Waste policy overview – what does 2019 tell us about future waste policy?

The government published the Climate Action Plan during the summer, listing 183 actions to meet Ireland’s EU climate and energy targets, reduce its carbon emissions by 30% during 2021 to 2030 and lay the foundations for achieving net zero carbon emissions by 2050.

Progress has been made in reducing greenhouse gas emission from waste. The EPA reported that emissions from the waste sector decreased by 2.8% in 2018. While waste only accounted for 1.5% of Ireland’s greenhouse gas emissions in 2018, the government is focusing considerable attention on waste policy because the way we use materials is estimated to be associated with 60% of GHG emissions. Therefore reducing material use, re-using or recycling is assumed to have a much greater role in climate change than suggested by the 1.5% figure.

Actions 135-144 relate specifically to waste and the circular economy. In looking to what headway will be made in the more immediate term, 2020 will see progress on the delivery of a new national waste policy, the consideration of a number of environmental levies and the introduction of measures to incentivise the use of recycled materials in packaging.


Climate Action Plan:  Waste and Circular Economy Actions

Action 135

Lead the transformation from waste management to circular economy practice through delivery of a new national policy

Action 136

Revise waste legislation to incorporate new circular economy requirements, including legally binding waste/recycling targets

Action 137

Develop a new National Waste Prevention Programme, and Regional Waste Management Plans that will guide our transition to a circular economy by EPA and Local Authorities

Action 138

Support the development of eco-design and circular economy opportunities for Irish enterprises to reduce waste over the full lifecycle of products

Action 139

Develop and implement a suite of measures to reduce the impact of single-use plastics

Action 140

Maintain Government leadership in taking responsibility for own resource consumption, particularly single use plastics, energy, waste and water

Action 141

Identify opportunities to strengthen the regulatory and enforcement frameworks and structures for the waste collection and management system, to maximise the collection of clean, segregated materials for reuse and/or recycling from all households and businesses, and to incentivise consumers to reduce, reuse and recycle

Action 142

Regulate and incentivise producers of waste, particularly packaging, to ensure the prevention of waste and the use of recycled materials in packaging products

Action 143

We will scope a number of possible environmental levies, including a possible levy on single use plastics, as part of the review of the Environment Fund. Further detailed research would be required prior to the introduction of any new levy

Action 144

We will identify and commence delivery of measures to address the key regulatory barriers to the development of the bioeconomy, including exploring opportunities to establish “End of Waste” criteria for certain bio-wastes

Environmental levies

Since the publication of the Climate Action Plan, the Department of Climate Action, Communications & Environment launched a public consultation on the proposed introduction of Environmental Levies. This includes a proposal to increase the plastic bag levy, the introduction of a coffee cup, takeaway and food packaging levies, and levies specifically related to the waste industry (see action 143). These include a waste recovery levy on recovery operations at municipal solid waste (MSW) landfills, waste-to-energy plants,  co-incineration plants and the export of MSW.

Keeping the waste hierarchy in mind, an alternative approach is that the existing landfill levy exemptions should be reviewed in their entirety prior to the introduction of new environmental waste levies. A number of waste streams are currently exempted from the landfill levy. In line with the stated objective of transitioning to a circular and low carbon economy, exemptions applicable to waste streams with an energy value or organic content should no longer be exempt from the landfill tax i.e. street sweepings which are biodegradable for the most part. They would be better suited to treatment higher up the waste hierarchy. Access to existing or future landfill should be reserved for waste that cannot be recovered in any other way.

Use of recycled materials in packaging – fee modulation

Action 142 relates to measures to incentivise the use of recycled materials in packaging.  One of the key measures introduced in the revised Waste Framework Directive is the obligation on EU Member States to introduce fee modulation with the aim of boosting packaging recycling.  

There is a wide variety of approaches currently applied to the setting of fees for packaging across EU Member States. Fee modulation involves the differentiation of fees and moving away from a single fee level for all packaging of a certain material type, to a greater disaggregation in the fee structure – which is likely to more closely represent the net costs associated with managing the specific packaging formats at end-of-life. The aim is to improve the recyclability and incentivise the eco-design of packaging products.  Modulated fees are those which vary with the eco-design of the packaging. It is an incentive for producers to design products that contribute to waste prevention and facilitate recycling.  It rewards producers who at the outset, design their products with this in mind.

A higher fee will be charged for packaging material that is not widely recyclable. This material fee charging system is reflective of the producer pays principle. The key criteria in designing any fee modulation structure is the recyclability of the material. Fee modulation is very much data dependent and this will add to the reporting requirement of producers who place packaging on the market.  Other criteria which is likely to be considered in determining fee modulation is the recycling rate, reusability and recycled content.

The European Commission is due to release guidance on the eco-modulation of EPR (Extended Producer Responsibility) fees. This guidance is scheduled to be issued in Q1 2020. Repak has been running the first phase of a fee modulation pilot for the past six months with large plastic producers.  This will be rolled out to all producers over the coming months. Modulated fees will be introduced for Repak members for plastics in January 2021 and for all packaging materials from January 2023.

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