FEAD’s feedback on the 2027 Early Warning Report on Waste

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe welcomes the objective of the Early Warning Report (EWR) drawn up by the Commission to assess Member States’ progress towards reaching: (i) the 2030 recycling targets for municipal waste and packaging waste; (ii) the waste food reduction targets for food and packaging waste and; (iii) the 2035 landfill target.

FEAD supports the objectives of the EWR in assessing Member States’ progress towards reaching the targets in question and providing targeted recommendations for Member States to improve their waste management performance, including by sharing best practice.

FEAD would like to take this opportunity to emphasise key aspects and challenges faced by waste management companies at the EU and national levels.  

FEAD general recommendations

Significant disparities remain between Member States regarding recycling performance, collection infrastructure, and treatment capacities. Several countries are still heavily reliant on landfilling and risk missing the 2035 landfill diversion target (a maximum of 10% landfilled) as well as the 2030 recycling targets.

FEAD would like to take this opportunity to provide key recommendations requiring concrete action based on the challenges faced by the waste management companies in Europe:

1. A stronger market and boosted demand for recycled materials

Increased demand for the secondary raw materials has been identified as a key priority in increasing recycling rates and creating a strong market for recycled materials. To boost the demand for secondary raw materials, a level playing field and fair competition with the virgin and imported materials at an EU level must be ensured. This can be achieved through several policy instruments:

• mandatory recycled content targets (focused only on post-consumer waste);
• circular criteria in (green) public procurement;
• EU-wide harmonised end-of-waste criteria to create a functioning single market;
• incentivising use of compost and digestate from biowaste in agriculture; and
• targeted tax incentives for products with recycled content.

2. Better separate collection at source, especially biowaste

In reaching the 2030 recycling target for municipal and packaging waste, insufficient separate collection – especially of biowaste – was identified as one of the main bottlenecks, leading to high contamination of recyclable materials and greater pressure on sorting facilities. Considering that from January 2027 onwards, biostabilized materials from MBT plants derived from the residual fraction will no longer count towards the recycling targets, unless separated, the reported rates will be affected. Despite mandatory separate collection of biowaste, performance differs widely between and within Member States. To improve separate collection, we propose the following measures:

• strengthening the role of and enforcing rules on local municipalities in monitoring and enforcing compliance with separate collection requirements among households and businesses;
• targeted strategy by local municipalities on raising awareness and providing clearer and targeted guidance and feedback to citizens and businesses e.g. door-to-door collection or closed or smart containers for biowaste;
• “one size does not fit all”: collection systems must be adapted to local housing conditions, balancing the degree and ways of source separation and separate collection;
• economic incentives such as pay-as-you-throw schemes, with lower charges for recyclables and biowaste than for residual waste can help but need case-by-case assessment;
• better implementation of existing measures by national authorities to ensure that waste producers comply with sorting requirements, while avoiding enforcement that could lead to illegal dumping.

3. Increased investment and support for sorting, recycling and treatment infrastructure

Many of the Member States have identified significant gaps in waste management and recycling infrastructure needed to increase the quantity and quality of recovered materials. To close the gaps, several measures should be implemented including, but not limited to:

• targeted investment to address regional imbalances in treatment capacity;
• investment in advanced technologies for sorting of municipal waste;
• protecting existing capacity and minimising additional costs related to incorrect disposal of waste in the wrong stream (e.g. battery fires in waste facilities);
• long-term regulatory certainty and predictability for investment in the waste and recycling sectors;
• public support schemes and state aid; streamlining permitting procedures.

4. More effective EPR schemes and eco-design

EPR schemes are often underfunded, with producer fees too low to cover the full costs of managing waste. Unclear responsibilities along the value chain also cause delays and storage bottlenecks for separately collected waste. At the same time, too many products that cannot be recycled still enter the waste stream. To make EPR more effective and tackle the problem at its source, the following measures were recommended:

• full and timely coverage of costs by producers, in line with the Waste Framework Directive and the PPWR;
• clear allocation of responsibilities, and better coordination between municipalities, waste operators and EPR schemes;
• detailed EPR fees that reward recyclable design;
• inclusion of mandatory European recycled content targets in the eco-design requirements
• producer responsibility, including take-back by retailers, for products that are not designed to last and cannot be recycled.

