confirmed by the situation in Luxembourg which has seen
an overall stabilisation of household waste generated despite no taxes or bans having
been implemented. 965966
In the UK, it is difficult to be clear whether the landfill tax, which has escalated
significantly in recent years, has had a strong impact upon waste prevention. In the
household sector, it seems reasonable to argue that the tax will have had little or no
impact upon household waste growth for the simple reason that there is no means of
conveying, to the householder, the changing cost of disposal other than through a flat
rate increase in the Council Tax levied locally. Notwithstanding this, municipal waste
growth rates have been in decline since 2000, though much of this may be
attributable to the effect of the LAS, which has generated an incentive for local
authorities to minimise the quantity of non-household municipal waste which they
collect. 967
The situation for non-household waste from commerce and industry is almost
certainly very different, only partly because revenues from the tax have been recycled
into schemes designed to foster increased resource efficiency (with prevention and
re-use being prominent in these). However, the quality of the available data does not
inspire one to suggest that a basis for any trend analysis exists, let alone, that the
basis for discerning a clear change in trend due to the tax is reliable. Rather, the
evidence is more anecdotal, and where surveys of commercial and industrial waste
have been carried out, quite suggestive. In addition, a report by ECOTEC following the
tax’s introduction suggested that, on the basis of a survey, the tax had been a key
factor leading some businesses to reappraise their waste management behaviour. In
964 A. Sanders, l. Putseys and E. Van Der Putten (2004) Beheer van afvalstoffen. Chapter 2.17. In
Milieurapport Vlaanderen (MIRA), www.milieurapport.be
965 Luxembourg Ministry of the Environment (2006) Waste Statistics Website, Accessed on 16 th
October 2008, http://www.statistiques.public.lu/stat/TableViewer/tableView.aspx?ReportId=1036
966 EIONET: European Topic Centre on Resource and Waste Management (2007) Luxembourg Waste
Factsheet, Accessed 16 th October 2008,
http://waste.eionet.europa.eu/facts/factsheets_waste/Luxembourg
967 It is important to recognise that in the UK, and indeed, several other EU countries, municipal waste
is defined as, effectively, an administrative category. The quantity of waste regarded as ‘municipal’
depends upon whether the waste is collected by, or on behalf of, the local authority. Decisions by local
authorities to collect, or not collect, commercial waste will influence the quantity of municipal waste
reported. This – the difference in the way the definition of ‘municipal waste’ is applied - is a key reason
why a) EU statistics regarding municipal waste are essentially non-comparable, and b) attempts at
cross-country analysis of the effectiveness of policy instruments are likely to be thwarted unless
account is taken of the way instruments and definitions are applied in different countries (and such
studies are rare, if not, completely absent).
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some cases, notably in the foundry sector, this led to waste prevention effects, with
commensurate savings to the businesses concerned. 968
52.5.3 Hazardousness of Waste
In terms of reducing the hazardousness of waste, beyond the regulatory measures in
the Landfill Directive, levies and bans have not been widely used to influence the
generation of hazardous waste. One reason for this is that it is generally considered
‘potentially problematic’ to make treatment / disposal of hazardous waste much
more expensive than it already is because of the potential dangers associated with
illegal disposal of hazardous materials.
Some countries have bucked this trend and have applied increased levels of taxation
for hazardous materials, such as in Slovakia. In the Czech Republic there is a ‘risk’
component of the tax to cover hazardous materials. As a general principle, and as
mentioned in Section 52.11, high levels of taxation and unmanageable bans are to
be avoided to limit illegal dumping of environmentally damaging substances. Indeed,
there are good reasons to argue that hazardous materials ought not to be subject to
punitive measures so as to ensure that improper disposal of hazardous materials
does not become problematic.
In summary, the quantity of waste prevented and thus the waste prevention related
environmental benefits from the implementation of waste treatment taxes and bans
are likely to have been minimal, if there are in fact any at all. Benefits from the
reduction of materials which are hazardous in the context of landfilling may have
arisen following banning of such wastes from landfill.
52.5.4 Recycling
Some of the environmental benefits associated with recycling relate, as with waste
prevention, to avoidance of landfilling, but there will also be additional savings from
avoiding virgin material use, and the associated embodied energy achieved through
material recovery.
Recycling rates in most of the countries considered in this report have been
increasing (though in some, such as Denmark, this is barely discernable any more).
As with waste prevention, however, there is relatively little documented evidence to
demonstrate that the introduction of a tax or a ban on its own correlates strongly to
any increase in recycling.
In the UK, one study suggested that when it was first introduced, the tax led to several
companies reviewing their waste management operations, and changing
arrangements to increase recycling of waste. 969
968 See ECOTEC (1997), Effectiveness of the Landfill Tax in the UK: Barriers to Increased Effectiveness
and Options for the Future, A Final Report for Friends of the Earth, Birmingham: ECOTEC; D. Hogg
(1999), ‘The Effectiveness of the UK Landfill Tax - Early Indications’, in Sterner, Thomas (ed) (1999),
Environmental Implications of Market-based Policy Instruments, Cheltenham and :Edward Elgar
771
International Review of Waste Policy: Annexes

Where household waste is concerned, recycling rates have tended to be driven more
by recycling targets and, more recently, by the LASs. The situation is almost certainly
very different where commercial and industrial wastes are concerned, though the
data is not of sufficient quality to confirm this. Particularly as the tax has increased
more recently, growing emphasis has been placed upon recycling of commercial and
industrial waste, and the diversity of collection schemes reflects this.
In Denmark it was reported that the overall recycling rate of 61% of all waste in 1996
was the result of a comprehensive waste reduction policy with several elements,
including the waste tax. 970 Furthermore, the establishment of new recycling facilities,
especially for construction and demolition waste (see Section 52.12), and garden
waste was considered to have played a prominent role.
It is also interesting to note that the year in which the ban was introduced, 1997, was
the same year in which the waste tax was significantly increased. Studies by CESAM
suggest the tax, not the ban, has influenced changes in waste quantities, but that
these effects have been at best limited outside the sphere of construction and
demolition waste. 971 One commentator notes: 972
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As a conclusion it could be said, that while taxes are very effective in changing
the way waste is managed, it seems as if they have no or very little effect on
the total amount of waste generated. Denmark has not succeeded in delinking
the growth in waste from the growth in GDP.
In relation to non-landfill technologies, a Dutch report concludes that little technical
change has been seen in the Netherlands in terms of new incinerators, but the use of
SRF abroad has increased. 973 Additionally, any link between the landfill ban and the
tax, and recycling infrastructure was described as ‘ambiguous’.
In Germany, where no tax is in place, and where (as discussed above) the differential
between the costs of landfilling and of, for example, incineration or MBT, is large,
there may have been more of an incentive effect. This might be partly an explanation
for the continuing increase in German recycling rates even some time after the
general frameworks for waste management were well established, and even in the
969 ECOTEC and Cambridge Econometrics (1997), Employment and Sustainability: The UK Landfill Tax,
Final Report for the European Foundation for the Improvement of Living and Working Conditions,
Dublin: EFILWC.
970 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005
971 Miljøstyrelsen, Working report no. 18 (1999) and Miljøstyrelsen, Working report no. 23 (1999).
972 Suzanne Arup Veltzé (2003) Taxes on Waste, a Steering Instrument – Experience from Denmark,
Presentation at ISWA Beacon Conference Seminar, 23-24 October 2003, Malmo, Sweden.
973 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.

absence of any form of waste tax. Figure 52-7 shows the evolution of recycling and
composting rates for municipal waste in Germany from 1995 to 2007.
Figure 52-7: Recycling and Composting Rates for Municipal Waste in Germany
Rate of Material Recovery (%)
773
70%
60%
50%
40%
30%
20%
10%
0%
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
International Review of Waste Policy: Annexes
Year
Recycling and Composting
Recycling
Composting
Source: Eurostat (note the figures for 1996 and 2007 are country estimates, whilst
the figures for 1995 are Eurostat estimates).
In addition, Figure 52-8 shows the rates of recovery for key waste fractions in
Germany. Of particular interest is the fairly rapid increase in recovery of Production
and Commercial waste (as stated above, equivalent to the UK’s commercial and
industrial waste), which rises from 50% in 2000 to over 80% in 2006. It is not clear to
what extent the recovery reflects and increase in thermal recovery, or an increase in
recycling. This may, however, indicate the more market sensitive nature of the
Production and Commercial waste stream, with the ban’s effect causing a shift of
material away from disposal and into recovery.

Figure 52-8: Recovery Rates for Waste Fractions in Germany
Generally, the absence of strong evidence should not be taken as evidence of the
absence of an effect. Most countries which deploy landfill taxes and bans, however,
also deploy an armoury of other policy instruments. Taxes and bans tend to support
these policies, and assist in moving waste up the hierarchy, but the degree to which
they, and not other policies, are responsible is difficult to discern.
52.5.5 Reduction in Landfilling
There are generally benefits associated with reducing the quantity of waste disposed
of in landfills, though these vary with the nature of the material, and with the change
in the management method. For example, when plastics are switched from landfill to
incineration, the net impact in terms of climate change is, under most reasonable
assumptions, strongly negative.
The majority of policies discussed in this Section relate to mechanisms for
discouraging disposal of waste in landfill, and this is the focus of the discussion.
However, some mention of the environmental impacts from incineration can be found
below in Section 52.5.6.
The majority of landfill bans indicated in this report relate to wastes of a hazardous
nature (see Section 52.5.1), and bans on combustible or biodegradable wastes. In
terms of combustible waste, the driver for the implementation of regulatory ban has
historically come from those countries with high levels of incineration wanting to
control the flow of waste into their treatment plants, for example, in Demark, The
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Netherlands and Sweden. One might argue, therefore, that the principle switch
achieved by this is one from landfill to incineration.
The key driver for the implementation of regulatory bans on biowaste comes from the
desire to reduce problems associated with methane generation at landfills, or (which
amounts to much the same thing) to meet landfill directive targets. Note that no
equivalent driver has been found in any state outside of Europe. The European
countries that have landfill bans in place that specifically target biodegradable waste,
are Austria, Finland, Germany, Belgium, France, Sweden, Czech Republic, and
Slovenia. The benefit from eliminating such materials from landfill may be significant
considering the propensity of biodegradable wastes to generate methane in the
anaerobic conditions that occur in landfills.
The effectiveness of a landfill ban can relate to the notice given by the relevant
government before the implementation of the ban. Essentially, if not enough time is
given infrastructure does not have time to develop and infringements are likely to
occur. This is discussed further in the Section 52.12. Of course, where a lead time is
used, it does make any assessment of the effectiveness of a ban more difficult to
assess.
The level of detailed data that could be used to perform a thorough ex-post evaluation
of a number of landfill tax mechanisms is simply not available. We have therefore
pulled together sparse information from relevant reports and highlighted some of the
important issues.
To determine what environmental benefits are associated with a landfill tax, one
study sought to understand whether there is a relationship between the level of the
tax and the proportion of waste landfilled in that country. Figure 52-9 shows that, at a
glance, no relationship exists between landfill tax levels and municipal waste
landfilled. However, the combination of waste policies in each of the countries, and
specific intentions of the landfill tax, are different, making such a univariate analysis
almost useless. For example, one of the clear outliers is Germany (DE), with a low
level of municipal waste landfilled but no landfill tax. In Germany the Ordinance on
Landfilling of waste significantly restricts landfilling, and has had a significant effect in
reducing the quantity of waste landfilled. Equally, to take the view that the tax is
responsible for the low levels of landfilling in Netherlands and Denmark would be to
miss the influence of the landfill bans in those countries.
775
International Review of Waste Policy: Annexes

Figure 52-9: Correlation between Landfill Tax and Waste Landfilled
Source: Bartelings, H., P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A.
Wagtendonk (2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie
von VROM, November 24, 2005.
France (FR) also looks like the tax has had a pronounced effect relative to other EU
countries. However, the level indicated in this chart only relates to the level of tax that
is chargeable for waste deposited in legal landfill sites. There has historically been a
large quantity of waste deposited in unregistered sites in France, and this waste is
subject to a higher level of landfill tax (around 36 €). This and the regulatory ban on a
number of waste streams, has had the effect of reducing the quantity of municipal
waste to a lower level than in countries with a higher rate for licensed landfills e.g. the
UK.
The Netherlands (NL) has, what looks like, an over inflated landfill tax compared to
other EU countries whereby similar levels of municipal waste landfilled can be
achieved through lower rates. This is most certainly the case, but there has been a
relatively unique case in Dutch waste management. In the late 1980s the Dutch were
rebuilding their incineration capacity with much higher pollution control mechanisms
following a dioxin emissions scandal. Fiscal and regulatory measures were needed to
ensure that incineration capacity would be used, and hence, that the high investment
cost would not be wasted. A landfill ban on all combustible waste was implemented
and the landfill tax was escalated sharply between 1995 and 2003. A Dutch study
indicates that in the same period: 974
974 MNP (2005), Milieubalans 2005, Milieu- en Natuurplanbureau, Bilthoven.
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777
‘the amount of landfilled waste decreased by around two thirds from 8.215
ktonne to 2.753 ktonne. During the same period, the amount of waste
incinerated increased by around 75% from 4.695 ktonne to 8.218 ktonne.’
The sharp rise in landfill tax increased the cost of disposal to a point where landfill
gate fees exceeded the gate fee for incinerators. Therefore the lower cost of
managing waste by incineration meant that incineration substituted landfilling, where
possible, and thus allowed for a more efficient allocation of resources.
UK Experience
Figure 52-10 shows how the quantity of waste landfilled has changed over time in the
UK. The most relevant quantity for the purposes of this study is the quantity of waste
landfilled in the standard rate category. This remained fairly stable from 1997/98 to
2002/03, but has fallen since then. The fall has been of the order 11 million tonnes.
We estimate that changes in the management of municipal waste accounts for
around 5 million tonnes of this fall.
Figure 52-10: Quantities of Landfilled Waste in the UK
Tonnes Landfilled ('000 tonnes)
120,000
100,000
80,000
60,000
40,000
20,000
0
1997-98 1998-99 1999-00 2000-01 2001-02 2002-03 2003-04 2004-05 2005-06 2006-07 2007-08
Source: based on data from HMRC
International Review of Waste Policy: Annexes
3% 3% per per annum annum annum nominal nominal increase,
increase,
approx approx 0% 0% in in real real terms
terms
£1 £1 per per tonne tonne per per per annum annum escalator escalator £3 £3 per tonne per annum annum annum escalator
escalator
Financial Year
8% 8% per per per annum annum nominal nominal increase, increase,
increase,
approx approx 5% 5% in in in real real terms
terms
Exempt
Lower rate
Standard rate
The remaining drop is likely to be due either to a decline in commercial and industrial
waste arisings, or to waste moving into other non-landfill routes. This drop would be
against the backdrop of our estimate of UK commercial and industrial waste landfilled
of the order 34 million tonnes across the UK early in the decade.
The commercial and industrial waste market is, in principle, more dynamic than the
municipal one (owing to the more ‘naked’ nature of the competition), yet at the same
time, this competition can have the effect of slowing down development of
infrastructure and services (because of the increased risk associated with ensuring
sufficient supply into the investment).

The reason for this is that the competition for waste services reduces the security
which any developer of more capital intense facilities might have that waste will come
into the facility in the quantity and manner desired. In essence, investments are more
risky than they are in the case – as with municipal waste – where flows of waste can
be more or less guaranteed under long-term contracts.
In order for developers to have some certainty that waste will flow into specific
facilities, the economic conditions must be right. The lack of increase (in real terms)
in landfill costs implied by the landfill tax in the period to 2003-04 can partly explain
what would appear – at least at the UK level - to be a lack of any very strong shift
from landfill to other treatments as a result of the tax. This may have changed since
2002-03 (with the increase in landfill tax escalator), but it is far more likely that
greater changes will come as the escalator increases the tax to £72 per tonne by
2013.
Pre-treatment requirements may also be encouraging segregation of wastes by
companies which have not hitherto been engaged in any such activity, although the
UK pre-treatment requirements demand minimal change on the part of most waste
producers.
With respect to household waste, the landfill tax has been far less influential in
driving waste away from landfill. The LASs have been more important in recent years.
Finland
The Ministry of the Environment assessed the effectiveness of waste tax in Finland in
a report published in 2005, which indicates that waste taxation has helped to reduce
the amounts of waste ending up in public landfills in spite of increasing consumption.
Reductions were particularly significant for construction, commercial and industrial
wastes. Taxation controls have been less effective in terms of limiting household
waste.
Sweden
A report by the Swedish Environmental Protection Agency stated that although the
amount of waste going to landfill had actually decreased, there was much doubt as to
the quantified effects of the landfill tax. 975 This was because the tax was evaluated
when it had only been in place for a short time, there was limited access to the data
that could be used for the evaluation, and waste management policy includes a
number of other instruments alongside the landfill tax.
As regards the Swedish incineration tax, a study by Sahlin et al suggested that the
incineration tax would have the largest effect on biological treatment of kitchen and
garden waste, which could increase by 9%. 976 The authors stated that the
975 Naturvårdsverket (2003) Ekonomiska styrmedel inom miljöområdet - en sammanställning. Rapport
5333, Naturvårdsverket, Stockholm.
976 J. Sahlin, T. Ekvall, M. Bisaillon and J. Sundberg (2007) Introduction of a waste incineration tax:
Effects on the Swedish waste flows, Resources, Conservation and Recycling, Volume 51, Issue 4,
October 2007, pp. 827-846.
778
29/09/09

consequences of an incineration tax depend upon: (a) the level of the tax, (b) whether
the tax is based on an assumed average Swedish fossil carbon content or on the
measured carbon content in each incineration plant, (c) institutional factors such as
the cooperation between waste incinerators, and (d) technological factors such as the
availability of central sorting of waste or techniques for measurement of fossil carbon
in exhaust gases, etc. Information turns out to be a key factor in transferring the
governing force of the tax to the households as well improving the households’
attitudes towards material recycling.
Others
Table 52-6 below shows the reported effectiveness of the landfill tax in some more of
the Member States according to a Dutch study.
As one can see from the tax effectiveness evaluation summaries presented in the
Dutch report there is no strong evidence to show that the landfill tax or ban on its own
has a great impact on the change in municipal waste landfilled over time, and thus in
associated environmental benefit. What is clear is that a tax can be used effectively in
combination with a range of other regulatory measures, to divert waste from landfill.
Where this waste will be diverted to will be related to prices for the alternative
management routes and other institutional factors, historical trends in waste
management (Denmark – incineration, Belgium - recycling), technical change
following pollution scandals (The Netherlands, Austria), or a means to assist in
securing supply of waste for incinerators mainly in countries where district heat
networks were existing (Denmark, The Netherlands, Germany, Finland, Sweden).
Summary
To summarise, waste taxes or bans can be used by governments, as part of a
package of measures, to help divert municipal waste from landfill and direct it to
alternative residual treatments as required (the rate of tax levied on each type of
treatment will determine how waste disposal authorities will act – based on cost
effectiveness only – and hence what treatment is favoured). Or, if a greater level of
household waste recycling is the favoured alternative to disposal in landfill (or via
other residual management processes), because it is the householders making the
decision as to whether the waste will be recycled, they must feel the price signal from
a tax though some differentiated unit-based pricing scheme. Such systems are in
accordance with the ‘polluter pays principle’ and can contribute to an efficient
allocation of resources, because they imply a non-zero marginal cost of waste and
thus stimulate recycling and waste prevention. 977 However, unit-based pricing
systems also have some disadvantages. They sometimes involve high transaction
costs, and tend to stimulate the illegal disposal of waste. Relevant to both taxes and
bans (as the success in Belgium has shown), is that widespread and easy to access
recycling collections must be in place to help behavioural change.
977 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
779
International Review of Waste Policy: Annexes

Table 52-6: Effectiveness of Waste Taxes in European Member States
780
Country Country
Country
Denmark High
29/09/09
Landfill Landfill
Landfill
Diversion Diversion
Diversion
Austria Medium
Finland
Belgium –
Flanders
Low /
Medium
High
Tax Tax Tax Effectiveness
Effectiveness
Effectiveness
There are a number of strong incentives to incinerate waste in
Denmark. These are in place because incineration was chosen
as a preferential method for generating energy in comparison
to fossil fuel based processes. A landfill ban on all combustible
materials is in force and price ceilings on the sale of heat have
been set so that EfW is more cost effective. It is difficult to say
which factor (including the tax) has had more effect, but it is
clear that the Danish system is unique.
However, this was reported as ‘the result of a comprehensive
waste reduction policy with several elements, including the
waste tax’, and that much of the reduction had come from
unregulated areas.
The tax has had a clear effect on the level of technologies at
landfill sites, but the 30% reduction in municipal waste
between 1989 and 1999, could well have been attributed to
other regulations and an increased awareness of recycling and
composting.
The waste disposal policies in Finland are, like in Denmark,
designed to provide a secure supply of waste to EfW plants.
Combustible waste must be source separated and is also
banned from landfilling. Up until 2003, when the level of the
tax was low (27 €) there was doubt as to the quantifiable effect
of it having any bearing on the reduction in waste landfill that
was observed. No evidence was found to show what has
happened since the tax was subsequently increased to (40 €).
It is therefore not possible to clearly state the result of the tax
in isolation, but it is likely that the mix of policies have diverted
waste from landfilling to recycling and incineration.
The amount of waste being disposed of in landfills decreased
from 52.6% to 16.3% between 1991 and 2003. The amount of
waste generated per annum has actually started to decline
since 2003. The complex system of differentiated taxes and
bans has been highlighted as being responsible for this
decrease, but that major factors that have contributed to the
diversion of waste from landfill (mainly to recycling) are - the
widespread availability of separate collection facilities and the
application in almost all Flemish municipalities of some kind of
differentiation in waste collection charges.
Source: Adapted from Bartelings, H., P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander
and A. Wagtendonk (2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by
Ministerie von VROM, November 24, 2005

52.5.6 Reduction in Incineration
As shown in Section 52.5.5 above, waste taxes and bans can achieve a certain level
of environmental benefit by diverting waste from landfills. However, as also touched
upon, to what process the waste is diverted will also have an impact on the net
environmental benefit from the switch in management methods. Several countries in
Europe have constructed taxes and bans to switch waste from landfilling to
incineration, mainly through bans targeting waste described as ‘combustible’, and
through setting up tax differentials against the backdrop of a static situation in
respect of recycling.
Switching from a poor performing landfill to an efficient incinerator with extensive flue
gas cleaning equipment installed, is unequivocally going to provide you with greater
environmental benefit than from switching waste from a fully sealed landfill with a
high gas capture rate and subsequent generation of energy, to a low performing EfW
plant. The Dutch report on landfill effectiveness performed a cost benefit analysis of
landfill, incineration and co-incineration. This study took full consideration of the
environmental externalities associated with each. It found that incineration had
significantly higher social costs than landfilling.
As Austria successfully managed to do with landfill technology, several countries are
using waste taxes and bans to manage the environmental performance of EfW plants,
or in fact, actually discourage their use in favour of recycling by levying rates on the
combustion of waste. In Sweden, for example, the amount of the tax is calculated
based on a model of the fossil content of material in the waste. 978 Furthermore, the
amount of tax is dependent on whether facilities produce electricity and, if so, how
efficiently. In Norway there is an emissions based tax that focuses on pollutants such
as CO2, NOx, SOx, particulates and dioxins. The tax was developed to be revenue
neutral and not change the balance of residual treatments.
If incineration is compared to recycling, in terms of cost effective GHG performance, it
fairs worse in most cases, except when looking specifically at the combustion of low
grade wood. 979 If one were to include a whole range of environmental factors the true
social cost is likely to be considerably worse for incineration. Thus several countries
include taxation or banning policy mechanisms to discourage the disposal / recovery
of waste in EfW plants, and to promote recycling. 980 In Belgium, for example,
incineration is forbidden for:
978 Avfall Sverige (2008) Swedish Waste Management,
http://www.avfallsverige.se/se/netset/files3/web/P01.m4n?download=true&id=2371_94867351
979 Eunomia (2008) Development of Marginal Abatement Cost Curves for the UK Waste Sector, Final
Report for the Committee on Climate Change, Defra and EA.
980 Historically waste could be ‘disposed’ of in incinerators where there was no means to recovery any
energy from the process. Consequently the Waste Incineration Directive required that all incinerators
must generate some form of energy, be it heat or electricity only, or combined heat and power (CHP).
Hence why incineration is often referred to as energy from waste (EfW). One of the last amendments to
the European Waste Framework Directive stipulated that EfW could be categorised as a recovery
process, rather than a disposal process, but only if the specific facility met certain requirements in
terms of energy efficiency, hence discouraging the management of waste in EfW facilities due to low
781
International Review of Waste Policy: Annexes

782
� Separately collected waste fit for material recovery or recycling, except some
types of biowaste if they have a caloric value of above 11.500 kJ/kg and used
for the creation of renewable energy;
� Unsorted industrial waste; and
� Unsorted household waste.
Moreover, a tax is levied on any waste where BAT for sorting exists. The tax is
differentiated in relation to the level of sorting carried out, thus strongly incentivising
source segregated separation and recycling. Consequently Belgium has one of the
highest recycling rates in the world. Additionally, Denmark, Norway, Sweden, and the
Catalonia region of Spain, all have some form of taxation or banning policy in place.
Considering Denmark’s desire to use EfW to generate heat for its district heating
networks, it seems likely that this tax could just be a revenue raiser for the
government’s budget.
Interestingly, if one refers back to Table 52-1, several of the countries with high
recycling rates, but high incineration, have a policy mechanism for discouraging EfW,
and none of the countries with high recycling and low incineration do. In fact they all
have relatively low landfill taxes as well. This most probably indicates that taxation of
residual treatments is an effective means to promote the switching of waste between
treatments, but that other policy mechanisms are more effective at promoting
material recovery and recycling.
52.5.7 Commercial and Industrial Wastes
The data for commercial and industrial waste is generally less comprehensive than
for municipal wastes, and sometimes non-existent. Thus there has been very little
reference to C&I wastes in any of the evaluation studies queried. So this section will
take an overview of what are considered to be the important issues and highlight the
small points from literature where applicable.
C&I businesses have waste collection by private waste collection companies and are
generally charged by weight or volume of waste collected. Waste collection
companies will pass the price of an increase in landfill taxation directly through to
them by increasing, for example, the cost per tonne of waste collected. This gives a
direct signal to the business that it must reduce the amount of waste that it produces.
Ecotec report that in England:
29/09/09
‘There is some evidence that the landfill tax has had an effect on the disposal
of commercial and industrial waste.’
This was relating to a survey of firms which suggested that the introduction of the
landfill tax stimulated waste minimisation and recycling activities. Such evidence has
been backed up by work undertaken for the Environmental Technology Best Practice
programme, a UK Government initiative that provides free advice to industry on
GHG performance vis-à-vis recycling, or because of it’s net social cost, could be strictly classed as
discouraging disposal in some cases and recovery in others.

environmental performance. The landfill tax has been highlighted as the reason
behind many waste minimisation, recycling and segregation initiatives identified by
the programme.
In addition to this Kautto and Melanen explain that in Finland economic instruments
(including the waste tax) have stimulated companies to increase the recovery of
waste, although in most cases the costs of waste management were relatively low. 981
The authors argue that this can be at least partly explained by the fact that many of
the companies they studied were located in municipalities in which the municipal
waste charges had traditionally been low. 982 When the charges had grown relatively
rapidly in the late 1990s and the national waste tax had been implemented in 1996,
this had given the firms a signal concerning anticipated developments, making them
search for new ways to minimise wastes. Many of their interviewees also felt that
taxation and other economic instruments are appropriate tools for enhancing ecoefficiency
and sound waste management.
The limited evidence base here seems to suggest that there is somewhat more of a
link between taxation and a reduction in disposal of C&I wastes. Unfortunately no
study has been found specifically concerning the evaluation of landfill bans in terms
of waste minimisation, so no further analysis can be made. The evidence suggests
that the environmental benefits from the policies in relation to C&I wastes are small
but potentially have a further capacity for increase if the price signal is continued to
be passed though at an appropriate level.
52.6 Implementation Costs
For a landfill ban the costs are essentially those associated with the design of the
system, administration and publicity needed to inform the stakeholders affected by
the ban i.e. landfill operators and wastes generators. These costs would also be
applicable to landfill taxes. In addition there would also be the costs of measuring the
weight of material disposed of at landfill, for example, by weighbridges.
Several landfill taxes and bans limit the nature of waste by certain proxies to
biodegradability such as:
783
� Limits on Total Organic Content (TOC);
� Limits on Total Carbon Content; or
� Limits on Calorific Value (CV).
These all require some calculation or measurement to be taken. There will be some
cost incurred by the agency setting up and administering this type of system. No
specific financials were found in the literature, however.
981 P. Kautto and M. Melanen (2004) How does industry respond to waste policy instruments – Finnish
experiences, Journal of Cleaner Production, 12(1), 1-11
982 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
International Review of Waste Policy: Annexes

Additionally for incineration taxes, if not based on weight of material but pollutant
levels, costs of measuring instruments and infrastructure on the plant would also be
incurred.
Furthermore there will be some costs associated in developing a system of regulation
and enforcement. New regional offices may need to be set up and staffed to monitor
landfills or manage illegal dumping, for example – see Section 52.11.
Moreover, the cost-effectiveness (in terms of net social benefit) is likely to be low if a
ban on all waste is introduced. 983 This is because the marginal costs for waste
diverted from landfill to another process will be expensive for some materials and / or
streams, and is likely to exceed the benefits of such diversion. Where specific
streams have a high negative environmental impact because of their nature, and
there exists a cost effective alternative to manage the stream, bans may represent a
closer approximation to what is socially optimal.
52.7 Effects on Technical Change / Innovation
In Austria the landfill tax has had a significant impact on the rate of technological
change at landfills. In other countries, concerns over local pollution have been
enough to stimulate legislation to incentivise the implementation of pollution
abatement equipment at landfills. For example, the statutory regulations on landfill in
Denmark require operators to manage their sites in an environmentally favourable
way.
However in relation to non-landfill technologies, a Dutch report concludes that little
technical change has been seen in the Netherlands in terms of new incinerators, but
the use of SRF abroad has increased. 984 Additionally, any link between the tax and
recycling infrastructure was described as ‘ambiguous’.
52.8 Social and Distributional Consequences
Although landfill taxes are not highly significant where sectoral turnover is concerned,
some sectors are clearly affected more than others. The construction industry can be
significantly affected, depending upon the nature of the tax regime, because it
generates significant waste relative to turnover. The same applies for universities,
and other sites where large numbers of people are domiciled and generating waste.
Those areas where there are relatively low gate fees for waste disposal will see a
higher percentage increase and thus ‘feel’ the effects of the tax to a greater extent. In
England typical disposal fees pre-tax for municipal wastes, or non-inert industrial
wastes were between £7-£25 (approx 11.2-40€) per tonne so that the tax implied an
983 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005
984 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
784
29/09/09

increase of between 30-100%. In Austria the level of tax as a percentage of the
disposal cost varies quite strongly across the employment sector. Therefore it is likely
that some sectors will be more affected than others. 985
Initially in France some rural areas faced much higher total costs for household waste
due to greater distances to small landfill sites generally charging higher landfill gate
fees per ton of waste. However, before 2004 in Austria, the differential in disposal
costs at landfills, between those that had upgraded and those that had not complied
with the regulations, resulted in a commercial advantage for those ‘hanging on’ until
the last minute to comply. This promoted waste tourism, whereby waste generators
found it cheaper to transport material across the country to sites that had not yet
upgraded (despite the higher taxation levels).
52.8.1 Waste Sector
Ecotec reports that the landfill tax in England has had a major effect on the pricing
structures of the waste management industry itself. For example, with skip hire firms,
prices appear to have roughly doubled in the wake of the tax. For this reason, in the
wake of the tax, waste delivered by small traders to civic amenity sites probably
increased. Evidence suggests that waste from some home improvement projects
were being taken to CA sites in hired vans instead of being disposed of in skips as
might have been the case previously. This is not legal in the UK, where CA sites are
reserved for household waste, and the practice led to the introduction of permitting
schemes by local authorities to ensure that material delivered to their sites was not
from tradespeople.
52.8.2 Adaptive Strategies
One would expect companies who assist in offering the provision of advice concerning
recycling and waste minimisation to benefit from the tax.
52.8.3 Impacts on Employment
In England, increased employment can be seen in the form of waste minimization
officers, recycling contractors and operatives, and those associated with the
environmental schemes associated with the landfill tax credits scheme.
In France it was thought that sorting activities would see that greatest increase, with
additional community schemes set up for disabled and ‘youth’ workers. However, the
French also expressed concerns about the reduction of employment in waste
management near its borders with waste being exported to countries with a lower
cost of disposal.
Attention should also be given to the employment effects of re-directing funds into
waste management. For example, if a local authority spends more on waste
management, and in doing so, employs more people in the process, it is diverting
985 Ecotec (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
785
International Review of Waste Policy: Annexes

funds which it may have spent elsewhere hence reducing employment in other
sectors such as health and education.
52.8.4 Commerce
In England service sector companies will have gained whilst manufacturing industries
will have seen a net loss because the disposal costs will have been higher and the
increased NI contributions less. However, this reveals only the static picture. In some
enterprises, the signalling effect of the tax led to re-appraisal of waste management
expenditures and, subsequently, to changes in behaviour which left the company in a
better financial position after the tax than before. 986
52.9 Complementary Policies
As discussed in this section of the report, the effects of policies are very much linked.
We describe each and how they relate to taxes and regulatory bans under the
headings below.
52.9.1 Pay by Use
As disposal costs increase (and both taxes and bans have this effect), so the rationale
for avoiding disposal increases. The potential for a rational structuring of charges
under pay-by-use schemes increases as disposal costs increase, enabling charge
structures to incentivise prevention and recycling in a manner consistent with the
costs of service delivery.
52.9.2 Producer Responsibility
Many countries have indicated the importance of this policy in driving recycling
initiatives and diverting waste from landfill. As with pay-by-use, the financial rationale
for recycling and prevention is strengthened by higher avoided costs of disposal.
52.9.3 Compulsory Collections of Biowaste / Pre-treatment
In some jurisdictions, such as Massachusetts in the US, ‘landfill bans’ are
implemented which are not, strictly speaking, bans. Local authorities comply with the
ban through delivering source separation of materials specified as being banned from
landfill. Rather than constituting a ban, these measures imply a requirement for
source separation.
Some countries with more ‘genuine’ bans in place do make use of requirements to
source separate materials. In Austria the Ordinance on the Separate Collection of
Biowaste (1995) specifies materials which the householder must either compost at
home, or must separate for collection by local authorities. The remained biowaste
must be pre-treated to stabilise it before disposal in landfill. Since 1994 in the
Netherlands, municipalities have the obligation to collect organic waste and the
986 ECOTEC (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
786
29/09/09

emaining residual waste separately. 987 This gave an enormous boost to the amount
of household waste composted. In Catalonia (Spain) municipalities pay a lower rate of
landfill tax if there is a source separated food waste collection system in place.
All these instruments will complement and support policies that ban biowaste from
landfill (see Annexes 34.0 and 35.0).
52.9.4 Energy Policies
In Denmark the price of heat from EfW plants is discounted to insure that the use of
waste as a fuel is incentivised. This complements the ban on combustible materials
from landfill.
Similarly, in Sweden, where there is less tax on the combustion of wastes than for
fossil based fuels, further incentive is also given to use waste to fuel the district
heating systems.
52.10 Effect of the Policy on Pricing of Resources / Services
Landfill and incineration taxes are rarely set on the basis of externalities. The closest
examples come from the early days of the UK experience, and the incineration tax in
Norway. Elsewhere, taxes have tended to follow a preference ordering, without
necessarily justifying this ordering.
Bans are not efficient instruments. Arguably, they should not be sanctioned,
particularly from the perspective of economic efficiency. As the OECD puts it: 988
787
191. From an economic perspective, introducing a ban on landfilling is
equivalent to stating that the value of the environmental harm caused by the
landfilling is infinitely high. While this can be defendable for certain types of
hazardous waste, it is much more difficult to see the theoretical underpinning
for a ban on the landfilling of paper waste . whether or not it has been
collected separately.
192. For such waste categories, it would seem more relevant from an
economic perspective to lift the ban and to set a tax on landfilling that more
closely reflected the environmental externalities that actually would be caused
if the waste was to be landfilled. For paper wastes, the relevant tax rate could
very well be considerably lower than the current rate of the Landfill Tax.
Taxes have more to recommend them.
Even so, as in the UK, taxes tend to be used in a pragmatic way to deliver waste
management objectives, and although some taxes can seem quite high, to some
extent, they can be perceived as second best policies where, instead of taxes on
987 Since the year 2000 several municipalities, especially the large ones like Utrecht and Rotterdam,
have asked for and got an exemption from this law. They do not have to collect waste separately in
some parts of the municipality if the quality of collected organic waste is too low.
988 OECD (2005) Instrument Mixes Used to Address Household Waste: Further Analyses and Additional
Case Study, ENV/EPOC/WGWPR(2005)4/REV1, Paris: OECD.
International Review of Waste Policy: Annexes

disposal and subsidies for recycling, higher taxes are used to represent the
differential between disposal and recycling.
52.10.1 Product Pricing
In most cases it is difficult to know exactly what effect the tax has had on product
prices. It is almost certainly true that the impact on end product prices is negligible
because for most sectors, the tax expressed as a percentage of turnover is small, and
although some evidence of this relates to taxes that are now at much higher levels
than when the analysis was carried out, the evidence suggests that the levels would
have needed to be some orders of magnitude higher to affect prices. 989 For example,
in Austria there is no evidence of an effect on product prices arising from the
introduction of the landfill tax. 990 Another good indicator of this is that whilst
environmental taxes may be accounting for a growing share of tax revenues in some
countries, the total tax take from landfill taxes tends to be a very small proportion of
overall tax revenues. With the K tax at £32 per tonne in 2008-9, the total tax take
was less than £1 billion of a total tax take in excess of £500 billion.
52.10.2 Trade
The Ecotec report indicates the awareness of no major impacts on trade. 991 As
regards waste itself, the costs of waste management already vary across countries
depending upon the legislative (regulatory) framework and the mix of waste
management options available. Therefore the trade or movement of waste will vary
depending on the adjacent countries regulatory conditions, and most importantly for
inter-continental trade, the transportation costs of waste (which are relatively high).
On mainland Europe, tax differentials, or bans imposed unilaterally, can have an
impact on trade where facilities are defined as recovery. For example, waste moves
across borders in pursuit of lower gate fees in different EU Member States. The Waste
Framework Directive now allows for Member States to limit movement of waste to
protect their own incineration capacity for municipal waste. This could have the effect
of limiting some of the effects of different prices across Member States.
52.10.3 Recycling / Waste Management Industry
The most significant observable effect of the policies will be to grow the recycling
industry, so notwithstanding the increased costs for disposal of ‘final residues’, the
cost of services are still likely to fall. The same could be said for the incineration
industry unless there is also an incineration tax present.
989 See Ecotec (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes
& Charges in the EU.
990 Ecotec (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
991 Ecotec (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
788
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52.11 Evasion and Enforcement
52.11.1 Illegal Dumping Sites, Fly tipping and Waste Stream Transfer
In the Ecotec report on EU taxes and charges it was mentioned that there were
substantial numbers of illegal landfills or dumping sites in pre-tax France. Once the
tax was introduced these sites could still be taxed, but there seemed to be a
reluctance to prosecute and have the sites shut down; the reason for this is
unclear. 992
In England, Local Authorities (LAs) bear the costs of clearing up waste that is flytipped
on public land. 993 Some claim to have experienced increases in fly-tipping.
However, it is also suggested that this could be due to a greater awareness of the
problem post-tax, and that there was a poor baseline, because local authorities
previously defined fly-tipping in different ways.
Moreover, in Germany the introduction of the landfill ban on untreated wastes has
stimulated the illegal dumping of untreated waste and waste to unlicensed sites such
as quarries (see Annex 53.0).
Eunomia’s household waste prevention report states that there was some concern
that waste which was previously in the commercial and industrial stream might enter
the household stream through being taken to civic amenity sites. 994 The effect is that
municipal waste almost certainly increased as a result of the tax. This resulted in the
tightening up of procedures at HWRCs to stop the switch of C&I wastes into the
municipal stream. For example, the drivers of any vans now entering HWRCs in
England have to produce a proof of address, copy of hire certificate, and demonstrate
to the site operators what is in the vehicle on entrance.
52.11.2 Illegal Administration Fees
Ecotec also reports that the trade body SNADE tried to use its member’s dominant
position in the market to implement an administration fee to the costs of disposal.
This resulted in a substantially hike in the tax in 1993. This activity was illegal and
brought to the competition court whereby the group was fined on the grounds of free
market competition and abuse of dominant position. This was discovered to be a
sensitive issue and stakeholders are now reluctant to discuss the tax, however, no
repeat incidents have been reported.
992 ECOTEC (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
993 Eunomia et al (2007) Household Waste Prevention Policy Side Research Programme, Final Report
for Defra.
994 Eunomia et al (2007) Household Waste Prevention Policy Side Research Programme, Final Report
for Defra
789
International Review of Waste Policy: Annexes

52.12 Waste Taxes and Bans (C&D waste)
The compositional and arisings data for the Construction and Demolition sector is
poor and thus there are limited studies to draw on for relevant information.
Table 52-7 below indicates that the taxation mechanisms vary significantly between
countries. For example, some keep the same rate as for MSW / C&I, some have
separate rates for C&D wastes specifically, others differentiate the inert fraction and
several do not indicate any specifics at all.
52.13 Environmental Benefits
The environmental benefits from waste prevention of C&D wastes stem from where
re-use is promoted either on-site or at sites much closer than landfills. The dominant
factor here being the emissions associated with the transportation of the high
volumes and weight of materials. The actual switch away from landfill is not very
relevant here as there are very small quantities of rapidly degrading materials (i.e.
food waste) disposed of in the waste stream, hence methane emissions will be
negligible. Waste volumes from the C&D sector are obviously going to be linked to the
amount of construction activity occurring. Thus any trends in waste arisings must be
considered with this in light.
The only evaluation information additional to that discussed in Section 46.0 which
included any analysis of the impact of landfill taxation on C&D wastes concluded the
following: 995
790
� In England the waste stream which has been most affected by the tax has
been C&D;
� The pre-tax gate-fee for inert wastes was of the order £0-2 (0-3.2€) per tonne.
So in percentage terms, the introduction of the tax at £2 (€3.2) has had a
significant effect (>100% increase);
� After a survey of operators was conducted, post-implementation, the total
volumes of material landfilled appeared to drop considerably, however the
preliminary data was thought to be of low quality;
� The arrival of the tax has seen the further development of an industry recycling
materials suitable for (re)use in construction (previously this was noticeable
principally in areas where landfill void space was scarce). Alongside the tax,
other initiatives may also have assisted in this development; and
� In Austria the Construction industry will clearly be strongly affected by this
waste tax in terms of volume of waste being produced, however the rate for
demolition waste is low and therefore the burden should be acceptable.
Particularly in the case of construction materials, the waste tax may have been
important in promoting recovery and reuse. 996
995 ECOTEC (2001) Study on the Economic and Environmental Implications of the use of Env. Taxes &
Charges in the EU.
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Table 52-7: Summary of Measures by Policy Approach (C&D waste)
Country Country Country Landfill Landfill Landfill Tax Tax Tax Tax Tax Tax Rate Rate ( (€ ( ( € € per per tonne tonne) tonne
Comments:
Comments:
South Australia 1993 5.4
Non-metropolitan
waste
Western Australia 1998 3.4 Inert waste
Austria 1989 8 C&D
Finland 1996 30 As MSW / C&I
Germany x X As MSW
Hungary x X As MSW
Italy 1996 10.3997 C&D (Industrial)
Belgium-Flanders 1990 -
Reduction for
construction waste
Belgium-Wallonia x X As MSW
Denmark 1987 50 As MSW
France 1992 X MSW and C&I only
The Netherlands 1996 14
Non-combustible
waste
Norway 1999 40 Unclear
As MSW – but
Sweden 2000 43
reductions for
landfill construction
material
Czech Republic 1991 16 Unclear
Estonia 1990 8 Unclear
Slovakia 1992 0.26 Inert waste
Slovenia 2001 Unclear
Spain – Catalonia 2003 Unclear
Less than MSW /
C&I
United Kingdom 1996 3.2 Inert waste
Note: where the word unclear appears, we have not been able to establish the rate for C&D waste.
52.14 Lessons Learned (MSW)
The main lessons learned, as expanded on below, can be summarised as follows.
� Taxes are rarely based on externalities – the policy is generally used in the context
of other instruments to achieve specific objectives;
� Reflecting the above, few jurisdictions apply taxes in a manner that targets the
sources of pollution which are generated by treatments;
996 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
997 Highest rate is given. Lowest rate set regionally can be €1.
791
International Review of Waste Policy: Annexes

� Landfill bans are often applied alongside high landfill taxes. The principle effect
appears to be to shift from landfill to incineration / other forms of residual
treatment;
� The effect of landfill taxes on waste prevention seems limited. They are more likely
to have a positive effect on waste prevention where the price signal is passed
through to the waste producer (PBU);
� Landfill bans or restrictions, when applied alone, may have an impact on waste
prevention, and it may be the case that this impact is greater where landfill is
relatively cheap compared to the alternatives;
� Landfill and incineration taxes can improve recycling but the extent of the impact
depends upon the extent to which other policies have already led to the
development of the activity;
� Furthermore, if the policies are to decrease pollution they must incentivise the
shift to a better performing alternative method of treatment (via the substitution
price effect) or make it more cost effective for plant operators to include a high
level of abatement equipment in their facilities;
� Landfill bans and restrictions can be implemented either rapidly, with exemptions
in place where infrastructure is not adequately developed, or with a long lead
time, so that infrastructure has time to come on stream. The former has the merit
of being less likely to be politically derailed, but in order to prevent repeated resort
being made to exemptions, these exemptions should be expensive to those who
seek them.
52.15 Prerequisites for Introduction
Success factors in the way that taxes have been introduced have been attributed to
the following:
792
� the analytical and policy ground was well prepared in advance of the tax;
� the consultation process helped defuse potential criticisms;
� the tax was based on externality estimates, which was acceptable to
economically knowledgeable commentators;
� fiscal neutrality of the tax (the revenue was used to reduce taxes elsewhere in
the economy); and
� the move to a weight-based tax and the use of revenues for environmental
remediation schemes that were favoured by the environmental lobby.
Complementary Policies such as those described in Section 52.9 are very much to be
recommended with the implementation of any taxes / bans that affect the majority of
the residual stream. This is so that other avenues for the disposal of the material
become available. In addition, the following are recommended;
� The implementation of bans and levies needs to pre-empt the potential for
additional illegal behaviour. Changing price structures leads to changed incentives
to avoid the effects of the instruments. Regulatory enforcement needs to choke
off such activities.
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� A clear rationale for the proposed policy needs to be in place.
� Complementary policies should encourage development of alternatives to the
taxed / banned / restricted activity.
� In the case of taxes, announcements should occur in advance of the instrument
coming into force.
� In the case of bans and restrictions, the policy needs to be capable of being
implemented and enforced.
793
International Review of Waste Policy: Annexes

53.0 Landfill Ban (German Case Study)
53.1 Outline of Policy
Waste Waste Disposal Disposal Ordinance
794
29/09/09
Ordinance 998
The policy “landfill ban” means the restriction of the disposal of untreated municipal
waste, and other waste streams with certain carbon content, in landfills. In the
following chapters the policy on the German landfill ban will be described.
The Waste Disposal Ordinance (AbfAblV) is intended to avoid climate-damaging
emissions and landfill leachate containing hazardous substances, in order to mitigate
the environmental impact associated with municipal waste. In order to achieve this
objective it specifies, amongst other things, which thermally or mechanically
biologically treated wastes may be deposited in landfill; this is known as the input
criteria. According to the Waste Disposal Ordinance the disposal of untreated waste in
municipal landfill had to cease by 31.05.2005 (Article 6, Section 2, No. 1 Waste
Disposal Ordinance).
53.2 Where Has the Policy Been Applied and Why?
The policy has been applied in Germany since 1 June 2005.
Until 1 June 2005, a significant amount of household waste in Germany was still
disposed in landfills. This was a consequence of the fact that the disposal of waste in
landfills is far cheaper than the cost of recovering materials, or of energy generation
from waste through incineration or co-incineration.
As the ban entered into force, and as a result of the falling amount of residual waste,
municipalities in many German regions which were owners of the landfills tried to
reduce the problems of overcapacity by lowering the prices for disposal before June
2005, thus trying to stimulate disposal to landfill, and generate additional revenue in
the period before the ban was implemented.
In some German regions, municipal waste incinerators had been the main fate of
household waste for many years. The treatment of household waste in modern
municipal waste incinerators (with acceptable technologies according to the legal
obligations) is much more expensive than the simple disposal in landfills. Therefore
many cities and counties have developed and realized regional waste management
concepts (includes measures to encourage waste prevention, waste separation and
recycling, and pay by use schemes incorporating incentives to reduce the total
amount of waste, as well as the proportion of unrecycled material 999) to reduce the
998 Ordinance on Environmentally Compatible Storage of Waste from Human Settlements
(Abfallablagerungsverordnung - AbfAblV) of 20.2.2001, Federal Law Gazette pg. 305.
999 For more details see Annex 9.0.

overall costs of household waste management and minimise the cost burden for
single households.
The disposal of household waste is regulated through the Technical Instructions on
Waste from Human Settlements (the Technische Anleitung Siedlungsabfall, or TASi).
The TASi has been amended by the Ordinance on the Storage of Municipal Wastes
and on Biological Treatment Processes (Abfallablagerungsverordnung), which entered
into force in March 2001. According to the TASi, the disposal of untreated wastes in
landfills has been forbidden from 1 June 2005.
The reasons for the landfill ban of untreated household waste, and of other waste
flows with a specified organic carbon content in Germany are related to the following
facts:
795
� Tremendous environmental problems were caused by landfills in the 70s, 80s
and 90s, and a serious shortage of landfill capacity was emerging in regions
with high densities of population (“waste emergency” was a popular headline
in German newspapers);
� Germany is a country with a high population density in many regions. Serious
political discussions and ongoing debates about the problems of landfill arose
during the last three decades in many of these regions, e.g., the spectacular
case of “Messel fosse” (close to Darmstadt), which is a world famous place of
discovery for prehistoric fossils, was foreseen, until the early 90s, as a new
large-scale landfill. Due to tremendous civil engagement the authorities were
forced to give up the landfill plan and today the area is now preserved for the
scientific community;
� Considerable technical developments in the field of recycling, pre-treatment of
waste and waste incineration; and
� The large scale of greenhouse gas emissions from landfills led also to focus on
a landfill ban due to national greenhouse gas reduction plans.
Therefore the long-term issue was mitigated by introducing a landfill ban of untreated
waste, with the target for implementation set for 2005.
53.3 Key Organisations Involved in Implementation and
Management
The Federal German Ministry of Environment was responsible for the implementation
of the legislation in agreement with the German Länder. The German Länder are in
charge for the ongoing control of the implementation and management in practice in
compliance with the legislation.
53.4 Evaluation Studies Available
For general aspects see:
� Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen,
SRU) Environmental Report („Umweltgutachten“) 2008, July 2008 (See:
http://www.umweltrat.de for further information).
International Review of Waste Policy: Annexes

796
� Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen,
SRU) Environmental Report („Umweltgutachten“) 2004, July 2004 Council of
Environmental Advisors (Sachverständigen Rat für Umweltfragen, SRU)
Environmental Report („Umweltgutachten“) 2002, July 2002.
For the reduction of greenhouse gases by the landfill ban and other measures in
Germany see:
� Contribution of waste management to climate protection and its potentials
(Beitrag der Abfallwirtschaft zum Klimaschutz und mögliche Potenziale),
Dehoust, G. (Öko-Institut e.V.); Umweltbundesamt workshop „Energy from
waste – a significant contribution to climate protection” 6 November 2006,
Berlin.
For the development of waste quantities in intermediate storages see:
� Further decrease of quantities in intermediate storages, EUWID from 15 July
2008.
53.5 Environmental Benefits
The landfill ban has reduced the share of landfill for untreated waste since the
Nineties until the final implementation of the ban in June 2005. The Federal Ministry
of Environment has announced a reduction of 31 million tons CO2-equivalents until
2010 (compared to 1990) resulting from the landfill ban, and further measures for
landfill gas collection and energy recovery. 1000
Furthermore member states of the EU-27 with a low share of landfill are showing the
highest rates regarding recycling/recovery of municipal waste. Concerning the issue
of waste prevention, a moderate reduction of the waste intensity (amount of waste
per GDP) has been detected for Germany. So, a slight decoupling of waste production
from GDP could be said to have occurred, not necessarily related only to the landfill
ban. 1001
53.6 Implementation Costs
According to the BDE, the Technische Anleitung Siedlungsabfall - TaSi (incorporating
the announcement of the disposal ban from 1 June 2005) has promoted investments
of 20 Billion Euro in new treatment, recycling and incineration plants since 1993 in
Germany. 1002
1000 Facts about sustainable waste management, September 2007, www.bmu.de/5886.
1001 Council of Environmental Advisors (Sachverständigen Rat für Umweltfragen, SRU) Environmental
Report („Umweltgutachten“) 2008, July 2008 (See: http://www.umweltrat.de for further information).
1002 BDE: Bundesverband der Deutschen Entsorgungswirtschaft, EUWID, Nr. 28. 12. 07.2005.
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53.7 Effects on Technical Change / Innovation
The quite demanding requirements of the TaSi were eased through use of a long
transition period (1993 to 1 June 2005) to give the authorities enough time to
develop new waste management concepts, and investments in new technologies and
installations.
Higher costs for dealing with waste provide the most obvious incentive for private
households and communities, respectively, to foster waste prevention and, obviously,
where increasing costs relate to disposal, to a much greater extent, waste separation
and recycling.
Knowing the TaSi deadline (1 June 2005) for many years, fundamental changes were
introduced in Germany concerning household waste management over the
intervening 10 – 15 years. In 1999 about 49 % of household waste was recycled. By
2003 the recycling rate had reached 61 %. Furthermore the rate of waste treatment
in municipal waste incinerators (a more expensive, but better way for the
environment) increased, and the rate of disposal in landfills fell. The increase in
incineration is shown in Table 53-1.
Table 53-1: Treatment of Household Waste in Municipal Waste Incinerators in
Germany 1003
797
Year
Year
Municipal Municipal waste
waste
Incinerators
Incinerators
(Number) (Number)
(Number)
International Review of Waste Policy: Annexes
Input Input Capacity Capacity in in
in
Germany Germany in in in total total (in
(in
1,000 1,000 tons/y) tons/y)
tons/y)
Average Average Input Input Capacity
Capacity
per per Incinerator Incinerator (in
(in
1,000 1,000 tons/Y) tons/Y)
tons/Y)
1990 48 9,200 191
1992 50 9,500 190
1993 49 9,420 192
1995 52 10,870 202
1998 53 11,900 225
2000 61 13,999 230
2005 67 16,900 252
2007 1004 72 17,779 247
1003 Daten zur Umwelt, Der Zustand der Umwelt in Deutschland, Ausgabe 2005, Umweltbundesamt
Berlin.
1004 Estimated figure for 2007.

In addition to incineration capacity increasing, the capacity of MBT treatments has
also increased. In some respects, the pace of this development has been more rapid
than that for incineration. The principle legislation allowing the development of the
technology was not finalised until 2001.
A report by the ASA states that there are currently 46 MBT plants operated in
Germany. These plants pre-treat approximately 25 % of the total municipal solid
waste (approximately 6 million tonnes). The pre-treatment processes generate an
estimated 3 million tonnes of a high calorific material with a biogenic content of some
50 %. 1005
53.8 Social and Distributional Consequences
Of course, the disposal ban concerning landfills could not be realized free of any
costs. The increase in costs for private households was a key argument against the
demanding requirements of the TaSi and its consequences. However, in many cities
and counties, it was demonstrated that, in practice, the realization of intelligent waste
management concepts (waste separation, local waste charges with incentives for
waste prevention etc.) delivered positive results. This means, perhaps surprisingly,
that cost savings could be achieved in the overall waste management costs in a given
region. So, even if the disposal costs per tonne increased as a result of the measure,
the costs per household did not necessarily increase in the same way because of the
possibility of generating a dynamic incentive to reduce waste quantities, and increase
recycling rates. This highlights the important role of higher disposal costs incentivising
municipalities to introduce measures such as pay by use to avoid the rising costs of
disposal. 1006
In the county Darmstadt-Dieburg for instance (see Annex 9.0) reductions of the waste
costs for the households are currently under serious consideration of the authorities
due to the successful overall waste management system.
53.9 Complementary Policies
A landfill tax policy could deliver similar results to a landfill ban depending upon the
rate of the tax per tonne of disposed waste. Under German market conditions, a
landfill tax of the order € 100 per tonne of waste would be necessary to achieve
similar results to those of the landfill ban. Depending on the region, and for instance
1005 ASA (Arbeitsgemeinschaft Stoffspezifische Abfallbehandlung) (2008) The Road to MBT Technology,
December 2008; see also T. Grundmann and M. Balhar (2008) Status quo and Perspectives of
Mechnaical Biological Waste Treatment (MBT) in Germany, February 2009.
1006 Interestingly, in Landkreis Schweinfurt, the ban on landfilling of untreated waste was cited as a
major reason for enhancing the sophistication, and strengthening the incentives within, a charging
scheme incentivising household waste reduction. The authority anticipated having to pay higher costs
for disposal of waste to incineration, and in anticipation, sought to incentivise more segregation and
waste reduction activities (see Eunomia (2003), Waste Collection: To Charge or Not to Charge? A Final
report to IWM (EB), http://www.eunomia.co.uk/Charging%20report.pdf.).
798
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the costs for disposal in municipal waste incinerators, an even higher tax rate might
have been necessary.
53.10 Effect of the Policy on Pricing of Resources / Services
The overall driving force for a change in waste management is the fact that the
treatment of household waste in municipal waste incinerators could be up to 10
times higher per ton than disposal on landfills (about 170 – 250 Euro/ton compared
to about 20 – 40 Euro/ton). As a consequence waste prevention and recycling look
better from an economic point of view, because the cheap landfill option is no longer
part of the market, as the ban precludes its use.
53.11 Evasion and Enforcement
Within the last few years serious criminal activities were uncovered mainly in the
eastern German States regarding dumping of untreated waste in landfills as well as
quarries. The scale of these criminal activities amounts to several hundred thousand
tons of waste and proves that in some German States the authorities have a serious
control problem due to often inexperienced staff with uncertainties regarding the
definite role of the different legal bodies. Nevertheless it is interesting to note that
these criminal cases were mainly uncovered by private detective bureaus engaged by
South German companies which are running recycling and incineration plants – and
have problems with an underperformance of their capacities. 1007 , 1008
53.12 Lessons Learned
Not much time has passed since the implementation of the ban, but the overall
success of the policy could be said to be high.
53.13 Prerequisites for Introduction
The essential elements for the policy “landfill ban” are an ambitious and precise
national waste management plan with definite targets and appropriate work plans.
The landfill ban must be embedded in a mid term phase out over time and
incorporate action plans for incineration and recycling capacities in the country. The
local communities need clear advice and support by the government to plan and
come out with the right policies (e.g. “pay as you throw”) on the local level.
1007 EUWID from 8.7.2008.
1008 EUWID from 22.7 2008.
799
International Review of Waste Policy: Annexes

54.0 Waste Levies and Bans (Belgium-Flanders
Case Study)
54.1 Outline of Policy
In Flanders two central policies can be defined to discourage disposal.
800
� Levies on incineration and on landfill give financial incentives to avoid final
disposal; and
� Direct landfill and incineration bans exclude final disposal for a range of waste
types.
Both policies have the same final objective. By avoiding disposal waste has either to
be recycled or its production has to be prevented (direct prevention). The measure
indirectly promotes social prevention as well, if the waste which cannot be landfilled
or incinerated has to be fit for recycling.
54.2 Reasons for Implementation
The VLAREA, the Flemish law on waste management, excludes three waste treatment
applications, i.e. D2 (Land treatment like biodegradation of liquid or sludgy discards
in soils, etc.), D3 (Deep injection such as injection of pumpable discards into wells,
salt domes or naturally occurring repositories, etc.) and D11 (Incineration at sea,
which is in any case already prohibited by EU legislation and international
conventions).
In addition, for certain waste streams, landfill is forbidden, because of the nature of
the wastes, or because the possibility clearly exists to treat it through a means higher
in the waste hierarchy. For some waste streams, both landfill and incineration are
forbidden, which means that at least one preparatory sorting activity has to be
applied to it.
Over and above this, landfills and incineration plants have acceptance criteria
included in their permits to operate.
Landfill and incineration levies are imposed on a wide variety of waste streams and
disposal operations. Some of the levies have been increasing over the years, but all of
them are automatically linked to an index of consumption prices (otherwise known as
the Retail Price Index or RPI).
54.2.1 Landfill and Incineration bans
Landfill is forbidden for:
� Unsorted household waste;
� Waste collected for the purpose of recovery;
� Waste that is, due to its nature, quantity and homogeneity, fit for recycling;
� Incinerable sorting residues from household and comparable waste; and
29/09/09

801
� Old and expired medication.
Incineration is forbidden for:
� Selectively collected waste fit for material recovery or recycling, with the
exception of some types of biowaste if they have a calorific value above 11.5
MJ/kg and are used for the creation of renewable energy;
� Unsorted industrial waste; and
� Unsorted household waste.
A peculiarity of Flemish legislation is the possibility for the Flemish minister to allow
for exceptions from these obligations, on a case-by-case basis, for technical reasons
(mainly due to treatment capacity issues).
54.2.2 Landfill and Incineration levies
The Flemish landfill and incineration levies are one of the most complex systems in
the EU, with 37 different regimes and tariffs. Illegal landfill and incineration is
suppressed with an indexed levy of €150 euro/tonne.
The levies vary based on the possibility to apply more environmentally friendly
alternatives for the treatment of the waste, or to promote recycling. Recycling
residues that are landfilled or incinerated have a lighter levy than the same material
which is landfilled or incinerated directly.
To define ‘recycling residue’ the legislation includes 21 definitions, with percentages
evolving from 3% of weight for the treatment of bottom ashes or garden waste, 5% of
weight for e.g. plastic, wood, paper… up to 25% for used solvents or shredder
residues from scrap treatment. For some waste streams for which no BAT alternative
is present a zero levy is imposed.
Levies are imposed on the treatment installations, with the aim that they cover this
cost through the treatment costs charged to the producer, in order to respect the
polluter pays principle. Waste collectors are also subjected to the levy for the fraction
of the collected waste which is disposed outside of Flanders. If comparable levies
exist outside Flanders, the Flemish levy can be diminished accordingly, but never
becomes a negative value.
The treatment installations have to report the treated quantities of waste every
trimester, and have to pay the levy accordingly.
54.3 Key Organisations Involved in Implementation and
Management
OVAM is involved in the calculation and the collection of the levies, and in the
inspection.
AMI, the Flemish environmental inspectorate, is responsible for the control on the
landfill and incineration bans.
Municipalities have as well an inspection competence, and are involved as they can
install a surcharge on levies imposed on installation on their territory.
International Review of Waste Policy: Annexes

The revenues of the levies are destined for the MINA-fund, to fund all kinds of
environmental programmes.
54.4 Pre-implementation / Evaluation Studies Available
On the website of OVAM www.ovam.be several manuals and FAQ files can be found
on the practical aspects of the levies (in Dutch).
OVAM (2007) Tarieven en capaciteiten voor storten en verbranden (actualisatie tot
2006, evolutie en prognose). This is a yearly report on tariffs for landfill and
incineration plants and on available, and foreseen, capacities. It includes, each year,
a comparison between the net costs and the levies for each type of treatment.
54.4.1 Environmental Benefits
The goal of the levies is to discourage final disposal and to make landfill, which is at
the bottom of the waste treatment hierarchy, more expensive than incineration. As
Figure 54-1 shows, this situation exists for household waste, but this is not quite the
case for industrial waste.
Figure 54-1: Operational Costs and Levies for Landfill and Incineration in Flanders
euro/ton
802
140
120
100
80
60
40
20
0
29/09/09
landfill
hazardous waste
costs and levies for waste disposal 2006
landfill
industrial waste
incineration
low caloric
industrial waste
incineration
high caloric
industrial waste
tarif levy
The levies for landfill usually equal or exceed the pre-levy costs for landfilling, while
the levies for incineration are merely a small correction on a relatively high pre-levy
cost.
Hazardous waste is incinerated in specialised plants, but the costs are very much
dependent on the nature of the waste so that a comparison with the costs of
landfilling is not meaningful. Moreover, landfill and incineration do not compete as
such in the market for hazardous waste since the waste streams usually follow
different routes.
landfill
household waste
incineration
household waste
landfill inert waste

Even with high landfill levies, the total price for landfilling of industrial waste remains
more attractive than incineration. A zero levy for incineration would not rectify this
situation. Even after 27 years of levies with shifting and augmenting levies on landfill
and incineration this undesired effect has not been corrected, and other policy
instruments have to be applied to avoid industrial waste being landfilled.
Figure 54-2 and Figure 54-3 show how the landfilling and incineration of waste has
changed over time. Incineration of household waste remains stable in absolute
quantities whilst incineration of industrial waste has slowly increased. Compared with
the total production of industrial waste, incineration remains marginal. Landfill is still
the more widely applied disposal technique than incineration for industrial waste.
Figure 54-2: Evolution in Landfill of Household and Industrial Waste in Flanders
kton
803
7.000,00
6.000,00
5.000,00
4.000,00
3.000,00
2.000,00
1.000,00
0,00
International Review of Waste Policy: Annexes
landfill evolution
1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005
landfill industrial waste landfill household waste

Figure 54-3: Evolution in Landfill of Household and Industrial Waste in Flanders
kton
804
7000
6000
5000
4000
3000
2000
1000
0
29/09/09
incineration evolution
1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005
54.5 Implementation Costs
incineration industrial waste incineration household waste
Landfill and incineration bans can impose the financing of more expensive waste
treatment or waste recycling technologies on waste generators.
The aim of the landfill and incineration levy is not to finance the MINA-fund, but to
steer waste to better waste treatment techniques. The revenues drop, or remain
stable, even when each year, higher tariffs are used (see Figure 54-4).
54.6 Effects on Technical Change / Innovation
In Germany, landfill bans have been imposed with a clearly marked transition period
between publication in the state courier and entry into force. This has created some
adverse effects with landfills that have tried to use all remaining permitted capacity,
but in general it has stirred the waste treatment industry to develop and install
alternative waste treatment facilities.
In Flanders, the landfill and incineration bans entered into force from the moment
they were published, but the implementing mechanism allowed for individual
exemptions as well. The effect is that industry has focused on addressing these
exemptions, based on capacity problems, rather than on installing new technologies.

Figure 54-4: Revenues from Flemish Levies on Landfill and Incineration
milieon euro
805
90
80
70
60
50
40
30
20
10
0
79,3
International Review of Waste Policy: Annexes
revenues levies on landfill an incineration
66,8
53,7
41
38
40
40,7
2001 2002 2003 2004 2005 2006 2007
54.7 Social and Distributional Consequences
No social or distributional consequences have been observed under the latest version
on the legislation (see Section 54.10). However, it might be expected that the levy
does affect some industrial sectors more than others, notably those which would, in
the absence of the levy, tend to be more reliant on landfilling.
Some municipalities which host large landfills or incinerators that serve a whole
region can benefit from the revenue derived from the levies, which can become an
important source of income for the municipal administration. The effect can be an
eagerness to host these kinds of installations.
54.8 Complementary Policies
Levies on waste disposal can only be effective in terms of their environmental effects
if alternative management routes are available through recycling or prevention. Levies
should, therefore, be accompanied by instruments promoting, or enhancing, recycling
and prevention.
The policy is complementary to other environmental levies, of which the most
important is a levy on wastewater.
An essential complementary policy is the MINA-fund, where the revenues are
combined with other revenues from different environmental levies. The levies gain
public acceptance if the revenues are used for environmental policies. The MINA-fund
is used to support the project arm of OVAM and the other environment
administrations.

