With the approval of the revised waste legislation within the European Union in July 2018, the 27 Member States had a period of 2 years, so until July 2020, to transpose the Waste Framework Directive (WFD) and the Packaging and Packaging Waste Directive (PPWD) into national legislation.
This period of 24 months was a very ambitious deadline from the very beginning as the new Directives introduced not only several quantitative changes (like increased recycling targets, for example to increase the minimum recycling target for plastic packaging from 22.5% to 50% in 2025) but also many qualitative changes just to name the change in the way how to measure the recycling performance and to introduce minimum requirements for applying Extended Producer Responsibility (EPR). For some of the qualitative changes the European Commission has been mandated to issue Implementing Acts (IA) which become immediately also national legislation but for many others, the EC should issue guidelines to help Member States to make the transposition into national legislation in a harmonized way.
Whereas the IA for the new measuring point has been published in the meantime, the guidelines for certain minimum requirements for EPR like “eco modulation” of EPR fees, which costs are necessary and dealing with online sales are still missing.
So, it is not of a surprise that only few Member States have already transposed the new legislation into national law; most of those who have reported some transposition to the EC have only implemented parts of the new legislation.
On top, our member states have to implement the so-called Single Use Plastic Directives (SUPD) until July 2021 which has severe and drastic impacts to the national implementation of the PPWD as well. Also, for the SUPD, the EC has been mandated also to issue several IAs and various guidelines, inter alia to clarify the scope of Directive and to outline how the costs for litter cleanup should be determined and calculated.
Finally, the EC has started again to revise the PPWD and is spending huge resources on this project, again with drastic impact to our national EPR systems such as restrictions and bans on the use of certain packaging are prepared and minimum recycled content target for several packaging items.
Our national governments will have to design from all these various pieces of European legislation a comprehensive and senseful national waste management system which our obliged national industries and their EPR systems together with our local authorities have to bring in a convenient way to our inhabitants.
So, a real prove that we all have to engage in the European discussion to ensure that all of this makes finally sense for our societies!