The National Audit Office: The introduction of bio-waste has stagnated; a stricter monitoring of separate bio-waste collection is needed

Priit Simson | 3/17/2021 | 12:00 AM

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TALLINN, 17 March 2021 – If Estonia wants to meet its obligations to the European Union, it must significantly improve the possibilities of recycling bio-waste and support the demand for products made from bio-waste, the National Audit Office finds. To achieve the recycling target, local authorities must start collecting bio-waste separately to a much greater degree than they are doing currently, because this will facilitate the recycling of waste. At present, only a quarter of bio-waste generated is collected separately, which means that if the situation does not improve, Estonia is at risk of incurring a European Union waste fine.

The National Audit Office is pointing out that in Estonia, too much municipal food and garden waste is disposed of in the same waste bin compared to other European Union states. Bio-waste contains nutrients, and using compost made of it helps to improve soil fertility. Bio-waste can also be used to produce biogas, which helps to replace non-renewable energy sources. Bio-waste accounts for nearly a quarter of municipal waste, but in order to use it, it is important to collect it separately from other waste.

“Promises and the reality are becoming more and more divergent,” said Auditor General Janar Holm. “Although Estonia as a Member State of the European Union has had the obligation to recycle half of municipal waste since last year, it is actually able to recycle less than third of it. And it’s precisely the greater recycling of bio-waste in addition to packaging waste that would help to achieve the recycling targets.” Holm pointed out that Estonia has stayed at this level for ten years already.

In a decade, the Ministry of the Environment has not been able to bring about a change to better collect bio-waste separately. At the same time, the recycling of bio-waste has decreased from 18% to 11% in 2019 compared to the previous year. Although recycling of municipal waste should double by 2025, the action plan of the Ministry of the Environment to achieve this target will not be completed until 2023. The goals will, however, increase even further because Estonia as a Member State of the European Union has made the promise that 55% of municipal waste will be recycled in 2025 and 65% will be recycled in 2035.

Both the Ministry of the Environment and the Ministry of Rural Affairs should, in addition to preventing the generation of food waste, make efforts to ensure that compost made from this waste is taken back to fields as valuable nutrients that replace artificial fertilisers and improve soil properties. “The measures of the  Rural Development Action Plan could promote the use of compost made from bio-waste, but this has not been done at present,” the Auditor General Janar Holm commented. The use of compost made from bio-waste would also be boosted if its use were required in road construction and landscaping procurements.

A large proportion of municipal waste still ends up unsorted in landfills. Some of the municipal waste taken to landfills is deposited without being sorted, even though such waste should no longer be deposited in landfills for more than ten years. Non-recycled bio-waste ends up mixed in with mixed municipal waste and is either incinerated or landfilled. The Waste Act prohibits the disposal of unsorted mixed municipal waste in landfills, and the maximum amount of biodegradable waste in landfilled waste may be 20%. These include paper and cardboard waste, bio-waste, timber, and natural fibre textiles and clothing.

The analysis by the National Audit Office indicated that the Environmental Inspectorate (today, the Environmental Board) has not inspected compliance with landfilling requirements in any of the landfills in 2017–2019. The Environmental Board justifies the lack of inspection of the landfilling of unsorted mixed municipal waste in landfills with the fact that the requirements of legislation can be interpreted in different ways and that local authorities claim that collection by types taking place as part of the organised municipal waste transport, installation of public packaging containers by producer responsibility organisations and the availability of waste stations ensure that waste is being sorted. Neither the local authorities nor the Environmental Board have inspected whether waste is actually collected by types.

In the opinion of the National Audit Office, the Ministry of the Environment should establish a requirement that no municipal waste that can be incinerated or recycled as material can be deposited at landfills. This would make it easier for the Environmental Board to inspect whether waste deposited at landfills has been sorted. This means that mixed municipal waste from which waste collected by types have been sorted out can be taken to a landfill. In conclusion, this requirement could influence local authorities to further develop separate collection of waste.

In the last five years, the recycling of waste in landfills has increased significantly, but the National Audit Office sees a risk that waste could be deposited under the label of recycling to avoid paying pollution charges. The risk arises because the Environmental Board does not determine whether recycling is justified when permitting it, the environmental permits do not establish specific requirements for recycling, and supervision is not effective.

The National Audit Office recommended the Environmental Board to inspect when permitting the recycling of waste whether it is necessary and that its purpose is not to avoid paying pollution charges. Landfill operators must provide credible evidence for recycling, proving that waste is used to replace natural materials that would have been otherwise used, that replacing waste is useful and that waste is recycled in the same quantity as natural materials would have been required.

Background information

The National Audit Office prepared two reports “Recycling of bio-waste included in municipal waste” and “Waste recycling operations at landfills and supervision of landfilling” covering the period 2017–2020.

Bio-waste makes up a quarter of municipal waste. 122,000 tonnes of bio-waste was generated in 2019. Majority of bio-waste ends in mixed municipal waste (93 000 tonnes) and just 29 000 tonnes is separately collected. According to the Ministry of the Environment, presently, a maximum of 37,500 tonnes of food waste per year can be composted or used to produce biogas. Additionally, 57,000 tonnes of garden waste per year can be handled. Only 11% (13,900 tonnes) of bio-waste generated to date has been recycled, the majority is composted. Only 10,000–11,000 tonnes of compost is certified, i.e. made sure that it meets certain requirements. The Ministry of the Environment has commissioned an analysis to be completed in 2021 to determine the possibilities of achieving the targets, and further activities regarding both waste management and circular management will be planned only by the end of 2022 when these topics are included in the environmental development plan to be completed.

There are five municipal waste landfills operating in Estonia. A total of 175,000 tonnes of waste was deposited in them in 2019. Pollution charges must be paid when disposing waste, the aim of which is to make the disposal of waste more expensive than recycling or recovery of waste. A landfill has to pay 29.84 euros for the disposal one tonne of waste. In 2019, the landfills paid a total of 4.9 million euros of pollution charges. Landfills also use waste to generate waste fuel and building various construction works (e.g. landfill slopes, interlayers, roads and sites). In 2019, landfills recovered 110,000 tonnes of waste.


Priit Simson
Head of Communications of the National Audit Office of Estonia
+372 640 0102
+372 5615 0280
[email protected]
[email protected]

  • Posted: 3/17/2021 12:00 AM
  • Last Update: 3/16/2021 11:06 PM
  • Last Review: 3/16/2021 11:06 PM

In Estonia, too much municipal food and garden waste is disposed of in the same garbage can.

Mihkel Maripuu/ Postimees/Scanpix Baltics

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