54.9 Effect of the Policy on Pricing of Resources / Services
The waste levies are intended to be regulating, which means that the polluter should
pay and, as a result, be motivated to prevent or recycle his / her waste. When
payment of a levy can be recovered through use of tax allowances, the incentive
effect disappears, and society carries the costs of the levy. Flemish law has recently
been adapted to prohibit levies being deducted from corporation tax as company
expenditures.
As companies cannot recover their levies via their tax declaration, an inequality has
risen between private companies and intermunicipal utility companies, since the
latter do not have to pay taxes. Therefore the Flemish government has introduced a
provision whereby companies that have to pay taxes can diminish their levies by a
factor of 0.7.
The main argument introduced by OVAM is an alignment between companies subject
to corporate taxes and associations which are not. The compensation with factor 0.7
intends to create equality between market rates applied by intermunicipal operators
and by private operators.
In order to compensate for the non tax deductible costs, a private operator will charge
the waste producer a more expensive price (corresponding to the corporation tax that
has to be paid). Waste companies state that their prices are increased by a factor
1.51 as a result of the inequality. For each €100 of disposal levy, the operator will
charge a waste producer €151. In this way he was suffering a competitive
disadvantage relative to an intermunicipal utility company that can charge €100 of
levy as €100 to be paid by the producer.
Now, private operators can diminish their levies by a factor 0.7. Instead of €100, they
pay only €70 to government. They charge the waste producer, however, €70
multiplied by 1.51, which is comparable to the €100 paid by the intermunicipality
(slightly higher at 70 x 1.51 = 105).
54.10 Evasion and Enforcement
For several years, waste levies were avoided by classifying wastes as sorting residues,
which attract a much lower tariff. Waste lorries with mixed waste entered the sorting
plant and immediately left the plant with the same load, but with waste now called
“recycling residue”.
To avoid this activity, percentages of what is acceptable as recycling residue have
been introduced in the legislation. A perverse effect is that now, waste is mixed up
until the maximum percentage of recycling residue is obtained, so that it can be
landfilled or incinerated with diminished levies.
The municipalities can demand surcharges on the levies for companies on their
territory. It is sometimes more effective to charge levies for illegal dumping or
incineration than to seek to obtain a prosecution and to seek to have a fine imposed.
Levies, and surcharges, can be demanded on a quarterly basis until an illegal dump
has been cleaned.
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54.11 Lessons Learned
A complex system can be very balanced and can contain a lot of measures to avoid
adverse effects or unjust levies, but a complex system opens a lot of space for
discussion, and many issues of interpretation. A simple system is more transparent
and easier to manage and to control. The right balance between simplicity and
complexity has to be found.
Very high standards for the administration are necessary, as the system is susceptible
to fraud, since large amounts of money are involved and interpretation issues can
arise.
It should not be able to offset levies against corporate taxes, unless a choice is made
for a financing contribution instead of a regulating levy.
The German model for introducing a landfill ban (a strict ban with a future starting
date) is more able to stir waste treatment and recycling investments than the Flemish
approach with an immediate introduction and a system for exemptions.
Levies can support the waste treatment hierarchy, if they serve to make landfilling
more expensive than incineration, and definitely more expensive than recycling.
54.12 Prerequisites for Introduction
The following would appear to be pre-requisites for such levies:
807
� Legal and fiscal know-how within the waste administration;
� Enough manpower for a strict follow up, both for interpreting the levy
declarations on paper and the inspection on the field; and
� Political will to introduce a tax.
International Review of Waste Policy: Annexes

55.0 Landfill Allowance Schemes (UK)
55.1 Outline of Policy
The principle policy for ensuring that the targets under Article 5 of the Landfill
Directive are met in the UK are the Landfill Allowances Schemes (LASs). The targets,
and hence, the LASs, apply only to municipal waste, and so, the definition of
municipal waste acquires some significance.
55.1.1 UK Definition of Municipal Waste
“Municipal waste” is defined in Article 2(b) of the Landfill Directive as: 1009
808
29/09/09
“waste from households, as well as waste which, because of its nature or
composition, is similar to waste from households”.
When implementing the Landfill Directive, UK Government followed the ‘copyout
approach’ and included a definition of ‘municipal waste’ in the Waste and Emissions
Trading Act that is similar to that in the Landfill Directive: 1010
“(a) waste from households, and
(b) other waste that, because of its nature or composition, is similar to waste
from households.”
In an attempt to provide certainty and clarity through consistent interpretation the
Government set out, in guidance which was the subject of repeated consultation, its
view that this definition encompasses ‘all waste under the control of local
authorities’. Under this interpretation it follows that any waste which passes the test
of being in the possession or under the control of a waste disposal or collection
authority, and so potentially within the LAS regime, also passes the test of being
municipal waste, and so is within the LAS regime. It is on this interpretation that LAS
has been designed and operates.
55.1.2 Devolved Administrations and The Role of Waste Disposal
Authorities
Prior to the late 1990s, the market for municipal waste services could be considered
to be ‘a UK one’. Even so, within the UK, different waste management companies
have their own regional strongholds, as well as their own areas of specific expertise.
Since the late 1990s, the different devolved administrations have started to shape
their waste management strategies in ways which are specific to their own
circumstances and priorities. They have, however, been constrained in their ability to
1009 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste Official Journal L 182 ,
16/07/1999 P. 0001 – 0019.
1010 Waste and Emissions Trading Act 2003, Part 1: Waste, 13 th November 2003.

forge a genuinely ‘autonomous’ path by virtue of the fact that some key aspects of
legislation – notably fiscal policy – still fall under the competence of Whitehall
Government. So, for example, the different administrations could not set the Landfill
Tax at the level they may have wished because Whitehall effectively controls fiscal
policy. 1011
The different devolved administrations have different local government structures. In
England, local government responsibilities are often split into two tiers, those of the
lower-tier (the District and Borough Councils) and those of the upper-tier (the County
Councils), though in some (usually metropolitan) areas, the responsibilities are vested
in one single body and they are known as Unitary Authorities. Waste collection is a
responsibility of the lower-tier of local government, and these are called Waste
Collection Authorities (WCAs). Waste treatment and disposal, as well as operation of
civic amenity sites and spatial planning as it affects waste, are all responsibilities of
the upper tier, known as Waste Disposal Authorities (WDAs). Unitary Authorities fulfil
the functions of both WCA and WDA for the area they cover.
The picture is complicated further in some areas, such as Greater Manchester,
Merseyside and London, in that in these areas, there exist Statutory Joint Waste
Disposal Authorities (SJWDAs), which are not local authorities in the conventional
sense (their only raison d’etre is to deal with waste matters), but which take on most
of the responsibilities of the upper tier of local government as regards waste in those
areas they cover.
This rather complex system of local government organisation is not replicated in
Scotland, Wales and Northern Ireland. All local authorities are unitary in these
administrations. In principle, this should imply that decision making in these
administrations is more streamlined.
In summary, regarding local government structures, and with particular emphasis on
the responsibility for waste disposal:
809
� In England, there are 394 local authorities. As regards waste disposal matters,
there are 121 waste disposal authorities (including SJWDAs). Some of the 121
authorities are, where residual waste is concerned, working in partnerships of
more than one WDA;
� In Wales, there are 22 Unitary Authorities. The Welsh authorities are also
forming groupings. We believe there are currently 9 ‘groupings’, though there
is still some movement among these;
1011 Scotland and Wales, for example, have lamented the slow pace at which the tax has increased, as
well as the fact that they have no control over the use of the revenue raised. Scotland and Wales are
also covered by the Environmental Protection Act 1990 (and subsequent amendments) which
effectively prevents local authorities from charging households directly for waste. These are two key
policies which, taken in combination, would have been sufficient to drive recycling rates higher and
faster over the recent past.
International Review of Waste Policy: Annexes

810
� In Scotland, there are 31 Unitary Authorities. For the purposes of waste
management, these 31 authorities formed groupings known as Waste Strategy
Areas, of which there are 11;
� In Northern Ireland, there are 26 unitary authorities. These have formed 3
Groupings for the purposes of waste management. However, it should be
noted that now that the Northern Ireland Assembly is ‘active’ (after many years
in suspended animation), a fairly major restructuring of local government is
being considered, the proposed outcome of which is consolidation of areas
which are not consistent with the borders of the Regions working together on
planning for municipal waste.
As far as waste disposal is concerned, therefore, across the UK, one could say that
there are something of the order 200 WDAs.
55.1.3 Basics of the LASs
The Waste and Emissions Trading Act 2003 essentially transposes the Landfill
Directive into UK law, and was granted Royal Assent on 13 November 2003. 1012 The
legislation gives the Secretary of State powers to impose a duty upon WDAs to ensure
that they landfill no more biodegradable municipal waste than that for which they
hold the equivalent number of landfill allowances.
Within the UK, the different devolved administrations have each adopted an approach
to meeting the Article 5 Landfill Directive targets which makes use of the allocation,
to local authorities, of a diminishing (over time) number of allowances for the disposal
of biodegradable municipal waste to landfill. Biodegradable municipal waste (BMW)
has to be dealt with in ways other than landfill in line with the overall allocation of
allowances, with key target years being 2009/10, 2012/13 and 2019/20.
The details of the Landfill Allowances Schemes (LASs) in the different countries are
not the same (see Table 55-1). Notably, England and Scotland allow trading of
allowances (hence, in England, the scheme is known as the Landfill Allowances
Trading Scheme, or LATS), whilst Wales and Northern Ireland do not. In addition, for
the purposes of making mass balance calculations, the biodegradable content of
waste is assumed to be different in the different countries. 1013 Finally, as a point of
technical detail, the quantity of BMW landfilled can be reduced either through
sending less material to landfill or through reducing the biodegradability of waste
which is landfilled. The approach to measuring loss in biodegradability is different in
Scotland to the approach in the other administrations of the UK.
It is clearly a simplification to believe that all local authorities will have similar waste
composition. Indeed, the fact that the composition of waste in the different devolved
1012 Waste and Emissions Trading Act 2003, Part 1: Waste, 13 th November 2003.
1013 Work is ongoing in Defra to estimate the current biodegradable content of waste in England, and a
review has also taken place in Northern Ireland. Our understanding is that latest estimates suggest a
downward shift in biodegradable content in both areas. We are not, however, able to make use of this
data at this stage as it is not in the public domain.
29/09/09

administrations is deemed to change as one crosses borders between the countries
of the UK highlights a peculiarity of the approach this is. It is well known that
(amongst other things) differences in housing types, and differences in
socioeconomic standing will influence the composition of household waste.
Another factor which will influence composition is the nature and quantity of
commercial waste collected as municipal waste in any WDA area. Whether this is
collected at household waste recycling centres (HWRCs) or at commercial premises
on collection rounds is likely to determine how much of the non-household waste is,
for example, inert rubble or biodegradable paper.
Table 55-1: A Comparative Analysis of the Landfill Allowance Schemes in England,
Wales, Scotland and Northern Ireland
Name Name of of the
the
Scheme
Scheme
Biodegradable
Biodegradable
content content content of of
of
municipal municipal municipal waste waste
waste
Introduction
Introduction Introduction of
the the scheme
scheme
Trading Trading of
of
allowances
allowances
The The Landfill
Landfill
Directive Directive targets
targets
for for each each of of the
the
countries
countries
(tonnes (tonnes of of
of
biodegradable
biodegradable
biodegradable
municipal
municipal
waste)
waste)
811
England England Wales Wales
Scotland Scotland Northern Northern Ireland
Ireland
Landfill
Allowance
Trading Scheme
International Review of Waste Policy: Annexes
Landfill
Allowances
Scheme
Landfill
Allowances
Scheme
68% 61% 63% 71%
Landfill
Allowances
Scheme
1 April 2005 1 October 2004 1 April 2005 1 April 2005
Trading is
permitted
although not
obligatory.
2009/10 2009/10 2009/10 –
11,200,000
2012/13 2012/13 2012/13 – 7,
460,000
2019/20 2019/20 2019/20 –
5,220,000
Sanctions Sanctions £150 per tonne
excess BMW
landfilled
No trading of
allowances
2009/10 2009/10 –
710,000
2012/13 2012/13 –
470,000
2019/20 2019/20 –
330,000
£200 per tonne
excess BMW
landfilled
Trading will be
permitted from
2008. Before
2008, waste
disposal
authorities may
be able to swap
allowances, at
the discretion of
the Executive.
2009/10 2009/10 –
1,320,000
2012/13 2012/13 –
880,000
2019/20 2019/20 –
620,000
£150 per tonne
excess BMW
landfilled
No trading of
allowances.
Transfer of
allowances
between
authorities
permitted.
2009/10 2009/10 –
470, 000
2012/13 2012/13 –
320, 000
2019/20 2019/20 –
220,000
£150 per tonne
excess BMW
landfilled
Source: Defra (http://www.defra.gov.uk/environment/waste/localauth/lats/pdf/latscomparanalysis.pdf)
The quantity of commercial waste collected itself is affected by strategic and policy
decisions made by WCAs and WDAs. As such, the grandfathering of allowances (i.e.

their allocation based on past quantities collected) is likely to imply the awarding of
assets to those who may have made strategic decisions in the past to maximize
commercial waste collection as a revenue-raising activity for their Direct Service
Organisations (DSOs). The only way to limit the degree to which the value of these
assets can be realized without taking any effective action is to seek to restrict the
degree to which the proportion of non-household waste collected in municipal waste
can change over time.
Defra has tried to clarify the way in which non-household waste is to be dealt with by
local authorities. Specifically, it has sought to restrict the degree to which local
authorities can reduce the amount of commercial waste they collect by providing
clarification of its interpretation of Section 45(1) of the Environmental Protection Act
1990. 1014 However, would-be commercial waste customers choosing, in possession of
all the facts, a lower cost service than one on offer from a given local authority could
not be restrained from making such a choice. It would be difficult to argue that such
waste would remain ‘under the control of’ the local authority concerned where it is no
longer chosen as the collection contractor.
It can be seen that both the allocation mechanism and the way in which the
biodegradable content of landfilled waste is calculated are likely to lead to some
perverse strategies being developed, notwithstanding Defra’s move to try to head off
actions by local authorities intending to reduce the amount of commercial waste they
collect. It is doubtful whether Defra could really require local authorities to continue to
collect commercial waste from their existing customers, and the recent court
judgement in the case of WRWA v Wandsworth would tend to support this view. 1015
The additional risk that this would imply in respect of maintaining a balance of
allowances sufficient to cover the quantity of BMW being landfilled could itself be
argued as justifying an increase in the price of the service being offered by the local
authority. Since competitors in the market for the provision of commercial waste
collections in the WDA area would not be faced with any such risk (the waste would
not fall under the definition ‘municipal’), then this would be tantamount to forcing
customers to choose a higher priced service, thereby restraining trade. 1016
1014 Defra (2004) Municipal Waste, Commercial Waste and the Landfill Allowances Trading Scheme,
http://www.defra.gov.uk/ENVIRONMENT/waste/localauth/lats/pdf/lats-municipalwastedefine.pdf.
1015 In this judgement, Justice Evans-Lombe ruled that WRWA, which sought judicial review of a
decision made by Wandsworth BC to set charges for trade waste which effectively reduced the quantity
of waste collected by the authority, had no case for such a review. In other words, Wandsworth had not
acted outside the law in essentially seeking to reduce its collection of non-household municipal waste..
1016 Matters would, or course, have looked somewhat different had Defra taken the view that municipal
waste did in fact include all commercial waste in the WDA area, irrespective of who collected it. This
would have made the tasks of data acquisition and verification more difficult, but it would also have
led, potentially, to a more rational form of collection logistics rather than encouraging its
fragmentation. It might also have ensured a more enlightened approach to procurement of facilities in
which treatment facilities were designed to deal not only with the material collected by the WCAs /
WDAs, but also with the wider commercial wastes.
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The desire to improve recycling performance on the part of WCAs is over-shadowed by
the desire of WDAs to ensure that they comply with the terms of the Landfill
Allowances Scheme under which they are operating. This relates to the mechanisms
for implementing sanctions. These exist for the LASs (in the form of fines), but not for
the recycling targets, though the administrations apply mechanisms which make
achieving recycling targets likely to draw in additional funding from central
government.
55.2 Timetable
The underpinning work for the LAS was a review of policy options carried out for Defra
in 1999. 1017 This led to the issuing of a consultation document in the same year,
Limiting Landfill, which set out policy options for compliance with the Landfill
Directive, responses to which favoured a scheme similar to the one which
subsequently emerged. 1018 A further consultation was carried out in 2001. 1019
However, although it was widely accepted that the scheme would enter into force,
details were not agreed until 2004. The Waste and Emissions Trading Act (2003) was
given further substance by the Landfill Allowances and Trading Scheme (England)
Regulations 2004, and similar documents (listed below) for the other devolved
administrations, these having been consulted upon in the countries concerned.
813
� The Landfill Allowances Scheme (Scotland) Regulations 2005
� The Landfill Allowances Scheme (Wales) Regulations 2004
� The Landfill Allowances Scheme (Northern Ireland) Regulations 2004
The LASs ‘went live’ on April 1 2005.
55.3 Key Organisations Involved in Implementation and
Management
The principal players are:
� The WDAs themselves;
� The regulators (the Environment Agency, SEPA and the Environment and the
Northern Ireland Environment Agency), who act as auditors for the scheme,
reviewing data and the balances of allowances held by WDAs; and
� Defra, the Scottish Executive, the Welsh Assembly Government, and the
Department of Environment Northern Ireland, who are the allocating
authorities in their respective countries.
1017 D. Hogg (1999) Policy Instruments to Implement the Proposed Landfill Directive BMSW Targets,
Final Report to DETR.
1018 DETR (1999) Limiting Landfill, October 1999, London: HMSO. Devolved administrations carried
out similar consultations.
1019 DETR (2001) Tradable Landfill Permits Consultation Paper, March 2001, London: HMSO.
International Review of Waste Policy: Annexes

55.4 Pre-implementation / Evaluation Studies Available
There were some studies which sought to understand the potential impact of the
LASs. One sought to outline potential instruments. 1020 Another study sought to
understand the interaction between the allowances system and the landfill tax. 1021
However, both of these focused upon the mechanisms rather than the expected
outcomes from the schemes.
55.5 Environmental Benefits
The environmental benefits of LASs are somewhat difficult to discern. In truth, the
effects appear to be varying by devolved administration, though this masks the
underlying activities which are leading to preparation for procurement of
infrastructure. The following comments examine the situation in each of the devolved
administrations. However, these comments are contextualised by some crucial points:
814
� The path to reducing landfilled BMW under a time constraint is achieved most
quickly through improving collection systems; and
� Procuring and commissioning infrastructure for treating residual waste has
been slow, partly owing to the nature of the procurement process, and partly
owing to the nature of what is being procured.
Hence, in the short-term, many authorities have focused upon recycling and
composting, recognising the time taken to procure residual waste treatment
infrastructure.
55.5.1 England
In England, the LASs have been crucial in focussing the minds of local authorities on
their obligations to deliver the Landfill Directive targets. Waste Strategy for England
2007 increased recycling targets for household waste, partly in recognition of the fact
that the pace of residual waste treatment was not sufficient to ensure Landfill
Directive targets would be met, and partly in recognition of the climate change
benefits of recycling.
Table 55-2 shows how landfilled BMW has declined in the UK over the first full years
of audited data. A 7% decrease in BMW landfilled was followed by an 8% decrease in
2007/8, so that in 2007/08, England landfilled 85 per cent of the BMW landfilled in
the first scheme year.
1020 D. Hogg (1999) Policy Instruments to Implement the Proposed Landfill Directive BMSW Targets,
Final Report to DETR.
1021 D. Hogg and R. Salmons (1999) Instruments to Implement the Proposed Landfill Directive BMSW
Targets, Final Report to DETR.
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Table 55-2: BMW Landfilled in England
815
Year Year BMW BMW BMW landfilled landfilled (tonnes) (tonnes) Percentage Percentage of of of previous previous year’s year’s year’s BMW BMW BMW landfilled
landfilled
2007/08 10,581,953 92
2006/07 11,548,213 93
2005/06 12,380,966 Not applicable
Source: Environment Agency (2008) Report on the Landfill Allowances and Trading
Scheme 2007/08, November 2008
In England, the recycling rate for household waste has continued to increase over
time, but so has the proportion of waste dealt with through incineration and MBT.
The effectiveness of the scheme might also be considered through assessment of
prices for landfill allowances in future years. The trading scheme allows for forward
buying and selling of allowances. Currently, for what many thought would be a crunch
year in 2012/13 (the second target year), allowances are being traded well below the
level of fines (£150 per tonne) at around £15-£20 per tonne. Logically, now that it is
known that landfill tax will increase to £72 per tonne, the price of landfill allowances
ought to be rather small since this should reflect, in the equilibrium situation, the
difference between the costs of landfilling and the costs of the marginal treatment
option for reducing BMW landfilled.
55.5.2 Wales
In Wales, the development of residual waste treatment has been somewhat slow.
Notwithstanding this, the Welsh assembly Government is developing a waste strategy
which is intended to ensure that the 2013 Landfill Directive targets can be met
principally through source separation, with a target of 70% recycling being set (63%
through source separation, 7% from recycling of residual waste and treatment
residues).
The following information comes from the Environment Agency. 1022 Thus far, the
strategy is working. All 22 local authorities in Wales achieved their 2007/8 allowance
obligations. In 2007/8, Welsh local authorities sent 680,9121 tonnes of
biodegradable municipal waste (BMW) to landfill compared to the 2007/8 allowance
allocation of 866,000 tonnes (or 21% less BMW was landfilled in Wales relative to
the allowance allocation).
91% of local authorities in 2007/8 reduced the actual amount of BMW sent to landfill
compared to 2006/7. Two local authorities sent more BMW to landfill than in
2006/7, these being Ceredigion and Flintshire. Over the three years to 2007/8,
Wales reduced the amount of BMW sent to landfill by 20%, or 170,577 tonnes
1022 Environment Agency (2008) Report on the Landfill Allowances Scheme (Wales) 2007/08,
September 2008.
International Review of Waste Policy: Annexes

compared to the amount landfilled in 2005/6. Wales is currently landfilling 4% less
BMW (29,088 tonnes) than it is required to under the first Landfill Directive reporting
year in 2009/10.
Procurement Hubs have now been established in Wales with the intention of
procuring both facilities for the anaerobic digestion of separately collected food waste
and the treatment of residual waste. Under the new Welsh Strategy, local authorities
will be required to collect food waste separately. 1023 The Welsh Assembly Government
is supporting these procurement efforts.
55.5.3 Northern Ireland
Between 2005/06 and 2007/08, there was a decline of 8.57% in BMW landfilled. 1024
Municipal waste arisings decreased by 0.28% between 2006/07 and 2007/08,
whilst the municipal waste recycling rate increased from 25.54% to 28.48%. If BMW
landfilled remained constant at 2007/8 levels, Northern Ireland as a whole in
2009/10 would have a deficit of allowances of 40,205 tonnes.
However, the reduction in BMW sent to landfill should continue to decrease as the
three waste management groups continue to implement their Waste Management
Plans.
55.5.4 Scotland
In Scotland, landfilled BMW has fallen steadily over time. The BMW landfilled in
2007/08 was 79% the level of 2004/05. The quantity incinerated had remained
more or less constant. Total MSW was relatively static, but the recycling rate
increased from 17% to 31% (see Table 55-3).
Table 55-3: Evolution of Recycling and Landfill in Scotland
MSW MSW MSW Landfilled Landfilled Incinerated
Incinerated
Recycled Recycled Recycled / /
/
Composted Composted
Composted
BMW BMW
BMW
Landfilled Landfilled
Landfilled
BMW
BMW
Landfilled
Landfilled
as as % %
%
2004/05
2004/05
2004/05 3,407,978 2,748,819 71,548 588,039 1,724,273
2005/06 3,415,594 2,504,085 77,844 833,679 1,541,557 89%
2006/07 3,437,046 2,398,433 60,947 977,655 1,471,026 85%
2007/08 3,413,701 2,256,661 74,603 1,082,438 1,369,614 79%
Source: SEPA Landfill Allowance Scheme Reports
1023 This followed analysis of the financial case for doing so – see Eunomia (2008) Scoping New
Municipal Waste Targets for Wales, Report for the Welsh Local Government Association and the Welsh
Assembly Government.
1024 Northern Ireland Environment Agency (2008) The Landfill Allowance Scheme Regulations (2004)
Northern Ireland (NILAS) 2007/08 Annual Report, October 2008.
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55.6 Implementation Costs
The intention of the England scheme – involving trading – was to enable a target for
landfilling BMW to be met at least cost to the country. Clearly, costs have been
incurred in administering the scheme, but as a mechanism for meeting the Landfill
Directive, the scheme appears to have been quite successful thus far. Other
institutional factors in UK waste management are making compliance poorer value,
and there is a suggestion that in residual waste procurements, bidders are increasing
prices in the expectation that local authorities will accept these bids because of the
risk of exposure to landfill allowance deficits or fines.
55.7 Effects on Technical Change / Innovation
Our experience of working with local authorities is that the LASs are clearly
influencing the pace of development of recycling and composting, and are focusing
local authority minds on developing residual waste treatment facilities. Efforts to
reduce waste are also being heightened in some authorities.
Equally, the LASs are making authorities more commercially aware.
It is interesting to note that the LASs effects in terms of the delivery of residual waste
treatment infrastructure has been less apparent than the flurry of activity to engage in
procurement processes. One reason for this is the lengthy period taken to deliver
waste facilities, particularly those of more capital intense nature, and those which
have proved more contentious at the siting stage. Indeed, some commentators
suggest there is still a possibility that the UK may not meet its targets for 2013, but
that it might be tending towards over-capacity in the medium- to long-term. This is
because the lead-times are long, and, some have argued, the process of developing
facilities should have begun much sooner:
817
The EU Directive in 1999 created a need for a strategy for significantly
increasing diversion of waste away from landfill. Before 2003 the
Department’s strategies lacked practical plans for reducing reliance on
landfill. Only then did the Department start to address the complex issues
involved in building new waste treatment infrastructure. As a result, the
market for waste infrastructure projects developed slowly. Only two of the new
waste infrastructure projects developed since the EU Directive (1999) have
completed construction of all planned assets. 1025
Equally, it might be argued that the choice of facility and the approach to
procurement has tended to lengthen lead-times rather than shorten them. The NAO’s
review lends some support to this view:
Prior to contract award, PFI projects have been delayed by an average of 19
months compared to the original timetables. Some delays occur because
projects need to improve their business cases to gain central government
1025 NAO (2009) Managing the PFI Waste Programme, Report by the Comptroller and Auditor General,
HC 66 Session 2008-2009, 14 January 2009.
International Review of Waste Policy: Annexes

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approval. The current difficulties in the financing markets are also delaying
large deals. Some projects have, however, been funded by contractors out of
existing financial resources giving the prospect of faster deal closure. After
contract award, delays have occurred because some projects have
encountered difficulty in obtaining planning permission. 1026
55.8 Social and Distributional Consequences
There are no obvious consequences of this nature other than those which would flow
from Landfill Directive implementation. To the extent that authorities have had to
make allowance purchases thus far, these have been at low prices, implying costs per
annum of the order €1 per household per annum, and less, thus far.
55.9 Complementary Policies
The landfill tax has operated alongside the LASs. However, local authorities might
argue that the tax does not operate as a ‘complementary’ policy, but rather, that it
overlaps.
Recycling targets have been broadly complementary to the LASs to the extent that
where recycling increases, frequently, some or all of the additional material targeted
for collection is biodegradable (paper, card, food waste, garden waste, textiles, etc.).
Regulations have also been passed to enable assessment of the loss in
biodegradability achieved by biological treatment plants.
55.10 Effect of the Policy on Pricing of Resources / Services
The LASs have an effect on the infra-marginal tonnages of biodegradable waste which
is to be landfilled (i.e. the tonnages above the amount for which allowances are held).
The effect is to increase the costs of landfilling these infra-marginal tonnes. However,
the increase in cost is determined by the demand for allowances where allowances
are tradable (as in England), and by the level of fines where trading is prohibited (as,
for example, in Wales).
The effect of this on the behaviour of local authorities has been significant. Indeed,
although it was widely anticipated (since 1999) that a scheme such as the LASs
would be introduced, many local authorities’ waste officers found it difficult to make
the case for investing in new services and infrastructure to meet their obligations until
it became clear that a sanction, in the form of fines, would be applied in the event of
failure to discharge obligations under the scheme. This enabled waste officers to
make the case to finance officers and Chief Executives of their local authority along
the lines that failure to improve services could trigger significant financial penalties.
The magnitude of the fines - £150 per tonne of biodegradable waste landfilled for
which no allowance is held (and £200 per tonne in Wales) – is highly significant in the
1026 NAO (2009) Managing the PFI Waste Programme, Report by the Comptroller and Auditor General,
HC 66 Session 2008-2009, 14 January 2009.

context of UK waste management where landfill gate fees are of the order £20 per
tonne before landfill tax, with tax currently (in April 2009) at £40 per tonne. The
business case for dealing with waste in ways other than landfilling has been
considerably strengthened by the prospect of fines, or the need to purchase
allowances at a relatively high cost.
Interestingly, however, although many local authorities developed business cases on
the basis that fines could be triggered, in England, where trading is allowed, the value
at which allowances have been traded has been rather low. This was to be expected
in early years since WDAs’ allocation of allowances were based on a system of
grandfathering, with allowances issued tapering towards a fixed share of the UK
quota of allowances for the first target year, 2009/10 (the UK has availed itself of the
four-year derogation, available to those countries who were landfilling more than 80%
of their municipal waste in 1995).
In target years, and one year immediately before and after each target year, the
freedom to bank and borrow allowances is completely, and partially restricted,
respectively. This means that from 2009/10 to 2012/13, there is limited potential to
bank and borrow allowances, moving the allowance market into a ‘clearing’ situation.
Many commentators expect allowance values to increase as a result of supply being
much tighter, and demand for allowances increasing. Even so, forward purchases of
allowances are beginning to occur for those years, and prices for allowances of
between £12-£25 are being offered.
This suggests that, as with many other allowance trading schemes, the traded value
of allowances may be lower than commentators have expected. However, it remains
too early to say how the market will look in 2012/13, with recent commentators still
suggesting a shortfall is possibly, and indeed, likely.
55.11 Evasion and Enforcement
The Environment Agency has audited data from WDAs and has commented upon the
issues which are arising in terms of reporting of data. 1027 They report on data as
received, and some comments are picked up below, but a more general issues with
the scheme is the way in which it has led to shift in waste across administrative
categories, from ‘municipal’ waste into commercial waste, though local authorities
withdrawing from the provision of collection services for commercial waste.
Defra has tried to clarify the way in which non-household waste is to be dealt with by
local authorities. Specifically, it has sought to restrict the degree to which local
authorities can reduce the amount of commercial waste they collect by providing
clarification of its interpretation of Section 45(1) of the Environmental Protection Act
1990. 1028 However, would-be commercial waste customers choosing, in possession of
1027 Environment Agency (2008) Report on the Landfill Allowances and Trading Scheme 2007/08,
November 2008.
1028 Defra (2004) Municipal Waste, Commercial Waste and the Landfill Allowances Trading Scheme,
http://www.defra.gov.uk/ENVIRONMENT/waste/localauth/lats/pdf/lats-municipalwastedefine.pdf.
819
International Review of Waste Policy: Annexes

all the facts, a lower cost service than one on offer from a given local authority could
not be restrained from making such a choice. It would be difficult to argue that such
waste would remain ‘under the control of’ the local authority concerned where it is no
longer chosen as the collection contractor.
It can be seen that both the allocation mechanism and the way in which the
biodegradable content of landfilled waste is calculated are likely to lead to some
perverse strategies being developed, notwithstanding Defra’s move to try to head off
actions by local authorities intending to reduce the amount of commercial waste they
collect. It is doubtful whether Defra could really require local authorities to continue to
collect commercial waste from their existing customers, and a court judgement in the
case of WRWA v Wandsworth would tend to support this view. 1029 The additional risk
that this would imply in respect of maintaining a balance of allowances sufficient to
cover the quantity of BMW being landfilled could itself be argued as justifying an
increase in the price of the service being offered by the local authority. Since
competitors in the market for the provision of commercial waste collections in the
WDA area would not be faced with any such risk (the waste would not fall under the
definition ‘municipal’), then this would be tantamount to forcing customers to choose
a higher priced service, thereby restraining trade. 1030
Although one cannot be sure that changes in the rate of growth of municipal waste at
a national level are occurring at the expense of an increase in the rate of growth of
commercial waste (because the quality of data on commercial waste does not such
an analysis to be undertaken), the simple fact is that Eunomia is well aware that this
happening on a wide scale.
In addition to the above points, the reporting of data by local authorities clearly leaves
something to be desired. The Environment Agency noted that several local authorities
send material to be recycled to brokers, intermediaries and reprocessors. Sometimes
the waste is reprocessed and recovered in the UK and at other times it is exported.
The Agency noted that local authorities differ in their attention to detail when
reporting the final destination of municipal waste, yet this information is required in
order to demonstrate that reprocessing and recovery is legitimate and has diverted
waste from landfill. 1031
1029 In this judgement, Justice Evans-Lombe ruled that WRWA, which sought judicial review of a
decision made by Wandsworth BC to set charges for trade waste which effectively reduced the quantity
of waste collected by the authority, had no case for such a review. In other words, Wandsworth had not
acted outside the law in essentially seeking to reduce its collection of non-household municipal waste.
1030 Matters would, or course, have looked somewhat different had Defra taken the view that municipal
waste did in fact include all commercial waste in the WDA area, irrespective of who collected it. This
would have made the tasks of data acquisition and verification more difficult, but it would also have
led, potentially, to a more rational form of collection logistics rather than encouraging its
fragmentation. It might also have ensured a more enlightened approach to procurement of facilities in
which treatment facilities were designed to deal not only with the material collected by the WCAs /
WDAs, but also with the wider commercial wastes.
1031 Environment Agency (2008) Report on the Landfill Allowances and Trading Scheme 2007/08,
November 2008.
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During 2007/08, the Environment Agency also examined MRF data and how
authorities verify the information they report on the data reporting system, waste
dataflow (WDF). They found that reported reject rates from MRFs varied considerably,
with some authorities reporting an implausible zero percent reject rate, and cases
arising where the reject rates reported by authorities using the same facility varied
significantly (see Table 55-4).
Table 55-4: Reject Rates Reported by Local Authorities Using MRFs
821
Reject Reject rates rates
rates
International Review of Waste Policy: Annexes
No. No. of of authorities* authorities* with
with
reported reported MRF rejects in
this this this range range
range
zero reject 32
Above zero less than 5 per cent 62
5 per cent to less than 10 per cent 43
10 per cent to less than 15 per cent 24
15 per cent to less than 20 per cent 11
20 per cent or more 10
Source: Environment Agency (2008) Report on the Landfill Allowances and Trading Scheme 2007/08,
November 2008.
From 2008/09, the Environment Agency intends to serve notice on authorities that
report zero reject rates, asking them for firm evidence to substantiate reporting zero
reject rates (which is likely to be impossible to provide). The EA will also review reject
rates which are low and inconsistent with the MRF’s own data and that of other
authority users.
Another consequence of the sorting of commingled materials is that it is well known
that some materials sent from sorting facilities to reprocessors is rejected at the
reprocessors’ gates. As part of our auditing process in 2008/09 we will build on the
work already carried out during 2007/08 in this area.
55.12 Lessons Learned
There have been a number of lessons learned already in the relatively short lifetime
of the LASs:
� Sanctions have proved to be critical in ensuring that local authorities take not
of the scheme. Targets are not worth setting if there is no intention to enforce
them;
� The approach to assessing the reduction in biodegradability achieved by MBT
processes emerged late, and was confusing. The test methods used are
expensive and unfamiliar. It was impossible for MBT processes to demonstrate
their ability to comply with the requirements set out in tenders in early years of
the scheme because of the lateness and obscurity of the proposed
mechanisms for assessment;

822
� There are concerns that the mass balance approach encourages local
authorities to collect large quantities of garden waste, and that the way the
accounting process works encourages ‘waste generation’ and discourages
home composting. Defra is considering the potential for incorporating an
adjustment, related to home composting into the mass balance scheme.
� The definition of municipal waste in the UK is clearly enabling some authorities
to generate ‘assets’ from their allowance allocations, based on grandfathering,
by simply ceasing trade waste collections. The initial proposal for the scheme
proposed an allocation on household numbers;
� Some WDAs, in areas where Government has planned for major new housing
developments, have argued, not unreasonably, that their allocation of
allowances should reflect their changing circumstances. Defra and the other
administrations are giving the matter some consideration. The initial proposal
for the scheme proposed an allocation on household numbers, with
adjustments made periodically on the basis of WDAs’ share of total
households;
� Crucially, in England, where allowances are tradable, the availability of
information of ‘market relevance’ has been limited. This is, perhaps, less
problematic where the number and magnitude of trades is small, and when
prices for allowances are understandably low. If the market tightens, however,
there will be heightened concern regarding the quality of the market-relevant
information, not least since local authority officers may be required to make
substantial financial outlays through trades. It remains to be seen whether the
LATS Trading Floor (and electronic trading floor) can provide this information;
and
� In the trading system, it may have been wiser to ensure that targets were set
such that rules regarding banking and borrowing were the same in all years.
The existing system effectively changes the rules in ‘target years’ (2009/10,
2012/13 and 2019/20). This forces the market for allowances into a clearing
situation when in other years, banking and borrowing gives flexibility. Arguably,
this prevents any form of meaningful price formation for future years, reducing
the efficiency and liquidity of the market for trading allowances in those future
years.
55.13 Prerequisites for Introduction
Pre-requisites for the scheme’s introduction are:
� Targets are set upon those who can reasonably be said to have responsibility
for delivery against the targets;
� A clear method for allocation, and for each WDA, a more or less clear schedule
of allowances over time;
� Clear rules around trading, banking and borrowing;
� Crucially, sanctions to support the drive to meet targets;
� Clarity about the way the WDAs’ performance would be assessed under the
LASs (see Figure 55-1);
29/09/09

823
� Market-relevant information; and
� A clear mechanism for reporting of data.
Figure 55-1: Mass Balance Calculation for the LATS in England
International Review of Waste Policy: Annexes

56.0 Proposed Policy Changes
This study (see Annexes 52.0 to 55.0) has reviewed evidence in respect of:
824
� Landfill taxes;
� Landfill bans;
� Incineration taxes;
� Incineration bans;
� Tradable allowances for landfilling;
� Non-tradable allowances for landfilling;
� Restrictions on landfilling through pre-treatment requirements.
There are a number of studies which make comments about ‘what works’ and ‘what
doesn’t’. There are differences in the views presented therein, but generally, the view
is taken that the above instruments work in combination with others to steer waste
into different management routes. There are differences in perspective depending
upon whether the analysis is of household or municipal waste, or whether the
emphasis is on landfill diversion alone or other management routes.
Many commentators appear to lose sight of some basic principles of public policy. For
example, bans on landfill may appear attractive, but they are economically inefficient.
They are likely to impose high social costs unless they are targeted so as to eliminate
relatively significant environmental problems at an acceptable cost.
Although many argue in favour of landfill bans to promote movement of waste up the
hierarchy, it is interesting to note that two countries which have applied widespread
bans – Denmark and Netherlands – have done so with the objective of seeking to
ensure incineration capacity is well utilised. In other words, the principle aim has
been to shift material from landfill to incineration. In several other cases, landfill bans
have been applied alongside high taxes for landfilling of untreated waste. Again, in
these cases, to the extent that prices for landfill and alternatives are made ‘more or
less equal’ by the tax, it can be appreciated why, when recycling and waste prevention
find their motivation in the avoided costs of residual waste management / disposal,
the introduction of bans on top of taxes has little effect on recycling and waste
prevention. In many cases, therefore, the principle effect of bans and restrictions on
landfilling appears to have been to give the market additional certainty regarding the
financial case for developing alternative treatments to landfill.
Regarding landfill taxes and incineration taxes, few countries have deployed these
with a view to internalising externalities. Rather, these taxes have been used to
achieve broader objectives of waste management policy, in particular, improving the
financial viability of recycling and waste prevention, and providing incentives to
engage in such activity.
It is interesting to note that both Sweden and Denmark, which make considerable use
of incineration, have high incineration taxes in place. This latter point highlights the
29/09/09

need to consider not just ‘policy’ in the round, but also, the regulatory context and
ownership structures in understanding how policy has developed.
56.1 What Does Ireland Need?
The current situation as outlined in Annex 51.0 highlights:
825
� That in 2007, the quantity of BMW landfilled was 518,535 in excess of what
would be allowed in 2010;
� That commercial waste is growing far more rapidly than household waste,
though this degree to which this reflects reporting anomalies needs to be
clarified;
� That the capture of the largest biodegradable fraction in the municipal stream
– the organics – was very low (9%);
� That significant scope exists for increasing captures of paper and card;
� That relevant ‘targets’ set at the national level do not cascade down to those
who are actually delivering change on the ground; and
� That regional plans are not equipped with the relevant information, and nor
are they under any form of sanction, which would give anyone confidence that
meeting of the NBS targets is assured through the Regional Waste
Management Plans. Indeed, it will be interesting to see whether any Region in
Ireland meets ‘its share’ of the Landfill Directive target (accepting that no one
actually has formally required them so to do).
It would be preferable, in this context, if policy changes could achieve the following;
� Give the market clear incentives to develop alternatives to waste being sent
untreated to landfill;
� Do so consistent with environmental objectives;
� Give clarity concerning the role played by treatments such as MBT to the
meeting of Landfill Directive targets;
� Deliver some certainty of meeting future Landfill Directive targets without
compromising future improvements in waste management;
� Do so in such a way that the market for dealing with biodegradable waste
suffers no undue disruption because of insufficient capacity.
However, the time remaining before the first target must be met is incredibly short,
and the luxury of developing policy and waiting for incentives to take effect is simply
not available. In what follows, we consider short-term actions and policies intended to
take effect over the longer term, but which need to be announced / enacted urgently
if targets are to be met.
56.1.1 Short-term Actions
Unless recycling rates have changed very significantly since 2007, and unless the
quantity of municipal waste has dipped sharply since 2007, then the gap between
what is required, and what currently exists, seems unlikely to be met in the time
International Review of Waste Policy: Annexes

available. There are strong reasons to believe, however, that the economic downturn
will have affected the quantity of waste generated, probably in both 2008 and 2009.
ESRI forecasts a decline in GDP of 10% at market prices for 2009 and a further
decline of 1.9% in 2010. 1032 It would be expected that this effect, with an impact on
wages, would lead to a reduction in the overall quantity of municipal waste, though
the balance across the household and non-household sectors might be difficult to
estimate. We would assume that the response on the household waste side would be
less dramatic than on the commercial side, partly reflecting a reversing of the
apparent effects in the past in terms of growth.
We have estimated that household waste and commercial waste fell by 1% and 3%,
respectively, in 2008, 1033 and that growth rates will be -3% and -7% for household
and commercial waste in 2009, and -1% and -2% for household and commercial
waste in 2010. This would lead to a net fall of 8% in municipal waste by 2010 relative
to 2007 figures. 1034
The performance in respect of recycling of paper and card, and of organics, will be
crucial if Ireland is to meet the 2010 Landfill Directive targets. The recycling of paper
and card will have been stimulated by rising prices for secondary fibre in the first half
of 2008 but it will have suffered in the second half of 2008. Prices are recovering
again, so that it might be expected that by the end of 2009, capture rates (as a
percentage of total paper and card) might not be so different from 2007 levels
(having increased in previous years). We have projected that the capture rate reaches
55% in 2010, a slight increase from 2007 levels, but the same level as the EPA
reports for 2006, and on track with the target set in the National Biodegradable
Waste Strategy.
The situation regarding the organic waste stream then becomes crucial. Captures
were shy of 9% in 2007, but the National Biodegradable Waste Strategy sets a target
of 25% by 2010. A 25% capture rate would imply organic waste treatment of around
210,000 tonnes in 2010, up from 78,617 tonnes in 2007. This seems possible,
given the ongoing roll-out of collections for organic waste (‘the brown bin’) and given
also the potential biowaste treatment capacity in the country at the time of writing,
although anecdotal evidence suggests this might be happening more slowly than had
hitherto been the case. There is no room for complacency, and the key hurdle might
appear to be the licensing and permitting of biowaste treatment capacity. Any delays
could have significant implications for the overall approach, although as mentioned
above, some are viewing spare capacity at rendering plants as a possible solution,
possibly for an interim period.
1032 ESRI (2009).
1033 Although the economy was already in decline, CSO reports that net migration was still positive, with
population increasing by some 80,000 over the year.
1034 Recent UK figures, where the effect on GDP has been less dramatic than in Ireland, seem to
suggest that some local authorities will report drops in municipal waste – which is defined more
narrowly in the UK than in Ireland, and relates mostly to household waste – of as much as 10% from
2008 to 2009. Our estimates may well be conservative (i.e. the extent of the decline may be much
greater than we are predicting).
826
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In the above scenario, with captures of textiles and wood kept constant, there would
still be 227,592 tonnes more biodegradable waste in residual waste than could be
landfilled (see Figure 56-1). This would be equivalent, in this year, to the BMW
contained within a total of 323,564 tonnes of residual waste.
Figure 56-1: Estimated Performance Against 2010 Landfill Directive Target (25%
Capture of Organics, 55% Capture of Paper and Card, No Increase in Captures of
Textiles and Wood from 2007 Levels)
Waste Quantities (tonnes)
827
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
0
Distance to target =
227,592 tonnes BMW
2007 2008 2009 2010
International Review of Waste Policy: Annexes
Year
MSW
BMW
Recycling of Paper and Card
Recycling of Textiles
Recycling of Wood
Collection of Biowaste for Composting /
Digestion
BMW in Residual Waste
If this scenario is deemed a credible starting point, then in order to meet targets, one
or more of the following would need to happen:
� Waste quantities would need to be lower than projected here. Note that
because it has not been made clear exactly how attempts to reduce the
quantity of biodegradable waste in the waste stream will be accounted for in
Ireland, it is not clear how prevention activity will affect performance against
the BMW targets. If the EPA’s intention is to assume that all households with a
particular type of system generate waste of the same composition, then it may
be just as beneficial to reduce the quantity of rubble as it will be to reduce the
quantity of food waste; 1035
� Paper and card recycling rates would need to be in excess of 55%. Our
experience in the UK is that the addition of further materials to recycling
1035 This is a problem – in terms of the perverse consequences of mass balance calculations – that
has been widely discussed in the UK in the context of the LASs (see Annex 55.0).

828
29/09/09
collections has tended to improve the capture of those which were already
being targeted. In particular, yields of dry recyclables have increased when
biowaste collections have been introduced. This suggests there may be an
effect on recycling rates for paper and card anyway, purely as a result of the
roll-out of ‘brown bins’. There is likely to be some room for further
improvement in services, but also, in the nature of incentives used to
encourage waste producers to make use of recycling services already
available;
� The capture of organics would need to be in excess of 25% of total. This does
not seem impossible from the perspective of collection, but a key hurdle would
be the availability of suitable treatment capacity. This would, after all, need to
be ‘on-stream’ for the whole of 2010 (i.e. up and running in five months time).
This is clearly a challenge;
� The capture of textiles would need to be increased, especially from the
household stream. The textiles fraction as measured in the Waste
Characterisation report, is unusually high for household waste (compared with
other countries). 1036 However, around half of this is, on closer inspection,
nappies. The recycling of textiles is, according to many studies, highly
beneficial from the perspective of greenhouse gas emissions. 1037 It is notable
that many collection permits do not specify a requirement to collect textiles
separately. Figure 51-3 showed uncaptured textiles as the second largest
single uncaptured fraction, after the organic fraction, in the household waste
stream, but around half of this is nappies (so more amenable to waste
prevention and re-use than recycling per se). 1038 The target capture in the
National Biodegradable Waste Strategy is 15% for 2010, but there is little by
way of clear signs that this target will be met. 1039 The 15% target in the
National Biodegradable Waste strategy relates to all textiles, including
nappies, so implies a recycling rate of the order 30% of non-nappy textiles.
Prognos reports recycling rates of 41% for Austria, 46% for France, 49% for
Belgium and 53% for Germany. 1040 It is not clear whether or not these ‘textile’
1036 The EPA 2007 figures amount to around 50kg per inhabitant for Ireland in the municipal stream
alone. Prognos reports that only Austria produces more textile waste than Ireland on a per capita basis,
and that the average for EU countries is around 25kg per inhabitant. The figure reported for the
household waste stream in Waste Characterisation reports is 12.2%. By way of comparison, the UK
reports that textile wastes are around 3% of municipal waste (which, in the UK, is mainly household
waste). Our experience in other countries suggests that figures of the order 4% are more typical,
although the age of ‘the disposable clothing item’ is clearly encroaching as real prices fall.
1037 See Annex 63.0.
1038 There are proceses which can recycle nappies, but they essentially require the nappies to be
collected separately in the first place.
1039 It should be noted that the 15% target in the National Biodegradable Waste strategy relates to all
textiles, including nappies, so implies a recycling rate of the order 30% of non-nappy textiles.
1040 Prognos (2008) European Atlas of Secondary Raw Materials: 2004 Status Quo and Potentials,
January 2008.

829
figures include nappies, as is the case in Ireland, but our experience suggests
they would not. The general picture, however, is that there is very significant
potential for progress to be made in this area in Ireland, and that through
capturing around 50% of the non-nappy textiles, an additional 40,000 tonnes
or so of landfilled waste could be avoided; 1041
In the following scenario we have assumed that:
� Growth rates are as previously projected;
� The capture rate for paper and card increases to 60%;
� Textiles recycling / re-use rates increase to 15% of total (around 30% of nonnappy
textiles), in line with the National Biodegradable Waste Strategy; and
� Organic waste captures increase to 30% in 2010.
Other material captures are increased slightly from the previous scenario (reflecting,
as with paper and card, increased efforts to sort). The results from this scenario are
shown in Figure 56-2. The Scenario would require capacity for treatment of source
segregated organics to be of the order 250,000 tonnes, an increase of 170,000
tonnes or so from 2007.
A critical variable will be the change in gross quantities of MSW, and in particular, the
effect that the recession has had upon this. Even so, they highlight the fact that even
with these efforts, there would be 143,170 tonnes more BMW in residual waste than
could be landfilled. This is equivalent to the BMW contained in 208,000 tonnes of
residual MSW.
The treatment possibilities for this residual waste then become important. Here, there
appear to be four possibilities:
1. The residual waste is incinerated. There would appear to be only one
possibility in this respect by 2010. This is the Carranstown plant at Meath,
though it seems unlikely that this would be operating for the whole year, even
if it was operating for part thereof (and it might not be);
2. The residual waste is used in the preparation of SRF for export. This has been
happening for some years, with more that 30,000 tonnes exported to UK and
Sweden in 2007;
1041 It is far from clear to us why ‘textiles’ should be treated as 100% biodegradable for the purposes of
the Landfill Directive. There are many synthetic textiles available and the fact that Ireland’s
performance in respect of capturing textiles is relatively poor simply increases the magnitude of the
task ahead. Effectively, the approach overstates the quantity of biodegradable waste in the waste
stream, making it more difficult to meet a target in any given year. According to a recent life-cycle study
on nappies, 16.8% of the weight of nappies disposed is not biodegradable (ERM (2008) An Updated
Lifecycle Assessment Study for Disposable and Reusable Nappies, Report for WRAP and Defra,
Science Report SC010018/SR2, October 2008). In the UK, it is generally assumed that 50% by weight
of textiles are biodegradable, and whilst this may not be strictly accurate, it implies a pragmatic
approach to the issue that not all textiles are biodegradable. This matter is taken up below.
International Review of Waste Policy: Annexes

830
3. The residual waste is used to prepare SRF for co-incineration at cement kilns.
The capacity of the kilns is likely to be of the order 100,000 -150,000 tonnes
SRF for the year. The issue is one of whether the facilities exist which can
produce this quantity of SRF to the desired specification. Furthermore,
depending upon the fuel preparation process, the SRF might have a
biodegradable content of the order 60%, so that the SRF might contain 60-
90,000 tonnes of BMW;
4. The residual waste is stabilised prior to being landfilled. Here, there are
facilities which are primed for this purpose, but the question remains as to
whether the incentive exists for this to occur. Some incentive may flow from
the EPA’s Pre-treatment Guidelines.
Figure 56-2: Estimated Performance Against 2010 Landfill Directive Target (30%
Capture of Organics,60% Capture of Paper and Card, 15% Capture of Textiles)
Waste Quantities (tonnes)
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
29/09/09
0
Distance to target =
143,170 tonnes BMW
2007 2008 2009 2010
Year
MSW
BMW
Recycling of Paper and Card
Recycling of Textiles
Recycling of Wood
Collection of Biowaste for Composting /
Digestion
BMW in Residual Waste
The sum total of these has the potential to deliver the required diversion from landfill.
However, the prospects for meeting the 2010 target still appear to be slim. Indeed,
even if all the above actions were deemed possible, it is not clear who really has the
incentive to undertake them. Where the Landfill Directive is concerned, no one is
faced with any target, let alone a sanction for not meeting it. This is a situation from
which Ireland needs to learn (in terms of how targets set at the national level can be
met).
Much also depends on how the accounting against the targets is carried out. As noted
above, there may be ways of reducing the target simply through specifying a
proportion of textiles that are biodegradable which more accurately reflects the
reality, and is below the current 100% figure. Setting this at a highly plausible figure

of the order 65% would reduce the quantity of BMW in waste at the outset, and
reduce the net quantity being landfilled, by around 70,000 tonnes. However, the
1995 baseline would also be lower, so that the net improvement in the position re
landfilling of BMW would be of the order 50,000 tonnes. Given how close Ireland
could be to meeting these targets, such a change – which merely improves the
accuracy of the accounting – could be rather important in the final analysis.
Possible means to achieve the target would need to include one or more of the
following:
831
1. Rapid Rapid development development of of home home composting composting for for municipal municipal biowastes;
biowastes;
Whilst this might be a useful and cost-effective measure for households, the
increase in uptake of home composting might not be extraordinarily high,
whilst for many households, home composting is not an option. A 5% increase
in home composting would be a very significant result in the time available,
but this would give an estimated benefit of only 13,230 tonnes. Nor is it clear
how this would be accounted for – it is not clear that the reduction in waste
would necessarily be registered as being of a wholly biodegradable nature.
Finally, such campaigns do require planning and trained staff. They are
unlikely to be successful in such a short space of time, so it seems likely that
the best option would be to build upon existing schemes; 1042
2. A A campaign campaign to to reduce reduce the the wastage wastage of of food food (and (and other other waste waste prevention
prevention
campaigns);
campaigns);
The Waste and Resources Action Programme (WRAP) ‘Love Food, Hate Waste’
campaign has specifically targeted food waste, recognising the cost of wasted
food to households and to the environment (embodied greenhouse gas
benefits are estimated to be of the order 2.5 tonnes CO2 equ per tonne of food
waste avoided). Even if 5% of all food waste could be prevented in the time
available, the net benefit might be only of the order 30,000 tonnes. As with
home composting, because it is not clear how this would be accounted for, it is
not clear that the reduction in waste would necessarily be registered as being
of a wholly biodegradable nature;
3. Rapi Rapid Rapi Rapid
d development development of of facilities facilities to to deal deal with with BMW BMW in in residual residual waste.
waste.
So as not compromise efforts of those already advanced in developing plans
for residual waste treatment, it might make sense to seek rapid procurement
of MBT capacity for Ireland capable of carrying out basic pre-treatment of
waste to stabilise the material prior to landfilling. To the extent that this was
deemed to meet threshold criteria, the aim of this would be to deliver the
additional diversion necessary to meet the 2010 targets. However, it might be
argued that several of the urban areas already have proposals in hand for
incineration, and that the procured facilities might more usefully be targeted at
rural areas. To the extent that this approach was favoured, development of the
1042 CSO figures suggest Ireland has 1.47 million private households. We have assumed an average
figure, taken from studies by WRAP, of 180kg per hhld, giving a total of 265,000 tonnes if all
households were home composting (which, logically, they could not be).
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procurement strategy, and work to identify appropriate sites, would need to
begin straightaway, and would probably still be too late to deliver what is
necessary. However, it might be realistic to expect such a development to bear
fruit only in a timescale of two years or so if this was prioritised by all relevant
parties (notably in respect of permitting, planning and funding). Furthermore,
these facilities would need to have some longer-term guarantee of waste into
their plant, and so without commitments of waste for the medium- to longterm,
they would be unlikely to be supported by debt finance, especially in the
current economic climate;
4. Identifying Identifying Identifying export export export markets markets markets for for residual residual residual BMW BMW BMW destined destined destined for for recovery recovery recovery facilities. facilities.
facilities.
Some SRF is already sent abroad for combustion in Sweden. The
development of incineration capacity abroad is tending towards over-capacity
in a number of situations. 1043 Given the high avoided cost of landfilling (higher
with an increase to the waste levy as proposed – see Section 56.2.1) the
potential to make use of surplus capacity abroad may be available. Clearly,
exports would have to be destined to recovery facilities, so not all incinerators
ought to be capable of receiving exports. Care would need to be taken to
ensure appropriate safeguards were in place regarding exports.
5. So So as as to to to buy buy some some some additional additional time time for for Ireland, Ireland, Ireland Ireland Ireland could could could consider consider baling baling of
of
waste waste prior prior to to subsequent subsequent subsequent use.
use.
Baling tends to be applied to materials which are subjected to biodrying, with a
view to later using the material as solid recovered fuel. However, this is a less
than ideal solution, whilst the approach lends itself to temporary storage. It is
not clear how temporary storage would need to be.
There are a worryingly large number of unresolved matters in seeking to understand
how efforts to meet the targets would be accounted for, let alone how they could be
achieved. The task is a large one, and the starting point is not a particularly strong
one.
The scenario set out at Figure 56-1 is not entirely implausible, but the scenario is
likely to see Ireland fail to deliver its 2010 targets unless growth is lower than we
have indicated. The scenario depicted in Figure 56-2 would require a considerable
mobilisation in a short period of time, and whilst this, along with changing the
accounting method for textiles, could deliver on the targets, it is the time available,
not the level of the achievement, which is the principle barrier.
Furthermore, these changes would be having to be made concurrently with a range of
changes in policy and institutions which appear, in our view, necessary to improve the
functioning of the waste management market and industry in Ireland. Evidently, at
some point one has to ask whether the achievement of a target which, because
changes might be being forced upon actors in an untimely manner, is expensive to
achieve is worth the significant effort that would be required, recognising also that the
2013 target is now looming rather large.
1043 See, for example, the recent report by NABU (2009) Müllverbrennung in Deutschland wächst
unkontrolliert – Recycling ist gefährdet, Müllimport wird attraktiver, Berlin, March 2009.

56.2 Proposed Policies to Deal with Residual Waste in the
Context of the Landfill Directive
In principle, three options appear to be available regarding the Landfill Directive:
1) Re-couch the national targets as regional, or local authority ones, and implement
a mechanism to ensure these are met. This might lead Ireland to a situation akin
to the UK’s landfill allowances schemes, where Waste Disposal Authorities are
effectively allocated quotas of allowances limiting the quantity of biodegradable
municipal waste they could landfill. One major difference between the UK and
Ireland, however, is that local authorities have control over what happens with the
totality of what is defined as municipal waste in the UK. The same is not true for
Ireland, and nor would it be true if Irish local authorities were made directly
responsible for the collection and management of household waste, as proposed
in Section 3.6. The large (and, hitherto, rapidly growing) quantity of commercial
waste would still be open to the marketplace to determine the management of.
Hence, this mechanism does not seem to recommend itself, at least not for ‘all
municipal waste’, since no addressee is appropriate for the target being proposed;
2) A second option would be to choose an addressee for Landfill Directive targets
that does have control over how waste is managed. By the time waste arrives at
landfill, decisions have already been made, so this could not be the landfill
operator itself, unless the main implementing mechanism was a requirement to
pre-treat (see below). The only real alternative appears to be the collectors.
Collectors could, in principle, be given landfill allowances relating to the proportion
of (biodegradable) municipal waste they handle (another option would be to
auction the allowances), this proportion declining each year. They would be
allowed to trade these with other collectors so that those who had surplus
allowances (who had recycled more, or ensured more waste was treated) could
sell to those who were in deficit. One issue with this is that rather like the regions
/ local authorities in Ireland, collectors are not always in a position to influence
investments in treatment. The level of vertical integration across collection and
treatment / disposal varies across collection companies. The mechanism might
also compromise any efforts to develop indigenous infrastructure, with exports a
likely means used to meet targets (rather more so than already happens). Finally,
the required accounting mechanism would be difficult to design and implement in
a fair manner, and there would be significant issues of moral hazard to be
overcome; and
3) A third option is to re-cast policy such that, whatever other instruments are in
place, the market is incentivised and regulated to deliver on the targets. Here, a
wide range of options are available, and they could, in principle, be considered.
However, as highlighted above, there are some key policies already in
development regarding residual waste and the Landfill Directive. In essence, we
believe that with some adaptation, these will take Ireland a long way to meeting
its Landfill Directive targets in 2013. The 2010 issues are clearly more pressing,
as discussed above.
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56.2.1 A Waste Levy
The existing landfill levy is too low. Everyone appears to agree with this, but this does
not mean landfill taxes should be increased ad infinitum. Principles of public policy
suggest that some justification for a level of taxation should be provided, and the
most solid justification (at least in the sense of the principle) is the internalisation of
externalities associated with the activity in question.
The measurement of these, however, proves to be somewhat more difficult. We have
provided a review of literature on the external costs and benefits of residual waste
treatments in Annex 61.0. This highlights the fact that the literature is far from
equivocal, even where the preference for landfill vis a vis incineration is concerned,
especially where attempts are made to consider all social costs.
Several actors, organisations and bodies highlight the desirability of using life-cycle
assessment to determine preferences for the environmental performance of waste
facilities. However, life-cycle approaches, whilst usefully setting out estimates of
possible impact in different assessment categories, do not use a common metric that
enable easy alignment with environmental damages, as monetised through economic
techniques. Indeed, in our view, life-cycle assessment approaches are more shaky in
terms of the insight they bring to the complex systems we are dealing with. By way of
illustration, in Annex 62.0, we have carried out some comparative analysis using the
tool WRATE, developed by the Environment Agency in England and Wales, to show
how the choice of facilities and impact assessment methods can shift analysis in
favour of one or other facility. This seemed relevant given that some recent modelling
using this tool was undertaken in a recent appraisal of the performance of MBT for
the EPA. 1044
Over many years, Eunomia has developed an in-house model of residual waste
treatments which allows for the modelling of both life-cycle impacts of facilities and
their external costs and benefits. This model has been used in analyses for many
local authorities in the UK, for the UK’s Committee on Climate Change and WRAP, and
for other bodies such as the Greater London Authority. In this study, we have
modelled the external costs and benefits of different residual waste treatment
options with a view to understanding how a waste levy might be structured, and to
understand the relationship it bears to the levy already proposed as part of the
aforementioned RIA. 1045 Details of the modelling are given in Annex 63.0.
We have modelled the following treatments
1) Landfill, Landfill, untreated untreated residual municipal waste ( (RMSW (
RMSW RMSW) RMSW (50% (50% lifetime lifetime capture)
capture)
This is a landfill where the gas capture rate is set at 50% over the facility’s
lifetime;
1044 Fehily Timoney & Company / Veolia Environmental Services / Ramboll (2008) Critical Analysis of
the Potential for Mechanical Biological Treatment for Irish Waste Management: Volume 2, Research
Report, Report for the Environmental Protection Agency, September 2008.
1045 AP EnvEcon (forthcoming) Regulatory Impact Analysis on Proposed Legislation to Increase Levies
on Shopping Bags and Certain Waste Facilities, Final Report.
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2) Incineration, Incineration, Incineration, RMSW RMSW RMSW – WI WI WI Directive Directive Directive compliant compliant
compliant
This is an incinerator which ‘just complies’ with the emissions limit values under
the Waste Incineration Directive
3) Incineration, Incineration, Incineration, RMSW RMSW RMSW – State State-of State of of-the of the the-art the art art Flue Flue Flue Gas Gas Gas Cleaning Cleaning
Cleaning
This is an incinerator whose performance far exceeds that required the emissions
limit values under the Waste Incineration Directive;
4) MBT, MBT, Stabilisation Stabilisation of of Waste, Waste, All All Residue Residue to to Landfill Landfill (50% (50% lifetime lifetime capture)
capture)
This is a basic stabilisation facility where the principle objective is to ensure the
residue is more stable before it is landfilled, thereby reducing methane emissions.
The landfill is assumed to be the same as at 1) above. The level of stability
achieved is in line with the standard outlined in the Second Draft Biowaste
Directive, suggested as being sufficient to render waste no longer biodegradable
for the purposes of the Landfill Directive;
5) MBT, Biodrying, Biodrying, RDF to Incineration, Residue to Landfill (50% (50% lifetime lifetime capture)
capture)
This is a biodrying facility where the principle objective is to use energy from
biodegradation, as well as air passing through the mass of material, to dry the
material. The material is then subject to some sorting to derive a solid recovered
fuel which is sent for incineration. The unrecycled residue is stabilised before it is
landfilled, thereby reducing methane emissions. The landfill is assumed to be the
same as at 1) above;
6) MBT, MBT, Stabilisation Stabilisation of of Waste, Waste, All All Residue Residue to to Landfill Landfill (dedicated (dedicated cells)
cells)
This is as for 4) but the landfill is assumed to be a dedicated cell, operated with
the intention of maximising oxidation of fugitive methane (0% gas capture);
7) MBT, Biodrying, Biodrying, RDF RDF to Incineration, Residue to to Landfill (dedicated (dedicated (dedicated cells)
cells)
This is as for 5) but the landfill is assumed to be a dedicated cell, operated with
the intention of maximising oxidation of fugitive methane (0% gas capture).
The results are shown in Table 56-1. Key features are, amongst others, that:
835
1. The externality assessment for landfill and ‘just-compliant’ incineration is in
line with the proposed levy rates as set out in the RIA. This is especially true for
the mid-point between the high and low damage costs. This is coincidence.
The RIA set about establishing the level of the levy through seeking to ‘more or
less equalize’ the costs of MBT, incineration and landfill. In doing this, it made
assumptions regarding the cost of those facilities. Our assessment relates only
to externalities, and makes no assumption at all about the costs of the
facilities;
2. If the incinerator is operated with state-of-the-art abatement equipment,
however, externalities are considerably reduced;
3. This is also apparent where the MBT Biodrying plant, which is deemed to send
RDF for incineration, switches the destination for the RDF from a ‘just
compliant’ incinerator to a state-of-the-art incinerator;
4. For the MBT treatments, some material is sent to landfill. The performance of
the landfill significantly affects the results:
International Review of Waste Policy: Annexes

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a. Where the residues are landfilled at a ‘standard landfill’, with assumed
50% gas capture, then the Biodrying facilities perform better than
stabilisation facilities.;
b. Where the residues are landfilled at dedicated cells, with assumed 0%
gas capture, but 90% oxidation, then the Biodrying facilities perform
worse than Stabilisation facilities. The switch in ordering relates to the
landfill’s performance and to the mass of material destined for the
landfill. The significance of this is explored below;
c. Where the stabilisation facility sends material to a dedicated cell, which
is designed to maximise passive oxidation of residual methane, the
externalities using high unit damage costs are very close to the
maximum levy rate proposed for landfilling stabilised biowaste in the
RIA of the proposed levy. 1046
This analysis suggests that the levy rates are broadly justifiable, and would appear to
have the potential to improve the management of waste in a positive direction, in line
with what is efficient from the economic perspective. However, some adjustment to
the currently proposed levy would appear to be desirable to improve the efficiency of
its design.
The analysis above highlights the fact that the externalities from incineration are
significantly affected by the performance in terms of the air emissions other than
greenhouse gases. The difference is €6 per tonne where low unit damage costs are
used in the analysis, or €21 per tonne where high unit damage costs are used. The
magnitude of this difference is sufficient to warrant consideration as to how the levy
could be designed to incentivise a reduction in these externalities.
The design of the Norwegian incinerator tax provides a useful pointer (see 52.2.4).
There, the tax focuses on emissions of each pollutant. These have to be monitored
anyway by the facility. Hence, it ought to be possible to tax the source of the
externality, the first best solution in this case. We propose, therefore, that the
incineration levy might be adapted in its structure. A more efficient levy would be:
� a per tonne levy for waste treatment, reflecting the climate change damages
from carbon dioxide releases (there is rather limited potential to abate these
emissions); and
� a levy based upon emissions of key pollutants.
Structured in this way, the levy affords the operators to abate emissions to an
efficient level.
1046 This is, perhaps, where the EPA might usefully focus its determination of BAT for landfills receiving
residues from MBT facilities which meet the pre-treatment stability threshold. The operation of the
landfill appears to have a more important effect on the environmental performance of the overall
treatment and disposal cycle than the additional retention of the waste to achieve a small additional
reduction in the tendency to produce biogas once landfilled.

Table 56-1: Levies Proposed in RIA, and Estimated Externalities from Treatments
Landfill, untreated
RMSW
(50% lifetime
capture)
Incineration, RMSW
– WI Directive
compliant
Incineration, RMSW
– State-of-the-art
Flue Gas Cleaning
MBT, Stabilisation
of Waste, All
Residue to Landfill
(50% lifetime
capture)
MBT, Biodrying, RDF
to Incineration,
Residue to Landfill
(50% lifetime
capture)
MBT, Stabilisation
of Waste, All
Residue to Landfill
(dedicated cells)
MBT, Biodrying, RDF
to Incineration,
Residue to Landfill
(dedicated cells)
MBT, Biodrying, RDF
to State of the Art
Incineration,
Residue to Landfill
(dedicated cells)
Landfilling of
Stabilised Biowaste
837
Proposed Proposed Levy Levy
Levy
Levels, Levels, 2011
2011
(€/tonne) €/tonne)
International Review of Waste Policy: Annexes
Proposed Proposed Levy
Levy
Levels,
Levels,
Maximum Maximum Rate
Rate
(€/tonne) €/tonne)
Calculated
Calculated
Externalities,
Externalities,
Externalities,
High High End End
End
Damage Damage Damage Costs
Costs
(€/tonne) €/tonne) €/tonne)
Calculated
Calculated
Externalities,
Externalities,
Low Low End End
End
Damage Damage Damage Costs
Costs
(€/tonne) €/tonne)
75 85 86 65
22 45 51 31
0 20
32 25
38 31
35 24
19 16
31 21
25 19
Source: AP EnvEcon (forthcoming) Regulatory Impact Analysis on Proposed
Legislation to Increase Levies on Shopping Bags and Certain Waste Facilities, Final
Report.
As regards the MBT processes, the impacts are affected by the type of treatment and
the fate of the materials. Some of the externalities are associated with the pretreatment
step, others are associated with the management of residues. It may make
sense to structure the levy as follows:
• A per tonne levy on the process itself;

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• A per tonne levy for landfilling of waste at conventional landfills; and
• A lower levy rate for landfilling of waste at landfills designed so as to
minimise the unoxidised methane escaping from the landfill (through use
of, for example, passive oxidation layers). The specification of this type of
landfill cell would need to take place under the auspices of the EPA, but it
would allow for additional environmental benefits to be gained from the
overall treatment process. 1047
As will become clear below, we expect that the latter landfill type would become more
common over time.
It is crucial that the levy for stabilised waste is linked to a standard for assessing the
stability of waste. Like the EPA Consultation Guidance, we recommend using the
standard set in the EU Working Document on Biological Treatment of Biowaste 2 nd
Draft: 1048
‘stabilisation’ means the reduction of the decomposition properties of
biowaste to such an extent that offensive odours are minimised and that
either the Respiration Activity after four days (AT4) is below 10 mg O2/g dm or
the Dynamic Respiration Index is below 1,000 mg O2/kg VS/h
This is for the simple reason that the measure needs to be agreed quickly (to give
effect to the levy) and experience from the UK suggests that deliberation on this
measurement can lead to unfamiliar measurement approaches which make it
impossible for developers to know how their technology will fare under a given
measurement method.
Meetings with the EPA suggest that in the Final Version of the Guidance, the stability
criterion might be changed over time, dropping from 10 mg O2 / g dm to 7mg O2 /g
dm, the latter being the Austrian standard (see 52.2.4). We question the rationale for
moving from one standard to the other for the following reasons:
1. The difference in environmental performance is likely to be insignificant, yet
the impact on costs might be significant. The benefit relative to the cost would
appear to be unjustified.
2. The effects on the capacity of a facility effectively change when the stability
criterion changes (and this is equivalent to the effect on costs mentioned
above). This is the lesson of the German experience, where some stabilisation
facilities, which used to operate as double duty sites, had to shut down the
composting side of the plant because the capacity of facilities was
1047 When stabilised waste is landfilled, then to the extent that it is properly stabilised in line with an
appropriate threshold value, the aim is not so much to capture gas for energy generation. Rather, the
objective is to deal with the much reduced fluxes of methane in such a way that they are not emitted to
the atmosphere as methane, and passive oxidation at the landfill surface offers the potential to
achieve this as long as the methane fluxes through the surface are sufficiently low (allowing oxidation
through the surface).
1048 EPA (2008) Municipal Solid Waste - Pre-treatment and Residuals Management: An EPA Technical
Guidance Document, Consultation Draft, Johnstown Castle Estate: EPA.

