European Wastes: A Not So Perfect Union

Maggie Thurgood

Many Americans describe Europe as one country, with only one approach to waste management (see chart). In actuality, this thinking could not be further from the truth.

For comparison, when the U.S. EPA issues an environmental standard, each state vies with its neighbors in a power struggle to introduce even stricter limits. This competition is comparable to that among European Union (EU) member states.

All 15 EU member states are collectively bound by several pieces of legislation on waste management (see "Regulating EU's Waste" on page 26). These directives require each country to meet certain standards by specific dates, but in most cases do not detail how to arrive at those standards. These framework directives make it possible for each country to pursue markedly different policies.

Despite the directives' intent to bring conformity, waste management policies, methods and standards vary across Europe. In many cases, additional and even conflicting national requirements for waste management also are in place; in other cases EU laws which officially have been adopted are not actually being implemented.

However, several European trends are becoming apparent, including:

* Using fiscal measures to promote higher environmental standards;

* Prohibiting organic materials from landfills; and

* Segregating waste materials into different product streams such as packaging, electronic goods and cars, for which the manufacturer is responsible.

But across Europe, there are no commonly agreed standards for waste characterization or quantification and virtually no reliable data on the amounts of waste generated or the costs to handle waste. Even the definition of municipal solid waste (MSW) varies dramatically - in most countries, municipal solid waste includes only household and commercial waste; in some countries, light industrial waste is also included and, in Germany, even the sewage sludge is considered to be MSW.

The method of charging for waste services also varies dramatically and, until recently, has been difficult to identify because the costs were part of local authority taxes. The on-set in a small but growing number of cities and towns across Europe (but not nationally anywhere) of pay-as-you-throw and pay-by-weight programs has started to make waste management costs transparent to the general public. These schemes provide a much-needed incentive to reduce waste generation rates, in addition to inspiring innovative ways to dispose waste without incurring costs or waste tourism.

Across the board, packaging waste has received the most attention. Virtually every country had existing requirements for packaging waste recovery even before the recently agreed Packaging Directive came into force.

Fiscal Measures Landfill levies and product taxes may be better ways to improve performance than the punitive approaches used in the past. On the other hand, money raised from landfill taxes does not go to remedial work on old landfills, but disappears into a national government general revenue fund.

France already has initiated a landfill levy and other taxes on air pollution. In the United Kingdom, a landfill levy is expected to be introduced in 1996.

Belgium introduced controversial eco-taxes more than a year ago, but the green politicians' bite has not yet been felt. Soon it will be harder to evade the taxes on items like disposable razors and one-way packaging.

One of the forerunners of producer-responsibility initiatives was the celebrated German packaging ordinance, which spawned the Dual System Deutschland (DSD) system. While initial moves toward producer responsibility have focused on packaging in Austria, France, Sweden and the United Kingdom, the second wave of plans is aimed at items such as scrap cars, old computers and televisions. Many people are attracted to the concept of making the manufacturer take back items at the end of their lives, seeing it as an extension of the "polluter pays" principle; however, the consumer, ultimately, will pay.

There are potential disadvantages to treating different waste streams separately, not the least of which is the inevitable increase in hauling distances. Collection costs are likely to increase as more separated waste streams are being collected by more product-dedicated reprocessing facilities. While a landfill site, incinerator or materials sorting facility can serve a single geographical area, a plant dedicated to dismantling old computers or televisions cannot be built in every neighborhood. Unless these initiatives are addressed sensibly, and with regard to other product waste streams, a nightmare scenario could soon develop with hundreds of trucks and trains criss-crossing the continent to deliver scrapped goods to specialist re-manufacturers.

Landfill Controls After a long, drawn-out debate and many revisions of the wording, the EU has agreed on a Landfill Directive. One of the more contentious aspects was Britain's insistence on being allowed to continue practicing co-disposal, in which special wastes' impact is diluted through disposal with municipal solid waste. Unlike most of Western Europe, Britain still relies heavily on landfills to dispose more than 90 percent of its wastes.

Britain's landfill levy, which will come into force when its Environmental Protection Agency becomes operational in 1996, marks the country's first use of fiscal measures. A Producer Responsibility Initiative involving all sectors of the packaging chain from converters, manufacturers and fillers to retailers, recently reached the end of its preliminary deliberations. To prevent free loading, motivated sectors in the industry have asked the government to introduce legislation, despite the government's preference for a voluntary agreement. A levy will be introduced to meet the costs of operating the system, but, it is still unclear where in the chain the levy will appear.

By the year 2000, Germany will only allow wastes with less than 3 percent carbon to be landfilled. The same ruling, but at 5 percent carbon content level, has been introduced in Austria. Both Austria and Germany will require new incineration capacity to meet this rule. Denmark, Switzerland, France and Sweden are simply banning the landfilling of putrescible wastes. It's still unclear how the percentage limits or the total bans will be enforced, but expanding waste incineration will likely play a part.

In 1993, Austria adopted an ordinance that is designed to prevent wastes from packaging materials; Alstoff Recycling Austria (ARA) was formed to handle the materials. Like Germany's DSD system, member companies must pay ARA a levy to collect and process their materials. An 80 percent recovery and treatment/recycling rate is required by the year 2000. But unlike DSD, ARA also handles transport and secondary packaging. Recent reports suggest that after one year, ARA may be experiencing difficulties, although Austria's Environment Minister Maria Kallat reports that the ordinance has greatly reduced levels of waste for disposal.