5. Energy recovery / Waste-to-Energy recognised as complementary for non-recyclable residues

Without enough capacity for incineration with energy recovery, non-recyclable residues and sorting rejects end up in landfill by default. Member States leading in recycling rates show that high rates can go hand in hand with strong Waste-to-Energy capacity. To meet the 2035 landfill target, several measures should be implemented including, but not limited to:

• explicitly recognising efficient energy recovery, including co-processing, as complementary to recycling and as part of the route to the 2035 landfill target, under predictable rules;
• integrated waste management planning to ensure appropriate treatment capacity for non-recyclable residues;
• a clear programme to develop and upgrade high-efficiency Waste-to-Energy plants in line with the local waste management plans;
• adapting the EU Taxonomy and the ‘do no significant harm’ principle to ensure needed investments are possible;
• connecting Waste-to-Energy plants to district heating and industrial heat users;
• recognising waste heat from Waste-to-Energy plants also in industrial symbiosis, when the installation directly supplies heat to an end-user, without being connected to a district heating network;
• introducing a harmonised European framework for landfill levies to ensure that, where energy recovery is a realistic alternative, landfilling of non-recyclable residual waste is not the economically more attractive option, while recognising equivalent national measures and avoiding cumulative taxation.

6. Better data and statistics on waste

Many members have raised concerns over the lack of accurate, transparent and harmonised collection and processing of data at an EU level, which has been identified as a major barrier. Eurostat data and statistics are often hard to compare and difficult for stakeholders to understand. Several issues have been noted in the reporting of municipal waste recycling rates and targets.

The 2025 special report on municipal waste management by the European Court of Auditors pointed out the significant discrepancies between Member States in reporting the municipal waste recycling targets, as they were allowed to choose among different calculation methods until 2025. The harmonised (least advantageous) calculation method lowered the reported recycling rates on average by 12 percentage points, making comparison with data prior to 2025 unreliable.

Inconsistent applications of the common EU methodology on municipal waste statistics across EEA countries has been observed. Misclassification of municipal waste can either overstate or understate a country’s performance, as outlined a the recent report looking on statistics in the Nordic countries.

Serious concerns over Eurostat data for energy recovery underpinning the overcapacity claim have arisen among members as well. The data aggregates R1 (energy recovery) capacity across all facility types (including coal plants, biomass, cement kilns, or steel plants) and does not distinguish between municipal waste and other streams. We believe that a more granular approach than the one provided is needed to gather accurate data on capacities for municipal waste treatment.

Listed inconsistencies and the lack of harmonised and accurate data raise concerns over the statistics used for designing effective policies for waste reduction and recycling, and for a comparable and accurate evaluation, such as the EWR, of each country’s success in reaching municipal waste targets.

Country-specific recommendations

Several national waste management associations have provided individual perspective and input on country specific challenges they face and measures they propose for addressing the targets in question.

FRANCE

Several challenges have been identified at national level including high operational costs, an uneven playing field compared to virgin materials or imported low-cost alternatives, high contamination levels of recyclable materials, and insufficient separate collection at source (particularly for biowaste and specific plastics)]. Additionally, potential end-of-pipe financial burdens risk raising costs across the entire value chain, including for recyclers.

These must be tackled at source through eco-design, standardized packaging formats, and granular EPR fee structures. Transferring financial and design responsibility to manufacturers ensures better recyclability and reduces non-recyclable fractions before they enter the waste stream. To bridge the cost gap, targeted policy instruments—such as mandatory recycled content targets, green public procurement criteria, and reduced VAT for circular products—should be deployed.

GERMANY

Germany is at ‘no risk’ of missing the 2030 municipal waste recycling target (around 68%) and the landfill target (at less than 1%) and it attributes its success to clear framework conditions with realistic transition periods: the ban on landfilling untreated municipal waste which led to a fundamental modernisation of waste treatment. It must be noted that the German Circular Economy Act and national statistics largely measure waste entering recycling facilities rather than material returned to the economy. National members identified several areas experiencing challenges in the sector:

• waste prevention: identified as the weakest area at a national level (577 kg of municipal waste in 2023 p.p.). To reach the national target of a 10% reduction by 2030, around 25 kg per inhabitant still need to be avoided;
• collection: large regional differences in separate collection rates – especially bio-waste, stronger implementation measures by public waste management authorities;
• sorting: the heterogeneity of lightweight packaging makes separation difficult (around 30% of the material collected consists of missorted items, battery-related fires in waste management facilities;
• recycling: key barriers are economic and regulatory – unfair competition of recyclates with virgin material and cheaper imports, lack of sales markets (e.g. for green glass cullet), lack of practicable end-of-waste rules, long and costly permitting procedures, uncertain framework conditions undermining investment security and lack of demand shown in public procurement.