839
dramatically reduced by marginal tightening of the stability criterion
(increasing the required residence time, and hence the capacity of the plant to
treat waste);
3. It is unclear what rationale could be offered for a stability measure that is
different in one year to that set in another; and
4. To the extent that it is to be used as the basis for establishing when waste can
be considered no longer biodegradable for the purposes of the Landfill
Directive, this has already been considered at some length by the European
Commission, and the 10 mg O2 / g dm was deemed adequate.
The standard would essentially:
� Allow for the application of a lower tax rate than for untreated waste in the
short-term:
� Set the basis for a ban on landfilling of waste which fails to meet this standard
in the medium- to long-term; and
� Importantly, it would make explicit the fact that meeting the standard rendered
the waste no longer biodegradable for the purposes of the Landfill Directive.
It is important to recognise that the above externality assessments do attribute
external benefits to energy generated at different facilities. It is entirely consistent to
apply a levy to address the external costs of pollution whilst also seeking to
incentivise the generation of renewable energy (although the latter is not the first best
solution since the more efficient policy would be to tax the pollution from nonrenewable
sources).
It is worth pointing out, however, that to the extent that other policies internalise
benefits associated with energy generation, then the uninternalised externalities
which a waste levy should consider will, other things being equal, increase for those
facilities upon which policy bestows a benefit. In other words, the level of the levy
should consider the effects of other policies to the extent that they internalise
benefits associated with the treatment. As stated above, however, the way in which
REFIT will support municipal waste treatment facilities is not clear, though an
estimation of benefits received by landfill operators is easier to discern.
The suggested levy structure is below. Note that the rates proposed are in nominal
terms, so we have allowed for some price inflation over this period. Our proposal
involves some changes in structure and design from the initial proposal. The changes
are designed to reward environmental improvement where this is deemed feasible.
Incinerator operators, in particular, will be able to choose the level of abatement they
use to optimise their exposure to the levy. The landfilling of stabilised biowaste is also
affected by the nature of the receiving landfill.
It is important to state that the first announcement of the levy must make clear what
the levy rates will be for the foreseeable future. In other words, the rates for the years
2010 to 2015 must be announced in 2010 so as to give the market confidence. We
would suggest that a commitment is made to increase the proposed rates in Table
56-2 in the years after 2012 at the Retail Price Index to maintain their value in real
terms.
International Review of Waste Policy: Annexes

Table 56-2: Suggested Levy Structure
Landfill, untreated
RMSW
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RIA RIA Proposed
Levy Levy Levels,
Levels,
2011
2011
(€/tonne) €/tonne)
RIA RIA Proposed
Levy Levy Levels,
Levels,
Maximum Maximum Rate
Rate
(€/tonne) €/tonne)
75 85
Incineration 22 45
MBT processes
Landfilling of
Stabilised Biowaste,
Standard Landfill
Landfilling of
Stabilised Biowaste,
Dedicated Cell
0 20
0 20
Eunomia
Eunomia
Prop Proposed Prop sed levy,
2010
2010
2011
2011
2012
2012
€40/t
€60/t
€85/t
€10 /t
€20 /t
€24 /t
plus non-GHG
pollutant related
taxes
(per kg of
pollutant)
NH3 € 9.15
VOCs € 2.50
PM2.5 € 52.00
SOx € 17.30
NOx € 13.60
Cd € 26.00
Cr € 21.00
Hg € 7,400.00
Ni € 2.60
Pb € 740.00
Dioxin 46,000,000
As € 99.00
€5/t
€12/t
€20/t
€5 /t
€15 /t
€25 /t
€0/t
€0/t
€5/t
56.2.2 A Ban on Landfilling of Waste Exceeding a Threshold
Biodegradability
We have reviewed a wide range of landfill bans across Europe. These tend to relate
to:
1) Household waste
2) Segregated fractions of waste
3) Biodegradable waste

4) Combustible waste
5) Waste exceeding a stability standard; and
6) Waste exceeding a threshold calorific value.
What is of particular interest is the rationale for these, and how they are actually
implemented. Implementing a ban on landfilling is not entirely straightforward, and in
several countries where they are in place, exceptions have to be applied to allow for
landfilling of materials for which there is insufficient treatment capacity. In some
countries, a key objective has been to shift was from landfill and into incineration.
Bans are blunt instruments. They are, by definition, economically inefficient. They will
not always lead, unequivocally, to environmental benefits and they may impose
significant costs. Hence, to the extent that bans are deployed, they need to be
considered carefully in order to ensure that gains are commensurate with costs. It is
also worth considering that the practicalities of implementing and enforcing a ban
limits the degree to which such bans can be targeted in ways which might, on purely
environmental grounds, appear desirable (for example, banning food waste from
landfill is extremely difficult unless whole waste streams are banned from landfill, or
unless the ‘ban’ implies a requirement to source separate, in which case, it in not,
strictly speaking, a ban).
Some of the bans which seem more likely to deliver benefits are those which are not,
strictly speaking, outright bans. The above assessment of externalities suggests that,
to the extent that the externalities of landfill are associated with biodegradable
wastes, then treating waste to reduce that biodegradability seems to render
significant benefits. This implies not so much a ‘ban’ as a restriction on the
characteristics of wastes which can be landfilled. Our review highlights Austrian and
German experience in this regard. These countries use broader criteria to restrict
wastes sent to landfill. For example, in Austria, wastes which exceed a specified
calorific value cannot be landfilled. However, in our view, this type of criterion is far
less justified as the basis for a landfill ban. The presumption, presumably, is either
that waste with a higher calorific value is better utilised in energy from waste plants,
or that the environmental impacts of landfilling waste are somehow correlated with
their calorific value. Neither is true, and brief consideration of how plastics fare in
landfills and incinerators in respect of climate change supports this point. 1049
The restructured levy, discussed above, will give a signal to the market that all
residual waste treatments are to be made more expensive, most notably, landfilling of
untreated waste. This will move waste up the hierarchy and will give the market
greater certainty in respect of developments other than landfilling.
1049 We have discussed this elsewhere (D. Hogg (2006) A Changing Climate for Energy from Waste?
Report to Friends of the Earth). Subsequently, Defra stated, in Waste Strategy for England 2007,
‘Burning plastics has a general net, adverse greenhouse gas impact due to the release of fossil
carbon. Recycling shows significant potential for carbon and energy savings through displacing virgin
materials, although the scale of this varies widely with the processing route.’ The same conclusion was
reached in previous work for the European Commission (see Smith, A., K. Brown, S. Ogilvie, K. Rushton
and J. Bates (2001) Waste Management Options and Climate Change, Final Report to the European
Commission, DG Environment, July 2001).
841
International Review of Waste Policy: Annexes

This will not, however, give any certainty regarding the meeting of Landfill Directive
targets. If a treatment for residual waste has the same cost as landfill, inclusive of
levies, then the chances are that the treatment facility will not be built for the simple
reason that the landfill option still exists, and the landfill operator might be better
placed to drop prices in the short terms than the treatment facility. Additional
certainty is required, and this ought to be achieved under the EPA’s proposed pretreatment
approach.
We have proposed that the levy is announced and increased over a period of three
years. We would suggest that to give certainty to the meeting of Landfill Directive
targets, a ban on the landfilling of waste which does not meet the 10 mg O2/g d.m.
stability criterion is implemented in 2013. We also suggest that some thought is given
to the potential need for exemptions from the restriction in situations where, come
2013, insufficient treatment capacity is available (locally). The lesson of the Dutch
experience, however, is that if exemptions are available, some may seek to avail
themselves of them indefinitely. Consequently, if a waste holder has no option other
than to landfill residual waste, such an exemption could be granted, but at a cost to
the holder of the waste. This ‘exemption levy’ should maintain the stimulus to build
alternative treatments to landfill.
56.3 ‘Government Policy’ and the Waste Framework Directive
It should be noted that non-incineration technologies for dealing with residual waste
are unlikely to be developed as long as the perceived view is that ‘government policy
is that residual waste should be incinerated’.
It is widely held that Government policy is to favour thermal treatment over other
forms of residual waste treatment. There is, it would appear, no clear and
unequivocal reason to support thermal treatment over other forms of residual waste
treatment, and in any case, to the extent that the levy proposed above simply seeks
to internalise externalities, the levy itself effectively removes the rationale for any
such explicit discrimination – the aim of the levy is to allow the market to determine
which facility is most appropriate.
In European law, the revised Waste Framework Directive proposes that incinerators
which exceed a specific threshold of efficiency in energy generation should be defined
as ‘recovery’. The conditions are as follows:
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This includes incineration facilities dedicated to the processing of municipal
solid waste only where their energy efficiency is equal to or above:
— 0,60 for installations in operation and permitted in accordance with
applicable Community legislation before 1 January 2009,
— 0,65 for installations permitted after 31 December 2008,
using the following formula:
Energy efficiency = (Ep - (Ef + Ei))/(0,97 × (Ew + Ef))
In which:
Ep means annual energy produced as heat or electricity. It is calculated with
energy in the form of electricity being multiplied by 2,6 and heat produced for
commercial use multiplied by 1,1 (GJ/year)
Ef means annual energy input to the system from fuels contributing to the
production of steam (GJ/year)

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Ew means annual energy contained in the treated waste calculated using the
net calorific value of the waste (GJ/year)
Ei means annual energy imported excluding Ew and Ef (GJ/year)
0,97 is a factor accounting for energy losses due to bottom ash and radiation.
This formula shall be applied in accordance with the reference document on
Best Available Techniques for waste incineration.
In order to meet this criterion, a new facility generating only electricity has to exceed
24.25% gross efficiency even if no energy is used in the process itself (in other words,
even if Ei and Ef are set equal to zero in the above formula). Including the energy use,
a report by CEWEP suggests that at existing plants generating mainly electricity, 6 of
25 facilities reviewed would meet the threshold for new facilities. 1050
Although facilities which met this threshold efficiency level would be classified as
‘recovery’ under the revised Directive, this does not necessarily confer upon such
plants a preferred position in the hierarchy over all other residual waste treatments.
Article 4 of the Waste Framework Directive states:
When applying the waste hierarchy referred to in paragraph 1, Member States
shall take measures to encourage the options that deliver the best overall
environmental outcome. This may require specific waste streams departing from
the hierarchy where this is justified by life-cycle thinking on the overall impacts of
the generation and management of such waste.
Given this, it might have been expected that the Commission itself would have sought
to demonstrate a clear distinction between incinerator which would, and would not,
meet the recovery criteria. To the best of our knowledge, it did not. Given that a tradeoff
may exist, in some instances, between an incinerator’s energy use, and the quality
of flue gas cleaning, such an analysis would have been entirely appropriate.
The above externality assessment, as well as the analysis in Annexes 61.0 and 62.0,
suggests that for municipal waste, there is no obvious reason why incineration which
qualifies as recovery should be preferred to some other forms of residual waste
treatment. Even with respect to landfilling of untreated waste, surprisingly, the
evidence is equivocal, including some of the work carried out under auspices of the
European Commission itself. The Waste Framework Directive is also not well adapted
to answering questions as to whether, and if so, under what conditions, different
configurations of MBT should be regarded as recovery or disposal.
In the light of the above, Government may wish to consider issuing a statement to the
effect that as regards residual waste, the levy is intended to internalise environmental
costs. With these estimated externalities internalised through the levy, other factors
would be used to determine the pattern of residual waste treatment used, including
other policy instruments and their effects. Indeed, it is not clear what is to be gained
by Government stating a preference for one or other approach to dealing with residual
1050 D.O. Reimann (2006) CEWEP Energy Report, Report for CEWEP, Update July 2006.
International Review of Waste Policy: Annexes

waste if the levy comes into force, with the key issue then being to ensure that policy
seeks to minimise the quantity of waste which is managed as ‘residual waste’. 1051
1051 Note that given the requests for evidence we have received, we have, for the sake of
completeness, carried out an assessment of external benefits from recycling. These would indicate a
case for subsidy rather than a levy because of the external benefits generated. This will be made
available at a later date, and to support the work on policy measures operating at higher levels in the
hierarchy.
844
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OTHER POLICIES
845
International Review of Waste Policy: Annexes

57.0 Green Public Procurement
57.1 Introduction
The European Commission uses the following definition for green public procurement:
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“Green public procurement means that public purchasers take account of
environmental factors when buying products, services or works”.
European and national legislation strictly governs public procurement in order to
ensure the following three main objectives are achieved:
� best value for money;
� equal treatment of bidders; and
� transparency of contract specifications and criteria.
Green public procurement accounts for environmental issues through the contract by
ensuring value for money.
The environmental impact of a good or service can be displayed through eco-labelling
or environmental management system certification. Eco-labelling is very often
informed through Life Cycle Analysis (LCA) calculations. LCA proves that the products
chosen, and eco-labelled, have a reduced environmental impact throughout their life
cycle. This also demonstrates that green procurement is a cost-effective process
when life-time, not just purchase costs, are taken account of. Eco-labelling, is usually
voluntary and requires the product to be certified by a third party, having reached a
certain environmental quality standard. The best-known of the eco-labels is the
European label, which is a flower, whilst other successful systems are operating in
Scandinavia, whose logo is the Nordic Swan, and Germany which use a Blue Angel
logo. 1052 Also, environmental management systems such as EMAS and ISO140001
are used as recognisable certification systems. In addition, several Member States
have compiled databases of accredited green products and links to possible
suppliers. 1053
Green public procurement (GPP) is defined somewhat differently to sustainable
procurement, which aims to account for social, ethical and environmental issues
throughout the procurement process, although frequently the terms are used
interchangeably.
1052 European Commission (2004) Buying Green! – A Handbook on Environmental Public Procurement,
Available: http://ec.europa.eu/environment/gpp/pdf/buying_green_handbook_en.pdf
1053 ICLEI Local Governments for Sustainability (2007) The Procura+ Manual: A Guide to Cost-Effective
Sustainable Public Procurement, 2 nd Edition, Available:
http://www.procuraplus.com/fileadmin/template/projects/procuraplus/New_website/Printed_Manual
/Procura__Manual_complete.pdf

57.2 Benefits of Green Procurement
In total, public authorities across Europe have the purchasing power equivalent to a
16% share of the EU’s gross domestic product, amounting to almost €2,000 billion
per year. 1054 This vast sum of money is commonly spent within sectors which have
relatively high environmental impacts, for example, construction, waste management,
transport and energy.
The significant market leverage force held by public authorities can influence
suppliers, and innovation and production, of ‘greener’ products and services. 1055 The
force of public procurement may have the capacity to reduce the unit costs through
increasing demand for ‘greener’ products. Furthermore, this has the potential to
influence the behaviour and consumption habits of the private sector and general
public when purchasing good and services, not least by enhancing the availability of
product information.
Reducing the environmental impact of the public sector, and potential improvements
this may have upon procurement within the private sector, are expected to result in
reduced carbon emissions, reduced waste and increased water efficiency. These
environmental impacts will often help to meet various national and European
environmental targets which have been agreed.
57.3 Regulatory Framework
In the past, concerns were raised regarding potential problems, including distortion of
the single market and reduction of competition within the EU, as the uptake of Green
Public Procurement policies increased across Member States. The need for continuity
in policies from country to country led to the development of the EU regulatory
framework as it stands today, which is shown in Figure 57-1. This framework has
developed under the Treaty of the Amsterdam in 1997, in which sustainable
development became a fundamental objective; the 2001 Gothenburg Summit, which
launched the first EU sustainable development strategy; and the 2002 World Summit
on Sustainable Development in Johannesburg, during which a Plan of Implementation
was agreed stating that all relevant authorities at all levels should,
847
“promote public procurement policies that encourage development and
diffusion of environmentally sound goods and service.” 1056
1054 European Commission (2008) Quote from Stavros Dimas, EU Commissioner for Environment,
http://ec.europa.eu/environment/gpp/background_en.htm
1055 Öko-Institut and Iclei (2007) Costs and Benefits of Green Public Procurement in Europe, Available:
http://ec.europa.eu/environment/gpp/index_en.htm .
1056 IDeA Procurement (2003) Sustainability and Local Government Procurement, Improvement and
Development Agency for Local Government, Available: http://www.idea.gov.uk/idk/aio/1701515
International Review of Waste Policy: Annexes

Figure 57-1: EU Regulatory Framework
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Year Policy / Strategy Summary of Policy/Strategy Objective(s)
2003
2004
2006
2008
Commission Communication on
Integrated Product Policy
Directive 2004/17/EC: to
coordinate the procurement
procedures of entities
operating in the water, energy,
transport and postal services
sectors
Directive 2004/18/EC: to
coordinate the procedures for
the award of public works
contracts, public supply
contracts and public service
contracts
EU Sustainable Development
Strategy
Action Plan on Sustainable
Consumption and Production
and Sustainable Industrial
Policy (SCP/SIP)
Training Toolkit on Green Public
Procurement
Renewed EU Sustainable
Development Strategy
Member States recommended to adopt
national plans for GPP by the end of
March 2006
Clarified how public purchasers can
include environmental considerations
into their procurement procedures. This
is explained in the ‘Buying Green! -
Handbook on Green Public Procurement’
Set the policy objective for 2010 of
bringing the average level of EU GPP up
to the standard achieved by the best
performing Member States in 2006.
Series of communiciations which aim to
develop and set environmental criteria in
greater detail for potential use for GPP.
Defines criteria which have been
developed for product and service groups
in the 10 sectors that are thought to be
most suitable for implementing GPP.
Set the policy objective for Member
States to have 50% GPP by 2010.
As shown explicitly in Figure 57-1, in 2004 the two Directives (Directive 2004/17/EC
and Directive 2004/18/EC) allowed public authorities to include environmental
priorities within their procurement process. The Directives, and supporting
documents, show how environmental criteria can be introduced, whilst ensuring the
internal market functions correctly allowing for free movement of good and services,
equal treatment of bidders and best value for money is achieved.
One supporting document, the EU’s ‘Green Procurement Guide’, provides practical
advice on how to implement environmental measures within a contract, in line with
European legislation. Table 57-1 is not exhaustive but it provides some examples of

what can, and what cannot be done, when including environmental criteria within a
contract.
Table 57-1: Limitations to the Inclusion of Environmental Criteria within a Contract
849
Topic Topic Topic
You You can… can…
You You cannot…
cannot…
Subject Matter of a Contract
International Review of Waste Policy: Annexes
...freely define the subject of
the contract.
…specify using technical
standards or on performance
based requirements.
…define specific products or
services since this may
distort the level playing-field.
…require tenderers to be
registered under a certain
eco-label scheme.
Technical Specifications E.g. Using EU eco-labels for light bulbs: The EU eco-label
criteria for light bulbs require that they should have an
average life-span of 10 000 hours. When reflecting this in a
call for tender for light bulbs, 10 000 hours could be set as
the technical specification for the minimum life span. 1057
Technical Standards
Material Requirements
Process Requirements
Process Requirements
Examples
…define a higher level of
environmental protection
than laid down in a standard.
…insist that the product you
are purchasing is made from
a specified material.
…include requirements on
production methods in the
specifications for green
procurement.
…e.g. ask for electricity
produced from renewable
energy sources
…define a higher level of
environmental protection
than laid down in a standard
that discriminates against
potential bidders.
…breach the principles of
non-discrimination, and the
free movement of goods and
services.
…include requirements which
are not related to the
manufacturing of the
product, or which don’t
contribute to its
characteristics.
…e.g. require a company
from whom you are
purchasing furniture to use
recycled paper in their offices
In 2008, ten priority sectors were identified by the Commission in the Training Toolkit
on Green Public Procurement. These were based on the following:
� scope for environmental improvement;
1057 European Commission (2004) Buying Green! – A Handbook on Environmental Public Procurement,
Available: http://ec.europa.eu/environment/gpp/pdf/buying_green_handbook_en.pdf

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� public expenditure;
� potential impact on the supply side;
� example setting for private or corporate consumers;
� political sensitivity;
� existence of relevant and easy-to-use criteria (e.g. current eco-labelling);
� market availability; and
� economic efficiency. 1058
The priority sectors are:
1. Construction;
2. Food and catering services;
3. Transport and transport services;
4. Energy;
5. Office machinery and computers;
6. Clothing, uniforms and other textiles;
7. Paper and printing services;
8. Furniture;
9. Cleaning products and services; and
10. Equipment used in the health sector. 1059
The current legislative framework has resulted in a non-binding target of 50% for the
average level of Green Public Procurement in each Member State from 2010,
progress towards which will be monitored using the methodology proposed by the
consortia of PricewaterhouseCoopers, Significant and Ecofys published in January
2009. 1060
1058 European Commission (2008) Communication from the Commission to the European Parliament,
the Council, the European Economic and Social Committee and the Committee of the Regions: Public
Procurement for a Better Environment, Available: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0400:FIN:EN:PDF
1059 European Commission (2008) Communication from the Commission to the European Parliament,
the Council, the European Economic and Social Committee and the Committee of the Regions: Public
Procurement for a Better Environment, Available: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0400:FIN:EN:PDF
1060 PricewaterhouseCoopers, Significant and Ecofys (2009) Collection of Statistical Information on
Green Public Procurement in the EU: Report on Data Collection Results, Available:
http://ec.europa.eu/environment/gpp/pdf/statistical_information.pdf

In light of the renewed EU Sustainable Development Strategy several Member States
adopted ambitious green and sustainable procurement targets across a range of
priority sectors. 1061
57.4 Government Influence towards Green Procurement
Despite the propensity for environmental criteria to be included within public
procurement at an increasing rate, Ireland has shown comparatively limited progress.
Their absence from the ‘National Sources’ section of the European Commission’s
Green Public Procurement website is notable, along with the lack of progress
regarding their Action Plan for Green Procurement. 1062 In 2007, Ireland’s National
Climate Change Strategy stated that,
851
“The Government will publish its Action Plan for Green Public Procurement in
2007,” 1063
Despite this claim it is still being drafted.
Within the current legislative framework European governments can be hugely
influential. Through adoption of the EU targets, outlined in a national action plan, they
can lead the way towards the ‘greening’ of their public sector. In order to encourage
adoption across local government and other public bodies, central government can
produce guidance and information. This should inform the procurement officers with
all the information they need to confidently include environmental specifications
within a call to tender.
For example, the UK adopted a ‘Sustainable Procurement Action Plan’ which is
enforced via target-setting. The targets apply to all central Government Departments,
executive agencies and Non-Departmental Public Bodies (in the majority of cases)
and have been effective since 2006. This replaced the ‘Framework for Sustainable
Development on the Government Estate’. In 2003, national policy filtered down to
local government in the ‘National Procurement Strategy for Local Government in
England (2003-2006)’.
Many green procurement processes target emissions, but equally examples can be
found which affect the waste management sector. For example, for construction and
demolition projects the targets set can influence recycling and reuse rates on site,
and minimum recycled content requirements for the materials used.
Four waste related examples follow in Section 57.4.1 to Section 57.4.7.
1061 The Dutch government has set a 100% Sustainable Procurement target for 2010 and the Austrian
government has set targets by priority sector including 95% for IT, 80% for electricity, 30% for paper,
95% for cleaning products and 20% for vehicles.
1062 European Commission (2009) Green Public Procurement Website: Useful Sources of Guidance
and Information, Available: http://ec.europa.eu/environment/gpp/guideline_en.htm
1063 Department of the Environment, Heritage and Local Government (2007) Ireland: National Climate
Change Strategy 2007 – 2012, Available:
http://www.environ.ie/en/PublicationsDocuments/FileDownLoad,1861,en.pdf
International Review of Waste Policy: Annexes

57.4.1 UK Public Sector
Central Central Central Government
Government
Across the Government there is a hierarchy of support for the development and
implementation of green procurement policy. This includes Defra, responsible for
developing green procurement policy across Government departments, the Chief
Sustainability Officer and the Centre of Expertise in Sustainable Procurement at the
Office of Government Commerce. These groups are guided by the Sustainable
Development Commission who act as an independent watchdog.
In 2005 the Government’s sustainable development strategy set the ambitious goal
of becoming a sustainable procurement leader amongst EU member states by 2009.
This was followed by a Sustainable Procurement Action Plan published in 2007 and
most recently a Delivery Plan in 2008.
A main issue with the Government’s strategy is the lack of measurability. There is not
one single quantified goal, just the statement regarding leadership within the EU.
Progress is measured against a series of initiatives which include:
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� The Framework for Sustainable Operations on the Government Estate;
� Sustainable Procurement Action Plan;
� Quick Wins standards; and
� The Sustainable Procurement Task Force’s Flexible Framework.
The most recent progress report, ‘Addressing the Environmental Impacts of
Government Procurement’ focused on four main procurement categories which were
energy, information and communications technology, office supplies and services and
vehicle fleets. The report covers five areas of government which account for a high
percentage of the Government’s overall expenditure which are the Department for
Work and Pensions (DWP), HM Revenue and Customs, Ministry of Defence, Ministry
of Justice and the health service. 1064
The main findings from the National Audit Office’s progress report suggest that of the
five departments investigated only the National Health Service Purchasing and Supply
Agency (NHS PASA) are reaching the required level of sustainable procurement a year
in advance of the requirement, according to the Sustainable Procurement Task
Force’s Flexible Framework. The DWP are also on target to fulfil this goal but the other
three departments are,
‘some way from having embedded sustainable procurement into their working
practices’. 1065
1064 National Audit Office (2009) Addressing the Environmental Impacts of Government Procurement,
Available: http://www.nao.org.uk//idoc.ashx?docId=56417d76-45d6-4181-916cda4c00b1bc88&version=-1
1065 National Audit Office (2009) Addressing the Environmental Impacts of Government Procurement,
Available: http://www.nao.org.uk//idoc.ashx?docId=56417d76-45d6-4181-916cda4c00b1bc88&version=-1

WRAP WRAP
WRAP
The greening of service procurement has arisen through inclusion of recycled paper
requirements for the tender. The attitude surrounding presentation of project bids has
changed in recent years – with a shift away from wasteful printing. This is exemplified
by a tender invitation published by WRAP in March 2009 which is typical of all WRAP
tenders in that it states,
853
‘Your tender submission should be printed double sided, submitted on
recycled paper wherever possible and should be limited to no more than 20
pages (excluding appendices)’. 1066
Craigavon Craigavon Borough Borough Council
Council
Craigavon Borough Council has a Green Procurement Policy, implemented by their
Purchasing Group, which aims to reduce their overall environmental impact.
Craigavon, along with the Greater London Authority and York, is one of the only three
UK participants in the International Procura+ Sustainable Procurement Campaign. 1067
Some examples of how waste-related issues have been included with Craigavon’s
GPP are as follows: 1068
Compost
Compost
Craigavon Borough Council specify that with regards to compost and mulch
preference should be given,
‘to those produced from regionally generated plant debris and/or food waste’
Recycled Recycled Content Content Products
Products
‘Products that contain recycled content, particularly post consumer content,
are to be prioritised.’
Small Small Small Consumables
Consumables
Tenders
Tenders
‘GPP requirements will apply to each of the products through the use of the
procurement software. Purchasing criteria and guidelines on small
consumables will be stored on a database, along with relevant order
information on each product.’
‘To demonstrate our commitment to ensuring that companies providing
services to Craigavon Borough Council are in compliance with environmental
regulations and are taking additional steps to conserve resources, prevent
pollution and minimize waste, suppliers and contractors wishing to provide
1066 WRAP (2009) Tender Invitation Document: EVA123-000 Landfill Bans Research.
1067 Procura+ is an initiative designed to help support public authorities in implementing Sustainable
Procurement, Website available: http://www.procuraplus.org/index.php?id=4594
1068 Craigavon Borough Council (1999) Green Procurement Policy, Available:
http://www.procuraplus.org/fileadmin/template/projects/procuraplus/files/tenders___NAP/Craigavon
_Green_Procurement_Policy_2007.pdf
International Review of Waste Policy: Annexes

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services should be encourages to become certified by some environmental
standard.’
57.4.2 Japan’s Green Purchasing Law
The Green Purchasing Law, which came into force in 2001, stipulates the
requirement for the Japanese Government and national public organisations to
promote green procurement. This is supported via a green purchasing guideline which
catalogues several hundred green products and which is updated annually; a Green
Purchasing Network which disseminates information; and an ‘Eco-product’ exposition
which is held each year. The promotion of green procurement is reinforced by an
annual reporting requirement to the Ministry of the Environment. 1069 The increasing
share of green products since the year the policy was implemented is shown in Figure
57-2.
Figure 57-2: Green Purchasing by the Japanese Government and National Institutions
(excluding Public Works)
Source: Tananka,R. (2007) Waste Reduction in Japan, British Embassy Tokyo, Available:
http://ukinjapanstage.fco.gov.uk/resources/en/pdf/5606907/5633507/071030WasteReduction.pdf
1069 R. Tananka (2007) Waste Reduction in Japan, British Embassy Tokyo, Available: http://ukinjapanstage.fco.gov.uk/resources/en/pdf/5606907/5633507/071030WasteReduction.pdf

57.4.3 Washington State Recycling and Conservation Paper Law
In May 2009 Washington adopted a paper recycling and conservation law which
requires state agencies and colleges, with buildings with 25 or more employees, to:
855
� purchase 100% recycled content printing paper;
� reduce printing paper use by 30% before July 2010;
� recycle 100% printing paper;
� restrict future leases/purchase of printers and copiers to those which
efficiently use 100% recycled content paper; and
� prioritise purchasing from companies that produce paper in mills powered
by renewable energy. 1070
57.4.4 The Scottish Executive
In 2006 the Scottish Executive requested all Scottish public authorities to ensure that
at least 10% of the total value of materials used on projects worth over £1m should
be derived from reused or recycled materials. In addition minimum recycled content
levels were set for paper products (50% for printing paper and 100% in tissue
paper). 1071
57.4.5 The Olympic Delivery Authority
In preparation for the 2012 Olympics the Olympic Delivery Authority are undertaking
major construction works. Their Sustainable Development Strategy has set the
minimum requirement of 90%, by weight, of the material arising through demolition
works to be reused or recycled. 1072
57.4.6 Newport Southern Distributor Road
This project involved road improvement to a dual carriageway in Newport, South
Wales. This case study was used by Defra to undertake a cost-benefit analysis of the
project. 1073 The project, funded under a Private Finance Initiative (PFI) contract,
1070 State of Washington Department of Ecology (2009) New Law Makes State’s Paper Usage Leaner,
Greener, News Release 6 th May 2009, Available: http://www.ecy.wa.gov/news/2009news/2009-
103.html
1071 Edie News (2006) Scottish Institutions Set Green Procurement Targets, Available:
http://www.edie.net/news/news_story.asp?id=12368&channel=0
1072 Olympic Delivery Authority (2007) Sustainable Development Strategy, Available:
http://www.london2012.com/documents/oda-publications/oda-sustainable-development-strategy-fullversion.pdf
1073 SQW Ltd (2006) Cost Benefit Analysis of Sustainable Public Procurement, Final Report to DEFRA,
Available:
http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=140
62&FromSearch=Y&Publisher=1&SearchText=EP01024%20&SortString=ProjectCode&SortOrder=Asc
&Paging=10
International Review of Waste Policy: Annexes

sought to utilise locally available recyclable materials. In using steel slag, available
from the former steelworks in the area, and material from the nearby rail recycling
depot, they used 97.5% recycled aggregate which resulted in a direct cost saving of
just over £1 million, mainly due to savings made from avoiding the aggregate tax.
Further savings were made through avoided carbon emissions since by using locally
sourced aggregate, haulage distances were reduced; recycling material generated onsite
led to reduced landfill disposal costs and reduced carbon emissions; and health
benefits were identified through less transportation. The total savings equated to
3.82% of project costs.
57.4.7 Mayor of London’s Green Procurement Code
The Mayor of London’s Green Procurement Code is a support service which has been
set up for London based organisations. Having committed to the Green Procurement
Code, organisations receive a green procurement toolkit with advice and information.
A progress review encourages organisations to strive to achieve progressive
environmental targets which are awarded with gold, silver and bronze certifications.
The service was launched in 2001 and since then members of the Green
Procurement Code have collectively diverted 1.3 million tonnes of waste from landfill.
In 2006, 175,000 tonnes of carbon dioxide was saved which is equivalent to yearly
emissions of over 29,000 households. 1074 In truth, it may be that some of this would
have happened anyway, since these figures relate to organisations signing up to the
Code.
57.5 Scope for Green Public Procurement in Ireland
With respect to Ireland, the EU regulatory framework is highly relevant in setting the
scene and realising the scope for green public procurement. However, it is worth
noting that the EU is currently lagging behind the USA, Canada and Japan who have
all mandated green public procurement in various forms. 1075
In 2006 work undertaken for the European Commission highlighted the top seven
countries undertaking a significant level of Green Public Procurement, of which
Ireland was not one. 1076 The ‘Green 7’ are Austria, Denmark, Finland, Germany,
Netherlands, Sweden and the UK. However, even within these countries many of the
tenders were found not to be fully compliant with EU procurement law. At the
beginning of 2008, Ireland was not one of the 14 Member States that had adopted a
national action plan for their Green Public Procurement, despite the Commission’s
1074 Mayor of London’s Green Procurement Code (2009) Information taken from the website:
http://www.greenprocurementcode.co.uk/
1075 European Commission (2008) Communication from the Commission to the European Parliament,
the Council, the European Economic and Social Committee and the Committee of the Regions: Public
Procurement for a Better Environment Impact Assessment, Available:
http://ec.europa.eu/environment/gpp/pdf/sec_2008_2124_EN.pdf
1076 M. Bouwer, M. Jonk, P. Szuppinger, H. Lusser, T. Berman, R. Bersani, V. Nappa, C. Vigano, A.
Nissinen and K. Parikka (2006) Green Public Procurement, Report to the European Commission,
Available: http://ec.europa.eu/environment/gpp/pdf/report_facts.pdf
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ecommendation to do so in 2003 via the Communication on Integrated Public
Policy. 1077
Ireland’s National Climate Change Strategy 2007-2012 states the following with
regards to procurement,
857
“The Government will publish its Action Plan for Green Public Procurement in
2007” 1078
Despite this claim, Ireland has started work on their draft national action plan but to
date their current Green Public Procurement relevant legislation is:
� Green Government Guide (1996) which recommends green public
purchasing; and
� Policy Statement on Recycling and Preventing Waste (2002) which
recommend use of recycled and recyclable materials in GPP. 1079
The Department of the Environment, Heritage and Local Government’s website has a
small section on GPP located on the ‘Sustainable Development’ webpage. 1080 The
text is copied into Box 1 below and highlights the need for national legislation to be
developed. The national government cannot rely upon local authorities to adopt, and
take forward, European Guidelines. There is likely to be a need for leadership, and
possibly, binding targets, alongside information to guide central government, its
agencies and local authorities to demonstrate how implementation of GPP can be
made straightforward, and how to realise the benefits of GPP.
In order to confirm the Department’s commitment to green procurement the following
two questions, and subsequent answers, were put to the Minister for the
Environment:
1. Q: To ask the Minister for the Environment, Heritage and
Local Government the reason Ireland has not adopted a national action
plan for green public procurement despite the fact that such a plan was
required to be adopted by the end of 2006; and if he will make a
statement on the matter.
1077 European Commission (2008) Communication from the Commission to the European Parliament,
the Council, the European Economic and Social Committee and the Committee of the Regions: Public
Procurement for a Better Environment Impact Assessment, Available:
http://ec.europa.eu/environment/gpp/pdf/sec_2008_2124_EN.pdf
1078 Department of the Environment, Heritage and Local Government (2007) Ireland: National Climate
Change Strategy 2007 – 2012, Available:
http://www.environ.ie/en/PublicationsDocuments/FileDownLoad,1861,en.pdf
1079 European Commission (2008) Guide to National GPP Policies and Guidelines, Available:
http://ec.europa.eu/environment/gpp/pdf/national_gpp_strategies_en.pdf
1080 Department of the Environment, Heritage and Local Government (2009) Sustainable Development
web page, Available: http://www.environ.ie/en/Environment/SustainableDevelopment/
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A: “The conclusions adopted by the September 2008 EU Competitiveness
Council recalled the aim of the EU Sustainable Development Strategy on
Green Public Procurement and provided a comprehensive overview of
developments and commitments.
The Government’s commitment to green public procurement was
confirmed in the 2008 Framework For Sustainable Economic Renewal
Building Ireland’s Smart Economy. My Department is committed to the
preparation of an action plan on green public procurement. In doing so, we
will work with the Department of Finance’s National Public Procurement
Policy Unit which has overall responsibility for public procurement policy in
Ireland.”
Box Box Box 1: 1: Green Green Public Public Procurement Procurement 1081
In Ireland, the total Government and public sector purchasing budget is over €10 billion per
annum. If purchasers in the public sector consistently specified environmentally
advantageous criteria in their specifications, it would provide significant leverage to “move
the market” towards the economic provision of environmentally superior goods and services.
The Government is therefore committed to promoting Green Public Procurement (GPP).
The National Public Procurement Policy Unit (NPPPU) of the Department of Finance has
overall responsibility for public procurement policy in Ireland. NPPPU maintains the website
http://www.etenders.gov.ie/, a centralised portal containing comprehensive information on
public procurement. Sustainable Development Unit has the lead role in “greening”
procurement across the public sector. We therefore liaise closely with NPPPU on highlighting
information on http://www.etenders.gov.ie/ on how to integrate environmental
considerations into purchasing practices for goods and services. This includes the EU
Handbook on Environmental Public Procurement.
The Procura Plus Manual, published by ICLEI Local Governments for Sustainability, is a very
practical and useful guide to cost-effective public procurement. It includes international
examples and case studies from a variety of organisations in the public sector.
The European Commission maintains a dedicated website on Green Public Procurement. This
includes information on Member States’ National Action Plans on GPP, envisaged as part of
the implementation of the EU Environmental Technologies Action Plan (ETAP). Sustainable
Development Unit is currently preparing Ireland’s National Action Plan on GPP.
2. Q: To ask the Minister for the Environment, Heritage and Local Government
the action proposed to ensure that the EU sustainable strategy in respect
of green procurement targets will be met; and if he will make a statement
on the matter.
A: “We will also work with the National Procurement Operations Unit in the
Office of Public Works. The new Unit will be a centre of excellence for
public procurement generally and will facilitate the integration of whole-of-
Government policy issues in areas such as sustainability and the
1081 Department of the Environment, Heritage and Local Government (2009) Sustainable Development
web page, Available: http://www.environ.ie/en/Environment/SustainableDevelopment/

859
environment into public procurement practice for the organisations served
by the Unit.”
The Market Development Programme (MDP) is now involved in this process. The MDP
Action Plan states: 1082
The Department of Finance is committed to the further integration of
environmental considerations into the public procurement process in 2009,
with the goal of bringing us into line with the best performers in Europe. In this
regard, the National Operations Unit (NOU) has been established by the
Department of Finance in order to achieve efficiency and value for money
through the use of centralised and specialised procurement, allowing all
central Government Departments and Offices, agencies and non-commercial
bodies to acquire a range of goods and services more effectively and
efficiently.
The Market Development Programme will co-operate with the Department of
Finance in promoting Green Procurement. In addition, the Implementation
Team will collaborate on Green Procurement with the DOEHLG, other
Government Departments and Agencies, the Forfás High Level Action Group
on Green Enterprise as well as key stakeholder groups like the EU, EPA and
local authorities who have already started delivering best practice and tools in
this area. Working together will avoid duplication of efforts and ensure that
optimal and consistent Green Procurement strategies are put in place across
the different sectors and organisations.
The goals of the Market Development Programme are stated as:
� Identify and overcome challenges to Green Procurement in the use of
materials produced by the recycling of organic, paper, plastic and other waste
materials,
� Provide information on the availability and suppliers of green products,
� Promote the development of Green Procurement policies in public and private
sectors,
� Demonstrate the economic and environmental benefits of Green Procurement
policies within public and private sectors,
� Provide information to the public and private sectors on the practical aspects
of Green Procurement.
It is to be hoped that this will add some impetus to the process, although the above
goals suggest that the MDP’s role will be supportive rather than leading on policy
development. Critical in the process will be the commitment of high level officials in
Government, notably in the Department of Finance and in DoEHLG, to carry the
process forward with vigour. The slowness of progress thus far suggests that in the
past, this has been absent, with words uttered, but little by way of action taken.
1082 Market Development Programme (2009) Market Development Programme for Waste and
Resources, Action Plan 2009.
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57.5.1 Barriers to Uptake of Green Public Procurement
The European Commission’s ‘Public Procurement for a Better Environment: Impact
Assessment’ details specific problems and barriers which are known to hinder the
uptake of green public procurement. They are listed below, but further details can be
found in the source document:
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1. Lack of awareness of benefits, misperception of the extent of costs, and
lack of political priority for GPP;
2. Legal problems;
3. Lack of information and tools for GPP, inadequate training structures, lack
of knowledge of priority areas and absence of easy to apply GPP criteria;
and
4. A lack of similarity between GPP procedures and criteria across the EU.
It is also felt that perceived legal problems, and general misperception over the scale
of the green procurement implementation process, hinder the take up of such a
policy. 1083
57.5.2 Administrative Costs
Green procurement leads to consideration of a product or service’s whole life costs.
The overall saving made through implementation of GPP depends on the
administrative costs involved, and whether or not they offset the savings. A report to
Defra in 2006, which undertook a cost benefit analysis on sustainable public
procurement, found evidence to suggest that savings are made over time when the
GPP process has been established and administrative tasks have been integrated.
This means that the majority of associated costs are ‘one-off’ and once embedded
into the system they can begin to deliver value. As policy implementation internalises
environmental performance (emissions trading etc.) then Green Procurement starts
to become more cost-effective.
Administrative costs will depend on the current procurement processes in place, and
how these are managed. On average, individual authorities who are setting up and
implementing GPP spend a total of €223/1000 inhabitants over 2-6 years. 1084
57.6 Conclusions
In light of the European framework which is in place, Member States ought to be
striving to reach the target of 50% for the average level of green public procurement
by 2010. This target seems unlikely to be met by Ireland, and there is not yet any
formalised commitment to this as far as we are aware. The formalised EU framework
1083 National Audit Office (2009) Addressing the Environmental Impacts of Government Procurement,
Available: http://www.nao.org.uk//idoc.ashx?docId=56417d76-45d6-4181-916cda4c00b1bc88&version=-1
1084 Oko-Institut (2007) Costs and Benefits of Green Public Procurement in Europe, Available:
http://ec.europa.eu/environment/gpp/pdf/eu_recommendations_2.pdf

has created a ‘level playing field’ in which the potential issues of barriers to trade
have been largely resolved.
In Ireland the framework requires formalising through production of a finalised
national action plan. This should go above and beyond the influence of the current
sustainable consumption and production initiatives which are in place. Failing to
formally adopt a green public procurement policy may hinder product innovation and
eco-design and availability of environmentally sound services. In the area of waste
management, it essentially implies a failure to ‘close the loop’ to the extent that those
who recycle might not be using the power of public purchasing to help increase
demand for secondary materials, and hence, the viability of the industry which leads
to their production.
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58.0 Ireland and the UNECE / Stockholm
Conventions
Irish waste management (and other) policy should incorporate measures to ensure
compliance with both the UNECE and Stockholm Conventions (see Annex 1.0). This
requirement may be not be immediately obvious because whilst Ireland is a signatory
to both the UNECE and the Stockholm conventions, it is not a party to either. 1085 The
EU, however, is a party to both and has implemented them through regulations which
also apply to Ireland. The main legal instrument for implementing the Stockholm
Convention and the UNECE Protocol on POPs within the EU is Regulation (EC) No.
850/2004. 1086 This Regulation entered into force 20 th May 2004 and as a
regulation, it is directly applicable in all Member States, including those, like Ireland,
which are not yet Parties in their own right to the Stockholm Convention or the UNECE
Protocols. Two separate Council decisions concerning the Community’s conclusions
on these two international agreements have been made in parallel to the
Regulation. 1087 Ireland should, therefore, have implemented these requirements
already and should be ensuring compliance with the Stockholm Convention
obligations. At present, there is no obvious evidence that this has been done in
practice, though a National Implementation Plan (NIP) is in the process of being
prepared (see below).
The EPA has been designated by the Department of Environment, Heritage and Local
Government as the Competent Authority for the implementation and enforcement in
Ireland of Regulation 850/2004 on POPs. 1088 The EPA liaises with relevant public
bodies such as, Food Safety Authority of Ireland, Irish Medicines Board, Health and
Safety Authority and Pesticide Control Service to regulate POPs in Ireland.
Article 8 of the same Regulation - 850/2004 - is the legal basis for the requirement to
prepare a NIP. This is currently being prepared in Ireland, as described above
1085 Ireland signed the Stockholm Convention on 23 rd May 2001 but has not yet ratified.
http://chm.pops.int/Countries/StatusofRatification/tabid/252/language/en-US/Default.aspx
1086 European Commission (2004) Regulation (EC) No 850/2004 Of The European Parliament and of
the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC
Note that whilst this was published in the Official Journal of the European Union L158 of 30th April
2004, a Corrigendum to the Regulation was subsequently published in the Official Journal L229/5 of
29th June 2004. 2004, Official Journal of the European Union L 229/5.
1087 Council Decision 259/2004/EC of 19 February 2004 concerning the conclusion, on behalf of the
European Community, of the Protocol to the 1979 Convention on Long Range Transboundary Air
Pollution on Persistent Organic Pollutants; and Council Decision concerning the conclusion, on behalf
of the European Community, of the Stockholm Convention on Persistent Organic Pollutants was
adopted on 14 October 2004.
1088 Environmental Protection Agency (2008) Consultation Paper on a Proposal to Prepare a National
Implementation Plan on Persistent Organic Pollutants, June 2008.
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Article 6 of Regulation (EC) No.850/2004 requires:
863
3. Member States shall, when considering proposals to construct new
facilities or significantly to modify existing facilities using processes that
release chemicals listed in Annex III, without prejudice to Council Directive
1996/61/EC (1), give priority consideration to alternative processes,
techniques or practices that have similar usefulness but which avoid the
formation and release of substances listed in Annex III. (Our emphasis)
The substances listed in Annex III are:
• Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF)
• Hexachlorobenzene (HCB) (CAS No: 118-74-1)
• Polychlorinated biphenyls (PCB)
• Polycyclic aromatic hydrocarbons (PAHs)
The incineration of waste clearly results in releases of all these substances -
especially within residues, but also in emissions to atmosphere. 1089 It follows directly
from this that the EPA, in considering any proposals for incinerators is required to:
“give priority consideration to alternative processes, techniques or practices
that have similar usefulness” but which avoid the formation and release of
PCDD/PCDF, HCB, PCB and PAHs.
The same applies to other processes which are net emitters of these compounds.
A document produced by the Stockholm Convention, Guidelines On Best Available
Techniques And Provisional Guidance On Best Environmental Practices, provides an
outline of the approach that is envisaged to be necessary to satisfy the
requirement. 1090 The guidelines suggest, for example, that this assessment may be
undertaken which includes, for example:
“a comparison of the proposed process, the available alternatives and the
applicable legislation using what might be termed a “checklist approach”,
keeping in mind the overall sustainable development context and taking fully
into account environmental, health, safety and socio-economic factors.”
The meaning of “priority consideration” in the context of the development of
incineration capacity, or of the capacity for other waste treatment facilities, within
Ireland is not entirely clear. How such consideration should be given is perhaps a
moot point. On the one hand, the provisional low POPs threshold under the Stockholm
Convention is not an especially low threshold by EU standards. On the other hand, the
spirit of the Convention would appear to imply something rather more stringent, and it
1089 See, for example, European Commission (2006) Integrated Pollution Prevention and Control
Reference Document on the Best Available Techniques for Waste Incineration, 2006.
1090 Stockholm Convention (2007) Guidelines On Best Available Techniques And Provisional Guidance
On Best Environmental Practices Relevant To Article 5 And Annex C Of The Stockholm Convention On
Persistent Organic Pollutants - Adopted at COP 3, May 2007. 2007: Geneva, Switzerland.
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might be argued that no threshold applies, and the issue is whether or not a process
is, on assessment, established to be a net emitter of dioxins and furans. The effects
would most likely be quite significant for Ireland in terms of both recycling, and the
consideration of alternatives to incineration. This matter has been discussed in more
detail within a Strategic Environmental Assessment of a proposed Section 60 Policy
Direction. 1091
As discussed in Annex 1.0, the UNECE POPs Protocol obliges Parties to reduce their
emissions of dioxins, furans, polycyclic aromatic hydrocarbons (PAHs) and HCB below
their levels in 1990 (or an alternative year between 1985 and 1995). The dioxin
emissions in Ireland are low – and this is reflected in the most recent results of the
ongoing national dioxin surveys. 1092 The 2002 dioxin inventory, however, suggests
that Ireland plans to increase dioxin emissions over the period from 2000 to 2010
and that the main increase would be in incinerator residues. 1093 It is difficult to
reconcile this with the obligations of the UNECE POPs protocol.
The addition of nine new POPs to the Convention at the fourth Conference of the
Parties seems likely, within Europe, to lead to a revision of Regulation 850/2004, and
this will have knock-on implications for Ireland. In this context, it would seem to make
sense to avoid making commitments that prejudice future compliance with what is a
predictable change in regulation. The Annex A listings of c-Octa BDE and c-Penta BDE
significantly increase the likelihood that brominated dioxins and furans (‘PBDD/DFs’)
will soon be proposed for similar listing because PBDD/DFs are both contaminants of
the newly listed flame retardants and are also by products from their combustion. It
is notable that the EPA has already started testing for these compounds in the annual
dioxin surveys. 1094
Releases of unintentionally produced by-products (chlorinated dioxins, chlorinated
furans, PCBs and HCB) are subject to continuous minimisation and ultimate
elimination where feasible. The main tool for this is an action plan which should
cover source inventories and release estimates, as well as plans for release
reductions.
The EPA is currently working on the preparation of a draft national implementation
plan (NIP). 1095 Once completed this draft will be made available for public
consultation. In June 2008 the EPA prepared a short consultation paper to provide
interested parties with more information on the proposed NIP. Written
1091 Eunomia (2009) Section 60 Policy Direction Capping Incineration of Municipal Waste and Other
Matters, Environmental Report for DoEHLG, June 2009.
1092 C. Concannon (2008) Dioxin Levels in the Irish Environment 2007 Fifth Assessment Based on
Levels in Cow's Milk November 2008. 2008: Dublin, Ireland
1093 F. Hayes and I. Marnane (2002) Inventory of Dioxin and Furan emissions to air, land and water in
Ireland for 2000 and 2010 Final Report, Prepared for the Environmental Protection Agency By URS
Dames & Moore: Dublin.
1094 C. Concannon (2008) Dioxin Levels in the Irish Environment 2007 Fifth Assessment Based on
Levels in Cow's Milk November, Environmental Protection Agency, Ireland.
1095 http://www.epa.ie/whatwedo/resource/hazardous/pops/
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epresentations in relation to this consultation paper were invited up to 28th of July
2008. The European Union completed and published an Implementation Plan in
2007. 1096
58.1 Recommendations
Evidently, there is a need to progress the National Implementation Plan with some
urgency. This plan will, presumably, have to consider the best approach to the
Conventions in the light of their requirements.
It is useful to define the main sources that give rise to POPs in the environment in
order to consider where measures can be taken to reduce their generation or
emission to the environment:
865
A) Pesticides (e.g. DDT);
B) Industrial chemicals (e.g. polychlorinated biphenyls (PCBs));
C) Unintentional by-products (e.g. dioxins, furans).
In relation to POPs arising from Source A), although regulation on the production and
use of pesticides is clearly a valuable measure (and the EPA is naturally the
appropriate responsible authority to administer this), this may be considered outside
the scope of this review of waste policy.
The requirements of the UNECE / Stockholm Conventions imply, in relation to Source
B), regulation on the use of industrial chemicals which utilise or have potential to give
rise to POPs. In this regard, many of the policy measures explored in other sections of
this annex have significant relevance. The obligation for producer responsibility,
minimum recycling standards, and levies and bans on specific substances are
measures which can reduce or eliminate the risk of environmental accumulation of
POPs.
In relation to Source C), there is clear benefit to be derived from minimising the
generation and dispersion of POPs as unintended by-products of waste treatment
processes. Two potentially complimentary policy developments present themselves
here:
1. To ensure that any technologies used for the treatment of waste which may
give rise to POPs operate to high environmental standards; and
2. In the light of the possible alternatives available, to seek to reduce the
quantity of material that passes to technologies that might give rise to
additional emissions of POPs in order to reduce their generation and
dispersal.
In relation to the first point, some more detailed policy assessment has been carried
out for the DoEHLG. The proposed Section 60 policy direction seeks to achieve a
1096 Commision of the European Communities (2007) Community Implementation Plan for the
Stockholm Convention on Persistent Organic Pollutants Commision Staff Working Document
SEC(2007) 341, 9.3.2007.
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number of objectives, the last of these specifically relevant to the issue of POPs and
their generation from (thermal) waste treatment: 1097
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“to reduce air soil and water pollution from incineration and comply with the
Stockholm Convention”
The second point here implies that waste minimisation, and diversion of material up
the waste hierarchy (or to non-thermal waste treatment technologies) should be
encouraged in the first instance, thereby reducing the quantity of material which may
give rise to POPs from thermal treatment. There are some issues here in respect of
some of the recycling processes themselves (at least where, for example, flame
retardants are concerned).
Where recycling is not possible, the aim should design out substances of concern,
through, for example, producer responsibility measures, or more generally,
implementing substance bans.
In respect of treatment, the issue of “priority consideration to alternative processes,
techniques or practices that have similar usefulness but which avoid the formation
and release of PCDD/PCDF, HCB, PCB and PAHs” remains of significance. It would
appear to be of some relevance to ensure that guidance is produced detailing how
the requirement to give ‘priority consideration’ is to be implemented.
The full scope of the measures to tackle POPs need to be addressed within the
National Implementation Plan. In addition to the currently legislated requirements, a
forward looking plan will need to consider the new POPs added at the most recent
Conference of the Parties. It is notable that the EPA has demonstrated its ability to
take such a forward look in respect of monitoring.
1097 Eunomia (2009) Section 60 Policy Direction Capping Incineration of Municipal Waste and Other
Matters, Environmental Report for DoEHLG, June 2009.

TARGET SETTING
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59.0 Target Setting
Discussions regarding targets often focus upon whether objectives can be deemed to
be ‘SMART’. The term ‘SMART’ is an acronym that is interpreted in various ways.
However, we interpret it as follows:
1) The degree to which the targets can be said to be well defined for the meeting of
the desired objectives (are they Specific?);
2) Whether or not the targets are measurable (are they Measurable?); and
3) The degree to which one might state that they are appropriately set (are they
Achievable, and are they Timed? 1098).
4) The degree to which the targets could be said to lead to the desired outcomes,
whether in a direct sense, or indirectly through changing behaviour (their
Relevance).
In addition, of considerable relevance are the following:
5) What the ‘desired outcomes’ actually are (which might be deemed linked to the
test of specificity);
6) The degree to which the targets are addressed to the right person (is there a
defined Addressee for the target?); and
7) The degree to which the objectives and targets could be said to have avoided the
potential for perverse outcomes (Perversity avoidance);
We would suggest that targets should be appraised against these questions,
effectively appraising whether they are ‘SMART’ targets with an additional ‘P’ for nonperversity,
and an additional ‘A’ for the addressee. 1099 We have, for ease of reference,
referred to the test as the TRAMPAS test.
It should be said that not all targets necessarily need a well-defined addressee. It
seems sensible to distinguish between targets against which performance is to be
measured, and used to guide the development of policy, and those which effectively
have to be met, being related to a legal or statutory requirement, or to a target which
is seen as important for environmental reasons. In the case of the former, where
performance against the target might be difficult to ‘devolve’ downwards, then
configuring policy and incentives to enable the target to be met, and adjusting these
policy tools where they appear unlikely to be met, becomes the key issue. In the case
of the latter, it seems more necessary to assign responsibility for meeting targets to
1098 If a target is not achievable, it will generally be because it is too challenging. Whether a target is
challenging or not will informed by the timeframe given over to achieve the target.
1099 Since discussion of SMART targets is often taking place within an organisation, it is often taken as
read that they are
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specific actors, or failing that, to take a very active role in reviewing policy to ensure
the targets are met.
59.1 Key Irish Targets
The main Irish targets are set out below (see also Annex 6.0). Some, though by no
means all, of these targets are set as a direct consequence of implementation of EU
Directives. We highlight, alongside each, the issues with the targets as they were
framed:
From Changing Our Ways:
869
� Diverting 50% of household waste away from landfill by 2013;
No clear addressee; no sanction for non-compliance; and limited policy drivers
until very recently;
� A minimum 65% reduction in biodegradable wastes consigned to landfill by
2013;
No addressee(s); no sanction for non-compliance; limited policy drivers until
very recently; relevance not clear when set alongside other targets (for
example, even if waste had not grown, the suggestion is that recycling would
account for a relatively small fraction of the reduction);
� The development of waste recovery facilities employing environmentally
beneficial technologies, as an alternative to landfill, including the
development of composting and other feasible biological treatment facilities
capable of treating up to 300,000 tonnes of biodegradable waste per annum
by 2013;
No addressee(s); no sanction for non-compliance; limited policy drivers (and
arguably, the ABPR has acted to limit development here, until very recently);
potential for perverse outcomes (the ‘up to 300,000 tonnes’ potentially
constrains capacity – it is likely that a figure in excess of this will be required
by 2013);
� Recycling of 35% of municipal waste by 2013;
No addressee(s); no sanction for non-compliance; limited policy drivers; too
easily achievable;
� Recycling at least 50% of C&D waste within a five year period (by 2003), with
a progressive increase to at least 85% over fifteen years (by 2013);
No addressee(s); no sanction for non-compliance; limited policy drivers;
absence of interim measures;
� Rationalisation of municipal waste landfills, with progressive and sustained
reductions in numbers, leading to an integrated network of some 20 state-ofthe-art
facilities incorporating energy recovery and high standards of
environmental protection;
Implicitly, this is aimed at the EPA and planners. It is not obvious what the
relevance of the figure of 20 is, but the figure is specified in an appropriately
vague manner;
� An 80% reduction in methane emissions from landfill, which will make a
useful contribution to meeting Ireland's international obligations;
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No addressee(s); no sanction for non-compliance; unclear how this is being
measured (and measurement may be quite different to ‘estimation’ in this
respect).
National Biodegradable Waste Strategy
� Reductions in biodegradable waste (relative to trend in arisings), of 3% each
year (2005 to 2007), 4% each year (2008 to 2010), 5% each year (2011 to
2013), and 6% each year (2014 to 2016);
No addressee(s); no sanctions; unclear whether this is achievable;
� Targets for home composting at 20% of urban households and 55% of rural
households – equivalent to some 35% of all households - by 2010;
No addressee(s); no sanctions; unclear how this would be measured (and what
the current level is);
� Capture rate for paper and cardboard:
• 45% for households and 61% for commerce in 2010, corresponding to
55% of overall paper / cardboard generation within BMW;
• 55% for households and 71% for commerce in 2013, corresponding to
65% of overall paper / cardboard generation within BMW; and
• 60% for households and 73% for commerce in 2016, corresponding to
67% of overall paper / cardboard generation within BMW.
No addressee(s); no sanctions for non-compliance; policy drivers unclear;
� For organic waste, the targets were:
• 40% coverage for households and 60% coverage for commerce in
2010 at an estimated average yield of 45% to 60% respectively,
corresponding to 25% of overall organic waste generation within BMW;
• 45% coverage for households and 70% coverage for commerce in
2013 at an estimated average yield of 50% to 65% respectively,
corresponding to 33% of overall organic waste generation within BMW;
and
• 50% coverage for households and 70% coverage for commerce in
2016 at an estimated average yield of 55% to 70% respectively,
corresponding to 36% of overall organic waste generation within BMW.
No addressee(s); no sanctions for non-compliance; policy drivers only now
being shaped;
In addition, there are now targets which Ireland has to meet under the producer
responsibility Directives. These targets are set at the lowest rates permissible under
EU legislation. Generally, producers are required to demonstrate that they are
meeting the required targets, though not all addressees face such targets (notably
the ‘producers’ who are not classified as major ones for the purpose of the producer
responsibility scheme for packaging).
A clear and persistent theme in the setting of targets in Ireland is that, with some
exceptions, there are no clear addressees, and that where there are no addressees,

policy has not been sufficiently responsive to deliver the desired outcome with any
certainty. The best example is the Landfill Directive targets, whilst those in the
National Biodegradable Waste Strategy. It is almost always the case that targets have
been set with the presumption that Regions would embed these within the Regional
Waste Management Plans. However, there is no meaningful monitoring of these
Plans, and even where the Plans show no sign of meeting their own targets, there is
no plan to apply any sanction in this respect. Even if the Regions were to be made
‘responsible’ for delivering on targets, to what extent would it be reasonable to
assume, for example, that they should be sanctioned for failure to meet the required
capture rate for commercial biowaste? The 2010 targets in the National
Biodegradable Waste Strategy look, today, worryingly difficult to achieve, yet no one
will ‘pay’, or face any other sanction, for failure in this regard because no one is
obviously responsible for the targets.
It seems clear that one lesson from this experience is that Ireland needs to change its
‘hands-off’ mentality where target setting is concerned, especially where these are
ones which have to be met as a matter of (European) law. In addition, where it seeks
to ensure that its own objectives are to be met, then where these are considered of
high relevance, these should be supported by policies which drive matters towards
meeting the target, and devolution of targets to relevant addressees as appropriate,
supported by sanctions for non-compliance. If no appropriate addressee exists, then
policy should adjust to meeting targets. In cases where targets seem likely to met with
ease, then consideration should be given to revising these to improve later
performance.
Ireland has to consider which targets to set, in the light of consideration of who
should have (can reasonably take) responsibility for them, and how sanctions will be
applied to ensure compliance. The role of Government should be to ensure that
targets are set and, where appropriate, made the responsibility of those who can be
made responsible for their delivery.
Target setting does need take into account:
871
• data availability, and
• availability of proxy information,
In some cases, it may be appropriate to highlight the desirability of specific targets
without setting them until more data and information is available. This is particularly
important in respect of, for example, targets set relative to an ongoing trend. Until this
trend is established, setting targets can lead to overly, or under-ambitious targets.
59.2 Objectives for Targets
The types of objectives which have been the focus of targets in other countries are:
1. Reducing Reducing waste waste production production (household waste, municipal waste, business
waste, public authority waste, commercial waste, industrial waste, hazardous
waste, construction and demolition waste);
These objectives find expression in terms of:
a. Requirements to reduce growth in a waste stream relative to ‘business
as usual’ trends (Flanders);
International Review of Waste Policy: Annexes

872
29/09/09
b. Requirements for pay-by-use of households (e.g. South Korea, Italy);
c. Targets for residual waste per inhabitant (e.g. Wales, England,
Flanders);
2. Increasing Increasing re re-use re use use of selected streams (ELVs, household waste, municipal
waste, construction and demolition waste);
Other than in some countries, where targets for the proportion of beverage
containers to be in refillables exist (e.g. Germany), we are not aware of specific
targets for re-use in different countries since these are usually combined with
recycling or recovery targets (as in the case of ELVs). Like waste prevention, reuse
tends to be a ‘Cinderella area’ of waste policy despite its position in the
hierarchy, the exception being deposit refunds (see Annex 16.0);
3. Increasing Increasing recycling recycling of of selected selected streams streams (packaging, ELVs, household waste,
municipal waste, construction waste, construction and demolition waste):
These are probably the most common targets and are used in many countries.
However, the ease with which recycling targets can be met and the cost
implications of doing so vary across actors in the economy. For producers of
large quantities of homogenous waste streams, such targets may present no
financial or technical problem. Problems can relate to perverse incentives, as
well as the definition of ‘recycling’. The definitional issues are especially
important where construction and demolition wastes are concerned given that
many Member States – including the UK – exempt from licensing some
activities through which large tonnages of material are handled;
4. Increasing Increasing Increasing recovery recovery of of selected selected streams streams (packaging, ELVs, household waste,
municipal waste, construction and demolition waste);
These targets are also common. They need – at least insofar as specific waste
streams are concerned – to pay particular attention to what modes of recovery
are likely to be used. The hierarchy under Article 4 gives priority to materials
recycling with other forms of recovery ranked lower. To the extent that recovery
targets are set, they need to respect the extent of latitude which the term
‘recovery’ may imply, so it is becoming more common in the EU for targets for
recycling and for recovery to be set.
5. Reducing Reducing residual residual waste waste quantities quantities (household waste);
This objective has been deployed in Flanders and Walloonia in Belgium and is
also one of three National Indicators for waste which English local authorities
are expected to report. In Flanders and Walloonia, the target has generally
supported the introduction of pay-by-use for waste. In England, the reporting of
the indicator is not such that any local authority faces any sanction if the
national target (225kg/inh) is not met. There are also no interim targets. In
Walloonia, a residual waste levy system was used to give authorities an
incentive to keep below the national target (see below);
6. Reducing Reducing the the the quantity quantity quantity of of waste waste waste sent sent to to landfill landfill; landfill
It is not clear how many Member States actually set targets to reduce
quantities of waste sent to landfill, but given that many Member States deploy
bans of narrower or broader scope, this objective is more or less implicit (see
Annex 52.0). The different drivers are considered below. The justification for
this target usually relates to reducing the landfilling of ‘resources’. However, a

873
ban only ensures the best use of those resources where complementary
measures ensure waste is moved up the hierarchy and to options where the
environmental impact is superior. Our research indicates that success in this
regard is, at best, mixed. The wording of some bans tends to imply that the
objective is to ensure that waste which can be combusted to generate energy
is used for that purpose. If sufficient measures are in place to promote
recycling strategies, this might be acceptable. In many cases, however, this is
clearly not the case;
7. Limit Limiting Limit Limiting
ing the the the quantity quantity quantity of of of waste waste waste sent sent sent for for for incineration incineration;
incineration
Whilst there appear to be no specific targets for this, again, there are some
measures which imply a desire to ensure environmental standards are not
compromised. Waste sorting in many municipalities in Japan distinguishes
between ‘burnable’ and ‘non-burnable’ waste, with plastics being treated as
‘non-burnable’ owing to problems with dioxins in the past. In Denmark, treated
wood is banned from incineration, presumably owing to the potential for
emission of furans and possibly brominated dioxins from its combustion. In
Flanders, a ban on unsorted waste being sent to incineration is intended to
ensure that the ban on landfilling does not lead to a simple switch from landfill
to incineration. This reflects the fact that in Flanders, the aim is to promote
prevention, re-use and recycling. In Denmark, on the other hand, the effect of
policy has been to shift waste away from landfill and into incineration. A brief
comparison of recycling rates in Flanders and Denmark highlights the fact that
as regards household type waste, Denmark’s recycling rate stood at 29% in
2001, with the aim to increase this to 33% by 2008. 61% of waste was
incinerated in 2001, and it was intended that this should be reduced to 60%
by 2008. In Flanders, source separation rates now stand at 71%, a level which
would be very difficult for Denmark to achieve given its existing infrastructure;
and
8. Reducing Reducing Reducing GHG GHG emissions from waste management
management;
management
The England strategy includes an objective of this nature though no specific
policy mechanism to deliver this. Rather than being an objective, this seems to
be an assessment of the consequences of doing what the strategy seeks to
achieve. There is a serious problem with setting this as an objective in the way
that the English strategy has calculated it. The assessment is carried out ‘as if
waste prevention does not matter’. The consequence is that because of the
methodology and baseline used, then as growth rates increase, the claimed
benefits increase under a given apportionment of waste across the different
management routes. Caution would need to be used if this measure was
deployed, and one might argue that it should only be used once the energy
used in manufacturing materials in the first place enters into the equation.
Finally, there are objectives which relate to the waste sector but in an indirect
manner, and where key drivers might relate to sectors other than waste per se. These
might relate to, for example, the application of waste-derived organic matter on land,
or the generation of renewable energy from waste, and the related drivers might be
found in other sectoral strategies.
International Review of Waste Policy: Annexes

59.3 Looking Forward
In order to be aligned with the Waste Framework Directive (see Annex 1.0), and to
pre-empt 2014 revisions, a forward looking approach would (with regard to targets):
874
1. Develop Develop objectives objectives in in line line with with the the hierarchy hierarchy outlined in in in Article Article 4 4 of the WFD;
2. Include a specific programme for waste prevention prevention. prevention
A forward looking strategy
would pre-empt the decoupling objective foreseen by the WFD;
3. Put Put in in place place means means to to ensure ensure that that targets targets for for recycling recycling of of at at least least 50% 50% from
from
household household waste waste and and 70% 70% from from constructi construction constructi on and demolition waste waste are are met met in
the spirit of pre-empting the WFD objectives;
4. Ensure Ensure that that mechanisms mechanisms are are in in place place which which lead lead to to the the separate separate collection collection of
of
glass, glass, glass, metals, metals, metals, paper paper paper and and and plastic plastic plastic (where (where (where appropriate),
appropriate), appropriate), again pre-empting the
WFD requirements. This requirement relates to materials rather than specific
waste streams, and does not apply to household / municipal waste waste only only; only
5. Implement mplement mplement measures measures designed designed to to lead lead to to separate separate collection collection of of biowaste, biowaste, but but
this this this should should should be be be extended extended extended beyond beyond beyond the the the municipal municipal municipal waste waste waste str stream str stream
eam; eam
6. Implement policies policies or or mechanisms mechanisms that that encourage the use use of of products products of
biowaste biowaste management
management;
management
management
7. Include a vision vision which which might might include the concept of resource resource efficiency efficiency. efficiency
These would appear to be more or less essential components of policy for Ireland if it
is intended that this review should be relatively robust over time. Indeed, one might
argue that genuinely progressive policy would go some way beyond these measures
and targets since they may yet become the minimum requirements for policy which
seeks to defend itself from the need for constant updating.
The types of target which should set are likely to be:
� Reducing the quantity of household waste generated relative to an existing
trend;
� Reducing the quantity of other wastes generated against existing trends.
These targets should be set with a view to linking to output measures (in other
words, they should seek to embody some measure of the efficiency of
resource us – if they do not reflect output measures, then declining use can
simply reflect changing economic structures). If these targets cannot be set,
because of data limitations, then they should not be included at this juncture;
� Targets which promote recycling of household wastes;
� Targets for recycling of commercial and industrial wastes;
� Targets for recycling construction and demolition wastes;
� Targets related to the phasing out of landfilling of specific waste streams /
waste which has not been pre-treated. This component is already in
development through the EPA.
In the medium term, it may be appropriate for Ireland to set climate change-related
targets. Several countries already seek to measure climate change impacts, and
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ecent reports from PROGNOS, the EEA and Defra / Committee on Climate Change /
the Environment Agency, as well as the waste strategies of England and Wales,
indicate that interest in this area is growing. 1100 However, a key issue with target
setting in this area is that because some management methods, for example,
recycling, are assigned (in most studies) negative contributions to the climate change
indicator, the perverse consequence can arise that improvements relative to a
baseline are greater the greater is the quantity of waste in the waste stream. Hence,
absolute indicators are required, which seek reductions from a fixed level.
Key policy measures are likely to be:
875
1. The extension of producer responsibility to a wider range of materials;
2. Lifting targets for recycling under producer responsibility;
3. Strengthening of implementation of re-use measures in existing and future
producer responsibility schemes;
4. Minimum requirements for source separation schemes for:
a. Households;
b. Commerce and industry;
5. Minimum requirements, in terms of sorting, in the case of construction and
demolition waste;
6. The mandatory use – once collection schemes are of sufficient quality - of payby-use
for households and / or measures to encourage this (such as a residual
waste levy);
7. A pre-treatment requirement for landfilling to be phased in over time;
8. A ban on specific materials being landfilled or incinerated;
Other measures which might support the approach, but which, arguably, belong in
other sectors might include agri-environmental measures to encourage the use of
compost and digestate in agriculture (subject to specific standards being met). These
might mimic payments made in some Italian regions to farmers in lieu of the
improvement in the organic matter status of soils which this represents. 1101
1100 The USEPA encourages local authorities to use its WARM model to calculate greenhyouse gas
reduction benefits from recycling. See also, for example, G. Dehoust et al, Status Report on the Waste
Sector’s Contribution to Climate Protection and Possible Potentials, Federal Ministry for the
Environment, Nature Conservation and Nuclear Safety, August 2005; ERM (2006) Carbon Balances
and Energy Impacts of the Management of UK Wastes, Final Report for Defra, December 2006;
Eunomia (2009) Development of Marginal Abatement Cost Curves for the Waste Sector, Report for the
Committee on Climate Change, Defra and the Environment Agency; M. Skovgaard, N. Hedal and A.
Villanueva, F. Andersen and H. Larsen (2008) Municipal Waste Management and Greenhouse Gases,
ETC/RWM Working Paper 2008/1, January 2008; Prognos, with Infu and Ifeu (2008) Resource
Savings and CO2 Reduction Potential in Waste Management in Europe and the Possible Contribution
to the CO2 Reduction Target in 2020, Berlin: October 2008.
1101 See Enzo Favoino and Dominic Hogg (2008) The Potential Role of Compost in Reducing
Greenhouse Gases, Waste Management Research, 2008; pp. 26; 61.
International Review of Waste Policy: Annexes

59.4 Levels of Achievement – Household / Municipal Waste
The level at which targets might be set might be influenced by whether they are to be
made statutory or not:
876
1. Where targets are to be made statutory, what is deemed to be possible, with
the emphasis placed upon being suitably ambitious. As far as possible, the
target should be deemed likely to lead to beneficial outcomes;
2. Where targets are to be non statutory, or where they are not backed by
sanctions, there is reason to believe that they can be set at more ambitious
levels, seeking to push boundaries. It is possible that such targets might not
be met. The aim, however, should be to orient policies in order to meet such
targets.
Of course, the latter type of target risks being seen as ‘tokenism’, whilst the tendency
with any target tends to be – perhaps for political reasons – to ensure that they can
be met, sometimes, rather easily.
One jurisdiction which has not been afraid to establish challenging targets is the
Flemish region of Belgium. The Flemish Government’s household waste plan 1997-
2001 set the following objectives (using 1995 as a baseline – see Table 59-1):
• Waste reduction targets of 6 per cent by 2001 and of 10 per cent by 2006,
later revised to 13% by 2007 (measured relative to trend);
• Recycling rates of 52 per cent by 2001 and 55 per cent by 2006, rising to 70%
thereafter; and
• Each municipality was set the target of generating less than 150
kg/inhabitant/year of residual waste by 2006.
Earlier in the decade, eight of the 20 incinerators in existence in 1991 had been
closed despite bans on landfilling in place since 1998 (see below).
Table 59-1: Targets for Flemish Household Waste Management
Year Year Waste Waste prevention prevention prevention Waste Waste Waste recycling recycling +
+
composting
composting
29/09/09
Waste Waste incineration incineration +
+
landfill
landfill
1995 0 % 34 % 66 %
2001 6 % 52 % 48 %
2006 10 % 55 % 45 %
Source: OVAM
In support of the recycling objectives, minimum requirements were established in law
for waste collection by the municipalities in the Flemish region (by waste stream).
They were:
� Requirements to collect waste door-to-door, applicable for residual waste,
bulky waste, organic waste, paper and cardboard, packaging waste;
� Requirements for locating bottle banks and textile containers at a density of
1/1000 inhabitants or more (otherwise, the use of door-to-door collection);

877
� Separate collection at the containerpark, covering 20 - 40 different types of
waste; and
� Special collection systems for city centres, rural municipalities, tourist/coastal
areas.
For door to door collections, it should be added that minimum frequencies were
established.
In Flanders today, virtually all municipalities make use of pay-by-use systems. The
evolution of charges for sacks, and typical charges for schemes combining weight and
volume based schemes with a charge per pick up are shown in Table 59-2 and Table
59-3. Using these charges, the average costs of waste management for households in
Flanders have been calculated as € 225 per household (2.4 persons). This is
composed of;
1. € 30 paid through the producers responsibility
2. € 195 paid at municipality, broken down broadly as follows:
a. 1/3 taxes related to the amount of waste (variable cost)
b. 1/3 fixed household waste tax/household (fixed cost)
c. 1/3 general taxes related to household income
Table 59-2: Charges for 60l Sacks (€/sack)
Year Year Year 1996 1996 1998 1998 1998 2000 2000 2003 2003 2007 2007 Maximum
Maximum
Euro 0.44 0.60 0.66 1.14 1.25-1.50 2
Table 59-3: Charges Used in Flanders for 120l Bins
Charge Charge Base Base Base
Charge Charge Rate
Rate
Volume Based Charge €2.5/litre
Weight Based Charge €0.15-0.2/kg
Frequency Based Charge (per pick-up) €0.5-1/pickup
Charges are generally applied to the following items:
� per volume or weight, fully or only for big quantities
� organic waste (garden + kitchen)
� bulky waste
� wood
� demolition waste
� organic waste
� nappies
They are generally zero, or close to zero, for:
International Review of Waste Policy: Annexes

878
� textiles
� glass
� paper and cardboard
� old metals
� small dangerous wastes
� when producers responsibility
� Light packaging fraction (only €0.125 for cost of production and distribution of
the blue bag).
In Flanders, this approach has delivered considerable success. The residual waste
target has largely been met, whilst recycling rates are of the order 70%.
The Flemish approach is interesting. The targets for residual waste effectively
encourage both recycling and composting / digestion as well as waste prevention.
Recycling targets do not do this. Indeed, in some countries, recycling targets can be
met through collecting additional quantities of waste, notably garden waste, with
relatively limited impact on the quantity of residual waste generated. A residual waste
target is, in short, better aligned with the hierarchy that a straightforward recycling
target.
It could be argued that a waste prevention target and a waste recycling target, acting
together, could achieve similar, perhaps better, results. However, prevention targets
are not straightforward to set (especially where data is not of high quality), and
indeed, the targets might need to be differentiated across local authorities depending
upon current performance. Residual waste targets are, to some degree, fairer across
local authority types. Some inhabitants, residing in flats, generate less waste than
those in rural areas, especially in respect of garden waste. Where garden waste is
collected, authorities may collect more waste, but high recycling rates can be
achieved relatively straightforwardly.
It is important to stress that the question as to what levels of performance can be
achieved in future, and what that might imply for maximum levels of performance, is
not the same as the question ‘what level of performance can be achieve today?’ or
even, ‘what level of performance could be achieved today?’ It is a future-oriented
question, and one whose answer will be affected by policy, as well as by wider
developments in the nature of products, consumption and waste.
There is no fixed maximum rate for recycling and composting / digestion of waste
streams (for Ireland or anywhere else), and nor is there any clear understanding as to
what might be achieved in respect of constraining waste growth, or reducing waste.
The composition of waste streams, and the processes available for recycling them,
will change over time, and are, at the margin, amenable to being shifted by policy.
Technologies also change, allowing for new uses of materials collected separately
from the waste stream. A brief review of recent history would demonstrate that in
developed economies, where the challenges of recycling are arguably growing as the
waste stream becomes more complex, the highest recycling rates being achieved are
trending upwards over time, not down. Today, it is not uncommon for municipal waste
recycling rates of 70% to be achieved in some regions, though no Member State
29/09/09

achieves this rate country wide. Some regions where this rate is achieved do,
however, cover a larger population than Ireland.
At the same time, even before the economic crisis started to affect household
consumption, there appeared to be evidence of some ‘de-linking’ of waste from
economic growth. Countries where evidence of this was observed include England,
Belgium (Flanders), Germany, Denmark and probably others besides. As such, as
recycling rates have increase, and as waste growth has slowed, so the potential for
targeting a declining quantity of residual waste has suggested itself.
In Italy, the source separation of food waste has become a cornerstone for the
achievement of very high recycling rates in some areas. In the Consorzia Priula, a
consortium of municipalities near Treviso, the recycling rate for the area was 78% in
2007. The figures for each municipality are shown in Figure 59-1. Figures for those
municipalities included within the Consortium are shown in Figure 59-2, which shows
how quickly the residual waste quantities dropped once a quality source separation
scheme was put in place alongside pay-by-use charges. Indeed, residual waste
quantities fell to less than 100kg per inhabitant per year.
Figure 59-1: Recycling Rates in Priula, 2000 and 2007
Source: Consorzio Priula
879
International Review of Waste Policy: Annexes

Figure 59-2: Effects of Charging Scheme in Priula
Waste (kg/inh/yr)
880
500
450
400
350
300
250
200
150
100
50
0
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2000 2001 2002 2003 2004 2005 2006 2007
Source: Consorzio Priula
New Recycling
Scheme Charging Scheme
Introduced
Year
Recycling (kg/ing/yr)
Residual (kg/inh/yr)
Similar recycling rates can be observed in the area around Udine, in Italy, where food
waste collections were introduced in 2008. Recycling rates in the area were
averaging just under 80% in 2008 (see Figure 59-3). These examples are interesting
precisely because they are recent examples from a nation which has not been widely
viewed as a ‘high recycling nation’. They indicate that through novel adaptations of
existing ideas, notably the intensively targeted collection of food waste, very high
recycling rates can be achieved when such systems are implemented alongside pay
by use.
Rates can be similarly high in other countries. The County of Schweinfurt in Germany
achieves high recycling rates again through a combination of pay-by-use, and
collection systems which are convenient and of broad scope. Figure 59-4 shows how,
following the revision of the pay-by-use scheme in 1998/99, the recycling rate
increased significantly to 76%, with residual waste falling to 92 kg per inhabitant.

