Country profile

Early warning assessment related to the 2025 targets

for municipal waste and packaging waste

Belgium
June 2022
Contents
Acknowledgements................................................................................................................................. 1
1 Introduction ..................................................................................................................................... 2
1.1 Background and purpose ........................................................................................................ 2
1.2 Approach ................................................................................................................................. 2
1.3 Member State profile – context parameters .......................................................................... 3
2 Success and risk factors likely to influence future performance ..................................................... 9
2.1 Target for preparing for reuse and recycling of municipal waste........................................... 9
2.1.1 Current situation and past trends ....................................................................................... 9
2.1.2 Legal instruments .............................................................................................................. 12
2.1.3 Economic instruments ...................................................................................................... 14
2.1.4 Separate collection system ............................................................................................... 16
2.1.5 Extended producer responsibility (EPR) and similar schemes .......................................... 20
2.1.6 Treatment capacity for bio-waste..................................................................................... 22
2.2 Target for the recycling of packaging waste ......................................................................... 25
2.2.1 Current situation and past trends ..................................................................................... 25
2.2.2 Legal instruments .............................................................................................................. 30
2.2.3 Economic instruments ...................................................................................................... 31
2.2.4 Separate collection system ............................................................................................... 33
2.2.5 Extended producer responsibility (EPR) and similar schemes .......................................... 36
2.3 Target on landfill of municipal waste.................................................................................... 39
2.3.1 Current situation and past trends ..................................................................................... 39
3 Conclusion ..................................................................................................................................... 41
3.1 Prospects for meeting the recycling target for municipal solid waste ................................. 41
Prospects for meeting the recycling targets for packaging waste .................................................... 43
3.2 Prospects of meeting the landfill of municipal waste target ................................................ 44
List of abbreviations .............................................................................................................................. 45
References ............................................................................................................................................ 46
Annex 1 Detailed scoring of success and risk factors ........................................................................... 48
Acknowledgements
This assessment was prepared by the ETC/WMGE and the successive ETC/CE under guidance of the
European Environment Agency and with inputs from a consortium led by Rambøll Group under
contract with the European Commission. It builds to a large extent on the answers to a questionnaire,
developed by the EEA and ETC/WMGE, provided by provided by the Public Waste Agency of Flanders
(OVAM), Bruxelles Environment (BE) and Public service of Wallonia-Environment (PSWE) for
respectively the Flemish Region (FR), Brussels Capital Region (BCR) and Walloon Region (WR), as well
as the Belgian Interregional Packaging Commission (IRPC) in 2021. The EEA and ETC/CE would like to
thank the Belgian authorities for the information provided and for the kind review of drafts of the
assessment in 2021 and April 2022.

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1 Introduction
1.1 Background and purpose
The Waste Framework Directive 2008/98/EC (as amended by Directive (EU) 2018/851) includes a
target to recycle and prepare for reuse, by 2025, 55 % of municipal waste generated. The Packaging
and Packaging Waste Directive (94/62/EC as amended by Directive (EU) 2018/852) includes targets
for the recycling of packaging waste, both in total and by material, to be achieved by 2025. The Landfill
Directive (1999/31/EC as amended by Directive (EU) 2018/850) requires to limit the landfilling of
municipal waste to 10 % of the generated municipal waste by 2035. The Directives also foresee that
the European Commission, in cooperation with the European Environment Agency, publishes early
warning reports on the Member States’ progress towards the attainment of the targets, including a
list of Member States at risk of not attaining the targets within the respective deadlines, three years
ahead of the target dates. This assessment is a contribution from the EEA to the early warning reports
according to Article 11b Waste Framework Directive and Art. 6b Packaging and Packaging Waste
directive.

This document is an early warning assessment for Belgium. The document is based on the analysis of
a number of factors affecting recycling performance (success and risk factors). The assessment aims
at concluding whether Belgium is at risk of missing the targets for municipal waste and packaging
waste set in EU legislation for 2025. In addition, it provides an early assessment of the prospects for
meeting the 2035 target for landfilling of municipal waste.

This assessment takes into account information that was available before 10 May 2022.

1.2 Approach
The assessment follows a methodology developed by the EEA and ETC/WMGE and consulted with the
Eionet in 2020 (ETC/WMGE, 2021), which was adjusted in 2021 taking into account experiences with
applying the methodology in 2021 (ETC/CE & ETC/WMGE, 2022). This methodology uses a set of
quantitative and qualitative success and risk factors that have been identified to affect the recycling
performance. The assessment is to a large extent based on the information provided by the Member
State in the reply to an EEA-ETC/WMGE questionnaire as well as on available data and information
from Eurostat and other relevant sources. In addition, a consortium under contract with the European
Commission (led by Rambøll Group) has conducted a critical review of the draft assessment in
Q4/2021 and provided further information.

More specifically, chapter 2.1 assesses the likelihood for Belgium to achieve the target to prepare for
reuse and recycle at least 55 % of municipal solid waste (MSW) for 2025. Chapter 2.2 assesses the
likelihood for Belgium to achieve the overall packaging waste and specific packaging materials’
recycling targets for 2025. Chapter 2.3 examines the prospects for Belgium to landfill less than 10 %
of the generated municipal solid waste by 2035. The official early warning assessment for the
landfilling target is only due in 2032 and accordingly the assessment contained in Chapter 2.3 is only
preliminary.

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1.3 Member State profile – context parameters
Municipal waste generation and treatment
Belgium has shown a rather stable level of waste generation over the past five years, with almost five
million tonnes of municipal waste generated in 2020 (Figure 1.1). This corresponds to 416 kg/cap,
which is below the EU average of 505 kg/cap.

Belgium over the last years has managed to divert more than half of the municipal solid waste (MSW)
generated to recycling. The recycling rate was more or less stable during the last five years. A landfill
ban, in practice, is applicable in the entire country: there is a landfill ban in both Flanders and Wallonia,
and no landfill facility in BCR. Moreover, the tax system (landfill tax and incineration tax) makes landfill
the least favourable option and favours separate collection, with corresponding sorting and recycling,
over incineration for most of municipal solid waste fractions. In 2020, the landfill rate was at an all-
time low, of about 1 %. The country has a high level of incineration, reaching a stable plateau around
43 % in 2020 and previous years. In Belgium, the installed incineration capacity is significant: there are
ten waste incinerators (all R1 status) in Flanders that also treat MSW, four in Wallonia (all R1 status)
and one in BCR (with energy recovery, R1 status). Flanders also has one MBT installation.

Figure 1.1 Municipal waste generation and treatment in Belgium between 2016 and 2020, in
thousand tonnes

Source: Eurostat (2022a)

Legal Framework
Waste management (as part of ‘environment’) is a regional competence in Belgium and therefore the
responsibility of the three regions, the Brussels Capital Region (BCR), Flanders and Wallonia, in which
waste management planning and statistical reporting are undertaken by three separate entities. All
the relevant waste-related statistics are submitted individually to Eurostat, where the information is
then compiled, as such providing national data.

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Since ‘product legislation’ is a national competence, all EPR schemes in Belgium are more or less
uniform across the regions. For packaging waste, the Flemish Region, the Walloon Region and the
Brussels Capital Region have jointly signed the Cooperation Agreement on the prevention and
management of packaging waste. The Cooperation Agreement is a legal framework for the prevention
and management of all types of packaging waste in Belgium. This Cooperation Agreement is a legal
document that applies to the whole of Belgium. The creation of the Interregional Packaging
Commission (IRPC) is laid down in the Cooperation Agreement.

In Wallonia, Directive 2018/852 has been transposed through a cooperation agreement in March
2020, amending the Cooperation Agreement of 4 November 2008 on the prevention and management
of packaging waste (EEB, 2020). On top of that, additional and operational provisions are laid down in
the decisions of the Interregional Packaging Commission (IVCIE), in particular during the recent
renewal of the approval of the producer responsibility organisations for household packaging (Fost-
Plus) and industrial packaging (Valipac). The sorting, separate collection and recycling of packaging
waste are also covered by provisions in the Walloon Waste-Resources Plan.
The transposition of EU Directives 2018/850 and 2018/851 is still in progress. New provisions for EPR
schemes are targeted by the legislation, focusing on WEEE, batteries and accumulators, end-of-life
vehicles, tyres, non-food oils, packaging (all prior to 4 July 2018) and mattresses (recently), defining
the financial management system, waste prevention and management. The fiscal decree of 22 March
2007, promoting the prevention and recovery of waste, already includes tax provisions encouraging
the waste hierarchy. An increase if the incineration tax is about to be voted.
The Walloon Waste-Resources plan (PWD-R), adopted by the Walloon Government on 22 March 2018,
anticipated the obligations of Directive 2018/851. In particular, it includes a waste prevention
programme (section 2 of the PWD-R) including provisions relating to the prevention of food waste
(fight against food losses and waste), and it provides new restrictions for landfill, incineration and a
focus on public cleanliness (in accordance with Article 11 of Directive 2019/904).
The separate collection of hazardous waste and recoverable waste has been in place for many years.
The municipalities have an obligation to organize the service, and the list of different waste streams
has grown over time, to also include the collection of bio-waste. The framework of the obligation is
the decree of 5 March 2008, relating to the management of waste resulting from households and the
related costs. Specifically, for packaging waste, the cooperation agreement of 4 November 2008,
relating to the prevention and management of packaging waste, sets the minimum obligations for
household and industrial packaging. Sorting for the recovery of business waste in general is regulated
by the order of the Walloon Government of 5 March 2015, establishing an obligation to sort certain
waste that sets separate collection for flows, including packaging waste, green waste, non-soiled
textiles and wood waste. (EEB, 2020)

In Flanders (EEB, 2020), the EU Waste Directives are transposed through three relevant sets of
environmental legislation, but the transposition process was only finalized in August 2021:
1. VLAREM II: Order of the Flemish Government of 1 June 1995 concerning General and
Sectoral provisions relating to Environmental Safety. The VLAREM legislation contains the
rules on environmental permits. It lays down the criteria for which kind of activity an
environmental permit is required, and it sets the minimum criteria that activities need to
abide to, with the aim of protecting the environment. For different kinds of activities,
minimum rules have been laid down, such as for the recovery and disposal of waste. These
environmental permits need to guarantee that waste treatment activities have a limited
environmental impact.
2. The Materials Decree entered into force on 1 June 2012. The legal text starts from an
integral view of the material chain that is essential to find a lasting solution to the waste
issue. It anchors sustainable materials management in Flanders. The decree implements the
European Waste Framework Directive (EC) 2008/98 for waste management in Flanders.

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 3. Parallel to the decree, the Flemish Regulations for the sustainable management of material
cycles and waste, the VLAREMA, contain detailed regulations on special waste, raw
materials, separate collection, transport, the obligation to register and extended producer
responsibility. The Materials Decree and VLAREMA entered into force simultaneously on 1
June 2012, with a few exceptions of transitional provisions.

Since 1995, Flanders has had in place overall mandatory measures on separate collection and recycling
for many waste streams, established in the aforementioned laws and implementing acts. Apart from
that, Flanders also uses bans and taxes to discourage landfill and incineration. Landfill and incineration
taxes have been in place since 2007 and are regulated by the Materials decree (Articles 44 et seq).
Landfill and incineration taxes guarantee that landfilling is more expensive than incineration and that
incineration is more expensive than recycling. The taxes were raised by 50 % in 2015. An effective
raise of the incineration tax is currently being investigated. The basic principle is that the polluter pays.
The Flemish Climate Action Plan 2021-2030 contains targets for a reduction in the amount of residual
waste sent to incineration, more specifically by 25 % by 2030, through stepping up the separate
collection of recyclable waste streams. This corresponds with a drop in the amount of residual
household waste, from 145 kg per person to 100 kg per person by 2030.

The key legislation in the Brussels Capital Region related to waste is the Waste Ordinance (Region de
Bruxelles-Capitale, 2012), which is the main legal basis for all actions taken on the Brussels level. The
Waste Ordinance was modified by the Ordinance of 6 May 2021 in order to implement the obligations
from the Waste Framework Directive.
The main objective of this text is to protect the environment and public health by preventing or
reducing the harmful impact of waste generation and management, as well as by reducing the global
impact of the use of resources and improving the efficiency of this use. The Waste Ordinance enforces
several principles, namely the waste hierarchy, principles of self-sufficiency and proximity and the
material and financial responsibility of the waste producer for the management of its waste.
It lays out the obligation for waste producers and holders to sort waste adequately, and the mandatory
separate collection of paper, cardboard, metal, plastic and glass. It also gives license to the
Government to extend this separate collection to other waste streams.
The other key legislation regarding waste is the BRUDALEX, which is the executive order adopted by
the Government of the Brussels-Capital Region enforcing inter alia the Waste Ordinance and the
Permit Ordinance. It contains four parts, each of them treating a specific subject, as follows:
• Title I: General provisions;
• Title II: Provisions relating to EPR schemes;
• Title III: Provisions relating to waste operations and operators;
• Title IV: Provisions specific to certain waste streams.
Overall, the BRUDALEX specifies in detail the general principles and rules laid out in its two legal bases,
as mentioned above.

Waste management plan(s)

The Belgian territory is covered by three Regional Waste Management Plans (RWMP) for the regions
of Wallonia, Flanders and Brussels. Currently, only the RWMP of the Brussels region has been updated
in line with the requirements of the new Waste Framework Directive 2018/851/EU.

