Read It & TEEP

After many years of gestation, the legislative changes included in the EU’s Circular Economy Package (CEP) came into force last month. In his first CEP blog, Dr Colin Church looked at bio-waste; here, he explores the implications of these changes for UK household recycling.

One of the main headlines the sector talked about throughout negotiations on the Circular Economy Package is the proposed increases in recycling targets. The final package (which came into force on 4 July 2018) does introduce new, higher targets. But what else is in there that – subject to what the UK decides to do in the medium to long term if we do indeed leave the EU – will affect household recycling here?

The main pieces of legislation relevant here are the new Landfill Directive (EU) 2018/850, the new Waste Framework Directive (EU) 2018/851 and the new Packaging and Packaging Waste Directive (EU) 2018/852.



The CEP focuses on ‘municipal’ waste, which alongside household waste (the previous focus) now brings in waste from other sources that is similar (broadly, the ‘C’ in ‘C&I’). It includes paper and cardboard, glass, metals, plastics, bio-waste, wood, textiles, packaging, waste electrical and electronic equipment, waste batteries and accumulators, and bulky waste.

A new definition of ‘material recovery’ is introduced to cover forms of recovery other than energy recovery. It includes preparing for re-use, recycling and backfilling and other forms of material recovery such as the reprocessing of waste into secondary raw materials for engineering purposes in construction of roads or other infrastructure.

The new default calculation method for recycling targets is based on the weight of municipal waste which enters recycling. Where justified to limit administrative burdens, the calculation can be done via measuring the output of any sorting operation, less any material not subsequently recycled. Good quality metals recycled from incinerator bottom ash can also be included.

Member States are encouraged to make full use of economic instruments (such as deposit return schemes, landfill taxes, etc) to drive the changes in waste policy.


The inclusion of non-household waste probably doubles the volume of waste covered by the regime compared to UK current practice and is likely to lower the UK’s recycling rate as currently reported. To meet the future recycling targets in the CEP, a renewed focus on the provision of recycling services to the commercial sector, and particularly smaller firms, is likely to be needed.

Moving to a smaller set of potential calculation methods of recycling (two from the previous four) and making them more consistent will make inter-country comparison easier. However, depending on which of the old methods a country is currently using, the new definitions may also reduce reported recycling rates across Member States to varying degrees.

For example, the reduction in reported recycling rates for England and the UK as a whole is likely to be less than that for Germany or Wales, which counts rubble and recycled incineration bottom ash (not just the metals recovered) in its headline recycling rate.

Prevention & Reuse


The CEP places a greater emphasis on waste prevention and reuse in general. It recommends the promotion of more sustainable business models and products; reduction in use of packaging and of hazardous substances; and more and easier remanufacture and repair, amongst other approaches. There will also be a duty on member states to promote food waste prevention and on the Commission to consider setting targets on preparing for re-use of textiles and other waste streams.


Most of the requirements here are around promoting and encouraging action, indicative targets, etc. In some areas and with some waste streams this may move things along, but it will require continued strong political will by the four UK governments to turn this into concrete action.



Source: Directive (EU) 2018/852; Defra 22 February 2018[1]. UK achievement is combined recycling & recovery, so is not directly comparable
The requirement for separate collection of waste is strengthened and the test as to whether separate collection isn’t technically, environmentally or economically practical (‘TEEP’) is made tougher. Member States will have to report to the Commission on implementation of this (including any TEEP derogations) by the end of 2021. Introduction of the separate collection of bio-waste (2023), hazardous waste produced by households (2025) and textile waste (2025) is required.

The overall targets for recycling of municipal waste are increased to 55% by 2025, 60% by 2030 and 65% by 2035. The corresponding targets for recycling of packaging waste are 65% (2025) and 70% (2030), broken down as in the table. Reusable packaging will be counted towards recycling targets.

The CEP sets out new requirements on extended producer responsibility (EPR) schemes. The main change is to require producers of materials covered by an EPR scheme to cover the full net costs for separate collection, transport and treatment, providing adequate information to waste holders and the costs of data gathering and reporting.

This can be reduced to 80% of the net costs when justified, or 50% if it is an existing scheme to meet national (not EU) targets. In the UK, producers cover 10-20% of these costs for consumer packaging in the current (PRN/PERN) regime, with the rest covered by local authorities.


These changes will require greater efforts in England, Northern Ireland and Scotland in particular to reach the more demanding municipal recycling rates. They are likely to drive reform of the packaging regime to pass more cost onto producers. Along with the tightened ‘TEEP’ tests and the requirements on biowaste, etc, this is also likely to push more waste collectors towards separate collection in England, catching up with the direction of travel elsewhere in the UK.

The increase in availability of recyclate will cause issues if there is insufficient demand for it – a situation made more concerning by the closure of the Chinese (and increasingly other) markets to much of our material.



By 2030, there should be no landfill of material suitable for recycling or recovery, and the amount of municipal waste going to landfill must be less than 10% of the total arising by 2035. A new ban on incineration of separately collected recoverable waste comes in. For biowaste, various changes promote the use of anaerobic digestion and in-vessel composting over incineration. Member States are encouraged to do more to ensure any waste exported for reuse or recycling is sent to facilities that broadly meet EU environmental standards.

Not in the legislative package itself, but in the Commission’s 2017 Communication on the role of waste to energy, there is also the start of a push against the deployment of additional incineration infrastructure in those countries (such as the UK) that the Commission considers already have significant capacity.


Alongside the changes to collection rules, this will push much more biowaste towards AD and IVC and, as highlighted above, strengthen the case for more UK-based reprocessing capacity. It will also drive a further reduction in landfilling (the UK currently landfills just under a quarter of its total waste).


The overall impact of the changes in the CEP will be to make the case for separate collection of food waste far stronger for English local authorities. Once collected separately, this waste will need to be recycled (not landfilled or incinerated), which will drive demand for AD and IVC until and unless food waste reduction actions bite or new technologies (such as biorefineries, etc) come along.


The key dates are:

  • 2020    Transposition
  • 2021    Separate collection reporting
  • 2023    Separate biowaste collection; possible proposal for a binding food waste reduction target
  • 2024    Possible proposal for recycling targets for municipal biowaste
  • 2025    55% recycling of all municipal waste; indicative reduction of food waste by 30%; separate collection hazardous waste from households and of textile waste; increased packaging recycling targets
  • 2027    Separate collection of feedstock for AD and composting for it to count as recycling
  • 2030    60% recycling of all municipal waste; no landfill of material suitable for recycling or recovery; increased packaging recycling targets
  • 2035    65% recycling of all municipal waste; indicative reduction of food waste by 50%; maximum 10% of municipal waste to landfill


Directive (EU) 2018/852; Defra 22 February 2018

Darrel Moore

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