Figure 59-3: Recycling Rates Around Udine
Recycling Rate (%)
881
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
Buttrio
Camino al T.
Mortegliano
Nimis
Pavia di Udine
International Review of Waste Policy: Annexes
Pradamano
Reana del Rojale
Remanzacco
Sedegliano
Figure 59-4: Effects of Charging Scheme in Landkreis Schweinfurt
Tonnes of Waste Collected
70,000
60,000
50,000
40,000
30,000
20,000
10,000
0
Varmo
AVERAGE
1995 1996 1997 1998 1999 2000 2001 2002
Source: Hogg, D. (2006) Impact of Unit-based Waste Collection Charges
ENV/EPOC/WGWPR(2005)10/FINAL, Paris: OECD
Year
Recycling Rates
Achieved
Residual Waste
Separately Collected

Some general observations are as follows:
882
� The highest recycling rates for household waste achieved over an area of a
given size (in terms of household numbers) tends to decline as the number of
households covered increases (so in the best Italian regions, recycling rates
are moving towards 60%, whilst at the local level, they may exceed 70%,
though at the national level, rates are now around 50%). This is because
recycling rates are calculated as averages. The larger the number of
households covered, the lower the maximum rate for the area of that size
becomes. This is not necessarily due to ‘limits’. It may equally relate to the
(limited) extent of diffusion of high performance systems across a region;
� Even so, household recycling rates of 70% are achieved in regions with a
greater number of households than are present in the whole of Ireland. For
example, Flanders, a region of 6 million inhabitants in 308 municipalities
(grouped in 25 intermunicipal waste management associations) achieved a
rate for separate collection of 71% in 2005. 1102
� The rates of recycling of municipal waste for the leading EU Member States –
these are Austria, Germany, Belgium, Netherlands and Italy – are, according to
most recent data, recycling 64%, 62%, 60%, 50% and 60%, respectively, of
municipal waste according to preliminary figures produced from Eurostat data
for 2007. The figures for Austria, Germany and Belgium are country estimates,
with the figures for 2006 suggesting rates of 67%, 62% and 58%
respectively; 1103
� Recycling rates tend to be highest in rural and suburban areas. In this respect,
one could argue that Ireland ought to be capable of achieving higher, not
lower, rates of recycling, though in practice, much depends upon how the
matter is approached. In some rural regions of Austria, such as Upper Austria,
the collection of recyclables is not so heavily focused on collection from the
kerbside / doorstep, yet the recycling rate still reaches 70% (see Box 2). This
experience highlights how adapting the collection of materials to specific
circumstances can enable the achievement of high recycling rates in rural
areas in an efficient manner. Other regions of Austria achieve high recycling
rates in areas of relatively low population density.
This brief review is at least suggestive of what might be achieved in future. If recycling
rates of 70% or so are becoming more common locally, and if the trend is upwards, it
would seem to make sense to consider targeting those sorts of rates in a country
where the waste management system is ‘in development’ at some stage in the future.
Similarly, if Ireland is to constrain household waste generation, residual waste targets
should reflect such rates in the context of relatively static waste arisings.
1102 OVAM (u.d.) Activiteitenoverzicht 2006, Mechelen: OVAM.
1103 This data has been gathered
29/09/09

Box 2: Recycling Centres in Upper Austria
The company LAVU AG operates a system of bring collection centres across Upper
Austria. The Region is organised into 445 municipalities grouped into 18 provinces
which are responsible for waste management in their area. The Region covers 1.4
million inhabitants, living in 550,000 hhlds, across an area of 12,000 km 2.
In 1990, more than 60% of waste was sent to landfill. Now, 30% of waste is sent for
some form of disposal. This change has been based upon a system of bring banks
and the introduction of Waste Collection Centres (WCCs). 180 WCCs have been
erected to collect up to 70 different waste materials, which can be recycled at a later
date. These collection centers are public buildings, where residents are invited to
bring their waste and separate it in different boxes and containers. Specially trained
employees are present at all times to help and encourage this service.
In rural parts of the country each WCC services approximately 10,000 inhabitants; in
urban areas this increases up to 50,000 inhabitants per WCC. These WCC are also
used for collecting hazardous waste from households.
The WCCs feed their materials into one Central Logistics Centre. The vehicles sent
from the centre are compartmentalized and are specifically arranged so as to collect
all materials (in their relative proportions) from a given WCC. The centre genuinely
puts ‘reverse logistics’ into practice, dismantling WEEE items, making biofuels from
old vegetable oils, and recycling a bewildering range of different materials. 500 jobs
have been created by the system.
Preparing Vegetable Oil Containers Unloading a vehicle from the WCC
for Unloading
883
International Review of Waste Policy: Annexes

The introduction of this waste system has resulted in an extremely high quality of
collected material and guarantees that 90% of all waste collected at WCCs is
recycled. The overall performance of the waste management system is now such that
71% of all waste is collected for recycling and composting. Collection fees for residual
waste correlate roughly to population densities and are now between 80 and 220
EURO per year for 13 pick ups of a 120 litre bin.
884
29/09/09
Packaging for Recycling Other Dry Materials for Recycling
Separately Collected Biowaste Residual Waste
WEEE Disassembly at the Central Logistics Centre

Source: Eunomia (2007) Scoping new Municipal waste Targets for Wales, Report to
the WLGA, September 2007.
59.5 Levels of Achievement for Packaging Wastes
In reporting data on packaging recycling to the European Commission, Member
States indicate packaging recycling rates as shown in Figure 59-5 to Figure 59-9, we
show European recycling rates for packaging materials made from wood, glass, paper
& board, metal and plastic, respectively.
Ireland has the highest reported recycling rate for wood packaging at nearly 100%.
Sweden, Denmark, Belgium and Luxembourg are all recovering very high percentages
of glass, whilst Germany and Austria are not very far behind. The suggestion is that
capture rates in excess of 90% for glass packaging should be achievable.
Paper and board packaging has the highest overall recycling rate across Europe as
shown in Figure 59-7. The packaging element of the paper and board stream may or
may not be the best captured fraction. It might be supposed, however, that nonpackaging
paper (such as newsprint and graphic papers from offices and households)
might be rather easier to capture at high rates than the packaging paper and card.
The suggestion is that as with glass, paper and card could be captured at very high
rates, in excess of 90%.
Figure 59-5: Recycling Rates Achieved by Member States for Wood Packaging, 2006
Figures
Recycling Recycling Rate Rate (%)
(%)
885
80
70
60
50
40
30
20
10
0
A
BE
BU
CY
International Review of Waste Policy: Annexes
CZ
Source: EUROSTAT
DK
EST
FI
F
GER
GR
H
IRE
IT
LIT
LUX
M
NO
POL
P
ROM
SLA
SLO
SP
SWE
UK
Wood

Figure 59-6: Recycling Rates Achieved by Member States for Glass Packaging, 2006
Figures
Recycling Recycling Rate Rate (%)
(%)
886
120
100
80
60
40
20
0
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A
BE
BU
CY
CZ
Source: EUROSTAT
DK
EST
FI
F
GER
GR
H
IRE
Figure 59-7: Recycling Rates Achieved by Member States for Paper and Board
Packaging, 2006 Figures
Recycling Recycling Rate Rate (%)
(%)
100
90
80
70
60
50
40
30
20
10
0
A
BE
BU
CY
Source: EUROSTAT
CZ
DK
EST
FI
F
GER
GR
H
IRE
IT
IT
LIT
LIT
LUX
LUX
M
M
NO
NO
POL
POL
P
P
ROM
ROM
SLA
SLA
SLO
SLO
SP
SP
SWE
SWE
UK
UK
Glass
Paper & Board

Figure 59-8: Recycling Rates Achieved by Member States for Metal Packaging, 2006
Figures
Recycling Recycling Rate Rate (%)
(%)
887
100
90
80
70
60
50
40
30
20
10
0
A
BE
BU
CY
Source: EUROSTAT
International Review of Waste Policy: Annexes
CZ
DK
EST
FI
F
GER
GR
H
IRE
IT
Figure 59-9: Recycling Rates Achieved by Member States for Plastic Packaging, 2006
Figures
Recycling Recycling Rate Rate (%)
(%)
50
45
40
35
30
25
20
15
10
5
0
A
BE
BU
CY
CZ
Source: EUROSTAT
DK
EST
FI
F
GER
GR
H
IRE
IT
LIT
LIT
LUX
LUX
M
M
NO
NO
POL
POL
P
P
ROM
ROM
SLA
SLA
SLO
SLO
SP
SP
SWE
SWE
UK
UK
Metals
Plastic

Where metals are concerned, there is clearly room for improvement, but few Member
States achieve, for metals, the sorts of recycling rate which they achieve for paper
and board, or glass. This is somewhat surprising given a) the value of the material,
and b) the ease with which it can be collected and sorted. Metal packaging materials
might not be captured so well as larger, bulkier metal fractions, but at the same time,
the relative quantities of metals in bulky items, and metal packaging within the Irish
municipal stream may be relatively even. The data suggest that a capture rate of 80
to 85% would be a challenging target.
Where plastics are concerned, few Member States report a very high recycling rate.
This is a consequence of the fact that whilst bottles might be well recycled, other
materials, notably films, are not so well recycled. Indeed, some Member States take
the view that non-bottle plastics are simply too expensive to target for recycling (a
perspective which is assisted by the low targets for plastic packaging recycling under
the Packaging Directive). Also, in some Green Dot schemes, only packaging marked
with the Green Dot is actually collected through the collections set up through the
system. Although the raw material has considerable value, plastics are more
expensive to collect and can be costly to sort. This will be the most challenging
material for which to achieve high recycling rates, particularly as one expands the
range of materials beyond bottles.
59.6 Levels of Achievement for Municipal Biowastes
Where biowaste is concerned, the information on captures is less clear. However,
there is considerable evidence to support the view that where garden waste is
collected, the capture of garden waste tends to be extremely high. Flanders reports a
capture rate of 94% for garden waste. 1104 In 1999, the Danish EPA reported that: ‘97
per cent of garden waste was recycled in 1997... almost all garden waste is recycled
today’. 1105 Note that the Danes also set a target for a maximum of 15% of garden
waste to be incinerated in their 1993-7 Plan (which was clearly met). One of the
reasons for high captures is that garden waste tends to draw additional waste into
the waste stream. Consequently, the numerator and denominator, in calculating the
recycling rate of the garden waste fraction, are similar, giving rise to high capture rate
figures.
Table 59-4 shows some countries with high performance in respect of biowaste
collection. Most countries that have high capture rates for biowaste collect garden
and kitchen waste together in their waste collections. This suggests that typically,
captures of food waste achieved nationally are lower than those for garden waste.
The approaches now being adopted in parts of Italy and Catalunya in Spain, however,
target kitchen waste fractions in an attempt to optimise the collection system in terms
of cost. Although these systems do not achieve the same level of biowaste capture (in
1104 OVAM (2007) Evaluatierapportage 2006: Uitvoeringsplan Huishoudelijke Afvalstoffen 2003-2007,
Mechelen: OVAM.
1105 Danish EPA (1999) Environmental Review from the Danish EPA, No.1 1999, Copenhagen: Danish
EPA.
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absolute terms, i.e. in terms of weight per household), they prevent the ‘over-delivery’
of garden waste into the waste stream when such material can be readily composted
at home. Furthermore, they capture kitchen waste more accurately so the proportion
of biowaste in the residual waste fraction tends to be lower.
Table 59-4: Amount of Separately Collected and Composted Bio- and Green Waste in
the EU
Country Country Country Total Total Total MSW MSW MSW
Organic Organic Organic MSW MSW
MSW
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excl excl excl home home
home
composting
composting
International Review of Waste Policy: Annexes
incl incl incl home home
home
composting omposting
omposting 1
Separately
Separately
collected
collected
TOTAL
TOTAL
Separately Separately
Separately
collected collected
collected
as% as% total
total
Separately Separately
Separately
collected
collected
and and and home home
home
composted composted
composted
as% as% total
total
(inc (inc (inc home home
home
comp) comp)
comp)
Austria 2,800,000 800,000 1,570,000 600,000 75.00% 87.26%
Flanders 3,126,044 1,158,795 1,264,795 723,795 62.46% 65.61%
Denmark 2,780,000 973,000 652,000 67.01%
Germany 49,100,000 9,000,000 7,000,000 77.78%
Netherlands 8,220,000 3,452,400 1,790,000 51.85%
Sources: Amlinger, F. (2000) ‘Composting in Europe: where do we go?’ Paper for the
International Forum on Recycling, Madrid, 14 November 2000; Barth, J. (2000)
‘Composting, quality assurance and compost utilisation - sustainable solutions in the
European countries’, unpublished mimeograph; Hogg, D. et al. (2002) Economic
Analysis of Options for Dealing with Biodegradable Municipal Waste, Final Report to
the European Commission.
1 In most of the European countries no statistical data about home-composting is
available, so an estimation about full extent of the potential of organic waste is very
difficult.
As an example of the differentials between captures of food waste and captures of
garden waste, OVAM estimated that in 2005, capture rates for garden waste 94%,
but captures for ‘GFT’ (non-meat kitchen waste) were 53%. It would seem reasonable
to aim for very high captures of garden waste in Ireland. Ireland could achieve high
captures of kitchen waste if the collection systems are well-designed. Captures of the
order 60% would appear to be possible.
59.7 Levels of Achievement for Non-household Wastes
It is less common to find targets set for ‘commercial waste’ or ‘industrial waste’. Brief
reflection suggests that this may be because the targets could not be made to
meaningfully ‘stick’ on any specific addressee. The approach to improving
performance in these areas focuses upon the use of one or more of the following:
• Producer responsibility measures;

890
• Mandates for the collection of specific waste fractions / streams;
• Targets for pre-treatment facilities; and
• Taxes and restrictions / bans on landfilling.
In the commercial and industrial waste areas, the key differences are that for many
industries, there is a strong link between the level of waste, and the company’s
financial performance. As such, there is a strong motivation for waste prevention in
many sectors. In addition, for many sectors, waste may be generated in relatively
large and homogeneous quantities. The question regarding management is less one
to do with which collection system to employ, and more one of the best destination for
the collected material. For commercial enterprises, the nature of collection systems
are more important, whilst the link between waste prevention and bottom line
performance is weaker, though certainly not absent.
Generally, as a consequence of these considerations, the potential for high levels of
‘landfill diversion’ (not necessarily ‘recycling’, as wastes might not always be suitable
for recycling) in the industrial sector is significant. In the commercial sector, the
potential to achieve high recycling rates ought to be greater than in the household
sector, though somewhat similar owing to the nature of the wastes.
OVAM’s activity report suggests that of industrial waste in Flanders, a significant
proportion of waste (63%) is sent initially to conditioning plants, with 16% recycled
directly and 13% used as secondary materials. Ultimately, some 13% is incinerated
and 12% landfilled, with the remainder effectively recycled, or treated in some
alternative manner.
In Germany, the “Commercial Wastes Ordinance, 2002” came into force on 1 st
January 2003, and provide a minimum separation requirement for pre-treatment
facilities receiving both municipal and commercial wastes, including specific
construction and demolition wastes. To facilitate high levels of recovery, Section 8,
Paragraph 1 of the Ordinance specifies a number of wastes which should be held,
stored, collected and hauled for recovery, separately. These wastes are: paper and
card, glass, plastic, metals and biowaste. The recovery quota is a minimum of 85% by
weight over a calendar year, and applies to the wide range of waste streams
mentioned in the Annex.
59.8 Levels of Achievement for Construction and Demolition
Wastes
Many countries report high rates of recycling for construction and demolition wastes.
Statistical data tends, however, to be of a less good quality than for, for example,
household waste, and many countries make provision for differing ranges of recovery
activity.
In the Netherlands, the general policy and framework for waste management is laid
down in the Landelijk Afvalbeheerplan (National Waste Management Plan). This
describes the general rules for all aspect of waste management, from collection to
final disposal, specifying the minimum treatment requirements for each waste
stream. For example, it specifies that, as a minimum, inert C&D waste must be
treated to achieve material recycling. The “Regeling niet-herbruikbaar en niet-
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verbrandbaar bouw- en sloopafval” (Regulation on non-recyclable and noncombustible
C&D waste) prescribes that recyclable and combustible C&D waste
cannot be landfilled. C&D waste is defined as non-recyclable and non-combustible if
the >60 mm fraction contains more than 85% of the following materials:
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• Contaminated stony material
• EPS insulated concrete
• Thermal/acoustic insulation material based on minerals
• Tar and bitumen roof material
• Soft stony material
• Preserved wood based on “Wolman salts” (Cu, Cr, As)
• Glass
• Non-separable combinations made of at least 50% of the above materials
For demolition the “Asbestbesluit” (Asbestos Regulations) require the separate
removal and collection of asbestos. The “Regeling scheiden en gescheiden houden”
(Waste Separation and Storage Regulations) require the separation at source of
hazardous waste.
In the Netherlands, recyclable/reusable wastes from construction and demolition
have been banned from landfill since 1997. These wastes include masonry &
concrete rubble, metals, untreated wood, paper and cardboard etc. Currently, about
95% of all C&D waste is recovered.
In Germany unsorted construction and demolition wastes have been banned from
landfill sites since 2001. The Closed Substance Cycle and Waste Management Act
was an overarching legislative development in waste management in Germany,
coming into force in September 1996. Its aim was to make producers and
consumers radically rethink approaches to waste: “integrating product responsibility
through economic decision-making process, with the aim of building a life cycle
economy that avoids waste generation”. Developing from this, and in response to
pressures to improve recycling and recovery performance, a number of other
regulations have come into force, two of which are focused on here:
• Commercial Wastes Ordinance 2002
• Waste Wood Ordinance 2002
Commercial Wastes Ordinance 2002
The German Regulations, the “Commercial Wastes Ordinance, 2002” came into force
on 1 st January 2003, and provide a minimum separation requirement for pretreatment
facilities receiving both municipal and commercial wastes, including
specific construction and demolition wastes. To facilitate high levels of recovery,
Section 8, Paragraph 1 of the Ordinance specifies a number of wastes which should
be held, stored, collected and hauled for recovery, separately. These wastes are: (i)
glass, (ii) plastic, (iii) metals, (v) concrete, bricks, ceramics (or a mixture of these).
The Ordinance provides a derogation from this separation, on the basis that these
waste streams can only be mixed with those set in the Annex to the Ordinance, and
that the initial quantity and purity of the these five categories of input waste streams
are produced as separated streams for substance, or energy recovery (unless it can
be demonstrated that there is a technical reason why this is not possible).
International Review of Waste Policy: Annexes

The recovery quota is a minimum of 85% by weight over a calendar year, and applies
to the wide range of waste streams mentioned in the Annex (not containing, or
contaminated by dangerous substances).
According to the Ordinance, waste streams at pretreatment facilities should be
separated to meet the 85% minimum recovery target (quota). A pretreatment facilty
can be defined as such if the wastes in question undergo pre-treatment prior to
substance or energy recovery. Examples of pretreatment processes given are sorting,
crushing, compacting, or pelletizing. Though not stated in the Ordinance, for
illustration, an example of substance recovery would be the use of
separated/pelletised plastics used in a plastic moulding process.
Waste Wood Ordinance
In March 2003, the Waste Wood Ordinance came into force. The legal framework of
the Ordinance divides waste wood into four categories, according to pollutant type.
Certain energy recovery or material recycling processes are only admissible for
individual or multiple waste wood categories. Recovery or recycling applies to all
categories except contaminated wood, which must be thermally treated (incinerated).
In addition, the dumping of waste wood on landfill sites is prohibited.
In Austria, the 1993 “Ordinance on the Separation of Materials Generated during
Construction” requires that groups of materials (mineral construction waste,
excavated soil, concrete waste, broken asphalt, wood, metal and plastic waste, as
well as construction site waste) must be separated if they exceed certain threshold
levels. Since this Ordinance entered into force, the recycling has been increased from
the original level of 15 per cent (1985) to more than 70 per cent today.
59.9 Residual Waste Targets
The Flemish-speaking region of Flanders has a population of 6 million living in 2.4
million households. It is divided into five provinces and subdivided into 308
municipalities. In its municipal waste management plan 1997-2001, OVAM, the
public waste agency of Flanders, set the following targets for the generation of
residual waste:
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� 1998: 225 kg per person
� 2001: 220 kg per person
� 2006: 200 kg per person
� 2010: 150kg per person
Success in meeting and exceeding these targets during the plan period led to the
targets being revised and further tightened in the 2003-2007 waste management
plan. The revised targets are:
� 2003: 180 kg per person
� 2005: 165 kg per person
� 2007: 150 kg per person
Figure 59-10 below shows the residual waste per capita against targets from 1991 to
2002 with the targets from 1998 to 2007.
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Figure 59-10: Flanders Residual Waste Reduction Targets and Actual Quantities
Source: David Davies Associates (2003) High Diversion of Municipal Waste: Is It Achievable? Resource
Recovery Forum
More recent data obtained suggests that residual waste per capita dropped to 159 kg
per person by 2004, a figure below the 2005 target level (see Figure 59-11). 161 of
the 308 municipalities were below the 150 kg per person level (the 2007 target) in
2004. 1106
In calculating the targets, residual waste is defined as not recycling/composting. The
quantities included in the residual figure includes waste that is incinerated. The total
quantities of landfilled waste have fallen substantially over the period from 1.13
million tonnes (43% of waste arisings) in 1993 to 147,000 tonnes (4% of waste
arisings) in 2002. While quantities of waste incinerated have remained relatively
constant (821,000 tonnes [31%] in 1993 compared to 868,000 tonnes [26%] in
2002. 1107
1106 Julie Hill, Hannah Hislop, Charlotte Steel and Ben Shaw (2006) An International Survey of Zero
Waste Initiatives, Green Alliance.
1107 David Davies Associates (2003) High Diversion of Municipal Waste: Is It Achievable? Resource
Recovery Forum.
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International Review of Waste Policy: Annexes

Figure 59-11: Evolution in Quantities of Household Waste, Residual Waste, and
Separately Collected Waste (kg per inhabitant)
Source: Danny Willle (2006) The Polluter Pays: Key to Successful Household Waste Policy,
Presentation to ACR+ Conference, Dublin Castle, 19th May 2006.
In terms of waste prevention the question is: to what degree has the per capita
residual waste target reduced arisings versus simply stimulating greater recovery
from the waste stream? The data suggests that the reduction in residual waste per
capita has come substantially from an increase in recycling. This is shown in Figure
59-11 above.
Waste Arisings grew by an average of 2.9% per annum over the period 1991 – 2002.
However, in the period since 1998, when the first target was introduced, the growth in
arisings has slowed considerably. In the 1998-2004 period, the line of best fit
suggests an average growth rate of 0.42%, though the correlation of this fit is poor. In
the period 2000-2004, the line of best fit actually suggests a decrease of 0.44% per
annum, though again, the correlation is poor, and inspection by eye suggests zero net
growth over the period.
While the measures taken by OVAM have clearly not reduced overall arisings in
absolute terms, the question can be asked as to whether the rate of growth might
have been different in a counterfactual scenario. This is difficult to say, but if the
trend from 1991-2002 had continued from 1998, the arisings per inhabitant would
have been 628kg per inhabitant by 2004. The policy could, under this assumption,
have been responsible for a 10.8% reduction in overall waste quantities over the 6
year period.
Even here, however, the matter is not so clear. Generally, the pre-1998 evolution
shows that prior to this date, overall waste arisings were increasing as recycling rates
improved. This may well have been due to the roll out of biowaste collections to
households, generating ‘above background’ growth rates. Notwithstanding this fact,
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there does appear to have been a slowing in the rate of growth, though of course, one
could not, unequivocally, attribute this change to this policy alone. 1108
It is worth stating that the setting of residual waste targets alone cannot be held to be
responsible for the reduction in residual waste that has been observed in Flanders.
The targets form part of an integrated package of initiatives which include:
895
� implementing awareness and information campaigns (possibly with specific
target groups in mind, such as schools);
� drafting municipal environmental covenants or cooperation agreements
between local authorities and the Flemish region;
� financial aid for initiatives pertaining to waste prevention and reuse, and
developing a collection and processing infrastructure for the separated
collection of municipal waste;
� imposing environmental taxes on the incineration and landfilling of waste;
� consultation on policy relating to appropriate environmental permits;
� systematically and consistently applying the ‘the polluter pays’ principle;
� implementing acceptance and take-back obligations, based on the principle of
producer responsibility;
� implementing and applying landfilling and incineration bans;
� monitoring and enforcing the observance of rules and regulations. 1109
Although a wide range of initiatives has been employed, the importance of setting a
target should not be underestimated. The target provided a clear focus for action,
and the need or desire to meet the target was integral to the successful
implementation of the above initiatives. OVAM also enforced the target through the
application of upper target limits which no single municipality was allowed to exceed.
These were 220kg/per inhabitant in 2003 and 200kg/per inhabitant in 2005. In
addition local authorities are encouraged to reduce residual waste through signing
voluntary ‘Environmental agreements or covenants’. These link the results obtained
to the provision of financial support which is financed through taxes on the landfilling
and incineration of waste. 1110
1108 Parent et al (2004) attribute some of the decrease in waste growth to an increase in reuse centres
and a decrease in the total quantity of packaging, due mainly to lightweighting of packaging design
(see Frank Parent, Luc Vanacker, Anne Vandeputte, Danny Wille (2004) Municipal Waste Management
in Flanders - Experiences and Challenges, Public Waste Agency of Flanders, April 2004).
1109 Frank Parent, Luc Vanacker, Anne Vandeputte, Danny Wille (2004) Municipal Waste Management
in Flanders - Experiences and Challenges, Public Waste Agency of Flanders, April 2004.
1110 Frank Parent, Luc Vanacker, Anne Vandeputte, Danny Wille (2004) Municipal Waste Management
in Flanders - Experiences and Challenges, Public Waste Agency of Flanders, April 2004.
International Review of Waste Policy: Annexes

59.9.1 Residual Waste Levy
In Wallonia (Belgium), the regional Government introduced a novel instrument in
which the local authorities were subjected to a residual waste levy. In essence, the
levy specified a quantity of residual waste per inhabitant which could be generated
free of any levy. For those authorities whose generation of residual waste exceeded
this ‘quota’, a levy on the excess was applied. The quota was reduced over time to
encourage local authorities to reduce the residual waste generated.
In Wallonia, this had the effect, amongst other things, of encouraging widespread
dissemination of pay-by-use charging. The development in the uptake of charging
schemes is shown clearly in Figure 59-12 below.
Residual waste levies applied only to waste quantities exceeding a specified target
level imply that where waste quantities fall below this level, there is no further
motivation for residual waste reduction.
In principle, a residual waste levy could be used to create incentives for local
authorities to both:
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a) not exceed a set annual waste per household target; and
b) reduce annual waste per household arisings as much as possible below this
target.
It is suggested here that there are two ways of doing this:
a) By setting a pre-determined target and charging local authorities who exceed
the target level and refunding the revenue to those who fall below it. By using
this approach of ‘rebating revenue’, those doing better are rewarded with the
penalty revenue gained from those doing worse; or
b) By setting the level against which rebates are paid at the average level of
performance of the authorities. Those above would be charged a predetermined
levy, with the overall revenue refunded to those who are below the
average level in proportion to how far below they are.
59.9.1.1 Pre-determined Target
The first approach sets targets to continuously improve. Critical to the success of the
levy would be setting the fines/rebates at a level that would provide sufficient
incentive for authorities to take action without being unduly punitive for authorities
that fail to reach the target levels.
On the other hand, since the levy is fiscally neutral, with rebates equalling fines, then
it seems possible that the marginal incentive could be slightly higher than in cases
where no such rebating system was in place. Although the level of any levy would
have to be announced in advance, it seems possible that it (and possibly the targets
themselves) could be periodically reviewed so as to give greater or weaker incentives,
as appropriate, to ensure targets were met without generating unduly large costs or
benefits to specific authorities.

Figure 59-12: Residual Waste per Inhabitant Related to Charge Scheme
Note: OMB (kg/hab.an) = Residual Waste per Inhabitant per Year
59.9.1.2 Levy Based on Average Residual Quantities
The second approach generates a relatively unpredictable target, but it has the merit
of avoiding the setting of targets which prove to be impossible to achieve (under
existing frameworks). Authorities would have an incentive always to be operating with
above average performance (lower quantities of residual waste than others) so as to
avoid charges and receive refunds. This ought to imply that the average residual
waste per household trends continuously downwards.
In a slightly dystopian outcome, this approach may promote cross-authority
cooperation to maintain relatively conservative and constant quantities of residual
waste arisings, but even here, there would be a considerable incentive to cheat, or to
stay out of such a collusive arrangement.
The target is set as the annual average quantity of residual waste per household and
establishes accountability for every authority because evidently the average is, by
definition, attainable. More interesting variants could apply levies on the excess
which increase as the magnitude of the excess changes.
59.9.2 Scenario Examples
In Table 59-5, we show how such a levy might function in the case where there are 4
authorities, two whose arisings exceed the target level (expressed in terms of kg per
inhabitant per annum – the figures are indicative only) and two who have residual
waste quantities below the target level.
897
International Review of Waste Policy: Annexes
Red= No scheme
Yellow = Volume-based
Grey = Weight-based
Development of Charging Scheme Types

Table 59-5: Residual Waste Levy, Pre-set Target @ 300kg/inh
Residual waste
per inhabitant
300kg
Assume that:
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Authority A
Authority B
Excess of
100kg/inh
Authority C
• Authority A has 75,000 households;
• Authority B has 50,000 households;
• Authority C has 60,000 households; and
• Authority D has 100,000 households.
Excess of
60kg/inh
Authority D
Assume also that the levy is set at €30 per tonne. Then:
Below target by
75kg/inh
Below target by
100kg/inh
• Authority A has a total excess of residual waste = 75,000 x 100kg = 7,500
tonnes. It pays 7,500 * €30 = €225,000
• Authority B has a total excess of residual waste = 50,000 x 60kg = 3,000
tonnes. It pays 3,000 x €30 = €90,000.
This gives a total of levy revenue of €315,000. Those that do better than target would
receive this revenue (net of administrative costs, here assumed to be zero for the
sake of simplicity). Hence
• Authority C has a total ‘deficit’ of residual waste = 60,000 x 75kg = 4,500
tonnes;
• Authority D has a total ‘deficit’ of residual waste = 100,000 x 100kg = 7,500
tonnes;

899
• The total ‘better than target’ performance amounts to 12,000 tonnes of which
Authority C is responsible for (4,500/12,000) = 37.5%, and Authority D is
responsible for (7,500/12,000) = 62.5%;
• Consequently:
o Authority C receives 37.5% x €315,000 = €118,125; and
o Authority D receives 62.5% x €315,000 = €196,875
In the round, the approach is revenue neutral. It implies transfers from authorities
which do well to authorities which do less well.
In the case where the average is used as the target, then from the same figure:
• Authority A produces 400kg/inh;
• Authority B produces 360kg/inh;
• Authority C produces 225kg/inh; and
• Authority D produces 200kg/inh.
Then the weighted average is 285.96 kg/inh. It can be seen that the same calculation
in terms of levies and rebates would generate similar results, but in this case, the
quantum of revenue would be greater (the excesses are larger), so the rebates would
be greater also.
What would clearly be different in the two examples is how the impact of the levy
would change over time. Where the target is pre-determined, then care would be
needed to ensure that the targets were achievable. If they are too challenging, then
the consequence might be that authorities simply pay the levy and there is no
recipient of the rebate. This could also be the outcome if the levy is set too low (so
that the cost of taking action exceeds that of doing nothing).
59.10 Summary
There appears to be plenty of scope for revising key targets upwards in Ireland. In
respect of waste prevention, we would caution against setting these in Ireland at
present, not least because there remain problems with past data sets. In particular:
• it appears that the boundary between household and non-household waste is
not so sharply distinguished. This means that the underlying trends in the one
and the other are not so straightforward to discern;
• the quantities of household waste generated are distorted by factors such as
the number of households not currently having their waste collected and the
likely prevalence of backyard burning; and
• the fact that in respect of construction and demolition waste, the data are
generally of poor quality.
That does not mean that such targets should not be set in future.
A possible way of integrating a recycling target alongside a driver for waste prevention
is a target on ‘residual’ quantities. We have noted above that this type of target is
well-suited to the household waste area because it gives equal status to waste
International Review of Waste Policy: Annexes

prevention and waste recycling, whilst waste recycling targets tend to underplay, and
sometimes even undermine, waste prevention (especially where garden waste
collections are offered free of charge). We recommend this for Ireland.
We did consider that a residual waste target might be appropriate for packaging. We
looked at Irish performance in this regard in Annex 12.0, and noted that it appeared
to be comparatively poor, but also that the data might not be reliable. The data is the
main reason for not pursuing this target. It should be noted that under such a target,
‘self-compliance’ is not possible. All that all producers (major and otherwise) can do is
contribute to the meeting of this target as part of a collective. This might, in some
respects, make enforcement somewhat more straightforward, especially in the Irish
case where only one compliance scheme exists.
As regards recycling targets, these are proposed in the Main Report.
As regards targets on reducing waste sent to landfill, the EPA’s pre-treatment
requirements should ensure that in due course, no waste which has not undergone
pre-treatment is landfilled.
The potential impact of these targets, at least in respect of municipal waste, is
discussed below in Annex 63.0.
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GRANT FUNDING
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International Review of Waste Policy: Annexes

60.0 Grant Funding
60.1 Introduction
The public sector is the main source of the grant funding, offering financial assistance
to organisations across the public and private sectors. The public sector sources the
funds both from general taxation, and from specific ring-fenced pots of money,
derived from particular taxes associated with potential environmentally detrimental
activities, e.g. landfilling. The funds are then used to finance projects which offset
these detrimental activities, or support environmental policy goals.
The OECD suggests:
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‘The golden rule of public funding suggests that governments should support
only those investments that are economically efficient but not financially
viable’. 1111
By following the OECD’s advice, grants should fund projects which can prove that their
reliance upon the funding is not long-term, and that they have the capacity to function
sustainably, i.e. without the grant support, in the future. This generally makes it
important to ensure that the applications for funding demonstrate an ability to stand
on their own feet once grant support falls away. In some cases, revenues may be
used to support specific activities on an ongoing basis, but in these cases, it is not
clear what purpose the ear-marking purpose serves. If there are areas of activity
which require ongoing support, presumably in the public sector, then it becomes
unclear why the activity should not be supported through general taxation rather than
ear-marking per se, though clearly, it can be argued that the two are equivalent.
Having looked at the Irish case (Section 60.2), this report seeks to identify current
international examples of grant funding (Section 60.4 to Section 60.12). Following
this, the Irish case will be examined and recommendations will be made.
60.2 Grant Funding in Ireland
60.2.1 National Development Plan
In Ireland the co-ordinating structure for the planning of government over a
programme period is the National Development Plan (NDP). Historically, over past
programme periods for the NDP, a significant feature of the NDP was the co-funding
of some programmes and measures with income from the Irish exchequer along with
EU funding. This has significantly reduced in the latest NDP period (2007-2013), in
which an expected €3 billion from the EU Structural Funds was planned for within the
€184 million expenditure planned for priority investment in the period.
1111 OECD (2007) Handbook for Appraisal of Environmental Projects Financed from Public Funds,
report to OECD by the Task Force for the Implementation of the Environmental Action Programme,
Available: http://www.oecd.org/dataoecd/10/63/38786197.pdf

NDP 2000-2006
Waste management & waste infrastructure development planning have been
included within the NDP in regional programmes in the past, to facilitate funding of
waste management activities at regional & local levels. The National Development
Plan website outlines the mechanism through which the allocation of funds was
administered, in particular where receipt of funding is negotiated and agreed with the
EU; 1112
903
“To draw down E.U. Structural Funds, each Member State has to draw up and
submit a plan setting out its investment priorities for the funding period….in
Ireland’s case, the National Development Plan (NDP)…. (the subsequent) …
agreement resulted in a Community Support Framework (CSF.)…”
The NDP and the CSF form the basis of the implementation of the agreement for EU
funding.
Within the previous NDP (2000-2006), there were two regional assemblies which
were the administrative bodies within which funding was administered through
regional programmes; the Border, Midland & Western (BMW) assembly and the
Southern & Eastern (S & E) assembly. The regionalisation arrangements negotiated
by Ireland in the context of the Agenda 2000 Agreement resulted in the designation
of two regions in Ireland for Structural Funds Purposes:
� The Southern and Eastern Region (S&E Region) which will qualify for a six year
phasing out regime for Objective 1 Structural Funds up to the end of 2005,
and
� The Border, Midland and Western Region (BMW Region) which has retained
Objective 1 status for Structural Funds for the full period to 2006.
Following this designation, two new Regional Assemblies where established and came
into effect on the 21st July 1999 under the Local Government Act, 1991 (Regional
Authorities) (Establishment) Order, 1999. The Assemblies are comprised of
nominated elected representatives of the regional authorities within their Region. The
principal functions of the Regional Assemblies are:
� To promote the co-ordination of public services in the Southern and Eastern
Region
� To manage the Southern and Eastern Regional Operational Programme under
the National Development Plan (2000-2006)
� Monitor and make proposals in relation to the general impact of their regions
of all E.U. Programmes of assistance under the Community Support
Framework
1112 National Development Plan (2009) National Development Plan Website, Available:
http://www.ndp.ie/viewdoc.asp?fn=/documents/eu_structural_funds/overview/structural_funds.htm
&mn=euso&nID=3
International Review of Waste Policy: Annexes

904
� Make public bodies aware of the regional implications of their policies, plans
and activities
The BMW and S & E assemblies operated four sub-programmes in 2000-2006 of
which one was local infrastructure. This was divided into seven measures of which
one was waste management. The following came under the remit of waste
management:
� Waste recovery infrastructure for municipal waste, to be developed in
accordance with regional and local Waste Management Plans;
� Hazardous waste landfill capacity, to be provided in accordance with the
National Hazardous Waste Management Plan. 1113
In the 2000-2006 period, the funding available for these activities was €370.49
million in the BMW region and €621.18 million in the S & E region. This is an
extremely significant sum.
NDP 2007-2013
Within the 2007-2013 programme period for the NDP, € 5.8 billion will be in the
Environmental Services area, of which € 753 million will be within the Waste
Management Sub Programme of the NDP’s Economic Infrastructure Priority. In the
Irish context, this is a significant sum of money. The NDP indicates that the funds are
expected to ‘address the problems associated with legacy landfills; support, through
private investment, the development of thermal treatment plants to reduce landfill
usage, and promote greater use of recycling and recovery.’
Although some €3 billion is expected to come from EU funds in the latest NDP period,
the S&E Region’s Operational Programme makes no reference to waste management
within its Programme whilst the BMW Region’s Operational Programme is concerned
with waste only in terms of assisting in the protection of groundwaste (through
managing slurries).
60.2.2 Waste Management Infrastructure Capital Grant Scheme
In March 2002, within the context of the waste programme/ statement document,
“Preventing and Recycling Waste: Delivering Change”, a €127m capital grant scheme
was launched by Mr. Noel Dempsey, T.D., Minister for the Environment and Local
Government under the National Development Plan. The scheme, ‘The Waste
Management Infrastructure Capital Grants Scheme’ was launched as part of the
National Development Plan 2000-2006. The scheme was co-funded by the Irish
Exchequer and by the EU from the European Regional Development Fund. Local
1113 National Development Plan (2009) National Development Plan Website, Available:
http://www.ndp.ie/viewdoc.asp?fn=/documents/eu_structural_funds/overview/structural_funds.htm
&mn=euso&nID=3
29/09/09

authority projects approved for assistance under the Scheme were grant aided at the
rate of up to 75% of eligible costs. 1114
The National Development Plan website highlights some examples of development
funded under the ‘Waste Management Infrastructure Capital Grants Scheme’. 1115
� Sandy Sandy Road, Road, Galway Galway –Materials Materials Recovery Recovery Facility Facility Facility development development (Galway (Galway County ounty
Council Council) Council Council)
)
905
This facility recovers dry recyclable materials, such as cardboard, paper, plastic,
tetra pak and food and beverage cans which are collected from over 18,000
households in Galway City through the source separated collection system.
Additional facilities are also provided for the reception of bulky household waste
items, with a view to waste recovery and onward transfer to recycling companies.
The approved costs are €1,308,620 with €981,465 provided by grant aid.
� Carrowbrowne, Co. Galway - Composting facility development (Galway
County Council)
Composting facility - This facility is designed to process 9,500 tonnes of green
and household organic waste which is collected in the brown bins issued to over
18,000 households in the city and from the city's parks. The compost will be used
as soil enricher in the city’s parks and open spaces and may also be made
available to householders. The operational cost of the scheme is recovered from
each householder through an annual refuse charge in accordance with the
Polluter Pays Principle. The approved costs are €2,285,253 with €1,713,940
provided by grant aid.
� North Stand, Dublin 3 – Development of a Civic Amenity site (Dublin City
Council)
Dublin City Council received a grant of €285,262 for a Civic Amenity Site at
Aldborough Parade- Shamrock Terrace, in the North Strand. Of this, €142,631 of
the grant was funded by the Irish Exchequer, with a matching amount of
€142,631 being funded by the EU from the European Regional Development
Fund. The material accepted at the Civic Amenity facility is a combination of
domestic recyclable materials and civic amenity bulky wastes. No commercial
waste is accepted.
1114 National Development Plan (2009) National Development Plan Website, Available:
http://www.ndp.ie/viewdoc.asp?DocID=485
1115 National Development Plan (2009) National Development Plan Website, Available:
http://www.ndp.ie/viewdoc.asp?fn=/documents/GuideToFunding/default.asp?v=ProgID=1,RegionID=
1,SubProgID=4,MeasureID=3&mn=guij
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906
The site accepts the following materials: glass, textiles & clothing, paper,
cardboard, plastics, aluminium & steel, cans, wood, brown goods (typically
furniture), white goods (refrigerators, freezers, washing machines etc), rubble &
steel (small quantities), household electrical & IT goods (TVs computers etc),
bulky wastes (mattresses, household DIY waste) and household hazardous waste
(bleach, paint, fluorescent tubes, etc). The facility was officially opened in March
2003.
The National Development Plan website outlines the review and monitoring structures
in place to assess the progress and outcome of the various sub programmes.
29/09/09
While, overall responsibility for the implementation of the Plan rests with the
Department of Finance, each Operational Programme is administered by a
Managing Authority. The authority, in turn, delegates the implementation of
individual measures to an Implementing Body (in most cases a Government
Department or State Agency). Each programme is monitored by a Monitoring
Committee, comprising representatives from the Government Department or
State Agency responsible for implementing the measure, the Social Partners
and the Managing Authority. These committees meet twice a year to review
progress in the implementation of the Operational Programmes. 1116
Once an evaluation report is complete, the Managing Authority for the programme
concerned submits the report for discussion to the operational programme
monitoring committee. The Monitoring Committee is required to consider and take
a position on all recommendations made in the evaluation (It does not, of course,
have to accept the recommendations). The Managing Authority is required to
report back to the committee on progress made in implementing agreed
recommendations. 1117
The Waste Management Infrastructure Capital Grants Scheme, which was launched
in 2002 and under which over €100m was allocated in grant assistance to local
authorities, closed to new applications in 2008. This scheme assisted in the
development of the current nationwide network of almost 2,000 bring banks and
more than 80 civic amenity sites.
60.2.3 Waste Recycling Capital Grant Scheme
In July 2008, with the Waste Management Infrastructure Capital Grants
Schemehaving closed, the Waste Recycling Capital Grant Scheme was launched with
the aim of providing assistance in meeting the Landfill Directive diversion targets.
Under this scheme grant funding of up to 85% is available towards projects designed
to increase the biological treatment of waste. This is an increase from 75% which had
1116 National Development Plan (2009) National Development Plan Website, Available:
http://www.eustructuralfunds.ie/viewdoc.asp?fn=%2Fdocuments%2Foverview%2Fevaluation.htm&mn
=ovec&nID=5
1117 National Development Plan (2009) National Development Plan Website, Available:
http://www.eustructuralfunds.ie/viewdoc.asp?fn=%2Fdocuments%2Foverview%2Fevaluation.htm&mn
=ovec&nID=5

previously been available for such projects. In 2008, €24 million was made available
to local authorities under the scheme.
60.2.4 The Environment Fund
In addition to the position that exists for waste infrastructure development within NDP
planning, the regulatory mechanism of the Environment Fund exists as a source of
funding for waste management measures.
Provision for the creation of the Environment Fund was made through the Waste
Management (Amendment) Act 2001. Section 12 of the 2001 Act makes
amendments to the Waste Management Act 1996 through providing for the insertion
of Section 74 into the 1996 Act.
The Environment Fund comprises revenues from the landfill levy and the plastic bag
levy, although there is potential for money to be contributed to the fund from the
exchequer - if or when agreement is made with the Minister for Finance. It is managed
and controlled by the Minister for the Environment and Local Government and can be
utilised for the following purposes: 1118
907
� schemes to prevent/reduce waste
� waste recovery activities
� research & development into waste management
� production, distribution or sale of products deemed to be less harmful to the
environment than other similar products
� development of producer initiatives to prevent/reduce waste arising from their
activities
� implementation of waste management plans
� enforcement of the provisions of any enactment relating to waste
management, prevention of litter or protection of the environment
� partnership projects, that involve local authorities, to improve the quality of the
environment for particular local communities
� promotion of awareness of the need to protect the environment, including
national and regional campaigns
� promotion /support of education and training to assist achievement of
campaign objectives
� resources (human or material) to enable education and training to be carried
out
1118 Department for the Environment, Heritage and Local Government (2009) Environment Fund
Website Page, Available: http://www.environ.ie/en/Environment/Waste/EnvironmentFund/
International Review of Waste Policy: Annexes

908
� initiatives undertaken by community groups and others for protection of the
environment such other purposes for protection of the environment as may be
prescribed by the Minister in regulations.
Funding is allocated via a two tier process. It is allocated for use, within the
boundaries listed above, to the Department of the Environment. It is then down to the
Minister to pass individual applications for funding. Funding very often runs over a 3
year contract so that schemes periodically require authorisation by the Minister.
These are often informed by the direction the EPA are taking, for example a recent
increase towards research and development led to new funding contracts being
drawn up.
Provision of money from the Environment Fund is described below, as outlined by the
Department of the Environment in correspondence: 1119
29/09/09
Sections within the Department of Environment, Heritage & Local Government
may apply to the Environment Fund Administrator seeking an allocation from
the Fund for projects which fall within the remit of the Act - funding is not
made directly available from the Fund to individual applicants and there is no
mechanism by which applicants may apply for funding from the Environment
Fund. Where allocations to sections within the Department are approved, it
is up to the individual Departmental section concerned to invite applications
for projects within the remit of their sectional work area.
The requests from Departmental sections for an allocation from the
Environment Fund are assessed by the Fund Administrator and submitted to
the Minister for approval. Allocations are prioritised on the basis of their ability
to contribute to the purposes outlined at (a) to (m) [as given in the legislation].
If these allocations are approved it is up to the individual section concerned
to invite applications for their projects, decide as to the merits of individual
applications, set the criteria for awarding funding, evaluate the effectiveness
of the money spent , etc.
There is no limit placed by the Environment Fund Administrator on the
maximum grants available for specific projects. However, the various sections
drawing down funding from the Fund may put limits in place that
are appropriate to the grants awarded to specific local schemes/projects
receiving money from the Departmental sections.
The information available concerning the applications for the fund is limited, but
some can be gleaned from the Environmental Fund Published Accounts which are
currently available since the year the fund was established in 2001 until 2006 (Table
60-1)
1119 Department of the Environment (2009) Correspondence with C O Grady March 2009.

Table 60-1: Environment Fund Income & Expenditure 2002 - 2006
Income Income
2002 2002 2002 2003 2003 2003 20 2004 20
04 2005 2005 2006
2006
Environmental Levy on the Landfill of Waste €17,868,726 €29,359,585 €26,765,514 €27,798,605 €30,750,433
Environmental Levy on Plastic Bags €10,428,413 €12,883,408 €15,278,107 €17,484,551 €19,947,315
Interest on Investments - €71,383 €891,815 €914,525 €1,436,644
Total Income €28,297,139 €28,297,139 €42,314,3 €42,314,376
€42,314,3 €42,314,376
76 €42,935,436
€42,935,436 €42,935,436 €46,197,681 €46,197,681 €52,134,392
€52,134,392
Expenditure
Expenditure
North/South Waste Management Programmes - €945 €83,917 €341,585 €602,438
INTERREG Waste Management Projects - - €250,800 €92,669 €196
Waste Prevention Programme & MDP [Note 1] - - €283,463 €802,042 €1,725,866
Producer Responsibility Initiatives €1,000 €234,327 €61,674 €541,137 €408,304
Environmental Levy Operational Costs €1,828,688 €346,405 €374,601 €480,825 €237,248
Waste Prevention Operational Costs - €96,362 €123,868 €6,530 €59,074
Waste Management Including Recycling Projects €2,084,581 €5,625,391 €22,007,645 €7,272,502 €2,242,334
Recycling Operational Costs - €5,000,005 €7,000,200 €7,000,020 €10,000,200
Local Authority Enforcement Initiatives - €741,201 €4,051,313 €8,848,972 €7,774,502
Waste Infrastructure Operational Costs/ Consultancy - €85,825 - - -
Environment Awareness - €2,465,400 €2,619,155 €4,085,359 €3,649,342
Pollution Control Air/ Climate - €171,828 €332,205 €137,389 €239,595
International Conventions / Bodies / Organisations €17,634 €2,373,030 €2,318,268 €2,436,226 €2,497,984
Litter Initiatives - €1,043,482 €1,206,690 €1,044,339 €1,371,716
REACH - - - €14,188 -
Office of Environmental Enforcement - €266,509 €861,000 €1,800,000 €2,185,886
EPA R&D - - €7,250,000 €7,000,000 €7,000,000
Water Quality
Comhar - the National Sustainable Development
- €151,052 €193,932 €177,927 €78,974
Partnership - €168,847 €167,623 €102,567 €292,056
Total Expenditure €3,931,903 €3,931,903 €18,770,609
€18,770,609 €18,770,609 €49,186,354
€49,186,354 €49,186,354 €42,184,277 €42,184,277 €40,365, €40,365,715
€40,365, 715
Surplus for the Year €24,365,236 €23,543,767 €23,543,767 -€6,250,918
€6,250,918 €4,013,404 €4,013,404 €11,768,677
€11,768,677
909
International Review of Waste Policy: Annexes

These show that in the first year of the fund, 2001/02, there were four areas which
accounted for the Fund’s expenditure – with one of these being the collection costs of
the levy. Between 2003 and 2006 the expenditure increased from 15 key areas to 18
key areas, with the most recent listed below:
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29/09/09
� North/South Waste Management Programmes;
� INTERREG Waste Management Projects;
� Waste Prevention and National Market Development Programmes;
� Producer Responsibility Initiatives;
� Environmental Levy Collection Costs;
� Waste Prevention Operational Costs;
� Waste Management including Recycling Projects;
� Recycling Operational Costs;
� Local Authority Enforcement Initiatives;
� Environment Awareness;
� Pollution Control Air/Climate;
� International Conventions/Bodies/Organisations;
� Litter Initiatives;
� REACH;
� Office of Environmental Enforcement;
� EPA R&D;
� Water Quality; and
� Comhar – the National Sustainable Development Partnership.
Spending on programmes and measures under the Environment Fund must come
within the remit of the legislation governing the Fund. The assessment methodology
and criteria are outlined from correspondence with the Department;
Each section is responsible for ensuring that the funding they have been
provided with for subsequent distribution for individual projects complies with
the terms of Section 74(9) of the Waste Management Act 1996 (as inserted
by Section 12 of the Waste Management (Amendment) Act 2001) and the
Waste Management (Environment Fund) (Prescribed Payments) Regulations
2003 (SI No. 478 of 2003). Therefore there is no single contact point in the
Department to supply details on which individual projects are grant-aided from
the Fund. However details of the general headings under which funding has

een provided are available in the Environment Fund Accounts, which are
available on the Department's website. 1120
In so far as an application comes within the remit of the objectives (a) to (m) as set
out in the amended Act, there is potential for the grant application to be funded.
Further than that, grant approval is given across all waste management areas and
activities, rather than being streamlined or concentrated to the achievement of a
narrower set of outcomes e.g. achievement of the objectives of the Landfill Directive.
60.3 Comparison between Funds in UK and Ireland
There is some concern because with similar areas being funded year after year there
may be some reliance from certain organizations upon the fund. Their presumption
that they may be in line to receive a portion of the funding does not fall in line with
the, ‘golden rule of public funding which suggests that governments should support
only those investments that are economically efficient but not financially viable’. 1121
Funding must be seen to support projects which can prove to be sustainable after the
funding ceases. For this reason, public funding is usually required to be contributed to
by the organization applying for the funding, or a third party.
More information regarding the UK’s Landfill Communities Fund is described in
following sections, but an initial comparison between this funding stream, and
Ireland’s Environmental Fund, is shown in Table 60-2.
60.4 Sources of Fund and Size of Fund
The following examples show that environmental funding is most commonly made
available through the public sector which finances grants through their central budget
or through environmental taxation. Those funds sourced from taxes are seemingly
those which are ongoing, and those which are funded through the public sector’s
budget are usually for a limited period of time, with the amounts available from both
sources being hugely variable.
60.4.1 Environmental Taxation
Revenue from environmental taxes is sometimes ear-marked, or hypothecated, to
form an environmental fund which is used to support environmentally sound actions.
Environmental taxation is one direct source of grant funds, and the level of taxation
has a bearing upon the size of the fund available. Some examples of this are set out
below.
1120 Department of the Environment (2009) Correspondence with C O Grady March 2009.
1121 OECD (2007) Handbook for Appraisal of Environmental Projects Financed from Public Funds,
report to OECD by the Task Force for the Implementation of the Environmental Action Programme,
Available: http://www.oecd.org/dataoecd/10/63/38786197.pdf
911
International Review of Waste Policy: Annexes

Table 60-2: Comparison between the UK and Irish Landfill Levy Fund
Number of times you can
apply to the fund
Geographical area to
which the fund applies
Governance structure
Who can apply?
Can 100% funding be
applied for?
The The UK UK Landfill Landfill Communities Communities Fund Fund (LCF)
(LCF)
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29/09/09
Ireland’s Ireland’s Environment
Environment
Environment
Fund
Fund
There is no information
available on any time
limitations which may be
applicable to this fund.
This fund is administered
centrally and public and
private bodies all over
Ireland can apply to the
Fund.
It is managed and
controlled centrally by the
Minister for the
Environment and Local
Government
Public and private bodies
can apply to the Fund
Information on funding
guidelines are not clear
UK’s UK’s UK’s Landfill Landfill Landfill Communities
Communities
Communities
Fund
Fund
This varies according to
which Distributive
Environmental Body (DEB)
is applied to. For example,
Sita Trust only allow
applicants to apply for
funds for the same site or
project once in any three
year period
This varies according to
which DEB is applied to –
there is usually a distance
limitation with which the
project must comply, e.g. 3
miles with an active landfill
ENTRUST are an
independent regulatory
body. Funding is
distributed through
Distributive Environmental
Bodies who make the
decision regarding the
funding.
Registered Environmental
Bodies (EB) only can apply
to the Fund. They must be
a registered non-profit
organization.
Due to the way in which
landfill operators
contribute to the fund they
usually request around
10% of the total funds to
be sourced from a third
party.
The LCF is contributed to by landfill operators. They can contribute up to 6% of their
landfill tax liability and then reclaim 90% of this contribution as a tax credit. 1122 The
1122 Entrust (2009) Website Available: http://www.entrust.org.uk/home/lcf

additional 10% must be met by another funder to make the donation ‘cost-neutral’ to
the landfill operator.
The The The UK UK UK Aggregates Aggregates Aggregates Levy Levy Levy Sustainability Sustainability Sustainability Fund Fund Fund (ALSF) (ALSF)
(ALSF)
The UK aggregates levy provides the source of finance for the Aggregates Levy
Sustainability Fund (ALSF). The aggregates levy is an environmental tax on the
commercial exploitation of primary aggregate in the UK. The total fund is in the region
of £15 million per year. The Aggregates Levy is set at £1.60 per tonne, with the
exception of those in Northern Ireland who only pay 20% of the levy which equates to
£0.32 per tonne in return for committing to making significant environmental
improvements.
Western Western Australia’s Australia’s Waste Waste Avoidance Avoidance and and Resource Resource Recovery Recovery Account
Account
Western Australia’s landfill levy finances a range of zero-waste related schemes. The
fund is financed through direct allocation of all funds collected through the levy. The
levy is currently set at $8/tonne and is paid by landfill operators located in, or
receiving waste from, the Perth metropolitan area. The fund is worth just under $20
million/year. In a ‘Landfill Levy Review’ undertaken for the Waste Management Board
of Western Australia it is reported that the levy itself was imposed in order to generate
revenue to fund projects which were focused on resource recovery and reducing
waste to landfill:
913
“As reported by ECS (2003), the 1995 Report of the Parliamentary Select
Committee on Recycling and Waste Management stated that the levy concept
was developed primarily to fund a range of activities related to waste
minimisation and recycling. The levy rate was determined by dividing the total
amount of funds needed by the estimated tonnage to landfill.” 1123
This might appear a somewhat unusual approach to take to the introduction of a levy,
though in reality, one objective of levies is likely to be to raise revenue, whatever the
nature of the destination of the funds so raised. However, due to the increasing levy
rate the focus of this policy has now changed, with more emphasis placed on
capturing externalities and directly influencing waste management.
60.4.2 Centralised Public Finance
Money that has been allocated from a centralised budget to be used as funding is
less predictable and far more variable in size than those derived from taxation, as
exemplified by the following examples:
The The European European Commission
Commission
The European Commission run a series of funds which are sourced from public
money. The Directorate General for the Environment makes runs three funding
programmes which could be relevant to waste-related projects: the LIFE fund, the
Competitiveness and Innovation Programme – Entrepreneurship and Innovation
1123 Four Scenes Pty Ltd (2007) Landfill Levy Review, Report to the Waste Management Board of
Western Australia, Available: http://www.zerowastewa.com.au/documents/landfill_levy_51107.pdf
International Review of Waste Policy: Annexes

Programme (CIP-EIP) and through grants to environmental NGOs. In 2008 their CIP-
EIP fund was worth £28 million for which they received 444 submissions from 32
countries. 1124
WRAP WRAP Construction Construction Waste Waste Recycling Recycling Support Support Programme
Programme
The Waste and Resources Action Programme (WRAP) launched a capital grant fund in
2006 in England (the Construction Waste Recycling Infrastructure Capital Support
Programme), followed by a similar stream of funding in Scotland in 2008 (the WRAP
Construction and Demolition Capital Grant Programme for Scotland) and Wales (the
Materials Action Programme Wales Capital Grant Programme). WRAP is a not-forprofit
company who are backed by government funding from England, Scotland,
Wales and Northern Ireland.
A WRAP report from 2007 suggests that the total amount of funding made available
to support C&D waste infrastructure up to 2007 was £9.3 million. 1125 If bidders are
successful, the programme will provide up to 30% of their eligible capital costs.
These construction recycling funding streams are part of the WRAP Capital Grant
Programme which aims to fund areas of strategic need or focus upon areas where
market failures have been identified. It is worth noting that the source of the finance
for the capital grants varies, depending upon the funding stream. For example, the
WRAP aggregates program, is financed through the ALSF, described in Section
60.4.1. In the 2009/10 financial year WRAP aims to fund food waste reprocessing
facilities with a total capacity of 550,000 tonnes a year from a total fund of £14
million.
WRAP WRAP Organic Organics Organic Capital Grant Grant Programme Programme
WRAP’s organic capital grant programme aims to provide funding towards the
development of ABPR-compliant, thermophilic aerobic digestion or anaerobic
digestion facilities. It was launched in 2008 and was eligible to applicants in England,
Scotland and Northern Ireland. Projects must be able to demonstrate diversion of
organic waste from landfill in order to produce recycled products. The funding,
similarly to their other capital grant schemes, funds up to 30% of the capital set-up
costs.
Defra Defra Anaerobic Anaerobic Digestion Digestion Demonstration Demonstration Programme Programme
Programme
This £10 million fund aims to demonstrate the benefits of anaerobic digestion to a
range of industries. The fund is being administered by WRAP and the Carbon Trust.
Californian Californian Construction Construction and and Demolition Demolition Management
Management
In the USA funding for construction and demolition materials management projects is
most typically provided from the State level, e.g. the California Integrated Waste
1124 European Commission (2008) A Wealth of Ideas for a Greener Europe, Available:
http://ec.europa.eu/environment/eco-innovation/docs/publi/brochure_en_09.pdf
1125 WRAP (2006) WRAP Completes £2.3 M of Funding for Aggregate Recyclers, Available:
http://www.wrap.org.uk/wrap_corporate/news/wrap_completes_23m.html
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29/09/09

Management Board (CIWMB) provide grants which are funded by the Californian
State Government. Funding is also made available at the Federal level, although far
less frequently. This is through the Environmental Protection Agency’s Office of Solid
Waste and Emergency Response (OSWER). 1126 Information on the total funds
available over any time period could not be found.
Prevention Prevention Stimulating Stimulating Programme Programme ( (PREST ( PREST PRESTI) PREST )
The Government of Flanders’ PRESTI programme began in 1994. Since then a series
of PRESTI programmes have been run which have had the following OVAM (Public
Waste Agency of Flanders) budget:
915
� PRESTI 1 (1994-1997): 3,200,000 Euro
� PRESTI 2 (1997-2001): 560,000 Euro
� PRESTI 3 (1997-2002): 407,000 Euro
� PRESTI 4 (1998-2004): 1,622,000 Euro
� PRESTI 5 (2003-2008): 2,980,000 Euro
60.5 Objectives of Fund
The main reason for public sector intervention is to manage market failures, in
particular to internalise production/consumption externalities which may result from
imperfect competition within a market. This means working towards effectively
reflecting the true price of a good or service in the cost through government
intervention which should result in a more efficient allocation of resources. 1127 Insofar
as this is the case, then where waste management is concerned, in principle,
internalising externalities and implementing rational policies ought, in well-functioning
markets, to enable the market to deliver the desired outcomes. In practice, markets
do not always operate efficiently, and capital grants might be especially appropriate
as means to stimulate investment in times when the terms upon which companies
can access credit are somewhat poor, as at the time of writing.
60.5.1 Environmental Taxation
Environmental taxes are predominantly conceived as measures to ensure that the
environmental cost of an environmentally damaging procedure is reflected in the
price, though the reality remains that this is rarely the basis for setting the level of
such taxes. Revenue is occasionally ear-marked and an environmental fund is set-up.
The aim of the fund is to finance projects which work to offset the environmental or
social damage, or change behaviour, to reduce reliance on the environmentally
damaging service or product. Two UK based examples follow:
1126 United States Environmental Protection Agency (website) Available:
http://www.epa.gov/osw/conserve/rrr/imr/cdm/grants.htm
1127 European Commission DG for Regional Policy Evaluation Unit (2006) Cost-Benefit Analysis and EU
Regional Policy Main Lessons from the Experience, Draft paper prepared for the 5 th Milan European
Economy workshop 26-27 May 2006, Available:
http://florio.economia.unimi.it/Materiali/MEEW5/Mairate.doc
International Review of Waste Policy: Annexes

The The The Landfill Landfill Landfill Communities Communities Communities Fund Fund
Fund
The Landfill Communities Fund (LCF) was set up to help mitigate the effects of landfill
upon those living within a close proximity to the site. The LCF was formerly the Landfill
Tax Credit Scheme which had a much wider remit and covered waste research
projects, although they had to be within a certain proximity of the site. The fund has
the following specific objectives:
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1. The remediation of land (Object A)
2. The prevention of pollution (Object B)
3. The reduction of waste (Object C)
4. The recycling of waste (Object CC)
5. Public parks and public amenities (Object D)
6. Biodiversity conservation (Object DA)
7. The restoration of places of worship and historic buildings (Object E)
8. The provision of services to other Environmental Bodies (Object F)
The The The Aggregates Aggregates Aggregates Levy Levy Levy Sustainability Sustainability Sustainability Fund Fund
Fund
Similarly to the LCF, the ALSF’s overall main aim is to:
29/09/09
“reduce the environmental impacts of the extraction of aggregates and to
deliver benefits to areas subject to these impacts”. 1128
It aims to achieve this through the following objectives:
1. Quarries - To reduce the environmental footprint of quarries and to take
advantage of the opportunities they offer.
2. Marine - To reduce the environmental footprint of marine extraction.
3. Resource Use - To deliver more sustainable use of aggregates.
4. Transport - To reduce the environmental footprint of the transport of
aggregates.
5. Communities - To deliver benefits to communities affected by extraction. 1129
60.5.2 Centralised Public Finance
Grant funding that is provided through a government’s central budget is
disassociated with one product or service, in the way that funds sourced from
environmental taxes are. Therefore, a need must be identified for the fund to be put
1128 Defra (2009) Website: Aggregates Levy Sustainability Fund in England, Available:
http://www.defra.gov.uk/environment/waste/aggregates/index.htm
1129 Defra (2009) Website: Aggregates Levy Sustainability Fund in England, Available:
http://www.defra.gov.uk/environment/waste/aggregates/index.htm

in place. This is very often to enable the government to reach targets or goals. The
variety of these funding streams are shown by the following examples:
Eco Eco-Innovation Eco Eco Innovation Innovation Fund Fund
The European Commission runs an Eco-Innovation fund, which seeks to further,
917
“All forms of innovation which reduce environmental impacts and/or
optimising the use of resources”.
Construction Construction Waste Waste Recycling Recycling Infrastructure Infrastructure Capital Capital Support Support Programme
Programme
WRAP’s Construction Waste Recycling Infrastructure Capital Support Programme aims
to boost capacity for recycling construction waste. It specifically focuses on the noninert
fractions of construction and demolition waste and aims to stimulate ‘step
change in the collection, segregation, recovery and recycling rates of materials’. 1130
Defra Defra Anaerobic Anaerobic Digestion Demonstration Programme
The five key aims of this programme are:
� Maximising the cost effective production of biogas;
� Maximising the environmental benefits from the use of anaerobic digestions
and its products;
� Maximising the potential of anaerobic digestion to reduce the carbon footprint
of the food supply chain;
� Maximising the opportunity for the injection of biomethane into the gas grid;
and
� Maximising the potential of anaerobic digestion to reduce the carbon footprint
of water treatment infrastructure.
Californian Californian Californian Construction Construction and and Demolition Demolition Management
Management
The CIWMB provides the Californian public and private sector with grants in order to
enable the State’s waste reduction, reuse and recycling targets to be achieved. There
are 11 main grant programs, of which the Sustainable Building Grant program is of
most relevance to the construction sector and the Deconstruction Grant Programme
which only ran for 1 year in 1999.
Californian Californian Environmental Environmental Protection Protection Agency Agency (EPA)
(EPA)
The Californian EPA has provided grants under their Innovations Initiative which aims
to fund work with a greater emphasis on research. They have funded innovative pilot
projects which focus on development of new approaches towards waste minimisation,
energy recovery and recycling.
1130 WRAP (2006) WRAP Targets C&D Waste with New Capital Funding Competition, Available:
http://www.wrap.org.uk/wrap_corporate/news/wrap_targets_cd.html
International Review of Waste Policy: Annexes

Strategic Strategic Strategic Waste Waste Waste Initiatives Initiatives Initiatives Scheme Scheme
Scheme
The Western Australian Waste Authority runs two streams of grant schemes: the
Strategic Waste Initiatives Scheme and the Community Grants Scheme. Of most
relevance to the waste sector is the Strategic Waste Initiatives Scheme which has
identified five priority areas:
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1. Green Waste;
2. Construction and Demolition;
3. Plastics;
4. Used Tyres; and
5. Hazardous Waste from Households.
Proposals must be submitted for initiatives must be relevant to one of the five priority
areas and consistent with the ‘Statement of Strategic Direction for Waste
Management in Western Australia’.
Prevention Prevention Prevention Stimulating Stimulating Stimulating Programme Programme Programme ( (PRESTI ( ( PRESTI PRESTI)
)
The main over-arching objective of the PRESTI programme was to stimulate SME’s to
integrate environmental management and prevention in their policy. However, each of
the five PRESTI programmes have differed from one another:
PRESTI 1 offered practical and usable information to a group of enterprises in the
same activity-sector through using federations as partners. PRESTI 1 also wanted
increase ongoing prevention awareness in federations, that remained ingrained after
the ending of PRESTI 1.
PRESTI 2 gave financial support to federations for demonstration projects, a step
further than PRESTI 1. Pilot enterprises were screened and some prevention
measures were executed.
PRESTI 3 offered support to individual SME’s. Participating SME’s developed a
prevention plan. In a second phase, this plan was implemented where possible.
PRESTI 4 supported intermediary organisations developing systems to promote
prevention and environmental management in enterprises. PRESTI 4 was available to
each Flemish province.
PRESTI 5 supported research, demonstration projects and pilot projects. Research
and education institutions, environmental and socio-cultural associations, as well as
businesses were eligible for this fund.
60.6 Period of Operation
60.6.1 Environmental Taxation
The majority of funds which are financed through taxation, such as the LCF and the
ALSF, have been ongoing since the launch of the fund shortly after the launch of the
tax, in 1997 and 2002, respectively. This type of fund is predictable and politically
popular because a direct association between the revenue and the benefit provide
reasoning for implementation of the tax.

