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“Our mission is to guarantee effective compliance of the financial sustainability principle by the General Goverment”

Municipal waste management

Spending review 2018–2021. Phase III

  • Published: February, 2026
  • Amount: 4.000 mill. €

Scope: General State Administration, Autonomous communities, Local authorities

Spending policies evaluated

Community wellbeing

Environment

Tools evaluated

STUDY DESCRIPTION

The purpose of this study is to provide evidence on the effectiveness and efficiency of a set of instruments available to public administrations to achieve Spain’s municipal waste management objectives. The scope of this study is limited to municipal waste, defined in Law 7/2022 as waste under local jurisdiction, and covers the period 2010-2019, although, where available, it has been extended with the most recent information.

 

All documentation from the study is available for consultation here.

Findings and proposals

 There are differences when comparing Spaniards’ personal assessment of their own waste separation, their perceived level of knowledge about waste separation, and actual levels of separate collection.

There is a difference between what Spaniards who separate their waste say and the actual average levels of separate collection. Between 49% and 56% (depending on the fraction) of Spaniards say they separate their waste ‘always (without exception)’, which indicates a positive self-perception. If we compare the subjective assessment of the level of separation in the home with the actual levels of separate collection for Spain, 25% in 2020, it is clear that what is reported is quite far from the usual practice in most households.

  • Paper, cardboard and glass are the most commonly separated waste fractions according to Spaniards, with 81% of respondents indicating that they recycle them “always (without exception)” or “most of the time”. Organic waste is the least commonly separated fraction in the home, with 12% of respondents indicating that they “never” separate it.
Residuos-HyP_G40
  • Spaniards also rate their level of knowledge about waste separation positively. While 55% of Spaniards consider themselves to be “quite” or “very” well informed about how to separate waste correctly, 37% consider themselves to be “somewhat” informed and 8% admit to being “not at all” informed.

Methodologies: descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Establishment of local service points for waste management
  • Local authorities
  • Rejected

Local authorities should set up physical or virtual service points for waste management, emphasising the importance of publicising these channels.

Setting up physical or virtual service offices would be advisable in order to improve interaction with service users. This could lead to various benefits, such as improved separate collection results, reduced incidents and faster detection and resolution, and greater public awareness of certain aspects of waste management, among others. This tool can be accompanied by the creation of networks of environmental advisors or agents to raise awareness among residents and small businesses about waste management.

 A high percentage of the Spanish population lacks access to communication channels, and waste campaigns have little or no impact on most of those who receive them.

A high percentage of the Spanish population lacks information and communication channels regarding waste collection services. According to the survey, 60% of respondents said they did not have access to a citizen service telephone number, the same percentage said they did not have a reference website on waste, 65% did not have a specific social network on waste, and 84% did not have any in-person information points. In addition, only 6% have a mobile app for separate collection. It is also worth mentioning that 37% of citizens are unaware of the existence of any communication channel on waste in their municipality.

  • According to the survey, 28% do not remember seeing, hearing or receiving any information campaign on waste in the last year, and 45% say they have not received any.
  • The degree of impact of the campaigns is limited according to citizens’ perceptions. For 67% of respondents, the latest campaign on waste had little or no impact on their behaviour.

Methodologies: descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Establishment of local service points for waste management
  • Local authorities
  • Rejected

Local authorities should set up physical or virtual service points for waste management, emphasising the importance of publicising these channels.

Setting up physical or virtual service offices would be advisable in order to improve interaction with service users. This could lead to various benefits, such as improved separate collection results, reduced incidents and faster detection and resolution, and greater public awareness of certain aspects of waste management, among others. This tool can be accompanied by the creation of networks of environmental advisors or agents to raise awareness among residents and small businesses about waste management.

  •  
    Designing awareness campaigns with a strategic approach
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • In progress

Design public awareness campaigns with a strategic approach.

Public awareness campaigns should be designed with a more strategic approach in order to influence public behaviour. Innovative designs and methods are needed. Linking these campaigns to economic issues is key to achieving this effect.

 With domestic and community composting, the economic and environmental costs associated with organic waste management systems can be reduced.

Composting is a type of organic waste treatment that consists of an aerobic process which, under controlled ventilation, humidity and temperature conditions, transforms degradable organic waste into a stable and sanitised material called compost, which can be used as an organic fertiliser.

For the implementation of domestic and community composting to be considered good practice, it must:

  • Record the number of residents involved.
  • Ensure that all residents have access to a separate bio-waste collection system or the necessary means for composting. To this end, equipment such as compost bins and, in particular, informative documents or web pages can be provided free of charge or at a greatly reduced price.
  • Raise awareness among the citizens involved by offering training on the subject.
  • Provide regular updates to users.
  • Monitor and inspect the equipment deployed and have trained advisors to supervise and advise on its use.
  • Provide maps (web/apps) showing the locations of community composting facilities.

The study has collected cases in which this experience has been successful, both nationally (e.g., Usurbil) and internationally (e.g., Leicester).

Methodologies: case studies, documentary analysis, individual interviews

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Measures to support citizens in the separate collection of organic waste
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Facilitate support measures for households for the separate collection of organic waste.

It would be advisable to disseminate information about the use of compostable bags and aerated bins to ensure the proper functioning of organic waste separation in the home. It is also advisable to distribute these materials as part of communication campaigns to implement separate bio-waste collection.

The purchase of these materials by local authorities could be included among the eligible items for subsidies and grants aimed at improving the separation of organic waste at source.

  •  
    Creation of a state quality seal for compost
  • Ministry for Ecological Transition and Demographic Challenge
  • Rejected

Create a state seal that certifies compost in terms of quality.

This certification should include parameters such as heavy metal content, stability and maturity, as well as the rate of nutrient release into the soil, and establish the possible uses and applicable quantities based on these parameters.

 There are no uniform criteria for regulating recycling centres, and a significant portion of the Spanish population still does not have access to them or know what types of waste can be brought there.
  • A significant portion of the Spanish population still does not have access to recycling centres, and a large part of the population is still unaware of the types of waste that can be brought there. Seven out of ten Spaniards use fixed recycling centres with varying frequency, while half of Spaniards use mobile recycling centres. Among those who do not use recycling centres, 12% say there is no fixed recycling centre in their municipality and 22% say there is no mobile recycling centre. This factor varies substantially depending on the size of the municipality: in larger towns, usage is higher, as is the availability of this service.
  • The main reasons for not using recycling centres, apart from the aforementioned lack of availability, are: not generating waste suitable for recycling centres, distance or the need to access them with one’s own vehicle, and lack of knowledge about what types of waste can be brought in. Given that all households generate waste that should be deposited at fixed or mobile recycling centres, the first reason given suggests a lack of knowledge about what types of waste can be brought in.
Residuos-HyP_G38
  • With regard to the management of recycling centres by local authorities, there are no uniform criteria for their regulation, and this has an impact on their operation. Local authorities are responsible for recycling centres, so they must establish regulations for their operation and use. According to the FEMP, the lack of specific national regulations on recycling centres could be the cause of the heterogeneity of criteria in their management and operation.

Methodologies: descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Preparation of a technical guide for the management of recycling centres
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Develop a technical guide to advise local authorities on the operation of recycling centres, which will contribute to greater implementation of the most efficient systems and facilitate greater territorial uniformity in their operation.

The ministry responsible for waste management could approve a technical guide to advise local authorities on regulating the operation of their recycling centres.

  •  
    Provision of recycling centres and promotion of their use
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Seek to offer fixed or mobile recycling centre services to the entire Spanish population and widely promote their use.

It is proposed that offering recycling centre services be mandatory for all municipalities, either directly or through joint provision with other municipalities via supra-municipal entities, as well as widely promoting their use and providing information on what types of waste can be brought in. The existence of a fixed recycling centre should be ensured in municipalities with a certain number of inhabitants and complemented by mobile recycling centres for smaller municipalities or areas far from population centres.

 Smart bins equipped with locking systems and user identification can help improve waste indicators.
  • There are two types of smart bins: those that only incorporate fill sensors and those that also incorporate an opening system using a card, key fob or mobile phone.
  • Those equipped with locking and user identification systems can help improve waste indicators, especially if they are complemented by a pay-as-you-throw system. This collection system allows, as with the PaP with bins or bags with tags, although in this case through the use of the respective access element, the implementation of other instruments such as bonuses or incentives applied to the waste tax or, for example, a system of discounts or vouchers for municipal services, etc.
  • Smart containers offer a number of improvements over traditional ones. Among the advantages of this system are greater accessibility to real data with less delay, greater efficiency in route optimisation (with consequent reductions in the environmental and economic impacts associated with traditional collection routes) and a wider range of possibilities for updating and incorporating new improvements.
  • Generally, they are not introduced for all waste fractions in order to avoid high costs. They are commonly used for organic and residual waste.

Methodologies: case studies, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Implementation of efficient collection systems and setting of targets for the incorporation of recycled materials.
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Implement efficient collection systems and set targets for incorporating recycled materials, with the aim of obtaining high-quality recycled material.

Improvements must be made to collection and treatment systems, in line with other proposals in this study, and targets must be set for incorporating recycled materials into the production of new products and reducing the levels of unsuitable materials in the different collection fractions.

 The implementation of the door-to-door collection system has a significant positive effect on several waste management indicators.

AIReF has carried out a counterfactual assessment of the adoption of the PaP system in municipalities in Catalonia to try to identify a causal relationship between the establishment of this technical collection system and various performance indicators (per capita generation, separate collection and level of improper waste).