The Regional Resource and Waste Management Plan (PGRD) of Brussels (Plan de Gestion des
Ressources et des Déchets (Gouvernement de la Région de Bruxelles Capitale, 2018)) is the plan which
legally implements the regional waste policy. The plan is framed by the Ordinance of 14 June 2012
relating to waste and was adopted by the Government of the Region of Brussels Capital on 15

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November 2018. The application period is 2018 – 2023. The document constitutes the fifth Waste Plan
of the Brussels-Capital Region (RBC). The Plan is a strategic document that describes the intentions in
the waste policy of the Brussels Capital Region. The RWMP is divided into seven strategic objectives
which are all priorities. Each objective is broken down into several operational objectives which in turn
contain measures to be implemented. All this is organized according to the chosen strategic approach,
by the target audience. With the exception of the first objective, which structures the entire Plan, all
the other strategic objectives address specific target audiences. One action of the 5th RWMP is a study
on modernizing the EPR systems. This study is ongoing and aims to improve and optimize the system
of EPR, also in order to improve the collection and recycling rates of the waste flows under EPR.
In May 2021, an intermediate evaluation of the RWMP made it possible to analyse the concrete results
at mid-term, to consult and collect the opinion of Brussels stakeholders in order to draw up a series
of recommendations to be implemented in the next 30 months.
In summary, the RWMP has broadly met its commitments since its publication, despite the radical
change in circumstances brought about by the health crisis. The next challenges to be met by 2023
concern, in particular, supporting professionals and households in the obligation to sort bio-waste,
the operational implementation of a Brussels biomethanisation unit, the implementation of the re-
use roadmap and the implementation of new EPRs. (Brussels environment, 2022)

In September 2016, the Flemish Government approved the implementation plan proposed by OVAM
- the public waste agency - for the 2016-2022 period (OVAM, 2019). The plan complements the
previous one and aims at going beyond waste management to a focus on waste prevention and reuse
through local reduction targets (including for industrial waste) and tailor-made residual waste targets
for municipalities across Flanders for 2022.

In Wallonia, the 2018 Waste-Resources Plan (Wallonia Environment, 2018) contains targets and
actions for 2025 for household and similar waste, and for industrial waste. It followed the second
regional waste plan, which was adopted in 1998. The PWD-R includes the strategic framework which
covers the actions of the Plan, it constitutes the programme for prevention and reuse of waste,
covering both industrial waste and household waste. It constitutes a specific management plan for
both household waste and industrial waste, including a plan for public cleanliness and the fight against
litter and fly tipping.

Packaging waste generation and treatment

In 2019, 1.8 million tonnes (160 kg/cap) of packaging waste (both household packaging waste and
industrial and commercial packaging waste) were generated in Belgium, which is below the EU
average of 177 kg/cap. Total packaging waste generation increased by 10 % since 2010, with an
increase of 10 to 15 % for paper and cardboard packaging, wooden packaging and plastic packaging
(Figure 1.2). Waste generation increased by 2.2 % for glass packaging over the past ten years, while it
decreased for metallic packaging by 6.5 %.

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Figure 1.2 Packaging waste generation in Belgium between 2010 and 2019, in kg per capita

Source: Eurostat (2022b)

Capture rates for recyclables in municipal waste

The capture rate is a good performance indicator of the effectiveness of the separate collection
system. The capture rate is calculated by dividing the separately collected weight of a certain material
for recycling (as reported by the regions in the EEA-ETC/WMGE questionnaire) by the weight of the
material in total municipal waste (being the product of the residual waste composition and the total
amount of residual waste collected, as reported by the region in the EEA-ETC/WMGE questionnaire).
For Belgium, the calculated capture rates for different waste fractions, were calculated based on
numbers for household waste only (excluding the non-household part of municipal waste) due to lack
and uncertainty in data. The capture rates calculated are presented in Table 1.1.

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Table 1.1 Capture rates for different waste fractions in Belgium (F= Flanders, W=Wallonia, B=BCR)

Residual Residual Separately Materials in Capture

waste waste collected total MSW rates (%)
composition composition amounts (tonnes)
(%)(b) (tonnes)(a) (tonnes)(b)
F:2013-2014
Reference year W:2017/2018 2019
B:2019
F: 950 985
Mixed municipal waste, total W: 513 913
B: 206 100
F: 17 % F: 165 947 F: 398 841
Paper and cardboard W: 7.5 % W: 38 543 W: 174 154 814 353 74 %
B: 5 % B: 10 305 B: 26 563
F: 2.2 % F: 20 541 F: 34 904
Metals W: 1.4 % W: 7 195 W: 28 454 92 736 69 %
B: 1.3 % B: 2 679 B: 3 283
F: 3.1 % F: 29 385 F: 204 495
Glass W: 3.6 % W: 18 501 W: 110 249 393 953 87 %
B: 2 % B: 4 122 B: 27 201
F: 13.2 % F: 125 815 F: 45 711
Plastic W: 12.8 % W: 65 781 W: 10 178 274 036 23 %
B: 8.9 % B: 18 343 B: 8 208
F: 21.4 % F: 203 606 F: 713 660
Bio-waste W: 41.7 % W: 214 302 W: 305 869 1 544 099 67 %
B: 41.4 % B: 85 325 B: 21 337
F: 7 % F: 66 759 F: 54 696
Textiles W: 3.8 % W: 19 529 W: 25 986 181 243 47 %
B: 4.7 % B: 9 687 B: 4 586
F: 2.3 % F: 21 397 F: 203 859
Wood W: 0.3 % W: 1 542 W: 140 450 379 231 93 %
B: 1.7 % B: 3 504 B: 8 479
(a) Note: Share of material in residual waste (household waste only) multiplied with the amount
of residual waste in 2018 as reported in the questionnaire by the regions
(b) Source: As reported in the EEA-ETC/WMGE questionnaire by the regions

This indicates that there is especially room for improvement to capture higher shares of the generated
plastic and textiles wastes.

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2 Success and risk factors likely to influence
future performance
2.1 Target for preparing for reuse and recycling of municipal waste
This chapter aims at assessing the prospects of Belgium to achieve the 55 % preparing for reuse and
recycling target for municipal waste in 2025. For a detailed description of the methodology followed,
the development of success/risk factors and their impact on recycling, please consult the
Methodology report (ETC/CE & ETC/WMGE, 2022).

2.1.1 Current situation and past trends

SRF MSWR-1.1: Distance to target
The overall recycling rate for municipal waste in Belgium shows a very slight increase from 53.5 % in
2016 to 54.2 % in 2020 (Figure 2.1).
In this analysis the recycling rate is calculated by dividing the summed amounts of recycling of
materials and of composting and digestion by the total generated amounts. The data source use is the
Eurostat data set Municipal waste by waste management operations [env_wasmun] (following the
OECD/Eurostat Joint Questionnaire); Data reported by Member States according to Article 10.2(a) of
the Waste Framework Directive are not used for this assessment as the reporting methods differ by
Member State, resulting in a lack of comparability between Member States. The data source used
here is assumed to be the best available proxy given that data in accordance with the rules on the
calculation of the attainment of the targets defined in Article 11a is not yet available.

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Figure 2.1 Recycling rate in Belgium between 2016 and 2020, in percentage

Source: Eurostat (2022a)

The actual distance to the target for the most recent data point is a key factor determining the
likelihood of meeting/not meeting the target. The closer the Member State is to the target already,
the more likely that the target will be met. For Belgium, the recycling rate is 54.2 % in 2020, almost
reaching the 2025 target.

However, the data used for this analysis are based on a different methodology than the calculation
rules for the target. BCR and Flanders have estimated the impact of the new calculation rules for the
recycling rates for 2018 (Table 2.1). The impact of the new calculation rules has not yet been analysed
by Wallonia. However, if the average impact of BCR and Flanders is assumed for Wallonia, this would
result in a reduction of 11.3 percentage points. Taking into account the weighted impact of the
regions, the 2018 data estimate a reduction of the Belgian recycling rate by 11.6 percentage points.

Table 2.1 Overview of impact of new calculation rules for the 2018 recycling rate, in percentage

Region Recycling rate, Recycling rate, Impact on recycling Average estimated

old calculation rules new calculation rules rate (in percentage impact on recycling
(Commission (Commission points) rate (in percentage
Decision Implementing points)
2011/753/EU) Decision 2019/1004)
BCR 43 % 30 - 35 % 13 – 8 10.5
Flanders 63 % 51 % 12 12
Wallonia 44 % 11.3
Belgium 55.1 % 11.6

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If the same impact on the recycling rate as estimated by the Belgian authorities for 2018 is applied to
the reported recycling rate for 2020, the estimated recycling rate for Belgium would be 43.5 %.

Summary result
Based on the currently available data, Belgium’s recycling rate lies at 54.2
% in 2020, 0.8 percentage points below the 2025 target. However, the
Flemish and BCR authorities have estimated that the application of the
new calculation rules will reduce the recycling rate by 10.5 – 12
Distance to target 5 - 15
percentage points while no similar estimate is available for Wallonia.
percentage points
Assuming that the application of the new calculation rules will have a
similar effect in Wallonia as in Flanders and BCR, this would result in an
estimated recycling rate of 43.5 %, 11.5 percentage points below the
target.
The impact of the new calculation rules is an estimate only. Belgium has
Robustness of the underlying partially (Flanders and Brussels) assessed the influence of the new
information calculation rules on the recycling rate (at the time of writing of this
assessment).

SRF MSWR-1.2: Past trend in municipal solid waste recycling rate

The recycling rate over the past five years shows a very slight increase of about 0.7 percentage point
(Figure 2.1). This indicates that the recycling rate is stabilising, and that additional measures are
needed to improve the recycling rate and to be able to reach the 2025 target, especially taking into
account the effect of the new calculation rules for the recycling rate.

Both in Flanders and Wallonia, municipalities can get subsidies for investments in waste management
infrastructure or specific waste prevention measures (Wallonia). In all regions, a lot of attention goes
to sharing of experiences and best practices. For example, in Flanders, an interactive data tool has
been developed that shares information on waste management practices and results of all Flemish
municipalities. This allows municipalities to benchmark their performance. BCR is currently executing
a study in order to improve and optimise the EPR system, also with the aim to improve collection and
recycling rates of the waste flows under the EPR. In addition, BCR is currently developing a strategy to
support households and professionals to improve the sorting performance of waste, in particular bio-
waste, and is preparing the operational implementation of a biomethanisation unit in Brussels.
(Brussels environment, 2022)

Summary result
The recycling rate has increased with 0.7 percentage points over the past
five years. Flanders and BCR have estimated that the recycling rate
RR < 45% and increase in last would be between 10.5 and 12 percentage points below the currently
5 years < 10 percentage points reported one under the new calculation rules. Assuming a similar
reduction in Wallonia, the application of the new calculation rules would
indicate an estimated recycling rate for Belgium of 43.5 %.
The Eurostat data used are robust and there are no breaks in the time
Robustness of the underlying
series data. The recycling rate according to the new calculation is;
information
however, only estimated.

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2.1.2 Legal instruments
SRF MSWR-2.1: Timely transposition of the revised Waste Framework Directive into national law
Timely transposition of the Waste Framework Directive as amended by Directive 2018/851, into
national law within the foreseen period is key for a waste management system in line with EU
requirements.

Belgium has not yet fully transposed the amended Waste Framework Directive into national law in all
three regions.
Flanders implemented the amended WFD in two steps: 1) by amendment of the Materials Decree,
published in the Belgian Official Gazette on 1 April 2021, and 2) by amendment of the VLAREMA,
published in the Belgian Official Gazette on 17 August 2021.
BCR finalised the transposition and this was published in the Belgian Official Gazette on 5 May 2021.
For Wallonia, complete transposition is planned for the end of 2022, as part of a comprehensive
reform of waste law. However, in many ways the existing regulations already meet various
requirements of the framework directive. (PSWE, 2022)

Summary result
The transposition by all three regions was not finalised within 12 months
No full transposition yet
after the deadline.
The assessment is based on information provided by the Belgian regional
Robustness of the underlying
authorities. Information was also received from the European
information
Commission (status as of 12 November 2021)

SRF MSWR-2.2: Responsibilities for meeting the targets, and support and enforcement mechanisms, e.g.
tools, fines etc.
Clearly defined responsibilities, enforcement and support mechanisms for meeting the targets across
different entities and governance levels are important for achieving high recycling rates. The clearer
the responsibilities for meeting the target and the accountability for failing the targets are, the higher
the chance that the targets will be met.

With respect to the definition of responsibilities for meeting the targets, Flanders and Wallonia are
organised in a similar way, including:
• A regional authority (respectively OVAM1 and SPW ARNE2), responsible for laying down
targets and setting the general policy framework for waste management;
• Municipalities being responsible for collecting and treating MSW;
• Intermunicipal organisations collecting and treating MSW commissioned by associated
municipalities;
• Producer responsibility organisations (PROs), responsible for meeting the recycling targets
that are under an obligation for extended responsibility organisations; they have
corresponding operational and financial obligations;
• Private waste collectors and treatment operators who collect and treat commercial and
industrial waste and work as a contractor for municipalities that are in charge of MSW.

The above described responsibilities show that targets and requirements are included in regional
waste management plans and decrees, including the waste streams under an EPR obligation, but the

1
Public Waste Agency of Flanders
2
Service Public de Wallonie Agriculture, Resources naturelles et Environnement

12
actual duty of care for the collection and treatment of household waste lies mainly with the
municipalities.

For Flanders, the municipal solid waste production per municipality (both residual waste and separate
collected fractions) is monitored and published on a yearly basis as a first incentive to reach the
targets. Subsidies are granted by OVAM to municipalities for amongst other investments in recycling
centres, underground collection systems, but also certain waste prevention measures. Municipalities
can lose the possibility of getting these subsidies if they are not implementing legislation and in
particular when they do not respect the minimum prices for residual waste which are obliged as in
VLAREMA. These minimum prices for residual waste should stimulate citizens to sort their waste. This
is why a minimum price is set by Flanders for residual waste (also for bulky waste) which all
municipalities must implement. This approach seems to be successful as almost all municipalities now
have implemented the minimum prices, in some cases after they were refused subsidies.
In Wallonia, not reaching the target(s) could lead to penalties, but no detailed information was
provided about their severity.