However, earmarking reduces flexibility in public finances so ought to be withdrawn
when the funds objectives have been met. 1131 Equally, if levies increase, and if, as a
result of inelastic responses, the total revenue generated increases, questions should
be asked as to whether the size of the fund might simply generate waste in the use of
revenues. Although there are no examples of the fund actually being withdrawn, the
following evidence shows examples of continuous evaluation.
Taking the case of the landfill tax in the UK, this was introduced in order to reduce the
reliance upon landfilling of waste. Despite being ongoing since 1997, the fund did
change from the Landfill tax Credit Scheme to the Landfill Community Fund and in
doing so the objectives of the fund were shifted to a greater focus on communities
affected by landfills sites. This shift shows that evaluation of the fund was taking
place and potentially old objectives were deemed either unnecessary or they had
been met.
A similar example of good practice occurred in Western Australia when their Waste
Management and Recycling Fund (WMRF) (funded by the landfill levy) was suspended
in 2002 whilst a review was undertaken. Following this, the focus of the funding
strongly shifted to a zero waste focus and a series of Zero Waste Schemes were
introduced under the new Strategic Waste Initiatives Schemes, in 2004. 1132 It was felt
that although there was some merit to the previous funding expenditures, they lacked
innovation and leadership.
The ALSF was introduced in 2002 as a two-year pilot scheme which has been
extended by between 1 and 3 years ever since, currently up until 2011. This has been
through a series of reviews and consultations. There are no definitive indications at
this stage as to whether or not it will be renewed yet again, but it seems likely that
this will occur.
60.6.2 Centralised Public Finance
In contrast to funding sourced from taxation, centrally financed public grants tend to
be available for a limited period of time and with specific objectives in mind. Each
programme has a specific launch date and deadline date for application and date
marking the end of the availability of the fund.
For example, WRAP’s capital funding stream which focused on increasing
plasterboard recycling was launched in February 2007 and applications had to be
received by 30 th April 2007. Projects receiving the funding had to be operational by
the following March.
1131 OECD (2007) Policy Brief: Making Environmental Spending Count, Available:
http://www.oecd.org/dataoecd/1/18/39376495.pdf
1132 Western Australia Department of Environment and Conservation (2009) Waste Management,
Website available:
http://portal.environment.wa.gov.au/portal/page?_pageid=53,34379&_dad=portal&_schema=PORTA
L
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60.7 Decision/Allocation Mechanism for Funding Awards
The most oft-cited method to allocate funding is through a competitive tendering
process. The way in which this is administered varies across funding streams.
However, it is common for environmental funds, financed by the taxation, to be set up
in order to administer and manage the allocation of the money. The way in which this
fund is managed varies greatly as demonstrated by the following examples.
The LCF is regulated by the independent organisation ENTRUST. They are not-forprofit
and non-governmental. Although not involved in the final allocation of the fund,
Entrust are fundamental to reviewing the projects undertaken by environmental
bodies. Distributive Environmental Bodies makes the decision regarding the project
funding – these are often associated with the Landfill Operator, e.g. SITA Trust, Viridor
Credits Environmental Company. The taxes which are not donated to the fund
managed by HM Treasury, who also oversee ENTRUST, and DEFRA is instrumental in
setting out the goals which the fund hopes to achieve. Despite the ongoing nature of
the funding applicants can only apply for the same site or project once every three
years. 1133
The ALSF is managed by the following governments and government departments:
Defra in England; the Welsh Assembly Government in Wales; the Scottish Government
in Scotland; and the Department of the Environment in Northern Ireland. In England,
the management bodies set the overall fund objectives and then allocate funding to
delivering partners who then receive applications for the fund. There are nine national
organisations and 18 local authorities (who have the highest level of aggregates
production) who are delivery partners.
A competitive tendering process, managed by the Capital Grants Team at WRAP, is
undertaken to allocate the funding to the most relevant project proposals. This
includes having the applications independently assessed by a financial or
environmental assessor and specialist panel. From the announcement of the
availability of the fund there is approximately 10 weeks until the deadline for
applications. A requirement of the grant scheme is that the outcome of the funding
must be operational in 2 years from the application deadline. In order to support the
application process WRAP ran free workshop events.
European Structural and Cohesion funds are allocated as a result of a Cost-Benefit
Analysis (CBA). CBA is used as an evaluation tool to ensure that the fund gets
distributed to projects which are value for money in terms of effectiveness and
efficiency in contributing towards the main goals of the EU funds. CBA also assesses
the extent to which the project needs the grant, and the level of funding required,
using the ‘funding-gap’ method. 1134 The European Commission has encouraged this
assessment methodology across Member States.
1133 Sita Trust, Enriching Nature Guidance Notes, Available:
http://preview.sitatrust.org.uk/resources/documents/DA/DA_Guidance_Notes10.09.08.doc.dot
1134 European Commission DG for Regional Policy Evaluation Unit (2006) Cost-Benefit Analysis and EU
Regional Policy Main Lessons from the Experience, Draft paper prepared for the 5 th Milan European
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60.8 Approach to Evaluating Effects of Environmental Funds
In 1995, the OECD developed the ‘St. Petersburg Guidelines for Environmental Funds
in the Transition to a Market Economy’ which have provided a benchmark by which to
evaluate environmental funds. The main conclusions of the Guidelines include those
set out in the Box below: 1135
Effective evaluation of an environmental fund is necessary because it provides
information on whether the fund’s objectives are being successfully achieved and in
light of this whether or not the fund should be continued. 1136
This is particularly important for ear-marked funds because they can lead to
inefficient distribution of funding if areas outside the ear-marked sector are in greater
need of the funding. This point was discussed in Section 60.6, in terms of how long
funds operate for, and the ongoing evaluation that is required.
Acquiring information that covers any greater level of detailed evaluation, other than
that described in Section 60.8, has proven challenging. It seems that there is a
distinct lack of available information regarding funding evaluation. Any available
information is published by an associated organisation, rather than an independent
reviewer.
For example, WRAP explicitly state their targets for the aggregate programme, which
was funded through the ALSF. The fund was to achieve the following by 2006:
921
1. To deliver a 3 million tonne increase in reprocessing capacity for recycled and
secondary aggregates.
2. To bring about a 10% increase in the use of recycled and secondary
aggregates in higher-value (non-fill) applications.
3. To develop, agree and communicate quality protocols for the specification and
point of recovery of recycled and secondary aggregates.
4. To promote and facilitate the specification of recycled and secondary
aggregates to the point where 10% of local authorities are specifying these
materials in street maintenance contracts by 2005, rising to 20% by 2006.
5. To deliver a minimum of 50 training opportunities during the course of the
programme supported by new tools and information within the aggregates
supply chain.
Economy workshop 26-27 May 2006, Available:
http://florio.economia.unimi.it/Materiali/MEEW5/Mairate.doc
1135 Speck S., J. McNicholas and M. Markovic (eds) (2001) Environmental Funds in the Candidate
Countries, The Regional Environmental Center for Central and Eastern Europe, Szentendre, Hungary
based on OECD (1995) Environmental Funds in Economies in Transition, Paris
1136 OECD (2006) Recommendation of the Council on Good Practices for Public Environmental
Expenditure Management, Available: http://www.oecd.org/dataoecd/10/46/38787377.pdf
International Review of Waste Policy: Annexes

922
Box Box 11:
1 1:
: St St Petersburg Petersburg Guidelines Guidelines on on Environmental Environmental Funds
Funds
� To avoid or minimize the long-term economic inefficiencies inherent in the
earmarking of funds, expenditure should be targeted to meet environmental
priorities and promote projects with large environmental benefits relative to their
costs.
� Environmental funds should play a catalytic role in financing, ideally offering no
more support for project than is necessary, adapt to changing economic
conditions, and support, not compete with, emerging capital markets.
� Environmental funds should be used in conjunction with, and reinforce, other
environmental policy instruments, such as compliance schedules,
environmental auditing programs and voluntary agreements.
� Environmental Environmental funds funds should should develop develop an an overall overall financing financing strategy, strategy, follow follow follow clear
clear
and and explicit explicit operating operating procedures procedures for for evaluating evaluating and and selecting selecting projects, projects, adopt
adopt
effective effective monitoring monitoring and and evaluation evaluation practices, practices, and and make m
ake effective use of
internal internal internal and and and external external external expertise expertise expertise to to to enhance enhance enhance administrative administrative administrative efficiency. efficiency.
efficiency.
� For For For investment investment projects, projects, funds funds should should have have have well well-designed well well designed program program and and project project
project
cycles cycles to to ensure ensure cost cost-effective cost effective use of resources.
� Environmental Environmental funds funds should should leverage leverage iincreased
i increased
ncreased private private private sector resources resources and
capital capital market market financing financing for for environmental environmental investments.
investments.
� In defining and evaluating fund revenue mechanisms, environmental
authorities should try to ensure environmental effectiveness, economic and
administrative efficiency, equity and acceptability. Systems should provide a
stable base of revenues, be simple in structure, and be easy to monitor and
enforce.
� Environmental funds should ensure transparency and should be accountable
to government, parliaments, and the public for their actions.
Source: Eunomia & University of Pretoria (2003) Fiscal Reform in South Africa, A Final Report for
National Treasury of South Africa.
In Defra’s report, ‘Aggregates Levy Sustainability Fund in England 2002-2007’ these
targets are reported but the outcome of each is not. Each of the five aforementioned
targets are measurable in some way – however this is not demonstrated. The case is
same for other WRAP funding streams – where the funding targets are clearly
identifiable but the outcome is not.
WRAP’s Capital Grant Team were contacted but felt they were unable to answer
questions regarding how the capital funding streams were evaluated without
breaching confidentiality of those who received the fund. Their website provides no
substantial information on how this process is undertaken.
Individual case studies are readily available, which suggests that information over the
fund could, and probably has been collated. However, accessing this information is
problematic.
29/09/09

There is evidence to suggest that environmental funds have been developed in-line
with the St. Petersburg Guidelines, therefore they have the intention of following best
practise. For example, Sita, on behalf of the LCF, include the following in their
Guidance Notes:
“Projects should be self-sustaining once the initial project funding has been
invested. This will include ensuring that the project can be managed and
maintained and that funding is available to cover these costs into the
future.” 1137
The problem lies in post-evaluation of the fund, where although user-friendly casestudies
are frequently available to show project specific outcomes of the funding,
data to analyse overall fund efficiencies is not widely released. That is not to say that
detailed evaluation of the fund does not take place, because it most certainly does,
but the results of which are not widely circulated.
60.9 Environmental Impact of Fund
The OECD’s 2006 ‘Recommendation of the Council on Good Practices for Public
Environmental Expenditure Management’ provides a good practice checklist for
establishing, reviewing and reforming public environmental funding programmes in
terms of environmental effectiveness. It is structured using 5 principles, under which
good practices are provided, a summary of which is below:
Principle 1: Additionality and consistency with other environmental policy instruments
Good Practices: the need for the fund should be justified through the polluter-pays
/user pays principle. 1138 They should not be used to reach objectives which should
have been reached via a policy mechanism, or to fund projects which could have
received private investment. The fund should compliment existing policies. It should
be used to finance capital costs, not operational. The fund should be regularly
audited, and phased out when their role is fulfilled.
Principle 2: Well-defined programming framework
The fund should be distributed via a publicly-available expenditure programme which
is set within a wider policy-setting, and which has been approved by the appropriate
bodies.
Principle 3: Clear identification of environmental outcomes
Quantitative and qualitative information on projects’ environmental outcomes should
be submitted in a standard format, and expressed in monetary format where possible
to allow cost-benefit analysis to be undertaken. Environmental outcomes should be
1137 Sita Trust, Enhancing Communities Large Grants Scheme Guidance Notes, Available:
http://www.sitatrust.org.uk/resources/documents/LGS/LGS_Guidance_Notes3mile11.03.09.pdf
1138 The Polluter-Pays-Principle (PPP) requires polluters to pay the full costs of any subsequent clean-up
without subsidies. The User-Pays-Principle states that revenue generated by users must cover all the
costs related to the use of a natural resource.
923
International Review of Waste Policy: Annexes

monitored during and after the project. The funding body should take action if
expected outcomes were not achieved. Finally, information
Principle 4: Maximise environmental effect from available funds
Quantitative and qualitative information on projects’ costs should be submitted in a
standard format in order to allow verification, analysis and indicate costeffectiveness.
Principle 5: Leverage additional finance
Public funds should not fund 100% project costs and the percentage of project costs
borrowed, or financial leverage, should be used to assess the programme’s
performance. Public funding should not distort competition in the market.
Quantifying the overall environmental benefits of a fund is very difficult because
although case studies are usually available they are very succinct. The following
examples aim to give an overview of the environmental impacts.
WRAP WRAP WRAP Aggregate Aggregate Capital Capital Grant Grant Support Support
In 2007 a WRAP report suggested that the capital investment they had provided so
far had resulted in the addition of more than 3.6 million tonnes of annual recycling
capacity. As well as this significant increase in capacity the focus has been on
increasing the production of high quality recycled aggregate
With the announcement of the fund in Scotland and Wales being in 2008 the projects
will not yet have been completed. However, the fund’s environmental impact in
England can be illustrated via the following short case study produced by WRAP:
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29/09/09
� Eppleton Quarry Products Ltd received £101,000 for mobile plant for the
extraction of secondary aggregates from slag. This resulted in an increased
capacity which rose from 125,000 tonnes to 505,000 of quality recycled
aggregate. The environmental benefits of this are two-fold: as a direct
result of the project a greater quantity of waste is diverted away from
landfill in order to be recycled into quality aggregate material; and there is
potential for this to reduce the demand for virgin aggregate. The extraction
process can create noise, it’s unsightly and requires transportation from
the quarry to the site.. 1139
Aggregates ggregates Levy evy Sustainability
ustainability Fund und
A summary report of the ALSF in its first four years, since 2002, was published by
Defra. The main environmental achievements were:
� funding equipment with the capacity to recycle 1.7 million tonnes of
construction and demolition waste or process secondary aggregate;
� making improvements at or around existing or disused quarries; and
1139 WRAP Applying for a WRAP Capital Grant?, Available:
http://www.wrap.org.uk/businesses/business_and_markets/capital_grants.html

925
� undertaking research on quarry restoration, sustainable construction
and demolition processes and assessment and evaluation of wreck sites
at sea.
Californian Californian Californian Integrated Integrated Waste Waste Waste Management Management Management Board Board
Board
The State and Consumer Services Agency received $250,000 in 2001 in order to
construct streets with rubberised asphalt concrete (RAC), derived from tyres, into the
East End Complex. This resulted in the diversion of approximately 11,000 waste tyres
from stockpiles and landfills around California. 1140
Californian Californian Californian Environmental
nvironmental Protection rotection Agency gency
The University of Florida, the City of Gainsville and Gainesville Regional Utilities
partnered with the EPA in order to work on a deconstruction research project. The
work involved deconstructing a typical Florida wooden-framed house and effectively
utilising the constituent materials in new construction projects. Estimations
suggested that if only 60% of materials were recovered this would result in diverting
27 tons of waste from landfill. 1141
Prevention Prevention Stimulating Stimulating Programme Programme ( (PRESTI ( PRESTI PRESTI) PRESTI )
As by far the largest part of industrial waste in Flanders is generated by SMEs, they
are a useful target group. SMEs usually lack the required knowledge and know-how to
understand the costs and benefits of waste prevention, and how it helps in saving raw
materials and workload, and therefore they need to be supported by these external
instruments to make progress in the field of waste prevention.
The first PRESTI programme financed 32 projects and as a result, reached 15,262
enterprises out of a total of 40,505 potentially reachable enterprises. The benefits of
the programme were a higher awareness and knowledge level on prevention.
Research on the effectiveness of the PRESTI 2-programme, showed that 2,000
enterprises were positively affected by the programme. 13 projects were executed.
PRESTI 3 supported 30 SME’s.
More than 300 enterprises participated in the PRESTI 4 programme. Even though the
PRESTI 4 programme ended, most provinces continue with the ‘Environmental
Charter’ themselves, keeping the original logo.
No evaluation is yet available for PRESTI 5.
60.10 Costs of Administering Fund
A variety of methods for administering the funds have been described but no
information could be identified which gave an approximation of the administrative
1140 CIWMB (2001) CIWMB Grants Database Reports, Available:
http://www.ciwmb.ca.gov/Grants/Reports/ByCycle.asp
1141 United States Environmental Protection Agency (2002) OSWER Innovations Pilot Building
Deconstruction and Reuse, Available: http://www.epa.gov/oswer/docs/iwg/Deconstruction.pdf
International Review of Waste Policy: Annexes

costs involved. However, typically these are a small proportion of total funding
awards, or at least, they should be. Having said that, as part of the administration, it
is important to evaluate projects. This should be seen as an integral part of the fund’s
administration.
60.11 Advantages & Disadvantages of Environmental Taxation &
Centralised Public Finance
To have a fund/and or organisation which is set-up to offset the impacts of an
increase in environmental taxation is commonplace. It is a gesture which seeks to
soften the impact of the tax increase to the private sector through directly
demonstrating a positive impact the tax increase has had, e.g. the new fund or new
organisation. This use of hypothecated resources can lead to a situation whereby
money is allocated in a far less rigorous way than if it had come from central funds,
where a far wider number of stakeholders would have to understand the value of the
project in order to agree to allocating the money. It has been demonstrated (Section
60.3) that within ongoing funds, and grant-funded organisations, money can be
allocated to the same organisation repeatedly; it often has to be allocated within a
particular timeframe; and the evaluation information widely available is from an
internal source and therefore lacks independence. Although these are broadbrush
generalisations it is fair to say these problems are much less likely to occur where
money is being allocated from a central pot.
There are further issues with setting up an organisation or a fund which is directly
associated with an environmental tax. The likely justification for the establishment of
the organisation will be to combat the environmental problem which is being taxed, in
order to change behaviour in some way. In theory, a sign that the fund has achieved
its overall aim will be the reduction in available funding from the environmental tax,
leading to reducing/ending the fund or downsizing/closing the organisation. However,
as funds and organisations become established this becomes a very unlikely
scenario. Unless the focus of the work funded continually evolves money could be
being spent in highly inefficient ways due to a routine which has emerged.
It is possible that alternative approaches, other than grant-funding, may be strongly
supported by the private sector. For example, a ‘tax shift’ change, which has revenue
neutral implications, uses an environmental tax as a mechanism to encourage a
change in behaviour away from negative actions, whilst encouraging positive actions
through a tax reduction elsewhere, e.g. income tax.
This review has demonstrated the barriers which are commonly in place when trying
to evaluate the funds and has identified some key positive aspects of grant funding.
As such, it is felt that a key approach to ensuring the efficiency and effectiveness of a
grant fund is measurability, and alongside this transparency. The overall aim of the
fund must be clear. In order to know how close the fund is to meeting the overall aim
the action taken must be measurable and strict guidance must be kept to in order to
ensure continuity and accuracy of the measurement. This is fundamental to
understanding the impact that the fund has, in order to then independently evaluate
its success.
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60.12 Lessons Learned
The Flemish Prevention Stimulating Programme (PRESTI) highlights the following
lessons learned:
927
� Surveys show a general raise in consciousness regarding waste costs and the
environmental impact of products, particularly within industry.
� The impact of the different awareness and education programmes and
instruments is difficult to measure. Often no clear targets are set;
� SMEs are a central target group because they often lack knowledge and knowhow
and they are responsible for a large fraction of the industrial waste;
� The effectiveness of the instruments largely depends upon their practical
nature and the ease-of-use;
� The largest motivating driving force for preventive actions is the saving of
costs, more than the environmental awareness; and
� Strict monitoring and continuous improvement remains necessary to keep the
instruments successful.
Prerequisites for introduction of PRESTI are considered to be:
� Waste prevention should be embedded in the legislation;
� Good monitoring structures are required;
� A strong administrative backbone should support the instruments; and
� Support from the industry intermediates is necessary.
Rather few good examples of evaluations of other award programmes could be found.
60.13 Concluding Comments
The weaknesses of grant funding streams tend to be as follows:
� Frequently, grants are awarded hastily and without sufficient consideration of
the time required to prepare quality bidding documents and to allow for the
support to have its effect. This can result in low quality bids being prepared;
� Awarding bodies rarely hold on to their money. Awards making bodies are
often under pressure to disburse the whole pot of money. However, in our
experience, it would often be better for award making bodies to hold on to
their money where bids / applications are of low quality. Such bids rarely result
in quality projects. The corollary of this is that award making bodies should not
be under pressure to disburse money at all costs. Rather, care should be
taken to structure the process such that the chances of receiving quality bids
are maximised;
� In line with what is suggested in the OECD Principles, insufficient additionality
is obtained for the spend. In other words, the projects funded may have gone
ahead anyway, or could have done so without grant funding;
� Grant funding is sometimes used for projects which should not be supported
by grants. This may even place a break on policy development if it implies that
the polluter pays principle is not respected;
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928
� Rules regarding the split between capital and revenue spends are often rigidly
applied;
� Rules regarding the timing of spend are often unrealistic and put bidders off;
� In the case of hypothecated, or ear-marked revenue streams, there may be a
tendency to engender inefficiency in the projects sponsored. This is
particularly the case where projects become ‘favoured’ under a fund;
� In the case of projects supported by hypothecated tax revenues, care has to
be taken, when tax revenues increase, to ensure that funds do not simply
support ‘more of the same’. This can lead to funds being wasted through
duplication and inefficiency;
� It probably makes sense to ensure that grant awarding bodies who are seeking
to support a specific sector are well co-ordinated, and preferably, one and the
same entity. This can prevent duplication, as well as helping to build up
expertise in the evaluation of bids and awarding of funds;
� Grant awards are often poorly monitored, and evaluations tend to be selfserving.
Some experience in the UK suggests that different ‘delivery bodies’
have sought to publicise claims of their efficacy which are not obviously
substantiated by robust evidence, principally as a means to create the case for
further funding support. Care needs to be taken to make evaluation processes
clear and meaningful so that lessons can be learned to improve value for
money in subsequent funding rounds;
� Evaluation is crucial. This is public money, and as such, should be accounted
for properly. The evaluation should take place against clear criteria. Cases of
quality, independent evaluations of schemes are relatively rare. There has, as
far as we are aware, been no evaluation of the Environment Fund, though
some schemes within it have reported on their activities. It goes without saying
that fund evaluation should not be undertaken wholly by those whose
schemes have been supported;
� There may be a tendency for grant funds to ‘over-support’ projects, especially
where a general pool of bids is rather poor, or where those making the award
are insufficiently knowledgeable to judge the likely costs of projects (and what
represents value for money). Where awards are being made, it is important to
involve people who have an understanding of costs and value for money
issues;
� Those making grant awards frequently allow private sector partners to be less
than open with their accounts, even though, in some cases, the principle of
the funding might be that the project would not have been viable without
support. The cloak of ‘commercial confidentiality’ should not extend to the
accounts of projects which rely on public support for their existence, at least
where the awarding body is concerned. Grant awarding bodies need such
information to improve their understanding of costs in the areas they seek to
make awards;
� Grant funding can be too ‘ad-hoc’. Some services, which might appear
‘superfluous’, but which are actually essential and good value for money,
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929
might be axed in times of funding cuts. Arguably, such services should not be
‘grant funded’, but where they are, longer-term commitments should be made,
alongside detailed delivery plans and reviews to ensure efficiency of delivery.
This also highlights the role of evaluation in seeking to ensure that priorities
are understood;
� The flip side of this is that projects which are supported should, where it is
reasonable to expect this, be capable of continuing beyond the grant funding
period. This is especially important with support for fledgling waste projects.
Projects need to be able to demonstrate that there is a realistic prospect for
continuing beyond the period where grant money is spent;
� As public funding the positive outcomes are very often described in case
studies of each funded project and readily available on the funding body’s
website. However, publication of raw data is lacking. Also, although it is
considered very likely that funding bodies assess the effectiveness of their
funding stream no evidence of this type of report being made publicly available
has been found;
The variety of schemes that are run, in terms of size of the fund available, the quality
of applicants and the funding rate, makes evaluating grant funding in generic terms
challenging. This would infer that looking at specific cases is a more effective
evaluation method, and in theory this may be the case, but the lack of available data,
due to funding body’s reluctance to release specific details, makes this impossible.
With regards to the Environment Fund in Ireland feedback from the waste
management industry suggests that there is a lack of support towards the private
sector, despite there being no barriers in the legislation in funding private operators.
Instead, the fund has developed into a source of money mainly for public sector
projects or those of other bodies.
International Review of Waste Policy: Annexes

TECHNICAL ANNEXES
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61.0 Appraisal of Residual Waste Treatment
Options
Options appraisal can be achieved through using both quantitative and qualitative
assessment approaches. The merits and drawbacks of different approaches are the
subject of some considerable debate.
There is a clear tendency in most areas of public policy to favour, increasingly,
quantitative appraisal of options. Policies are increasingly subjected to Regulatory
Impact Assessments (RIAs), or to Extended Impact Assessments (EIAs), and there is
considerable emphasis placed upon quantitative evidence which can be used to
support (or indeed, reject) the case for a particular policy proposal.
61.1 Assessment Approaches
In the field of waste management, two particular approaches to quantitative
assessment are prominent. They are life-cycle assessment (LCA) and cost-benefit
analysis (CBA). These two approaches have both merits and shortcomings, and these
are discussed below.
61.1.1 Life Cycle Assessment
The approach of LCA is based upon quantification of the flows of pollutants as a
means to understand their impact upon the environment. The aim is to estimate the
effect of the options being considered (the scope of the study is usually defined, as
are the system boundaries) upon the environment by aggregating the flows of
pollutants across the whole life-cycle. Once the pollutants have been aggregated,
weightings are applied to them to estimate the relative contribution of the options to
different impact categories (such as global warming, air acidification, aquatic toxicity,
etc.). Some of LCA’s main flaws were laid out over a decade ago by Ayres, who argued
that, ‘LCA has no (or even negative) utility if the underlying physical data are wrong
with respect to critical pollutants.’ 1142 The obvious truth content of this statement
must be set against the enormity of the challenge facing any LCA practitioner,
especially one who is examining a municipal waste management system.
Any municipal waste management system is potentially complex. The options
available to a municipality include:
931
� Options in respect of collection systems:
o Which materials to collect separately?
o With how many passes?
o With or without a requirement for subsequent mechanical separation?
o In which vehicles?
1142 R.U. Ayres (1995) Life cycle Analysis: A Critique. Resources, Conservation and Recycling 14, 199-
223
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o At what frequency?
o In what type of container?
o With what type of incentive?
o On what rounds?
� Properly understood, collection systems need to consider each of these
separately, not as though they were discrete questions demanding separate
answers;
� Options in respect of transfer points for subsequent bulking / onward transfer
/ treatment;
o How many will there be?
o Where should they be located?
Once again, these questions are connected to other questions concerning the nature,
scale and type of treatment option to be used (ideally, the materials being collected
are either treated where they are ‘bulked up’, or they are bulked up in such a way as
to optimise the onward transport for subsequent treatment);
� Options in respect of the treatment of materials;
o Will any materials be composted at home?
o Which materials will be re-used, and if so, to what use will they be put?
o What type of mechanical separation technique will be used for dry
recyclables if any?
o If biowastes are being collected separately, will the treatment be
aerobic or anaerobic?
� If aerobic:
• Will it be enclosed, or open air?
• If enclosed, what type of technology will be used?
• How long will the material be treated for?
• What type of abatement equipment of exhaust gases will
be used?
� If anaerobic:
• What type of treatment will be used?
• What type of abatement equipment will be used?
• Will the residue be treated in an aerobic phase after
being digested?
• How will waste waters be dealt with?
o How will residual waste be treated?
� Sent untreated to landfill?
� Sent
� Options in respect of the products manufactured from materials collected for
recycling / composting / digestion
o Are recovered recyclables manufactured into the same products from
which they were derived?
o Where will this happen (how far will they travel?);
o To what use will compost / digestate be put, and what does this imply
for ‘avoided products’?
� Options in respect of energy generation;
o Will biogas from landfills / digesters be used as:

933
� Biogas for vehicle fuels?
� Electricity generation?
� Heat generation?
� Combined heat and power?
� Use in hydrogen cells?
o Will combustion / thermal treatment processes generate:
� Electricity?
� Heat?
� Combined heat and power?
� Syngas for chemical synthesis (thermal treatment)?
� heat, syngas, etc.)
o Where RDF is produced, will it be used for:
� Combustion in a fluidized bed incinerator
� Combustion in a cement kiln
� Combustion in a power station
� Options in respect of residues from thermal processes?
The point being made is that there are an almost infinite number of possible
arrangements (and the possibilities are increasing in number all the time). So Ayres’
apparently obvious statement becomes all the more significant when the sheer
complexity of the problem being addressed is understood.
The weaknesses of LCA in the context of waste management options appraisal have
been detailed elsewhere. 1143 Briefly, the key issues are:
� The accuracy / validity of the weightings attributed to pollutants in impact
assessment categories;
� The tendency to seek datasets for the sake of completeness without
necessarily assessing the quality of the data, its vintage, or its relevance;
� Insensitivity to location of the emissions (and hence, the potential receptors);
� Insensitivity to time (implying that effects related to concentration are not
captured);
� Inability to account for effects not related to the flow of pollutants (such as
disamenity); and
� Aggregation of impacts across impact assessment categories.
Each of these issues raises problems for the practitioner. In addition, it is clear that
some assumptions have a significant effect on results. Some of these are discussed
below with regard to CBAs, which are similarly affected by the assumptions made.
1143 D. Hogg (2004) Costs and benefits of Bioprocesses in Waste Management, in P. Lens, B.
Hamelers, H. Hoitink and W. Bidlingmaier (2004) Resource Recovery and Reuse in Organic Solid
Waste Management, London: IWA Publishing, pp.95-121.
International Review of Waste Policy: Annexes

61.1.2 Cost benefit Analysis
Cost benefit analysis takes a somewhat different approach. In cost benefit analysis,
the underlying philosophy is to translate impacts into a common metric – that of
money. Economists are often keen to make the distinction between valuing
somewhat controversial things – for example, life, or landscapes – and valuing
preferences for (or against) them. At one level, therefore, the approach would appear
to have something in its favour relative to LCA in that it enables various different
types of impact across different media quite readily aggregated in a common,
monetary, unit. Another positive feature of CBA is that it enables cost to be included
in the analysis. LCAs clearly cannot do this without significant modification.
Through the process of discounting, time is accounted for in CBA. This takes on
particular significance when comparing different treatment options with significantly
different profiles relating to emissions over time. This is a consideration that is not
available to LCA practitioners, though many LCA practitioners appreciate the
significance of time.
CBAs also tend to be more concerned with impacts than are LCAs. As mentioned
above, LCAs are insensitive to issues of pollutant concentration. In order to evaluate
impacts, economists rely upon credible dose-response relationships. This also
requires some understanding of how emissions from a given process can be
translated into concentrations to which receptors are exposed. A major plus point,
therefore – the attempt to estimate actual impacts – immediately becomes a
weakness. There are relatively few pollutants for which quality dose-response
relationships exist. For others, the way pollutants follow particular pathways is not
especially well known so even the exposure term is unclear. For some pollutants,
even where exposures are well known, the dose-response relationships are subject to
uncertainty (sometimes radically so, as exemplified by differences in US and EU
perspectives on the threshold at which dioxins present a hazard to human health).
On top of all this, even for those pollutants whose fate is relatively well-known (so the
exposure term is relatively well understood), and those for which the dose-response
relationships are tolerably well understood, there remain issues associated with the
valuation process itself. Many outside the economics discipline criticise the approach
to ‘valuing nature / health’ as ethically indefensible, though economists respond that
choices as to how to make best use of scarce resources must be made. However,
within the discipline, debate continues on issues such as how to value mortality and
morbidity, what discount rate to use, etc.
61.2 External Costs of Residual Waste Treatment
The analysis of costs and benefits associated with residual waste treatment options is
a subject which has been discussed in a range of studies. Many of these look not just
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at landfill and incineration, but at recycling too. However, very few have looked at
other non-landfill treatments for residual waste. 1144
Some of the key assumptions which influence the outcomes of such appraisals are
outlined and discussed below. This discussion will highlight important methodological
issues, serving to contextualise the subsequent review of specific studies.
61.2.1 Methodological Issues Common to External Cost Appraisal of all
Options
In what follows, issues relating to the calculation of external costs of different residual
waste options are considered. Firstly, a number of general comments are presented
on the methodology applied in studies assessing of external costs.
1) Most studies seem to use an approach based upon the use of unit damage costs
(UDCs) to assess the harm caused by specific pollutants. Relatively few make use
of ‘bottom up’ approaches in which the impact of emissions are modelled through
dose-response functions applied to the locality in which an activity takes place.
2) If the study is ‘top down’, the choice of unit damage costs becomes critical.
Similarly, if the study is ‘bottom up’, the choice of dose-response functions, the
way the dispersion of pollutants is modelled, and the nature of the location
assumed for any activity all become important. The scope of the analysis (the
range of the pollutants modelled) is of obvious significance in both cases. There
do appear to be some discernable trends in this regard:
� The range of pollutants to which a damage cost is assigned appears to be
expanding over time. Earlier studies tended to focus on emissions of GHGs,
NOx, PM and SOx, whilst more recent studies have become more ambitious in
their attempt to capture a range of externalities. A problem here is that neither
the unit damage costs, nor the dose response functions which typically
underpin studies from which UDCs are derived, are known with certainty.
There remains considerable uncertainty concerning the effects of a range of
pollutants upon human health. It barely needs stating that the long-term
consequences of some activities have barely been touched upon;
� The significance of specific types of pollutant in the overall assessment of
damages appears to be changing. GHGs may be becoming more important,
even as the damages associated with SOx, NOx, PM10, etc. are being
downplayed. PM2.5 may become more important in analyses as awareness
1144 J.C. Powell, David Pearce and Inger Brisson (1995) Valuation for Life cycle Assessment of Waste
Management Options, CSERGE Working Paper WM 95-07; Coopers & Lybrand, CSERGE and EFTEC
(1997) Cost-Benefit Analysis of the Different Solid Waste Management Systems: Objectives and
Instruments for the Year 2000, Luxembourg: Office for Official Publications of the European
Communities.); Broome, E., P. Vaze and D. Hogg (1999) Beyond the Bin: the Economics of Recycling,
Final Report to Waste Watch.; COWI (2000) External Costs of Landfill and Incineration, Final Report to
the European Commission; Nolan ITU (2004) TBL Assessment of Garden Organics Management, Final
Report to the NSW Dept of Environment and Conservation, Sustainability Programs Division, May
2004.
935
International Review of Waste Policy: Annexes

increases of the significance of the distinction between sub 10 micron
particles;
� Some attention is being given to the potential health effects– though we are
not aware of any study which has attempted to make an assessment of the
associated external costs – of bioaerosols from biological treatment plants;
� The focus of the majority of studies – or at least, of the valuation element - is
on the emissions to the atmosphere associated with different processes. The
effects of processes on, for example, water pollution are generally not
explored. This is of interest since few studies apply any discount factor to the
emissions to atmosphere from processes which generate emissions over
extended periods of time (such as landfilling, composting, anaerobic digestion,
mechanical biological treatment, etc.). If a zero discount rate is being
(implicitly) applied, it would be consistent to consider the emissions from
landfills (and landfilled residues from incineration plants) over the longer term.
Recent life-cycle studies suggest that if such emissions were, indeed, taken
into account, they might become decisive in any analysis of environmental
performance, especially if a zero discount rate is applied; 1145
3) Following from the above few studies appear to have applied a non-zero discount
rate to account for the fact that the emissions from some processes occur over an
extended period of time. The use of a non-zero rate would tend to have the effect
of reducing, in relative significance, the following externalities:
� Atmospheric emissions from landfills, MBT facilities, compost facilities,
anaerobic digestion facilities;
� The benefits associated from the capture of methane from landfills for energy
generation;
� Emissions to water and land from the landfilling of residues, whether these be
from incinerator bottom ash, incinerator air pollution control residues,
untreated refuse, MBT-treated residues, etc. However, only a few studies
appear to have attributed any environmental cost to these; 1146
� Emissions to air, land and water from the application of the products of
biological treatment (i.e. composts or digestion residuals) to land, as well as
those from any ‘displaced products’.
4) The way in which the flux of greenhouse gases is handled in the non-zero discount
rate case may be very important for the final analysis, but extremely difficult to
1145 See S. Hellweg (2000) Time- and Site-Dependent Life-Cycle Assessment of Thermal Waste
Treatment Processes, Dissertation submitted to the Swiss Federal Institute Of Technology. AWS, IFIP &
GUA (2000): Bewertung abfallwirtschaftlicher Maßnahmen mit dem Ziel der nachsorgefreien Deponie
– BEWEND. Unpublished case study Institute for Water Quality and Waste Management TU Vienna,
Institute for Public Finance and Infrastructure Policy TU Vienna & Gesellschaft für umfassende
Analysen GmbH, Vienna, Austria.
1146 See Nolan ITU (2004) TBL Assessment of garden organics management, Final Report to the NSW
Dept of Environment and Conservation, Sustainability Programs Division, May 2004; G. Döberl, R.
Huber, P.H. Brunner, M. Eder, R. Pierrard, W. Schönbäck, W. Frühwirth and H. Hutterer (2002) Longterm
assessment of waste management options - a new, integrated and goal-oriented approach, Waste
Management & Research, 20 (4), pp. 311-327; E. Dijkgraaf, and H. Vollebergh (2004) Burn or bury? A
social cost comparison of final waste disposal methods, Ecological Economics, 50, pp.233-247.
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handle. The choice of discount rate, as well as changing the sensitivity of the
damages assessed to the time period over which those emissions occur, should
also change the unit damage costs associated with the key climate change gases
and their relative significance since these gases have an effect which occurs over
an extended period, and their residence times in the atmosphere vary.
5) In bottom up studies, the value placed upon the different end-points associated
with the effects of different pollutants will affect the analysis. Different studies
resort, for example, to the use of values based upon the value of a statistical life
(VSL), whereas others use the value of life-years lost approach (VLYL). Similarly, in
top-down studies, the unit damage costs are likely to be high or lower (other things
being equal) depending upon whether the study from which the unit damage costs
are taken made use of VSL or VLYL; 1147
6) Where a study considers the implications of energy recovery, and makes an
assumption that the energy generated ‘displaces’ another source of energy, the
net effects of the energy generation depend critically upon which source of energy
the study assumes to be displaced. The ‘dirtier’ the displaced source, the more
advantageous (in the analysis) the generation of energy appears.
These issues are some of the critical ones in existing studies on the external costs of
waste management. They explain much of the variation between studies.
61.2.2 Landfill
Where landfilling is concerned, the majority of studies concentrate on air emissions.
Of these, methane has, unsurprising, received most attention. Relatively few studies
have sought to look at an expanded range of emissions, or at emissions to other
media. In the external costs literature, it is usually assumed that leachate is well
managed so that there are no relevant problematic emissions to land and water. This
is a contentious (though simplifying) assumption, and it is almost certainly incorrect in
the longer-term. 1148
As regards methane emissions, the quantity of methane released to the atmosphere
depends upon:
937
� The quantity generated in the landfill;
� The quantity collected by gas collection systems;
� The quantity of the uncollected methane which is oxidised as it passes through
the cap, or its leachate; and
� The efficiency of combustion processes in converting methane to carbon
dioxide and carbon monoxide
Each of these variables (with the possible exception of the last) is contested not least
because each of the parameters is likely to vary over time (and space).
1147 Value of Statistical Life or Value of Life Years Lost.
1148 S. Hellweg (2000) Time- and Site-Dependent Life-Cycle Assessment of Thermal Waste Treatment
Processes, Dissertation submitted to the Swiss Federal Institute Of Technology.
International Review of Waste Policy: Annexes

Landfills also emit other gases. Those which are generated in the early stages after
materials are deposited in the landfill are not so well characterised as those collected
from the landfill gas collection systems. Yet it seems reasonable to assume that in
the period during which degradation is aerobic, that emissions of various pollutants
will be significant. Most notable here may be ammonia emissions, which tend to
occur early in degradation processes, and which appear to be associated with
considerable damages. It might be added that in the UK, studies have hinted at a link
between landfills and the incidence of birth defects in their vicinity. However, the
strength of this association is not considered by government to be sufficiently strong
to support any causal link, though the evidence is at least suggestive. 1149
Landfills also lead to disamenity associated with dust, noise, odour, litter, etc. There
have been a number of studies addressing the issue and one which sought to
establish a meta-analysis of existing studies. The transferability of these results is not
clear.
As discussed above, the issue of discounting should be important in the context of
emissions from landfills. However, this issue has not been given the attention it
deserves from an economic perspective. Indeed, an Austrian study appears to have
assumed a zero discount rate in the analysis even though different time horizons for
the analysis were considered. 1150 Indeed, to our knowledge, all studies which have
assessed the external costs of landfill have applied a zero discount rate. This is true
of a recent UK study, even though the agreed approach of UK Government is to use a
discount rate which declines, over time, from its early rate of 3.5% per annum (but
not falling to zero). 1151 Where life-cycle studies are used to provide the emissions
inventory, the use of a zero discount rate assumption requires a decision to be made
about what the time horizon should be for time-dependent processes. In the absence
of a discount rate, this decision becomes arbitrary, and it usually made on an
arbitrary basis.
As discussed previously, to the extent that landfills generate energy, the issue of
‘which source is being displaced’ assumes considerable relevance.
61.2.3 Incineration
As with other treatments, the focus of external costs of incineration has been on air
emissions. Different studies seek to capture differing ranges of pollutants. Evidently,
the coverage of pollutants will affect the analysis.
1149 See Paul Elliott et al (2001) Risk of Adverse Birth Outcomes in Populations Living Near Landfill
Sites, British Medical Journal, 2001, Vol 323, pp.363-68. P. Elliott, S Richardson, J J Abellan, A
Thomson, C de Hoogh, L Jarup, and D J Briggs (2009) Geographic density of landfill sites and risk of
congenital anomalies in England, Occup. Environ. Med. 2009, Vol. 66, pp.81-89.
1150 G. Döberl, R. Huber, P.H. Brunner, M. Eder, R. Pierrard, W. Schönbäck, W. Frühwirth and H.
Hutterer (2002) Long-term assessment of waste management options - a new, integrated and goaloriented
approach, Waste Management & Research, 20 (4), pp. 311-327.
1151 HM Customs & Excise (2004) Combining the Government’s two heath and environment studies to
calculate estimates for the external costs of landfill and incineration, December 2004.
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Other key variables of importance include the following:
939
� The emissions assumed to result from the incineration process itself –
incinerators (as with most treatments) are not completely homogeneous. For
example, with regard to NOx emissions (which are a source of secondary
particulates), some countries routinely require use of selective catalytic
reduction of NOx whereas many others do not (yet still may be able to meet
Incineration Directive standards using non-catalytic methods and flue gas
recirculation). Generally, incinerators’ performance needs to be understood in
the context of knowledge of the flue gas cleaning system and of the waste
materials received at the plant;
� the nature of the energy recovery process, and hence the degree to which
offsetting emissions can be attributed to the process. There appears to be a
marked difference in the performance of some Scandinavian facilities, where
the efficiency of heat recovery is very high, and those of the other EU Member
States where energy is usually recovered as electricity, with relatively low
efficiencies. At the same time, it is not entirely clear whether the higher energy
efficiencies possible where heat recovery is the objective should be deemed
more superior from an environmental standpoint since generally, more fuel is
required to generate a kilowatt hour of electricity than is required to generate
a kilowatt hour of heat. Much depends upon the avoided sources of each;
� the degree to which it is assumed that materials are recycled at the facility (for
example, steel and aluminium extracted from bottom ash, or bottom ash
recycled for use as construction material);
� the way in which landfilled residues are treated, particularly the air pollution
control residues which contain hazardous components, and possibly the
bottom ash also if this is also of a hazardous nature.
Another issue which may be important for the analysis – especially if impacts are
being discounted (as they should be) is whether the materials used in the
construction of the plant are included in the analysis. Incinerators are complex pieces
of engineering and they operate for around two decades. Whilst life-cycle studies
suggest a small proportion of overall burdens are associated with materials used in
construction, the application of a non-zero discount rate in a CBA might change this
considerably. Probably of lesser importance are the inputs to the process, including
gas cleaning chemicals.
Of relevance to this discussion is the fact that several countries have instated landfill
taxes in order to try to increase the costs of landfilling so as to drive materials away
from disposal. In theory, this ought to be based upon a view that disposal is ‘worse
than’ recycling. The majority of cost-benefit studies tend to support this perspective
for most dry recyclables. 1152 Interestingly, however, fewer countries have applied
1152 Inger Brisson and Jane Powell (1995) Dump or burn? – the assessment of social costs and
benefits of waste disposal, CSERGE, University College of London and University of East Anglia; J.C.
Powell, David Pearce and Inger Brisson (1995) Valuation for life cycle assessment of waste
management options, CSERGE Working Paper WM 95-07; J.C. Powell, A.L. Craighill, J.P. Parfitt and R.K.
Turner (1996) A lifecycle assessment and economic valuation of recycling, Journal of Environmental
International Review of Waste Policy: Annexes

taxes on incineration despite the fact that much of the literature suggests that unless
heat is recovered with a high level of efficiency, the external costs of incineration are
not so different from those of landfills. 1153 Other studies are more positive regarding
incineration, though neither of the two referenced below applies a positive discount
rate in the analysis). 1154
61.2.4 Other Residual Treatments
There are not many studies appraising the options in respect of other residual
treatments. A summary of the issues relating to appraisal of these treatments is given
below.
61.2.4.1 Advanced Thermal Treatment
ATT systems are likely to be affected by similar considerations as incinerators. Key
differences may be as follows (and these differences are likely to be specific to
specific configurations);
1. Some systems may be configured so as to produce syngas from waste materials
rather than to combust the gas and generate energy. This means that the effect is
not to displace energy per se, but other feedstocks in chemical synthesis. To the
extent that these feedstocks are produced using processes which are
environmentally harmful, such substitution will be beneficial;
2. Although some incinerators make use of post-treatment processes to minimize
the impacts of landfilling air pollution control residues, in some high temperature
processes, the vitrification of such residues is integrated into the process. This
would imply that to the extent that landfilling of such residues without such
Planning and Management, Vol 39 (1), pp.97-112; I.E. Brisson (1997) Assessing the Waste Hierarchy
– a Social Cost-Benefit Analysis of Municipal Solid Waste Management in the European Union,
http:/www.akf/eng/waste1.htm; Coopers & Lybrand, CSERGE and EFTEC (1997) Cost-Benefit Analysis
of the Different Solid Waste Management Systems: Objectives and Instruments for the Year 2000,
Luxembourg: Office for Official Publications of the European Communities.); E. Broome, P. Vaze and D.
Hogg (1999) Beyond the bin: the economics of recycling, Final Report to Waste Watch.; Nolan ITU
(2004) TBL Assessment of garden organics management, Final Report to the NSW Dept of
Environment and Conservation, Sustainability Programs Division, May 2004.
1153 COWI (2000) External Costs of Landfill and Incineration, Final Report to the European Commission;
HM Customs & Excise (2004) Combining the Government’s two heath and environment studies to
calculate estimates for the external costs of landfill and incineration, December 2004; E. Dijkgraaf,
and H. Vollebergh (2004) Burn or bury? A social cost comparison of final waste disposal methods,
Ecological Economics, 50, pp.233-247; E. Dijkgraaf and H. Volleberegh (2005) Literature review of
social costs and benefits of waste disposal and recycling, in (2005) Rethinking the Waste Hierachy,
EAI: Copenhagen, pp. 80-98.
1154 J-O, Sundqvist et al (2002) Hur skall hushallsavfallet tas omhand – utvardering av olika
behandlingsmetoder (How shall municipal solid waste be disposed – assessment of different
treatment methods) Stockholm February 2002. IVL report B 1462; G. Döberl, R. Huber, P.H. Brunner,
M. Eder, R. Pierrard, W. Schönbäck, W. Frühwirth and H. Hutterer (2002) Long-term assessment of
waste management options - a new, integrated and goal-oriented approach, Waste Management &
Research, 20 (4), pp. 311-327.
940
29/09/09

treatment may give rise to damages, some reduction in the external costs of
landfilling such residues could be achieved;
3. As regards the energy efficiency of such processes, some have taken the view that
unless gas engines are used to generate energy from the energy carrying gases
derived from pyrolysis / gasification, the net conversion of energy may be less
than is the case with conventional mass burn incineration. Energy efficiencies are
significant in the analysis, the more so if it is assumed that the source of energy
which might be displaced is ‘less clean’. If gases are used in co-firing of power
stations, higher efficiencies may be achieved;
4. The design of the process itself may lead to lower emissions into raw flue gas with
the result being that either emissions of cleaned flue gas are, other things being
equal, improved relative to incineration, or that the expenditure on flue gas
cleaning to achieve a given standard may be lower with ATT than with
conventional incinerators.
It should be made clear that because the processes being considered tend to be
proprietary ones, the above comments are intended to apply to ‘possible
configurations’, and they do not necessarily apply equally to all ATT processes.
Furthermore, as stated earlier, the track record of ATT facilities for treating raw
residual waste is not well established in Europe.
61.2.4.2 MBT (basic stabilisation)
Basic stabilization systems rely, in the main, on reducing the biodegradability of
material prior to landfilling. In this system, it is assumed that following mechanical
treatment, the waste materials are subjected to an aerobic stabilization process with
the aim being to reduce the potential for gas generation when the material is
deposited in, or possibly on, a landfill. Some ferrous metals and perhaps some nonferrous
metals may be extracted during the process, but the mass of material
landfilled is essentially equal to the mass of material received minus the loss of
moisture and the mass loss due to the degradation of, principally, more rapidly
degraded carbon fractions.
The degree to which this represents an improvement on sending materials to landfill
in an untreated form depends upon:
1. The extent to which one believes that landfills fail to operate in a well-behaved
manner, in particular, whether one believes that they:
a. Do generate problematic emissions before gas capture systems are
effectively operational;
b. Fail to capture the majority of methane emitted over the time during
which emissions from the waste occur;
c. Generate relatively little energy from waste as a result;
d. Generate problematic leachate;
2. Whether the level of stabilization attained through the process is sufficient to
ensure that residual methane emissions from landfilled waste are effectively
reduced to close to zero (and this may imply active management);
3. The level of abatement of, in particular, ammonia and more harmful VOCs (as
opposed to less harmful ones emitted by biofilters) during the stabilization
process; and
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International Review of Waste Policy: Annexes

4. The degree to which materials (especially metals) are recovered, and recovered in
a useful form for recycling; and
5. The degree to which other potential hazards associated with landfills are likely to
be problematic in future, and he degree to which stabilization might minimize
these.
Each of these issues influences the degree to which stabilization contributes
positively to the outcomes.
Examining one of these more closely, it is clear that as regards greenhouse gas
emissions (GHGs), when compared to landfilling of untreated waste, basic
stabilization processes, with residues being landfilled, exhibit the following
performance characteristics:
� Less of the carbon is transformed into methane, and the majority is transformed
into carbon dioxide, a far less potent greenhouse gas. Other things being equal,
this means that the greenhouse gas emissions from the process (including the
landfilling of the residues) will not be so harmful;
� The absence of methane generation for subsequent capture for energy recovery
implies no displacement of fossil carbon by the stabilization process by means of
energy generation. Other things being equal, this means that the greenhouse gas
emissions from the process (including the landfilling of the residues) will be more
damaging than for untreated landfilling;
� On the other hand, stabilization processes would, typically, recover some
materials such as steel even in their most basic configuration. This would imply
recovery of energy embodied in materials, improving the greenhouse gas balance
of the stabilization process;
� Finally, the degradation of carbon is likely to occur more quickly under the more
controlled conditions in a stabilization process. Hence, the time profile of
emissions is such that proportionately more of the emissions occur earlier in time.
The effect of discounting will tend to make the impact of these earlier emissions
more important. Consequently, this would tend to increase the impact of the
stabilization process relative to landfill of untreated waste where GHGs are
concerned.
It can be seen that a fairly complex range of issues affects performance in this one
area. What is clear, however, is that in the overall system – stabilization plus
landfilling – the majority of GHG emissions is shifted into the stabilization process.
The emissions in the landfilling phase are likely to be less significant, and are likely to
occur further into the future (because the remaining carbon is, by definition, of a
more slowly degrading nature). Consequently, it seems reasonable to argue that
landfilling stabilized waste is less harmful than landfilling treated waste.
61.2.4.3 MBT (dry stabilisation, RDF to cement kiln)
In this configuration, it is assumed that input materials are first treated mechanically
(to render the material easier to treat aerobically) and then subjected to a process
where the material is dried using both the heat from aerobic degradation processes,
and the air from the aeration of the total mass of material.
The performance of dry stabilisation processes are likely to be improved, in relative
terms, if:
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1. As described above (for basic stabilisation), the landfilling of untreated wastes
performs relatively poorly;
2. Again as described above, the abatement of ammonia and VOCs is efficient;
3. Because the energy recovery process gives rise to ash and air pollution control
residues in the form of clinker, the performance relative to incineration is
improved where it is believed that landfilling of air pollution control residues from
incinerators gives rise to environmental damage;
4. Where the process of energy recovery through RDF utilisation clearly displaces
less clean energy sources, this may improve relative performance. This issue is
not straightforward as many cement kilns are beginning to utilise a range of
wastes (so the time may come where one waste simply replaces another, at the
margin);
5. Where the cement kiln itself is equipped with quality flue gas abatement. This may
be of concern regarding more volatile heavy metals such as mercury, though
equally, the significance of this must be contextualised by the mercury content of
incoming wastes;
6. Some materials (e.g. ferrous metals, non-ferrous metals) are recovered with the
ability to substitute for primary materials whose production incurs environmental
damages;
7. Any landfilled residues are biologically stable.
These issues are among the key variables likely to affect the environmental
performance of a treatment / disposal method based around dry stabilisation.
Evidently, the nature of input wastes is also important in determining the nature of,
for example, the RDF fraction which may be derived, and hence, the potential for, for
example, energy recovery through combustion of the RDF.
61.2.4.4 MBT (separation of some dry recyclables, AD of biowaste, and possibly
RDF to third party)
Several facilities are now in operation where the biological treatment aspect of the
MBT process involves anaerobic digestion (AD). Facilities utilising dry and wet AD
processes now exist. Evidently, in such processes, there may be advantages in
ensuring that the costs of the AD equipment itself are reduced through the separation
of a fraction consisting primarily of organic wastes suitable for digestion. This may
occur through, for example, using screen undersieves for the digester since, for
example, the food waste fraction of waste tends to be concentrated in small particle
size fractions.
As mechanical separation processes improve, it is becoming possible to consider
facilities where residual waste is treated:
1. Mechanically to separate out:
a. fractions for recycling. Fractions may include metals, glass, other inert
materials, and some plastics;
b. fractions for subsequent biological treatment;
c. fractions for subsequent use as an RDF;
2. Biologically (anaerobic), with a small size fraction being digested to produce
biogas;
3. Thermally, with an RDF fraction derived for subsequent use either in dedicated
waste facilities, or existing industrial facilities;
943
International Review of Waste Policy: Annexes

4. Biologically (aerobic), with residues being stabilised prior to landfilling /
landscaping (where of requisite quality).
Various different configurations are possible.
The relative performance of such facilities is likely to be quite good irrespective of the
assumptions made. The combination of materials recovery, energy recovery and
stabilisation of biodegradable fractions is likely to give favourable outcomes as long
as the abatement of relevant pollutants is efficient and as long as the materials
recovered are of sufficient quality to be put to use in ways which displace materials of
a similar quality to those being recovered.
The key issues for such facilities are likely to be their costs, and these will be
determined to a considerable degree by various policy-related instruments in future.
The fact that such processes are relatively new (albeit that digestion of mixed waste
has taken place for decades) is likely to mean that policies are not yet well-adapted to
accommodate them. Indeed, since they rely on various ‘outlets’ for their outputs,
there are risks associated with these technologies in the current policy environment.
It should also be said that such processes are still considered quite novel, and have
not been without their technical problems (so there is a technology risk to be
considered as well).
61.3 Relevant Studies
A number of studies have looked at the costs and benefits of waste treatments, but
few have looked at residual waste treatments other than landfill and incineration.
Accordingly, the majority of the studies presented here focus on landfill and
incineration. However, as shown in the list below, two reports assessing the costs and
benefits of MBT in Ireland are also reviewed.
Two of the major studies concerning the external costs and benefits of waste
management, focusing on disposal systems, were funded by the UK Government. The
studies are:
944
� The work underpinning the setting of the Landfill Tax, which majored on the
externalities associated with landfills and incinerators (the CSERGE et al
study); 1155 and
� More recently, the body of work leading to the derivation of figures by HM
Customs & Excise concerning the externalities of landfills and incinerators. 1156
1155 CSERGE, Warren Spring Laboratory and EFTEL (1993) Externalities from Landfill and Incineration,
London: HMSO.
1156 This body of work includes work on emissions and health effects by Enviros (Enviros, University of
Birmingham, RPA Ltd., Open University and Maggie Thurgood (2004) Review of Environmental and
Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes, Final Report to
Defra, March 2004), work on the external costs of waste management by Enviros and EFTEC (Enviros
and EFTEC (2004) Valuation Of The External Costs And Benefits To Health And Environment Of Waste
Management Options Final Report for Defra, December 2004) and a piece which brought together the
data concerning emissions from the first study and data concerning the unit damage costs for the
29/09/09

In addition to these UK focused studies, work undertaken elsewhere in Europe of
particular relevance includes:
945
� A literature review of social costs and benefits of waste disposal and recycling
(the Dijkgraaf & Vollebergh study), which challenges the assumption that the
waste hierarchy is always correct; 1157
� A study for the European Commission on the economic valuation of
environmental externalities from landfill disposal and incineration of waste
(the COWI study); 1158
The final reports reviewed relate to the impacts arising from the use of landfill,
incineration and MBT for residual waste.
� The first of these is a 2007 report for Greenstar on waste policy, planning and
regulation in Ireland by Eunomia and Tobin. 1159
� The second report, from 2008, by the same authors, for the same client,
focuses on the potential role of MBT in meeting Ireland’s waste targets. 1160
A forthcoming Regulatory Impact Analysis has been developed for both a levy on
plastic bags, and a levy on certain waste facilities. The study also considers the
external costs of the waste treatment options under consideration. However, the
studies mentioned in the work are all covered in this review (as well as some others).
61.3.1 CSERGE et al (1993)
This work was used in the run-up to the introduction of the Landfill Tax and was
influential in the decisions made concerning the level at which the tax should be
set. 1161 The aim was to understand the externalities associated with landfill and
incineration.
Although the study undertook a review of work carried out elsewhere in assessing
disamenity associated with landfills, these were omitted in the quantification of the
external costs. The study noted these could be ‘significant’ and therefore their
omission would affect the results. Brisson and Pearce later suggested that employing
benefits transfer techniques from US studies would make a figure of £160 (about
processes from the second study (see HM Customs & Excise (2004) Combining the Government’s Two
Heath and Environment Studies to Calculate Estimates for the External Costs of Landfill and
Incineration, December 2004).
1157 E. Dijkgraaf and H. Vollebergh (2005) Literature review of social costs and benefits of waste
disposal and recycling, in EAI (2005) Rethinking the Waste Hierachy, EAI: Copenhagen, pp. 80-98.
1158 COWI (2000) External Costs of Landfill and Incineration, Final Report to the European Commission.
1159 Eunomia and Tobin (2007) Waste Policy, Planning and Regulation in Ireland, Final Report for
Greenstar, Dublin, Ireland.
1160 Eunomia and Tobin (2008) Meeting ireland’s Waste Targets: The role of MBT, Final Report for
Greenstar, Dublin, Ireland.
1161 For a more detailed review of this study, see E. Broome, P. Vaze and D. Hogg (2000) Beyond the
Bin: The Economics of Waste Management, Final Report to Waste Watch.
International Review of Waste Policy: Annexes

£173 in 1999 terms) per household per annum not unreasonable for houses within a
4 mile radius of a landfill (which they also suggest is more or less equivalent to 3%
depreciation on house values). 11621163
The results of the study are shown in Table 61-1. Note that the study sought to
measure the external costs associated with ‘typical tonnes’ of waste being landfilled
or incinerated in different types of plant, and then averaged externalities across types
of plant to arrive at a UK figure. It is clear from these results that the relative rates of
energy generation from the two types of facility are crucial determinants of their
external costs as reported here. This is due to the significance of the pollution
displacement assumed to occur as a consequence of the energy generation.
The study assumed recovery of 664 kWh/tonne MSW for incineration and 79
kWh/tonne MSW for landfills with energy recovery. Interestingly, the more recent
study suggested figures of 581kWh and 203kWh respectively. 1164 If these figures had
been used in the 1993 study, then examination of the ‘pollution displacement’ figures
in Table 61-1 suggests that as a result of increased ‘pollution displacement’, landfills
with energy recovery would have shown no negative externalities, and incinerators
would have been attributed a reduced positive externality. Both results would have
moved closer to zero.
The external costs covered were:
• for landfill, emissions of CO2 and CH4, casualties as well as CO2, NOx and
particulate matter (PM) from transport of waste to the landfill, and reductions in
CO2, NOx, SO2, PM and CH4 from displaced energy sources. A limited attempt was
made to estimate leachate externalities whilst acknowledging the limitations of
the exercise; and
• for incineration, emissions of CO2, NOx, SO2, PM, casualties as well as CO2, NOx
and TSP from transport to the incinerator, and reductions in CO2, NOx, SO2, PM
and CH4 from displaced energy sources.
The ‘omission’ of other air pollutants might be important in such a study. The report
noted that ‘This component of economic damage is therefore left unvalued in the
current exercise, with the balance of probability being that such a value would be
close to zero or zero’. The statement was based upon the views of the 1993 RCEP
report on incinerators that comply with HMIP standards. There is a respectable body
of science which casts doubt upon this perspective.
1162 The lack of consideration of disamenity is more comprehensible when one sets the study in its
policy context. In informing the level of a landfill tax being levied on waste, the fixed rather than
variable nature of the disamenity externality could be used to justify not including the disamenity
externality.
1163 Inger Brisson and David Pearce (1995) Benefits Transfer for Disamenity from Waste Disposal,
CSERGE Working Paper WM 95-06.
1164 HM Customs & Excise (2004) Combining the Government’s Two Heath and Environment Studies
to Calculate Estimates for the External Costs of Landfill and Incineration, December 2004.
946
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Table 61-1: Externality Values for Landfill and Incineration (£/tonne waste other than disamenity)
Global pollution
947
CO2
CH4
Air pollution
International Review of Waste Policy: Annexes
L1 a L2 b L3 c L4 d I1 e I2 f
-0.32
(-0.08 - -0.87)
-2.36
(-0.86 - -5.40)
-0.46
(-0.12 - -1.27)
-1.36
(-0.45 - -3.32)
-0.32
(-0.08 - -0.87)
-2.36
(-0.86 - -5.40)
-0.46
(-0.12 - -1.27)
-1.36
(-0.45 - -3.32)
Conventional g n.a. n.a. n.a. n.a.
Conventional h n.a. n.a. n.a. n.a.
-2.55
(-0.69 - -6.70)
-2.55
(-0.69 - -6.70)
n.a. n.a.
-1.62
(-1.16 - -2.07)
-2.01
(-1.47 - -2.55)
-1.51
(-1.03 - -2.02)
-1.14
(-0.80 - -1.49)
Toxics n.a. n.a. n.a. n.a. Not est. Not est.
Transport impacts
Pollution g
Pollution h
Accidents
Leachate
Pollution displacement g
-0.09
(-0.05 - -0.16)
-0.10
(-0.06 - -0.17)
-0.23
(-0.13 - -0.33)
-0.45
(0 - -0.9)
0
-0.09
(-0.05 - -0.16)
-0.10
(-0.06 - -0.17)
-0.23
(-0.13 - -0.33)
0
+0.81
(0.45 – 1.54)
-0.38
(-0.10 - -1.06)
-0.46
(-0.14 - -1.19)
-0.55
(-0.31 - -0.79)
-0.45
(0 - -0.9)
0
-0.38
(-0.10 - -1.06)
-0.46
(-0.14 - -1.19)
-0.55
(-0.31 - -0.79)
+0.81
(0.45 – 1.54)
-0.23
(-0.11 - -0.52)
-0.26
(-0.12 - -0.57)
-0.20
(-0.11 - -0.29)
-0.45
(-0.11 - -0.93)
-0.42
(-0.15 - -1.03)
-0.33
(-0.18 - -0.48)
0 n.a. n.a.
+6.87
(4.30 –
+6.87
(4.30 – 11.93)

Pollution displacement h 0
Total
Total
Total g Range
Total
Total
Total h Range
Notes:
948
29/09/09
L1 a L2 b L3 c L4 d I1 e I2 f
+1.12
(0.69 – 1.92)
0
+1.12
(0.69 – 1.92)
11.93)
+9.40
(6.49 –
14.81)
+9.40
(6.49 – 14.81)
Range -1.12 1.12 1.12 - -7.66 7.66 -4.63 4.63 - +0.80 +0.80 -1.35 1.35 1.35 - -9.02 9.02 -6.00 6.00 - +0.57 -5.28 5.28 - +9.86 -5.88 5.88 - +9.78
Mean Mean j -3.4 3.4 3.45 3.4
-1.33 1.33 1.33 -4.06 4.06 -1.94 1.94 +2.26 +2.26 +2.26 +2.01 +2.01
+2.01
Range -1.13 1.13 - -7.66 7.66 -4.91 4.91 - +1.17 -1.58 1.58 1.58 - -9.15 9.15 -5.89 5.89 - +0.91 -3.61 3.61 - +12.41 -4.27 4.27 - +12.32
ME MEAN ME MEAN
AN J -3.45 3.45 -1.03 1.03 1.03 -4.14 4.14 -1.72 1.72 +4.38 +4.38 +4.09
+4.09
a L1 is an existing urban landfill without energy recovery;
b L2 is a new urban landfill with energy recovery;
c L3 is an existing rural landfill without energy recovery;
d L4 is a new rural landfill with energy recovery;
e I1 is a new urban incinerator with energy recovery;
f I2 is a new regional incinerator with energy recovery;
g Conventional air pollution damage including UK based damage only;
h Conventional air pollution damage including UK based as well as that in the rest of the ECE region;
j Mean values do not necessarily reflect midpoint of ranges due to use of specific statistical techniques.
Source: CSERGE, Warren Spring Laboratory and EFTEL (1993) Externalities from Landfill and Incineration, London: HMSO.