The results obtained include the following highlights:

  • The kilograms of waste produced per person decreased by 20% immediately after the system was established. Furthermore, this decrease has been maintained over the following four years.
  • Separate collection in kilograms per person increased by around 30%, and this effect was maintained over the following four years. The percentage of separate collection increased by almost 30 percentage points.
  • If standard estimators are used in the econometric analysis, a reduction in the percentage of improper waste in the organic fraction is observed after the implementation of the collection system. However, given that the phased implementation of the PaP collection system may lead to a problem of bias in the results, the analysis is replicated using estimators that take into account the gradual incorporation of the PaP collection system, and with these no significant reduction is detected.
  • The effectiveness of the door-to-door system varies by type of waste: organic waste shows a substantial increase in kilograms per capita (up to 60%), followed by packaging, at close to 40%. Glass waste also increases, but to a more limited extent.
Residuos-HyP_G34
  • No differences in generation or collection were observed based on the population density of the municipality (built-up area) or distance from the coast. When estimating the effects by population density, it can be seen that in municipalities with low population density, waste generation decreased in the same proportion as in those with high density.
  • Finally, it is worth mentioning that the Spanish population’s assessment indicates that the implementation of a separate door-to-door collection system would have an effect on household behaviour. Citizens give the door-to-door collection system an average rating (6.3/10) and consider it quite or very likely (51%) that they would increase their level of waste separation or recycling if door-to-door collection were made mandatory. This highlights the importance of accompanying this measure with a robust communication and awareness campaign.
Residuos-HyP_G31

Methodologies: difference in differences, descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Implementation of efficient collection systems and setting of targets for the incorporation of recycled materials.
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Implement efficient collection systems and set targets for incorporating recycled materials, with the aim of obtaining high-quality recycled material.

Improvements must be made to collection and treatment systems, in line with other proposals in this study, and targets must be set for incorporating recycled materials into the production of new products and reducing the levels of unsuitable materials in the different collection fractions.

  •  
    Promotion of the door-to-door collection system
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Actively promote the door-to-door (D2D) collection model.

The promotion of this collection model could be linked to various instruments:

  • Subsidies for local authorities to roll out separate collection, with additional points awarded in the application assessment criteria for municipalities with D2D collection.
  • At the treatment plant level, especially in the case of organic waste, tariffs could be established that discriminate according to the level of unsuitable waste. Regulations could even be defined for entry to the plant, limiting the maximum percentage of unsuitable waste admitted.
  • Municipalities with more than 5,000 inhabitants must draw up waste management plans in accordance with the plans defined at the regional level, so that the autonomous communities could incorporate into their planning the obligation to implement PaP (or the ‘most efficient’ model listed in Law 7/2022) in all or certain municipalities.

This system has so far been little implemented in Spanish municipalities with high urban density, although it has been implemented in other European countries (Brussels, Vienna, Berlin, Paris, Maastricht, Milan and Lisbon are examples of cities that have implemented PaP collection in all or part of the city). Despite this, it is a system that can potentially be implemented in any type of municipality, as there are various tools available to adapt it to the urban characteristics of the municipality: open community containers (e.g. for paper) or closed community bins (e.g. for organic waste), posts, hangers or closed cabinets to locate individual containers in the case of multi-dwelling buildings, etc.

 Deficit in the application of the waste hierarchy in terms of public investment
  • There is a deficit in the application of the waste hierarchy in terms of public investment by the autonomous communities, which does not contribute to achieving regulatory objectives. Between 2010 and 2019, only 1.1% of public investment by the ten autonomous communities that reported data on public investment was allocated to procedures for improving municipal waste management and prevention, compared to 21.4% invested in controlled landfills. The experts interviewed stated that it is in the stages of prevention, preparation for reuse (PxR) and reuse that the least resources have been allocated to meeting regulatory objectives and the guiding principles of waste management.
  • The Recovery, Transformation and Resilience Plan includes planned investments of €850 million for the period 2021-2023. Investment lines 1 to 4, relating to collection and treatment, are being managed by the autonomous communities through calls for subsidies, while lines 5 and 6 are the responsibility of the General State Administration. In the future, it will be necessary to evaluate the effectiveness of these investments and the extent to which they have facilitated the achievement of the regulatory objectives that Spain must meet in the coming years.
Residuos-HyP_C24

Methodologies: documentary analysis, descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Investment geared towards compliance with the waste hierarchy
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Implemented

Direct investment towards compliance with the waste hierarchy, giving greater weight to priority levels (prevention and reuse).

It is necessary to redirect investment towards compliance with the waste hierarchy, as currently the area in which the least resources are invested in municipal waste management is prevention.

 Payment per generation is a highly effective system for meeting regulatory objectives, but it has only been implemented in less than 1% of Spanish municipalities.
  • Pay-as-you-throw (PAYT) systems are variable pricing systems that apply the polluter pays principle by designing a waste charge in which each user pays according to their actual waste generation. The fee usually consists of a general part (fixed or related to household or taxpayer characteristics) and a variable part (which may be based on weight, actual volume collected, collection frequency or container volume). The variable part creates incentives for users, as it depends directly on waste generation and/or separation. In addition, discounts can be applied to the charge for good behaviour (e.g. participation in composting or use of recycling centres).
Residuos-HyP_C23
  • Payment by generation (PxG) is an effective system for encouraging waste prevention, high levels of separate collection and the reduction of waste sent to landfill. Despite this, it has been very little used by Spanish municipalities to date. The data reported by local authorities on the tax base applied in their fee regulations reveal a lack of knowledge about the concept of pay-as-you-throw (PxG).
  • On the other hand, the assessment made by the Spanish population indicates that the implementation of a pay-as-you-throw system would have an effect on changes in household behaviour. Citizens give PxG an average rating (6/10) and consider it quite or very likely (48%) that they would increase their level of waste separation or recycling if they had to pay according to the amount of waste they generate. This percentage is higher than that which would correspond to the case of paying extra for products with unnecessary packaging (46%), although lower than that of a SDDR (78%). The implementation of a PxG system must be properly designed so that the incentives incorporated into this instrument maximise their effect on waste performance indicators and must also be accompanied by other policies such as information and awareness campaigns.
Residuos-HyP_G29

Methodologies: descriptive statistical analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Promote pay-as-you-go systems and bonuses
  • Ministry for Ecological Transition and Demographic Challenge
    Ministry of Finance and Civil Service
    Autonomous communities
    Local authorities
  • Rejected

Promote the rollout of pay-as-you-throw (PxG) waste collection systems alongside incentives for improved separate collection behaviour.

The deployment of taxes or, where appropriate, non-tax public benefits associated with waste management at the local level should be promoted to ensure that the legally required costs are covered. It is recommended to promote pay-as-you-throw waste systems. In addition, it would be possible to offer bonuses for the use of recycling centres, home composting or waste reuse services, among others.

Although Law 7/2022 provides for the possibility of local authorities establishing both PxG systems and rebates and reductions on waste charges, this is only a guideline. The deployment of these instruments in Spain is very limited compared to other countries with good performance indicators, and the evidence provided in this evaluation demonstrates the effectiveness of these instruments.

 Municipalities that apply an environmental rebate to domestic waste collection fees show higher overall separate collection rates.
  • The main instrument used for revenue collection is fees. Ninety-three per cent of local authorities have a tax ordinance or other specific regulatory ordinance on waste costs, and fees are the main instrument used for revenue collection. Of the municipalities with a specific revenue collection instrument for waste, 88% have fees, 6% have public prices and 5% have non-tax public services. In this regard, local authorities that do not apply any type of environmental rebate have an average separate collection fee of 13.7%, while those that do apply some type of environmental rebate exceed 28%. Despite this, most local authorities (65%) did not change the formula for financing the waste management costs under their jurisdiction during the period 2010-2019. It is estimated that revenue is below 60% of cost coverage.
Residuos-HyP_G27
  • The public shows a high degree of agreement with the existence of environmental tax credits. According to the survey, 70% of respondents agree or strongly agree that households that manage their waste well should be rewarded.
Residuos-HyP_G28

Methodologies: descriptive statistical analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Promote pay-as-you-go systems and bonuses
  • Ministry for Ecological Transition and Demographic Challenge
    Ministry of Finance and Civil Service
    Autonomous communities
    Local authorities
  • Rejected

Promote the rollout of pay-as-you-throw (PxG) waste collection systems alongside incentives for improved separate collection behaviour.

The deployment of taxes or, where appropriate, non-tax public benefits associated with waste management at the local level should be promoted to ensure that the legally required costs are covered. It is recommended to promote pay-as-you-throw waste systems. In addition, it would be possible to offer bonuses for the use of recycling centres, home composting or waste reuse services, among others.

Although Law 7/2022 provides for the possibility of local authorities establishing both PxG systems and rebates and reductions on waste charges, this is only a guideline. The deployment of these instruments in Spain is very limited compared to other countries with good performance indicators, and the evidence provided in this evaluation demonstrates the effectiveness of these instruments.

The content of the technical-economic reports that justify the forecast of domestic waste management costs and the subsequent calculation of the fee is not defined in any legal text. In this context, both the description of the costs and the formula for calculating the fee tend to be insufficient and have been the subject of multiple legal challenges.

Thus, over the years, and even today, both the criteria used to determine the fee (e.g. the volume of water consumed) and the justification of the cost of the service have been controversial from the point of view of their jurisprudential interpretation (see, for example, judgment 382/2016 of the High Court of Justice of the Balearic Islands, judgment 2609/2022 of the High Court of Justice of Catalonia (appeal 1404/2020) or Appeal 2865/2022 before the Supreme Court).

Methodologies: regulatory analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Methodological guide for preparing economic reports for setting rates
  • Ministry for Ecological Transition and Demographic Challenge
    Ministry of Finance and Civil Service
  • Implemented

Develop a methodological guide for preparing economic reports for the establishment of fees.

The ministries responsible for waste management and public finance should draft a methodological guide for the preparation of economic reports on which agreements to establish fees to finance waste management services should be based, in accordance with the revised text of the Law Regulating Local Finances and Law 7/2022 on waste. This guide would make it easier for local authorities to determine the costs associated with waste management in a technically validated manner.

 Landfill taxes are an effective instrument that was only implemented in four autonomous communities in 2019.
  • Four autonomous communities applied a tax on municipal waste disposal in 2019: Catalonia (2003), Extremadura (2012), Castile and León (2013), and the Chartered Community of Navarre (2018). In the Balearic Islands, the tax was approved in 2019 but was not implemented until later. Catalonia was the first autonomous community to introduce this tax, has always had the highest tax rate (€41.30/tonne in 2019) and has been increasing it since its creation to a maximum of €59.10/tonne in 2022.
  • This tax became widespread throughout Spain in 2023 with the introduction of Law 7/2022 on the tax on the deposit of waste in landfills, incineration and co-incineration of waste, which adopts the European Commission’s recommendation on the need to introduce a harmonised tax system on landfilling and incineration, operational throughout the territory.
Residuos-HyP_G22
  • There is ample empirical evidence demonstrating the effectiveness of landfill taxes in municipal waste management. In fact, landfill levels below 10% (the level established in Royal Decree 646/2020 for 2035) have only been achieved in countries with a tax rate higher than €60/tonne.

