Environmental NGOs question Eurostat’s recycling data on Bulgaria

A new report by Zero Waste Europe and its Bulgaria-based member Za Zemiata, an environmental NGO, has found large discrepancies between Eurostat’s recycling figures for Bulgaria and data reports from local municipalities. While Eurostat finds Bulgaria’s packaging waste recycling performance to be above the EU average, Za Zemiata highlights its short falls.

According to Eurostat’s latest statistics, Bulgaria’s packaging waste recycling rate stood at 50.6% in 2019, placing it above the EU average. However, data from Za Zemiata suggests that many municipalities fall short of the EU’s 50% recycling target for municipal solid waste. Over half, 132 municipalities, reported recycling rates below 10% in 2019, and 43 recorded “practically zero.”

According to Evgenia Tasheva, part of Za Zemiata’s Zero Waste team, a key reason behind the data discrepancy is “institutional ‘blindness' to real-life data.”

“There is no distinction between household and commercial or industrial packaging waste, which allows packaging recovery organizations (PROs) to report high recycling rates that do not necessarily come from post-consumer waste but may be sourced, for example, from B2B transactions involving pre-consumer packaging waste, such as secondary and tertiary packaging,” she tells Packaging Insights.

“Packaging waste is part (subset) of the municipal solid waste stream and different recycling rates could be expected. However, the extreme gaps in reported amounts of packaging put on market, combined with the low-density separate collection of packaging, mean that Bulgaria's problem of high landfilling and low recycling ratio is a result (not fully, but considerably) of a deficient legal framework that leads to large amounts of mismanaged packaging waste.”

Tasheva explains the EU’s Green Deal Plastic tax on un-recycled plastic packaging are currently being paid out of the state budget, “that is, by all taxpayers in Bulgaria.”

A European problem

Ensuring the accuracy of Eurostat’s data will be crucial for monitoring and maintaining transparency in the implementation of the EU’s Packaging and Packaging Waste Regulation. 

Zero Waste Europe calls for the establishment of an European organization in charge of compliance monitoring.Tasheva says that the national legal regulations regarding the separate collection service for packaging waste from households to be provided by PROs are rather low. 

“This has resulted in more than a decade of stagnation with a system that only provides low-density collection points, and, unlike mixed waste collection, is very far from covering all municipalities.”

Larissa Copello, Packaging & Reuse policy officer at Zero Waste Europe, adds: “This is a European problem. Last year, Zero Waste Europe brought attention to the problem in Spain, exposing how the PRO was misreporting collection data.”

“As a direct result, the Spanish Government announced the introduction of a nationwide DRS to meet its recycling targets. It is urgent that the EU creates the right tools and rules to guarantee proper oversight and reporting. A European organization in charge of compliance monitoring is needed,” she asserts.

In Bulgaria, public costs currently cover local waste fees for managing packaging found within mixed waste in settlements lacking containers for separate collection of packaging, the management of packaging found in residual waste (for places with available packaging sorting bins), as well as for the costs of cleaning up litter (consisting mostly of packaging) from public areas and illegal dumpsites, explains Tasheva.

She tells us that the latest EU “Early Warning” report on Bulgaria recommends the introduction of new legal requirements that specify the minimum collection service that PROs are required to provide so that there is a focus on door-to-door collection (where appropriate).

“Bulgarian local authorities are facing an enormous challenge with the pending mandatory introduction of the 'pay-as-you-throw' principle for local waste charges. Lacking adequate and accessible separate collection infrastructure, not just for packaging, but notably for food waste, the task of making those fees both fair and collectible, is nearly impossible,” continues Tasheva. 

“Since Bulgarian municipalities are effectively responsible for compliance with the recycling targets, they should be enabled to provide and procure minimum-standard collection services, funded by the PROs.”

DRS and reporting

The “much-expected” introduction of a national DRS for beverage containers could “drastically improve the transparency and reliability” of data concerning the lifecycle of bottles and cans on the Bulgarian market.

The report by Zero Waste Europe and Za Zemiata, states that in 2017, an average of 113 plastic bottles per capita were “wasted” (landfilled, incinerated, or simply littered). The number for the same year was 95 in Poland, 54 in Slovakia, and 42 in Czechia. In Lithuania and Estonia, where DRS is already in place, only nine bottles per person were wasted in the same year. 

A national DRS for beverage containers could “drastically improve the transparency and reliability” of data, says Tasheva.“Regarding the remaining multitude of packaging types, the first step is to introduce separate targets for the packaging waste coming from households (post-consumer) and from businesses,” asserts Tasheva. 

She calls on the Ministry of Environment and Water to require annual or bi-annual waste composition analyses on local level that clearly distinguish between packaging and non-packaging materials found in the mixed municipal solid waste — a recommendation also found in the latest EU Early Warning report. 

Illegal waste dumping 

Investigative media reports conducted in the past couple of years in Bulgaria have repeatedly uncovered illegal waste dump sites consisting of imported waste, largely from wealthier EU states and officially destined for recycling.

“This indicated faulty monitoring mechanisms that fail to enforce the national ban of waste imports for landfilling. Bulgarian authorities’ responsibilities for monitoring incoming waste loads appear to be fragmented among several institutions, and it is unclear whether the border checking staff have the necessary training to properly inspect and classify waste,” asserts Tasheva.

“Moreover, it is totally unclear whether and how the Ministry of Environment and Water is enforcing the national rule of 50:50 ratio of domestic to imported refuse-derived fuel used by licensed operators — mostly cement kilns.”

Tasheva calls on the Bulgarian authorities to break the persistent over-reliance on landfilling by reviewing and increasing landfill charges, which are currently “frozen” at €45 (U$49) per ton of waste.

“Importantly, in order to ensure this drives waste higher up the waste hierarchy, a similar waste charge for each ton of waste incinerated (with or without energy recovery) should be introduced as well.”