Transport externalities were incorporated into the assessment of externalities
(through use of typical distances). It is somewhat debatable whether consideration of
externalities related to waste management facilities should consider transport
externalities as part of the ‘process related’ externality (implying that, in some way, a
particular facility always has associated with it a more or less well understood
transport externality). To the extent that transport externalities can be altered through
changed transportation modes as well as distances, such an analysis appears to
obscure the possibilities for improvement, or indeed, for their being addressed by
transport policies. Indeed, a number of instruments, notably, in the UK, the fuel duty
escalator, have been introduced since the CSERGE work was undertaken. These
effectively internalise transport related externalities to some extent. Consequently,
their inclusion in ‘process-specific’ estimates of externalities is somewhat
problematic. Several authors have opined that the UK fuel duty escalator internalises
either completely, or to a significant degree, the external costs. This is an issue which
we return to later. It is worth pointing out that since 1993, emissions of some of the
key pollutants on a per tonne per kilometre basis, notably NOx, have diminished
significantly.
The study made no attempt to consider the fact that emissions from landfill occur
over an extended period of time. Methane is not emitted from landfills
instantaneously, whereas the greenhouse gases from incinerators are. It would seem
to be appropriate to apply a discount factor (or at least, to justify not applying one)
where landfills are concerned. If it is deemed to be important to consider a non-zero
discount rate, then making a simple distinction between biogenic and non-biogenic
carbon, and assuming carbon dioxide from non-biogenic carbon is unimportant,
cannot be justified. This is because the emissions of biogenic carbon dioxide occur at
different rates from landfills and incinerators (and waste management facilities more
generally). 1165
61.3.2 HM Customs & Excise
Just as the CSERGE et al study was used to inform the discussions concerning a
landfill tax, so the work which culminated in the paper by HM Customs & Excise was
important in informing the debate concerning an incineration tax. 1166 The final output
– the HM Customs & Excise Report – is interesting for a number of reasons. These
are discussed below.
1165 D. Hogg et al (2002) Economic Assessment of Options for Dealing with Biodegradable Waste,
Report to DG Environment, European Commission, by Eunomia, Scuola Agraria del Parco di Monza,
HDRA Consultants, ZREU and LDK.
1166 Enviros, University of Birmingham, RPA Ltd., Open University and Maggie Thurgood (2004) Review
of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar
Wastes, Final Report to Defra, March 2004); Enviros and EFTEC (2004) Valuation Of The External
Costs And Benefits To Health And Environment Of Waste Management Options Final Report for Defra,
December 2004.
949
International Review of Waste Policy: Annexes

61.3.2.1 Restricted Range of Pollutants Attributed Values
First, like the CSERGE et al study in 1993, the valuation of externalities was confined
to a relatively narrow range of pollutants. The focus was on PM, SOx, NOx and VOCs,
as well as CO2 and CH4. Given that the study identified estimates from the literature
associated with a wide range of pollutants, this is quite surprising. At one point in the
study. The authors note:
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29/09/09
The remaining air pollutants are: HCl/HF, 1,1-Dichloroethane, Chloroethane,
Chlorothene, Chlorobenzene, Tertrachloroethene, Arsenic, Benzene,
Cadmium, Nickel, Mercury, Dioxins and Furans, Polychlorinated Biphenyls.
Valuation studies for these air pollutants are limited to their health impacts,
i.e. cancer and deaths brought forward, as identified in the scientific study
and covered in Section 4.1. Thus, to determine per kg estimates per
pollutant, these health impacts need to be multiplied by the number of cancer
cases and deaths brought forward per kg of pollutant. 1167
The statement is never really followed up, either in the externalities report, or the
‘combining’ report of HM C&E. Evidently, to the extent that many emissions which
may be of significance are effectively attributed a zero damage cost, then other things
being equal, the externalities from both landfill and incineration are likely to be
different from their actual value. Whether they should be higher or lower depends
upon the balance of direct impacts and the offsets associated with avoided pollution.
It is, perhaps, worth commenting in this context that a more recent Norwegian study
suggested that pollutants such as chromium, manganese (two pollutants not
mentioned in the italicized paragraph above) and dioxins account for up to 85-95% of
the total socioeconomic costs of waste incineration. 1168
61.3.2.2 Conservative Estimation of Damages of Pollutants Assessed
Second, the valuation of the damages associated with the individual pollutants is at
variance with the estimates being derived from other sources. In itself, this is not
surprising, and indeed, it is positive to the extent that the study seeks to derive
project-relevant estimates. Rather, it is difficult to find two studies that give identical
results.
In Europe, successive attempts have been made in the context of the ExternE
programme, the development of the Benefits Table (BeTa) database, and most
recently, damage cost estimates from the Clean Air for Europe (CAFÉ) programme, to
1167 Enviros and EFTEC (2004) Valuation Of The External Costs And Benefits To Health And
Environment Of Waste Management Options Final Report for Defra, December 2004.
1168 ECON, Senter for økonomisk analyse (Centre for Economic Analysis) (2000) Miljøkostnader ved
avfallsbehandling, ECON-report 85/00. The study is one of a number which were not considered in the
review of external costs of waste management undertaken in the context of the health Effects work,
including a number undertaken for the European Commission.

arrive at a ‘best estimate’ of the damages associated with the pollutants being
examined. 1169
Given that knowledge of the health effects of various pollutants is still developing,
and that some methodological issues are unresolved in the approaches to valuation,
it is to be expected that estimates will vary across studies. However, the values
derived for use in the HM C&E study are almost all lower than those derived for the
UK in the CAFÉ study. Indeed, only for PM does the high end of the range used in the
body of work we are discussing overlap with any part of the range deemed
appropriate from the UK-based modelling under CAFÉ.
The Enviros and EFTEC study adopts a sophisticated modelling approach to
understand the exposure arising from different sources of emissions but adopts
conservative – possibly outdated - estimates of the impacts of the pollutants. As
pointed out above, the analysis is doubly conservative since it concentrates on only a
small range of pollutants.
The estimates are considered conservative partly because a view from COMEAP - put
forward in 1998 – suggested that several impacts should not be valued because
‘accurate’ dose response functions could not be agreed upon. The values in this
report, therefore, omit a range of health effects typically captured in EU studies, such
as:
951
1. Congestive heart failure
2. Restricted activity days
3. Bronchodilator use
4. Cough
5. Lower respiratory symptoms –n children
6. Cerebrovascular hospital admission
7. Chronic bronchitis
8. Chronic cough
9. Asthma attack
10. Minor restricted activity day
For comparison, the unit damage costs derived from three studies are given in Table
61-2.
1169 See European Commission (1998) DGXII (JOULE Programme) Externalities of Energy, ExternE
Project, Report Number 10, National Implementation. Edited by CIEMAT. Report available from
European Commission DG Research; M. Holland and P. Watkiss (2002) Benefits Table Database:
Estimates of the Marginal External Costs of Air Pollution in Europe, Database Prepared for European
Commission DG Environment; AEAT Environment (2005) Damages per tonne Emission of PM2.5, NH3,
SO2, NOx and VOCs from Each EU25 Member State (excluding Cyprus) and Surrounding Seas, Report
to DG Environment of the European Commission, March 2005.
International Review of Waste Policy: Annexes

Table 61-2: Unit Damage Costs Used / Derived in Different Studies (£/tonne)
952
Pollutant Pollutant
Pollutant
29/09/09
CSERGE CSERGE et et al
1993 1993
1993
Enviros Enviros and and EFTEC
EFTEC
(2004) (2004)
(2004)
PM (landfill) 7,650 161 1,025
PM
(incineration)
EU EU-CAFÉ EU CAFÉ
(2005) (2005)
(2005)
Low High Low High
7,650 6,119 39,425
24,667 73,333
SOx 643 2,941 4,400 12,667
NOx 628 154 977 2,600 6,667
VOCs 263 665 759 2207
CO2 1.1-8.5 9.5 38 n/a n/a
CH4 31-139 158 630 n/a n/a
Sources: CSERGE, Warren Spring Laboratory and EFTEL (1993) Externalities from Landfill and
Incineration, London: HMSO: Enviros and EFTEC (2004) Valuation Of The External Costs And Benefits
To Health And Environment Of Waste Management Options Final Report for Defra, December 2004:
AEAT Environment (2005) Damages per tonne Emission of PM2.5, NH3, SO2, NOx and VOCs from Each
EU25 Member State (excluding Cyprus) and Surrounding Seas, Report to DG Environment of the
European Commission, March 2005. 1170
61.3.2.3 Key Results
The report from HM C&E derived, from the Enviros et al study and the Enviros and
CSERGE study, values for the externalities from landfills and incineration. Results for
what is termed the Central High scenario are given in Table 61-3.
Taking the results at face value, then as Table 61-3 shows, the effect of using
relatively low unit damage costs for non-GHGs is to render nothing important other
1170 The interested reader is referred to the CAFÉ website and to the reports present there
(http://europa.eu.int/comm/environment/air/cafe/). It should be noted that independently of CAFÉ,
the Danish institute, NERI, has come up with Danish values for damages associated with PM, NOx and
SOx. In densely populated areas (towns with more than 500,000 inhabitants), they estimate damages
from PM to be as high as £193,000 per tonne and for SOx, £86,667 per tonne. The figure for NOx – at
£7,333 per tonne – is consistent with the higher end of the CAFÉ range (see M. Skou Andersen et al
(2004) Sundhedseffekter af Luftforurening – Beregningspriser, DMU Report No. 507, Copenhagen:
Danmarks Miljøundersøgelser). NERI also modelled the impact of dioxin emissions from incinerators
(see D. Jensen and N. Dengsoe (2004) Værdisætning af skadesomkostninger ved affaldsforbrænding -
en analyse af dioxiners skadelige effekter og et egneeksempel på disse effekters
samfundsøkonomiske omkostninger, TemaNord 2004:518, Copenhagen, Nordic Ministry).

than greenhouse gases. This is hardly profound (rather, it is tautological). Table 61-2
shows that the unit damage costs for the non-GHG pollutants changed little between
the CSERGE study and the Enviros and EFTEC study. The damage costs for GHGs, on
the other hand, have moved significantly upwards.
Table 61-3: Externalities as reported by HM C&E for Central High Scenario
Externality Externality
Externality
953
Incineration Incineration Incineration with
with
Energy Energy Recovery
Recovery
International Review of Waste Policy: Annexes
Landfill Landfill (medium) (medium) (medium) –
Gas Gas Flared
Flared
Landfi Landfill Landfi ll (medium) – Gas
Gas
Used Used Used to to to Generate Generate
Generate
Electricity
Electricity
Costs -£19.11 -£9.83 -£12.04
of which:
CO2 -£19.09 -£3.82 -£5.73
CH4 -£0.01 -£5.99 -£6.30
VOCs -£0.00 -£0.00 -£0.00
SO2 -£0.01 -£0.02 -£0.01
Health -£0.01 -£0.00 -£0.00
Benefits £6.16 n/a -£2.15
Net Costs -£12.95 -£9.83 -£9.89
Source: HM Customs & Excise (2004) Combining the Government’s Two Heath and Environment
Studies to Calculate Estimates for the External Costs of Landfill and Incineration, December 2004.
Notwithstanding the importance of GHGs, the presumption that ‘only GHGs matter’
would suggest that there were no serious impacts arising from emissions associated
with the incineration or landfilling of household waste stream. If this were the case,
then this would be the first study, to our knowledge, to have arrived at such a
conclusion (since, as discussed above, most studies have steadily expanded their
scope in terms of emissions, and most have taken on board a general drift towards
higher, not lower, unit damage costs). 1171 It might be tempting, on the basis of the
results of this study, to simply concentrate on GHGs and ignore all other emissions
when considering waste management options.
Interrogating these figures and their provenance, it is very difficult to reproduce the
same numbers. The air pollution effects appear to have been miscalculated. In the
1171 The report on the damage costs produced under CAFÉ actually compares the values obtained with
those derived in earlier European work to feed into the BeTa database. Higher end results from the
CAFÉ work are higher than those obtained under the BeTa work by a factor of 2.7 for NOx, 8.7 for
PM2.5, 3.9 for SO2 and 1.4 for VOCs.

central high scenario, the effects from SOx, NOx, VOCs and PM, even using the
relatively conservative damage costs, are around £3.19 per tonne for incineration
(319 times what is stated in the report) and £0.83 and £0.35 for the two landfill
scenarios.
By way of comparison, if the same emissions data is used, but one uses the high end
estimates from the CAFÉ work, the externalities associated with the same pollutants
are in excess of £15.00 per tonne for incineration, and around £6.00 per tonne for
landfill with flaring. The differential is particularly great for NOx. In the majority of
studies reviewed by the main author of this study, NOx-related externalities have been
significant contributors to the non-GHG externalities associated with incineration. The
Enviros and EFTEC report effectively reduces their significance by assigning what
appears to be an extremely low unit damage cost for NOx. The incorrect calculation in
the HM Customs & Excise work exacerbates this. 1172
61.3.3 Dijkgraaf & Vollebergh
As part of a larger report by the Copenhagen based Environmental Assessment
Institute, Dijkgraaf and Vollebergh ask whether available social cost-benefit
evaluations of waste disposal provide support for the strict application of the waste
hierarchy. 1173 Of studies reviewed, two found incineration to be preferable to landfill
from a social cost perspective, in support of the EU hierarchy. However, three other
studies find that landfilling is the best option.
The report also refers to an earlier study by the same authors. 1174 This detailed the
findings in terms of private, environmental and total social costs arising from
landfilling and incineration. This multiplied the net private and environmental costs
per tonne of each treatment option in each of the EU-15 countries by total municipal
waste arisings for that country. While total environmental costs for landfill are shown
to be higher, the private costs of incineration are much more significant, with the
overall result that the social costs of incineration are greater than those for landfill.
These results are shown in Table 61-4.
The authors quite rightly add a number of qualifications that must be borne in mind
when interpreting these results, notably, the extent to which methane is used as a
source of energy generation. This can have a great influence on the relative social
costs of landfilling versus incineration. 1175 This is due not only to savings in energy
1172 The Enviros and EFTEC report reviews ten secondary studies which provide valuation data for NOx.
Only one has used a figure for NOx which is lower than the ‘high’ value derived in the context of the
Enviros and EFTEC study. That study was carried out in 1995. All the others that were reviewed have
been conducted more recently.
1173 E. Dijkgraaf and H. Vollebergh (2005) Literature review of social costs and benefits of waste
disposal and recycling, in EAI (2005) Rethinking the Waste Hierachy, EAI: Copenhagen, pp. 80-98.
1174 E. Dijkgraaf and H. Vollebergh (2004) Burn or bury? A social cost comparison of final waste
disposal methods, Ecological Economics, 50, pp.233-247.
1175 E. Dijkgraaf and H. Vollebergh (2004) Burn or bury? A social cost comparison of final waste
disposal methods, Ecological Economics, 50, pp.233-247;
954
29/09/09

production, but mainly the much lower emissions to air if methane is collected and
used as an energy source.
Table 61-4: Social Costs of Landfilling versus Incineration (million euros)
955
Total Total
Total
waste waste
waste
International Review of Waste Policy: Annexes
Costs Costs if if all all waste waste is is landfilled landfilled landfilled Co Costs Co sts if all waste is incinerated
(M
(M
tonnes) tonnes) tonnes)
Private Environmental Environmental Social Social Social Private Private Environmental Environmental Social
Social
Belgium 3 112 69 181 245 55 300
Denmark 3 108 66 174 237 53 290
Germany 25 901 554 1455 1977 442 2419
Finland 2 75 46 121 164 37 201
France 24 857 527 1385 1881 420 2301
Greece 5 192 118 309 420 94 514
Ireland 2 67 41 108 146 33 179
Italy 29 1036 637 1672 2273 507 2780
Luxembourg 0 5 3 8 10 2 13
Netherlands 5 173 106 280 380 85 465
Austria 2 89 54 143 194 43 238
Portugal 5 181 111 292 396 88 485
Spain 20 712 438 1150 1563 349 1912
UK 30 1067 656 1724 2342 523 2866
Sweden 4 129 79 208 283 63 346
Total EU 158 5702 3507 9209 12514 2794 15308
Source: Dijkgraaf, E., and H. Vollebergh (2004)
In addition, the benefits of incineration due to displaced emissions from electricity
generating plant can sometimes be overstated. It is therefore important to know the
reference energy generation technology that is assumed to be displaced. Some
studies assume this to be a coal fired plant. Others assume gas-fired plants, which
result in a much lower saving in emissions from incineration.
61.3.4 COWI
This report, dating from 2000, presented economic valuation estimates for
externalities associated with landfill disposal and incineration of waste. 1176 Further to
this they provide a series of example cost calculations under different assumptions,
the aim being to quantify the main externalities according to typical scenarios for
disposal and incineration.
Included are the following external cost components
� greenhouse gases;
1176 COWI (2000) External Costs of Landfill and Incineration, Final Report to the European Commission.

956
� conventional air pollutants and some airborne toxic substances;
� leachate; and
� disamenity effects.
Importantly, the examples include external benefits in the form of displaced
emissions from energy recovery.
Three examples were defined for incineration, reflecting different technological
standards and levels of energy recovery.
� I1. The incineration plant fulfils the (then proposed) directive on incineration of
waste (Common Position (2000/C 25/02)). Energy recovered will generate
electricity and heat (CHP). The percentage recovery is assumed to be 83%.
� I2. The incineration plant fulfils the (then existing) directive on incineration of
waste (89/369/EEC). Energy recovered will generate electricity only. The
percentage recovery is assumed to be 25%.
� The incineration plant does not fulfil the (then existing) directive. The flue gas
cleaning technology is an electrostatic precipitator. There is no energy
recovery.
Two examples were defined for landfill disposal of waste, reflecting different
technological standards and levels of energy recovery.
� L1. The landfill is a modern containment landfill that fulfils the demands of the
Landfill Directive. 1177 The landfill has a leachate collection and treatment
system. Further the landfill gas is collected to generate electricity and heat
(CHP).
� L2. The landfill is an old site without a liner and landfill gas is not collected.
The resulting external costs are shown in Table 61-5.
1177 Council Directive 99/31/EC.
29/09/09

Table 61-5: Summary of externality costs for incineration and landfill scenarios
(€/tonne)
957
Impact Impact Impact I1 I1 I2 I2 I3 I3 L1 L1 L2 L2
Global
warming
Damage
from air
pollution
Damage
from
leachate
Disamenity
Total
Total
external
external
costs
costs
Pollution
displacement
Net Net external
external
costs
costs
Source: COWI, 2000
0.8
(0.5 - 1.0)
20
(5 - 27)
International Review of Waste Policy: Annexes
0
(0 – 0.3)
8
(4 - 14)
28
(10 (10 (10 – 43)
43)
-71
(-115 - -19)
-43 43
(-72 72 - -9) 9)
0.8
(0.5 - 1.0)
50
(15 - 72)
0
(0 – 0.3)
8
(4 - 14)
58
(20 (20 – 88)
88)
-21
(-29 - -4)
37 37
(19 (19 – 84)
84)
0.8
(0.5 - 1.0)
69
(20 – 108)
0
(0 – 0.3)
8
( 4 - 14)
77
(25 (25 – 124)
124)
0
(-)
77
(25 (25 (25 – 124)
124)
5
(1 – 14)
0.1
(0.02 –
0.2)
0
(0 – 1)
10
(6 – 19)
15 15
(7 – 34)
34)
-4
(-10 - -1)
11 11
(6 – 24)
24)
8
(2 – 23)
0
(-)
1.5
(1 – 2)
10
(6 – 19)
20
(9 – 44)
44)
0
(-)
20 20
(9 – 44)
44)
Understanding the various assumptions underpinning these results is important.
Where incineration produces electricity, the authors credit it with displacing emissions
from a coal fired plant. The assumption that electricity from coal fired plant is the
marginal source has a large impact on the analysis. If gas, arguably a more likely
marginal generation source, was assumed to be displaced, the credited greenhouse
gas emissions would be significantly reduced. Moreover, the study also includes
emissions from mining and transport of the coal, while not accounting for transport
emissions associated with waste delivered to the incinerator. This somewhat
overstates the benefits of displaced energy generation. The assumed conversion
efficiencies could also be argued to be rather high.
The authors undertake sensitivity analysis using oil as the displaced fuel for electricity
generation. For I1, this roughly halves the pollution displacement, resulting in a net
external benefit of €9/tonne waste incinerated instead of the benefit of €43/tonne
waste incinerated with coal as the displaced source. Displacing gas, with a lower

carbon intensity, would have brought the external costs more in line with those of the
better performing landfill, L1.
In the nine years since the report was written, the general European trend has been
towards an increase in unit damage costs associated with both greenhouse gas and
non-greenhouse gas emissions. Against this backdrop, the trend in carbon intensity of
electricity generation in Europe has been downwards, and is expected to drop even
more significantly over coming decades. In interpreting these results, factors such as
these must be borne in mind. What this study would appear to suggest is that, again,
contrary to what is assumed in the waste hierarchy, landfill is not always
unequivocally worse than incineration.
61.3.5 Eunomia and Tobin Reports for Greenstar, 2007 and 2008
The first of these reports, looking at waste policy, planning and regulation in Ireland
presented damage cost estimates for landfill and incineration as shown in Table
61-6. 1178 ‘High’ and ‘low’ in the column headings refer to the unit damage cost
estimates applied.
Table 61-6: Externalities from Landfill and Incineration (€/tonne)
Direct emissions
non-GHG related
Direct emissions
GHG related
Total Total Direct
Direct
Emissions
Emissions
958
29/09/09
Incineration,
Incineration,
Low
Low
Incineration,
Incineration,
High
High
Landfill Landfill (75% (75%
(75%
engine, engine, 25%
25%
flaring), flaring), Low Low
Low
Landfill Landfill (75% (75%
(75%
engine, engine, 25%
25%
flaring), flaring), High
High
€6.86 €19.80 €2.92 €8.46
€17.73 €17.73 €12.76 €12.76
€24 24 24.59 24 59 59 €37 37 37.53 37 53 53 €15 15 15.68 15 68 68 €21 21 21.22 21 22 22
Offsets GHG related - €4.78 - €4.78 - €1.09 - €1.09
Offsets non-GHG - €3.11 - €8.92 - €0.71 - €2.03
Total Total Off Offsets Off sets - €7.89 89 - €13 13 13.70 13
- €1.80 80 - €3.12 12
Net Net Net Environmental
Environmental
Damages
Damages
Source: Eunomia and Tobin, 2007
€16 16 16.71 16 71 €23 €23.8 €23 €23.8
.84 .8 €13 13 13.89 13 89 €18 18 18.11 18 11
1178 Eunomia and Tobin (2007) Waste Policy, Planning and Regulation in Ireland, Final Report for
Greenstar, Dublin, Ireland.

The second report, on the potential role of MBT in meeting Ireland’s waste targets,
presented damage cost estimates for landfill, incineration, and MBT as shown in
Table 61-7. 1179
Table 61-7: Externalities from Landfill, Incineration and MBT (€/tonne)
959
International Review of Waste Policy: Annexes
Landfill Landfill Landfill Incineration
Incineration Incineration MBT MBT
MBT
Direct emissions non-GHG related €2.64 €23.51 €0.49
Direct emissions GHG related €59.13 €28.71 €15.62
Total Total Total Direct Direct Direct Emissions Emissions Emissions
€61.78 €61.78 €52.22 €52.22 €52.22 €16.11 €16.11
€16.11
Offsets GHG related - €1.60 - €6.79 - €4.72
Offsets non-GHG - €2.95 - €9.61 - €6.18
Total Total Offsets Offsets
- €4.55 €4.55 - €16.40 €16.40 - €10.90
€10.90
Net Net Net Environmenta
Environmental Environmenta
Environmental
l Damages Damages €57.23 €57.23 €35.82 €35.82 €35.82 €5.22 €5.22
€5.22
Disamenity €4.25 €14.30 €9.28
Total Total External External External Costs Costs
€61.48 €61.48 €61.48 €50.12 €50.12 €50.12 €14.49 €14.49
€14.49
Source: Eunomia and Tobin, 2008
The differences between these two reports give an interesting insight into the way
that assumptions affect the end result of such studies.
In the first report, the authors applied external cost estimates to emissions data from
another study carried out in the UK. This was used because it was being widely
quoted in Ireland (and the UK) as evidence of an absence of health effects from
incineration. Where landfill is concerned, the figures for emissions are low, partly
because gas capture rates from the landfill are assumed to be high in the study.
For the second report, the authors used their own modelling, developed over a
number of years. This incorporates LCA and CBA information, and permits the
modelling of the impacts of time upon those emissions which do occur over an
extended period of time. Typical LCA studies, as previously mentioned, do not permit
this. A lower gas capture rate was also assumed for methane at the landfill.
For incineration, the emissions were modelled ‘back’ to the input waste composition.
Emissions are therefore based upon a full engineering assessment of the
1179 Eunomia and Tobin (2008) Meeting Ireland’s Waste Targets: The role of MBT, Final Report for
Greenstar, Dublin, Ireland.

composition of the waste and the implications of this for emissions, assuming a
particular configuration of flue gas cleaning (as per the proposed Dublin incinerator).
For the second report, only high-end unit damage costs were used, whereas for the
first, low and high estimates were derived using different figures. Strictly speaking,
the only comparison is between the high values in the first report and the values in
the second. For incineration, disamenity accounts for a large proportion of this, while
for the first report, disamenity figures were not included.
For landfill, the change in assumptions regarding gas capture is the most important.
(This remains an area where there is surprisingly little agreement as to what the
correct figure should be).
Again the outcomes of these two reports show that the ordering of the lower tiers of
the waste hierarchy is not always supported by a cost-benefit appraisal.
61.3.5.1 A Note on Disamenity
The EFTEC and Enviros study underpinning the HM C&E work reviewed some of the
literature on disamenity. Cambridge Econometrics and EFTEC themselves carried out
a major hedonic pricing study which estimated the disamenity associated with
landfilling. 1180 This was based upon a hedonic pricing study, examining the effect of
proximity to landfills on house prices. The Enviros and EFTEC study updated the
estimates from the previous study (inflating the estimates in line with house price
inflation), giving a range for landfill disamenity of between £2.50 and £3.59 per
tonne.
However, the Eftec and Enviros study excluded disamenity impacts because it felt
that the only relevant study concerning incineration – from the US – was not
transferable to the UK context. Kiel and McClain looked at the effects on house prices
over time from the pre-rumour stage, through to the rumour stage, the construction
phase, the online phase, and later years of operation. 1181 They found that house
prices were affected only once construction began and peaked in earlier years of
operation before falling back slightly. The effect was a reduction of the order 3% per
mile in the vicinity of the incinerator.
At one level, the decision not to use the study’s findings was understandable. It was,
after all, carried out in the United States and the transferability of the results would
be questionable. However, the reasoning given is interesting. It was noted
960
29/09/09
‘When this [the disamenity from the incinerator] is compared to the average
disamenity cost of landfill from the Defra study of between £551,000 to
£789,000 when converted to £2003 prices using house price index changes,
the results of Kiel and McClain seem disproportionately large. For this, and
1180 Cambridge Econometrics in association with EFTEC and WRc (2003) A Study to Estimate the
Disamenity Costs of Landfill in Great Britain, London:Defra, February 2003.
1181 K.A. Kiel and K.T. McClain (1995) House Prices during Siting Decision Stages: The Case of an
Incinerator from Rumour through Operation. Journal of Environmental Economics and Management
28, 241-255.

961
also given the fact that the study is from the US, this estimate is not
recommended for use in the UK context’.
This is very different to the view taken in a recent Dutch study: 1182
Given these findings, we assume that the disamenity effects differ between
landfilling and incineration. First, the reduction in house prices seems to be
more pronounced with incineration. This may be due to the fact that
incineration is mainly disliked because of the perception of air pollution. In the
Netherlands, since the negative publicity of the emissions of the highly toxic
dioxins in the early 1990s, people are more reluctant to live near an
incinerator. Even if the legal standards are met, the fear will not disappear
immediately. Second, due to the importance of air emissions and the height of
the stack, the impact area of an incinerator is significantly larger than the
area affected by a landfill site. Therefore, the area of affected houses around
the landfill site is limited to a buffer of 1 kilometre around the site. The impact
area of incinerators in the Netherlands is assumed to reach as far as 5
kilometres from the actual site.
The study estimated minimum and maximum values for disamenity of €9.1-9.9 per
tonne (approx £6.50-7.00 per tonne).
A recent French study carried out a contingent valuation study to assess
disamenity. 1183 The reported results were estimated at €4.3/tonne (a range of €3.7-
4.9 per tonne). The study suggested that these levels were likely to include some
estimate (from residents) of the impacts of air pollution. Consequently, it hinted that
these might be high estimates. The relatively low value in the French study may be
explained by the fact that the incinerator chosen for the study was in an area of
relatively low population density (3km from a city of 50,000 inhabitants), dealing with
85,000 tonnes from 52 communes. As such, the disamenity per tonne of waste might
be suppressed by the reduced density of housing stock affected by the facility.
Another French study is worth reporting. Rabl et al intended to carry out a contingent
valuation study in France, however, these plans did not materialise:
Initial plans of our research project had been to carry out a contingent
valuation in France. However, at none of the sites suitable for a case study
were the authorities willing to let us survey the opinions of the population. The
projects were too controversial, and the authorities were afraid of anything
they perceived as potential outside interference. 1184
1182 H. Bartelings, P. van Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk
(2005) Effectiveness of Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM,
November 24, 2005.
1183 O. Arnold and S. Terra (2006) Consentement Local a Payer et Localisation d’un Incinerateur, Serie-
Etudes 05-E10, Ministere de l’Ecologie et du Developpement Durable.
1184 A. Rabl et al (1999) Impact Assessment and Authorization Procedure for Installations with Major
Environmental Risks, Contract ENV4-CT96-0236, DG XII European Commission, July 1999.
International Review of Waste Policy: Annexes

The authors went on to explore attitudes of households to different cost and benefit
profiles in an area where facilities were still being discussed.
In our view, it would be reasonable to expect significant disamenity from incinerators
as measured through hedonic pricing for the simple reason that the density of
housing stock is likely to be greater around incinerators than around landfills. Quite
how the disamenity effects of incineration, as measured through contingent valuation
approaches, would compare with landfill is still unclear (and likely to vary with
location). To the extent that population densities are important, the fact that
incinerators are usually in urban or peri-urban locations would suggest that the
disamenity would be larger (simply because more households would be affected). On
the other hand, we have only limited knowledge from studies seeking to elicit the
disamenity associated with municipal waste incineration so do not know the speed at
which the disamenity experienced falls with distance (and whether it varies with
capacity, and if so how?). Brisson and Pearce suggest 4 miles as the domain of
influence for landfills. It could be that this is less in the case of incinerators (though
the Dutch study cited above assumed it was 5km). 1185
COWI, in work for the European Commission, used the meta-analysis of Pearce and
Brisson, relating house price reductions to proximity to a landfill, and assumed the
same relationship applied to houses located near incinerators. 1186 COWI used a
population density around the typical incinerator of 120 per square mile. Yet
incinerators are rarely located in such sparsely populated areas. Eunomia et al
suggested that the population densities are typically an order of magnitude larger.
They suggested if COWI had used a figure of 1,200 households per square mile (469
per square kilometre), the values derived for a 200,000 tonne site, with the annual
disamenity being set at 8% of the total, is around €75 per tonne. On the basis of this,
they suggested that the importance of the housing density should not be underestimated
in the modelling of incinerator-related disamenity, and that further work
was urgently needed in this area. 1187
It is clear that both the COWI and Eunomia studies derived figures which were
dependent upon the transferability of a relationship derived for landfills to the
incinerator context. Neither study used the disamenity estimate derived in their
ultimate analysis. It seems possible, however, that disamenity values could be
considerable for these facilities.
To our knowledge, no studies of disamenity have been carried out at other waste
treatment facilities (than landfill and incineration)
1185 Brisson, Inger and David Pearce (1995) Benefits Transfer for Disamenity from Waste Disposal,
CSERGE Working Paper WM 95-06, London: CSERGE.
1186 COWI (2000) A Study on the Economic Valuation of Environmental Externalities from Landfill
Disposal and Incineration of Waste. Final Report to DG Environment, the European Commission,
August 2000.
1187 Eunomia Research & Consulting, Scuola Agraria del Parco di Monza, HDRA Consultants, ZREU and
LDK ECO on behalf of ECOTEC Research & Consulting (2002) Economic Analysis of Options for
Managing Biodegradable Municipal Waste, Final Report to the European Commission.
962
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61.4 Concluding Remarks on the Literature
A number of points have arisen from the studies reviewed.
1. Estimates of the unit damage costs for individual pollutants appear to increasing
over time. Although there is still some dispute over which methodological
approach is more valid (VSL or VOLY), the suggestion would be that a forward
looking appraisal of pollution might tend towards the use of damage costs at the
higher, rather than the lower end of existing ranges;
2. In addition, the range of pollutants to which damage costs are attributed is
likewise increasing.
3. The unit damage costs for greenhouse gas pollutants are also tending to increase
over time;
4. The pressure to deal with climate change is leading to a lower carbon intensity
associated with electricity generation, and this trend is expected to continue.
Consequently the benefits associated with energy generated from waste are likely
to decline over time.
5. Landfill may sometimes have greater external costs than incineration, but this is
not always the case. A critical assumption is the capture rate for gas assumed at
the landfill, whilst the assumption concerning the avoided source of energy is also
critical;
6. Very few studies have looked at MBT processes, and therefore very few have
looked at the impacts of landfilling pre-treated/stabilised waste;
7. Given points 1 & 2, and with pre-treatment becoming more widespread, there is
no reason to believe landfilling of pre-treated waste is necessarily worse than
incineration from an environmental perspective, at least given the boundaries
within which valuation studies are currently forced to work;
8. Disamenity may also be significant for residual (and other) waste treatment
plants.
To conclude, all these points suggest that especially at the bottom of the waste
hierarchy, the ordering appears to be far from unequivocal from an environmental
point of view. It should be re-emphasised that few CBAs manage to capture all
possible effects, and it is not entirely clear that those that are not captured would, if
included, have only a small impact on the outcomes.
963
International Review of Waste Policy: Annexes

62.0 Life-cycle Assessment of Residual Waste
Treatment Technologies
This section carries out a life cycle assessment of a range of residual waste treatment
technologies, using the Environment Agency’s tool WRATE. The assessment is
described in Section 62.1. Limitations of the LCA approach in general (as exemplified
by the WRATE analysis) are described in Section 62.2.
62.1 Life-cycle Assessment Using WRATE
A recently published report produced by Fehily Timoney & Company (FTC), Veolia and
Ramboll sought to investigate the role that the Mechanical Biological Treatment of
waste might play within the Irish waste management sector. 1188 Their report included
an environmental impact appraisal which used the life-cycle tool WRATE to assess
these impacts. Their appraisal indicated that the thermal treatment scenario which
included the recovery of both heat and electricity performed the best against the six
assessment criteria considered within WRATE’s default assessment method.
However, their analysis also briefly considered results obtained using the full range of
MBT processes included within the software. The latter assessment concluded that
there was considerable relative variability between the different MBT systems.
The approach taken within the current appraisal is to examine in more detail the
variation seen in the results of the impact assessments indicated by WRATE for a
range of MBT and incineration options. In addition, Eunomia holds an Expert License
for the software, which provides additional functionality with regard to analysis of
impacts at each of the process stages. This enables the identification of specific
pollutants or chemicals causing the impact at each stage of the treatment process,
within each of the impact assessments.
Our modelling uses the default impact assessment methods included within the
model. We have made the following core assumptions across all treatments
considered within the appraisal:
964
� We have used the residual waste composition data recently produced by RPS
for the EPA; 1189
� The baseline fuel mix is based on the 2007 mix for Ireland; we have separately
defined the marginal electricity source as a modern combined-cycle gas
turbine (CCGT, reflecting the carbon intensity of the new build of electricity
generation sources). Whilst the former is used when calculating impacts
1188 Fehily Timoney & Company / Veolia Environmental Services / Ramboll (2008) Critical Analysis of
the Potential for Mechanical Biological Treatment for Irish Waste Management: Volume 2, Research
Report, Report for the Environmental Protection Agency, September 2008.
1189 RPS (2009) Municipal Waste Characterisation Surveys 2008, Report for the EPA, March 2009.
29/09/09

965
associated with fuel used within facilities, the latter is used to determine
avoided emissions resulting from energy generated by facilities. 1190
WRATE’s default assumption is that heat generation offsets use of gas-fuelled heat
generation. We have retained this assumption.
Our assessment is carried out on the basis of impacts associated with 1 tonne of
residual waste sent to each treatment facility. The results presented in the following
sections are not directly comparable to those produced by the FTC analysis, as the
latter also considered impacts associated with collection and recycling of 100,000
tonnes of waste within each of their four scenarios.
Our analysis considers the performance of the following thermal treatment facilities
against key WRATE criteria:
� Chineham incinerator, generating electricity only (Incin Elec C in the graphs);
� Dundee incinerator, generating electricity only (Incin Elec D);
� Billingham incinerator, generating electricity only (Incin Elec B);
� Coventry incinerator, generating electricity and heat (Incin CHP C);
� Grimsby incinerator, generating electricity and heat (Incin CHP G).
The WRATE model includes two categories of MBT process – the “generic” processes
modelled using data obtained through literature published on MBT processes – and
proprietary processes (e.g. the Ecodeco process) compiled using data provided by
facility operators wherever possible. Whilst the FTC analysis considered only the two
generic processes, we have included two additional facilities within the analysis that
follows:
� The Arrowbio Anaerobic Digestion-based MBT plant;
� The Ecodeco MBT facility (producing an SRF which is sent to the Chineham
incinerator, generating electricity only).
In each case, the performance of the MBT and incineration facilities is compared to
that of landfill.
62.1.1 WRATE Impact Assessment
The default impact assessment method within WRATE considers the performance of
technology options against the following criteria:
1. Abiotic Resource Depletion
2. Global Warming Potential
3. Human Toxicity Potential
1190 The baseline mix includes 22% Coal, 54% Gas and 11% Peat. See: Energy Policy Statistical
Support Unit (2008) Energy in Ireland 1990 – 2007, Report for Sustainable Energy Ireland, December
2008.
International Review of Waste Policy: Annexes

kg kg antimony antimony eq.
eq.
966
4. Freshwater Aquatic Eco-Toxicity
5. Acidification
6. Eutrophication
These will be considered within each of the sections that follow.
62.1.1.1 Abiotic Resource Depletion
Abiotic Resource Depletion can be defined as the decreasing availability of natural,
non-living, non renewable resources. Within the context of waste management this is
likely to be related to the ability of treatment processes to generate energy, or to
reduce the requirement for energy and raw material use through the recycling of
materials. The default assessment in WRATE considers these impacts in terms of kg
antimony equivalent.
The results presented in Figure 62-1 indicate that the best performer is the Arrowbio
AD-based MBT facility. Landfill is the worst performing option against this assessment
criterion, with the Dundee incinerator the second worst performer. However all
options result in a negative value as each either generates energy or recycles some of
the input waste stream.
Figure 62-1: Abiotic Resource Depletion (AD)
0.00
-0.50
-1.00
-1.50
-2.00
-2.50
-3.00
29/09/09
Landfill Ecodeco
MBT
-0.46
-1.67
Generic
Aero MBT
-1.42
Generic
AD MBT
-1.76
AD
Arrowbio
MBT
-2.84
Incin Elec
C
-2.20
Incin Elec
D
-1.08
Incin Elec
B
-1.60
Incin CHP
C
-2.00
Incin CHP
G
The majority of the impact is from avoidance of the use of gas as a result of energy
generation. Facilities also gain from the avoided oil use. The Arrowbio AD-based MBT
plant performs best under the assessment owing to the relatively high levels of
material recycling assumed, alongside generation of energy through combustion of
biogas.
-2.43

kg kg CO2 CO2 eq. eq.
62.1.1.2 Global Warming Potential
The Global Warming Potential is a measure of how much a given mass of greenhouse
gas is estimated to contribute to Global Warming. The default impact assessment in
WRATE considers impacts over 100 years, calculated in terms of CO2 equivalent
emissions.
The results presented in Figure 62-2 indicate that the Arrowbio AD-based MBT facility
also performs well against this assessment criterion, due to avoided emissions
resulting from a substantial amount of materials removed for recycling, along with
emissions avoided as a result of the generation of energy from biogas. However, the
majority of MBT processes considered within WRATE do not fare well when assessed
against the global warming impact assessment criterion. Our analysis indicates that
the generic MBT facilities (along with the Dundee and Grimsby incinerators) perform
worse than landfill in this case. This is clearly somewhat counter-intuitive and
deserves explanation.
Figure 62-2: Global Warming Potential (GWP100)
350.00
300.00
250.00
200.00
150.00
100.00
50.00
0.00
-50.00
967
218.00
202.00
Landfill Ecodeco
MBT
321.00
Generic
Aero MBT
269.00
Generic
AD MBT
International Review of Waste Policy: Annexes
-9.62 AD
Arrowbio
MBT
144.00
Incin Elec
C
293.00
Incin Elec
D
200.00
Incin Elec
B
88.60
Incin CHP
C
247.00
Incin CHP
G
The poor performance of the MBT facilities within WRATE largely results from the
methodology used within the model to estimate emissions from landfill occurring from
pre-treated wastes. The model assumes a proportion of the carbon is degraded within
the biological part of the process and accounts for this in terms of the biogenic
carbon emissions that are reported as an information item within its inventory of
emissions. 1191 However, when this material is subsequently landfilled, the resulting
1191 CO2 emissions generated from biogenic carbon sources are not included within the total CO2
emissions considered within the Global Warming Potential assessment criterion.

kg kg 1,4-dichlorobenzene 1,4-dichlorobenzene eq.
eq.
methane emissions – considered in terms of kg of methane emitted per kg of
stabilised waste - is assumed to be exactly the same as that of the non-stabilised
material. WRATE does take into account the reduction in mass which occurs in
material which is biologically pre-treated as a result of moisture loss, and this leads to
a reduction in the landfill emissions – but it does not account for reduction in
biodegradability, so the emissions are reduced only to a limited extent. The model,
therefore, significantly underestimates the extent to which the biological component
of the MBT process reduces the biological activity of material subsequently sent to
landfill, biasing any assessment of residual waste facilities against this criterion. 1192
Any MBT process which stabilises waste prior to landfilling is effectively penalised by
the shortcomings of the model.
62.1.1.3 Human Toxicity Potential
The human toxicity potential is an index intending to reflect the potential harm of a
unit of chemical released, based both on the inherent toxicity of the chemical and its
potential dose. The default impact assessment in WRATE considers these impacts in
terms of kg 1,4 dichlorobenzene equivalent.
Our analysis shows that landfill performs relatively well against this assessment
criterion. The worst performing facility in this case is the Dundee incinerator, and
thermal treatments appear less favourable in comparison to the MBT options (with
the exception of the Chineham incinerator).
Figure 62-3: Human Toxicity (HTP inf)
80.00
60.00
40.00
20.00
0.00
-20.00
-40.00
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29/09/09
0.98
3.30
Landfill Ecodeco
MBT
12.10
Generic
Aero MBT
Generic
-5.32
AD MBT
14.40
AD
Arrowbio
MBT
Incin Elec
C
-27.10
70.60
Incin Elec
D
29.80
Incin Elec
B
39.50
Incin CHP
C
40.60
Incin CHP
G
1192 This is a problem of the model, related to the fact that WRATE does not incorporate a landfill model
per se, rather emissions are hard-coded into the model.

These results suggest a significant variation in the relative performance of the
different AD and incineration options. A closer inspection of the pollution inventory
reveals that results against this assessment criterion are heavily influenced by heavy
metal emissions from the facility.
For example, whilst the treatment and recovery stage of the Generic AD facility is
indicated to result in 17.9 kg of 1,4 dichlorobenzene equivalent, the same stage
within the Arrowbio AD-based MBT plant results in 43.2 kg of 1,4 dichlorobenzene
equivalent. This impact is linked to a substantial differential in the emissions of
Chromium VI assumed to occur from the two facilities. Whilst the Generic AD process
assumes an annual emission of 2.3E-06 kg Chromium VI to air (per 60,000 tonnes of
waste to facility) the Arrowbio AD-based MBT plant assumes 0.42 kg Chromium VI is
emitted annually (from 70,000 tonnes treated at the plant).
An analysis of the emissions data embedded within WRATE indicates that the former
process derives its estimated Chromium VI emissions:
969
“from the waste gas figures and the efficiency of the purification system to
reach a clean gas emissions figure”.
An inspection of the same entry for the Arrowbio AD-based MBT process indicates
that the data has been extrapolated from similar AD technologies in Germany as
aerial emissions data is lacking. It is not clear which German technologies were
referenced when compiling the model for the Arrowbio process. It does demonstrate,
however, how the quest for complete inventories can bias results obtained.
There is even greater variation in the performance of the different incinerator options.
Here, results are heavily influenced by:
� Avoided emissions of barite to water; and
� Emissions of cadmium and thallium to air.
The mineral barite is used as a weighting agent in the petroleum drilling industry;
impacts here, therefore, relate the amount of energy generated by each option.
For incineration facilities, WRATE calculates emissions to air based on emissions data
supplied by plant operators. These are scaled up within the model to give an annual
emission figure for the facility. Heavy metal emissions are then weighted using an
estimate of the heavy metal content in the input waste (derived from waste
composition supplied by the user within each bespoke scenario), divided by heavy
metal content of what is termed the ‘typical waste’ composition. As an example, the
cadmium emission is calculated using the following allocation formula:
[Total cadmium in input waste] * [Emissions from process]
[Total cadmium in ‘typical waste’]
The worst performing incinerator with regard to its human toxicity potential is that
located at Dundee (a fluidised bed incinerator). The Dundee incinerator is assumed to
emit 0.75 kg cadmium per 120,000 tonnes of waste; by contrast the Chineham
facility emits 0.07 kg cadmium per 95,000 tonnes. Both figures relate to a series of
actual emissions measurements taken at each facility, and in both cases the upper
measurement was used from the series.
International Review of Waste Policy: Annexes

kg kg 1,4-dichlorobenzene 1,4-dichlorobenzene eq.
eq.
The allocation formula for heavy metal emissions relies on a reasonably close match
between the ‘typical’ composition data used to model the facility and the measured
emissions data. Use of the upper emissions estimate may result in an overestimation
of the annual impacts if emissions measurement were taken at a point when material
containing an exceptional amount of heavy metal was being treated.
The human toxicity impacts of the treatment options are separately assessed using a
different impact assessment method in Section 62.2, which shows how different the
results can be. That section presents the results of this additional assessment, and
highlights the limitations of the LCA approach to technology appraisal. The preceding
discussion, however, highlights how sometimes obscure pollutants, and relatively
casual assumptions made about them, can be highly influential in the assessment,
especially against toxicity impacts where impact weightings vary enormously across a
very large range of pollutants emitted / avoided. 1193
62.1.1.4 Freshwater Aquatic Eco-Toxicity
This index is similar to the human toxicity assessment described in Section 62.1.1.3,
but is intended to measure the toxicity of a chemical to aquatic life. Impacts are also
considered in terms of kg 1,4 dichlorobenzene equivalent.
Figure 62-4: Freshwater Aquatic Eco-toxicity (FAETP inf)
5.00
0.00
-5.00
-10.00
-15.00
-20.00
-25.00
-30.00
-35.00
-40.00
970
29/09/09
-0.29
Landfill Ecodeco
MBT
-34.30
Generic
Aero MBT
-24.80
Generic
AD MBT
-26.30
AD
Arrowbio
MBT
-27.70
Incin Elec
C
-15.20
Incin Elec
D
-16.20
0.23
Incin Elec
B
Incin CHP
C
-8.56
Incin CHP
G
1193 Some LCA practitioners, for this very reason, prefer to concentrate their analysis on emissions for
which data is relatively robust, rather than seeking to be ‘comprehensive’ in the range of emissions
analysed. The ‘comprehensive’ approach risks biasing the assessment for trivial reasons, such as the
fact that inventories for some processes simply do not cover the same breadth of emissions as the
inventories for others. If omitted emissions are those for which impact weightings are high, the
assessment is effectively biased.
-19.50

kg kg SO2 SO2 eq.
eq.
The results shown in Figure 62-4 indicate the MBT treatments are the most
favourable options with regard to this assessment criterion whilst landfill and the
Billingham incinerator perform worst.
The impacts attributed through this assessment method result from two principle
sources:
971
� Avoided vanadium emissions to water as a result of recycling ferrous metal;
� Emissions of copper to water from the landfilling of combustion residues.
62.1.1.5 Acidification
The acidification indicator measures the potential for a pollutant to contribute to the
atmospheric acidification resulting in the production of acid rain. The default impact
assessment method within WRATE considers impacts in terms of kg SO2 equivalent.
Table 62-1 indicates that the thermal treatments perform the worst with regard to
their acidification potential. Whilst landfill fares relatively well in comparison to the
incineration facilities, the best performers are the MBT facilities. Again, the Arrowbio
AD-based MBT plant is the best performer against this particular assessment
criterion.
Table 62-1: Acidification (AP)
1.50
1.00
0.50
0.00
-0.50
-1.00
-1.50
0.10
Landfill Ecodeco -0.08
MBT
0.14
Generic
Aero MBT
0.06
Generic
AD MBT
International Review of Waste Policy: Annexes
AD
Arrowbio
MBT
-0.92
0.19
Incin Elec
C
0.66
Incin Elec
D
1.04
Incin Elec
B
0.73
Incin CHP
C
0.41
Incin CHP
G
The Arrowbio AD-based MBT process performs favourably because the facility recycles
plastic, resulting in avoided SO2 emissions (according to WRATE, this material is not
recycled by the other options considered within our appraisal).
The performance of incineration facilities against this criterion is heavily influenced by
the amount of NOx that is assumed to be emitted.

kg kg PO4 PO4 eq.
eq.
62.1.1.6 Eutrophication
The Eutrophication indicator measures the potential for pollutants to stimulate
excessive plant growth through their release into water courses (principally nitrogen
and phosphate). Impacts are considered in terms of kg PO4 equivalent within the
default assessment method.
The results displayed in Table 62-2 indicate that the Arrowbio AD-based MBT facility is
the least favourable option in terms of the Eutrophication assessment, and that the
majority of MBT facilities (with the exception of the Ecodeco plant) fare less well than
the thermal treatments.
Table 62-2: Eutrophication (EP1992)
0.45
0.40
0.35
0.30
0.25
0.20
0.15
0.10
0.05
0.00
972
0.41
29/09/09
0.09
Landfill Ecodeco
MBT
0.27
Generic
Aero MBT
0.24
Generic
AD MBT
0.33
AD
Arrowbio
MBT
0.06
Incin Elec
C
0.17
Incin Elec
D
0.19
Incin Elec
B
0.20
Incin CHP
C
0.14
Incin CHP
G
For the MBT treatment technologies eutrophication impacts are assumed to be
caused by ammonia emissions to water resulting from the landfill element - there is a
direct correlation between the amount of material sent to landfill and the
performance of MBT systems against this assessment criterion. Of the MBT
treatments considered here, the Arrowbio AD-based MBT facility has most material
(69% of the initial mass) sent to landfill, as no part of the stabilised material is
subsequently thermally treated. In contrast, the Ecodeco process sends only 16% of
the input waste to landfill.
WRATE does not properly account for the reduction in nitrogen content that would
occur as a result of the biological treatment part of the MBT process, although
emissions of nitrogenous compounds are also assumed to occur during that
treatment stage. There are similar problems here, therefore, as have been discussed
in respect of climate change emissions.
The different performance of the incineration facilities against this assessment
criterion principally relates to atmospheric emissions of NOx from the plant.

62.1.2 Summary of Results
In addition to the variation in performance between the different MBT options - noted
in FTC analysis and confirmed by the results of appraisal presented here - our
analysis indicates there is considerable variation in the performance of the
incineration facilities modelled within WRATE. This is shown in Table 62-3 which
shows the two most favourable options against each of the assessment criteria, along
with the worst performer in each case.
Table 62-3: Summary of the Best and Worst Performers
Abiotic Resource
Depletion
Global Warming
Potential
973
International Review of Waste Policy: Annexes
Performance Performance against against assess assessment assess ment crit criteria crit
eria
Best Best
Second Second best best
Worst
Worst
Arrowbio AD MBT Grimsby Incinerator Landfill
Arrowbio AD MBT Chineham Incinerator Generic Aero MBT
Human Toxicity Chineham Incinerator Generic AD MBT Dundee Incinerator
Freshwater Aquatic
Eco-toxicity
Ecodeco MBT Arrowbio AD MBT
Acidification Arrowbio AD MBT Ecodeco MBT
Billingham
Incinerator
Billingham
Incinerator
Eutrophication Chineham Incinerator Ecodeco MBT Landfill
Table 62-3 suggests that those facilities performing the most favourably against the
six criteria are:
� The Chineham incinerator;
� The Arrowbio AD-based MBT and Ecodeco MBT facilities.
The favourable performance of the Arrowbio AD-based MBT facility results from both
the production of energy from biogas and the relatively high proportion of material
recycled in comparison to the other MBT options.
Whilst landfill is the least favourable option against two of the criteria, an incinerator
is the worst performer in three. By contrast to the results generated within FTC’s
analysis, there is little indication here that the thermal options operating in CHP mode
are the most favourable – in the majority of cases the best performing incineration
facility is one which generates electricity only.
62.2 Limitations of the Life-cycle Assessment Approach
The WRATE expert user license allows the user to carry out the life-cycle assessment
of waste treatment technologies against a number of different assessment methods.

kg kg 1,4-dichlorobenzene 1,4-dichlorobenzene eq.
eq.
Life-cycle methodology involves the compilation of a life-cycle inventory, detailing all
direct and indirect emissions (the latter relating to avoided impacts associated with
energy generation and recycling). Each life-cycle assessment method assigns a series
of characterisation factors (or weightings) to each of the substances in the inventory,
according to their relative anticipated impact within the method. In some cases the
different impact assessment methods give quite different results for the same type of
impact, through the use of different characterisation factors against the data
contained within the same emissions inventory.
An example of this is shown in Table 62-4 and Table 62-5. These figures compare the
results obtained using two different impact assessment methods within WRATE to
measure the terrestrial eco-toxicity of waste treatment technologies treating one
tonne of residual waste. They show that whilst the CHP technologies perform
relatively favourably against this criterion when assessed using the Impact 2002
method, they do not fare well when the CML method is used to assess the same
criterion.
Further evidence of this can be seen when considering an assessment of the human
toxicity associated with the different treatment technologies. Table 62-6 shows the
results obtained using the Impact 2002. This method indicates the Arrowbio ADbased
MBT plant as the most favourable treatment option with respect to human
toxicity impacts, whilst the Billingham incinerator performs the worst against this
criterion in this method. In contrast, the HTP Inf Method outlined in Section 62.1.1.3
suggests that the Chineham incinerator is the most favourable treatment option,
whilst the Arrowbio AD-based MBT plant performs less well in comparison to the
Generic AD plant.
Table 62-4: Terrestrial Eco-toxicity Assessed using the CML Method
0.6
0.5
0.4
0.3
0.2
0.1
0
-0.1
-0.2
-0.3
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29/09/09
0.0132
0.174
0.468
Landfill Ecodeco MBT Generic Aero
MBT
0.358
Generic AD
MBT
AD Arrowbio
MBT
-0.182
0.0284
0.502
0.217
0.179
0.389
Incin Elec C Incin Elec D Incin Elec B Incin CHP C Incin CHP G

DALY, DALY, kg kg chloroethylene
chloroethylene
PDF*m2*yr/kg-triethylene PDF*m2*yr/kg-triethylene glycol
glycol
Table 62-5: Terrestrial Eco-toxicity Assessed using the Impact 2002 Method
6
4
2
0
-2
-4
-6
975
0.739
Landfill Ecodeco MBT Generic Aero
MBT
-4.01
-1.02
International Review of Waste Policy: Annexes
Generic AD
MBT
-1.34
AD Arrowbio
MBT
-2.78
-2.35
1.17
4.44
Incin Elec C Incin Elec D Incin Elec B Incin CHP C Incin CHP G
Table 62-6: Human Toxicity Assessed using Impact 2002+ (Endpoint) Method
1.20E-05
1.00E-05
8.00E-06
6.00E-06
4.00E-06
2.00E-06
0.00E+00
-2.00E-06
-4.00E-06
-6.00E-06
2.49E-07
Landfill Ecodeco
MBT
-3.07E-06
Generic Generic
Aero MBT AD MBT
-2.04E-06 -2.13E-06
AD
Arrowbio
MBT
-4.26E-06
4.93E-07
Incin Elec
C
2.60E-06
Incin Elec
D
1.09E-05
Incin Elec
B
8.30E-06
-5.12
Incin CHP
C
1.23E-07
Incin CHP
G
The model used in both this analysis and FTC’s appraisal - WRATE - suffers from some
significant shortcomings. The shortcomings of the model are particularly relevant
-3.72

when comparing facilities which biologically treat waste prior to landfilling. This is the
case especially for climate change and eutrophication.
This is somewhat disappointing since climate change is one of the impact
assessment categories where there is relatively good agreement as to how the impact
of different emissions should be weighted. In many other impact assessment
categories, particularly those related to eco-toxicity, there are some more general
concerns about the weightings applied to different pollutants under different impact
assessment methods.
This problem is almost certainly exacerbated in WRATE because the model seeks to
be comprehensive in the range of pollutants which are covered. It is almost certainly
the case that the datasets which reside within the model derive from studies which
vary in the degree to which they seek to record all pollutants emitted. Similar sorts of
bias can occur, as demonstrated above, where the model builders seek to make good
for the absence of data on specific emissions with reference to other facilities.
62.3 Concluding Comment
The upshot of the above discussion is that:
976
� The model used by the STRIVE report suffers from some shortcomings which
tend to bias the assessment which was carried out. This is not to say this was
deliberate on the part of the authors. Rather, it makes the point that the model
has some serious limitations;
� The relative confidence with which the conclusions are drawn in the report is
perhaps misplaced.
Hence, the report’s statement that: 1194
29/09/09
As can be seen from an examination of the charts, a waste management
scenario which includes a high energy recovery (i.e. recovery of both heat and
energy) thermal treatment performs consistently well over each of the impact
categories, performing best in each category. The mechanical biological
treatment scenarios and the low-energy recovery scenarios have varying
ranking over the impact categories.
Can be traced effectively to being a function of
� The operation of the model, and
� The choice of MBT system used in the modelling.
The study’s authors later state:
There is a need for further study into the emissions and environmental fate of
materials in MBT systems
1194 Fehily Timoney & Company / Veolia Environmental Services / Ramboll (2008) Critical Analysis of
the Potential for Mechanical Biological Treatment for Irish Waste Management: Volume 2, Research
Report, Report for the Environmental Protection Agency, September 2008.

This is clearly true, not least since there are so many potential variants. It is also true,
however, that the modelling tool used does not reflect the workings of MBT systems
in a particularly fair way. We understand that the Environment Agency is seeking to
update the software to incorporate these effects, though we have not been able to
analyse these expected changes.
977
International Review of Waste Policy: Annexes

63.0 Externalities of Waste Management Options
The following residual treatments are considered within our analysis:
978
1. Landfill of untreated material;
2. Incineration (generation of electricity only);
3. Two MBT treatment processes:
29/09/09
a. Aerobic Stabilisation (with pre-treated output sent to landfill);
b. Aerobic Biodrying producing SRF sent to incineration (generating
electricity only) with rejected material stabilised prior to being sent to
landfill.
We have considered emissions of greenhouse gases and the impacts upon air quality
that are expected to result from the treatment process, including both direct and
indirect impacts (the latter relating to avoided impacts associated with energy
generation and the recycling of materials).
Our approach is to apply external damage costs to emissions of greenhouse gases
and a range of air pollutants, allowing for the quantification of impacts in monetary
terms.
As highlighted in Annex 61.0, this type of analysis is complex and is affected by a
number of variables and parameters. The analysis that follows is focussed upon
emissions to air. Whilst waste treatment processes may also in some cases affect soil
and water quality, data regarding the precise nature of these impacts is less than
robust. Similarly, we have not included damage costs associated with disamenity of
waste treatment facilities, as estimates of disamenity costs vary considerably
between the different sources, and no studies are available of this nature on MBT
treatment processes, whilst few are available for landfill and incineration. This
omission is likely to be the more significant of the omissions if one takes the view that
well-regulated processes are unlikely to have significant effects of water and soils.
This section outlines the approach taken within our analysis. Section 63.1 discusses
the generic assumptions which apply to each of the treatment technologies under
consideration. These include assumptions relating to energy generation, and the
external damage costs applied to each of the air pollutants. This is followed by
sections on each of the residual waste treatment technologies in turn. A summary of
the results – presented in terms of the external damage costs attributed to each of
the treatment technologies - is provided in Section 63.6.
63.1 Generic Assumptions for Treatment Technologies
This section describes the underlying assumptions common to all treatment
technologies under consideration within the current analysis.
63.1.1 External Costs
Our approach has been as follows:

979
� We have used two ‘sets’ of unit damage costs, broadly corresponding to ‘low’
and ‘high’ unit damage costs. We have chosen these since they appear to be
the most appropriate to use for an Ireland-specific study:
• the first set uses the lowest of the four Ireland-specific figures (the four
figures are based on differing methodological approaches) for NH3,
VOCs, SOx, NOx and PM2.5 from the Clean Air for Europe (CAFÉ)
programme, and the standard figures from the Benefits Table (BeTa)
database for the remaining non-GHGs. 1195 The figures are given in year
2000 prices, so they are inflated to 2009 prices. Low damage costs for
carbon monoxide are taken from a Danish study. 1196 For carbon
dioxide, the 2009 value as outlined in an ESRI Working paper outlining
a methodology for the incorporating of GHG emission costs into
economic appraisal in Ireland is used, although we do have a number
of concerns about the approach, and whether it genuinely represents a
social cost of carbon. 1197 Damage costs for CH4 and N2O are calculated
by multiplying this figure by their respective Global Warming Potentials
(GWPs) of 21 and 310.
• the second set uses the highest of the four Ireland-specific figures for
NH3, VOCs, SOx NOx and PM2.5 from the Clean Air for Europe (CAFÉ)
programme, and the standard figures from the Benefits Table (BeTa)
database for the remaining non-GHGs. The figures are given in year
2000 prices, so they are inflated to 2009 prices. High damage costs for
carbon monoxide are taken from the same Danish study as the low
costs. For carbon dioxide the high values from the Benefits Table
(BeTa) database are used, and converted to 2009 prices. 1198 Damage
1195 M. Holland and P. Watkiss (2002) Benefits Table Database: Estimates of the Marginal External
Costs of Air Pollution in Europe, Database Prepared for European Commission DG Environment; AEAT
Environment (2005) Damages per tonne Emission of PM2.5, NH3, SO2, NOx and VOCs from Each EU25
Member State (excluding Cyprus) and Surrounding Seas, Report to DG Environment of the European
Commission, March 2005. the Clean Air for Europe programme did not derive estimates for the
remaining non-GHGs.
1196 COWI (2002) Valuation of External Costs of Air Pollution – Phase 1 Report (TRIP). The Danish
Environmental Research Programme.
1197 Tol and Lyons (2008) Incorporating GHG Emission Costs in the Economic Appraisal of Projects
Supported by State Development Agencies. ESRI Working Paper No. 247. Our concerns about the
applicability of this approach include whether the futures market, which has been subject to some
considerable volatility, provides a reasonable indication of the social cost. While this market would
represent the opportunity cost of having to import additional allowances, which could reasonably be
considered a private cost, it does not necessarily follow that this equates to the social cost. Of the two
variants, the model-based price at least accords with an IPPC concentration scenario, while the
assumption of holding the price at the latest available futures price does not seem to us to be a
credible way of representing the social cost of carbon out to 2030 (and beyond). Furthermore, there is
no indication as to whether the carbon prices shown in Table 3 of the paper are in real or nominal
terms.
1198 There is no single published GDP deflator for Ireland covering the period from 2000 to 2009, but
we have determined the correct index based on the GDP deflator for 2003 to 2007 as detailed in the
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costs for CH4 and N2O are calculated by multiplying this figure by their
respective Global Warming Potentials (GWPs) of 21 and 310.
Table 63-1 shows the unit damage costs used.
Table 63-1: Low and High Unit Damage Costs (€/tonne) in 2009 prices
Emission Emission
Low Low Damage Damage Cost Cost High High Damage Damage Cost
Cost
CO2 €26.64 €32.14
CH4 €559.44 €674.86
N2O €8,258.40 €9,962.16
NH3 €3,213.60 €9,146.40
VOCs €840.48 €2,472.00
SOx €5,932.80 €17,304.00
NOx €4,696.80 €13,596.00
CO €1.36 €2.71
Cd €25,956.00 €25,956.00
Cr €21,012.00 €21,012.00
Hg €7,416,000.00 €7,416,000.00
Ni €2,595.60 €2,595.60
Pb €741,600 €741,600
Dioxin €45,732,000,000.00 €45,732,000,000.00
As €98,880.00 €98,880.00
PM2.5 €18,540.00 €51,912.00
There remain considerable gaps in our knowledge of the environmental impacts of
waste management options, and even where the knowledge is ‘emergent’,
straightforward approaches to valuing benefits or costs rarely exist. Some of the
uncertainties involved in this kind of analysis are highlighted in the conclusions of a
recent Danish study, which noted, regarding dioxins from incineration:
The American Environmental Protection Agency put out a draft version of a
report from a very thorough dioxin study in 2000 (US-EPA, 2000). This study
Central Statistics Office’s National Income and Expenditure 2007. To this we have added information
received from the Department of Finance as to the rates of price increase from 2000 to 2002, the
Department’s estimate for 2008, and the Department’s forecast for 2009. The effect is to increase
2000 prices by 23.6% in order to convert them to 2009 prices.