Besides subsidies, Flemish municipalities can also get direct advice from OVAM and they can use an
interactive data tool provided by OVAM benchmarking the results of all Flemish municipalities and
sharing information on waste management practices. Flemish municipalities that are far from
reaching their targets, are proactively contacted by OVAM. OVAM visits these municipalities on the
spot (since COVID-19 more online) and tells them to make an action plan. These interactions take
place both on the level of the administration and the political level. Municipal action plans are also
followed up by OVAM.
Both in Wallonia and Flanders, learning networks are organised between municipalities to discuss
common challenges, share experiences and best practices.

In BCR, the responsibilities are shared by 2 main organisations:

• Brussels Environment is the regional public authority responsible for laying down targets and
setting the general policy framework for waste management, gathering and reporting
information about the state of the environment in BCR, including data on waste;
• Bruxelles-Propreté (ABP) is the public waste operator for collection and treatment of
household waste in BCR.

The 19 municipalities are in charge of cleanliness of local roads and public places and buildings, and
removing bulky waste on local roads.
Producer responsibility organisations (PROs) are responsible for meeting the recycling targets that are
under an obligation for extended responsibility organisations; they have corresponding operational
and financial obligations.
Additionally, several private waste collectors are active in BCR as well, including social economy.
(Brussels environment, 2022)
If the objectives for separate collection of household waste are not met, ABP has to pay a tax of
29 EUR/t of waste incinerated exceeding the objective (50 % of separate collection as of 2020). PROs
that do not fulfil their obligations can be charged with fines or be prosecuted.

In Belgium, the regional authorities are mainly responsible for setting the framework of municipal
waste management policy, but the responsibility for its implementation lies with municipalities, and
ABP for BCR, who are the ones directly in charge of collecting waste from households. The regional
authorities provide support in the form of information and research, and other tools for the
municipalities and ABP, to increase recycling more easily.

13
For Flanders, the complete waste management plan on household waste (uitvoeringsplan
huishoudelijk afval en gelijkaardig bedrijfsafval) is binding for local authorities. This includes targets
for residual waste generation, but also obligatory door-to-door separate collection of several waste
fractions, waste streams to be accepted at the recycling centres, the number of recycling centres
municipalities need to have, thresholds for contamination for all different separately collected waste
streams, among others.
For Wallonia and BCR, specific obligations for the municipalities are lacking; for example, the recycling
target is not translated into binding (uniform or differentiated) targets for the municipalities and the
regional authorities have hardly any enforcement tools at hand for municipalities lagging behind.
Instead, through a series of regional measures (e.g. disposal taxes), the authorities aim to make low
recycling levels uneconomic and unattractive (through peer pressure and inter-municipal
competition).

In summary, responsibilities are well defined and support mechanisms for municipalities are in place.
The high recycling rates achieved in Belgium indicate that these mechanisms have worked. However,
there are no direct consequences for the responsible authorities in Wallonia if the targets are not met.
In BCR, the Waste Ordinance foresees a tax of 29 EUR/t to the public operator if targets are not met.
The tax revenue may only be used for investment in selective collection infrastructure. Therefore, it
can be argued that the municipal waste management governance in Belgium functions in a somewhat
suboptimal manner.

Summary result
Clearly defined responsibilities
and good set of support tools Responsibilities are defined and support mechanisms for municipalities
but weak/no enforcement are in place, but there are no direct consequences for the responsible
mechanisms for meeting the municipal authorities if the targets are not met for the entire country.
recycling targets
Robustness of the underlying Credible information received from the regional authorities through the
information EEA-ETC/WMGE questionnaire.

2.1.3 Economic instruments

SRF MSW-3.1: Taxes and/or ban for landfilling residual- or biodegradable waste
Bans and taxes on landfilling of residual municipal waste can help to discourage strong reliance on
residual waste treatment and thus support recycling.

As BCR has no landfills within the region, it has no landfill tax nor a landfill ban.
Flanders and Wallonia both have a landfill ban as well as a landfill tax. Their situation is summarised
in Table 2.2.

Table 2.2 Landfill bans and taxes in Flanders and Wallonia

Region Landfill ban Landfill tax (EUR/t)

– Since 1998, ban on separately collected waste;
– Since 2000, ban on combustible waste (TOC > – 107.87 EUR/t for combustible waste;
Flanders
6 % and LOI > 10 %); – 59.33 EUR/t for non-combustible waste.
– Since 2007, ban on biodegradable waste.
– Since 2004, ban on combustible waste (TOC >
– 119.59 EUR/t for general waste;
Wallonia 6%);
– 66.37 EUR/t for non-combustible waste
– Since 2007, ban on biodegradable waste.

14
Already in 2007, a landfill ban was introduced in Belgium (both Flanders and Wallonia) for
biodegradable waste. At that time there already was a landfill ban applicable for combustible waste
in both regions.
The tax is levied on all Belgian waste to be landfilled, also on waste that is exported from Belgium for
landfilling in other countries and on waste that is imported from other countries for landfilling in
Belgium.
There is no algorithm or calculation method applied to determine the level of the tax, but considering
the waste management performance of Flanders and Wallonia, the tax seems to have been effective
in reducing landfilling of waste and in redirecting waste to incineration.
The landfill ban and tax contributed to driving down the landfill rate of municipal waste, to a level of
around 1 % of the generated municipal waste since many years.

Summary result
Flanders and Wallonia have a ban in place for landfilling residual and
Ban in place for landfilling
biodegradable waste. Both regions also apply landfill taxes, while BCR
residual or biodegradable waste
does not have own landfills.
Robustness of the underlying Information available in various official sources, and confirmed by the
information three regional authorities through the EEA-ETC/WMGE questionnaire.

SRF MSWR-3.2: Taxes on municipal waste incineration

Taxes on incineration of residual municipal waste can help to discourage strong reliance on residual
waste treatment and thus support recycling.

Flanders has nine waste incinerators (all R1 status) that also treat MSW. Wallonia has four waste
incinerators (all R1 status) and BCR has one waste incinerator (with energy recovery).
In all three regions an incineration tax is applicable to all waste entering the incineration facilities since
several years. The tax is also applicable to waste exported for incineration outside the region. For
export of waste, the amount of tax paid in the receiving country may be deducted and the remaining
part is levied in Flanders. If the waste is pre-treated in the other country, the tax is levied on the landfill
or incineration of the residue.
BCR recently decided to increase the incineration tax to 15 EUR/t from 2022 onwards, and Flanders
as well as Wallonia have plans to also increase their incineration tax, but are currently exploring the
most effective way to do this in combination with other policy measures, in order to help shifting
waste from incineration to separate collection (and recycling).

Table 2.3 shows the current incineration taxes applied in Belgium.

Table 2.3 Incineration taxes in Belgium

Region Incineration tax

2021: 6.43 EUR/t
BCR
From 2022: 15 EUR/t
Flanders 2021: 13.38 EUR/t
2021:
Wallonia – 14.69 EUR/t, for incineration with energy recovery;
– 68.33 EUR/t for incineration without energy recovery

Belgium strongly relies on incineration for the disposal of mixed municipal waste, incinerating 43 % of
the generated municipal waste in 2019. Reliance on incineration has been stable for the last 10 years.

15
Summary result
A tax of at least 13.38 EUR/t(a) (corresponding to 11.5 EUR/t rescaled
a
Taxes > 7 EUR/t( ), but without based on purchasing power parities) is already in place in 2021 in
escalator Flanders and Wallonia or will be in place soon (in 2022) in BCR. However,
no escalator is applied.
Robustness of the underlying
Small clarifications needed for the scope of the tax
information
(a) Note: Rescaled based on purchasing power parities Eurostat (2020)

SRF MSWR-3.3: Pay-as-you-throw (PAYT) system in place

PAYT systems are designed to incentivize citizens to make a bigger effort in separating their waste at
source. However, a PAYT system should be designed with the appropriate level of source separation
encouragement to ensure that citizens do not misplace waste in recycling bins in order to avoid
residual waste charges. Overall, PAYT usually has a positive effect on source separation and thus
recycling rates through direct involvement of citizens.

In BCR, door-to-door collection in plastic bags is the main collection system (around 70-80 %) for
residual MSW. For apartment buildings (around 20-30 %) the residual waste is collected in containers.
Inhabitants can buy the waste bags in stores and their price only covers the manufacturing price (so
not including the costs of the actual waste management). Also the containers are free of charge. In
BCR, no PAYT system is in place.

In Flanders and Wallonia, a PAYT system is being applied, covering the entire region and all of the
inhabitants. Municipalities charge a fee for the collection of mixed municipal waste and decide on the
level of the fee, taking into account a minimum and maximum level imposed by the regional authority.
Municipalities also decide on how the PAYT schemes are organised (volume based or weight based,
and/or the number of collections) for door-to-door collection.
There is no regulation on Flemish level in terms of fees for other waste streams than mixed municipal
waste. In general, municipalities tend to have a fee for bio-waste. Most other waste streams, in
particular those under EPR schemes, have no collection fee (e.g. paper and cardboard, WEEE,
batteries, …) or a very low fee (e.g. plastics packaging, metal packaging and drink cartons).

Summary result
Both Flanders and Wallonia have a PAYT scheme covering 100 % of the
PAYT scheme fully rolled out (to
inhabitants. BCR has no PAYT scheme. Flanders and Wallonia cover more
at least 80% of the population)
than 80 % of the Belgian population.
Robust information was provided by regional authorities through the
Robustness of the underlying
EEA-ETC/WMGE questionnaire, and was combined with additional
information
information from literature.

2.1.4 Separate collection system

SRF MSWR-4.1: Convenience and coverage of separate collection systems for the different household
waste fractions
Separate collection systems are a key enabler for high recycling rates and for collecting recyclables at
adequate quality. Generally, the more convenient and accessible these systems are for their users,
the better results they deliver. The assessment methodology categorises different types of collection
systems (door-to-door, bring points with a density of > 5 per km2, bring points with a density of < 5

16
per km2, civic amenity site) for assessing the degree of convenience, and differentiates between cities
(densely populated), towns and suburbs (intermediate densely populated) and rural (thinly populated
areas). It then calculates which share of the population is served by which type of system. The
assessment is done on a material basis and takes into account the different materials according to
their average share in municipal waste. This is described in more detail in the methodology (ETC/CE &
ETC/WMGE, 2022).

For Belgium, according to the most recent data, the percentage of households living in cities is
60.67 %, in towns and suburbs 35.59 % and in rural areas 3.7 % (Eurostat, 2021a).

Separate collection of municipal waste streams is strongly linked to the corresponding EPR schemes
that are applicable in Belgium. For several waste streams an EPR scheme at national level exists,
defining which waste streams should be collected separately. The actual implementation of the
collection, however, can be organised by the local authorities, being cities and municipalities.
National EPR schemes are applicable for paper and cardboard, glass packaging, plastic packaging,
metal packaging, composite packaging (drink cartons), EEE, batteries, mineral oils and cooking and
frying oils.
In Flanders recently also an EPR scheme for mattresses, Valumat, was set up.

Table 2.4 gives an overview of the collection system in both BCR, Flanders and Wallonia.
• For residual waste the dominant collection system is door-to-door collection;
• Also for paper and cardboard door-to-door-collection is the prevailing collection system in
Belgium, complemented with collection at civic amenity sites (CAS);
• Co-mingled door-to-door collection of plastic, metal and composite packaging,
complemented with collection at CAS, (in blue bags) is rolled out across the whole of Belgium;
• For glass packaging a diverse range of collection methods is available; in some cities and
municipalities, glass is collected only door-to-door and at CAS, in others bring points are the
most common collection method.

In several areas with high-rise buildings, door-to-door collection is replaced by a bring point close to
the buildings. Depending on the city or area, this can relate to residual waste, paper and cardboard,
PMC (plastics, metals, drink cartons), bio-waste and/or glass.

Based on the provided information for the three regions, the dominant system for separate collection
of paper and cardboard, ferrous metals, aluminium, plastic and composite packaging is high-density
collection, whereas for textiles and wood the dominant system is low-density collection. For glass and
bio-waste the situation depends on the preferences and priorities of the municipalities. Food waste is
collected mostly through door-to-door separate collection. Garden waste, on the other hand, shows
a more mixed picture, with, in cities, mostly door-to-door separate collection as well as civic amenity
sites, while in towns and suburbs, and in rural areas, the dominant system in all regions is mainly civic
amenity sites.

Table 2.4 shows that the collection system per fraction is similar in cities, towns and suburbs and in
rural areas, so all citizens receive a similar service.

17
Table 2.4 Characterisation of the collection system in Belgium (BCR (blue), Flanders (yellow)3,
Wallonia (red))

Cities Towns and suburbs Rural areas

(densely populated areas) (intermediate density areas) (thinly populated areas)
Door-to-door -

Door-to-door -

Door-to-door -

Door-to-door -

Door-to-door -

Door-to-door -
Civic amenity

Civic amenity

Civic amenity
(>5 per km²)

(<5 per km²)

(>5 per km²)

(<5 per km²)

co-mingled

co-mingled

co-mingled
Bring point

Bring point

Bring point

Bring point

Bring point
separate

separate

separate
site

site

site
xx
xx xx
Residual waste xx xx x x
xx xx
xx
xx x
Paper and xx x xx x
xx x
Cardboard xx x xx x
xx x
xx xx
xx xx xx xx
Ferrous metals xx xx
xx xx x xx
xx xx
xx xx
xx xx xx xx
Aluminium xx xx
xx xx x xx
xx xx
xx x xx x xx x
Glass x xx x xx x
xx xx xx x xx xx
xx xx
xx xx xx xx
Plastic xx xx xx
xx xx x xx
xx xx
Bio-waste
xx
xx xx xx
Food xx x x
xx xx
xx
xx
xx xx xx xx
Garden xx x xx
xx xx xx
x
xx
xx xx xx xx xx xx xx
Textiles xx xx
xx xx xx xx xx
xx
xx
xx xx
Wood xx
xx xx
xx
xx
x x x xx x x xx
WEEE xx xx xx
x x x xx xx xx xx
xx
xx
Composite xx xx
xx x x x
packaging** xx xx
xx
Note: xx: dominant system; x: other significant systems. Grey cells indicate high convenience
collection systems.
Source: Information provided by Flemish, Walloon and BCR authorities through the EEA-ETC/WMGE
questionnaire

Other relevant waste streams from households, mainly being collected through civic amenity sites
(CAS), are hazardous waste, frying oil, stony demolition waste (not in BCR), asbestos (not in BCR),

3
The information included in the table for Flanders refers to household waste. For municipal waste from
businesses a different waste collection system is in place, mainly dominated by private collectors that
provide door-to-door collection. For small amounts of similar waste, businesses can sometimes also use
the household waste provisions.