Methodologies: international benchmarking, comparative analysis, descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Anticipation of the path of tax rates on waste disposal
  • Ministry for Ecological Transition and Demographic Challenge
    Ministry of Finance and Civil Service
    Autonomous communities
  • Rejected

Anticipate the path of tax rates on municipal waste disposal, giving as much advance notice as possible to those responsible for waste management.

Knowing the expected tax increase years in advance helps those responsible for waste management to plan ahead, taking this evolution into account and thus increasing the effectiveness of the tax, as evidenced by the international data collected in this study.

 SDDRs are one of the most effective tools for waste management, but they have not been implemented in Spain.
  • The SDDR is an EPR implementation tool that has not been implemented in Spain during the period analysed, despite the good results obtained in countries where it has been established. In 2021, MITERD carried out a study to analyse the technical, environmental and economic feasibility of implementing an SDDR for beverage containers in Spain. Currently, 14 European countries already have an SDDR in place for beverage containers, covering 144 million people.
  • In Spain, the obligation to implement a SDDR for single-use plastic bottles at the national level is only contemplated if the objectives are not met. Law 7/2011 only contemplated the possibility of establishing a mandatory SDDR if the management objectives set out in the current regulations (Art. 31.2.d) were not met, without specifying what objectives or time frames. Law 7/2022, on the other hand, establishes the obligation to implement an SDDR for single-use plastic bottles at the national level within two years if the targets set for 2023 or 2027 are not met, leaving open the possibility of including other packaging and waste apart from plastic bottles (Art. 59).
  • In this regard, the implementation of an SDDR must take into account the relationship between this instrument and the SCRAPs, mainly because it reduces the volume of materials collected by the SCRAPs, which in turn alters their income and expenditure. The design of the SDDR must consider the compensation to be provided to the SCRAPs for materials subject to the SDDR that are managed by the SCRAPs’ collection and treatment systems.
  • The Spanish population’s assessment indicates that the implementation of a DRRS would be an effective incentive to increase household separation rates. Citizens give SDDRs a high average rating (8.1/10) and consider it quite or very likely (78%) that they would increase their level of waste separation or recycling if they were given a refund for the packaging at the shop where they bought it. Among the different actions proposed to them, citizens indicated that SDDR would be the measure that would have the greatest impact on their separate collection habits.
Residuos-HyP_G20

Methodologies: international benchmarking, descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Implementation of pilot programmes for deposit, return and refund systems (SDDR)
  • Ministry for Ecological Transition and Demographic Challenge
  • Rejected

Launch pilot programmes for deposit, return and refund systems (SDDR).

The ministry responsible for waste or the inter-administrative coordination body for waste should carry out a pilot programme to advance the possible implementation of an SDDR in Spain for certain products.

The MITERD study (Tragsatec, 2021) highlighted the feasibility of implementing an SDDR in Spain, so a pilot programme would be the natural next step.

Law 7/2022 incorporates its implementation in the event of failure to meet waste management targets, so this programme would provide evidence and detect difficulties at an early stage, facilitating and optimising its possible future implementation at national level.

The relationship between SCRAP and SDDR can be complex, but both can coexist with the right public policy (Laubinger, Brown, Dubois and Börkey, 2022), so the pilot programme should pay attention (as far as possible) to the SCRAP-SDDR interrelationship.

 The fees applied by SCRAPs operating in the period 2010-2019 have not promoted eco-design of products by producers.
  • The fees applied by SCRAPs operating in the 2010-2019 period have not promoted eco-design of products by manufacturers, as the cost of waste management has been given greater consideration than its environmental impact, which has made it difficult to recycle these products. Law 7/2022 incorporates the obligation to modulate, for each product or group of similar products, the fees applied by SCRAPs, taking into account their durability, reparability, reusability, recyclability and the presence of hazardous substances, but does not specify to which waste they should be applied (Art. 43).
  • The (eco)modulation of fees for producers facilitates the internalisation of end-of-life costs and strengthens incentives to improve the eco-design of products and packaging. Setting fees at a level that recovers the total cost of end-of-life management for products covered by extended producer responsibility is therefore a key measure, but it is also necessary to integrate the environmental impact of product management once it becomes waste, which is known as eco-modulation.

Methodologies: documentary analysis, individual interviews

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Extension of waste streams subject to extended producer responsibility and definition of minimum eco-modulation criteria
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Expand the waste streams subject to extended producer responsibility (EPR), especially those streams whose management has a high economic cost and which are also difficult to recycle. In addition, it is advisable to define minimum criteria to be met in terms of eco-modulation.

Currently, the EPR obligation is limited only to those waste streams established by European regulations (electrical and electronic equipment (WEEE), batteries and accumulators, end-of-life vehicles, packaging and packaging waste, end-of-life tyres and used industrial oils). Given the high cost of managing certain types of waste and the current low recyclability of some materials, it is considered necessary to extend the EPR obligation to other waste streams, such as textiles, sanitary textiles, furniture and mattresses, among others. Law 7/2022 already incorporates the obligation to develop regulations for EPR for textiles, furniture and household goods within a period of three years from its entry into force.

It is advisable to define minimum criteria to be met in terms of eco-modulation for the different existing or newly implemented EPR schemes. In this regard, Law 7/2022 defines that the financial contribution paid by the producer must be modulated for each product or group of similar products, especially taking into account their durability, whether they can be repaired, reused and recycled, and the presence of hazardous substances, adopting a life-cycle approach.

 There is no competition between SCRAPs for certain fractions.
  • In some cases, for certain fractions, there is no competition and there is only one SCRAP. For example, Ecovidrio is the only SCRAP for glass packaging waste, Ecoembes for light packaging and paper and cardboard waste, and Sigre for medicine packaging waste. This is due, in part, to certain barriers to competition arising from regulations relating to the SCRAP authorisation process.
  • The SCRAP models with greater competition in some European countries, such as France and Germany, are considered successful models, in which competition between SCRAPs has had a positive impact on recycling rates and the provision of services to the population. However, in cases where different SCRAPs coexist for the same type of waste, it is necessary to clearly define the responsibilities of each of them, and they must be coordinated, as stipulated in the regulations, in order to ensure proper waste management. This is already the case for certain WEEE waste, where some SCRAPs have set up coordination offices (OFIPILA and OFIRAEE). These offices in turn facilitate management for administrations that have agreements with different SCRAPs. Another aspect that needs to be taken into account with the existence of several SCRAPs for the same material is to prevent this competition from leading to a reduction in green point fees and a consequent decline in service quality and, therefore, in the results obtained from separate collection and recycling.

Methodologies: individual interviews, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Supervision and control by the Public Administration of SCRAP activities
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Improve the supervision and control by the Administration of SCRAP activities to ensure that they comply with all their regulatory obligations.

Law 7/2022 has already incorporated improvements with the aim of strengthening and ensuring the control of SCRAPs, but it is necessary to ensure that both regional and state administrations carry out their defined obligations to perform this control.

 SCRAPs have greater resources and information at their disposal than local authorities and, in some cases, higher levels of government.
  • The lack of resources in the Administration means that, on occasions, SCRAPs have greater resources and information at their disposal, which indicates a possible market failure due to information asymmetry. This situation is detrimental to the interests of the Administration in negotiations with SCRAPs. This inequality varies depending on the autonomous community and, as AIReF has been able to ascertain through interviews with representatives of local authorities, it is more prevalent in negotiations between SCRAPs and local government.

Methodologies: individual interviews, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Improvement of information and technical capacity of public administrations in negotiations with SCRAPs
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • In progress

Increase the technical capacity and availability of information of the competent authorities to negotiate agreements with SCRAPs on equal terms.

In order to have better information available, the actual costs of managing the different flows of materials subject to RAP should be analysed and this information should be made available to local authorities. For example, a working group could be set up within the Coordination Committee to promote the exchange of knowledge in this area between the different autonomous communities and local authorities.

 The Administration has not exercised sufficient control and monitoring of SCRAP activities.
  • Although current regulations establish mechanisms for controlling SCRAP activity through the annual submission of information on waste managed and audited annual accounts to the Coordination Commission (Art. 32.5, Law 22/20011), there has been no exhaustive control of their activity. This lack of control may be partly the result of the regional administration’s lack of sufficient technical resources to process and analyse the documentation provided by SCRAPs.
  • The MITERD suffers from the same limitation and has also failed to sufficiently verify the information provided by SCRAPs. In the case of packaging, this deficiency should be partially remedied by the creation of a packaging section in the Product Producers Register, which will provide access to data reported directly by producers. Law 7/2022 reinforces this control over SCRAPs by incorporating a section dedicated to the supervision, control and monitoring of extended producer responsibility.

Methodologies: individual interviews, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Supervision and control by the Public Administration of SCRAP activities
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Improve the supervision and control by the Administration of SCRAP activities to ensure that they comply with all their regulatory obligations.

Law 7/2022 has already incorporated improvements with the aim of strengthening and ensuring the control of SCRAPs, but it is necessary to ensure that both regional and state administrations carry out their defined obligations to perform this control.

 The tendering processes for services place constraints on administrations due to their duration, the difficulty of monitoring them, the appeals lodged and the asymmetry in specialisation between municipal technicians and companies.

Long tender processes, difficulties in obtaining sufficiently high-quality specifications, vulnerabilities observed in the award process (high number of appeals), and insufficient resource allocation limit the actions of public administrations.

  • The interviews conducted show that the quality of the specifications is essential for the proper implementation of the model, and they are mostly carried out by municipal workers without sufficient specialisation. Except in large municipalities, the specialisation of staff is usually much lower than that of companies. This translates into deficiencies when preparing specifications, evaluating bids, or dealing with negotiation or conflict resolution processes.
  • Tendering processes are often lengthy, lasting between one and two years, mainly due to reasons intrinsic to the Public Procurement Law and the associated bureaucracy.
  • The high number of appeals lodged against tender documents or awards is a serious factor in delaying the entry into operation of new contractors. According to the experts consulted, this means that the vast majority of contracts are currently still being extended once the contract term has expired.
  • The inadequacy of quality control systems for the services provided. Recently, although still in its infancy, requirements for inspection and control through the sensorisation of elements or certifications are being incorporated, either directly by municipal services or externally (allocating a budget item for monitoring to hire an audit or tendering the control in a separate lot).