981
includes a dose-response model of the relationship between dioxin and
cancer mortality. This model and Danish emission and intake data are used in
the present report to estimate the socioeconomic costs of dioxin emission
from waste incineration in Denmark and it is estimated that these costs are
about 13 DKK pr. ton of waste (the uncertainty range is 1-128 DKK/ton). This
indicates that dioxin may not be one of the most important kinds of emission
from a socioeconomic point of view. Even though dioxins can cause major
health problems, the emissions are so limited (6,4-28,9 g pr. year) that the
economic damages are probably relatively small.
Considering the large number of uncertainties, the estimate of 13 DKK pr. ton
has to be looked upon as an example of calculation rather than an exact price
that can be used directly in economic valuation studies or cost/benefit
analyses. One of the major problems of this estimate is that the doseresponse
model ascribes a very high risk to dioxins. On the other hand, the
estimate excludes all morbidity effects and potential damages on the
environment. Consequently, it is not possible to assess whether 13 DKK pr.
ton is a high or a low estimate. 1199
The range of damages referred to equates to a range from £0.93 to £11.85 per tonne
of waste incinerated. Considering both the scientific uncertainties in the estimation of
impacts, and the unresolved methodological issues which affect valuation
techniques, such ranges might be considered quite unexceptional (although it should
be noted that the effect of dioxins in this study is nowhere near as high as the upper
end of the range quoted in the Danish study). 1200
63.1.2 Omissions from the Analysis
The following is a list (almost certainly not extensive) of externalities not covered / not
explicitly accounted for by the study. In all cases, the omissions relate to ‘direct’ and
‘avoided’ impacts:
� Disamenity (including odour, nuisance)
The argument that there is insufficient data available to incorporate
disamenity in a cost-benefit study comparing landfill with incineration is losing
1199 D. Jensen and N. Dengsoe (2004) Værdisætning af skadesomkostninger ved affaldsforbrænding -
en analyse af dioxiners skadelige effekter og et egneeksempel på disse effekters
samfundsøkonomiske omkostninger, TemaNord 2004:518, Copenhagen, Nordic Ministry.
1200 Some take these ranges to be evidence of some shortcoming in the methodological approach, and
we have heard some give this as a reason whey they prefer life-cycle assessment over cost-benefit
approaches. But if LCAs appear to give a more certain view of the world, this has to be considered
largely illusory. LCAs tend to reduce ‘impact assessment’ to one number, obscuring (rather than
highlighting) uncertainties, and with rarely any attempt to place margins for error around the figures
being generated. The scientific uncertainties have not ‘disappeared’, rather they are less explicitly
acknowledged (or ignored) because of the lack of any ranges in the weightings assigned to pollutants
in any given impact assessment category. This is all the more strange in LCAs since there is no attempt
to pinpoint ‘impact’ (as opposed to ‘potential impact’) whereas most CBAs are at least based upon
some effort to understand actual impacts upon receptors. Neither approach is perfect, but scientific
uncertainties surround both.
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credibility. None of the impacts assessed can be said to have been estimated
with a high level of certainty. The standard of proof for disamenity should not,
arguably, have to be any higher. However, in comparing a wider range of
treatments, we have chosen to omit disamenity from the analysis. Our view is
that if disamenity was to be included, incinerators located in dense urban
areas would fare worst, and well-managed biological treatment facilities
(including quality odour treatment) in rural areas would fare best;
� Air emissions other than the following:
• CO2
• CH4
• N2O
• NH3
• VOCs
• PM2.5
• SOx
• NOx
• CO
• Cd
• Cr
• Hg
• Ni
• Pb
• Dioxin
• As
� Bioaerosols
It seems likely that the main risks relate to composting and anaerobic
digestion where the digestion process includes a post-digestion aerobic step.
However, some bioaerosols are likely to be present at all waste facilities. Key
uncertainties which remain to be considered relate to the source factor as it
relates to biowaste treatments (and, importantly, how the source factors might
be reduced) and the exposure response relationship between the microorganisms
which may be released and the population exposed.
� Emissions to land
No emissions to land have been. This almost certainly means that the
treatment of landfills, and processes which lead to landfilling, is too
favourable. Where the application of source separated organic material to land
is concerned, no environmental disbenefit is assumed to occur on the basis
that application rates would not lead to elevated (above prevailing levels)
concentrations of potentially toxic elements. A limitation of life cycle

983
assessments is that the blanket application of toxicity weightings to
applications of trace concentrations of metals to soil – even where the impact
on soil quality is suggested by reputable studies to be very limited – tends to
suggest major impacts in terms of toxicity where none may apply;
� Emissions to water
The emissions to water are likely to be a greater issue for landfills and for
anaerobic digestion plants (depending upon the details of the facility’s design
and operation). It is sometimes assumed, in cost-benefit analyses, that the
environmental costs of emissions to water are reduced, and effectively
internalised, through payments for / investments in waste water treatment at
waste management facilities. Our analysis includes some estimates of
emissions related to treatment of leachate from landfills. No other emissions
are accounted for. At compost facilities, it is assumed that the majority of
water is re-circulated in the plant. At anaerobic digestion facilities, whether or
not, and to what extent, process waters are treated at waste water treatment
plants varies. Finally, pollution of water courses can be an issue for
incinerators, notably where wet scrubbers are used, but in the facility modelled
in this study, water pollution is not assumed to be a major issue.
� Externalities associated with construction
We have not considered external costs associated with construction of
facilities. It is generally stated that these account for a small proportion of the
overall impacts. However, it is difficult to be quite so sanguine about this when
a cost-benefit perspective, incorporating non-zero discount rates, is employed.
All construction-related externalities occur early in time (by definition).
Consequently, the construction related externalities will weigh proportionately
greater in an analysis using discounting than in one where no discounting is
used (for example, in most life cycle assessments). Countering this argument
is the possibility that construction materials can be re-used / recycled at the
end of their life.
� Household time
The effect on household time has not been considered in this study. The
reader is referred to a recent study for a discussion of this issue; 1201
� Water use at facilities
This is another impact which is not captured in conventional life-cycle
assessment. We have looked at the effect of compost applications on reducing
the requirement for irrigation water. We have not looked at the use of water at
the plants themselves. Demand is likely to be greatest at incinerators, though
equally, low solids AD facilities may require considerable water. The degree to
which process waters can be recirculated in the process is likely to vary (for all
plant types) with detailed design.
1201 See D. Hogg (2006) Impact of Unit-based Waste Collection Charges, Report for the OECD
Environment Directorate, Working Group on Waste Prevention and recycling, May 2006.
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984
� Land use
Some studies have debated whether or not to assess the opportunity cost of
land in the assessment of externalities. 1202 Generally, however, the view tends
to be adopted that land values are reflected in the cost of facilities. 1203 This
has not been included in this analysis.
� Transport
The assumption made is that transport externalities are internalised in fuel
and other transport-related duties. The degree to which this assumption holds
good relates to the significance accorded to (and the approach to valuing)
congestion externalities, if indeed these should be considered as external
costs. It can be argued that a proportion of the costs associated with
congestion are not ‘external’ insofar as transport decisions are made on the
basis of some knowledge as to when congestion is likely to occur. Indeed, in
the waste management case, service providers will be sensitive to congestionrelated
issues in terms of the timing of their collection rounds. However, if
marginal congestion costs are estimated on the basis of marginal additions to
traffic, these can be quite high, and the assumption that existing duties
internalise all externalities almost certainly breaks down. 1204 Notwithstanding
these points, to the extent that the assumption might not be valid, then to the
extent that one is seeking to understand changes in the transport externalities
across different systems, it can reasonably be argued that these changes are
unlikely to have a major influence on the analysis.
63.1.3 Emissions Associated with Energy Generation
All waste management processes consume, and in many cases, generate energy.
Where energy is generated, it can be considered to replace a requirement for
equivalent amounts of power from other sources.
There are climate change and air quality impacts associated with the consumption
and the generation of energy. Emissions from the use of diesel are considered within
1202 For example, a Dutch study attributed significant externalities to landfill related to these costs (E.
Dijkgraaf and H. R. J. Vollebergh (2004), Burn or Bury? A Social Cost Comparison of Final Waste
Disposal Methods, Ecological Economics, 50, 233-247).
1203 This includes most, if not all, studies other than that cited in the previous footnote, including a
recent Dutch study which discussed Dijkgraaf and Vollebergh’s approach (H. Bartelings, P. van
Beukering, O. Kuik, V. Linderhof, F. Oosterhuis, L. Brander and A. Wagtendonk (2005) Effectiveness of
Landfill Taxation, R-05/05, Report Commissioned by Ministerie von VROM, November 24, 2005).
1204 For example, work for the then DETR looks at the marginal costs of congestion using linear (with
respect to vehicle quantities) speed-flow curves, and assuming that the value of time should be valued
at something close to the average wage rate (see T. Sansom, C. Nash, P. Mackie, J. Shires and P.
Watkiss (2001) Surface Transport Costs and Charges: Great Britain 1998, Report for DETR, July
2001). All these (and other) assumptions are open to question to a degree. This approach tends to give
high marginal costs for congestion. It gives highest costs for dense urban areas at peak hours,
arguably the very time when most people are likely to internalise these costs into their decision-making
processes. From this point of view, it is questionable whether the attribution of congestion costs as a
‘marginal externality’ is necessarily correct, albeit it is an accepted approach in the literature.
29/09/09

our analysis, as well as those associated with the use and generation of electricity.
These impacts are discussed in the following sub-sections.
63.1.3.1 Electricity
The carbon intensity of an energy source is the quantity of GHG emissions associated
with generating the energy. Where emissions are avoided as a result of generating
energy from waste, assumptions regarding which source of energy is considered to
have been displaced are important in determining the overall GHG benefit associated
with power generation.
Over the period 2005-2007, electricity demand in Ireland increased by 3.1% per
annum on average. With a growing demand for electricity, the marginal source of
generation – that considered most likely to be newly built in the absence of capacity
arising through energy from waste infrastructure – is assumed to be displaced. For
Ireland the marginal source would be CCGT gas plant, representing the trend in terms
of recently commissioned power generation technology in Ireland. 1205 The CO2
emissions associated with generating electricity from natural gas are taken to be
360g/kWh. 1206
Natural gas is a very clean fuel and is thus completely combusted at CCGT plant,
resulting in negligible emissions of particulates and SO2. The principal emissions to
air associated with the generation of electricity using CCGT are therefore NOx and CO.
The European Commission Reference Document for large combustion plant suggests
a range of NOx emissions of 10-130 g/GJ electrical output depending on the size of
the plant and the abatement technique employed. 1207 Measures taken to reduce NOx
emissions are less effective at the higher generation efficiencies. The lower end of the
range reflects measurements taken at a relatively small (100 MWe) facility using SCR
to reduce NOx emissions. We assume NOx emissions of 70 g/GJ electrical output for
electricity generated at a new CCGT plant.
CO emissions are usually lower for CCGT plant in comparison to the NOx emission,
although these also vary depending on the size of the facility. We assume CO
emissions of 45 g/GJ electrical output for electricity generated at a new CCGT plant
based on data obtained from the aforementioned Reference Document.
1205 Sustainable Energy Ireland (2008) Energy in Ireland 1990 – 2007. Available at
http://www.sei.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy_in_Ireland_1990-
2007.pdf (accessed May 2009)
1206 BERR (2009) Fuel Mix Disclosure Data Table, UK Department for Business Enterprise & Regulatory
Reform. Available at http://www.berr.gov.uk/energy/markets/electricity-markets/fuelmix/page21629.html
(accessed May 2009).
1207 European Commission (2006) Integrated Pollution Prevention and Control: Reference Document
on Best Available Techniques for Large Combustion Plant, July 2006.
985
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63.1.3.2 Diesel
We have used a figure of 3.09 kg CO2 equivalent per litre of diesel (including 0.46 kg
CO2 equivalent pre-combustion emissions). External damage costs with respect to
climate change associated with diesel use are therefore €0.09 per litre of diesel. 1208
Data regarding the air quality impacts associated with the use of diesel within waste
management facilities is taken from the BUWAL life-cycle inventory database
produced by the Federal Office for the Environment in Switzerland. 1209 Total damage
costs are €1.66 per litre of diesel if the high external costs are assumed, or €0.57 per
litre using the lower costs. Approximately 12% of the total damage cost relates to precombustion
emissions. The external costs are dominated by NOx externalities which
equate to 99% of the air pollution impacts associated with diesel use.
63.1.4 Emissions Avoided Through Recycling
Recovery of material from the residual waste stream occurs at incineration and MBT
facilities, as well as at recycling facilities.
Most studies provide estimates of greenhouse gas reductions delivered by ‘front-end’
collection and recovery systems, i.e. kerbside or bring recycling, followed if necessary
by sorting within a Materials Recovery Facility (if collected in commingled form).
Materials recovered from residual wastes, however, have higher levels of
contamination as a result of contact with the mixed residual waste stream.
Depending upon the material, this contamination may have the following impacts:
986
� Rather than a ‘closed-loop’ process, materials might be recycled into lower
value applications (for example, mixed glass to aggregates or plastics to
“plaswood”, which deliver reduced, if any, carbon benefits); and
� Prior to reprocessing, contaminated materials will require energy for cleaning
processes - for example, hot-washing of plastics - and thus will deliver lower
carbon benefits than clean streams.
The current analysis attributes the same greenhouse gas benefits to recyclables
removed from residual waste as those obtained through specific collections. For most
dry recyclables, this is a broadly acceptable approach since the effects of
contamination are probably such as to affect price more than the associated benefits.
However, the approach probably overstates the benefits associated with this practice
at present, though this will be true only where it is assumed that plastics are
extracted for recycling. Table 63-2 provides a summary of the values used.
1208 There is relatively little difference between the high and low damage costs for climate change
impacts.
1209 Available from http://www.bafu.admin.ch
29/09/09

Table 63-2: Emissions Avoided Through Recycling from Residual Waste Facilities
Material
Material
987
International Review of Waste Policy: Annexes
Avoided Avoided emissions, emissions, t t CO CO2equ CO qu / t recycled
material
material
Dense plastic 0.7
Steel 1.0
Aluminium 10.5
Source: WRATE / Ecoinvent database, available from http://www.environmentagency.gov.uk/research/commercial/102929.aspx
The production of materials from recycled input may also result in avoided air quality
impacts when the manufacture of these goods is compared to their production from
virgin materials. However the air quality impacts associated with these processes are
localised. Since most of the manufacturing of material (from either virgin or recycled
input) occurs outside Ireland, we have not included these impacts within our analysis,
as they will not have a direct impact on Irish air quality.
63.1.5 Residual Waste Composition
The residual waste composition used within our analysis is developed from the recent
waste characterisation survey produced for the Environmental Protection Agency by
RPS. 1210 This data is shown in Table 63-3.
Table 63-3: Assumed Residual Waste Composition
Compositional Compositional element element element
%
Paper
Card
Plastic Film
Dense Plastic
Newspapers 0.99%
Magazines 0.66%
Other recyclable paper 0.76%
Non-recyclable paper 0.51%
Cardboard 3.01%
Card and paper packaging 8.60%
Card non packaging 0.43%
Liquid cartons 1.00%
Unclassified paper and card 1.29%
Refuse sacks and carrier bags 3.60%
Packaging film 3.44%
Other plastic film 0.33%
PET clear 0.50%
PET coloured 0.25%
HDPE natural 0.36%
HDPE coloured 0.18%
PVC natural 0.02%
1210 RPS (2009) Municipal Waste Characterisation Surveys 2008, Report for the EPA, March 2009

Textiles
Misc Combustibles
988
29/09/09
PVC coloured 0.02%
Food packaging 2.58%
Non-food packaging 1.29%
Other 2.58%
Natural man-made fibres 0.89%
Unclassified 3.99%
Disposable nappies 7.40%
Shoes 1.05%
Wood (includes furniture) 4.94%
Misc Non Combustibles Unclassified 7.40%
Glass
Ferrous Metals
Non-ferrous
Putrescibles
Clear bottles and jars 0.77%
Green bottles and jars 0.77%
Brown bottles and jars 0.47%
Other glass 0.13%
Food cans 1.13%
Beverage cans 0.57%
Batteries 0.07%
Other ferrous 1.31%
Aluminium foil 0.14%
Aluminium beverage cans 0.29%
Aluminium food cans 0.56%
Garden waste 2.80%
Kitchen waste 26.13%
Unclassified 1.78%
Fines Fines 5.07%
63.2 Landfill
63.2.1 Climate Change Impacts
Section 63.2.1.1 discusses landfill gas generation (related to the carbon content of
the waste) and its capture. This is considered for the landfilling of untreated wastes
and those that have been subject to pre-treatment such as occurs in an MBT facility.
Assumptions regarding landfill gas management are summarised in Section 63.2.1.6
which also includes a summary of the external costs associated with the climate
change impacts of landfill.
63.2.1.1 Landfill Gas Generation
In order to capture the relationship between degradation and residence time, our
model links the nature of the constituent organic compounds to the release of
greenhouse gases through time-dependent ‘first order decay’ functions (as is done in

the Swedish ORWARE model for controlled anaerobic processes). 1211 Emissions of
methane from landfill are allocated to specific years over a 150 year period. The
degradation factors within the model have been validated to some extent through
assessing the implied methane emissions from the materials and cross-checking
against work undertaken in the United States and by the UK Environment Agency. 1212
The constituent carbon fractions degrade at different speeds as a result of variations
in their chemical and physical structure. Our model uses three degradation speeds to
represent the varying speeds at which carbon degrades within the landfill. 1213 The
simplified grouping of carbon fractions used within the model is shown in Table 63-4.
Table 63-4: Simplification of Carbon Fractions for Landfill
Speed Speed of of Decay Decay
Carbon Carbon Fraction(s)
Fraction(s)
Fast Sugars
Medium Fats, Proteins, Cellulose
Slow Lignin and some Cellulose 1
Notes
1. Some cellulose is bound within the lignin and is therefore similarly resistant to
degradation
Source: Dalemo M (1996) The Modelling of an Anaerobic Digestion Plant and a Sewage Plant in the
ORWARE Simulation Model, Rapport 213, Swedish University of Agricultural Sciences, Uppsala 1996
To take account of the time profile of these emissions over the 150 year period, the
damage costs for landfill emissions are discounted using a declining long-term
discount rate as recommended in the UK Treasury’s Green Book. 1214 Table 63-5
shows the rates at which damage costs are discounted for the relevant time periods
1211 M. Dalemo (1997) The ORWARE Simulation Model - Anaerobic Digestion and Sewage Plant Submodels;
Licentiate thesis, Swedish University of Agricultural Sciences, SLU, Uppsala; Dalemo M (1999)
Environmental Systems Analysis of Organic Waste Management; The ORWARE Model and the Sewage
Plant and Anaerobic Digestion Submodels, Ph D Thesis, Swedish University of Agricultural Sciences,
Uppsala.
1212 M. Barlaz (1997) Biodegradative Analysis of Municipal Solid Waste in Laboratory-scale Landfills,
EPA 600/R-97-071, Washington, DC: USEPA; R. Gregory and A. Revans (2000) Part One, in
Environment Agency (2000) Life Cycle Inventory Development for Waste Management Operations:
Landfill, Project Record P1/392/3, Bristol: Environment Agency
1213 The same approach is taken in modelling other anaerobic processes, including landfill (see, for
example, LQM (2003) Methane Emissions from Landfill Sites in the UK, Report for Defra, January
2003). The method is not usually applied to aerobic processes, though some work of a similar nature
has been undertaken for degradation of organic matter in soil (including the work by DU).
1214 HM Treasury (UK) The Green Book: Appraisal and Evaluation in Central Government, Treasury
Guidance, http://www.hm-treasury.gov.uk/d/green_book_complete.pdf .
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Table 63-5: Declining Long-Term Discount Rate as Applied to Landfill Emission
Damage Costs
Period Period Period of of
of
years years
years
Discount
Discount
rate rate
rate
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0-30 30 30 31 31-75 31
75 75 76 76-125 76
125 125 126 126-200 126 126 200 200 201 201-300 201 201 300 300 301+ 301+
301+
3.5% 3.0% 2.5% 2.0% 1.5% 1.0%
63.2.1.2 The Issue of Gas Capture
There is some debate with regard to both the efficiency landfill gas capture and the
proportion of the gas that is used for energy generation. Of these, the gas capture
rate is both the most sensitive and the most contested component.
A previous assessment undertaken by Eunomia used a gas capture rate of 50%, an
approach based upon two studies conducted on behalf of Defra by LQM and
Enviros. 1215 A subsequent study conducted by ERM on behalf of Defra, however,
assumed a 75% capture rate over the 100 year timeframe assessed. 1216 A
subsequent ERM report acknowledged that if one moved the analysis beyond this
(somewhat arbitrary) timeframe, lifetime capture rates might be around 59%. 1217
Documentation supplied with the Golders model indicates that the expert review
group formed as part of that study considered that 85% of the gas would be collected
during the gas utilisation phases, and a lifetime 75% gas capture rate appears to
have been suggested upon that basis. 1218
The wider literature suggests a range of estimates for the efficiency of gas collection
with a distinction being made between instantaneous collection efficiencies and the
proportion of gas that can be captured over the lifetime of the landfill. 1219 Whilst
1215 Eunomia (2006) A Changing Climate for Energy from Waste? Final report to Friends of the Earth,
May 2006; LQM (2003) Methane Emissions from Landfill Sites in the UK, Report for Defra, January
2003; Enviros, University of Birmingham, RPA Ltd., Open University and M. Thurgood (2004) Review of
Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes,
Final Report to Defra, March 2004.
1216 ERM (2006) Impact of Energy from Waste and Recycling Policy on UK Greenhouse Gas Emissions,
Final Report for Defra, January 2006.
1217 ERM (2006) Carbon Balances and Energy Impacts of the Management of UK Wastes, Defra R&D
project WRT 237. December 2006
1218 Golder Associates (2005) Report on UK Landfill Methane Emissions: Evaluation and Appraisal of
Waste Policies and Projections to 2050, report for Defra, November 2005
1219 P. Anderson (2005) The Landfill Gas Recovery Hoax, Abstract for 2005 National Green Power
Marketing Conference; USEPA (2004) Direct Emissions from Municipal Solid Waste Landfilling, Climate
Leaders Greenhouse Gas Inventory Protocol – Core Module Guidance, October 2004; K.A. Brown, A.
Smith, S.J Burnley, D.J.V. Campbell, K. King and M.J.T. Milton (1999) Methane Emissions from UK
Landfills, Report for the UK Department of the Environment, Transport and the Regions.

instantaneous collection rates for permanently capped landfilled waste can be as
high as 90%, capture rates may be much lower during the operating phase of the
landfill (35%) or when the waste is capped with a temporary cover (65%). 1220 In
addition, gas collection is technologically impractical towards the end of the site’s life.
The Intergovernmental Panel on Climate Change (IPCC) has recently stated that
lifetime gas capture rates may be as low as 20%. 1221 We would consider, however,
that landfills in the UK are somewhat better engineered than in the general (global)
case, although a recent report by the European Environment Agency uses the IPCC
figure. 1222
We have assumed a landfill gas capture of 50% as our central assumption. Results
obtained assuming 20% of the landfill gas is captured are also presented for
sensitivity analysis.
Our model assumes that waste which has been pre-treated (e.g. through an aerobic
stabilisation process) will behave differently in landfill with respect to the generation
of landfill gas, and that pre-treated wastes will therefore ultimately require a different
form of gas management in landfill. The landfill of pre-treated waste is discussed in
Section 63.2.1.5.
63.2.1.3 Energy Generated from Landfill Gas
Energy is generated from a variable proportion of the recovered gas. At times of high
flux, emissions can be greater than the capacity of the engines and thus a proportion
of the gas must be flared. At times of low flux, i.e. towards the end of the site lifetime,
emissions may be too small for the gas engines to function effectively. In such a
situation, the usual practice of the landfill operator is to flare the gas.
LQM carried out a survey of landfill operators to estimate the total flare capacity
across UK landfills. 1223 They noted within their analysis that:
991
There are difficulties in ascertaining the actual volumes of LFG burnt as
detailed records, if they exist at all, will be held by individual site operators. It
is rare to find a flow stack with a flow measurement device installed, even
though the capital cost of such a device is relatively small.
1220 K. Spokas, J. Bogner, J.P. Chanton, M. Morcet, C. Aran, C. Graff, Y. Moreau-Le Golvan and I. Hebe
(2006) Methane Mass Balance at 3 Landfill Sites: What is the Efficiency of Capture by Gas Collection
Systems? Waste Management, 5, pp515-525
1221 IPCC (2007) Climate Change 2007: Mitigation. Contribution of Working Group III to the Fourth
Assessment Report of the Intergovernmental Panel on Climate Change (B. Metz, O.R. Davidson, P.R.
Bosch, R. Dave, and L.A. Meyer (eds), Cambridge University Press, Cambridge, United Kingdom and
New York, NY, USA., pp 600.
1222 M. Skovgaard, N. Hedal, A. Villanueva, F. Andersen and H. Larsen (2008) Municipal Waste
Management and Greenhouse Gases, ETC/RWM Working Paper 2008/1, January 2008.
1223 Land Quality Management (2003) Methane Emissions from Landfill sites in the UK, Final Report
for Defra, January 2003.
International Review of Waste Policy: Annexes

LQM did not consider the amount of energy generated from LFG within their analysis,
although they estimated the total flaring back-up capacity to be around 60% of
generation capacity. It is usual for landfill operators to maximise energy generation as
this represents a revenue stream. We assume within the current analysis that 40% of
the recovered gas will be flared. Although it is acknowledged that there is some
uncertainty here, the impact of this uncertainty (in terms of CO2 equivalent offsets
associated with energy generation from landfill) is relatively small.
63.2.1.4 Oxidation of Landfill Gas
Some of the uncaptured landfill gas will be oxidised as it passes through the cap to
the surface, the proportion being dependent upon the nature of the cap. The USEPA
suggests a range of 10% to 25%, with clay soils at the lower end of the range and topsoils
being at the higher end. This reflects a figure proposed by Brown et al in 1999 in
a study on behalf of what was then the DETR. 1224 A similar value was proposed by the
IPCC.
However, a recently published review of the wider literature on this subject suggests
that the mean fraction of methane oxidised was 36% (an average across 42 studies
taken in a variety of locations). 1225 We have retained the 10% figure assumed by the
IPCC and USEPA, but acknowledge that this is likely to overestimate fugitive
emissions of methane occurring from landfill in many cases.
63.2.1.5 Landfill of Pre-treated Waste
Under the very low fluxes of landfill gas assumed to occur when pre-treated wastes
are landfilled, the methanotrophic bacteria within the soil cover can oxidise a much
larger portion of the methane delivered them, oxidising up to 95-100% of the
emission. 1225 The very low gas production resulting from landfilling MBT residues in
German and Austrian cases, especially for methane, is estimated to be around 1 l
CH4/m 2 *h in a typical landfill. 1226 In this case, no active landfill gas collection is
possible. To prevent gas emissions into the atmosphere, a passive method of
oxidation of the residual emissions is necessary. A suitable approach is the use of a
biologically active oxidising landfill cover, consisting of biologically active material like
compost. This oxidises the methane gas during its passage through the layer.
As a survey of several experimental results indicate, the oxidising capacity of soils and
landfill layers are in the range of 0.01 to 16.8 l CH4/m 2*h. 1227 Most values are
1224 K.A. Brown, A. Smith, S.J. Burnley, D.V.J. Campbell, K. King and M.J.T. Milton (1999) Methane
Emissions from UK Landfills, A Report for the UK Department of the Environment, Transport and the
Regions.
1225 J.P. Chanton, D.K. Powelson and R.B. Green (2009) Methane Oxidation in Landfill Cover Soils, is a
10% Default Value Reasonable? Journal of Environmental Quality, 38, pp 654-663.
1226 Soyez, K., and Plickert, S. Mechanical-Biological Pre-Treatment of Waste – State of the Art and
Potentials of Biotechnology, University of Potsdam, mimeograph.
1227 K. Hoering, I. Kruempelbeck, H-J. Ehrig, (1999) Long-term emission behaviour of mechanicalbiological
pre-treated municipal solid waste. In: Proceedings Sardinia 99. Seventh International Waste
992
29/09/09

etween 0.1 to 5 l CH4/m 2*h, so that a mean value of 3 l CH4/m 2*h seems realistic.
Even if one considers the potential influence of temperature, water content, and the
varying gas qualities, it seems entirely probable, therefore, that such a layer would be
able to oxidise a very high proportion of methane from the landfill gas emanating from
MBT-treated wastes. Early trials suggest that a gas oxidation layer of about 120 cm
combined with a gas distribution layer of 50 cm is suitable. 1228 Fugitive emissions of
methane are therefore minimal in this case.
The positive effects on landfill behaviour of pre-treatment can only be realised if the
landfill is adapted to the conditions presented by the waste. Landfill gas capture is
not necessary (the low flux makes this technically infeasible, as was previously
discussed in Section 63.2.1.2) and therefore no energy is generated from the landfill
gas.
We have effectively modelled two landfills. In the first, we keep the characteristics of
the landfill the same as for general mixed waste. All that changes is that the gas
generation from the treated waste is low. However, as part of a more general
‘landfilling of waste’, we assume that in these situations, any gas emitted is treated
as though it was coming from untreated waste.
In the medium- to long-term, we would expect, particularly with the pre-treatment
guidelines enforced, that landfill cells would be designed for primarily treated waste.
In this case, we have modelled a second landfill kin which there is no gas capture in
the conventional sense, where an active cover layer is depleted, and where, in line
with the evidence cited above, 90% of the remaining methane emitted is oxidised by
the landfill cover layer.
63.2.1.6 Summary of Assumptions - Climate Change Impacts of Landfill
Table 63-6 summarises our assumptions with regard to the management of landfill
gas for untreated waste. These landfill gas capture assumptions result in total climate
change impacts of €79.80 per tonne of untreated waste to landfill if the high external
costs are assumed, or €63.06 if the lower damage costs are applied. The totals
include emissions associated with energy used at the landfill (although these are
insignificant in comparison to the direct emissions from the process).
Management and Landfill Symposium. S Margherita di Pula, Caligari, Italy, 4-8 October 1999. pp 409-
418.
1228 Humer, M.; Lechner, P.: Design of a landfill cover layer to enhance methane oxidation - results of a
two year field investigation. In: Christensen, T.H.; Cossu, R.; Stegmann, R. (Eds): Proc. Sardinia 2001,
8. Int. Waste management and Landfill symposium, Vol. 2, 541-550, Cagliari, 2001.
993
International Review of Waste Policy: Annexes

Table 63-6: Landfill Gas Management – Untreated Waste
Parameter Parameter Parameter
Assumption
Assumption
Proportion of methane captured (central assumption) 1 50%
Proportion of captured methane used for energy generation 60%
Proportion of captured methane that is flared 40%
Efficiency of electricity generation, landfill gas engine 35%
Rate of oxidation of methane within the landfill cover 10%
Notes
994
1. Results obtained assuming 20% of the gas is captured are considered as sensitivity
analysis
Table 63-7 outlines the central assumptions used to model the behaviour of pretreated
waste in landfill.
Table 63-7: Landfill Gas Management – Pre-treated Waste (Central Assumptions)
Parameter Parameter
Assumption Assumption
Assumption
Proportion of methane captured 0%
Rate of oxidation of methane within the landfill cover 90%
Notes
We also present results assuming the same landfill gas management as described in Table
63-6 for sensitivity analysis
63.2.2 Air Quality Impacts of Landfill
63.2.2.1 Landfill of Untreated Wastes
Whilst landfill gas is principally comprised of methane and carbon dioxide,
approximately 1% of the volume of the gas is made up of trace elements. This can
29/09/09

include up to 150 substances including halogenated organics, organo-sulphur
compounds and aromatic hydrocarbons depending on the nature of the waste. 1229
The gases which are emitted in any one year are assumed to be related to the
quantity of methane or CO2 produced, depending upon whether one is considering
raw gas or gas once combusted (Table 63-8). Methane emissions to the atmosphere
and methane emissions captured are both used to estimate, on a proportional basis,
emissions of different trace gases in a given year using the relative composition of
gas outlined in below. The way this is done is to normalise the concentrations (by
weight) so that:
995
� Where gas is flared, the emissions of other gases are calculated with
reference to the studies by Enviros et al and White et al. The way this is done
is by calculating the CO2 content of flared gas and calculating the emissions of
other gases through the quantities relative to CO2 as specified in the two
studies mentioned;
� A similar approach is used to calculate fugitive emissions, but in this case, the
other emissions are calculated relative to the calculated quantity of methane
emissions; and
� For gas which is emitted from the gas engine, the emissions of other gases are
calculated using the quantities estimated in other studies relative to
calculated CO2 emissions.
There are some inconsistencies in this approach, the principal one being that the
White et al data make little allowance for changes in the level of oxidation of methane
through the cap of the landfill site. Our model incorporates this as a variable. It is
important to appreciate here that oxidation may appear not only at the cap (and
typical estimates in the literature are 10%), but also in the leachate, so that total
oxidation of methane to carbon dioxide may be greater than is sometimes suggested.
Landfills produce less of the pollutants for which dose response functions are
tolerably well known. No external damage costs have therefore been developed for
many of pollutants listed in Table 63-8. Externalities associated with the non
greenhouse gas air pollutants result in damage costs totalling €4.92 per tonne of
landfilled waste under the high externalities, or €2.07 if the lower values are
assumed. These figures include impacts associated with the use of diesel at the
facility, and a small amount of avoided emissions resulting from the generation of
electricity from landfill gas.
1229 Komex (2002) Investigation of the Composition and Emissions of Trace Components in Landfill
Gas, R&D Technical Report P1-438/TR for the Environment Agency, Bristol.
International Review of Waste Policy: Annexes

Table 63-8: Non Greenhouse Gas Emissions to Air from Landfilling
996
29/09/09
Emissions Emissions mg/Nm mg/Nm3
landfill landfill gas
gas
Fugitiv Fugitive Fugitiv
Ratio Ratio to
to
CH CH4 CH
Flaring Flaring
Flaring
Ratio Ratio to
to
CO CO2 CO
Generation
Generation
Ratio Ratio to to
to
CO CO2 CO
Source
Source
Methane 1 0.001818 0.005714 Enviros
Carbon dioxide 1.733333 1 1 Enviros
Carbon monoxide 3.03E-05 4.09E-04 4.09E-04 White et al
Hydrogen sulphide 4.66E-04 1.69E-08 1.69E-08 White et al
Hydrogen chloride 2.67E-06 8.64E-05 1.14E-05 Enviros
Hydrogen fluoride 5.33E-07 1.82E-05 1.14E-05 Enviros
Chlorinated HC 8.10E-05 5.10E-06 5.10E-06 Enviros
Dioxins and furans 0 3.36E-13 5.43E-13 Enviros
Total Particulates 0 3.64E-05 0.00002 Enviros
Nitrogen oxides 0 0.000455 0.002571 Enviros
Sulphur dioxide 0 0.000545 0.0002 Enviros
Cadmium 0 0 2.86E-07 Enviros
Chromium 7.12E-08 1.25E-08 1.25E-08 White et al
Lead 2.00E-08 2.49E-09 2.49E-09 White et al
Mercury 1.41E-08 2.49E-09 4.57E-09 Enviros
Zinc 1.68E-07 6.64E-11 6.64E-11 White et al
Nickel 0 0 3.71E-08 Enviros
Arsenic 0 0 4.57E-09 Enviros
Total VOCs 0.000333 7.73E-06 0 Enviros
Non-methane VOCs 0 8.64E-06 8.57E-05 Enviros
1,1-dichloroethane 0.000036 0 0 Enviros
Chloroethane 1.33E-05 0 0 Enviros
Chloroethene 1.47E-05 0 0 Enviros
Chlorobenzene 0.000032 0 0 Enviros
Tetrachloroethene 0.000044 3.64E-08 5.71E-07 Enviros
Poly-chlorinated biphenyls 0 0 0 White et al
Benzene 3.2E-06 0 0 Enviros
Source: Adapted from White P R, Franke M and Hindle P (1995) Integrated Solid Waste Management:
A Lifecycle Inventory, Blackie Academic & Professional, Chapman and Hall; Enviros, University of
Birmingham, RPA Ltd., Open University and Thurgood M (2004) Review of Environmental and Health
Effects of Waste Management: Municipal Solid Waste and Similar Wastes, Final Report to Defra,
March 2004

63.2.2.2 Landfill of Pre-treated Wastes
Whilst data relating to measurement of trace components in fugitive emissions of
landfill gas from untreated waste is relatively limited, even less research has been
undertaken into those from pre-treated wastes. 1230
Most MBT processes use biofilters (or in limited cases regenerative thermal oxidation
(RTO) techniques) to capture trace components from the exhaust gas produced
during the stabilisation phase. It would seem logical that there will be fewer trace
components emitted through fugitive emissions of gas once the output is resident in
landfill following the pre-treatment process.
Optimized biofilters can remove 50-70% of the total organic content of the waste gas
generated during these processes, although their efficiency is in part determined by
the volume of gas produced. 1231 Typical values for efficiency of compound removal
are shown in Table 63-9.
Table 63-9: Biofilter Efficiencies of MBT Treatment Process
Waste Waste Gas Gas Gas Component Component / / Substance Substance Group Group
Biofilter Biofilter Efficiency Efficiency %
%
Aldehydes 75%
Alkanes 75%
Alcohols 90%
AOX 40%
Aromatic hydrocarbons (benzene) 40%
Aromatic hydrocarbons (toluene, xylene) 80%
NMVOC 83%
PAK, PCB, PCDD/F 40%
Odour 95% - 99%
Ammonia 90%
Source: Binner E (2002) The Impact of Mechanical-Biological Pre-treatment on the Landfill Behaviour
of Solid Wastes, Biological treatment of Biodegradable Waste: Technical aspects, Workshop 8-10 April
2002, Brussels, pp355-372
A reduction in the externalities associated with emissions of the trace elements found
in landfill gas can be expected for pre-treated wastes. Given the lack of data available
for such material, however, we have applied the values in Table 63-8 for both types of
wastes. In this context, we acknowledge that our results will underestimate the overall
reduction in externalities that will occur as a result of treatment of wastes at MBT
facilities.
1230 It should be noted that levels of trace components in landfill gas from untreated wastes are much
lower than in typical emissions from incinerators.
1231 K. Fricke and W. Bidlingmaier (2002) Gaseous and Sewage Emissions in Mechanical-Biological
Rest Waste Treatment, Biological Treatment of Biodegradable Waste: Technical Aspects, Workshop 8-
10 April 2002, Brussels, pp341-354.
997
International Review of Waste Policy: Annexes

63.3 Incineration
63.3.1 Climate Change Impacts of Incineration
Greenhouse gas emissions occurring as a result of the incineration of waste will be
dependent upon the carbon content of the dry material, along with the overall
efficiency of energy generation that results from the combustion of that material.
Table 63-10 details the carbon content of waste components together with their
energy and moisture content.
Table 63-10: Carbon Contents and Energy Content for Materials in the Waste Stream
998
29/09/09
Total Total C C (% fm)
Proportion Proportion of of of C
C
that that is is non non
non
fossil fossil2
Energy
Energy
content content (lower
(lower
heating heating value
value
as as received)
received)
MJ MJ per per per kg kg3
Typical
Typical
moisture
moisture
content
content
Paper 32% 100% 11.5 18%
Card 30% 100% 11.5 24%
Dense plastic 1 76% 20.0 – 32.0 18%
Plastic film 74% 23.0 22%
Textiles 29% 50% 15.0 19%
Glass 0% 0 2%
Ferrous metal 0% 0 3%
Non ferrous metal 0% 0 5%
Wood 23% 100% 14.5 41%
Garden waste 26% 100% 5.0 45%
Food waste 13% - 20% 100% 4.0 – 5.0 58% - 71%
Misc. combustibles 40% 50% 14.5 41%
Misc. non combustibles 7% 2.7 6%
Fines 17% 100% 4.5 41%
Notes
1. The lower values represent PVC material; the upper end of the range HDPE bottles
2. This results in an overall biogenic carbon content of 54% (using the composition analysis
provided in Table 63-3)
3. The overall energy content of residual waste (as received at facility) is 10.8 MJ per kg, based on
the composition analysis provided in Table 63-3
Sources: Vito (2001) Procesbeschrijving Afvalverwerkingstechnieken: Integrale Miliestudies; Dalemo M
(2004) The Modelling of an Anaerobic Digestion Plant and a Sewage Plant in the Orware Simulation
Model: Swedish University of Agricultural Sciences, Report 213; Beker D and Cornelissen A (2006)
Chemische Analyse Van Huishoudelijk Restafval Resultaten 1994 En 1995, Dutch National Institute of
Public Health and the Environment, November 2006; The National Household Waste Analysis
Programme (1992); Energy Research Centre of the Netherlands (u.d.) Phyllis Database: The
Composition of Biomass and Waste

63.3.1.1 Energy Use at Incineration Facilities
The energy usage of the plant depends upon the scale of plant, and the nature of the
flue gas cleaning system. It also depends upon the presence or otherwise of:
999
� Mechanical pre-treatment systems;
� Incineration air preheating;
� Equipment for re-heating of flue gas;
� Waste water evaporation plant;
� Flue gas treatment systems with high pressure drops (which demand more
powerful fans); and
� Changes in the energy content of input waste (necessitating use of fuel to
maintain minimum combustion temperatures).
ERM’s analysis suggests 3.9 kWh electricity is consumed per tonne of waste treated
at an incinerator, with process diesel use indicated as 1.2 kg of per tonne of
waste. 1232 They arrived at these figures using Environment Agency data collected for
the development of the waste model WRATE. However, they note in their report that:
These process data were used as a substitute for all thermal treatment
processes. In reality the ancillary requirements of each will differ, but within
the context of the research the more important parameter relates to the
energy conversion efficiency of the process.
ERM’s energy consumption figures appear to be very low in comparison to values
given in the wider literature. The Draft BREF note for Incineration gives figures of: 1233
� Electricity use
62 kWh per tonne – 257 kWh per tonne, average 142 kWh per tonne;
� Heat demand
72 GJ thermal energy per tonne – 3,366 GJ thermal energy per tonne, average
433 GJ thermal energy per tonne.
These, in turn, are far higher than figures suggested in, for example, reports by
Erichsen and Hauschild (46 kWh electricity per tonne) though this figure reflects only
the operation of gas cleaning equipment. 1234 The Flemish Institute for Technological
1232 ERM (2006) Carbon Balances and Energy Impacts of the Management of UK Wastes, Defra R&D
Project WRT 237)
1233 A BREF note is a note prepared by the Joint Research Centre of the European Commission to give
guidance to Member States as to what is implied by ‘Best Available Techniques’ under the Directive on
Integrated Pollution Prevention and Control. European Commission (2005) Integrated Pollution
Prevention and Control, Draft Reference Document on the Best Available Techniques for Waste
Incineration, Final Draft, May 2005.
1234 L. Hanne, L. Erichsen and M. Hauschild (2000) Technical Data for Waste Incineration -
Background for Modeling of Product Specific Emissions in a Life-cycle Assessment Context, Elaborated
as part of the EUREKA project EUROENVIRON 1296: LCAGAPS, sponsored by the Danish Agency for
Industry and Trade, April 2000.
International Review of Waste Policy: Annexes

Research (VITO) gave the following consumption of energy for processes with and
without SCR: 1235
1000
� Natural gas: 7.2 m 3 per tonne
� Oil: 4 kg per tonne (or 4.7 litres per tonne)
� Electricity use (per tonne): 80 kWh with Selective Non-Catalytic Reduction
(SNCR) pollution abatement, 85 kWh with Selective Catalytic Reduction (SCR)
abatement.
To ensure the catalyst is not contaminated by other elements within the flue gas the
SCR abatement system is typically located just prior to the emissions stack, which
requires the 200°F flue gas to be reheated using additional electrical energy. 1236 Use
of SNCR and SCR systems is discussed further in Section 63.3.2 with respect to the
air quality impacts of these facilities.
CEWEP’s survey of 97 facilities during 2001-2004 suggested the average electricity
used by incineration processes was 78 kWh per tonne of waste input. 1237 We use the
CEWEP figure for electricity consumption with SNCR and VITO’s figures for energy use
assuming SCR within the current analysis. We have also used VITO’s data for the
natural gas and diesel usage.
63.3.1.2 Efficiencies of Electricity Generation
The efficiency of generation of electricity by an incinerator may be quoted gross, or
net of any energy used in the plant itself. The energy use in the plant depends partly
upon the nature of the flue gas cleaning system used, but also upon a range of other
factors. The relationship to flue gas cleaning is important since it seems likely that as
standards for abatement have improved, so the energy used in achieving those levels
of abatement has increased also.
ERM suggested gross efficiencies of 20-27% for conventional incineration with steam
cycle electricity generation in a recent report for Defra. 1238 Fichtner quotes a ‘realistic
range’ for net electrical efficiency of 19-27%. 1239 The highest figures we have seen
quoted are those quoted in the context of the Belvedere Inquiry where it was claimed
that a net efficiency of 27% would be achieved. This was based around assumptions
1235 VITO (2000) Vergelijking van Verwerkingsscenario’s voor Restfractie van HHA en Niet-specifiek
Categorie II Bedrijfsafval, Final Report
1236 Note that this is not always the case – see European Commission (2005) Integrated Pollution
Prevention and Control, Draft Reference Document on the Best Available Techniques for Waste
Incineration, Final Draft, May 2005.
1237 I. Riemann (2006) CEWEP Energy Report (Status 2001-2004): Results of Specific Data for Energy,
Efficiency Rates and Coefficients, Plant Efficiency Factors and NCV of 97 European W-t-E Plants and
Determination of the Main Energy Results, updated July 2006.
1238 ERM (2006) Carbon Balances and Energy Impacts of the Management of UK Wastes, Defra R&D
Project WRT 237).
1239 Fichtner Consulting Engineers Limited (2004) The Viability Of Advanced Thermal Treatment Of
MSW In The UK, ESTET, March 2004.
29/09/09

of a thermal efficiency of 84% and an electrical efficiency of 35%. These are
optimistic in the context of efficiencies currently achieved and are likely to be
deliverable only at large operating scales. The Draft BREF note gave no case where
the net export of electricity exceeded 18%. 1240 A survey of 25 incinerators across
Europe generating electricity only reported a maximum gross energy efficiency of
27.9% with a weighted mean efficiency of 21.8% across the 25 facilities (the mean
net efficiency was given as 17.7%). 1241 The current analysis uses a gross efficiency of
27%, reflecting the top end of the range quoted by ERM and the CEWEP survey.
N2O emissions are modelled based on previous research undertaken by Eunomia on
behalf of WRAP. 1242 The considerable uncertainty with respect to these emissions is
acknowledged within the EU BREF note, which provided a range of 5.5 – 66 g N2O per
tonne of waste treated by the facility. We use the mid point of these values within the
current analysis. CH4 emissions are negligible from incineration facilities.
The efficiency with which metals are recovered from incineration facilities is modelled
based on a survey of Dutch facilities. 1243
Table 63-11 summarises the assumptions for incineration discussed previously.
Table 63-11: Assumptions for Incineration
Parameter Parameter Parameter
Assumption
Assumption
Gross electrical generation efficiency 27%
Electricity demand for flue gas cleaning 78 kWh / t input
Diesel use by process 4.7 l / t input
Use of natural gas by process 7.2 m 3 / t input
Recycling of bottom ash 50%
CH4 emissions from process 0 kg CH4 / t
N2O emissions from process 0.04 kg N2O / t
Recovery rate for ferrous metals 70%
Recovery rate for non-ferrous metals 30%
1240 European Commission (2005) Integrated Pollution Prevention and Control, Draft Reference
Document on the Best Available Techniques for Waste Incineration, Final Draft, May 2005.
1241 I. Riemann (2006) CEWEP Energy Report (Status 2001-2004): Results of Specific Data for Energy,
Efficiency Rates and Coefficients, Plant Efficiency Factors and NCV of 97 European W-t-E Plants and
Determination of the Main Energy Results, updated July 2006.
1242 Eunomia (2007) Emissions of Nitrous Oxide from Waste Treatment Processes, Report to WRAP,
July 2007.
1243 L. Muchova and P. Rem (2008) Wet or Dry Separation: Management of Bottom Ash in Europe,
Waste Management World Magazine, 9(3).
1001
International Review of Waste Policy: Annexes

63.3.2 Air Quality Impacts of Incineration
Typical air pollution control (APC) technology installed in incinerators located in the UK
comprises of:
1002
� Bag filters, used to trap polluted dust (particulate matter) entrained with the
exhaust gases;
� Semi dry flue gas scrubbing involving the use of lime neutralizes acidic
pollutants (such as SOx) within the flue gas;
� Selective Non-Catalytic Reduction (SNCR) processes, used to thermally reduce
NOx by injection of a reducing agent (ammonia or urea) into the post
combustion flue gas;
� Activated carbon to deal with dioxin (and furan) formation.
Whilst SNCR processes typically allows the incinerator to meet WID with respect to
NOx emissions, use of Selective Catalytic Reduction (SCR) techniques results in
significant further reduction in NOx. SCR involves the addition of ammonia and the
use of a catalyst (usually made of titanium oxide) to convert the NOx and ammonia
into steam and nitrogen. 1244 The reduction in NOx is typically achieved at the expense
of additional energy expenditure, as has been previously discussed in Section
63.3.1.1. 1245
NOx emissions have a significant influence on the damage costs attributed to the air
pollution from waste incineration facilities. Reductions in NOx emissions results in a
considerable improvement in the performance of the facility with respect to external
costs attributed to the non greenhouse gas air pollution impacts.
A significant proportion of the NOx emission from waste incineration is generated by
the thermal process itself, and is not therefore directly linked to the nitrogen content
of waste entering the facility. Data on the chemical constituents of waste varies
considerably between different literature sources with the nitrogen content being
particularly variable, largely reflecting the natural variation in the nitrogen content of
organic material (likely to be the main source of nitrogen within residual waste). We
have therefore based our assessment of the air pollution impacts of incinerators
upon emissions data, rather than linking to specific chemical elements within the
composition.
Our analysis considers emissions from two types of incinerator:
1. A facility that meets the Waste Incineration Directive (WID), typical of those
that have installed SNCR to reduce NOx emissions;
2. A facility that significantly out-performs the requirements of the WID through
the installation of SCR and wet scrubbing techniques. Emissions are based on
1244 The ammonia is added to support the reduction reaction.
1245 To ensure the catalyst is not contaminated by other elements within the flue gas the SCR system is
typically located just prior to the emissions stack. This requires the flue gas to be reheated using
additional electrical energy.
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1003
data obtained from plant operating in the Netherlands with this type of
equipment installed.
Emissions data for the facilities are detailed in Table 63-12.
Table 63-12: Emissions from Incineration Facilities
International Review of Waste Policy: Annexes
WID WID compliant compliant facility facility Significantly Significantly out out-performs out performs WID WID2
mg/Nm mg/Nm3
g g / / t t waste waste1
mg/Nm mg/Nm3
g g g / / t t waste
waste
PM10 / dust 3 10.0 61.0 0.5 3.0
Dioxin (ng ITEQ/Nm 3 ) 0.1 0.0 0.0 0.0
NOx 200.0 1,220.0 45.0 274.5
SO2 50.0 305.0 1.0 4.8
HF 10.0 6.1 0.0 0.0
HCl 1.0 61.0 0.5 1.2
CO 50.0 305.0 10.0 55.2
NMVOC 10.0 61.0 0.5 3.0
Total heavy metal 0.5 3.0 0.0 0.2
Notes:
1. Assumes an exhaust gas exit volume of 140 Nm 3/s, based on data provided by a
650,000 tonne per annum incinerator located in Paris (Source: ExternE)
2. Assumes the use of SCR and wet scrubbing techniques to reduce emissions
3. 70% of PM10 is assumed to be PM2.5 (Source: Chang et al)
Sources: Information Centre for Environmental Licensing (2002) Dutch Notes on BAT for the
Incineration of Waste, Report for the Ministry of Housing, Spatial Planning and the Environment, The
Netherlands, February 2002; European Commission (2006) Integrated Pollution Prevention and
Control: Reference Document on Best Available Techniques for the Waste Treatment Industries,
August 2006; ExternE (1999) Externalities of Energy, Vol 10: National Implementation, prepared by
CIEMAT for the European Commission, Belgium; Chang M B, Huang C K, Wu J J, and Chang S H (2000)
Characteristics of heavy metals on particles with different sizes from municipal solid waste
incineration, Journal of Hazardous Materials 79(3): pp229-239
Air pollution control residues from waste incineration facilities consist of a mix of
unspent reagents and chemicals extracted from the flue gas. They are typically
treated as hazardous waste and are usually required to be sent to hazardous waste
landfills. Chlorine, sulphur, and heavy metals are likely to be concentrated in the air
pollution control residues produced by incinerators. Ironically, the better flue gas
cleaning systems perform, the more likely it becomes that toxic materials are
concentrated in these residues.
Several recent studies indicate that long-term impacts of landfilling this hazardous
material may be significant. In a Dutch study comparing the costs and benefits of
landfill with those of incineration, the environmental damages associated with air

pollution control residues were considered as the most important externality
associated with treatment in an incineration facility. 1246
Another recent life-cycle study suggests:
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‘The evaluation of waste incineration technologies largely depends on the
assessment of heavy metal emissions from landfills and the weighting of the
corresponding impacts at different points in time. Unfortunately, common LCA
methods hardly consider spatial and temporal aspects.’ 1247
Using a geochemical model to model some pollutants, the same study concluded:
‘Landfills might release heavy metals over very long time periods ranging from
a few thousand years in the case of Cd to more than 100,000 years in the
case of Cu. The dissolved concentrations in the leachate exceed the quality
goals set by the Swiss water protection law (GSchV) by a factor of at least 50.’
These impacts are only likely to be significant in the much longer term, and as such
have been excluded from the current analysis.
63.3.2.1 Summary of Air Quality Impacts of Incineration Facilities
The principal determinant of air quality damage costs associated with incineration
facilities relates to the NOx externalities – both with respect to direct emissions from
the treatment process and emissions generated through the use of diesel in the
facility. A proportion of the impact is offset by NOx emissions avoided through the
generation of electrical energy (as discussed in Section 63.1.3.1).
Table 63-13 details the damages resulting from non greenhouse gas air pollutants
emitted at incineration facilities. These externalities are calculated using the
emissions data provided in Table 63-12 and the damage costs for the pollutants
provided in (cross reference). 1248
1246 E. Dijkgraaf and H. Vollebergh (2004) Burn or Bury? A Social Cost Comparison of Final Waste
Disposal Methods, Ecological Economics, 50: pp233-247.
1247 S. Hellweg (2000) Time- and Site-Dependent Life-Cycle Assessment of Thermal Waste Treatment
Processes, Dissertation submitted to the Swiss Federal Institute of Technology.
1248 No damage costs are given for HCl and HF although emissions of these pollutants are limited by
the WID.

Table 63-13: Air Quality Externalities from Incineration Facilities
1005
International Review of Waste Policy: Annexes
High High Externalities Externalities ( (€ (
€ / / tonne tonne
tonne
input input input to to facility)
facility)
Meets Meets WID WID
Out Out-performs performs
WID
WID
Low Low Externalities Externalities ( (€ (
€ / / tonne tonne
tonne
input input to to facility)
facility)
Meets Meets WID WID
Out Out-performs performs
WID WID
WID
PM10 / dust €3.17 €0.05 €1.13 €0.02
Dioxin 1 €0.00 €0.00 €0.00 €0.00
NOx €16.32 €2.99 €5.64 €1.03
SO2 €5.28 €0.17 €1.81 €0.06
CO 2 €0.00 €0.00 €0.00 €0.00
NMVOC €0.15 €0.00 €0.05 €0.00
Total heavy metal €0.29 €0.06 €0.29 €0.06
Total - direct process €25.21 €3.29 €8.92 €1.18
Energy use at facility 3 €9.45 €9.45 €3.27 €3.27
Avoided emissions 4 - €2.78 - €2.78 - €0.96 - €0.96
Notes
1. The impacts associated with dioxin emissions are negligible from well managed
incineration facilities
2. Damage costs for CO are very low, resulting in low external costs for this pollutant
3. Over 80% of these emissions result from the combustion of diesel
4. Avoided emissions resulting from electricity generation
63.4 MBT - Aerobic Stabilisation Systems
63.4.1 Climate Change Impacts of Aerobic Stabilisation Systems
The approach for modelling the impacts of stabilisation processes draws upon work
by Eunomia on behalf of WRAP, which was based upon a raft of published
research. 1249 The body of research included work by Baky and Eriksson, Sonneson,
1249 K. Schleiss (1999) Grüngutbewirtschaftung im Kanton Zürich aus betriebswirtschlaftlicher und
ökologischer Sicht: Situationsanalyse, Szenarioanalyse, ökonomische und ökologische Bewertung
sowie Synthese mit MAUT, Dissertation ETH No 13,746, 1999; Eunomia Research & Consulting,
Scuola Agraria del Parco di Monza, HDRA Consultants, ZREU and LDK ECO on behalf of ECOTEC
Research & Consulting (2002) Economic Analysis of Options for Managing Biodegradable Municipal
Waste, Final Report to the European Commission; D.P. Komilis and R.K. Ham (2004) Life-Cycle
Inventory of Municipal Solid Waste and Yard Waste Windrow Composting in the United States, Journal
of Environmental Engineering, 130(11), pp.1390-1400; A. Baky and O. Eriksson (2003) Systems
Analysis of Organic Waste Management in Denmark, Environmental Project No. 822, Copenhagen:

and Komilis and Ham, all of whom investigated the link between the biochemical
composition of the waste and the release of CO2 within composting processes. This
research, together with data sourced from technology suppliers, was used to model
the degradation of carbon fractions within our model.
Table 63-14 outlines the key assumptions within the model for stabilisation
processes.
Table 63-14: Assumptions for Stabilisation Process
Parameter Parameter
Assumption
Assumption
Residence time 10 weeks
Electricity requirement 50 kWh / t input
Diesel use by process 1 l / t input
CH4 emissions from process 0.01 kg / t input
N2O emissions from process 0.04 kg / t input
Recovery rate for ferrous metals 80%
Recovery rate for non ferrous metals 80%
Recovery rate for plastics 70%
Our assumptions for the landfill of pre-treated (stabilised) material have been
previously discussed in Section 63.2.1.5.
63.4.2 Air Quality Impacts
To minimise emissions from the stabilisation process, air circulation and/or a
controlled air supply system is usually installed. Biofilters are typically used to reduce
emissions of NMVOC and other organic pollutants emanating from the stabilisation
process itself. These involve the use of microorganisms to biologically degrade the
pollutants.
In the biological treatment step, the material is assumed to undergo an aerobic
stabilisation. The emissions are derived from Hellweg et al, these being derived in
turn from work by Wahlmann et al. 1250
The principal air quality impacts are:
Danish EPA; U. Sonesson (1996) Modelling of the Compost and Transport Process in the ORWARE
Simulation Model, Report 214, Swedish University of Agricultural Sciences (SLU), Department of
Agricultural Engineering, Uppsala Sweden.
1250 Stefanie Hellweg, Gabor Doka, Goran Finnvenden and Konrad Hungerbuhler (2003) Ecology:
Which Technologies Perform Best?, in Christian Ludwig, Stefanie Hellweg and Samuel Stucki (eds)
(2003) Municipal Solid Waste Management: Strategies and Technologies for Sustainable Solutions,
London: Springer.
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1007
1. Energy used within the treatment process, giving rise to damage costs of
€3.08 under the high externalities (mostly from the use of diesel);
2. Total direct emissions from the stabilisation process and the landfilling of the
residues result in external damage costs of €0.47 under the high externalities
(emissions of NMVOCs from stabilisation account for most of this impact).
63.5 MBT Aerobic Biodrying Systems
63.5.1 Climate Change Impacts of MBT Aerobic Biodrying Systems
Biodrying systems involve the application of intensive heat to the waste to ensure the
removal of moisture prior to it being used as fuel. During this process degradation of
some of the carbon fractions will occur as a result of the increase in temperature but
the amount of degradation is relatively limited in comparison that occurring during
aerobic decomposition (stabilisation) processes.
Emissions of CO2 are calculated from the carbon loss estimated over a two week
period. The figures for carbon loss are estimated by ourselves for each of the
components of the waste stream. We have been able to correlate these estimates
over several years using an analysis of data from technology suppliers.
The central aim of biodrying processes is to produce a fuel. A reject stream is also
produced, which is assumed to be stabilised before being sent to landfill, using the
process previously described in Section 0.
Table 63-15 outlines key assumptions used to model the biodrying phase.
Our assumptions regarding the nature of the SRF produced are detailed in Table
63-16.
Our analysis considers two uses for the output from the biodrying process:
1. The SRF is combusted at a dedicated incineration facility generating electricity
as has been previously described in Section 63.3.
2. The SRF is combusted at a cement kiln where it is assumed to displace the
use of coal. We assume a 90% substitution ratio for the fuel displacement,
and that the coal would otherwise emit 0.37 kg CO2 equivalent per kWh of
energy generated.
Our assumptions for the landfill of pre-treated (stabilised) material have been
previously discussed in Section 63.2.1.5.
International Review of Waste Policy: Annexes

Table 63-15: Assumed Used for Modelling Biodrying Phase
Parameter Parameter Parameter
Ass Assumption Ass umption
Residence time in biodrying phase 12 days
Residence time of rejects in maturation (stabilisation) phase 7 weeks
Electricity requirement 1 40 kWh / t input
Diesel use by process 1 0.5 l / t input
CH4 emissions from process 2 0.01 kg / t input
N20 emissions from process 2 0.02 kg / t input
Recovery rate for ferrous metals 80%
Recovery rate for non-ferrous metals 80%
Recovery rates for plastics 70%
Notes:
1. Per tonne input to the MBT facility.
2. Per tonne input to the biodrying process.
Table 63-16: Model Parameters for Residual Waste to SRF
Parameter Parameter Parameter
Assumption Assumption
Assumption
Amount of SRF produced by biodrying process (per tonne to facility) 0.4 tonnes
Energy content of SRF (lower heating value as received) 16.5 MJ / kg
% of carbon that is non-fossil 46%
63.5.2 Air Quality Impacts of Aerobic Biodrying Systems
As is the case with the aerobic stabilisation systems, biodrying plant typically install
controlled air supply systems and biofilters to minimise the impact of organic
pollutants emanating from the aerobic degradation process. Non-GHG air emissions
are calculated from work undertaken for the Austrian Umweltbundesamt, though we
have adapted these over time based on more up to date data. 1251 These are
dependent upon the choice of emissions abatement equipment at the plant (each
modelled in the study). There are three key options which the study addressed:
1008
� Basic biofilter;
1251 Uwe Lahl, Barbara Zeschmar-Lahl and Thomas Angerer (2000) Entwicklungspotentiale der
Mechanisch-biologischen Abfallbehandlung: Eine Ökologische Analyse, Vienna: Umweltbundesamt,
June 2000.
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1009
� Optimised biofilter; and
� Thermal filter.
The choice of abatement equipment determines the level of removal of some of the
gases prior to their emission to the atmosphere. It also determines the level of energy
use in the process (especially relevant for the thermal filter option).
We have assumed that MBT facilities operate with optimised biofilters. The
requirement, in Germany, to deploy regenerative thermal oxidation (or other)
processes to crack remaining VOCs from the exhaust gas appears, in our view, to be
unjustifiable when the additional benefits are set against the additional energy
demand implied by the process. 1252
Pollution abatement techniques employed at incineration facilities have been
previously discussed in Section 63.3.2. Again we have assumed two types of facilities
– one which complies with the WID, and a second which has installed additional
abatement equipment and therefore exceeds the requirements of the WID. Our
assumptions for the landfill of pre-treated (stabilised) material have been previously
discussed in Section 63.2.1.5.
Our analysis considers two uses for the output from the biodrying process:
1. The SRF is combusted at a dedicated incineration facility generating electricity
as has been previously described in Section 63.3.
2. The SRF is combusted at a cement kiln where it is assumed to displace the
use of coal. We assume a 90% substitution ratio for the fuel displacement,
and that the coal would otherwise emit 0.37 kg CO2 equivalent per kWh of
energy generated.
Our assumptions for the landfill of pre-treated (stabilised) material have been
previously discussed in Section 63.2.1.5.
The principal air quality impacts are:
1. Energy used within the treatment process, giving rise to damage costs of
€6.42 under high externalities or €2.22 assuming low external costs. Most of
this impact arises from the use of diesel within the facility. 1253
2. Where the SRF is sent to an incinerator, total emissions from direct treatment
processes (including the biodrying and stabilisation components and the
combustion of SRF as well as the landfilling of residues) result in external
damage costs of €10.64 under the higher externalities or €3.69 assuming low
1252 Biofilters themselves are sources of VOCs, though typically of less benign species than the type
one seeks to remove from exhaust gases. To assume that all VOCs are equally detrimental to air
quality and health is to misunderstand the problem, and although RTO deployment will further reduce
VOC emissions, (as we show within this review) it tends to do so at considerable additional cost from
the perspective of climate change.
1253 The additional diesel consumption reflects that used within the incineration of SRF. Assumptions
used here are the same (on a per tonne basis) as for the incineration of untreated wastes.
International Review of Waste Policy: Annexes

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external costs. Emissions associated with the combustion of SRF account for
over 90% of these impacts. The total direct impact is reduced to €3.27 and
€1.15 for the high and low costs respectively if the incinerator significantly outperforms
the WID (as previously discussed in Section 63.3.2).
3. The combustion of SRF in an incinerator is assumed to avoid emissions of
€1.67 associated with the generation of electricity assuming high external
costs or €0.58 if the lower external costs are applied.
4. Where the SRF is sent to a cement kiln, external damage costs relating to the
total combustion related impacts are €8.11. These damages are assumed to
occur as a result of the 90% substitution ratio for SRF and coal, based on the
higher emissions that occur in the cement kiln. 1254
63.6 Summary of Results, Residual Waste
Table 63-17 and Table 63-18 summarise the results of our analysis, detailing the
external costs associated with the different waste treatment technologies under the
high and low external costs respectively. Climate change impacts are highly
significant for landfill whilst the air quality impacts are relatively more significant for
incineration.
Table 63-17: Results with High External Costs
Climate Climate
Climate
Change
Change
Air Air Quality Quality Total
Total
Landfill (50% gas capture) €80.66 €5.88 €86.54
Landfill (20% gas capture) €123.62 €5.52 €129.14
Incineration (meets WID) €26.24 €31.87 €58.11
Incineration (out-performs WID) €26.24 €9.96 €36.20
MBT aerobic biodrying / incineration €22.94 €15.38 €38.32
MBT aerobic stabilisation €18.82 €3.55 €22.37
MBT aerobic biodrying / cement kiln €9.16 €11.53 €20.70
MBT aerobic biodrying (50% gas capture) €26.67 €15.38 €42.05
MBT aerobic biodrying (out-performs WID) €22.83 €8.02 €30.85
MBT aerobic stabilisation (50% gas capture) €35.84 €3.55 €39.39
1254 The Waste Incineration Directive allows higher emissions limits for cement kilns co-incinerating
waste than those imposed on dedicated incineration facilities.

Table 63-18: Results with Low External Costs
1011
International Review of Waste Policy: Annexes
Climate
Climate
Change
Change
Air Air Quality Quality Total Total
Total
Landfill (50% gas capture) €66.86 €2.07 €68.94
Landfill (20% gas capture) €102.48 €2.35 €104.83
Incineration (meets WID) €21.75 €11.23 €32.98
Incineration (out-performs WID) €21.75 €3.49 €25.24
MBT aerobic biodrying / incineration €18.98 €5.33 €24.31
MBT aerobic stabilisation €15.38 €1.23 €16.61
MBT aerobic biodrying / cement kiln €7.48 €4.00 €11.48
MBT aerobic biodrying (50% gas capture) €22.07 €5.33 €27.40
MBT aerobic biodrying (out-performs WID) €18.98 €6.99 €25.97
MBT aerobic stabilisation (50% gas capture) €28.67 €1.23 €29.90
63.7 Dry Recycling
In producing virgin products (i.e. products made from non-recycled materials) it is
inevitable that raw materials will be required. These raw materials may be mined from
the ground or extracted from forests (in the case of paper/wood manufacture).
Additional resources, in the form of the energy used for the mining or paper
manufacture, for example, will also be required. This resource requirement results in
emissions to air that have consequences for climate change and for local air quality.
If a product is manufactured from recycled materials, the requirement for raw
materials is diminished. This typically reduces the energy used resulting in a reduction
in emissions during the manufacturing process. Emissions are therefore said to have
been ‘avoided’ as a result of the use of the recycled materials.
Although the concept of reduced emissions from recycling/reprocessing is well
understood, there is rather less by way of consensus as to the actual quantity of the
savings offered by recycling. In recent years, there has been focus on evidence from
life cycle assessment (LCA) studies, which have sought to estimate the entire
environmental impact of waste management systems. However, LCA studies are
sensitive to a range of issues such as starting assumptions and boundary setting,
which lead to very different results for similar systems, depending on the
methodology involved. The outcome of the analysis is dependent upon a range of
assumptions, which include:
� Energy sources used for primary and secondary production from raw materials;
� The collection system for the recovered materials;
� Energy requirements for reprocessing the recycled material;

1012
� Emissions associated with disposal of the product (for the virgin production
system, where it is assumed that the product is not recycled at the end of its
life).
The range of possible re-processing technologies and the different methodologies
employed for calculating emissions reductions has resulted in a wide range of offsets
being attributed with respect to the recycling of the same type of material. This is
particularly the case with regard to the climate change impacts, which have been
more widely studied.
63.7.1 Climate Change Impacts
Table 63-19 summarises some of the evidence from the literature with regard to the
climate change impacts associated with recycling the most commonly collected
materials. Best and worst case scenarios are presented, along with typical values.
The table identifies the key assumptions within the reviewed studies that result in the
calculation of the more extreme values associated with the best and worst cases. The
table shows that recycling typically results in avoided greenhouse gas emissions for
all of those materials commonly recycled.
The results presented in Table 63-19 show that aluminium recycling results in the
most significant emissions savings where impacts are considered on the basis of one
tonne of material recycled, largely as a result of the significant energy expenditure
involved in manufacturing the product from virgin materials. The damage costs
associated with the typical values presented in Table 63-19 are shown in Table
63-20, under both the high and low externalities.
63.7.2 Air Quality Impacts
Section 63.7.1 confirms that the greenhouse gas implications of recycling materials
have been considered by a range of studies. Far less data is available with respect to
the air quality impacts associated with recycling the same products.
One study that did consider these impacts is the international review of the
environmental benefits of recycling undertaken by WRAP. The study included a range
of different re-processing technologies for different materials being recycled across
various countries. However the majority of studies included within the review focused
on the climate change impacts of recycling (this data is included within Table 63-19).
Far less information is available with respect to the air quality impacts associated
with these processes, and what is available is limited to emissions of NOx and SOx
only.
29/09/09

Table 63-19: Emissions Associated with Recycling Materials
Material Material Emissions Emissions t t CO CO2 CO equ
equ
(per (per tonne tonne of of waste)
waste)
Paper
Steel
Aluminium
Plastic
Glass
Textiles
1013
Best -3.5
Worst 1.1
Typical Typical -0.6 0.6
Best -3.1
Worst 1.5
Typical Typical -1.2 1.2
International Review of Waste Policy: Annexes
Critic Critical Critic al assumptions
assumptions
Inclusion of carbon sequestration; substantial avoided
emissions from landfill / wood energy not used
Incineration of paper; use of wood energy to produce
virgin paper
Recycling process uses similar / less carbon intensive
energy generation process; relatively high energy use in
virgin manufacturing process
Recycling process uses a more carbon intensive energy
generation process
Best -15.1 Higher energy use in virgin manufacturing process
Worst 1.5 High recovery efficiency from incinerator residues
Typical Typical -9.17 9.17
Best -4.1
Worst 3.8
Typical Typical -1.4
Best -2.5
Recycled is substituted for virgin on 1:1 basis; no hot
water washing required
Compared to incineration; hot water washing and poorer
substitution ratio
Recycled glass system produced with low carbon
intensive source of energy
Worst 0.5 Open loop processes (use of glass as aggregate)
Typical Typical -0.3 0.3 0.3
Best -7.9 .9
Worst -0.93 0.93
Typical Typical -3.03 3.03
These tend to be associated with natural fibres such as
wool – presumably, synthetic fibres might tend towards
values akin to those for plastic, or lower
Notes Notes: Notes : The negative values here represent emissions ‘avoided’ or saved as a result of recycling
Typical emissions for paper recycling have been adjusted to remove the element associated
with avoided disposal.
Sources: WRAP (2006) Environmental Benefits of Recycling: An International Review of Life cycle
Comparisons for Key Materials in the UK Recycling Sector, Banbury: Oxon, WRAP, May 2006; AEA
Technology (2001) Waste Management Options and Climate Change: Final Report, European
Commission: DG Environment, July 2001; USEPA (2006) Solid Waste Management and Greenhouse
Gases: A Life-Cycle Assessment of Emissions and Sinks, 3 rd Edition, September 2006; ERM (2006)
Carbon Balances and Energy Impacts of the Management of UK Wastes, Final Report for Defra,
December 2006; ERM (2006) Impact of Energy from Waste and Recycling Policy on UK Greenhouse
Gas Emissions, Final Report for Defra, January 2006; European Aluminium Association (2008)
Environmental Profile Report for the European Aluminium Industry: Life Cycle Inventory Data for
Aluminium Production and Transformation Processes in Europe, April 2008; Enviros (2003) Glass
Recycling – Life Cycle Carbon Dioxide Emissions, internal report for the British Glass Public Affairs
Committee

Table 63-20: External Costs of Dry Recycling – Climate Change Impacts
Material
Material
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External External Costs Costs – Climate Climate Change Change Impacts
Impacts
High High externalities externalities
Low Low Low externalities
externalities
Paper - € 19.93 - € 16.52
Steel - € 38.57 - € 31.97
Aluminium - € 294.69 - € 244.29
Plastic - € 44.99 - € 37.30
Glass - € 9.64 - € 7.99
Textiles -€ 97.38 -€ 80.72
Notes
Analysis uses the typical values presented in Table 63-19 together with the external costs
presented
Data regarding the other air emissions associated with recycling materials is also
available within the Environment Agency’s life-cycle tool for waste management
processes, WRATE. 1255 These impacts are calculated using the Swiss life-cycle
database Ecoinvent. 1256 The inventory produced by WRATE presents data on a much
wider range of air emissions than is considered within the WRAP review.
Impacts calculated using WRATE are based on the differential (in air quality terms)
between products manufactured using virgin materials, and those manufactured from
recycled input. In contrast, the methodology used by WRAP also considers emissions
avoided as a result of recycled material not being sent for disposal.
Air quality impacts associated with manufacturing and re-processing will not have a
direct impact on Irish air quality where both of these activities takes place overseas.
Emissions avoided as a result of recycled material not being sent for disposal will,
however, directly affect Irish air quality. The principal avoided disposal emissions are
presented in Table 63-21. These impacts are calculated using the same methodology
as for calculating the impacts associated with residual waste.
Table 63-22 shows the air quality impacts associated with the re-processing part of
the system (i.e. where a product is manufactured from recycled input). In many cases
the production of goods from recycled materials results in reduced air quality burdens
in comparison to the manufacture of the same product from raw materials. Much of
this reduction results from the lower energy requirements associated with the use of
recycled input in manufacturing processes (this is particularly the case for non ferrous
1255 Available from http://www.environment-agency.gov.uk/research/commercial/102929.aspx
1256 Ecoinvent (2004) Ecoinvent Data v1.1, Final Reports Ecoinvent 2000, No. 1-15, Swiss Centre for
Life Cycle Inventories, Dubendorf, 2004

metal, the production of which consumes significant quantities of energy). However,
such emissions reductions will not have a direct impact on Irish air quality, since a
significant proportion of the manufacturing of these products (whether made from
virgin or recycled input) occurs overseas.
Table 63-21: Avoided Disposal Emissions (Non Greenhouse Gas Emissions)
Material(s)
Material(s)
1015
Disposal
Disposal
method
method
International Review of Waste Policy: Annexes
Principal Principal avoided avoided air air emissions (per tonne tonne of
material aterial disposed at at facility)
Paper Landfill 0.9 kg ammonia; 0.7 kg NOx
Plastic, metals, glass Landfill 0.1 kg NOx (diesel use)
Paper Incineration 1.5 kg NOx; 0.3 kg SOx; 0.1 kg particulates
Plastic Incineration 1.1 kg NOx; 0.3 kg SOx; 0.1 kg particulates
Glass, metals Incineration 1.7 kg NOx; 0.3 kg SOx; 0.1 kg particulates
Paper Biodrying 0.8 kg NOx; 0.2 kg SOx; 0.1 kg particulates
Plastic Biodrying 0.3 kg NOx; 0.1 kg SOx
Glass Biodrying 0.4 kg NOx; 0.1 kg SOx
Metals Biodrying 0.4 kg NOx; 0.1 kg SOx
Paper Stabilisation 0.2 kg NMVOC; 0.2 kg NOx (energy use)
Plastic Stabilisation 0.2 kg NOx (energy use)
Glass Stabilisation 0.2 kg NOx (energy use)
Metals Stabilisation 0.2 kg NOx (energy use)
Notes
Plastic has a higher calorific value than the other materials so more NOx emissions are
avoided through energy generation
Table 63-23 presents damage costs for the air quality impacts associated with dry
recycling. The table separately identifies impacts resulting from the avoided disposal
of the material, and those associated with re-processing impacts.

Table 63-22: Avoided Emissions Recycling – Re-processing Impacts
Pollutant
Pollutant
1016
29/09/09
Avoided Avoided emissions emissions emissions through through recycling recycling (kg (kg polluta pollutant polluta polluta nt / t t recyclate)
recyclate)
Paper Paper Paper Dense Dense plastic plastic Glass
Glass
Ferrous
Ferrous
metal
metal
Non Non ferrous ferrous
ferrous
metal
metal
NH3 0.01 -0.01 0.16 0.07 0.15
VOCs 0.04 3.54 0.02 0.25 2.20
PM2.5 0.10 0.40 0.19 0.78 4.62
SOx 0.01 -0.01 0.03 0.01 0.01
NOx 0.92 5.68 0.30 2.70 18.00
Cd 0.00 0.00 0.00 0.00 0.00
Cr 0.00 0.00 0.00 0.00 0.00
Hg 0.00 0.00 0.00 0.00 0.00
Ni 0.00 0.00 0.00 0.00 0.00
Pb 0.00 0.00 0.00 0.00 -0.04
Dioxin 0.00 0.00 0.00 0.00 0.00
As 0.00 0.00 0.00 0.00 0.00
Notes
The negative numbers in the above table represent an additional air quality impact occurring
as a result of re-processing (in comparison to a situation where the product is manufactured
from virgin input)
Source: WRATE
Table 63-23: Damage Costs – Air Quality Impacts of Recycling
Paper Paper Plastics Plastics Glass
Glass
Ferrous Ferrous
Ferrous
metal
metal
Non Non
Non
ferrous
ferrous
metal metal
metal
Re-processing impacts - € 17.95 - € 108.05 - € 16.12 - € 81.83 - € 453.29
Notes
Re-processing impacts are calculated using inventory data from WRATE.
63.8 Composting Processes
This section considers the environmental impacts associated with two types of
composting process
1. Windrow (or open) composting systems;
2. In vessel (or enclosed) composting systems.