18
mattresses (not in BCR), tires (only in BCR), batteries, drugs (only in Wallonia) and mineral oils (only in
BCR).

Summary result
A high share of the population is The dominant collection system is door-to-door
Paper and
covered by high convenience collection, complemented with collection at CAS in
cardboard
collection services all 3 regions, in all 3 areas.
Ferrous metals and aluminium are collected co-
A medium share of the population is mingled door-to-door and at CAS, both in cities,
Metals covered by high convenience towns and suburbs and rural areas. The high
collection services convenience (door-to-door) collection is mostly
limited to packaging.
Plastics are collected co-mingled door-to-door and
A medium share of the population is
at CAS, both in cities, towns and suburbs and rural
Plastics covered by high convenience
areas. The high convenience (door-to-door)
collection services
collection is mostly limited to packaging.
For glass, the dominant collection method is by
A high share of the population is
bring points. In Flanders, door-to-door collection of
Glass covered by high convenience
glass is also provided in some municipalities.
collection services
Additionally, glass waste is also collected at CAS.
In cities, bio-waste is collected door-to-door in all 3
A medium share of the population is regions. For towns and suburbs and rural areas,
Bio-waste covered by high convenience both the scope (food/garden waste) can be smaller
collection services than in cities, and also the convenience level is
typically lower.
Wood is collected at CAS, in all three regions,
A low share of the population is
regardless the population density.
Wood(a) covered by high convenience
In addition wood is also collected door-to-door
collection services
(mingled with bulky waste) in BCR.
In Flanders, textiles waste is collected both door-to-
A low share of the population is door, at CAS and/or at remote bring points.
Textiles covered by high convenience In Wallonia and BCR, textiles is only collected at CAS
collection services or at remote bring points, regardless the population
density.
For WEEE the most dominant collection method is
High to medium convenience
WEEE at CAS, for all 3 regions, but also door-to-door
collection services dominate
collection and in bring points are applied.
The information can be considered robust, and was
Robustness of the underlying information provided by the regional authorities through the
EEA-ETC/WMGE questionnaire.
(a) Note: For wood, collection results are very good in Flanders and sorting analyses show that
wood is hardly found in household residual waste despite the fact that it is not
collected by high convenience collection services.

SRF MSWR-4.2: Firm plans to improve the convenience and coverage of separate collection for the
different household waste fractions
In BCR, separate collection of garden waste is already compulsory for professional waste holders. BCR
plans to extend the compulsory bio-waste collection to food and garden waste for households and
professional waste holders.
Also, Flanders will extend separate collection of bio-waste to all households from 2024 onwards.

19
A clear plan has been launched and is being implemented to extend the scope of the door-to-door
plastic packaging waste collection, from plastic bottles only to all plastic packaging, with a target of
8 kg/inhabitant additional plastic packaging waste collection. This plan will clearly improve the
convenience of the separate collection for more types of plastic packaging by extending the scope of
collection by allowing for additional waste and discarded product categories.

Summary result
N/A (for countries in which a high share of
Paper and More than 80 % of the population is already
the population is already covered by high
cardboard covered by high convenience collection points.
convenience collection services)
No firm plans to improve the convenience None of the regions has firm plans to improve the
Metals
and coverage type or coverage for collection of metals waste
A clear plan is launched and in implementation to
extend the scope of the door-to-door plastic
packaging waste collection, with a target of 8
Firm plans to improve the separate
kg/inhabitant additional plastic packaging waste
Plastics collection system, with clear responsible
collection. The plan will clearly improve the
entities and defined targets and timeline
convenience of the separate collection system by
extending it with more plastic packaging waste
types
N/A (for countries in which a high share of
A high share of the population is already covered
Glass the population is already covered by high
by high convenience collection systems
convenience collection services)
Bio-waste collection will become compulsory in
There are plans to improve the collection BCR in 2023, and in Flanders for all households
Bio-waste service but unclear plan for and companies from 2024 (or composted at
implementation. source), and Wallonia plans to extend food waste
collection.
No firm plans to improve the convenience No changes planned that will improve the type
Wood
and coverage and coverage of separate collection
No changes planned that will improve the type
and coverage of separate collection
No firm plans to improve the convenience
Textiles Textile Waste collection will become compulsory
and coverage
in BCR in 2025, complying with the Waste
Framework Directive
N/A (for countries where high to medium
No changes planned that will improve the type
WEEE convenience collection services dominate
and coverage of separate collection
already)
Information received through questionnaires from
Robustness of the underlying information
all three regions.

2.1.5 Extended producer responsibility (EPR) and similar schemes

SRF MSWR-5.1: Fee modulation in EPR schemes for packaging
Within EPR schemes, fee modulation (or eco-modulation) is a system with different fees for different
types of packaging material and designs. While basic fee modulation, i.e. different fees for the main
material groups, are common, advanced fee modulation can create stronger incentives for packaging
producers to design for recycling and thus create favourable conditions for higher recycling rates. The
level of advancement of the fee modulation is assessed against four criteria that have been selected
as benchmarks for a well-designed eco-modulated fee system:

20
 • recyclability, for example differentiating between PET and PS, between different colours of
PET, or between 100 % cardboard boxes and laminated beverage cartons;
• sortability and disruptors, for example a malus for labels/caps/sleeves made of other
materials, which are not fitted for the recycling technologies of the main packaging;
• recycled content; and
• if there is a transparent compliance check by the PRO that producers report correctly.

In Belgium, Fost Plus promotes, coordinates and finances the separate collection, sorting and recycling
of household packaging waste for all three regions. Fost Plus is a not-for-profit organisation, set up
and financed by industry. It cooperates with (inter-)municipalities, private waste management
companies and recyclers to organize the collection and recycling of household packaging, such as
glass, paper-cardboard and PMC. As a complementary organization, Valipac is the PRO for the EPR
scheme for industrial and commercial packaging waste, and therefore responsible to fulfil the
obligations and to stimulate recycling.

Fost Plus is accredited in Belgium for the collection and recycling of household packaging waste. It has
financial and partial organisational responsibility. Companies that place packaging material on the
Belgian market can join Fost Plus and pay an annual contribution, the Green Dot Tariff, which is based
on the quantity and type of their packaging. In return, Fost Plus fulfils their information and take-back
obligations, finances the collection and recycling of a number of packaging materials and coordinates
the activities of municipalities, inter-municipal waste companies, collection companies and sorting
centres.
The Green Dot tariffs applied by Fost Plus are differentiated by packaging material such as ‘drink
carton’ or ‘PET bottle’. The Green Dot tariffs for recent years are presented in Table 2.5. They are the
lowest for paper-cardboard and highest for non-recoverable materials. The fees are not modulated
based on environmental criteria.

For some materials (such as plastics and paper and cardboard) the fee modulation of the EPR scheme
does take into account sortability and recyclability (including market prices for secondary materials)
as a criterium for defining the level of the fee, both between polymers (f.e. PE versus PS) and even
within one polymer (e.g. colourless PET bottles versus coloured PET bottles).

A compliance check is done by Fost Plus with respect to producers reporting correctly for all packaging
materials. This is done through automatic timeline checks, comparative analysis of data from
members producing similar packaging and regular independent audits. There are several adequate
checks on reporting, as this determines directly how much a company has to contribute to the EPR
scheme. Competitive companies want assurance that everyone is financing their relevant share. In
addition to checks by Fost Plus, this is also checked by an external inspection body/company auditor
on a regular basis.

Recycled content is not taken into account in the fee modulation for any of the packaging materials.

21
Table 2.5 Green Dot Tariffs in the Fost Plus scheme

Green Dot Tariffs (EUR/t)

Materials
2015 2017 2019 2021
Glass 24.1 21.4 31.1 49.9
Paper-cardboard 13.9 16.9 22.3 118.9
Steel 52.4 124.4 52.9 211.4
Aluminium 31.7 32.6 33,9 46.2
PET/HDPE 111.1 210.7 - -
200.4
PET bottles - - 346.3
(transparent)
HDPE bottles - - 341.8 364.7
Other plastics - - 510.3 329.7-1133.7
Drink cartons 232.7 245.5 354.1 445.3
Other recoverable materials 267.7 282.3 618.1 1152
Other non-recoverable
294.4 310.6 781.8 1440
materials

In 2021, a dissuasive rate (tariff: 2267 EUR/t) was introduced for nuisance packaging such as:
• plastic cans with metal on top or bottom;
• plastic bottles which are at least 75 % covered by a sleeve (or 50 % for bottles <50cl), provided
that the sleeve consists of another material than the bottle and is not perforated;
• aluminium foil laminated plastic packaging for drinks, fruit and vegetables, prepared dishes,
pet food, care products and body care;
• oxodegradable packaging;
• laminated cardboard packaging of crisps and milk powders, provided they contain less than
85% paper fibre.

Summary result
There is advanced fee
modulation for at least two of Both sortability and recyclability are taken into account for plastics and
the main packaging fractions(a) paper and cardboard.
AND fee modulation for one In addition, the PRO performs transparent compliance checks on the
packaging fraction meets three data provided by all involved actors.
assessment criteria
Robustness of the underlying
The fee structure is transparent and publicly available.
information
(a) Note: Paper and cardboard, Ferrous metals, Aluminium, Glass, Plastic

2.1.6 Treatment capacity for bio-waste

SRF MSWR-6.1: Capacity for the treatment of bio-waste
Bio-waste is the largest single waste fraction in municipal waste, and adequate treatment capacity
needs to be (made) available.

The situation with respect to bio-waste collection and treatment is not uniform across the three
regions:

22
 • In BCR, food waste is collected separately only since a few years; in 2019 about 4 kg food
waste and 9 kg garden waste per person was collected (a total of 15 816 tonnes of bio-waste)
and composted in an installation with a total capacity of about 20 000 tonnes per year. This
composting unit covers only garden waste.
In 2019 about 200 000 tonnes residual municipal solid waste was incinerated in BCR; with a
bio-waste content of 41 %, the additional theoretical maximum potential for bio-waste
collection is 82 000 ton per year, so the current available capacity only covers about 20 % of
the total generated municipal bio-waste. BCR is preparing the operational implementation of
a biomethanisation unit in Brussels.
• In Flanders more than 41 kg food waste and 67 kg garden waste per person was collected in
2019, corresponding to an overall amount of 713 660 tonnes of bio-waste; in Flanders,
treatment capacity for 350 000 tonnes food waste per year is installed and 650 000 tonnes
garden waste, originating from households; also separate collection of bio-waste is already
mandatory for all businesses for garden waste, for some businesses for food waste; it has
already been decided to expand the mandatory separate collection for food waste for all
businesses from 2024 onwards.
The residual municipal solid waste still contains about 200 000 tonnes of bio-waste
(theoretical maximum); there is an expansion in digestion capacity of bio-waste on the existing
bio-waste composting plants in Flanders planned during the next years.
• The separate collection rate for garden waste in Wallonia is similar to Flanders (67 kg garden
waste per person in 2019); for food waste the collection rate was 17 kg per person; so in total
about 300 000 tonnes of bio-waste was collected and treated in 2019. No information is
available about the overall treatment capacity for bio-waste in the Walloon region; separate
collection of bio-waste is currently only mandatory for households, with expansion to non-
households under investigation.
The residual municipal solid waste still contains about 220 000 tonnes of bio-waste
(theoretical maximum).

Summary result
Based on current information, Flanders collects and treats about 80 % of
bio-waste separately. This means that Flanders already has treatment
capacity for 80 % of the generated municipal bio-waste.
For BCR, this is currently only about 20 %, but the Government is
preparing the operational implementation of a biomethanisation unit in
Enough bio-waste treatment Brussels.
capacity for 80% of generated In Wallonia about 60 % of municipal bio-waste is collected and treated.
municipal bio-waste No firm plans to expand capacity are foreseen. However, a prospective
needs study to have an integrated planning of waste management
infrastructure must be carried out every 4 years under the PWD-R and
might/should identify the need for additional capacity timely.
Belgium as a whole has enough bio-waste treatment capacity to cover
more than 80 % of generated municipal bio-waste in Belgium.
The information can be considered robust, and was provided by the
Robustness of the underlying
regional authorities in response to the questionnaire by the EEA and
information
ETC/WMGE.

SRF MSWR-7.2: Legally binding national standards and Quality Management System for
compost/digestate
To create a market for compost and digestate, compost should be of a good quality for use as a soil
improver or fertilizer. Legally binding standards provide guarantees regarding the quality of the
compost/digestate produced. A quality management system aims at addressing different elements of

23
a production process to ensure a stable and high-quality output (product) which helps toward
reaching a defined quality for the product.