Measures proposed at a national level:

• stronger enforcement of rules on separate collection of bio-waste: mandatory bio-waste bin in all districts and cities, utilising sensor-based detection of missorted items to increase the quality of collection;
• enforcement of the obligation to separate waste should focus more on waste producers in the commercial sector;
• Increase of number and quality of container sites for glass;
• fee models combining a basic and a performance-based fee to create incentives for waste prevention and separation while ensuring stable financing.

IRELAND

Ireland is on course to reach the 2035 landfill target due to the expected closure of one of its three landfills in the next 15 months, a planning system that does not allow new landfill capacity and the export of waste for Waste-to-Energy (WtE). Recent progress in the recycling rate has been observed. However, reaching the 2030 municipal waste recycling target is described as difficult. National strategy Is geared more towards lower waste generation rather than higher recycling rates by implementing direct charges to waste generators for every municipal waste stream, strict monitoring and tracing of the waste collected by private companies, a targeted public awareness campaign aimed at costumers not following the measures and the application of Contamination Detection System (CDS) technology in private waste facilities.

Key challenges in achieving the recycling targets include, but are not limited to:

• increased complexities in the export of waste for WtE operations;
• lack of public awareness when it comes to waste separation practices: non-target materials in the mixed-dry-recyclables bins, under-utilisation of the biowaste bins and the amount of recyclable and biowaste materials in the residual waste bins;
• data sharing and inconsistencies between private waste facilities and national bodies;
• under-funding by the EPR schemes for packaging, WEEE and batteries;
• poor quality of wood waste hindering its recycling and diversion towards biomass;
• battery fires at our transfer stations and Materials Recovery Facilities;
• incorrect labelling (coding) of municipal solid waste (MSW) and non-municipal waste leading to over-estimated MSW generation and under-estimated MSW recycling in Ireland.
  
  

Measures proposed at a national level:

• a targeted strategy of public engagement in source separation – cited as a key priority in the national and local strategy – developed with a “one size does not fit all” approach;
• reinforcement of the existing collection and sorting practices for the household
  municipal waste by introducing additional ‘on the go’ recycling bins on the streets; 
• application of CDS technology in the form of cameras mounted on the back of refuse collection vehicles across all waste management facilities;
• introducing greater responsibility for producers of medium-density fibreboard and similar products that are not designed to last and are non-recyclable at the end of their life: take-back policies for poorly designed materials.

ITALY

Italy is in a comparatively favourable position and is not considered ‘at risk’ for reaching the 2030/2035 targets depending on maintaining and strengthening recycling capacity and, ensuring sufficient and stable demand for recycled materials. A significant progress has been achieved in recent years; however, several implementation challenges remain that may hinder the achievement of future waste prevention, recycling and landfill diversion targets:

• weak and unstable demand for recycled materials and secondary raw materials, particularly in sectors such as plastics;
• persistent territorial disparities in the performance of separate collection;
• quality issues in separately collected waste streams, particularly due to contamination, which reduces sorting and recycling efficiency;
• insufficient recognition, within EU and national monitoring frameworks, of the full environmental benefits that recycling generates.
• insufficient integration of waste prevention principles into product design, production and consumption patterns, limiting opportunities to reduce waste generation at source and extend product lifetimes;
• operational challenges linked to EPR schemes, including delays by Producer Responsibility Organisations (PROs) in the collection and take-back of separately collected materials;
• increasing complexity of waste streams, particularly composite, multi-material and difficult-to-recycle materials, which generate significant residual fractions during sorting and recycling processes;
• insufficient and unevenly distributed recycling and treatment infrastructure, combined with lengthy permitting procedures, local opposition and regulatory uncertainty, which may delay investments needed to meet future targets;
• challenges related to achieving landfill diversion targets, due to limited treatment capacity for non-recyclable residues generated during sorting and recycling processes; gaps in efficient Waste-to-Energy capacity limit the availability of alternatives to landfill for non-recyclable residual waste.
• high cost of residual treatments, that might have an impact on the cost of the entire system, including recycling.

high cost of residual treatments, that might have an impact on the cost of the entire system, including recycling.

Several measures have been suggested in order to tackle the outlined challenges:

• increasing demand for recycled materials through procurement policies and market-based incentives, including targeted fiscal incentives for products containing certified recycled materials;
• better data collection and reporting and early corrective actions where performance gaps emerge (e.g. a lack of a market for plastic recyclates);
• reducing territorial imbalances in recycling and waste treatment capacity;
• establishing a clear programme for developing and upgrading efficient Waste-to-Energy plants where residual waste treatment capacity is insufficient;
• promoting the integration of Waste-to-Energy plants with district heating networks and industrial heat users, where local conditions allow;
• strengthening coordination between municipalities, waste operators and EPR schemes to prevent storage bottlenecks and ensure the efficient management of separately collected materials.