The two processes have similar environmental impacts. Key differences between the
two are:
1017
� The use of biofilters in the in-vessel system to reduce ammonia (NH3) and VOC
emissions occurring during the process, resulting in additional N2O emissions;
� The nature of energy consumption (in vessel systems require the use of some
electricity, whilst the windrow facilities use more diesel).
The sections that follow discuss the environmental impacts of composting processes
with respect to air emissions of relevance to climate change and air quality. The use
of the compost results in other environmental benefits such as a reduction in the
requirement for the use of synthetic fertilisers. These benefits - relating to reductions
in soil and water pollution, as well as air pollution - are discussed in Section 63.8.4.
A summary of the damage costs associated with composting processes is provided in
Section 63.8.5.
63.8.1 Nitrogenous Emissions from Composting Processes
Nitrogenous emissions from composting processes impact on both climate change
and air quality. The NH3 emissions are determined by the quantity of ammonium ions,
urea, and organically bound nitrogen. The pH value, temperature, ventilation, and the
C/N-relation constitute other influencing factors. An increase in the pH value, higher
temperature, or better ventilation may all lead to greater emissions. High C/N
relations cause NH3 emissions to diminish. 1257
Nitrous oxide emissions are also determined by temperature, ventilation, nitrogen
content, the C/N relation, and other factors. 1258 Maximum N2O formation rates are
observed if the supply of oxygen during decomposition is insufficient. This may occur,
for example, if the partial pressure of oxygen in the rotting material drops to zero due
to very high rates of biological activity. 1259
1257 K. Csehi, J. Beck and T. Jungbluth (1996) Emissionen bei der Mietenkompostierung tierischer
Exkremente. Landtechnik 51, S. 218-219; K. Csehi (1977) Ammoniakemission bei der Kompostierung
tierischer Exkremente in Mieten und Kompostqualität. Diss. Universität Hohenheim 1977, MEG-
Forschungsbericht 311, 156 S; T. Maeda and J. Matsuda (1997) Ammonia Emissions from Composting
Livestock Manure (Ammoniakemissionen bei der Mistkompostierung), in A. M. Voermanns and G.
Montney (eds.) (1997) Ammonia and Odour Control from Animal Production Facilities (Ammoniak- und
Geruchskontrolle aus Tierproduktionsanlagen), Proceedings I, Vinkeloord, Niederlande, 6.-10. 10.
1997, S. 145-153.
1258 L. Hüther (1999) Entwicklung Analytischer Methoden und Untersuchung von Einflußfaktoren auf
Ammoniak-, Methan- und Distickstoffmonoxidemissionen aus Flüssig- und Festmist.
Landbauforschung Völkenrode, Sonderheft 200, Braunschweig (FAL) 1999, 225 S.
1259 H. J. Hellebrand (1998) Emission of Nitrous Oxide and Other Trace Gases During Composting of
Grass and Green Waste (Emission von Lachgas und anderen Spurengasen während der
Grüngutkompostierung). J. Agric. Engng Res. 69, S. 365-375; S. Zhou, H. Zaeid, and H. Van den Weghe
(1999) Kompostierung tierischer Exkremente - Einfluß der Sauerstoffkonzentration auf
Reaktionskinetik und Emissionsverhalten, Agrartechnische Forschung 5, S. 2-10
International Review of Waste Policy: Annexes

Aeration and the C:N ratio are believed to have an important effect on the nitrogen
conversion processes. Where composting processes have included manures,
intensive aeration in connection with low C-content has been shown to give rise to
nitrite accumulation in slurry (up to 33% of the total nitrogen content) and incomplete
ammonium oxidation. Low ventilation rates and sufficient carbon supply support the
formation of nitrous oxide during nitrification and denitrification processes.
Gronauer et al suggest that around 12% of total nitrogen escapes from the material in
the form of ammonia. 1260 This gave a figure of 0.53kg/tonne waste in raw gas, but
0.0264kg per tonne waste when the air is passed through a biofilter. Gronauer et al
also assumed that 0.15kg N2O per tonne waste would be emitted.
One Swedish study assumed the nitrogen leakage to air was 7.5% of the nitrogen
content of the feedstock. 1261 Of this leakage, it was assumed 89% was emitted as
NH3, 9% as N2O and 2% N2. The study for the Danish EPA assumed that of the total
amount of nitrogen lost as gaseous emission, 98 % was volatilised as NH3, 0.5 % as
N2O and 1.5 % as N2 (the figures relate to raw gas as opposed to gas which has been
scrubbed). 1262
Our analysis assumes nitrogenous emissions from composting processes are as
follows:
1018
� 10% of the total nitrogen content of the waste is released in some form. Of this
10%, we further assume that:
29/09/09
• 88% is released as NH3;
• 2% is released as N2 (this is not a problem for the environment); and
• 10% is released as N2O.
Whilst the NH3 is released untreated in windrow systems, in vessel systems typically
make use of biofilters to convert much of this pollutant to N2O. This is discussed in
the sections that follow.
63.8.2 Climate Change Impacts of Composting Processes
Table 63-24 outlines the key assumptions used to model the climate change impacts
of composting processes, which were developed in a previous study for WRAP by
1260 A. Gronauer, M. Helm, H. Schon (1997) Verhafen und Konzepte der Bioabfallkompostierung –
Vergleich – Bewertung – Empfehlungen, Bayerische Landesanstalt fur Landtechnik der TU Munchen-
Weihenstephan
1261 Goran Finnvenden, Jessica Johansson, Per Lind and Asa Moberg (2000) Life Cycle Assessments of
Energy from Solid Waste, Forskningsgruppen for Miljostrategiska Studier, FMS 137, August 2000
1262 B. Gunnarsdotter Beck-Friis (2001) Emissions of Ammonia, Nitrous Oxide and Methane during
Composting of Organic Household Waste, Agraria 266, Doctoral Thesis, SLU, Sweden, sited in A. Baky
and O. Eriksson (2003) Systems Analysis of Organic Waste Management in Denmark, Environmental
Project No. 822, Copenhagen: Danish EPA

Eunomia. 1263 The principal climate change impacts are associated with release of
biogenic CO2 emissions which are not reported in the majority of studies that use a
life-cycle assessment approach to analyse the emissions of greenhouse gases. Some
impacts are different depending on the feedstock used within the composting
process. N2O emissions are higher when food waste is composted due to the higher
nitrogen content of the feedstock.
Table 63-24: Assumptions Used to Model Composting Processes
Parameter Parameter
Assumption
Assumption
CH4 emissions from process 0.816 kg / t input
N2O emissions from process
In vessel (garden waste)
In vessel (food waste)
Windrow
1019
International Review of Waste Policy: Annexes
0.361 kg / t input
0.477 kg / t input
0.117 kg / t input
Non-degraded carbon (retained in biomass) 30%
Electricity requirement
In vessel
Windrow
Diesel use by process
In vessel
Windrow
40 kWh / t input
0 kWh / t input
0.3 l / t input
1.0 l / t input
Mineralisation rate of readily available organic matter 20%
Mineralisation rate of stable humus 1%
% of organic matter from compost becoming humus 25%
Notes:
1. No action of biofilter is assumed for windrow facilities.
2. A further 0.4 litres of diesel is used to spread the compost onto land.
3. The mineralisation rate is the rate at which carbon contained within the organic
matter (or humus) is assumed to become atmospheric CO2.
63.8.3 Air Quality Impacts of Composting Processes
Other than the greenhouse gases, the principal emissions to air from composting
processes are:
1. NH3;
2. VOCs;
1263 Eunomia (2006) Managing Biowastes from Households in the UK: Applying Life-cycle Thinking in
the Framework of Cost-benefit Analysis, Final report for WRAP, May 2006

1020
3. Bioaerosols
Of these, the first two impacts differ depending on the nature of the composting
process. This is discussed in Sections 63.8.3.1 and 63.8.3.2. Bioaerosols are
discussed in Section 63.8.3.3.
63.8.3.1 Air Quality Impacts in Windrow Composting
As was previously indicated in Section 63.8.1, our analysis assumes that 10% of the
total nitrogen content of the waste is released in some form and that of this 10%,
88% is released as NH3 in windrow systems that operate without the use of a biofilter.
This results in NH3 emissions of 795 g of NH3 per tonne of waste to the facility.
Although relatively few studies have investigated emissions of VOCs from composting
processes, the UK’s Environment Agency did measure emissions from sites. These
are shown in Table 63-25.
Table 63-25: Emissions of VOCs from Monitoring of Compost Facilities
Compounds Compounds Detected Detected
g / / tonne tonne of of MSW
MSW
m,p Xylene [108-38-3; 106-42-3] 0.81
Nonane [111-84-2] 0.44
o Xylene [95-47-6] 0.54
Beta.-Pinene [127-91-3] 3.7
Ocimene [13877-91-3] 3.0
D-Limonene [5989-27-5] 10.5
Undecane [1120-21-4] 2.4
Dodecane [112-40-3] 1.2
Methyl-(methylethyl)-Cyclohexane [99-82-1] 1.5
Total 24.0
Source: Environment Agency (2000) Life Cycle Inventory Development for Waste Management
Operations: Composting and Anaerobic Digestion, R&D Project Record P1/392/4
We have used the total Environment Agency figure – of 24 g of emission per tonne of
waste to the facility - with regard to the emission of VOCs from windrow composting
processes.
63.8.3.2 Air Quality Impacts In Vessel Composting Systems
In in-vessel composting systems, NH3 is usually treated in biofilters. In biofilters, the
nitrogen in the ammonia is converted to, in varying proportions, N2, NO and N2O.
One study looking at MBT processes suggests a mass balance for a biofilter as shown
in Figure 63-1. The figure suggests that, as regards N, for every 500 g of N entering
the biofilter as NH3, an additional 111 g of N is emitted as N2O. This would imply a
conversion ratio of 22%. On the other hand, the above figure suggests a low overall
rate of destruction of NH3.
29/09/09

Figure 63-1: N-balance of a One Step Biofilter at the MBP Plant in Bassum, Germany
Source: H. Doedens, C. Cuhls, F. Mönkeberg et al. (1999) Balancing Environmentally Relevant
Chemicals in the Biological Pre-Treatment of Residual Waste – Phase 2: Emissions, Pollutant Balances
and Waste Gas Treatment (in German: Final Report for the German Federal Research Project on
mechanical-biological treatment of waste before landfill. Hannover: University, 1999
Trimborn et al conclude that independent from the level of NH3 load in the raw gas
ca. 29% of the transformed NH3 is released as N2O and ca. 9% to NO. 1264
Amlinger et al assume that: 1265
1021
the continuous aerobic conditions in the biofilter supports the microbial
oxidation of NH4 + to NO2 - . High concentrations of NH3 and NO2 - can inhibit
further oxidation to NO3 - (Spector, 1998a,b). NO2 - can be directly denitrified to
NO and N2O. It is likely that caused by a high NH3 - concentration the microbial
community in the biofilter is shifted in a way that deoxidising, denitrifying
enzymatic activities become predominant.
Literature suggests range of removal efficiencies for different compounds using
biofilters. Vogt et al assumed a removal efficiency of 96% for NH3, 50% for methane
and 50% for total organic carbon. Omrani et al site removal efficiencies of 97-99% for
a biofilter using peat, soil and sand, whilst one of sawdust, clay and sand achieved
94% abatement. 1266
1264 M. Trimborn, H. Goldbach, J. Clemens, C. Cuhls, A. Breeger (2003) Endbericht zum DBU-
Forschungsvorhaben Reduktion von klimawirksamen Spurengasenin der Abluft von Biofiltern auf
Bioabfallbehandlungsanlagen (AZ: 15052)
1265 F. Amlinger, C. Cuhls and S. Peyr (2007) Greenhouse Gas Emissions from Composting and
Mechanical Biological Treatment, Waste Management and Research
1266 G. Omrani, M. Safa and L. Ghaghazy (2004) Utilization of Biofilter for Ammonia Elimination in
Composting Plant, Pakistan Journal of Biological Sciences, 7, pp2009-2013
International Review of Waste Policy: Annexes

The current analysis assumes that in total, 95% of the nitrogen in the NH3 entering
the biofilter is converted by the action of the biofilter. Of the converted proportion,
25% of the nitrogen is assumed to be converted to N2O. We also assume that 50% of
the VOCs are removed by the action of the biofilter, and that those remaining are not
harmful to health (and therefore no damage cost is associated with their emission).
63.8.3.3 Bioaerosols
Significant recent interest, at least within the UK, has centred on the potential
consequences of emissions of bioaerosols from composting processes. The
Environment Agency sponsored two studies in the early part of the decade. These
studies were reviewed for the Cabinet Office in a paper by Hogg. 1267 That review cast
some doubt upon the conclusions drawn from the research undertaken, notably, the
way in which it was used to influence regulatory guidance, for example, in respect of
distancing from compost facilities. 1268
Bioaerosols are micro-organisms and other tiny biological particles that are
suspended in air. They are respirable and generally invisible. Dusts are small particles
that are larger than bioaerosols. They are inhalable but not respirable and are visible.
Bioaerosols and dusts can both be produced by the composting process. Surveys
have drawn particular attention to a fungus called Aspergillus fumigatus. It is found
all over the world, especially in soils and in forest litter. It is particularly associated
with the composting process as it is capable of degrading cellulose (a carbohydrate
found in plant material) and it is capable of surviving at temperatures of up to 65°C.
As part of its lifecycle, Aspergillus fumigatus produces tiny spores. If inhaled as a
bioaerosol these spores may cause allergies and inflammation, which in certain
individuals can cause serious health disorders such as Asthma, Alveolitus, Mucus
membrane irritation, Chronic Bronchitis and coughs, Gastro-intestinal disorders and
Skin disorders.
Individuals who work at a composting facility – less frequently those who are located
in close proximity to a facility – may be exposed to, and inhale large quantities of
bioaerosols, particularly when compost is being moved or agitated, To most
individuals, exposure to bioaerosols does not appear to cause significant problems.
However, as with some more conventional pollutants, certain individuals, for example
asthmatics and the immuno-compromised, may suffer adverse health effects after
exposure to bioaerosols.
The number of individual organisms necessary to cause a reaction varies according to
the state of health of the person exposed to them. In the composting process, the
levels encountered can be significantly higher than background levels. Therefore it is
imperative that steps should be taken to protect site operatives and residents in the
surrounding areas. Effective operational management can help to control the
formation of bioaerosols and dusts and thus reduce the impacts associated with
these pollutants.
1267 D. Hogg (2002) Waste Treatments Mk II: Health Effects, Report for the Strategy Unit.
1268 See Environment Agency (2001) Agency Position on Composting and Health Effects, 2001.
1022
29/09/09

It should be noted that bioaerosols from the composting process contain the same
micro-organisms as ones to which citizens are routinely exposed. They are present
naturally and are essential to the recycling of nutrients in our gardens, parks and
countryside.
We have not been able to incorporate the impacts of bioaerosol emissions into our
model as no dose-response functions have yet been developed to quantify the
impacts associated with this type of pollutant. However the preceding discussion
suggests the environmental and health impacts of these emissions should be
minimised with the adoption of appropriate operational management techniques.
63.8.4 Benefits Associated with the Use of Compost
The use of compost is associated with monetised benefits, extending beyond the
realm of air pollution to include, amongst others, reductions in water pollution and
improvements to soil quality.
We include within our model the slow release of CO2 from the soil after the compost is
added. After 50 years, approximately 13% of the initial carbon contained within the
compost remains in the soil.
65% of the compost produced is assumed to be used in agriculture. Our model
considers the following benefits associated with the use of compost in this way: 1269
1023
� The displacement of alternative nutrient sources otherwise applied through
the use of synthetic fertiliser, including the avoided external costs of fertiliser
manufacture and the avoided energy use associated with this;
� The greenhouse gases avoided from nitrogenous fertiliser applications (i.e.
N2O emissions) and the external costs associated with this;
� Avoided external costs from a reduction in the leaching of nitrate (from
nitrogenous fertilisers) into groundwater;
� Avoided external costs associated with process wastewater and
phosphogypsum disposal during the manufacture of phosphate fertiliser;
� Avoided energy requirement associated with the mining of phosphate rock for
phosphate fertiliser, and the avoided external costs associated with this;
� Avoided external costs through a reduction in the use of pesticides; and
� Avoided external costs through a reduction in the use of water.
The remaining 35% of the compost is assumed to displace the use of peat in
horticulture and hobby gardening applications. Here the avoided impacts are the slow
release of CO2 from the aerobic degradation of peat after its removal from the peat-
1269 For a detailed description of the methodology used to calculate these estimates see: Eunomia (2007)
Managing Biowastes from Households in the UK: Applying Life-cycle Thinking in the Framework of Cost-benefit
Analysis, Appendices to the Main Report, Report for WRAP, May 2007
International Review of Waste Policy: Annexes

land. 1270 The use of compost in horticulture is also assumed to result in a reduction in
the use of pesticides.
Monetised benefits associated with the use of compost are presented in Table 63-26.
Table 63-26: Monetised Benefits Associated with the Use of Compost
Agriculture
Horticulture
1024
29/09/09
In In vessel vessel Windrow
Windrow
Pesticide reduction - € 3.23 - € 3.93
Nutrient displacement - € 2.84 - € 2.62
Avoided phosphate rock extraction - € 0.76 - € 0.56
Avoided process wastewater disposal - € 0.26 - € 0.19
Avoided water use - € 1.07 - € 1.07
Avoided N-leaching - € 2.31 - € 2.29
Avoided N2O emissions - € 0.18 - € 0.18
Avoided peat extraction - € 0.32 - € 0.32
Pesticide reduction - € 1.74 - € 2.11
Notes
Compost produced from the in vessel process is assumed to result from a mixture of 70%
garden waste and 30% food waste.
The results shown in Table 63-26 show damage costs relating to compost produced
in an in vessel system with a feedstock of 30% food waste, against compost resulting
from a windrow system that is assumed to treat only garden waste. The differences in
the damage costs result from the different feedstocks assumed to be treated by each
type of system. A larger volume of compost is produced from a feedstock comprised
of 100% garden waste, as garden waste contains less moisture, and more of the
lignin-based materials which are resistant to degradation. Against this, compost
produced from a feedstock containing food waste has a higher nutrient content, and
can therefore displace greater quantities of nutrient that are assumed to have been
otherwise supplied by the use of synthetic fertilisers.
63.8.5 Summary – Damage Costs Associated with Composting Processes
Table 63-27 summarises the damage costs associated with treating source
separated organic wastes in composting systems.
1270 This follows the methodology described in AEA Technology (2001) Waste Management Options and Climate
Change: Final Report, European Commission: DG Environment, July 2001

Table 63-27: Summary of Damage Costs – Composting Systems
1025
International Review of Waste Policy: Annexes
Damage Damage costs, costs, € per tonne of input to process process
In In vessel vessel
Windrow
Windrow
High High Low Low Low High High Low
Low
Climate Change €14.59 €12.21 €14.89 €12.44
Air Quality €2.76 €0.96 €9.02 €3.16
Benefits – use of compost - €12.71 - €11.68 - €13.27 - €12.36
TOTALS €4.63 €1.49 €10.64 €3.24
Notes
The feedstock for the in vessel composting system is assumed to comprise of 70%
garden waste and 30% food waste.
63.9 Anaerobic Digestion of Food Waste
The environmental impacts associated with the anaerobic digestion (AD) of food
waste depend in part on how the biogas produced by the process is subsequently
utilised. The sections that follow discuss these impacts with reference to the following
possible uses of the gas:
1. On-site combustion of biogas, generating electricity;
2. Biogas upgrading and its subsequent use as a vehicle fuel displacing the use
of diesel in a heavy goods vehicle such as a bus.
63.9.1 Climate Change Impacts
CO2 emissions resulting from the AD of source-separated organic waste are based on
the carbon content of the input waste, assumed to 100% food waste for the purposes
of this study. The carbon content is calculated on the basis of the total organic
content of the waste and its volatile solids (VS) content. A proportion of the total
carbon content will be converted to CO2 as a result of biogas combustion for energy
generation. A further (albeit small) amount is emitted as CH4 through fugitive
emissions occurring during the digestion process. Table 63-28 outlines key
assumptions used to model the AD process within this study. 1271
1271 For more information regarding the methodology used to model the AD process see Eunomia
(2007) Managing Biowastes from Households in the UK: Applying Life-cycle Thinking in the Framework
of Cost-benefit Analysis, Appendices to the Main Report, Report for WRAP, May 2007

Table 63-28: AD Process Emissions
Parameter Parameter
Assumption
Assumption
Dry matter content of food waste 30%
Organic matter content of VS 93%
Carbon content of VS 45%
VS content of organic matter 45%
VS loss during digestion 70%
Methane content of biogas 60%
Electricity requirement 10% of biogas energy
Heat requirement 125 kWh / t
Fugitive emissions (% carbon converted to CH4) 1%
Notes
The energy requirement is assumed to be supplied by the plant itself (i.e. as parasitic load).
No additional emissions are therefore associated with the use of this energy, but the biogas
used in this way is assumed to be unavailable for further utilisation. The energy utilisation
figures are based on data supplied by plant operating in the UK and Germany.
Sources: Greenfinch (2005) Mass and Energy Balance: Ryegrass and Pig Slurry Biogas Plant,
Produced for DTI, September 2005; University of Glamorgan, The Wales Centre of Excellence for
Anaerobic Digestion and the Sustainable Environment Research Centre (2007) Ludlow (Greenfinch)
Trial Scale Kitchen Waste Treatment Plant; H. Bachmaier, M Effenberger and A Gronauer (2008)
Agricultural Biogas Production: What About the Climate Balance?, 17 th Annual Convention of
Fachverband Biogas e.V, 15 th -17 th January 2008, Nuremberg; Eunomia (2007) Managing Biowastes
from Households in the UK: Applying Life-cycle Thinking in the Framework of Cost-benefit Analysis,
Appendices to the Main Report, Report for WRAP, May 2007
Assumptions used to model the on-site utilisation of biogas in a gas engine are
presented in Table 63-29. These assumptions have been developed from data
provided by German plant operators.
Table 63-29: Emissions from the Use of Biogas in a Gas Engine
Parameter Parameter
Assumption
Assumption
Gross electrical efficiency of gas engine 40%
Fugitive emissions (gas engine slip) 2%
Notes
Net electrical efficiency is 30% taking into account parasitic load figures provided in Table
63-28. The net electricity generation total is assumed to be 286 kWh per tonne of waste to
the facility.
Sources: H. Bachmaier, M Effenberger and A Gronauer (2008) Agricultural Biogas Production: What
About the Climate Balance? 17 th Annual Convention of Fachverband Biogas e.V, 15 th -17 th January
2008, Nuremberg; F. Scholwin (2008) The State of Treatment of Biogas for Feeding in the Natural Gas
Network in Germany, 17 th Annual Convention of Fachverband Biogas e.V, 15 th -17 th January 2008,
Nuremberg
1026
29/09/09

If the biogas is cleaned of impurities it can be subsequently used as a vehicle fuel,
displacing the use of diesel. Our assumptions for modelling this option assume the
fuel to be used within a fleet of vehicles, re-fuelled from a central point, as is the
practice in Scandinavia and France. Some modification to the vehicle will be required
to allow it to run on gas as opposed to diesel. Assumptions used to model this option
are summarised in Table 63-30.
Table 63-30: Emissions from the Use of Biogas in a Vehicle
Parameter Parameter
Assumption
Assumption
Energy used during upgrade process 0.2 kWh / Nm 3 biogas
Process losses for CH4 (from upgrade process) 2%
Fuel consumption of CBG bus 23.4 MJ / km
Emissions avoided by diesel production 13.63 g CO2 equ / MJ
Emissions from diesel bus 1,226 g CO2 equ / km
Sources: W. Urban (2008) Methods and costs of the generation of natural gas substitutes from
biomass – presentation of results of latest field research, 17 th Annual Convention of Fachverband
Biogas e.V, 15 th -17 th January 2008, Nuremberg; N. Nylund, K. Erkkilä, M. Lappi, and M. Ikonen (2004)
Transit Bus Emission Study: Comparison of Emissions from Diesel and Natural Gas Buses, VTT
Processes, October 2004; Bio-NETT (2008) Bio-methane in Lille: A Case Study
63.9.2 Air Quality Impacts
63.9.2.1 Combustion of the Biogas in a Gas Engine
Where biogas is used to generate energy using a gas engine, emissions are
associated with the combustion process. The most significant air quality impacts
resulting from the combustion of biogas relate to emissions of SOx and NOx.
SOx emissions are generally a matter for process management. To the extent that
they stem from the H2S in raw gas, the emissions are related to the use of, for
example, precipitation salts which seek to precipitate out the sulphur emitted from
the degradation of proteins as iron sulphide.
NOx emissions result from high temperature reactions occurring between
atmospheric nitrogen, and trace elements such as NH3 and H2S contained within the
biogas. 1272 These emissions can be significantly reduced using Selective Catalytic
Reduction (SCR) techniques. Use of this technique was cited as the Best Available
Technique (BAT) in the Reference Document for the Waste Treatment Industries for
MBT systems using AD. However, although this equipment is widely used to reduce
NOx emissions from waste incineration facilities across Europe, use of SCR within AD
1272 V. Aschmann, R Kissel and A Gronauer (2008) Efficiency and Environmental Compatibility of
Biogas Fired Cogeneration Plants in Practical Service, 17 th Annual Convention of Fachverband Biogas
e.V, 15 th -17 th January 2008, Nuremberg
1027
International Review of Waste Policy: Annexes

plant is still relatively limited. 1273 The air quality limits imposed upon AD facilities are
typically less onerous than those for waste incinerators; thus there is a lack of
incentive to incur the further expense that the installation of this additional
equipment requires.
Table 63-31 outlines the emissions from the combustion of biogas using a gas
engine. The table uses data from the previously cited Reference Document along with
information supplied through emissions tests at an Australian MBT plant operated by
Global Renewables Ltd (GRL). The latter may overstate emissions, being derived from
mixed waste sources.
Table 63-31: Emissions from the Combustion of Biogas
1028
29/09/09
Emissions Emissions from from from biogas biogas combusti combustion combusti on (g / tonne
of of of waste waste to to process)
process)
CO 200
Dust 20
NOx 250
Hydrocarbons 40
SO2 20
Notes
Emissions are calculated assuming 3,960 m 3 exhaust gas is produced per hour from each of
two gas engines, using data provided by GRL from their Eastern Creek MBT facility in Australia
(that facility treats 70,000 tonnes of waste per year in the AD part of the plant).
Sources: European Commission (2006) Integrated Pollution Prevention and Control: Reference
Document on Best Available Techniques for the Waste Treatment Industries, August 2006; EML Air
PTY (2008) Test Report Prepared for Eastern Creek Operations, report for Global Renewables Ltd, April
2008; AEA (2007) Mechanical Biological Treatment: Case Study 2: Eastern Creek UR 3R Sydney,
Report to IEA Bioenergy Task 36, April 2007
However, as was previously indicated in Table 63-29 the plant is assumed to
generate 286 kWh of electricity per tonne of waste to the facility, and emissions to air
are assumed to be offset as a result of this energy production. The avoided air
emissions resulting from electricity generation are presented in Table 63-32,
calculated using emissions data supplied by Ecoinvent for European CCGT plant. The
data suggests that there is a marginal air quality benefit associated with generating
electricity using AD in comparison to generation at larger scale CCGT plant. As gas
turbine efficiencies increase, the resultant higher firing temperatures lead to greater
NOx formation. Thus measures taken to reduce NOx formation will be less effective at
the larger and more efficient CCGT plant. 1274 Levels of other emissions will depend on
1273 It is understood, however, that authorities in The Netherlands wanted to impose this as standard
for all AD facilities.
1274 European Commission (2006) Integrated Pollution Prevention and Control: Reference Document
on Best Available Techniques for Large Combustion Plants, July 2006

the source of the natural gas, and on the pollution control regime undertaken by the
plant.
Table 63-32: Emissions Offset by Electricity Generation at AD Plant
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International Review of Waste Policy: Annexes
Emissions Emissions Emissions from from biogas biogas combustion combustion combustion (g (g / / tonne tonne
tonne
of of waste waste to to process)
process)
Dust -31
NOx -268
Hydrocarbons -15
SO2 -35
Source: Ecoinvent (2004) Ecoinvent Data v1.1, Final Reports Ecoinvent 2000, No. 1-15, Swiss Centre
for Life Cycle Inventories, Dubendorf, 2004
63.9.2.2 Use of the Upgraded Biogas to Fuel Vehicles
The size of vehicle has a considerable impact on its emissions. Fuel consumption is
far greater for heavier vehicles such as lorries and buses in comparison to cars,
resulting in higher emissions per km. Both liquid fuel and gas operated heavy goods
vehicles have seen considerable improvements in emissions over the past decade.
There remains, however, considerable variation in performance between currently the
available vehicles using either fuel.
Table 63-33 shows the emissions data used within our model of environmental
impacts associated with the use of biogas to fuel vehicles, taken from a Finnish study
produced in 2003. This data has been used because compares gas operated and
liquid fuelled engine performance using similar Euro III engines, thus allowing the
differential in performance associated with the type of fuel to be more accurately
assessed. Although the Finnish study looked at emissions from natural gas buses, as
opposed to those fuelled on biogas, the data is consistent with emissions data from
Scandinavia and France where biogas-fuelled buses are more widely used. 1275
1275 C. Plombin (2003) Biogas as Vehicle Fuel: A European Overview: Trendsetter Report No 2003:3,
Stockholm; Bio-NETT (2008) Bio-methane in Lille: A Case Study

Table 63-33: Emissions of Gas-fuelled and Diesel-fuelled Buses
1030
29/09/09
Emissions Emissions g g / / km
km
NMHC NMHC
NOx NOx
PM PM
Diesel 0.12 8.50 0.10
Gas 0.03 4.60 0.01
Source: N. Nylund, K. Erkkilä, M. Lappi, and M. Ikonen (2004) Transit Bus Emission Study: Comparison
of Emissions from Diesel and Natural Gas Buses, VTT Processes, October 2004
The data in Table 63-33 suggests the use of biogas to fuel vehicles should result in
improvements to air quality, particularly with regard to the NOx emission.
63.9.3 Compost Produced by AD Process
The residues can either be dewatered, creating a solid and a liquid fraction, or used
directly on land as a slurry, sometimes using flocculants in the process.
Whilst there may be some arguments for direct spreading, not least that of cost, it is
considered better practice to stabilise the solid residues (following dewatering
depending upon the materials and the process) through an aerobic stage so as to
produce a compost. One of the reasons for stabilising the solids from digestion is to
reduce the potential for nitrogen to leach following application – the stabilisation
process makes for an amendment with high organic matter content, but with reduced
availability of nitrogen. The level of nutrients such as phosphorous is much lower than
in, say, sludge based materials, making it possible to apply more organic material
without creating problems of groundwater pollution / surface water run-off.
In this study, we have assumed that the digestion process is followed by an aerobic
treatment phase, and that the early stages of the aerobic treatment employ a
biofilter. This adds slightly to the costs of treatment, and some equipment suppliers
prefer to make the slurry available without such a treatment step.
Additional emissions of CO2 and NH3 are assumed to occur in the aerobic phase, and
some additional CH4 is assumed to be emitted in the transition from the anaerobic to
the aerobic phase. The use of the biofilter necessitates the use of some additional
electricity.
Emissions offsets attributed to the use of the compost produced in this way are
calculated using the same methodology described in Section 63.8.4.
63.9.4 Summary – Damage Costs Associated with AD Processes
Table 63-34 summarises the damage costs associated with treating source
separated food waste in AD systems.

Table 63-34: Summary of Damage Costs – AD Systems
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International Review of Waste Policy: Annexes
Damage Damage costs, costs, € per tonne of input to process process
On On-site On site use use of of biogas biogas to
to
generate generate electricity
electricity
Use Use of of upgraded upgraded biogas biogas to
to
fuel fuel fuel buses
buses
High High Low Low High High Low
Low
Climate Change €11.70 €9.75 €6.21 €5.20
Air Quality - €0.25 - €0.09 - €5.21 - €1.81
Benefits – use of compost - €7.32 - €6.83 - €7.32 - €6.83
TOTALS €4.13 €2.83 - €6.32 - €3.44
Notes
Climate change and air quality impacts include the emissions offsets attributable to the
generation of energy
63.10 Benefits of the Policy Package to Ireland
We have attempted to calculate the benefits of the proposed policies in the Main
Report to Ireland. The basis for the calculation is as follows:
� The year for which benefits are calculated is 2016;
� The benefits cover those from municipal waste only;
� Growth rates are estimated as in Table 63-35;
� Capture rates are assumed to be as in Table 63-36 (this level of capture will
meet the targets set out);
� A food waste prevention effect equivalent to 10% of food waste is assumed to
be related to the introduction of food waste collections in households and
commercial enterprises;
� The greenhouse gas effects include all greenhouse gases, so do not reflect
reporting to IPCC. The figures used are from previous sections in the Annex;
� The monetised benefits from textiles recycling and food waste prevention
relate to GHGs only;
� For organics, we have assumed emissions of 0.25 tonnes CO2 equ per tonne
of waste and we have assumed environmental costs (not benefits) of the
average of the AD plant using electricity only, and the in-vessel composting
plant modelled earlier in this Annex; and
� The GHG benefits from avoided disposal are related only to biodegradable
materials, and are calculated as an average of the non-landfill treatments
modelled.
The results for greenhouse gas savings are shown in Table 63-36. The overall
environmental benefits are shown in Table 63-37. It can be seen that benefits in

excess of €76 million are expected, whilst the reduction in greenhouse gases is
equivalent to more than 1.4 million tonnes of carbon dioxide.
Table 63-35: Assumed Growth Rates from 2007
2008 2008 2008 2009 2009 2010 2010 2010 2011 2011 2011 2012 2012 2012 2013 2013 2013 2014 2014 2014 2015 2015 2015 2016 2016
2016
Household -1% -3% -1% 1% 1% 1% 1% 1% 1%
Non-household
Municipal
-3% -7% -2% 1% 2% 2% 2% 2% 2%
Table 63-36: Capture Rates and GHG Benefits Relative to 2007 Performance
Captures Captures
Captures
Additional Additional
Additional
Tonnage
Tonnage
Captured
Captured
GHG GHG
GHG
Benefits
Benefits
(tonnes (tonnes
(tonnes
CO CO2 CO equ) equ)
equ)
Paper 90% 292,240 181,189
Glass 90% 29,982 8,995
Plastic 40% 50,565 70,792
Ferrous 85% 7,156 8,588
Aluminium 85% 20,045 184,413
Other Metals 85% 3,034 15,779
Textiles 60% 136,591 413,872
Organics 75% 574,211 -143,553
Wood 50% / 99% 3,451 3
Food Waste Prevention (@10%) 206,053
Avoided Disposal 469,099
TOTAL 1,415,230
Note: A positive figure denotes a a reduction in GHGs
Table 63-37: Environmental Benefits Relative to 2007 Performance
Activity
Activity
Environmental
Environmental
Benefit Benefit ( (€) (
€)
Separate Collection €45,741,864.247
Avoided Disposal €24,878,888.57
Food Waste Prevention (@10%, GHG benefit only) €5,975,547.29
TOTAL €76,596,300.10
Note: A positive figure denotes a benefit (a reduction in environmental costs)
1032
29/09/09

64.0 Costs of Household Waste Collection
64.1 Background – The Waste Collection Market Operating in
Ireland
The chargeable waste collection services operated in Ireland are practically unique.
The collection market is effectively an open one in which private companies and local
authorities alike are competing against one another. The Waste Management Act
(1996) stipulates that all local authorities in Ireland are obliged to collect or arrange
for the collection of domestic waste in their area. However, as discussed in the policy
review annex, though this means that local authorities are responsible for
administering the permits to collect waste, there is no control on individual
households as to how they choose to avail themselves (or not) of the services offered,
and only limited control (though the collection permits) on how the waste is
subsequently managed. 1276
A consequence of the free market for waste collection is that collection routing
(referred to as round design) probably suffers inefficiencies due to low customer
densities. In addition, spatial logistics may be less than optimal with regard to cost in
that average distances (and hence, other things being equal, journey times) from
depots to rounds might be expected to be longer where different collection operators
are operating in overlapping territories.
Organised competition for providing collection services is certainly to be encouraged
as it forces contractors to optimise for cost efficient services. In the majority of
instances around Europe (and worldwide), however, the competition is conducted
through a tendering process to win a contract for comprehensive collection from all
households. In some cases, local authorities themselves provide the service.
However, the situation where the competition remains open on a day by day basis
leads to multiple companies being operational in an area, even though they may only
have a small number of customers in any one street. Collection costs per household
naturally suffer due to the impact that this has on the efficiency of utilisation of staff
and vehicles.
Using an analogy to the electricity supply market, rather than customers all using the
one set of power lines, it is much like a number of different companies all providing
their own power lines in every street, with households selecting their cable of choice.
The total costs of providing the service are greatly increased, and the efficiency in the
way in which the service is provided is reduced. In situations where such services are
provided in a genuinely competitive market, ironically, the costs may rise to users
even as the margins to operators decline. In short, nobody wins.
1276 The collection permit system does appear to be being deployed with increased vigour by the
relevant authorities so that this level of control may be increasing.
1033
International Review of Waste Policy: Annexes

This annex attempts to interrogate the costs borne by households for their waste
services in Ireland, and to deconstruct them to assess the fundamental issues that
may be obstructing value for money.
64.2 Collection Service Case Studies in Irish County Councils
There has recently been a move towards the roll out of organics collection in many
parts of Ireland in recognition (by county councils and Joint Waste Management
Plans) of the desirability of diverting biodegradable waste from landfill. In 2007, the
EPA reported that 14 of the local authorities had some brown bin collections in their
area, but in only 5 of these were more than 1,000 tonnes being collected (see Table
64-1). Only in Galway City was the private sector achieving such rates. It can
reasonably be suggested therefore that the majority of the households are still not
served with a brown bin collection.
Table 64-1: Separate Collection of Household Organic Waste
Local Local Authority Authority
2006 2006
2007
2007
Separate Separate Separate Kerbside Kerbside Collection Collection of of Food
Food Separate Separate Separate Kerbside Kerbside Kerbside Collection Collection of of Food
Food
and and Garden Garden waste waste (brown (brown bins)
bins) and and Garden Garden waste waste (brown (brown bins)
(tonnes)
(tonnes)
(tonnes) (tonnes)
(tonnes)
Local Local Authority Authority Authority Private Private Operator Operator Local Local Authority Authority Authority Private Private Operator
Operator
Dublin City
Council
411 1,315
Dun Laoghaire-
Rathdown
285
Fingal County
Council
1,971 3,266
Galway City
Council
4,987 774 4,163 1,968
Galway County
Council
883 889
Kerry County
Council
345 368
Louth County
Council
346
Mayo County
Council
127
Monaghan County
Council
27
South Dublin
County Council
36
Waterford City
Council
3,766 3,976
Waterford County
Council
2,165 2,123
Westmeath
County Council
10 90
Wicklow County
Council
10
Total Total
13,655 13,655 13,655
1,942 1,942
15,312 15,312
3,393
3,393
Source: EPA (2009) National Waste Report 2007, Johnstown Castle Estate, Wexford: EPA.
1034
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Within the following section we assess the waste collection systems that have been
operating over the past few years against the available data on waste tonnages
collected and collection costs.
The most common collection systems that have been operating in Ireland over the
past few years are twin bin, alternating fortnightly collections of residual waste and
recyclable materials. The basis for the annual levies for waste collection faced by
individual households is often not clear, in many cases not even to the households
themselves. As such, we attempt here to draw together information on the typical
fees paid by households in a number of areas around the country.
Anecdotal evidence from an OLAM Briefing presentation for the CCMA Environment
Committee suggests that the green bin recycling services cost the four Dublin local
authorities €27 million per annum in 2006. 1277 This includes the costs associated
with collecting, transporting, segregating, processing, shipping and marketing etc. It
goes on to state that Repak contributes €1 million, while the sale of the processed
product collected from households generates approximately €500,000. A significant
cost, therefore, is attributable just to providing the collection services.
Dividing the annual €27 million by the total of 380,000 households in these
authorities suggests providing the services costs €70 per household per year for a
fortnightly wheeled bin recycling collection service. This assumes that all households
use the local authority service, which they might not due to a) their opting out (dealing
with waste themselves) or b) their using the services of a private sector company. If
the number is smaller, the average cost is higher. Total captures of recyclables at the
kerbside under this system stand at around 180kg/hh/yr. It is important to note that
where household waste services are concerned, ‘cost per household’ are a somewhat
better measure than ‘cost per tonne’ (though both provide relevant information). This
is because:
1035
� The costs of different elements of a service can contribute to reductions
elsewhere;
� Different systems may draw more or less material into the waste stream (and
those that draw more in will have lower costs per tonne than those that do
not); and finally,
� What matters most from the household perspective is what they need to pay.
The following review seeks to bring together more evidence on collection services and
their associated costs in a snapshot of instances across the country. The
government’s circular 06/06 sought to assemble detail on the collection services
operated in individual counties together with fee structures and the charges levied.
Extracts from this data, supplemented by information gained from council and
1277 Murphy, R (2006) Managing The Environment: A Key Financial Challenge For Local Authorities,
OLAM Briefing for CCMA Environment Committee, February 2006.
International Review of Waste Policy: Annexes

collection operator websites and other sources 1278, are summarised for some
example flat rate fee services in Table 64-2.
Table 64-2: Sample of Flat Rate Standing Charge Waste Collection Levies in Irish
Counties
County County, County County , Service
Collection
Collection Details Details
Charges Charges Levied
Levied
Provider
Provider service service
service
Westmeath –
Mahons
Residual
Recycling
Organics
Fortnightly
Fortnightly
None
Standing charge €348 for 240l residual
bin, €288 for 140l (recycling free)
Wexford
County/Borough
Council
Residual
Recycling
Organics
Fortnightly
Fortnightly
None
Various rates from €260 (80l bin) to
€516 (240l)
Cork - Country
Clean
Residual
Recycling
Organics
Fortnightly
Fortnightly
None
€300 pa for 240l residual bin, recycling
free
Galway – City
Bin
Residual
Recycling
Organics
Fortnightly
Fortnightly
Fortnightly
€259 fixed fee
Kilkenny –
Greenstar
Residual
Recycling
Organics
Fortnightly
Fortnightly
None
€369 pa for 240l residual bin, €299 for
140l residual bin; both with 240l
recyclates bin
Residual Weekly
Fingal – Panda Recycling Fortnightly
€282 pa, fixed fee
Louth
Organics Fortnightly
(Drogheda) –
Panda
Residual Weekly €282 pa, fixed fee
Residual Every 3 weeks
Waterford Recycling Every 3 weeks
€320 pa, fixed fee
Organics Every 3 weeks
Where charges are levied according to the frequency or weight of material set out for
collection, annual charges to households will be variable. Charging structures for an
example set of pay by use (PBU) or pay by weight (PBW) services are given in Table
64-3.
The total annual fees payable by households in such cases where there is a variable
element to the charge are less transparent. It is however, possible to estimate some
typical costs in these circumstances by bringing together waste generation data from
the national waste reports and (where charges are levied for each pickup) making
assumptions on the number of collections required per annum. In general, at the
levels of residual waste generation observable in Ireland, it is likely for a typical
household to require a 240l wheeled bin to be emptied once per fortnight, although
this might fall to once a month, perhaps less frequently for some households (the
frequency required would be expected to fall with well designed biowaste collections
1278 Sunday Business Post (14 June 2009), Waste Not, Want Not, www.thepost.ie/story/eycweykfau
1036
29/09/09

in place). It is possible to sense-check this against the collected waste tonnage data
by using approximate bulk densities for waste and recycling. 1279 However, this
requires knowledge of how many households are using collection services. The fact
that there is no obligation on households to subscribe to a collection service is an
important one. Statistics on the number of households subscribing to collection
systems are hard to come by. The simplistic approach we use to quantify participation
here is to consider the tonnage of waste collected through kerbside operations and
relative to waste managed by other means (bring sites, civic amenity, direct to landfill,
home composting estimates and ‘uncollected waste’). This allows approximate typical
weights and volumes of waste produced per participating household to be estimated,
and for resulting annual charge levels to be quantified. 1280 Such an analysis is
undertaken in Table 64-4.
Table 64-3: Sample of Variable Charging Collection Systems
County County, County Collection
Collection Details Details Details
Charges Charges Levied
Levied
Service
Service
Provider
Provider
service
service
Dublin City
Council /
Greyhound
PBU
Residual
Recycling
Organics
Fortnightly
Fortnightly bin (paper,
card, cans, plastics)
Fortnightly
€84 + €5.25 / lift for 240l bin. Other
charges for sacks / different sized bins.
-
€2 / lift for wheeled bin
South
Tipperary CC
PBU
Residual
Recycling
Organics
Fortnightly
Fortnightly bin (paper,
card, cans, plastics)
None
€210 + €7 / lift for 240l bin
€0.70 / recyclable bag
-
Westmeath -
Mulleadys
PBW
Residual
Recycling
Organics
Fortnightly
Fortnightly (paper, card,
tetrapak, cans, plastics)
None
€208 + €0.17/kg
-
-
Westmeath -
Mulleadys
PBU
Residual
Recycling
Organics
Fortnightly
Fortnightly (paper, card,
tetrapak, cans, plastics)
None
€7.50 / lift
€4.00 / lift
-
Westmeath - Residual Fortnightly €8.00 / lift (240l bin)
Wallace Recycling Fortnightly €3.00 / lift
PBU Organics None -
Cork County Residual Fortnightly €120 + €0.46 / kg
Council Recycling Fortnightly -
PBW Organics None -
Cork County - Residual Weekly €418 + €0.162/kg over 400kg/annum
Mr Binman Recycling Weekly -
PBW Organics None -
1279 We may assume for the sake of this analysis a residual waste bulk density of 200kg/m 3 , mixed
recycling excluding glass of 150kg/m 3 and (though of less relevance here) mixed organic waste of
400kg/m 3 .
1280 This clearly does not allow for any link between the nature of the charging system and the quantity
of waste set out. As such, it is an approximation to the actual costs likely to face households.
1037
International Review of Waste Policy: Annexes

The data in the tables above when combined with Table 64-4, shows households
being charged an estimated €220 to €420 per household per annum for alternating
fortnightly collection services. The example weekly waste and recycling collection
services are up to €464 per household per annum. Obviously this cost has to cover
both the collection costs, as well as the processing / recycling / disposal of the
material. We may assume to isolate the collection service provision costs (vehicles,
staff, containers) by simply subtracting the calculated costs of treating / disposing of
the collected material. This calculation is performed in Table 64-5 using a cost for
residual waste disposal of €120/tonne, a cost for sorting mixed recyclables
(excluding glass) of €40/tonne, and (where relevant) for composting mixed biowaste
of €80/tonne. In the case of private sector contractors VAT is payable on disposal
costs. As such, in these instances we account 13.5% VAT on private sector disposal
costs in Table 64-5, but deduct the VAT for the final column.
The evaluated costs in Table 64-5 are particularly revealing. Calculated by deducting
the organic treatment and residual disposal costs (in Table 64-5) from the charges
levied (in Table 64-4), they show a range of costs for collection only (excluding VAT) of
between €113 and €316 per household per annum for an alternating weekly
collection of waste and recyclables, and the one example weekly service over €380
per household per annum.
Such figures are greatly in excess of costs borne by collection services in other
countries. The following section provides some international perspective on waste
management costs.
1038
29/09/09

Table 64-4: Household Annual Collection Cost Estimates
County County, County , Serv Service Serv
ice ice Provider;
Collection Collection
Collection Annual Annual
Annual Estima
Estima kg/
litres/
litres/ Estimated Estimated
Estimated Calculated Calculated
Calculated Total Total
Total
Number of households in county; service
service kerbside
kerbside ted
ted particip
particip wk wk
collection collection
collection charge charge per
per charge
charge
Proportion of total county waste
tonnage
tonnage partici
partici ating ating-
ating
requirement
requirement participating
participating /
collected through kerbside services
pation pation
pation hhld/yr
hhld/yr
(rel (relevant (rel (relevant
evant in the
household
household house house-
house
case case of of PBU
PBU
hold hold /
/
charging)
charging)
annum annum
annum
Dublin Dublin City City Council Council / / / Greyhound Greyhound PBU PBU Residual 145,070 88% 912 88 Fortnightly €221
Households: 180,852 Recycling 25,704 88% 162 21 n/a €0
Kerbside as % of total waste: 88% Organics 1,315 3% 242 12 Monthly €24 €245
South South South Tipp Tipp County County Council Council PBU Residual 16,787 74% 862 83 Fortnightly €392
Households: 26,410 Recycling 6,626 74% 340 44
3 in 4 weeks
(for 60l sacks)
€27
Kerbside as % of total waste: 74% Organics 0 0% 0 0 - €0 €419
Westmeath Westmeath - Mulleadys PBW Residual 14,493 71% 874 84 n/a €357
Households: 23,360 Recycling 4,161 71% 251 32 n/a €0
Kerbside as % of total waste: 71% Organics 90 0% 0 0 - €0 €357
Westmeath Westmeath - Mulleadys PBU Residual 14,493 71% 874 84 Fortnightly €195
Households: 23,360 Recycling 4,161 71% 251 32
4 weekly (for
240l bin)
€52
Kerbside as % of total waste: 71% Organics 90 0% 0 0 - €0 €247
Westmeath Westmeath - Wallace PBU Residual 14,493 71% 874 84 Fortnightly €208
Households: 23,360 Recycling 4,161 71% 251 32
4 weekly (for
240l bin)
€39
Kerbside as % of total waste: 71% Organics 90 0% 0 0 - €0 €247
Cork Cork County County Council Council PBW Residual 48,391 67% 686 66 n/a €436
Households: 105,248 Recycling 22,370 67% 317 41 n/a €0
Kerbside as % of total waste: 67% Organics 0 0% 0 0 - €0 €218
Cork Cork County County - Mr Binman PBW PBW Residual 48,391 67% 686 66 n/a €464
Households: 105,248 Recycling 22,370 67% 317 41 n/a €0
Kerbside as % of total waste: 67% Organics 0 0% 0 0 - €0 €464
Note: As opposed to council operated services, private sector contractor costs are liable to (and are shown to include) VAT payable at 13.5%.
1039
International Review of Waste Policy: Annexes

Table 64-5: Breakdown of Costs into Individual Collection Systems
County County, County County , Service
Provider
Provider
1040
29/09/09
Collection Collection service service service kg/
participating-
participating
hhld/yr
hhld/yr
Calculated Calculated
Calculated
residual
residual
disposal disposal, disposal , MRF
sorting sorting and
and
organic
organic
treatment reatment
costs costs / hhld
Dublin City Fortnightly residual 912 €109
Council / Fortnightly recycling 162 €6
Greyhound PBU Fortnightly organics 242 €19
South Tipp CC Fortnightly residual 862 €103
PBU Fortnightly recycling 340 €14
Westmeath – Fortnightly residual 874 €119
Mulleadys PBW Fortnightly recycling 251 €10
Westmeath – Fortnightly residual 874 €119
Mulleadys PBU Fortnightly recycling 251 €10
Westmeath – Fortnightly residual 874 €119
Wallace PBU Fortnightly recycling 251 €10
Cork County Fortnightly residual 686 €82
Council PBW Fortnightly recycling 317 €13
Cork County - Weekly residual 686 €82
Mr Binman PBW Weekly recycling 317 €13
Total Total
Total
organic
organic
treatment treatment &
&
residual residual
residual
disposal
disposal
costs costs / hhld
(excluding (excluding
(excluding
MRF MRF fees)
fees)
Remaining
Remaining
cost cost cost to to cover
cover
collec collection collec collection
tion
expenditure
expenditure
/ / hhld
hhld
(excl (excl VAT)
VAT)
(including
(including
MRF MRF fees fees )
)
€129 €116
€103 €316
€119 €209
€119 €113
€119 €113
€82 €135
€82 €382
Note: Blue figures indicate private sector service providers where VAT (payable at 13.5%) is levied on
waste disposal costs. For consistency, the VAT has been deducted from these private sector costs for
the final column to be comparative with international collection costs as investigated below.
64.3 Comparisons to International Collection Costs
64.3.1 Collection in Wales: Hitting 70% Recycling
The most thorough publicly available report from WRAP on expected costs of kerbside
collections is a recent study for Wales. 1281 For this report, modelling was undertaken
of services designed to deliver up to the country targets of 70% recycling/composting.
Data from this study is compiled in Table 64-6 (some interpretation of the data was
necessary to generate collection costs per household including recycling
income/sorting fees, the figures are calculated based on the data presented in the
report). Here, the collection only costs per tonne from Figure 10 in the WRAP report
(using a relatively generous £1 to €1.33 exchange rate) together with yields and gate
fee data suggests that a commingled fortnightly bin recycling service alongside a
fortnightly refuse collection ought to be deliverable at a maximum collection cost of
€73 per household per annum. The systems modelled here are somewhat more
comprehensive to the Ireland alternating fortnightly collections and yet they again are
much lower than the Ireland costs evaluated for Table 64-5.
1281 Priestley-Leach, O,, Bragg, J (2009) Kerbside recycling in Wales: Indicative Financial Costs, WRAP,
March 2009

Table 64-6: Interpretation of WRAP Report Data and Calculations to Determine Comparative Collection Costs
WRAP WRAP modelled
modelled
data data data for for Wales Wales
Wales
System description
Collection only cost
per tonne (£)
Collection only cost
per tonne (€)
Yield: kerbside
recyclables + food
waste (kg/hhld/yr)
Yield: kerbside
recyclables only
(kg/hhld/yr)
Total kerbside
collected waste
(kg/hhld/yr)
Total collection cost
per household
(all services)
excluding recycling
fees / revenues
Total collection cost
per household
(all services)
including recycling
fees / revenues
1041
Single Single stream
stream
fortnightly fortnightly recycling
recycling
Fortnightly
recycling RCV +
food waste pod.
Fortnightly residual
RCV + food pod.
210
(MRF fees =
£33/tonne)
International Review of Waste Policy: Annexes
Single Single stream
stream
weekly weekly recycling
recycling
Weekly recycling +
food waste pod.
Weekly residual
RCV.
Kerbside Kerbside sort
sort
stillage stillage vehicle
vehicle
Weekly stillage
vehicle (including
food). Fortnightly
residual RVC.
Kerbside Kerbside Kerbside sort
sort
Labrie Labrie vehicle vehicle
vehicle
Weekly recycling
vehicle with
compaction for
cans/plastic.
Fortnightly residual
RVC.
Two Two stream stream weekly weekly
weekly
recycling
recycling
Weekly recycling
/food spit RCV.
Fortnightly residual
RCV.
Two Two stream
stream
fortnightly fortnightly fortnightly recycling
recycling
Fortnightly
recycling /food spit
RCV. Fortnightly
food mini-RCV.
Fortnightly residual
RCV.
£58 £52 £59 £57 £57 £50
€77 €69 €78 €76 €76 €67
372 372 377 377 384 384
210
(MRF fees =
£33/tonne)
181
(income calculated
from figures in
report to average
£62/tonne)
181
(income calculated
from figures in
report to average
£62/tonne)
210
(zero cost for
containers, £7/t
income for fibres)
210
(zero cost for
containers, £7/t
income for fibres)
926 926 926 926 926 926
€71 €64 €73 €70 €70 €62
€81 €73 €58 €55 €70 €62

The kerbside sort systems shown in the Table, which suggest a lower cost, are not so
relevant in the current context as few if any are currently operated in Ireland.
Nevertheless, they are of relevance more generally. International experience, indeed,
including from Northern Ireland, shows that kerbside sort approaches can be
particularly cost competitive on collection costs alone. The particular advantage they
hold is that since material is segregated at collection, it can be sold direct to recovery
markets rather than incurring sorting costs. Issues of contamination and rejects are
also largely avoided.
64.3.2 Collection in Eden District Council, England
The collection services operated in Eden District Council are interesting to compare to
the situation in Ireland. Throughout the review we have undertaken, it has been
argued that Ireland is in some way ‘unique’, and that as a result, the collection
systems in place in other countries might not be transferable to the Irish context. One
of the arguments advanced in support of Ireland’s ‘uniqueness’ is its low population
density. Clearly, though, the majority of countries have both urban and rural areas,
and few are uniquely composed of one or the other.
Eden is the least densely populated local authority in England, with a population of 23
persons per square kilometre. The average population density across the Republic of
Ireland as a whole stands at 60/km 2 , with a range from Dublin City at 4,304/km 2 , to
Leitrim at 18/km 2 and Mayo 22/km 2 . As such it may be fair to parallel Eden with the
more remote areas of Ireland. 1282
The services operated in Eden are a weekly sack based collection of refuse from all
24,000 households, fortnightly kerbside sort collection of dry recyclable materials
(paper, cans and glass) from 15,000 households, and a fortnightly (4-weekly in
winter) collection of garden waste from 15,000 households using wheeled bins.
Data from Eden’s revised waste management strategy gives detail on the costs paid
to collection contractors for the separate collection systems in operation. The figure of
£158,000 is quoted for a fortnightly kerbside sort collection operation provided to
15,839 households in the district. Using an exchange rate of £1.33 to €1, this
equates to a collection service cost of €13 per household per annum.
We have specific insight into the collection systems operated in Eden having
conducted detailed cost modelling in a WRAP-funded study, for the authority, of the
existing and potential replacement collection systems in the district. Our proprietary
collection cost model, Hermes, has to date been used to model collection systems for
around 25% of local authorities in the UK, frequently in the context of local authority
business cases and procurements, and sometimes used with contractors
interrogating the model, giving us some confidence in the costs and performance of a
vast range of different collection systems operated in different environments.
The baseline service in Eden includes:
1282 http://www.cso.ie/newsevents/pr_census2006vol1.htm
1042
29/09/09

1043
� Refuse collected weekly in sacks (all households);
� Free garden waste collection is provided to some (not all) households; and
� Dry recyclables are collected from some (not all) households.
The total collection cost for all kerbside collection services in Eden was evaluated to
be €67 per household per annum.
In assessing the potential cost of alternative services five options were assessed (in
each case all services were offered to all households).
Option Option 1 1 1 – Weekly Weekly collection collection of of food food waste waste using using a a a sep separate sep arate pass single single operative
operative
vehicle. vehicle.
vehicle.
Option Option Option 1 1 1 Sensitivity Sensitivity Sensitivity Analysis Analysis
Analysis
Option Option 2 2 – Fortnightly Fortnightly co co-mingled co mingled collection collection of of food food and and garden garden waste waste using using RCVs RCVs 1283
Option Option Option 3 3 3 – Co Co-collection Co collection collection of of food food waste waste with with dry recyclables recyclables one one week week week and and and a a separate separate
separate
pass pass pass single single single operative operative operative vehicle vehicle on on the the alternate alternate week. week. week. Card Card Card to to to be be be added added added to to the the
fortnightly fortnightly fortnightly garden garden garden waste waste waste collection. collection.
collection.
Option Option Option 4 4 4 – Co Co-collection Co collection collection of of of residual residual residual and and and food food food waste waste waste in in in split split split bodied bodied bodied vehicles. vehicles.
vehicles.
The results of the modelling are shown below relative to an ‘Intermediate Baseline’
where the dry recyclables services modelled in the Options are made the same as
those where biowaste collections are added.
It can be seen that the total system costs can show a drop, particularly under the ‘B’
scenarios. In the A scenarios, the refuse collection remains on a weekly basis (in
sacks) whilst in the B scenarios, refuse is collected fortnightly in bins. This saving –
associated with reduced costs of collection – along with the avoided costs of
disposal, more than offset the increase in cost for providing the additional biowaste
collection and the treatment of biowaste.
1283 RCVs would need to be suitable for the collection of mixed food and garden wastes – the
additional liquid in the food waste may require minor modifications to be specified.
International Review of Waste Policy: Annexes
1283.

Table 64-7: Additional Cost per Household (relative to Intermediate Baseline)
-£10
1044
£20
£15
£10
£5
£-
-£5
29/09/09
Option
1A
Option
1B
Option
2A
Option
2B
Option
3A
Option
3B
Option
3C
Option
4A
Option
4B
Option
1A/k
Option
1A/c
Source: Eunomia (2007) Cost & Performance Modelling of Kerbside Collection Options, Report to Eden
District Council supported by WRAP.
64.3.3 Collection in Ballymoney & Coleraine Borough Councils, Northern
Ireland
We have also carried out collection modelling for two borough councils in Northern
Ireland which have particular relevance when comparing to the Republic of Ireland
(ROI). In these cases, both authorities were operating an alternating fortnightly
collection of waste and recyclables (paper, card, plastic bottles and cans) – the same
as the typical ROI system. Full details on the services were provided to allow us to
model the existing systems and compare against alternate collection options in order
to advise on collection strategies.
For purposes here we extract the relevant data on the existing services direct from
the modelling and convert to Euros. The results which are comparable to the figures
for the ROI in the rest of the report are shown in Table 64-8.
Table 64-8: Data Extracted from Collection Modelling for Northern Ireland Authorities
Ballymoney Ballymoney Ballymoney
Coleraine Coleraine
Coleraine
Average vehicle crewing level Driver plus 1 Driver plus 2
Households served / vehicle / day 706 890
Number of unloads / vehicle / day
1 (recycling)
2 (residual)
1 (recycling)
2 (residual)
Calculated total collection cost per household
per annum (staff, vehicles, fuel, etc.)
€54 €55
Recycling, kg/household/year 119 108
Residual waste collected, kg/household/year 599 611

The nature of these authorities themselves is also worth some consideration.
Ballymoney Borough Council is a predominantly rural authority with 27,000 residents
and a population density of 70 people per square kilometre. Approximately one third
of the population live in Ballymoney town. Coleraine Borough Council, an important
tourist destination has a somewhat seasonal population of around 56,000, a
population density of 115 people per square kilometre and over 40% of residents
living within the town of Coleraine. Although these districts may be fairly
representative of the general topography of the ROI, they have untypically small
administrative boundary areas.
The issue this presents, particularly in the Ballymoney case, is that only a very small
number of collection vehicles are required. As such, they tend to be less efficiently
utilised. Ballymoney, using just two vehicles for recycling and two for residual waste,
operate only eight and a half days each fortnight. Coupled with short working days we
calculated the redundancy to be around 25% of a standard (5 day) working week. In a
larger authority this redundancy would be reduced by more accurately matching the
collection requirements to the vehicle provision (and consequently reducing collection
costs). However, in this case Ballymoney is able to keep costs lower than they would
otherwise be by using an average crew size of driver plus one on its collection rounds.
Matching crew sizes to the demands of the collection round is a useful means of
keeping costs in check.
The leading option modelled for this work in both the Ballymoney and Coleraine
studies was an option with food waste and dry recyclables both collected weekly and
sorted at the kerbside onto stillage vehicles. Residual waste was kept as a fortnightly
service to best maintain (in the absence of charging for waste, which is still not an
option in the UK) an incentive to recycle and reduce costs of refuse collection. In
these cases the figures extracted from the model are as follows:
1045
� Ballymoney: €90 per household per year (total collection cost);
� Coleraine: €83 per household per year (total collection cost);
In terms of whole system costs (in other words, the costs of provision of the totals
service, including costs for sorting, treatment and disposal), the figures were:
� Ballymoney: €170 per household per year (total system cost);
� Coleraine: €147 per household per year (total system cost);
In other words, the cost of systems inclusive of a weekly food waste collection are
considerably lower than the average charge in Ireland for a system providing dry
recyclables only. It is not possible to explain these differences through reference to
specific input factors alone, as we shall see below. 1284
1284 See Eunomia (2008) Ballymoney & Coleraine Borough Councils Kerbside Collection Appraisal and
Modelling Report, Report for WRAP.
International Review of Waste Policy: Annexes

64.4 Collection Costs in England
Until recently, all local authorities in England were required to report information on
collection costs to the Audit Commission. These figures were often subject to
inconsistencies in reporting and different authorities were often reporting systems
with quite different levels of service provision (in terms of, for example, the scope and
quality of recycling services). Even so, it is noteworthy that the costs of collection in
the year 2005/6, when many authorities were operating recycling services, and when
organic waste collections were on the increase, lay between €30 and €80 per
household, with the vast majority lying between €40-€60 per household (the very
lowest figures would have probably related to authorities offering only refuse
collections). 1285
Figure 64-1: Collection Costs (£ per household) for English Local Authorities
Cumulative Number of Authorities
1046
313
300
287
274
261
248
235
222
209
196
183
170
157
144
131
118
105
92
79
66
53
40
27
14
1
29/09/09
0.00 20.00 40.00 60.00 80.00 100.00 120.00 140.00
Source: Audit Commission
Collection Cost per hhld (€/hhld)
1285 In 2005/6, the recycling rate for household waste in England was 27%, more or less the same as
in Ireland in 2007, suggesting a broadly similar service mix, though with the absence of PBU in England
suppressing performance relative to the systems on offer.

64.5 Collection Modelling for Ireland: Assessment of Current and
Potentially Achievable Collection Costs and Resulting
Annual Charge Levels
Although the assessment conducted in the previous sections establishes that
collections in Ireland are particularly expensive compared to international experience,
the full reasoning for this has not yet been explored. Data provided by a collection
company operating in Ireland provides a particular insight. 1286
The cost of collecting waste from households is strongly influenced by the number of
households the collection vehicles can serve each working day; the lower the number
of households, the more vehicles (and crew) are needed to perform the service. The
key detail in the data provided is the quote “The typical number of homes serviced in
a single shift using a standard truck is 300.” Even in Eden, with its low (including by
Irish standards) population density, the residual waste collection vehicles average
700 households per day on a collection route. In a more typical situation in the UK we
would expect wheeled bin residual waste collection services to achieve pass rates of
the order 1,200, with ranges from around 900 to 1,300 households depending on
the rural/urban nature of the local authority. Daily pass rates in urban settings can be
above 2,000 where the collections are entirely sack based.
It is difficult to understand how conditions could so severely limit collections in the
Ireland context to just 300 collections per day; there is no reason for transport
logistics to be significantly different from the broad range of conditions faced in the
UK (and certainly, the Irish average would not give rise to lower pass rates than in,
say, Eden). One possible issue leading to this situation may be the free market
approach to collection whereby collection densities are severely reduced.
Using the Hermes collection model we attempted to model a collection system
achieving just 300 collections per day. The model is populated with the combined
experience of benchmarked collection data provided by industry collection operators
from a considerable number UK authorities. Frequently, we have made use of the
model in a fully transparent mode with a collection contractor watching over us.
We have assumed that collection crews in Ireland have similar working practices
(work time per day for example), and that logistics are broadly similar to the most
challenging of those in the UK (Eden as a specific example). We have, however,
adjusted the parameters in the model to account for the low levels of subscription to
the services in the Ireland context by increasing the effective distance between
households served (representing a lower route density). A pick up rate of 300 was
modelled by assuming poor transport logistics and one in 5 households subscribing to
the service. Even so, a very high collection time per property also needed to be
modelled to deliver the costs which had been presented. This may be associated with
the fact that a low collection density will mean collection crews are forced to
frequently get in and out of the cab between pick-ups to get to the next collection
1286 Greenstar (2009), The Economics of Brown Bin Domestic Waste Collection in an Irish Context
1047
International Review of Waste Policy: Annexes

point, rather than working on foot from house to house alongside the slowly
progressing vehicle.
As a comparator to the system with a pass rate of 300 households per day, we
modelled an alternative option whereby all households on the collection route utilised
the collection system. Effectively, this gives a comparison between the two situations
of “Competition in the market” (collecting from one in 5 households) and
“Competition for for the market” (collection from all households). In other words, in the
model we assumed to increase the number of households setting out bins in any one
street by a factor of 5. This leads to much greater numbers of households served by
each vehicle each day. Headline results are shown in Table 64-9.
These figures correlate well with the examples provided from Northern Ireland in
Section 64.3.3 of the Annexes. They show that the simple fortnightly collection service
is achievable at a little over €50 per household per year. The more rapid collection
operation when collecting from house to house will also be better utilising the driver
plus two staffing levels on the vehicles.
Table 64-9: Current Approach to Collection in Ireland compared to a Single Collection
Operator (Hermes Collection Modelling)
Competition Competition in in the
the Competition Competition for
for
market
market
the the market market
market
Vehicle crewing level Driver plus 2 Driver plus 2
Percentage incidence of single bin emptyings 80% 30%
Percentage incidence of two bin emptyings 20% 70%
Households served / vehicle / day
300
(for either recycling or
residual collections)
862 (recycling)
748 (residual –
more restricted by
weight capacity)
Number of unloads / vehicle / day 1 2
Collection costs per household per annum
quoted in the Irish data
€137 -
Calculated collection cost per household per
annum (staff, vehicles, fuel, etc.)
Calculated collection cost per household per
€134 €52
annum (staff, vehicles, fuel, etc.) plus
recycling gate fees
€157 €75
64.6 Costs of Adding in ‘Brown Bin’ Collections
A more thorough service including weekly food waste collection may be expected to
significantly increase the total capture of materials for recycling, and without
increasing the quantity of waste collected. Disposal costs will also be reduced. As
such, as long as the costs of treatment of the collected food waste lie below those of
treating or disposing of residual waste, then the avoided disposal cost savings will
help to fund the provision of such services. Furthermore, the introduction of food
waste collection services allows for a reduction in frequency of residual waste
collections. This is extremely important.
In Ireland, there has been much made of the contrast between weight-based systems
and other forms of PBU charging. This has been motivated, in part, by a desire to
understand the performance drivers for better performing systems. What this tends to
1048
29/09/09

ignore, however, is that whilst costs are affected by the fate of materials in terms of
their management (recycling, biowaste treatment, residual waste treatment /
disposal), the system costs are also influenced by the costs of collection. In this
regard, a key feature of collection systems which target the most putrescible element
- food waste – is that it allows for a reduction in the frequency with which households
set out refuse for collection. This leads to reduced set out rates, with high quantities
per set out, allowing for re-optimisation of logistics. Hence, frequency based charging
systems which allow households to choose when to set out waste (as opposed to
those which imply a subscription for a specified frequency – these have limited effect
on behaviour at the margin) have an important role to play in optimising the costs of
collection logistics. It should be noted that whilst many municipalities charge only on
the basis of frequency, some charge on the basis of frequency and weight, which
combined an incentive to reduce set out (improving collection logistics) with an
incentive to generate less residual (and other charge-for fractions of) waste.
In Table 64-10, we show how the costs of the modelled service (as described above)
would change when a dedicated weekly collection of food waste is added to the
existing service. It can be seen that the increase in cost per household is relatively
small, with higher collection costs offset by reduced costs for treatment and disposal.
Table 64-10: Current Approach to Collection in Ireland compared to a Single
Collection Operator (Hermes Collection Modelling)
Competition ompetition for for the
the Competition Competition for
for
market
market
the the market market plus
weekly weekly food food food waste
waste
collection
collection
Vehicle crewing level Driver plus 2 Driver plus 2
Percentage incidence of single bin emptyings 30% 30%
Percentage incidence of two bin emptyings 70% 70%
Households served / vehicle / day
862 (recycling)
748 (residual – more
restricted by weight
capacity)
824 (recycling)
742 (residual)
1046 (food waste
– only unloading
once per day)
Calculated collection cost per household per
annum (staff, vehicles, fuel, etc.)
Calculated collection cost per household per
€52 €64
annum (staff, vehicles, fuel, etc.) plus
recycling gate fees
€75 €87
Total net collection treatment and disposal
cost per household per annum*
€199 €204
*Assumes MRF gate fee €40/tonne, organic treatment €80/tonne, residual waste €120/tonne
It should be noted that:
1049
1. The above analysis assumes no change in the frequency of refuse collection. If
such changes occurred, costs ought to fall as round logistics are re-optimised;
and
2. The above analysis assumes no change in the costs as the costs of residual
waste treatment / disposal increase, so the collection costs will remain
unchanged, but the costs of dealing with the collected residual waste increase.
International Review of Waste Policy: Annexes

1050
29/09/09
Hence, the effects of an increased landfill levy would be expected to move the
balance in favour of the system which sends less material to landfill.
If such possibilities were factored in, the financial argument would shift more in
favour of the system which includes the collection of food waste on a weekly basis.
64.7 Summary
It is true that Ireland is an expensive country. However, in reviewing existing
household collection costs, the following seems to be the case:
� The existing costs of services to householders are well above what they should
be. This is clear from comparing costs with Ireland’s nearest neighbour, and
when modelling collection systems using Irish input costs;
� Even without considering other changes, then other things being equal, by
simply moving to a ‘competition for the market’ approach, it ought to be
possible to save around €80 per household per year on average, more in
some case, less in others, on the costs which households are charged. This is
a significant saving to Irish households and would be expected to have
beneficial economic consequences far beyond the saving itself; and
� The costs of adding biowaste to existing collection systems are likely to be
relatively small, especially if food waste is well targeted, and households have
an incentive to reduce set out frequencies for refuse.
If the landfill levy increases, and if levies on other residual waste treatments are
applied, then the costs of options which increase the scope for recycling and
composting / digestion are likely to decline relative to the situation where no change
occurs. Under such a scenario, the inclusion of biowaste collections is likely to
become the cost-minimising solution. The only exceptions to this rule would be where
one or more of the following apply:
a) collection systems were poorly optimised
b) services were procured inefficiently; and / or
c) the cost of biowaste treatment relative to residual waste treatment /
disposal is small. The prospects for this seem likely to be increasingly
limited in future if the landfill levy is changed in line with what is
proposed in the Main Report (see Annex 56.0).