Methodologies: individual interviews, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Reallocation of municipal resources
  • Local authorities
  • Rejected

Reallocate resources in local entities to provide staff with greater specialisation in procurement matters in the field of waste management.

The current long deadlines in tendering processes, the difficulty in obtaining sufficiently high-quality specifications, the vulnerability observed in the award process (high number of appeals), and insufficient dedication to monitoring and controlling services make it advisable to allocate more resources to the waste area of local authorities.

 Public administrations did not make sufficient use of green public procurement to promote waste reduction between 2010 and 2019.

During the study period, the various public administrations did not make sufficient use of public procurement to promote waste reduction. When contracting a service or work, purchasing a product or awarding a contract, public administrations have the possibility of incorporating clauses that promote environmental or social sustainability. The evidence observed leads to the conclusion that the inclusion of these clauses to reduce waste generation or encourage better management in line with the waste hierarchy was limited.

  • The MITERD, within the framework of the General State Administration’s Green Public Procurement Plan, promoted the introduction of clauses on the acquisition or use of recycled products in public contracts, as well as other circularity clauses in regulatory or technical documents applicable to the General State Administration.
  • Seven autonomous communities report having promoted, between 2010 and 2019, actions related to public procurement and contracting in the field of municipal waste management. Specifically, these are Aragon, Catalonia, the Valencian Community, the Balearic Islands, La Rioja, the Chartered Community of Navarre and the Basque Country.
  • Nearly a third of local authorities say they do not include clauses that promote environmental or social sustainability, although 44% say they design procurement procedures and specifications with clauses that encourage better management and use of products and materials in line with the waste management hierarchy.

Methodologies: documentary analysis, individual interviews

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Technical quality of tender documents for waste collection services
  • Local authorities
  • Rejected

Improve the technical quality of tender specifications for waste collection services.

Waste collection specifications must be technically sound in order to prevent future costs and problems. The specifications must be evolutionary, allowing for the incorporation of improvements.

 Promoting preparation for reuse by special employment centres and integration companies through reserved contracts is not sufficient on its own.

Promoting preparation for reuse by special employment centres and integration companies through reserved contracts is not sufficient on its own. During the period analysed, the introduction of reserved contracts for social entities engaged in preparation for reuse operations has not led to an increase in public procurement from social entities. According to the information obtained in the interviews conducted, reserved contracts are an instrument whose limited scope does not yet allow for evaluation by the main actors. The promotion of PxR through social integration entities requires robust formulas in the commercial and social spheres to ensure that these types of organisations remain in the market. In the specific case of textile waste, Law 7/2022 (nineteenth additional provision) requires that at least 50% of the amount awarded in public administration contracts for textile waste management be through reserved procurement from integration companies and special employment centres of social initiative, authorised for waste treatment. However, representatives of the sector associate the increase in contracts with the increase in waste management policies rather than with the use of this figure.

Methodologies: documentary analysis, individual interviews

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Ensure compliance with the contract reserved for special employment centres and integration companies.
  • Local authorities
  • Rejected

Ensure compliance with the existing reserved contract for promoting preparation for reuse by special employment centres and integration companies through monitoring and reporting mechanisms.

Monitoring and control mechanisms should be introduced to ensure compliance with the percentages of reserved contracts through periodic audits that verify compliance with the requirements, as well as monitoring the quantity of products reused or prepared for reuse. It would also be useful to provide local councils with information on the functioning of this type of contract, as well as reserved contract templates.

 The scarcity and quality of recovered and recycled materials influence competition and economic conditions in the market.
  • The low quality of municipal waste collected has a negative impact on the activity of waste collectors and limits the uses of recycled materials. Ensuring the quantity and quality of waste streams reaching recyclers provides stability to the recycling market. According to the evidence obtained from the interviews conducted, the high content of inappropriate materials in the different fractions makes it difficult to incorporate them into recycling processes. It is expected that there will be increasing demand for quality waste to obtain secondary raw materials that can be used for higher value-added purposes.
  • There is domestic demand for high-value recycled materials, such as metals, paper-cardboard and plastics, but there is fierce competition with the price of virgin raw materials. During most of the analysis period, a significant flow of waste—especially lower quality waste—was exported, but with some countries banning waste imports, especially since 2018, and European restrictions on waste exports, the domestic and European market for recycled materials is struggling to absorb all the waste.
  • A large amount of technically recoverable waste ends up in landfill or incinerators because the economic conditions for its recovery do not exist.
  • During the period 2010-2019, there was no obligation to incorporate recycled material into products. With the obligation to incorporate recycled PET from 2025 onwards, it is estimated that there will not be enough supply of recycled PET (food grade) on the Spanish market to meet the state’s recycled PET production targets. The recycled PET production targets generate a demand for rPET from the food industry that is currently not being met on the Spanish market. According to the Centre for Innovation and Development for the Circular Economy, Spain needs to double its production of recycled plastic to meet the demand from the food industry. There is a mismatch between supply and demand for food-grade rPET: the PET bottle sector would need 54 kilotonnes of food-grade rPET, and installed capacity does not exceed 35 kilotonnes.

Methodologies: individual interviews, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Implementation of efficient collection systems and setting of targets for the incorporation of recycled materials.
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Implement efficient collection systems and set targets for incorporating recycled materials, with the aim of obtaining high-quality recycled material.

Improvements must be made to collection and treatment systems, in line with other proposals in this study, and targets must be set for incorporating recycled materials into the production of new products and reducing the levels of unsuitable materials in the different collection fractions.

  •  
    Establishment of economic instruments to promote more competitive prices for recycled materials
  • Ministry of Finance and Civil Service
    Ministry for Ecological Transition and Demographic Challenge
  • In progress

Establish taxes on virgin materials or other economic instruments to promote more competitive prices for recycled materials.

It would be effective to implement economic instruments such as taxes on virgin materials to help promote more competitive prices for recycled materials in relation to virgin raw materials, which would enable the consolidation of recycled material markets. Other economic instruments could also be considered, such as financial support or the inclusion of sustainable criteria in public procurement.

  •  
    Reduction of inappropriate waste through improvements in collection systems and sorting plants
  • Local authorities
    Autonomous communities
  • Rejected

Improve collection systems and the sorting capacity of sorting plants, with the aim of reducing inappropriate items in municipal waste and increasing the quality of materials that reach recyclers.

With regard to collection systems, Law 7/2022 already recognises the need to prioritise more efficient collection models, although it does not establish any obligations. In this regard, local authorities could be required to implement an efficient selective collection system or be required to achieve a separate collection ratio as a condition for receiving government funds for municipal waste management.

At the sorting plant level, technologies should be improved to increase the percentage of material recovery and the quality of the recovered material by investing in advanced technology that incorporates artificial intelligence systems and real-time monitoring and tracking systems to control plant performance.

 Spain has one of the most concentrated waste markets in Europe.

There is a negative correlation between market concentration and recycling rates. Countries with higher market concentration, as measured by the Herfindahl-Hischmann index, have lower rates of preparation for reuse and recycling, although some countries with low market concentration also score poorly on this waste performance indicator.

Spain has one of the most concentrated waste markets in Europe, especially in the waste collection subsector, which may be a limiting factor in achieving regulatory objectives.

  • The operating income concentration curve shows that in Spain, 20% of business groups account for almost 90% of operating income in the waste sector, the highest figure among neighbouring countries.
  • The market share of the three largest business groups in the sector in Spain represents 67.9%, while in other countries the market share of the three largest companies represents 21.6% in Germany, 40.2% in France, 14.9% in Italy and 24.3% in Portugal.
  • In Spain, half of the turnover corresponds to 0.5% of companies. In contrast, at European level, half of the turnover corresponds to 7% of companies.

Methodologies: exploratory data analysis, international benchmarking, distributive analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Ensuring competition in the waste management market
  • Ministry for Ecological Transition and Demographic Challenge
  • Implemented

Ensure competition and facilitate the creation and incorporation of companies in the waste market in order to diversify the range of players and prevent market concentration in a few companies.

The implementation of measures to ensure competition and facilitate the creation and incorporation of companies in the waste sector is proposed. For example, a well-defined and uniform legal framework for the creation and authorisation of companies in the sector throughout the territory, clear, precise and transparent tendering procedures, incentives for innovation that promote the transition to a circular economy that prioritises the reuse, recycling and recovery of waste, as well as material auction processes with transparent award criteria.

 Insufficient allocation of resources to urban waste management and lack of staff specialisation

The insufficient allocation of resources to waste management at different administrative levels, as well as the lack of greater specialisation among the personnel assigned to this task, poses a challenge to achieving the objectives set.

As has been confirmed in various interviews with administrations at the state, regional and local levels, in all cases there has been a lack of human and financial resources allocated to waste management to comply with the recently approved regulatory framework and to achieve the objectives derived from it. It is worth noting the differences in the allocation of human resources, both between autonomous communities and between municipalities. In the case of local councils, as the bodies responsible for providing the service, it will be difficult for them to comply with the obligations established by the regulations with the level of resources available for waste management and the degree of technical specialisation of the staff assigned (Fundación CONAMA, 2021). Local authorities must have qualified personnel to implement and maintain an efficient waste management system and, in turn, have the authority and capacity to supervise performance and ensure compliance at all levels (The World Bank, 2021).

Methodologies: individual interviews

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Allocation of resources for specialised personnel at municipal level
  • Local authorities
  • Rejected

Allocate human and financial resources within the local administration to ensure proper waste management and guarantee the training and education of the personnel assigned to this service.

It is necessary to reallocate human and financial resources within the local administration to waste management services in order to facilitate the achievement of regulatory objectives. It is also necessary to ensure the specialisation of the technical personnel assigned, and to this end, the selection and transfer processes for civil servants assigned to waste management functions must ensure that the person has the necessary training and specialisation to perform their tasks effectively.