Flanders has a strong focus on the quality of the collected bio-waste, through strict requirements on
the quality of the compost. Flanders has a regional standard for compost quality, complemented with
a voluntary Quality Management System for the certification of compost (EEA, 2020). To be able to
use the output of composting as a product (as soil improver or for fertilizing purposes) in Flanders, an
independent certification scheme, called Vlaco, has been in place since 1992. In the certification
process, the operational management, the input streams, the process and the final product are
checked, through sampling and intensive company auditing.

On top of this certification scheme, an extra quality label exists, the Vlaco label. The compost producer
voluntarily commits to achieving stricter standards than those for the inspection certificate (legal
standards). In addition, the composting process is monitored more intensively, more samples are
taken and more administrative checks are carried out by Vlaco. Compost with the Vlaco label is
guaranteed to contain at least 18 % organic matter (instead of 16 %), consists of at least 55 % dry
matter (instead of 50 %) and contains even fewer impurities (0.25 % instead of 0.50 %).

In Wallonia, compost can get a utilisation certificate from the Walloon authorities on a case by case
basis, but a general certification system is not applied. Information on quality standards and
certification schemes for BCR are not available.

Summary result
Flanders has well-developed quality standards as well as a quality
No national standards or quality management system.
management system, or still Wallonia does not have a general certification system but applies
under development administrative norms on a case by case basis.
No information is available for BCR.
Robustness of the underlying The information can be considered robust, and was provided by the
information regional authorities through the EEA-ETC/WMGE questionnaire.

24
2.2 Target for the recycling of packaging waste
This chapter aims at assessing the prospects of Belgium to achieve the 65 % recycling target for
packaging waste in 2025 as well as the material specific packaging waste recycling targets (50 % of
plastic; 25 % of wood; 70 % of ferrous metals; 50 % of aluminium; 70 % of glass; 75 % of paper and
cardboard), and according to the provisions of the Directive (EU) 2018/852 of the European Parliament
and of the Council of 30 May 2018 amending Directive 94/62/EC on packaging and packaging waste.
This Directive was transposed through the Cooperation Agreement of 5 March 2020 containing an
amendment of the Cooperation Agreement of 4 November 2008 on the prevention and management
of packaging waste.
In order to conclude on this likelihood, the analysis takes stock of the status of several factors that are
proven to influence the levels of recycling in a country. For a detailed description of the methodology
followed, the development of success/risk factors and their impact on recycling, please consult the
Methodology report (ETC/CE & ETC/WMGE, 2022).

According to the provisions of the Cooperation Agreement of March 5, 2020, the following minimum
recycling rates also have to be achieved for the whole of Belgium for the various packaging materials
from 2021 onwards:
• 90 % by weight for glass;
• 90 % by weight for paper/cardboard;
• 90 % by weight for drink cartons;
• 90 % by weight for ferrous metals;
• 75 % by weight for aluminium;
• 50 % by weight for plastics;
• 80 % by weight for wood.
And furthermore, for household packaging waste, as from calendar year 2023, a minimum recycling
rate of 65% by weight for plastics must be achieved for the whole of Belgium. For industrial and
commercial packaging waste, as from calendar year 2023, a minimum recycling rate of 55 % by weight
for plastics must be achieved for the whole of Belgium.
Finally, for household packaging waste, as from calendar year 2030, a minimum recycling rate of 70 %
by weight for plastics must be achieved for the whole of Belgium.
And for industrial and commercial packaging waste, as from calendar year 2030, a minimum recycling
rate of 65 % by weight for plastics must be achieved for the whole of Belgium.
Also, the target recycling rates listed above shall be calculated using the methods determined by the
Interregional Packaging Commission, in accordance with European law, i.e. with the calculation rules
laid down in Commission Implementing Decision (EU) 2019/665.

2.2.1 Current situation and past trends

SRF P-1.1 Distance to target
The actual distance to the target for the most recent data point is a key factor determining the
likelihood of meeting or not meeting the target. This analysis is based on data reported by Belgium to
Eurostat in accordance with Commission Decision 2005/270/EC as last amended by the Commission
Implementing Decision 2019/665 (EC, 2019), published in the dataset Recycling rates of packaging
waste for monitoring compliance with policy targets, by type of packaging [env_waspacr]. The latest
available data refer to 2019. The performance of Belgium for 2019 is illustrated in Figure 2.2.

25
Figure 2.2 Packaging recycling rates for Belgium in 2019, in percentage

Note: No data available for ferrous metals and aluminium, only for metallic packaging
Source: Eurostat (2022c), EU (2018)

For Belgium, the 2019 recycling rates for total packaging as well as all individual materials exceed the
2025 targets, except for plastics. For metals, the reported rates do not make a distinction between
ferrous metals and aluminium, but the total recycling rate for metals exceeds the highest recycling
requirement (70 % for ferrous metals) with a large margin.

However, the recycling rates presented are based on the calculation rules of the Commission Decision
C(2005)854 and will likely differ from the recycling rates to be reported according to the calculation
rules laid down in Commission Implementing Decision 2019/665.
A key difference, inter alia, in the new calculation rules compared to the old rules is that the amount
of sorted packaging waste that is rejected by the recycling facility shall not be included in the reported
amount of recycled packaging waste.
Sorting residues from sorting plants have never been part of the Belgian reported figures; batches of
sorted materials refused by recyclers have in the past always been deducted from the recycling results.
Also data on the amount of packaging material placed on the market (PoM), which represents the
common denominator of the recycling rate, was corrected for factors, which may cause an
underreporting, such as the amount of packing material, which was not licensed via EPR schemes (free
riders). According to the quality report submitted alongside the data reported to Eurostat, no
information was, however, provided upon losses within the recycling plants and it appears likely that
losses during recycling were not accounted for.

As a matter of sensitivity analysis, to assess what the impact of these new calculation rules could be,
recycling losses found in literature (EXPRA, 2014) were applied to the packaging recycling rates as
reported for reference year 2019:
• Paper and cardboard packaging: decrease by 10 %, from 92.3 % to 83.1 %

26
 • Plastic packaging: decrease by 21 %4, from 47.3 % to 37.3 %
• Metal packaging: decrease by 14 %, from 95.0 % to 81.7 %
• Glass packaging: decrease by 5 %, from 100 % to 95 %
• Wooden packaging: decrease by 11 % from 80.5 % to 71.6 %
• Total packaging: Calculated based on the amounts of each packaging material generated and
recycled in 2019, the recycling rate would drop from 83.5 % to 74.9 %.
Taking these recycling losses into account hardly affects the situation for Belgium with respect to the
distance to target analysis; only for plastics the 2025 target would not be reached yet in 2019. A study
on the impact of the new calculation rules for recycling target is currently conducted by the IRPC, but
is not yet available.
Until 2018, the scope of plastic packaging collection was limited to PET/PE/PP bottles and flasks. The
recycling losses for this waste stream are typically lower than the numbers in the EXPRA report.

The reported data on generated packaging waste relies mainly on data provided by the PROs,
complemented with estimates of packaging put on the market by free riders, through online sales,
private imports and entities below the reporting threshold (de minimis) (Eurostat, 2021b). The
reported recycling rates for paper and cardboard, metals, glass and wooden packaging are all above
90 %, indicating a very high efficiency of the packaging waste collection system. However, a recycling
rate of 98-100 % seems unrealistic even in a very efficient system, indicating that the data might not
reveal the full picture and might point at some underreported packaging put on the market,
potentially with e-commerce and cross-border shopping as the main drivers. Therefore, the
estimation methods of the total market for household and industrial/commercial packaging waste are
being continually improved.

Summary result
Belgium reports a recycling rate of 85.3 %. If the
new calculation rules were applied (taking into
Total
Target exceeded account losses in the recycling plants), the
packaging
estimated recycling rate would drop to 74.9 %, 9.9
percentage points above the target.
Belgium reports a recycling rate of 92.3 %. If the
Paper and new calculation rules were applied (taking into
cardboard Target exceeded account losses in the recycling plants), the
packaging estimated recycling rate would drop to 83.1 %, 8.1
percentage points above the target.
Ferrous Belgium reports a recycling rate of 95 %. If the new
metals Target exceeded calculation rules were applied (taking into account
packaging losses in the recycling plants), the estimated
recycling rate would drop to 81.7 %, 11.7 and 31.7
Aluminium percentage points above the target for steel and
Target exceeded
packaging aluminium packaging, respectively.
Belgium reports a recycling rate of 100 %. If the new
calculation rules were applied (taking into account
Glass
Target exceeded losses in the recycling plants), the estimated
packaging
recycling rate would drop to 95 %, 25 percentage
points above the target.

4
This is the weighted recycling loss taking into account the 29 % recycling loss for packaging waste from
household sources (66 %) and the 5 % recycling loss for packaging waste from commercial sources
(33 %).

27
 Belgium reports a recycling rate of 47.3 %. If the
new calculation rules were applied (taking into
Plastic 5 - 15 percentage points below
account losses in the recycling plants), the
packaging target
estimated recycling rate would drop to 37.3 %, 12.7
percentage points below the target.
Belgium reports a recycling rate of 80.5 %. If the
new calculation rules were applied (taking into
Wooden
Target exceeded account losses in the recycling plants), the
packaging
estimated recycling rate would drop to 71.6 %, 46.6
percentage points above the target.
The assessment is limited by the fact that the
recycling rates for 2019 reported by Belgium to
Eurostat do not yet reflect the new calculation rules,
Robustness of the underlying information and the impact of the new calculation rules has
therefore been estimated based on literature.
Additionally, no separate data are available for
aluminium and steel packaging.

SRF P-1.2: Past trend in Packaging Waste Recycling

The development of the historical trend in the recycling rate indicates previous efforts towards
packaging waste recycling. In this analysis the recycling rate reported in the Eurostat dataset Recycling
rates of packaging waste for monitoring compliance with policy targets, by type of packaging
[env_waspacr] (latest data year: 2019) is used. The recycling trends for packaging waste by material
in Belgium are illustrated in Figure 2.3.

Figure 2.3 Trend in packaging waste recycling rates in Belgium between 2015 and 2019, in
percentage

Source: Eurostat (2022c)

28
The overall recycling rate for packaging waste in Belgium has steadily, but only slightly, increased in
the past five years. The recycling rate of plastic and wooden packaging increased, while the recycling
rates for glass, paper and cardboard and metallic packaging remained rather stable.

Since 2019, the scope of plastic packaging collection from consumers was extended from bottles and
flasks to virtually all household packaging. This was implemented gradually to cover the whole country
in 2021. The expected impacts of this extension are estimated at 70 000 tonnes additional collection
of plastic packaging and a raise of the recycling rate from 47 to 65 % (not taking into account the effect
of the new calculation method).

Summary result
The recycling rate increased by 2 percentage points
Total over the past five years and is estimated at 74.9 % if
RR > 65%
packaging the new calculation rules would be applied (taking
into account losses in the recycling plants).
The recycling rate increased with 1.6 percentage
Paper and
points over the past five years and is estimated at
cardboard RR > 75%
83.1 if the new calculation rules would be applied
packaging
(taking into account losses in the recycling plants).
Ferrous The recycling rate decreased with 3.6 percentage
metals RR > 70% points over the past five years and is estimated at
packaging 81.7 % if the new calculation rules would be applied
Aluminium (taking into account recycling losses in the recycling
RR > 50% plants).
packaging
The recycling rate remained stable over the past five
Glass years and is estimated at 95 % if the new calculation
RR > 70%
packaging rules would be applied (taking into account losses in
the recycling plants).
The recycling rate increased by 4.7 percentage
Plastic RR < 40% and increase in last 5 years points over the past five years and is estimated at
packaging < 10 percentage points 37.3% if the new calculation rules would be applied
(taking into account losses in the recycling plant). .
The recycling rate increased by 5.6 percentage
Wooden points over the past five years and is estimated at
RR > 25%
packaging 71.6 % if the new calculation rules would be applied
(taking into account losses in the recycling plants).
The assessment is limited by the fact that the
recycling rates for 2019 reported by Belgium to
Eurostat do not yet reflect the new calculation rules,
and the impact of the new calculation rules has
Robustness of the underlying information therefore been estimated based on literature. The
trends over time seem to be robust as there are no
breaks in time series indicated. There are no data
available for ferrous metals and aluminium
separately.

29
2.2.2 Legal instruments
SRF P-2.1: Timely transposition of the revised Packaging and Packaging Waste Directive into national
law
Timely transposition of the Packaging and Packaging Waste Directive as amended by Directive
2018/852, into national law within the foreseen period is key for a waste management system in line
with EU requirements.

The Directive (EU) 2018/852 of the European Parliament and of the Council of 30 May 2018 amending
Directive 94/62/EC on packaging and packaging waste, was transposed into Belgian national law
through the Cooperation Agreement of 5 March 2020 which amended the Cooperation Agreement of
4 November 2008 on the prevention and management of packaging waste. This was ratified by the
Government of the Walloon Region (published in the Belgian Official Gazette on 15/07/2020), the
Government of the Flemish Region (published in the Belgian Official Gazette on 04-08-2020) and the
Government of the Brussels Capital Region (published in the Belgian Official Gazette on 16/09/2020).

According to information provided by the European Commission, full transposition was achieved in
September 2021, so with a slight delay.

Summary result
The revised Packaging and Packaging Waste Directive into national law
Transposition with a delay of
has been transposed with only minor delay into national law in all three
less than 12 months
regions.
The assessment is based on information provided the Belgian national
Robustness of the underlying
authority. Information was also received from the European Commission
information
(status as of 12 November 2021).

