Packaging Undertakings and Apartment Associations: Problem with Municipal Waste Should Not Be Solved Based on Gut Feeling

19 organisations turned to the Environmental Committee of the Parliament in relation to the proposal made by the Ministry of the Environment according to which packaging waste should from now on be collected in a separate container at every private residence, apartment association and legal entity. The packaging undertakings and the Estonian Union of Co-operative Housing Associations do not support the proposal.

The Ministry’s proposal changes the functioning system, but ignores the problem

Organisations that have joined the joint address find that the proposal made by the Ministry is not the most reasonable and cost-effective solution for increasing recycling of municipal waste for the following reasons:

1. The biggest problems in Estonian waste management are not related to packaging waste but recycling of municipal waste. While the recycling rate of packaging waste in Estonia is over 60%, for municipal waste this is only approximately 30%. Furthermore, the proposal of the Ministry of the Environment has no impact on more than two thirds of the municipal waste, because packaging waste makes up less than a third of the municipal waste. This the proposal will not help to ensure the required 50% recycling rate for municipal waste. 
2. Amendments related to municipal waste and packaging waste have a direct impact on hundreds of thousands of people and companies and the impact of the amendments may reach millions of euros. Therefore, alternatives should be considered before the amendments are implemented and their impact should be assessed in order to find the best solution for the society. Unfortunately, the Ministry of the Environment has not considered it necessary to analyse the impacts of the amendments, has failed to analyse alternatives and has not included stakeholders into developing the proposal.
3. Organisations that have joined the joint address recommend increasing awareness among people in order to increase recycling of municipal waste and considering separating organic waste from municipal waste. When organic waste is no longer put into the municipal waste containers, it will not contaminate other municipal waste (e.g. packaging waste) and it will be easier to successfully sort and recycle municipal waste. Furthermore, other regulatory and non-regulatory solutions should be analysed (e.g. improving the network of public packaging containers, collecting packaging waste at the waste generation location in certain areas etc.) to find the best solution for the society.

Due to the above-mentioned reasons, 19 organisations proposed the Environmental Committee not to include the proposal of the Ministry of the Environment in the draft Waste Act. Additionally, we recommended that the Ministry form a broad working group consisting of different stakeholders in order to find the best solution for Estonia with the aim of increasing the separate collection and recycling of municipal waste.

Organisations who sent the joint address:

Estonian Chamber of Commerce and Industry
Estonian Union of Co-operative Housing Associations
NGO Eesti Taaskasutusorganisatsioon
Federation of Estonian Chemical Industries
Estonian Food Industry Association
Estonian Traders Association
Association of Estonian Printing Industry
NGO Jäätmehalduskeskus
Association of Construction Material Producers of Estonia
Estonian Machinery Association
Estonian Alcohol Producers and Importers Association
Estonian Clothing and Textile Association
Estonian Horticultural Association
Estonian Small Traders Association
Estonian Chamber of Agriculture and Commerce
Estonian Breweries Association
Estonian Association of Fisheries
Estonian Association of Bakers
Estonian E-commerce Association