NETHERLANDS

The Netherlands is not considered ‘at risk’ of missing the 2030 recycling and 2035 landfill targets. Reported measures leading to substantial progress are landfill bans coupled with appropriate treatment capacity, consistent enforcement and a predictable investment framework. These measures helped redirect waste towards recycling, biological treatment and energy recovery, while substantially reducing methane emissions. The Dutch Waste Management Association (DWMA) calls for more investment security in next level sustainable investments, through a fiscal and waste implementation level playing field, preventing waste that can be recycled and recovered from being landfilled.

DWMA therefore encourages the Commission to make accelerated and harmonised implementation of the Landfill Directive a central recommendation of the Early Warning Report.

NORWAY

According to the national waste plan Norway (2023) reported a municipal waste recycling rate of 43 % (46 % for household waste and 38 % for commercial waste). However, it is not clear from the plan whether the recycling rate has increased to 46 % overall for 2024. The 2025 targets for packaging waste have all been reached, except for plastic packaging, where the reported rate for 2024 is 19% below the target for 2025.

Several specific economic, regulatory and monitoring measures are proposed to improve the progress towards the recycling targets:

• better support schemes (public and state aid) which are targeted at the circular economy such as industrial facilities that boost sorting and recycling;
• well-functioning markets for recycled raw materials;
• regulatory predictability and security;
• putting weight on circular solution in public procurements;
• simplification of procedures and requirements regarding the transboundary movement of waste;
• establishing European requirements for new products to contain a certain proportion of recycled materials, on a product-by-product basis; and
• improved enforcement by national authorities to ensure that waste generators comply with waste-sorting requirements.

ROMANIA

The national waste management plan 2026-2035 (PNGD) states that, without faster investment and uniform application of separate collection obligations, the national and EU recycling and landfill targets cannot be met under current conditions. The national waste management sector emphasises several implementation challenges:

• poor practices in separate collection of waste: insufficient enforcement of pay-as-you-throw schemes and waste sorting rules by local authorities, with waste operators being penalised for non-compliance and other factors beyond their control;
• unbalanced tariff rules hindering waste operators’ investment: tariffs based on outdated waste quantities that no longer reflect real costs, excessive administrative burden on local authorities in calculating and implementing tariffs, and lengthy approval procedures requiring local authority authorisation for every tariff adjustment;
• lack of treatment capacity and lack of technical rules at national level for compost;
• delayed integration of energy recovery into the national strategy: planned investments would bring landfilling down to only about 20%. Energy recovery covered only about 7% of municipal waste in 2022; and
• lack of precise, current and harmonised data and monitoring at an EU and national level in calculating separate collection targets, landfill charges and waste quantities.

To increase the municipal waste recycling rate and reduce the landfill rate, several specific measures have been identified:

• increasing responsibility at the local municipality level regarding separate collection;
• no longer penalising operators for underperformance, given that many of the underlying causes lie beyond their sphere of influence;
• enforcement by the local and national authorities on correct household sorting and disposal of waste;
• introducing automatic tariff adjustments based on an index reflecting actual cost drivers (e.g. fuel, electricity and labour costs), without requiring individual approval from local authorities for each adjustment;
• requiring financial guarantees from municipal associations and EPR organisations, matching those that operators must provide;
• updating the affordability rule for household bills;
• more effective EPR schemes (in addition to the general measures): a uniform calculation method, more transparent data, a dispute settlement procedure and funding for deposit-return packaging that ends up in municipal waste;
• energy recovery: the need for an earlier adoption of the national strategy (end of 2026 instead of 2028) and transitional rules for waste-derived fuels in the meantime –  quality standards, end-of-waste criteria, temporary storage tied to a recovery contract, and access to district heating;
• utilising existing co-processing in cement plants and existing private capacity before planning new public plants and;
• improved conditions for biowaste collection and processing: setting up technical rules for compost, introducing limits on impurities gradually and without automatic penalties for collectors and requiring certified compostable bags that treatment plants accept;
• improved monitoring, financing and enforcement of measures on waste generators instead of placing contractual obligations for waste operators, who only handle waste once it has been generated;
• adopting the national waste plan, which is a condition for EU funding of waste infrastructure: including the sector’s requested corrections on indicators, energy recovery and cost of the service, consulting the sector prior to changing the relevant legislation, base monitoring on operators’ weighbridge data, and using landfill charge revenue for collection and treatment infrastructure.

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be