SRF P-2.2: Responsibilities for meeting the targets, and enforcement mechanisms, e.g. fines etc.
In Belgium, the responsibilities of authorities for packaging waste are defined in a similar way as for
municipal solid waste. Main (and only) difference is that specific arrangements have been laid down
in an interregional Cooperation Agreement on packaging and packaging waste, leading to the
establishment of an interregional governmental organisation, the Interregional Packaging Commission
(IRPC), responsible for monitoring the legal requirements of the producer responsibility organisations
for packaging waste in Belgium.
The Flemish Region, the Walloon Region and the Brussels-Capital Region have jointly signed the
Cooperation Agreement on the prevention and management of packaging waste. The Cooperation
Agreement is a legal framework for the prevention and management of all types of packaging waste
in Belgium, for household packaging waste as well as for industrial and commercial packaging waste.
This Cooperation Agreement is a legal document that applies to the whole of Belgium. The creation
of the Interregional Packaging Commission (IRPC) is laid down in the Cooperation Agreement.

The specific tasks of the IRPC include the following:

1. Monitoring whether companies (parties responsible for packaging, also referred to as
responsible companies) and accredited compliance organisations are fulfilling their reporting
obligation and take-back (i.e. recycling and recovery) obligation;
2. Checking the way in which the responsible companies and accredited compliance
organisations meet their statutory recycling and recovery targets (expressed as a percentage);
3. Approving or rejecting prevention plans of companies (responsible companies);
4. Granting or refusing accreditation to the organisations responsible for the promotion,
coordination and financing of selective collection, recycling and recovery of packaging waste;

30
 5. Assisting and advising the regional governments, for example by creating consultative forums,
providing logistical support or proposing legislative amendments;
6. Conducting or commissioning studies and research into the management and prevention of
packaging waste.

Additionally, two PROs for packaging waste are operational in Belgium: Fost Plus is responsible for
packaging waste from households and household applications, Valipac is responsible for packaging
waste coming from commercial and industrial activities.
PROs that do not fulfil their obligations can be charged with fines or be prosecuted.
The Cooperation Agreement sets out the obligations of parties such as the accredited compliance
organisations, companies responsible for packaging and industrial unpackers.
If a party fails to meet its obligations, it risks incurring an administrative fine and penal sanctions.
Sanctions may be imposed if one does not fulfil the take-back obligation or reporting obligation, fails
to submit a packaging prevention plan or repeatedly submits a prevention plan deemed inadequate,
and if obstructing the supervisory activities of the IRPC.
An administrative fine can be applied for failure to comply with the take-back obligation:
• EUR 500 for each tonne (or part tonne) of packaging waste that has not been recovered or
incinerated with energy recovery in waste incineration plants within the prescribed time
limits,
AND
• EUR 1 000 for each tonne (or part tonne) of packaging waste that has not been recycled within
the prescribed time limits.
However, the total amount of the administrative fine may not exceed EUR 25 000.

The penal sanctions can be severe, depending on the seriousness of the offence. The most serious
offences are punishable by a custodial sentence of between one and twelve months and a fine ranging
from EUR 1 000 to EUR 2 000 000. These penal fines must be increased by the statutory multiplication
factor (to correct for inflation). Sanctions and penal provisions are included in chapter 6 of the of the
Cooperation Agreement.

PROs are also monitored on their performance, both their financial performance as the distance to
target, and they have to foresee budget for setting up innovation, research and communication, in
accordance with the regional authorities.

Summary result
Clearly defined responsibilities, The information available indicates that the responsibility for reaching
enforcement and good set of the targets is set on PROs and that there are direct financial
support mechanisms for consequences if the targets are not met. Support mechanisms are in
meeting the recycling targets place for the PROs to improve their performance.
Robustness of the underlying Credible information received from the Belgian authorities through the
information EEA-ETC/WMGE questionnaire.

2.2.3 Economic instruments

SRF P-3.1: Taxes and/or ban for landfilling residual- or biodegradable waste
Bans and taxes on landfilling of residual waste can help to discourage landfilling and thus support
recycling, also of packaging waste.

31
As described in Section 2.1.3 in more detail, Belgium has an extensive landfill ban and a landfill tax.
These incentives also affect packaging waste.

Summary result
Flanders and Wallonia have a ban in place for landfilling residual and
Ban in place for landfilling
biodegradable waste. Both regions also apply landfill taxes, while BCR
residual or biodegradable waste
does not have own landfills.
Robustness of the underlying Credible information received from the Belgian authorities through the
information EEA-ETC/WMGE questionnaire.

SRF P-3.2: Taxes on municipal waste incineration

Taxes on incineration of residual waste can help to discourage strong reliance on residual waste
treatment and thus support recycling. As described in Section 2.1.3 in more detail, Belgium has a tax
on waste incineration.

Summary result
A tax of at least 13.38 EUR/t* (corresponding to 11.5 EUR/t rescaled
Taxes > 7 EUR/t(a), but without based on purchasing power parities) is already in place in 2021 in
escalator Flanders and Wallonia or will be in place soon (in 2022) in BCR. However,
no escalator is applied.
Robustness of the underlying Credible information received from the Belgian authorities through the
information EEA-ETC/WMGE questionnaire.
(a) Note: rescaled based on purchasing power parities Eurostat (2020)

SRF P-3.3: Packaging taxes

Packaging taxes can support the aim to reduce packaging waste generation and/or to influence the
choice of packaging materials and encourage recyclability and eco-design.
According to the information available, Belgium applies a packaging tax both on reusable and non-
reusable beverage packaging. For non-reusable beverage packaging, a tax of 9.86 EUR/hectolitre of
product packed in individual packages is applicable. For reusable beverage packaging, the rate is
1.41 EUR/hectolitre.
This is federal legislation, Law of 16 July 1993 (16 JUILLET 1993. - Loi ordinaire visant à achever la
structure fédérale de l'Etat, Livre III.) It is applicable on top of the EPR fees. The fees only apply to
individual recipients, excluding barrels etc. There has been no evolution in the fees for several years.

Summary result
In Belgium, a packaging tax is applicable for all beverage packaging. For
Packaging taxes in place
reusable packaging the tax rate is lower than for non-reusable packaging.
Robustness of the underlying Credible information received from the Belgian authorities through the
information EEA-ETC/WMGE questionnaire.

SRF P-3.4: Pay-as-you-throw (PAYT) system in place

Given the relevance of packaging waste management from households for the recycling targets of
packaging waste, PAYT systems influence the recycling rate of packaging waste.

As described in Section 2.1.3 in more detail, PAYT schemes are used in both Flanders and Wallonia.

32
Summary result
Both Flanders and Wallonia have a PAYT scheme covering 100 % of the
PAYT scheme fully rolled out (to
inhabitants. BCR has no PAYT scheme. Flanders and Wallonia cover
at least 80% of the population)
more than 80 % of the Belgian population.
Data both from the Belgian authorities through the EEA-ETC/WMGE
Robustness of the underlying
questionnaire and additional literature resources. Data is considered
information
robust.

SRF P-3.5: Deposit-return systems

Deposit Return Systems (DRS) generate high capture rates for packaging covered by the system and
thus contribute to increased recycling rates.

In Belgium only a voluntary deposit system applies for certain types of reusable packaging. For
example, for certain reusable household packaging such as glass bottles for drinks (beer, soft drinks,
milk, and even for certain wines); and for certain types of reusable industrial and commercial
packaging such as metal barrels for beer, various plastic containers, and pallets in wood or plastic. In
Belgium there is currently no deposit system for single-use packaging.

All reusable packaging are exempt of the EPR fee.

Summary result
Aluminium
No DRS No DRS in place
drink cans
Glass drink
Voluntary DRS for some drink bottles Voluntary for some reusable drink bottles
bottles
Plastic drink
No DRS No DRS in place
bottles
Plastic Voluntary DRS for some plastic
Voluntary for some reusable plastic crates
crates crates
No DRS in place for single use packaging. Voluntary
Wooden Voluntary DRS for some wooden
DRS in place for most reusable industrial packaging
packaging packaging
(pallets, IBC’s)
Credible information received from the regional
Robustness of the underlying information authorities through the EEA-ETC/WMGE
questionnaire

2.2.4 Separate collection system

SRF P-4.1: Convenience and coverage of separate collection for different packaging waste fractions
As a large part of packaging waste comes from households, separate collection systems for households
and similar sources are a key condition for achieving high recycling rates of packaging waste and for
collecting recyclables at adequate quality. Generally, the more convenient and accessible these
systems are for their users, the better results they can deliver. The material specific assessment
considers packaging waste from both household and non-household sources. For assessing the
convenience and coverage of separate collection systems for households, the same methodology is
used here as described in section 2.1.4.

33
There are two separate collection systems for packaging waste in Belgium. A system for packaging of
household origin, for which the accredited compliance organisation for this is Fost Plus, and a system
for industrial and commercial packaging, with Valipac as accredited compliance organisation. Separate
collection must take place for both household and industrial and commercial packaging waste. This is
applied for the whole Belgian territory.

The following packaging flows are collected separately for household packaging: glass, paper and
cardboard, plastics (various fractions), metals (Fe and Al), drinks cartons and a residual flow 'other' to
which the other materials belong. For household packaging waste, this residual category includes
small wooden packaging such as cigar boxes and orange boxes, stone bottles of jenever, etc. For
packaging of industrial and commercial origin, the following packaging flows are collected separately:
paper and cardboard, plastics, metals, wood, and a residual flow 'other'. For industrial and commercial
packaging, this residual category includes glass bottles from laboratory agents.

Belgium reports that the dominant system for households for separate collection of paper and
cardboard, ferrous metals, aluminium, plastic, and composite packaging is high density collection,
whereas for wood the dominant system is low-density collection.
In the accreditation of FostPlus is specifically stipulated that paper and cardboard, ferrous metals,
aluminium, plastic and composite packaging must be collected door-to-door at least every two weeks,
and in densely populated areas weekly, and, if needed, may be complemented with collection at civic
amenity sites. (IVCIE, 2018)
Separate collection of non-household packaging waste is mandatory in both BCR, Flanders and
Wallonia for paper and cardboard, ferrous metals, aluminium, glass, and plastic. For wood, it is not
mandatory in BCR, but it is in Flanders and Wallonia. For Wallonia, a threshold applies for the
packaging waste materials: 120 litres/week for glass packaging, 60 litres/week for PMC, 200
litres/week for plastic foils, 30 litres/week for paper and cardboard, 120 litres/week for non-
packaging metals.

Summary result
The dominant collection system is door-to-
1. Packaging waste from households
door collection, complemented with
A high share of the population is covered by collection at CAS, in all three regions and all
Paper and high convenience collection services areas.
cardboard 2. Packaging waste from non-household
packaging In Belgium it is mandatory for non-
sources
households to separate paper and cardboard
Separation at source is mandatory for non-
packaging waste at source, in all three
household paper and cardboard packaging
regions.
waste
1. Packaging waste from households Ferrous metals are collected co-mingled
A high share of the population is covered by door-to-door and at CAS, both in cities,
Ferrous high convenience collection services towns and suburbs and rural areas.
metals 2. Packaging waste from non-household
packaging In Belgium it is mandatory for non-
sources
households to separate metals packaging
Separation at source is mandatory for non-
waste at source, in all three regions.
household ferrous metals packaging waste
Packaging waste from households Aluminium is collected co-mingled door-to-
Aluminium
A high share of the population is covered by door and at CAS, both in cities, towns and
packaging
high convenience collection services suburbs and rural areas.

34
 For glass, the dominant collection method is
1. Packaging waste from households door-to-door (only in Flanders) or by bring
A high share of the population is covered by points.
high convenience collection services Additionally, glass waste is also collected at
Glass
CAS.
packaging
2. Packaging waste from non-household
In Belgium it is mandatory for non-
sources
households to separate glass packaging
Separation at source is mandatory for non-
waste at source, in all three regions.
household glass packaging waste
1. Packaging waste from households Plastics are collected co-mingled door-to-
A high share of the population is covered by door and at CAS, both in cities, towns and
high convenience collection services suburbs and rural areas.
Plastics
packaging 2. Packaging waste from non-household
In Belgium it is mandatory for non-
sources
households to separate plastic packaging
Separation at source is mandatory for non-
waste at source, in all three regions.
household plastic packaging waste
Packaging waste from non-household
In Belgium it is mandatory for non-
Wooden sources
households to separate wooden packaging
packaging Separation at source is mandatory for non-
waste at source.
household wooden packaging waste
Credible information received from the
Robustness of the underlying information Belgian authorities through the EEA-
ETC/WMGE questionnaire.

SRF P-4.2: Firm plans to improve the convenience and coverage of separate collection for the different
packaging waste fractions
To improve the type and coverage of separate collection, concrete plans are needed.

Belgium already has very convenient collection systems for packaging waste, and none of the three
Belgian regions has firm plans to further improve the type and coverage of separate collection for
packaging waste fractions.

The assessment is done on a material basis and summing up the scores of the different materials
according to their average share in packaging waste5. Again, the material specific assessment
considers packaging waste from both household and non-household sources.

5
Based on data from Eurostat on the average share of packaging materials in total packaging

35
Summary result
1. Packaging waste from households
N/A (for countries in which a very high
Paper and share of the population is already covered
cardboard by high convenience collection services)
packaging 2. Packaging waste from non-household
sources
N/A (for countries already having
mandatory separation at source)
1. Packaging waste from households
N/A (for countries in which a high share of
Ferrous the population is already covered by high
metals convenience collection services)
packaging 2. Packaging waste from non-household
sources
N/A (for countries already having
mandatory separation at source)
Packaging waste from households
Aluminium N/A (for countries in which a high share of Belgium already has very convenient
packaging the population is already covered by high collection systems for packaging waste, and
convenience collection services) none of the three Belgian regions have firm
1. Packaging waste from households plans to further improve the type and
coverage of separate collection for packaging
N/A (for countries in which a very high
waste fractions.
share of the population is already covered
Glass by high convenience collection services)
packaging 2. Packaging waste from non-household
sources
N/A (for countries already having
mandatory separation at source)
1. Packaging waste from households
N/A (for countries in which a very high
share of the population is already covered
Plastics by high convenience collection services)
packaging 2. Packaging waste from non-household
sources
N/A (for countries already having
mandatory separation at source)
Packaging waste from non-household
Wooden sources
packaging N/A (for countries already having
mandatory separation at source)
Robustness of the underlying information Credible information received from the
Belgian authorities through the questionnaire
from the EEA and ETC/WMGE.