 There is no evidence that the current distribution of powers hinders the achievement of regulatory objectives, although cooperation should be strengthened.
  • There is no evidence that the current distribution of powers hinders the achievement of regulatory objectives, although coordination between the different actors involved in the process should be strengthened. For example, there are no differences in the percentage of separate collection between municipalities that manage waste collection directly or indirectly. The median separate collection rate in municipalities with direct management is 14.2%, while for those with indirect management it is 14.5%. However, the dispersion of responsibilities without coordination poses a risk, as it can lead to fragmented policies, poorly defined roles and responsibilities, weak monitoring and supervision mechanisms, or a lack of accountability for results.
  • There is poor implementation of the powers of each administration and a lack of control over their execution.
  • The provision of waste collection and/or treatment services in partnership tends to lead to a disengagement and delegation of responsibilities on the part of local councils, which often results in a loss of information that can undermine the effectiveness and efficiency of service provision. In 2019, 40% of municipalities collected at least one fraction of waste through a supra-municipal entity. The existence of economies of scale in these services makes this supra-municipal level ideal, as it allows for more efficient management in terms of control and technical resources, as well as economically. However, it also presents a risk. It tends to generate a disconnection and delegation of responsibilities on the part of local councils, which often leads to information losses. Ultimately, this can undermine the effectiveness and efficiency of service provision. Supramunicipal entities provide services to municipalities of very different natures, so each local council must remain connected to this management.

Methodologies: descriptive statistical analysis, regulatory analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Municipal monitoring mechanisms in joint management
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • Rejected

Establish monitoring mechanisms to ensure the commitment and participation of local councils in cases where waste management is provided by a supra-municipal entity.

To encourage the involvement of local councils in the management of services provided in partnership, autonomous communities could establish mechanisms such as the obligation to report information on separate collection at municipal level.

  •  
    Coordination mechanisms between different public administrations
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Implemented

Establish mechanisms to ensure coordination between the different administrations with the aim of guaranteeing efficient and effective management and avoiding duplication in the exercise of powers, while also ensuring greater communication between them and standardising, as far as possible, the different procedures defined.

It is necessary to establish stable channels of communication and information exchange between the different public administrations involved in municipal waste management.

The Coordination Commission, whose main function is cooperation and collaboration between administrations, could respond to these needs.

 The wording and content of waste management regulations do not facilitate the deployment of municipal services, and it has even been shown that their implementation does not have a significant impact on separate collection.
  • In general, the way in which general management ordinances are drafted, as well as their content, does not facilitate the deployment of municipal services associated with waste management. The ordinances are mostly drafted with little adaptation to the particular reality of the municipality, with basic content and based on public participation processes that are still in their infancy.
  • There are a significant number of municipalities without municipal ordinances regulating the service, and those that do exist were mostly approved before Law 22/2011 and have not been updated. According to the questionnaire sent to municipalities, as of February 2023, 28% of municipalities still do not have waste management ordinances. And among the municipalities with ordinances, in 69% of cases, these were approved before Law 22/2011. In addition, 60% of municipal waste management ordinances have not been updated since their initial approval. On the other hand, in 13% of cases, the ordinance corresponds to a supra-municipal entity.
  • Likewise, monitoring of the implementation of ordinances and programmes is scarce, since around 60% of local councils state that they have not designed any monitoring mechanisms (indicators or other) for the implementation of the provisions contained in the ordinances and/or programmes.
  • The AIReF’s counterfactual econometric exercise to measure the causal relevance of ordinances leads us to conclude that the implementation of regulations on collection through municipal ordinances does not have a significant impact on the percentage of separate collection at the municipal level. Both the standard estimator of the econometric difference-in-differences method and the robust estimator for heterogeneous treatment effects (Callaway and Sant’Anna) show no differential behaviour in the percentage of separate collection between municipalities that adopted ordinances and those that did not.

Methodologies: descriptive statistical analysis, individual interviews, exploratory data analysis, difference in differences

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Adoption or updating of regulatory ordinances
  • Local authorities
  • Rejected

Adopt, where they do not exist, or update, where they are not recent, the regulations governing waste management services.

When drafting or updating the regulations governing waste management services, the following aspects, among others, should be considered:

  • A sufficient description of the services, the containerisation elements and the associated technology (bins, bags, containers, identification tags, etc.) for each area of the municipality/territory.
  • Determination of the rights and duties of citizens and commercial activities, as well as those of the local authority.
  • Listing of offences and classification into different levels of severity, together with the determination of applicable penalties.
  • For those aspects that may need to be updated more frequently (e.g. calendar, schedules, utensils, etc.), it is recommended not to include the details in the management ordinance, but to use another information channel available to service users to publish them.
  •  
    Mechanism for coordinating and supporting municipal waste management
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Promote a coordination and support mechanism or a specialised body for municipal waste management, involving central and regional governments, as well as local authorities, to promote excellence in management and support local authorities in implementing their municipal waste management responsibilities.

Municipal management, whether led by individual councils or by supra-municipal entities, has a very significant impact on municipal waste management. The existence of a coordination mechanism with specialised technical capabilities would enable support to be provided to local authorities in the development of their powers, promote excellence in the implementation of instruments and address the weaknesses identified in this study in the area of municipal management.

The support provided by this mechanism could be in the form of:

  • Waste management and tax regulations, municipal management and prevention plans, and tender specifications.
  • Compilation of data on waste management and educational dissemination of best techniques and calculation methodologies.
  • Training for local authority employees on matters relating to municipal waste management.
  • Advice on the management of recycling centres.
  • Support in the investigation of disciplinary proceedings.

Germany and France, for example, have state-level public bodies that share the function (with different nuances) of advising public management from a centralised specialisation in a public body. Germany has a state environmental agency (Umweltbundesamt – UBA) which, among other functions, uses its expert knowledge to advise the administration on the exercise of public management. In France, the Agency for Ecological Transition (Agence de la transition écologique – ADEME) supports public environmental management and includes a territorial approach. One of its functions is precisely to support local communities in the transition to a circular economy.

In Spain, there is no state-level body focused on waste prevention and management with characteristics and powers similar to those proposed for a possible new coordination and support mechanism. However, in Catalonia, a specialised public law entity, the Agència de Residus de Catalunya, attached to the department of the Generalitat responsible for the environment, which in 2023 has around 200 employees, centralises the autonomous community’s functions in the field of waste and includes in its service charter advice to local authorities on waste prevention and generation. This agency is not owned by other administrations, although its Board of Directors is made up of various departments of the Generalitat, the two associations representing local authorities and various business, trade union and environmental organisations, among others.

 Only 10% of local authorities have approved prevention programmes and/or waste management plans.

In the strategic sphere, only 10% of local authorities made use of the provisions of Law 22/2011 for local authorities to programme waste prevention and plan its management. In 2019, only 5% of municipalities had a unique (non-joint) municipal waste prevention programme and 3% had management plans, according to data obtained from the questionnaire sent to municipalities.

Methodologies: documentary analysis, descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Support for local authorities in drafting waste prevention and management programmes and plans
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Coordinate regional or national initiatives to support local authorities in facilitating and promoting the drafting of waste prevention and management programmes and plans.

The low level of planning could be due, at least in some cases, to local authorities lacking experience in developing these instruments. Technical support from another administration with greater capacity could accelerate their development, approval and implementation.

 Between 2010 and 2019, the autonomous communities made limited use of the penalty system.

Between 2010 and 2019, the autonomous communities made limited use of the penalty system.

  • Only ten autonomous communities report having imposed penalties for non-compliance related to municipal waste management. In 2019, these autonomous communities initiated a total of 1,466 disciplinary proceedings for a total amount of €4.5 million and an average amount of €3,075. However, there are considerable differences between autonomous communities, with Catalonia and the Valencian Community standing out in terms of both the total amount and the average amount of penalties per inhabitant. A high percentage of the penalties (17.6% of the amount and 15.5% of the proceedings) are associated with the absence of a licence, authorisation or mandatory notification, as well as the absence of bonds or guarantees for the performance of the activity and non-compliance with the provisions of the licences and authorisations.

Methodologies: exploratory data analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Effective application of control, inspection and sanction mechanisms
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Effectively apply existing regulatory control and inspection mechanisms and, where appropriate, apply the corresponding penalty system.

The State, autonomous communities and local authorities should effectively apply control, inspection and penalty instruments at the different stages of municipal waste management, as this study has found that these instruments are used to a limited extent.

 The MITERD has not imposed any sanctions on the autonomous communities for non-compliance in municipal waste management.
  • At the national level, MITERD has not imposed any penalties on autonomous communities for non-compliance in municipal waste management, although it does monitor compliance with regulations.

Methodologies: documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Effective application of control, inspection and sanction mechanisms
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Effectively apply existing regulatory control and inspection mechanisms and, where appropriate, apply the corresponding penalty system.

The State, autonomous communities and local authorities should effectively apply control, inspection and penalty instruments at the different stages of municipal waste management, as this study has found that these instruments are used to a limited extent.

 The maximum percentages of inappropriate materials in separately collected biowaste established in Law 7/2022 are not sufficient to meet the minimum quality standards for compost production established by MITERD.

The maximum percentages of unsuitable materials in separately collected biowaste established in Law 7/2022 are not sufficient to meet the minimum quality standards for compost production established by MITERD in 2013 and ensure high-quality compost with sufficient market outlets.

  • Law 7/2022 of 8 April on waste and contaminated soil for a circular economy (LRSC) established a maximum percentage of unsuitable materials allowed in the biowaste fraction of 20% from 2022 and 15% from 2027 (Art. 25.4.). However, as established by MITERD itself, the recommended percentage of unsuitable materials in biowaste is less than 5% and preferably less than 1-2% by weight, since when the level of unsuitable materials is high (10-20% or more), quality deteriorates due to the transfer of contaminants and additional difficulties arise in treatment. There is a relationship between the low quality of compost produced from biowaste and the presence of unsuitable materials in separate collection, where plastic packaging (3.2%), plastic bags (1.5%) and paper (1.4%) stand out as the predominant unsuitable materials.

Methodologies: documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Creation of a state quality seal for compost
  • Ministry for Ecological Transition and Demographic Challenge
  • Rejected

Create a state seal that certifies compost in terms of quality.

This certification should include parameters such as heavy metal content, stability and maturity, as well as the rate of nutrient release into the soil, and establish the possible uses and applicable quantities based on these parameters.

  •  
    Progressive reduction of maximum percentages of unsuitable candidates
  • Ministry for Ecological Transition and Demographic Challenge
  • Rejected

Progressive reduction of the maximum percentage of inappropriate items in separately collected biowaste.

