European watchdog probes Liechtenstein on wood packaging recycling shortfalls

The European Free Trade Association Surveillance Authority (ESA) is investigating Liechtenstein for failing to meet its recycling targets for wooden packaging waste, citing an inefficient waste separation system and a lack of proper infrastructure for recycling wood packaging. 

Under EEA rules, Liechtenstein was required to recycle at least 15% of its wood packaging waste by 2008. The most recent reporting for the year 2023 shows no recycling of wood packaging. 

“Having assessed the information provided by Liechtenstein, ESA considers that, by failing to take the necessary measures to attain the recycling target for wood packaging waste, Liechtenstein has failed to fulfil its obligations under the EEA Agreement,” says the compliance monitor. 

The ESA recommends the country improve its monitoring and reporting of data and reduce reliance on civic amenity sites by expanding existing private bring-points in supermarkets and considering the extension of convenient public bring-points, with a focus on wooden and plastic packaging waste.

A letter of formal notice is the first step in an infringement procedure against an EEA EFTA state. Liechtenstein has two months to respond and address the shortcomings raised in the letter before the ESA can take the case further.

Wood pack recycling gaps

According to an ESA Early Warning Report from 2024, Liechtenstein was at risk of missing the material-specific recycling targets of 25% for wooden packaging and 50% for plastic packaging under what was then the EU’s Packaging and Packaging Waste Directive.

The ESA attributes Liechtenstein's failure to recycle wood and plastic packaging waste to system inefficiencies and lack of wood packaging recycling.The ESA explains that Liechtenstein’s failure to recycle wood and plastic packaging waste is the “inconvenience of the system for separate collection” and the “absence of collection or recycling of wood packaging.” 

The ESA says: “A third factor is the lack of sufficient incentives for municipalities to prioritize and improve their recycling efforts to ensure better compliance with recycling targets. Specifically, legal instruments that determine consequences for municipalities that do not fulfil the recycling targets are not applied, due to the lack of data.”

Meanwhile, the report suggests that different labeling systems might cause consumer confusion when sorting waste. Liechtenstein imports a considerable amount of packaging from Switzerland and Austria, which have different labeling specifications. 

“Establishing unified labeling requirements for the Liechtenstein market is challenging, but other measures could be envisaged,” notes the ESA. 

It suggests that Liechtenstein could raise public awareness on how to sort waste with Austrian or Swiss labels. Liechtenstein could ensure that the “harmonized” pictograms which it established for the civic amenity sites are also systematically used by all civic amenity sites.

In January, the European Commission published its proposed harmonized waste-sorting label system for packaging, in line with the EU’s Packaging and Packaging Waste Regulation.

Improving waste reporting 

The ESA is also examining whether the country’s waste reporting meets EEA legal standards. 

For materials like paper, cardboard, aluminum, and glass, the country is meeting its recycling targets.“Liechtenstein must take the necessary measures to ensure compliance and may draw on the country-specific recommendations set out in our Early Warning Report,” says the EEA compliance monitor. 

The ESA notes that this is also important to ensure compliance with the amended EEA waste legislation targets for 2025, 2030, and 2035.

The report also notes that Liechtenstein does not yet have harmonized reporting rules, so its conclusion is made only on the best available data.

“Under EEA rules, Liechtenstein must meet binding targets for the collection and recycling of waste. These targets have become progressively more ambitious to support the transition to a circular economy,” says the ESA. 

Circular economy measures

For other materials, such as paper, cardboard, aluminum, and glass packaging, Liechtenstein reaches its recycling targets successfully, according to the ESA.

Moreover, regarding landfill waste, the ESA reports that Liechtenstein has already achieved its 2023 target, as it banned landfilling of municipal waste and biodegradable waste in 2000. 

However, the ESA highlights that Liechtenstein does not have an EPR in place or any other packaging tax, which the report argues is “complicated” due to Liechtenstein’s integration in the Customs Union with Switzerland.

“Therefore, while the introduction of economic instruments could help improve recycling performance, no recommendations to this effect are currently proposed.”