2.2.5 Extended producer responsibility (EPR) and similar schemes

SRF P-5.1: Coverage of EPR schemes
For households, Fost Plus manages and coordinates the separate collection of the following packaging
waste fractions for both Flanders, Wallonia and BCR: glass, paper and cardboard, metal (ferrous and
aluminium), plastics and drink cartons. Similarly, Valipac covers these packaging waste fractions in
Belgium for non-household sources.

36
Summary result
All main packaging fractions(a)
are covered by EPR schemes, A separate EPR scheme is active for all main packaging fractions
covering household and non- respectively for households (Fost Plus) and for non-households (Valipac).
household packaging
Robust information received from the Belgian authorities through the
Robustness of the underlying
EEA-ETC/WMGE questionnaire, confirmed by credible information
information
consulted online.
(a) Note: Paper and cardboard, Ferrous metals, Aluminium, Glass, Plastic

SRF P-5.2: Fee modulation in EPR schemes for packaging

As explained in Section 2.1.5, fee modulation (or eco-modulation) is a system with different fees for
different types of packaging material and designs. The assessment is the same as described in Section
2.1.5
Summary result
There is advanced fee
modulation in at least two of Both sortability and recyclability are taken into account for plastics and
the main packaging fractions(a) paper and cardboard.
AND fee modulation for one In addition, the PRO performs transparent compliance checks on the
packaging fraction meets three data provided by all involved actors.
assessment criteria
Robustness of the underlying
The fee structure is transparent and publicly available.
information
(a) Note: Paper and cardboard, Ferrous metals, Aluminium, Glass, Plastic

SRF P-5.3 Material specific EPR assessment

The material specific assessment is based on a combination of the coverage of the material-specific
EPR schemes and the use of fee modulation for the specific packaging material. The assessment takes
the different situations for different types of materials into account: Plastics packaging is the
packaging material that is the most difficult to recycle out of the packaging materials targeted by the
Packaging and Packaging Waste Directive. Fee modulation therefore plays a larger role for plastic
packaging than for the other materials and is therefore rated differently from paper/cardboard,
ferrous metals, aluminium and glass. The methodology foresees a green score for plastics packaging
only if all four fee modulation assessment criteria mentioned above are met. On the other hand,
wooden packaging is mainly generated by commercial and industrial sources and fee modulation is
less relevant, therefore the methodology only relies on EPR schemes for wooden packaging from
commercial and industrial sources.

The wooden packaging declared to Fost Plus, such as cigar boxes and small orange boxes, are placed
in the residual category 'other materials'. The global recycling and recovery targets apply, but there is
no material specific target for household wood packaging waste. The European target for wood
packaging waste is entirely met by the target for industrial and commercial wood packaging waste.
The wooden packaging declared to Valipac, such as wooden crates and wooden pallets, comprises a
separate waste stream and forms a separate material stream.

The tariffing system for packaging materials for households is explained in 2.1.5.
For industrial packaging (non-households) the tariffs applied are presented in Table 2.6. This implies
that distinction is made based on recyclability at the material level only and not within the material
level.

37
Table 2.6 2020 tariffs for industrial packaging in Belgium

Tariffs (VAT excluded) per ton of industrial packaging reported 2020

Single-use packaging EUR/t
Paper/cardboard, metal, glass, natural fibres, wood and other recyclable materials 14.50
Recyclable plastic 39.50
Recyclable plastic for construction industry 49.50
Non-recyclable materials (non-recyclable plastic included) 53.00
Reusable packaging 0

Summary result
SRF P-5.3.1
EPR scheme covering Belgium has an EPR scheme in place covering
EPR scheme for
household and non-household household, industrial and commercial packaging for
Paper and
packaging but no advanced fee paper and cardboard packaging waste, but limited
cardboard
modulation applied fee modulation.
packaging waste
SRF P-5.3.2 EPR scheme covering
Belgium has an EPR scheme in place covering
EPR scheme for household and non-household
household, industrial and commercial packaging,
Ferrous metals packaging but no advanced fee
but limited fee modulation.
packaging waste modulation applied
SRF P-5.3.3 EPR scheme covering
Belgium has an EPR scheme in place covering
EPR scheme for household and non-household
household, industrial and commercial packaging,
Aluminium packaging but no advanced fee
but limited fee modulation.
packaging waste modulation applied
SRF P-5.3.4 EPR scheme covering
Belgium has an EPR scheme in place covering
EPR scheme for household and non-household
household, industrial and commercial packaging,
Glass packaging packaging but no advanced fee
but limited fee modulation.
waste modulation applied
EPR scheme covering Belgium has an EPR scheme in place covering
SRF P-5.3.5
household and non-household household, industrial and commercial packaging,
EPR scheme for
packaging, with a fee but limited fee modulation. Fees are modulated for
Plastic packaging
modulation meeting at least household packaging but not for
waste
two assessment criteria commercial/industrial packaging.
SRF P-5.3.6
EPR scheme for EPR scheme covering all non- The EPR scheme covers wood for business in entire
Wooden household packaging Belgium.
packaging waste
Robust information provided by the Belgian
authorities through the EEA-ETC/WMGE
Robustness of the underlying information
questionnaire, complemented with reliable online
information from PROs.

38
2.3 Target on landfill of municipal waste
2.3.1 Current situation and past trends
SRF LF-1.1: Distance to target
The Landfill directive (1999/31/EC), as amended by Directive (EU) 2018/850, sets a target to reduce,
by 2035, the amount of municipal waste landfilled to 10 % or less of the total amount of municipal
waste generated (by weight).

Data to show the current rate of landfilling in line with the reporting rules will only be reported by
mid-2022. Therefore, this analysis calculates the landfilling rate based on the current Eurostat dataset
Municipal waste by waste management operations [env_wasmun]; by dividing the amount of
landfilled waste by the total amount of waste generated. The overall landfilling rate of Belgium was
1.1 % in 2020.

Summary result
Target exceeded The landfill rate in Belgium in 2020 is 1.1 %.
The data are derived from Eurostat and are considered to be rather
robust. However, the reported landfill rate might increase once the new
Robustness of the underlying calculation rules laid down in the Commission Implementing Decision
information (EU) 2019/1885 will be applied. Based on the available information, it is
currently not possible to quantify the impact of the new calculation rules
on the landfill rate.

SRF LF-1.2: Past trend in municipal solid waste landfill rate

Over the past five years, the overall landfilling rate of Belgium has been lower than 1 % (Figure 2.4).
This is merely due to fluctuation of the total generated waste rather than from the amount of
landfilled waste.

39
Figure 2.4 Landfilling in Belgium between 2016 and 2020, in percentage

Source: Eurostat (2022a).

Summary result
The landfill rate in Belgium was between 0,8 and 1.1 % during the past
Landfill rate in 2020 < or = 10%
five years.
Robust information, as in Eurostat databases and official regional and
Robustness of the underlying national reports. However, the reported landfill rate does not yet
information implement the new calculation rules laid down in the Commission
Implementing Decision (EU) 2019/1885.

SRF LF-1.3: Diversion of biodegradable municipal waste from landfill

Landfilling of biodegradable municipal waste is banned in Belgium, and the reported rate of landfilled
biodegradable municipal waste has been reported as 0 % in 2017, 2018 and 2019 (EC, 2022).

Summary result
Target for reducing the amount
of biodegradable municipal
waste (BMW) landfilled to 35 %
The landfill rate of biodegradable municipal waste related to the
of BMW generated in 1995 has
biodegradable municipal waste generated in 1995 is 0 %.
been achieved in 2016 or in the
year specified in the derogation
where applicable
Robust information, available in regional and national reports and
Robustness of the underlying
legislation. Data provided by the European Commission based on data
information
reported by Belgium.

40
3 Conclusion
This risk assessment indicates whether Belgium is at risk of not meeting the targets. The ‘total risk’
categorization is the result of the sum of the individual scores of each SRF as described in the previous
chapter, where the assessment of each SRF results in a score of 2 points (green), 1 point (amber) or
0 points (red), depending on the assessment of the SRF. As some SRFs are considered to have a higher
impact on meeting the target, the score of the SRF is multiplied by the defined weight of the SRF. As
some SRFs might not be applicable to Belgium, only the SRFs relevant to Belgium are taken into
account to define the maximum score. Belgium is considered to be ‘not at risk’ if its score is more than
50 % of this maximum score, and ‘at risk’ if its score is less than 50 % of this maximum score.

3.1 Prospects for meeting the recycling target for municipal solid waste

Based on the provided information and the analysis done, it is

55 % concluded that Belgium is not at risk for not meeting the MSW
recycling target in 2025.
of maximum score
Based on the currently available data, Belgium’s recycling rate
lies at 54.2 % in 2020, 0.8 percentage points below the 2025
target. However, the Flemish and BCR authorities have estimated
that the application of the new calculation rules would reduce
the recycling rate by 10.5 – 12 percentage points while no similar
Current situation and past
estimate is available for Wallonia. Assuming that application of
trends:
the new calculation rules will have a similar effect in Wallonia as
in Flanders and BCR, this would result an estimated recycling rate
of 43.5 %, 11.5 percentage points below the target.
The recycling rate has increased with 0.7 percentage points over
the past five years.
The transposition of the Directive was not finalised by the three
regions within 12 months after the deadline.

Legal instruments: Responsibilities are clearly defined and some support

mechanisms for municipalities are in place, but there are no
direct consequences for the responsible municipal authorities if
the targets are not met for the entire country.

Flanders and Wallonia have a ban in place for landfilling residual

and biodegradable waste. Both regions also apply landfill taxes,
while BCR does not have any landfills.
An incineration tax is already in place in 2021 in Flanders and
Economic instruments: Wallonia or will be in place soon (in 2022) in BCR.
Both Flanders and Wallonia have a PAYT scheme covering 100 %
of the inhabitants. The tariffing system is mainly based on
volume, frequency and/or weight.
BCR has no PAYT scheme.

41
 To foster the recycling of municipal waste, separate collection
has been part of the strategy of Flanders and Wallonia for many
years. Since several years, also BCR has joined this approach.
Belgium reports that the dominant system for separate collection
of paper and cardboard waste, and for metals and plastics is high
Separate collection systems:
convenience collection, whereas for textiles and wood the
dominant system is low-density collection. For glass and bio-
waste the situation depends on the preferences and priorities of
the municipalities. There are firm plans to improve plastics
separate collection as well as bio-waste collection.
In Belgium, one national PRO (Fost Plus) is in charge for all
Extended producer household packaging covering all three regions. Similarly, Valipac
responsibility: is the national PRO for all non-household packaging.
Advanced fee modulation is applied.

The overall available bio-waste capacity for Belgium is estimated

to be more than 80 % of the generated municipal bio-waste.
However, there are significant differences between the three
Bio-waste treatment capacity
regions. Quality standards and a quality management system for
and quality management:
compost/digestate are only in place in Flanders, while in Wallonia
there are administrative norms that are applied on a case by case
basis.

42
Prospects for meeting the recycling targets for packaging waste

94 % Based on the provided information and the analysis done, it is

concluded that Belgium is not at risk for not meeting the 65 %
of maximum score recycling target for total packaging waste in 2025

90 % of maximum score Paper and cardboard packaging Not at risk

90 % of maximum score Ferrous metals packaging Not at risk

84 % of maximum score Aluminium packaging Not at risk

84 % of maximum score Glass packaging Not at risk

59 % of maximum score Plastics packaging Not at risk

88 % of maximum score Wooden packaging Not at risk

The 2019 recycling rates for total packaging as well as all individual
materials exceed the 2025 targets, except for plastics, which is 12.7
Current situation and past
percentage points below the target.
trends:
The overall recycling rate for packaging waste in Belgium has
steadily, but only slightly, increased in the past five years.
The revised Packaging and Packaging Waste Directive has been
transposed into national law with a delay of less than 12 months.
Responsibilities are clearly defined and enforcement mechanisms
Legal instruments: are in place. The responsibility for reaching the targets is set on
PROs and there are direct financial consequences if the targets are
not met. Additionally, there are support mechanisms for the PROs to
improve their performance.

Belgium has banned the landfilling of mixed municipal waste, and

applies adequate taxes for both landfilling and incineration.

Economic instruments: A packaging tax is applicable for all beverage packaging. There is a
PAYT scheme in place in Flanders and Wallonia, covering 100 % of
inhabitants. BCR has no PAYT scheme. There are no or only
voluntary DRS for packaging.

There are two separate collection systems for packaging waste in

Belgium: a system for packaging of household origin and a system
for industrial and commercial packaging.
Separate collection
For all main packaging fractions a high share of the population is
systems:
covered by high convenience services.
Separation at source is mandatory for both households and non-
households, for all main packaging waste fractions.

43
 All main packaging fractions are covered by EPR schemes, covering
Extended producer household and non-household packaging, and advanced fee
responsibility: modulation is applied for some packaging fractions from
households.

3.2 Prospects of meeting the landfill of municipal waste target

Based on the provided information and the analysis done, it is

100 % concluded that Belgium is not at risk for not meeting the 2035 target
to reduce the amount of municipal waste landfilled to 10 % or less
of maximum score of the total amount of municipal waste generated.

Current situation and past The landfill rate in Belgium was between 0.8 and 1.1 % during the
trends: last five years.