Making use of the possibility provided for in Article 25.4 of the LRSC, the maximum percentage of unsuitable waste allowed should be reduced from 20% in 2022 and 15% in 2027 to the percentages recommended by the Ministry for Ecological Transition and Demographic Challenge (2022) of less than 5% and preferably less than 1-2% by weight.

 Only three autonomous communities regulated waste traceability in their regulations on waste managers in 2019.

Only three of the nine autonomous communities that reported having some form of regional regulation of waste managers in 2019 regulated traceability (the Balearic Islands, Galicia and the Basque Country), which is a key element in understanding waste transformation and trade processes. More stringent regulation of traceability during the different phases of waste management would mean greater control over infringements in transport, illegal waste collection or the sale or transfer of waste under irregular conditions, which between 2010 and 2019 accounted for only 2.6% of the disciplinary proceedings carried out and 0.9% of the amount of penalties declared by the autonomous communities It could also mean greater control over infringements such as the abandonment, dumping, storage or uncontrolled disposal of waste.

Methodologies: documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Mechanisms for monitoring the recycling process of certain materials
  • Autonomous communities
  • Implemented

Establish mechanisms to improve the monitoring (traceability) of the recycling process for certain materials and, in general, of all phases of municipal waste management.

The autonomous communities should establish regulations for waste managers and technical mechanisms to ensure the traceability of waste in the various municipal waste management processes, which would allow greater control over infringements such as the illegal transport or collection of waste or the sale or transfer of waste under irregular conditions, in addition to others linked to the abandonment, dumping, storage or uncontrolled disposal of waste.

 The existence of obligations to pre-treat waste prior to landfill contributes to the achievement of recycling targets.
  • The existence of obligations for pre-treatment of waste prior to landfill by the autonomous communities contributes to the achievement of recycling targets, but is not sufficient to achieve improvements in reducing landfill without pre-treatment. The eight autonomous communities that had regulatory pre-treatment obligations in 2019 for the remaining fraction or for all fractions destined for landfill had an average recycling rate of 40.1%, which is higher than the average for autonomous communities without pre-treatment obligations (35.1%). At the same time, the average landfill of waste without pre-treatment in the autonomous communities with pre-treatment obligations was, in 2019, 13.9% of the total waste generated (7.2% if the Community of Madrid is not considered), while in the autonomous communities without this requirement it reached, on average, 12.0% of the total waste generated.

Methodologies: descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Consistency between pre-treatment obligations and the existence of sufficient capacity
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Accompany the establishment of pre-treatment obligations for waste destined for landfill with other measures that ensure sufficient capacity at treatment facilities.

 Not enough importance has been given to waste prevention, especially the prevention of food waste.
  • Despite progress, insufficient importance has been given to waste prevention. Regulations and strategies have proven insufficient to guarantee what is proclaimed as the preferred action in the field of waste. Many of the non-quantitative prevention targets are included in plans and strategies as a general guideline for their achievement, without this being decisive in reducing waste generation. Although the most recent regional and national waste laws pay greater attention to the practical implementation of the waste hierarchy, waste prevention requires cross-cutting and related regulations. In this regard, eco-design or product repair policies, for example, are not represented in the few legal and strategic provisions that have sought to promote prevention until 2019.
  • Food waste, the reduction of which is of great importance in relation to municipal waste, was not incorporated into the regulatory provisions between 2010 and 2018, beyond including in Law 22/2011 a reference to measures aimed at preventing food waste and promoting responsible consumption, as an example to be integrated into prevention plans. It was not until 2019 that this issue began to be mentioned in the regulations, linked to responsible consumption or the containment of waste in the food supply. More recently, Law 7/2022 provides for measures such as the promotion of food donations and other types of distribution for human consumption.
  • All this despite the fact that citizens consider certain obligations or prohibitions that seek to promote reduction and reuse to be useful.
Residuos-HyP_G11

Methodologies: documentary analysis, descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Investment geared towards compliance with the waste hierarchy
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Implemented

Direct investment towards compliance with the waste hierarchy, giving greater weight to priority levels (prevention and reuse).

It is necessary to redirect investment towards compliance with the waste hierarchy, as currently the area in which the least resources are invested in municipal waste management is prevention.

 The autonomous communities that established mandatory separate collection of organic waste prior to the state regulations show better results in separate collection.
  • In the five autonomous communities that had established this obligation in 2019, separate collection of bio-waste accounted for 9% of total generation and 31.4% of overall separate collection, while the Spanish average was 5% and 23.3%, respectively. On the other hand, most of the autonomous communities that have included this obligation have accompanied it with other public policy instruments.
Residuos-HyP_C14

Methodologies: descriptive statistical analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Effective obligation to separately collect organic waste
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • In progress

Enforce the obligation to separate organic waste collection.

The obligation to separate organic waste collection introduced in Law 7/2022 is key to improving overall results, but it must be accompanied by regulatory and economic instruments (e.g. positive economic returns based on separate collection, as established in Catalonia with the ‘landfill tax’, subsidies and grants), together with information and awareness-raising instruments, to ensure its proper implementation.

 The mandatory separate collection of new waste fractions established in Law 7/2022 will be a new challenge for the autonomous communities.
  • The implementation of mandatory separate collection of new waste fractions established in Law 7/2022 will be a new challenge for the autonomous communities. However, some of them already had separate collection obligations for these fractions. For example, five autonomous communities (Catalonia, Valencia, Madrid, Navarre and the Balearic Islands) already had mandatory separate collection of organic waste, four had obligations for used vegetable oils (Community of Madrid, Valencian Community, Chartered Community of Navarre and Balearic Islands) and three for textile waste (Community of Madrid, Chartered Community of Navarre and Balearic Islands).
Residuos-HyP_C13

Methodologies: documentary analysis, regulatory analysis, individual interviews

  • Proposals
  • Organism
  • Status according to Agency
  •  
    There are no associated proposals.

There is no proposal associated with this finding.

 The difficulty in achieving the objectives does not lie in a lack of clear guidelines in the regulations and strategies.

The difficulty in making progress towards achieving waste management objectives has not been due to a lack of clear guidelines in regulations and strategies, which offer precise quantitative targets with appropriate timelines.

  • An examination of the 708 quantitative targets, which have been individualised and systematised for the purposes of this study, reveals that they are well described and mostly quantified in terms of percentages of weight, collection volume, etc., and are mainly set out in legally binding regulations.
  • Therefore, their achievement can be demanded of the public actors whose competences are decisive in achieving them. Despite this, only four autonomous communities (Catalonia, the Basque Country, the Valencian Community and La Rioja) have achieved two of the main quantitative targets, namely recycling and landfill.

Methodologies: documentary analysis, regulatory analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    There are no associated proposals.

There is no proposal associated with this finding.

 Only 45% of strategic documents include sections with information on funding and budgetary resources for the planned measures.
  • The allocated budget and the adoption of planned measures for waste management and prevention are decided separately. Although strategic documents are not suitable for recording budget items, only 45% include sections on financing, budgetary resources or other provisions in this regard. The lack of provision for the budgetary support needed to implement what is planned could be a weakness. This avoids establishing budgetary commitments in the plans themselves and leaves the resources to carry out the planned measures to depend exclusively on budgetary availability.

Methodologies: documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Quantification of necessary expenditure and income in strategic documents
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Rejected

Include quantification of the public expenditure and revenue necessary to achieve the forecasts in the plans or programmes.

Law 7/2022 on waste, when ordering the preparation, evaluation or content of prevention programmes or management plans and programmes by the competent authorities, only includes a reference to the means of financing in the case of planning the closure or opening of waste facilities.

In line with the principles of good regulation set out in Law 39/2015 on the Common Administrative Procedure of Public Administrations, plans and programmes, insofar as they affect present or future public expenditure or revenue, should be quantified in order to assess their impact and effects. Combining waste prevention and management planning with associated cost calculations and budget forecasts could increase their degree of implementation.

 Less than half of the autonomous communities had their own waste legislation during the period evaluated (2010-2019), leaving local authorities without waste management regulations to apply.
  • Between 2010 and 2017, only five autonomous communities (Catalonia, the Canary Islands, Valencia, Madrid and Galicia) had their own waste laws, and the Basque Country had an environmental protection law that included a chapter on waste. Although Andalusia and Cantabria did not pass their own laws, they did approve regulations governing certain aspects of municipal waste management. The rest implemented their waste policy without specific regional regulations and used the national law as their sole legislative reference. Since 2018, four additional autonomous communities have passed regional waste laws (Navarre, the Balearic Islands, Castile-La Mancha and Andalusia).
  • In general, the territorialised regulation of competences set out in regional waste laws facilitates greater adjustment to the nature of local authorities in each autonomous community, since neither the nature of local authorities nor supramunicipal groupings are homogeneous throughout the state. This simplifies the implementation of waste management policies by local authority officials. Planning instruments are also more precisely defined in these cases, where the characteristics have been detailed by a law that is more specific to the territory itself.

Methodologies: documentary analysis, regulatory analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Determination of the applicable standard for municipalities without ordinances in autonomous communities without their own waste legislation
  • Ministry for Ecological Transition and Demographic Challenge
  • Rejected

Complete the eighth final provision of Law 7/2022 so that there is no room for interpretation as to which regulation should apply in the event that a municipality located in an autonomous community without its own waste law lacks an ordinance.

 Spain has exceeded the transposition deadlines established in the European Union’s waste directives.
  • Spain has repeatedly exceeded the transposition deadlines established in European Union directives. Law 22/2011 exceeded the deadline for transposing Directive 2008/98/EC (12 December 2010) by more than six months, while Royal Decree 293/2018 of 18 May on reducing the consumption of plastic bags was approved a year and a half after the date set out in Directive (EU) 2015/720, which it transposed (27 November 2016). The approval of Law 7/2022 on waste and contaminated soil for a circular economy has also followed this trend, since the deadlines set out in the transposed directives ended on 5 July 2020 and 3 July 2021, and the law was approved on 8 April 2022.
Residuos-HyP_C11
  • In some cases, the approval of regional management plans (mandatory under Law 22/2011) was also delayed, as was the drafting of a national strategy on the circular economy. It was necessary to face an EU infringement procedure (2018), since Aragon, the Balearic Islands and the Community of Madrid had not approved their management plans, in accordance with the provisions of the directives.