Belgium's three regions - Brussels, Flanders and Wallonia - have voluntary agreements for packaging waste collection, which will use Germany's Green Dot system. Fost Plus, the national scheme that will coordinate the separate collection of household packaging waste, has a recycling target of 41 percent by the year 2000.

Waste incineration, a major part of Denmark's waste management strategy, will ban landfilling putrescible waste in 2000. Denmark's controversial ban on aluminum drink cans in the 1980s attracted more attention than the fact that the Danes continued to export their own drinks in aluminum cans. Many saw the ban as trade protection, which makes it hard to import beer and other drinks from neighboring countries, such as Germany, due to the costs of returning empty bottles.

France's Eco-emballages system reduces costs by collecting separated packaging materials and ordinary domestic waste. This compares with Germany's DSD, which created a collection system parallel to the municipal one. Introduced in 1993, Eco-emballages aims to valorize 75 percent of waste packaging by the year 2000 - and, unlike Germany, valorizing may include material or energy recovery from collected packaging materials.

Germany introduced legislation requiring manufacturers to take back packaging in 1991, and since the requirement called for separation from the municipal solid waste collection system, DSD was born. DSD is funded by licensing companies that use a Green Dot symbol on their packages. Germany's scheme has attracted much attention because the vastly overcollected materials lacked home markets. DSD also has been hurt by companies using the symbol without paying their license fees.

On a wider scale, Germany's latest Cycle Economy Law, which will come into effect at the end of 1996, will differentiate between waste for recycling and waste for disposal. It also will require goods to be designed to minimize waste and increase the opportunities for recycling as well as repair. Incineration, which has been politically unpopular in Germany in recent years, also will be permitted under the new law and has been given equal status with recycling.

According to the packaging directive's terms, and recognizing that it starts from a lower point, Greece has been permitted lower recovery targets for packaging waste than other countries; however, it must achieve a 25 percent recovery within five years. Greece also has been granted EU funds to raise the country's waste management standards.

In 1994, Ireland's government introduced a new waste law which includes a 20 percent waste recycling target by the year 1999 including an overall 33 percent rate for packaging waste and 25 percent for newspapers.

In 1994, Italy introduced a 10 percent tax on virgin polyethylene to promote plastics recycling. Funds collected are used to promote recycling programs, unlike many such funds. Italy has a number of national systems operated by industrial sectors that collect and reprocess waste materials, but a relatively low recycling rate.

Tiny, landlocked Luxembourg is considering introducing eco-taxes to raise environmental standards, as well as the possibility of requiring deposits on refillable bottles. In 1994, a waste law was introduced that follows the EU agreed hierarchy for waste management: prevention, reduction, re-use, recycling, energy recovery and disposal.

Separate collection of green waste was introduced in the Netherlands in early 1994, with a resulting rush to construct composting plants. Now the Netherlands is banning combustible waste from landfills. The Dutch Packaging Covenant, a voluntary agreement between the packaging industry and the government, recovers and recycles packaging wastes.

Although Norwegians vetoed a referendum to join its Scandinavian neighbors in the EU, Norway already operates a system of eco-taxes and a form of producer responsibility for some sectors of the packaging industry.

A new waste law is due to come into effect in Spain, with provisions for producer responsibility for packaging waste and the possibility of eco-taxes.

Sweden's former tax on one-way drink packaging has recently been replaced by the eco-cycle law, which came into effect in 1994. The new law carries lower recycling targets and is a more flexible, market-driven approach.

The variations in waste management policies throughout the EU and the many regulatory changes that have taken place in the past year only hint at the disparity beneath a seemingly united front.

Some of the European Union's current directives on solid waste management include:

EC Council Directive on Waste. A framework directive first agreed upon in 1975 and amended in March 1991, it details member states' obligations to implement waste policy. This, in turn, requires them to take adequate steps to encourage waste prevention, recycling and processing and to ensure that municipal solid waste disposal does not harm human health or the environment.

EC Council Directive on Hazardous Waste. This categorizes certain wastes as hazardous and requires identifying, recording, handling and disposing of specified materials in a sound manner.

EC Directive on Packaging and Packaging Waste. This was finally approved in 1994 after a number of amendments and a last-minute challenge by Belgium, which was nervous that its own eco-taxes would be adversely affected by the rules.

EC Directive on Spent Batteries and Accumulators.

EC Directive on the Landfilling of Waste. The European Council reached a common position on the terms of the Directive in mid-1994, after amendments and revised drafts which had taken more than three years. It supports a four-tiered hierarchy, with landfilling as the last resort, and includes definitions of waste, inert waste and hazardous waste. Waste acceptance, site licensing conditions and closure and after-care are addressed.

The National Association of Waste Disposal Contractors, a United Kingdom trade association, claims that 80 percent of the United Kingdom's landfill sites may have to be closed, since they cannot meet the new Directive's requirements. Countries such as Spain, Portugal and Greece are likely to have similar problems with the EC Directive on the Landfilling of Waste.

The European Unionwide eco-labelling scheme, which has been in preparation for several years, came close to foundering completely at the end of 1994. Current discussions may lead to a transfer in responsibility for the labels to the newly established European Environment Agency in Copenhagen.

The European Unionwide system has been proposed to limit in-consistencies due to the various national eco-label schemes introduced by separate nations. Germany, Denmark, the Netherlands, Norway and Sweden all currently have schemes in place, and many others, including Eastern countries such as Hungary, are now considering similar schemes. Since several of the former Eastern European countries have recently applied for European Union membership, conformity will become even more important and is expected to increase greatly in difficulty.