Methodologies: documentary analysis, regulatory analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    There are no associated proposals.

There is no proposal associated with this finding.

 The reporting of cost information by local authorities is confusing and misleading.

There is a confusing and misleading cost report by local authorities, as the subdivision of programmes to which the expenditure should be attributed does not comply with the definitions in the sectoral waste legislation.

The ministerial order establishing the structure of local authority budgets sets out a subdivision of programmes to which waste management expenditure should be attributed that does not comply with the definitions in sectoral legislation. Specifically, it includes, within Expenditure Area 1 (Basic public services) and Expenditure Policy 16, programme number 162, which corresponds to ‘Waste collection, management and treatment’. In turn, within this, it classifies three programmes:

  • 1621: Waste collection.
  • 1622: Urban solid waste management.
  • 1623: Waste treatment.

In this context, there is confusion when it comes to differentiating between the costs of ‘collection’, “management” and ‘treatment’ in municipal budgets. According to reports received from municipalities and data available from CESEL and CONPREL, the distinction between management and treatment is unclear to municipalities.

Local authorities do not have clear criteria for allocating expenditure to the appropriate programme, depending on whether it relates to waste collection, management or treatment. This confusion is a logical consequence of the fact that the various sectoral waste regulations refer to different concepts for the same action and, in some cases, lack definition.

Residuos-HyP_C10

The recording of transfers made by municipalities to supra-municipal entities to pay for waste management and treatment services is inconsistent, which often prevents the correct traceability of costs. Evidence has been found in the sample data from local entities and in CONPREL that reporting is frequently done within programme 94, where transfers to other public administrations are grouped together in aggregate form and where it is not possible to trace the amounts relating to waste management. According to the interview conducted with the Ministry of Finance, this practice may stem from the fact that municipalities agree on a single joint payment for various services that would be recorded in a single transfer to the same supra-municipal entity (e.g. waste, social services, water, etc.).

There is confusion when it comes to differentiating between revenue from ‘collection’ and ‘treatment’ fees in municipal budgets. It is common for municipalities to charge a single fee for collection and treatment, so it is common for municipalities to record all revenue in one of the two categories of collection (301) or treatment (302), even though the taxable event includes both. This prevents the traceability of revenue and the accurate calculation of the cost coverage of these services.

Methodologies: descriptive statistical analysis, documentary analysis, regulatory analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Allocation of amounts collected through financing instruments for collection and treatment services to their corresponding accounts
  • Ministry of Finance and Civil Service
    Local authorities
  • Rejected

Correctly allocate the amounts collected by financing instruments (fees, public prices or non-taxable public property benefits) for collection and treatment services to their corresponding separate collection and treatment accounts.

Waste tax regulations clearly and unambiguously establish the taxable event for the fee, which may cover collection, treatment or both services. When there is only one concept in the taxable event, the allocation of the income to the corresponding account code for budgetary purposes (302 for collection, 303 for treatment) is direct. In the very common case where the taxable event covers both concepts, the way in which the income is allocated to each of the concepts should be specified in the economic reports accompanying the tax regulations. As Law 7/2022 provides in Article 11 that municipalities must implement non-tax public fees or charges that must also cover management costs, specific monitoring by the ministry responsible for tax matters would be advisable to ensure consistency between the financial reports and the budget report.

  •  
    Coding of transfers between local authorities in specific waste programmes
  • Ministry of Finance and Civil Service
    Local authorities
  • Rejected

Establish the obligation to code transfers made to supra-municipal entities with specific waste programme codes.

Transfers made from municipalities to supra-municipal entities for waste collection and/or treatment should be recorded separately from other transfers in Chapter IV of programme codes 1621, 1622 and 1623, as appropriate. To ensure the correct traceability of amounts relating to waste management, these costs should not be added to programme 94 by grouping waste costs with transfers to other public administrations.

  •  
  • Ministry of Finance and Civil Service
  • Rejected

Link budgetary concepts and programmes relating to municipal waste management with the definition of these terms in specific waste regulations.

It is necessary to revise Order EHA/3565/2008, of 3 December, which approves the structure of local authority budgets, so that expenditure programmes relating to municipal waste management are associated with concepts that correspond to the definitions contained in State Law 7/2022 on waste.

Specifically, for the purposes of the classification used in local authority budgets, the concepts of ‘collection’ and “treatment” should coincide with those of Law 7/2022 on waste, and the concept of ‘management’ should disappear, as it covers all other phases.

The order should also be adapted to the waste management model outlined in European guidelines and provide for municipal spending programmes to differentiate between items associated with waste prevention and those associated with preparation for reuse.

 The report on municipal waste collection data contains gaps and discrepancies, showing considerable heterogeneity and indicating insufficient staffing and/or training in this area.
  • The capacity of autonomous communities and municipalities to collect and report municipal waste collection data is limited and uneven, with discrepancies between the two sources, according to the separate collection data compiled in specific information requests sent to all autonomous communities and a representative sample of municipalities.
  • The capacity of municipalities to report information on the configuration of the collection and/or treatment service is limited and indicates insufficient staff and/or training in waste management. Only 27% (160/598) of the municipalities contacted have satisfactorily reported the minimum information considered necessary on separate collection. These 160 municipalities only report complete series (the 15 collection fractions for all years in the period 2010-2019) in 54% of cases. On the other hand, only 55.7% provided complete information on collection entities, and 39.6% on treatment entities, including a high proportion of incorrect responses.
  • The responses received from both the autonomous communities and the municipalities reveal that the use of EWC codes is not fully integrated into the process of compiling municipal waste statistics. The difficulties observed in assigning the quantities collected to the corresponding EWC code, as well as common confusion between codes in the report, reveal that EWC coding is not used as a standard in the official recording of municipal waste management data in local councils and autonomous communities. In addition, there are multiple informal names for the different waste fractions (e.g., organic for all biodegradable waste from kitchens and restaurants and vegetable fraction, using ‘blue’ instead of cardboard to refer to the container where the waste is collected, or calling ‘plastic’ all light packaging), which contributes to inconsistent reporting by the authorities.
  • The autonomous communities have reported the requested information with significant gaps in the spatial dimension, in the separate collection fractions or in the time series. Only Catalonia has reported data for all fractions at the municipal level and for the period 2010-2019. Five other autonomous communities also provided information at the municipal level for the entire period, although not for all fractions. The information provided at the municipal level for 2019 would cover 53.8% of the population and 32.6% of entities, although not for all fractions.

Methodologies: descriptive statistical analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Training and specialisation of public workers involved in municipal waste management
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
    Local authorities
  • Implemented

Strengthen professional training and specialisation for workers involved in municipal waste management at regional and local level.

Aspects related to regulations and objectives, management, information gathering and reporting, service costs and financing, and models and instruments should be reinforced.

  •  
    Creation of an integrated waste management information system
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Creating an integrated information system on waste management in Spain with a clear and common methodology for all public administrations is a key tool for properly monitoring performance, evaluating the different instruments applied, and designing public policy measures.

This system should be centralised and collect information using a clear methodology that is common to all public administrations. The minimum information it should include is:

  • Data collected at least annually for the 15 fractions that make up municipal waste in Spain and with a spatial dimension, at least at the municipal level, regardless of whether the service is provided by a supra-municipal entity.
  • Collection models applied (e.g., door-to-door, containers, etc.) with spatial detail and population served by each model.
  • Infrastructure available for the provision of the service.
  • Details on the form of management and governance.
  • Costs of providing the service.

According to consultations with MITERD, the E-Sir database is being designed to enable the extraction of this data from the information reported by waste managers, which could cover part of the information proposed for this observatory.

 The degree of transparency in waste management performance has limitations.

Performance monitoring for all targets is available online. However, the methodologies and underlying data for the calculations are not available, or only partially so.

Residuos-HyP_C7

There are limitations to the transparency of Spain’s performance in relation to the target for preparation for reuse and recycling. Although the data used to make the calculations are publicly available in detail, this document has limitations from the point of view of transparency:

  • It does not explain the methodology used or how the calculations are made in terms of what the numerator is, what is considered ‘recycled’ for each fraction, what the denominator is, etc.
  • No explanation is given about the base data and the transformations made.
  • No mention is made of the methodology and results of the data provided by the INE (Spanish National Statistics Institute) and the possible discrepancies between these data and those from other sources.
  • In the regional performance chart, the interpretation is not clear if the fractions that make up the numerator are not known in advance.

The report on the autonomous communities for calculating Spain’s performance against the municipal biodegradable waste disposal target is not very transparent. The publication by MITERD does not present a breakdown by autonomous community or methodological instructions on how to calculate the indicator.

Residuos-HyP_C8

Methodologies: documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Public access to source data and methodologies applied
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Allow public access to source data and clear disclosure of the methodologies applied.

 Existing information on waste management is scarce and of poor quality.

Monitoring, tracking and transparency tools are not effective because there are significant gaps in the information on municipal waste management. These gaps have been found in most of the areas addressed in this study: calculation of targets, collection of basic data on waste collection, costs and revenues, management models, among others. Municipal waste management accounts for a significant percentage of local authority budgets (around 7%), hence the importance of having sufficiently spatially disaggregated information.

  • Lack of consistent information with sufficient granularity (spatial, fractions, temporal frequency). The availability of high-quality data with sufficient granularity is essential to inform public policy decisions that ensure compliance with regulatory objectives.
  • The waste collection data collected by the INE (Spanish National Statistics Institute) is inconsistent with the data reported directly to the MITERD (Ministry of Ecological Transition and Environmental Sustainability) by the autonomous communities. The INE applies sampling methodologies, while the autonomous communities usually report data based on administrative records. These discrepancies imply a disparity between the recycling data of the autonomous communities and that of Spain as a whole.
  • The methodology, quality and representativeness of the regional information used to calculate the percentage of biodegradable municipal waste sent to landfill are unknown. The numerator is calculated by aggregating the data provided by the autonomous communities, which are not required to submit the methodological specifications of their calculations to MITERD.
  • The calculation of the packaging recycling ratio does not include corrections to the denominator for fraud in placing packaging on the market. The SCRAPs estimate that fraud in the placing on the market (denominator of the recycling rate) is around 15.4% for packaging as a whole, according to information compiled in this study. This would increase the denominator and therefore reduce the recycling figure in Spain.
  • There is a gap in the collection of data on the collection and treatment of household-type waste generated by businesses and managed by private operators, which does not enter the municipal collection circuit. According to information provided by MITERD, there is no protocol for the collection of this data.
  • Absence of data on the percentage of unsuitable waste contained in the different fractions.

Methodologies: exploratory data analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Creation of an integrated waste management information system
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Creating an integrated information system on waste management in Spain with a clear and common methodology for all public administrations is a key tool for properly monitoring performance, evaluating the different instruments applied, and designing public policy measures.

This system should be centralised and collect information using a clear methodology that is common to all public administrations. The minimum information it should include is:

  • Data collected at least annually for the 15 fractions that make up municipal waste in Spain and with a spatial dimension, at least at the municipal level, regardless of whether the service is provided by a supra-municipal entity.
  • Collection models applied (e.g., door-to-door, containers, etc.) with spatial detail and population served by each model.
  • Infrastructure available for the provision of the service.
  • Details on the form of management and governance.
  • Costs of providing the service.

According to consultations with MITERD, the E-Sir database is being designed to enable the extraction of this data from the information reported by waste managers, which could cover part of the information proposed for this observatory.

  •  
    Public access to source data and methodologies applied
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Allow public access to source data and clear disclosure of the methodologies applied.

  •  
    Frequent analyses to characterise the composition of waste
  • Ministry for Ecological Transition and Demographic Challenge
    Autonomous communities
  • In progress

Perform frequent characterisations of the composition of the different fractions, particularly the residual fraction.

The characterisations must be based on an official source and use a methodology that ensures the statistical representativeness of the estimates according to different stratifications (e.g. by autonomous community), as well as any corrections that need to be applied consistently (e.g. calculation of the dry weight of packaging subject to extended producer responsibility). Given that the data on placing on the market based on the Register and SCRAP data, which must be verified, is only obtained at the national level, this action should be framed within the remit of the ministry responsible for waste, without prejudice to the appropriate coordination mechanisms with the autonomous communities.

 Spain is at risk, exacerbated by methodological changes, of failing to meet its targets in the following time frames, and has already received an early warning from the European Commission in June 2023.

Spain is one of the Member States at risk of not meeting its municipal waste management targets, as warned by the European Commission in its early warning in June 2023, although some autonomous communities are closer to compliance.

  • The percentage of separate collection reached 25% in 2020, compared to the target of 50% in 2035.
  • The percentage of waste prepared for reuse and recycling is far from the upcoming targets (55% in 2025, 60% in 2030, 65% in 2035). In June 2023, the European Commission warned of the risk of non-compliance by Spain.
  • In 2020, Spain continued to send a high percentage of collected waste to landfill (49.4%), far from the target of 40% by 2025 and 10% by 2035. The Commission also warns of the risk of non-compliance with the target of reducing municipal waste disposal to less than 10% of total waste generated by 2035.
gr7
gr6

In addition, European regulations include methodological changes in the calculation of the reuse and recycling rate, which increase the gap between Spain and the targets required from 2020 onwards.

  • According to the new methodological framework, from 2027 onwards, organic waste recovered from the residual fraction and subsequently subjected to mechanical biological treatment (MBT) and biostabilisation cannot be included in the numerator of this ratio. This waste contributed 16.2 points to the 2020 ratio, meaning that the ratio for that year, without counting the biostabilised waste from the residual fraction, would have been 24.3%.
  • At the regional level, the methodological changes mean that the autonomous communities that have focused their efforts on increasing separate collection at source are better positioned to meet current and future targets.

Methodologies: descriptive statistical analysis, documentary analysis, comparative analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Creation of an observatory of best practices
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Create, maintain and disseminate an observatory of good practices, which also allows technicians and decision-makers to connect, both in the field of collection and treatment, similar to the PowerBi tool that accompanies this assessment hosted on the AIReF website and which includes examples of experiences and good practices in municipal waste management.

The ministry responsible for waste or the inter-administrative coordination body for waste should create and subsequently maintain an observatory, preferably in web format and/or as a mobile application, which would collect, among other things, good practices and success stories from:

  • The application of instruments at the local level that have led to improvements in separate collection rates.
  • Technologies and training initiatives that have led to improvements in the efficiency of treatment plants.

This observatory should also facilitate communication between technicians and decision-makers, so that those who have implemented good practices can advise and share their experience and knowledge.

There are several examples at the international level (for example, Interreg compiles regional experiences in Europe on its policy learning platform and connects technicians and policy-makers). As a result of this study, AIReF has also made an observatory of this kind available on its website.

  •  
    Establishment of a national performance monitoring mechanism
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Create a flexible mechanism, at least once a year, to monitor performance against regulatory targets and identify risks of deviations well in advance so that corrective measures can be proposed, similar to the European Commission’s early warning system with Member States. This mechanism should:

  • Integrate anticipated regulatory changes and ensure that projections and measures implemented are consistent with the achievement of short- and medium-term objectives.
  • Cover the different levels of public administration (central government, autonomous communities and local authorities), as well as SCRAPs.

This mechanism could be created within the context of the Waste Coordination Committee or another coordination tool.

 The distribution of indicators varies significantly between autonomous communities.
  • Only four autonomous communities achieved the target of 50% of waste prepared for recovery and recycling: La Rioja, Catalonia, the Basque Country and the Valencian Community.
  • Selective collection also varies between autonomous communities, with Navarre (51%), the Basque Country (45%) and Catalonia (42%) leading the way, and Ceuta (9%), Melilla (8%) and Madrid (14%) bringing up the rear.
  • Per capita waste generation ranges from 362 kg/person in the Basque Country to 573 kg/person in the Balearic Islands.
  • Ten autonomous communities have met the target, required since 2016, of reducing municipal waste disposal to below 35% of the amount disposed of in 1995.

Methodologies: comparative analysis, descriptive statistical analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Creation of an observatory of best practices
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Create, maintain and disseminate an observatory of good practices, which also allows technicians and decision-makers to connect, both in the field of collection and treatment, similar to the PowerBi tool that accompanies this assessment hosted on the AIReF website and which includes examples of experiences and good practices in municipal waste management.

The ministry responsible for waste or the inter-administrative coordination body for waste should create and subsequently maintain an observatory, preferably in web format and/or as a mobile application, which would collect, among other things, good practices and success stories from:

  • The application of instruments at the local level that have led to improvements in separate collection rates.
  • Technologies and training initiatives that have led to improvements in the efficiency of treatment plants.

This observatory should also facilitate communication between technicians and decision-makers, so that those who have implemented good practices can advise and share their experience and knowledge.

There are several examples at the international level (for example, Interreg compiles regional experiences in Europe on its policy learning platform and connects technicians and policy-makers). As a result of this study, AIReF has also made an observatory of this kind available on its website.

  •  
    Establishment of a national performance monitoring mechanism
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Create a flexible mechanism, at least once a year, to monitor performance against regulatory targets and identify risks of deviations well in advance so that corrective measures can be proposed, similar to the European Commission’s early warning system with Member States. This mechanism should:

  • Integrate anticipated regulatory changes and ensure that projections and measures implemented are consistent with the achievement of short- and medium-term objectives.
  • Cover the different levels of public administration (central government, autonomous communities and local authorities), as well as SCRAPs.

This mechanism could be created within the context of the Waste Coordination Committee or another coordination tool.

 Spain has failed to meet several targets set by the European Union for 2020.
  • Municipal waste generation fell by 7.5% between 2010 and 2020, compared to a target of 10%.
  • Spain failed to meet the 50% target for preparing municipal waste for reuse and recycling in 2020. Specifically, it reached 40.5% in 2020, and Eurostat’s estimate for 2021 (36.7%) is even lower. Although the 2020 figure represents an increase of more than 11 points over that recorded in 2010, the trend for this indicator has not been consistently upward. This target for preparation for reuse and recycling is central to European legislation, as it includes all fractions and provides an integrated view of performance.
  • Spain has reported non-compliance with the target for separate collection of waste electrical and electronic equipment (WEEE) from households in 2019. The data reported to the European Commission indicate non-compliance with the aggregate target and the individual WEEE categories. For previous years, compliance was reported in 2012 and 2015 and non-compliance in the remaining years.
  • Before 2020, the European Commission (EC) warned of the risk that Spain would fail to meet its reuse and recycling targets and made recommendations to reverse this situation, which were partially incorporated into the Spanish regulatory framework in Law 7/2022 and Royal Decree 1055/2022.

Methodologies: descriptive statistical analysis, documentary analysis

  • Proposals
  • Organism
  • Status according to Agency
  •  
    Creation of an observatory of best practices
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Create, maintain and disseminate an observatory of good practices, which also allows technicians and decision-makers to connect, both in the field of collection and treatment, similar to the PowerBi tool that accompanies this assessment hosted on the AIReF website and which includes examples of experiences and good practices in municipal waste management.

The ministry responsible for waste or the inter-administrative coordination body for waste should create and subsequently maintain an observatory, preferably in web format and/or as a mobile application, which would collect, among other things, good practices and success stories from:

  • The application of instruments at the local level that have led to improvements in separate collection rates.
  • Technologies and training initiatives that have led to improvements in the efficiency of treatment plants.

This observatory should also facilitate communication between technicians and decision-makers, so that those who have implemented good practices can advise and share their experience and knowledge.

There are several examples at the international level (for example, Interreg compiles regional experiences in Europe on its policy learning platform and connects technicians and policy-makers). As a result of this study, AIReF has also made an observatory of this kind available on its website.

  •  
    Establishment of a national performance monitoring mechanism
  • Ministry for Ecological Transition and Demographic Challenge
  • In progress

Create a flexible mechanism, at least once a year, to monitor performance against regulatory targets and identify risks of deviations well in advance so that corrective measures can be proposed, similar to the European Commission’s early warning system with Member States. This mechanism should:

  • Integrate anticipated regulatory changes and ensure that projections and measures implemented are consistent with the achievement of short- and medium-term objectives.
  • Cover the different levels of public administration (central government, autonomous communities and local authorities), as well as SCRAPs.

This mechanism could be created within the context of the Waste Coordination Committee or another coordination tool.

Note: Status and justification of the proposal communicated by the organization to which it is addressed

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