Diversion of biodegradable
municipal waste from No biodegradable municipal waste is landfilled in Belgium.
landfill:

44
List of abbreviations
Abbreviation Name
ABP Bruxelles-Propreté
BCR Brussels Capital Region
BMW Biodegradable Municipal Waste
CAS Civic Amenity Site
DRS Deposit Return System
EEA European Environment Agency
EPR Extended producer responsibility
ETC/CE European Topic Centre on Circular Economy
ETC/WMGE European Topic Centre on Waste and Materials in a Green Economy
IRPC Interregional Packaging Commission
MBT Mechanical biological treatment
MSW Municipal solid waste
NWMP The National Waste Management Plan
PAYT Pay-as-you-throw
PET Polyethylene terephthalate
PGRD Plan de Gestion des Ressources et des Déchets
PMC Plastics, metals, drink cartons
PPWD Packaging and Packaging Waste Directive
PRO Producer Responsibility Organisation
PWD-R Walloon Waste-Resource Plan
RR Recycling rate
RWMP Regional Waste Management Plans
SPW ARNE Service Public de Wallonie Agriculture, Resources naturelles et
Environnement
SRF Success and risk factor
TOC Total organic carbon
VAT Value Added Tax
WEEE Waste Electric and Electronic Equipment
WFD Waste Framework Directive

45
References
Brussels environment, 2022, Information and comments provided to the EEA by Brussels Environment
during the review of this assessment by e-mail dated 26 April 2022.

EC, 2019, Commission Implementing Decision (EU) 2019/665 of 17 April 2019 amending Decision
2005/270/EC establishing the formats relating to the database system pursuant to European
Parliament and Council Directive 94/62/EC on packaging and packaging waste (notified under
document C(2019) 2805) (Text with EEA relevance.) (OJ L 112, 26.4.2019, p. 26–46).

EC, 2022, Data on the landfill of biodegradable municipal waste, 2018-2019, provided to the EEA by
the European Commission, status 14/01/22.

EEA, 2020, Bio-waste in Europe — turning challenges into opportunities, EEA report No 4/2020,
European Environment Agency (https://www.eea.europa.eu/publications/bio-waste-in-europe)
accessed 20 June 2020.

EEB, 2020, Circular Economy: Member States delay meeting the inevitable targets.

ETC/CE & ETC/WMGE, 2022, Methodology for the Early Warning assessment related to certain waste
targets, ETC/CE Report, European Topic Centre on Circular Economy and resource use.

ETC/WMGE, 2021, Methodology for the Early warning assessment related to certain waste targets,
ETC/WMGE Working Paper, European Topic Centre on Waste and Materials in a Green Economy
(https://www.eionet.europa.eu/etcs/etc-wmge/products/etc-reports/methodology-for-the-early-
warning-assessment-related-to-certain-waste-targets) accessed 29 April 2021.

EU, 2018, Directive (EU) 2018/852 of the European Parliament and of the Council of 30 May 2018
amending Directive 94/62/EC on packaging and packaging waste (text with EEA relevance) (OJ L 150,
14.6.2018, p. 141-154).

Eurostat, 2020, ‘Comparative price levels of consumer goods and services’

(https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Comparative_price_levels_of_consumer_goods_and_services) accessed 6
May 2021.

Eurostat, 2021a, ‘Household characteristics by degree of urbanisation (HBS_CAR_T315)’

(https://ec.europa.eu/eurostat/databrowser/view/HBS_CAR_T315__custom_37301/default/table?l
ang=en) accessed 6 May 2021.

Eurostat, 2021b, Quality check report according to Art. 10(3b) of the Packaging and Packaging Waste
Directive for Belgium for the reference year 2019.

Eurostat, 2022a, ‘Municipal waste by waste operations [env_wasmun]’

(https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/default/table) accessed 14
February 2022.

Eurostat, 2022b, ‘Packaging waste by waste management operations [env_waspac]’

(https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__custom_842634/default/table?l
ang=en) accessed 12 March 2022.

46
Eurostat, 2022c, ‘Recycling rates of packaging waste for monitoring compliance with policy targets, by
type of packaging [env_waspacr]’
(https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_waspacr&lang=en) accessed 12
March 2022.

EXPRA, 2014, The effects of the proposed EU packaging waste policy on waste management practice:
a feasibility study, (https://www.expra.eu/downloads/expra_20141004_f_UGGge.pdf).

Gouvernement de la Région de Bruxelles Capitale, 2018, PLAN DE GESTION DES RESSOURCES ET DES
DÉCHETS, (https://environnement.brussels/sites/default/files/user_files/pgrd_181122_fr.pdf).

IVCIE, 2018, Erkenning FostPlus, (https://www.ivcie.be/wp-content/uploads/2018/10/erkenning-

Fost-Plus-2018-NL.pdf).

OVAM, 2019, UITVOERINGSPLAN HUISHOUDELIJK AFVAL EN GELIJKAARDIG BEDRIJFSAFVAL,

(https://ovam.vlaanderen.be/uitvoeringsplan-huishoudelijk-gelijkaardig-bedrijfsafval).

PSWE, 2022, Information and comments provided to the EEA by the Public service of Wallonia-
Environment (PSWE) during the review of this assessment by e-mail dated 26 April 2022.

Region de Bruxelles-Capitale, 2012, Ordonnance relative aux déchets, 14 Juin 2012,

(http://www.ejustice.just.fgov.be/cgi_loi/change_lg.pl?language=fr&la=F&table_name=loi&cn=2012
061402).

Wallonia Environment, 2018, Plan wallon des Déchets-Ressources,

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47
Annex 1 Detailed scoring of success and risk
factors

48
Assessment sheet - Recycling target for municipal waste
MS Belgium
Date Jun-22

SRF Assessment result Weight Score

Current situation and past trends

MSWR-1.1 Distance to target Distance to target 5 - 15 percentage points 5 5

RR < 45% and increase in last

MSWR-1.2 Past trends in municipal solid waste recycling rate 1 0
5 years < 10 percentage points

Legal instruments
Timely transposition of the revised WFD into national Transposition with delay of > 12 months, or no full
MSWR-2.1 1 0
law transposition yet

Clearly defined responsibilities and good set of support

tools but weak/no enforcement mechanisms for
meeting the recycling targets
OR
Unclear responsibilities but clearly defined
Clearly defined responsibilities for meeting the targets
MSWR-2.2 enforcement mechanisms and a good set of support 1 1
and support and enforcement mechanisms tools for meeting the recycling targets
OR
Clearly defined responsibilities and enforcement
mechanisms but no/weak support tools for meeting the
recycling targets

Economic instruments
Taxes and/or ban for landfilling residual or biodegradable Ban, or landfill tax > 30 EUR/t* with escalator, or landfill
MSWR-3.1 1 2
waste tax > 45 EUR/t

MSWR-3.2 Taxes on municipal waste incineration Taxes > 7 EUR/t*, but without escalator 1 1

PAYT scheme fully rolled out (to at least 80% of the

population) OR Implemented in some regions /
MSWR-3.3 Pay-as-you-throw (PAYT) system 1 2
municipalities (50-80% covered) and firm plans for
rolling out to at least 80% of the population
 Separate collection systems

Convenience and coverage of separate collection

MSWR-4.1
systems for the different household waste fractions

A high share of the population is covered by high

Paper and cardboard 0.46 0.92
convenience collection services

A medium share of the population is covered by high

Metals 0.08 0.08
convenience collection services

A medium share of the population is covered by high

Plastics 0.28 0.28
convenience collection services

A high share of the population is covered by high

Glass 0.18 0.36
convenience collection services

A medium share of the population is covered by high

Bio-waste 0.84 0.84
convenience collection services

A low share of the population is covered by high

Wood 0.06 0
convenience collection services

A low share of the population is covered by high

Textiles 0.06 0
convenience collection services
High to medium convenience collection services
WEEE 0.04 0.08
dominate
Firm plans to improve the convenience and coverage of
MSWR-4.2 separate collection systems for the different household
waste fractions
N/A (for countries in which a very high share of the
Paper and cardboard population is already covered by high convenience 0.23 0
collection services)

No firm plans to improve the convenience and

Metals 0.04 0
coverage

Firm plans to improve the separate collection system,

Plastics with clear responsible entities and defined targets and 0.14 0.28
timeline

N/A (for countries in which a very high share of the

Glass population is already covered by high convenience 0.09 0
collection services)

There are plans to improve the collection service but

Bio-waste 0.42 0.42
unclear plan for implementation

No firm plans to improve the convenience and

Wood 0.03 0
coverage

No firm plans to improve the convenience and

Textiles 0.03 0
coverage

N/A (for countries where high to medium convenience

WEEE 0.02 0
collection services dominate already)
 Extended producer responsibility (EPR) and similar schemes

There is an advanced fee modulation for at least two of

MSWR-5.1 Fee modulation in EPR schemes for packaging the main packaging fractions* AND fee modulation for 1 2
one packaging fraction meets three assessment criteria

Bio-waste treatment capacity and quality management

Enough bio-waste treatment capacity for 80% of

MSWR-6.1 Capacity for the treatment of bio-waste 1 2
generated municipal bio-waste

Legally binding national standards and Quality No national standards or quality management system,
MSWR-6.2 1 0
Management System for compost/digistate or still under development

Total score 18.26

Maximum score 33.32
55%
Assessment sheet - Recycling target for packaging waste
MS Belgium
Date Jun-22

SRF Assessment result Weight Score

Current situation and past trends
P-1.1 Distance to target - Overall packaging < 5 percentage points below target, or target exceeded 5 10

Distance to target - Paper and cardboard packaging < 5 percentage points below target, or target exceeded 5 10

Distance to target - Ferrous metals packaging < 5 percentage points below target, or target exceeded 5 10

Distance to target - Aluminium packaging < 5 percentage points below target, or target exceeded 5 10

Distance to target - Glass packaging < 5 percentage points below target, or target exceeded 5 10

Distance to target - Plastics packaging 5 - 15 percentage points below target 5 5

Distance to target - Wooden packaging < 5 percentage points below target, or target exceeded 5 10

RR > 60% and increase in

last 5 years > 5 percentage points,
or
P-1.2 Past trends in packaging waste recycling rate RR > 55% and increase in 1 2
last 5 years > 10 %,
or
RR > 65%

RR > 70% and increase in

last 5 years > 5 percentage points,
or
Past trends in paper and cardboard packaging recycling RR > 65% and increase in 1 2
last 5 years > 10 %,
or
RR > 75%

RR > 65% and increase in

last 5 years > 5 percentage points,
or
Past trends in ferrous metals packaging recycling RR > 60% and increase in 1 2
last 5 years > 10 %,
or
RR > 70%

RR > 45% and increase in

last 5 years > 5 percentage points,
or
Past trends in aluminium packaging recycling RR > 40% and increase in 1 2
last 5 years > 10 %,
or
RR > 50%

RR > 65% and increase in

last 5 years > 5 percentage points,
or
Past trends in glass packaging recycling RR > 60% and increase in 1 2
last 5 years > 10 %,
or
RR > 70%
 RR < 40% and increase in last 5 years < 10 percentage
Past trends in plastic packaging recycling 1 0
points

RR > 20% and increase in

last 5 years > 5 percentage points,
or
Past trends in wooden packaging recycling RR > 15% and increase in 1 2
last 5 years > 10 %,
or
RR > 25%
Legal instruments
Timely transposition of the revised Packaging and
P-2.1 Transposition with a delay of less than 12months 1 1
Packaging Waste Directive into national law

Clearly defined responsibilities, enforcement and good

Clearly defined responsibilities for meeting the targets
P-2.2 set of support mechanisms for meeting the recycling 1 2
and support and enforcement mechanisms targets

Economic instruments
Taxes and/or ban for landfilling residual or biodegradable
P-3.1 Ban, or landfill tax > 30 EUR/t* with escalator 1 2
waste
P-3.2 Taxes on municipal waste incineration Taxes > 7 EUR/t* 1 1
P-3.3 Packaging taxes Packaging taxes in place 1 2

PAYT scheme fully rolled out (to at least 80% of the

population) OR Implemented in some regions /
P-3.4 Pay-as-you-throw (PAYT) system 1 2
municipalities (50-80% covered) and firm plans for
rolling out to at least 80% of the population

P-3.5 Deposit-return systems for aluminium drink cans No or voluntary DRS for some drink cans 1 0

Deposit-return systems for glass drink bottles No or voluntary DRS for some drink bottles 1 0

Deposit-return systems plastic drink bottles No or voluntary DRS for some drink bottles 1 0

Deposit-return systems for plastic crates No or voluntary DRS for some plastic crates 1 0

Deposit-return systems for wooden packaging No or voluntary DRS for some wooden packaging 1 0
 Separate collection systems

Convenience and coverage of separate collection

P-4.1
systems for the different packaging waste fractions

A high share of the population is covered by high

Paper and cardboard packaging (household) 1 2
convenience collection services

Separation at source is mandatory for non-household

Paper and cardboard packaging (non-household) 1 2
paper and cardboard packaging waste

A high share of the population is covered by high

Ferrous metals packaging (household) 1 2
convenience collection services

Separation at source is mandatory for non-household

Ferrous metals packaging (non-household) 1 2
ferrous metals packaging waste

A high share of the population is covered by high

Aluminium packaging 2 4
convenience collection services

A high share of population is covered by high

Glass packaging (household) 1 2
convenience collection services

Separation at source is mandatory for non-household

Glass packaging (non-household) 1 2
glass packaging waste

A high share of the population is covered by high

Plastics packaging (household) 1 2
convenience collection services

Separation at source is mandatory for non-household

Plastics packaging (non-household) 1 2
plastic packaging waste

Separation at source is mandatory for non-household

Wooden packaging 2 4
wooden packaging waste

Firm plans to improve the convenience and coverage of

P-4.2 separate collection systems for the different packaging
waste fractions
N/A (for countries in which a high share of the
Paper and cardboard (household) population is already covered by high convenience 0.5 0
collection services)

N/A (for countries already having mandatory sorting at

Paper and cardboard (non-household) 0.5 0
source)

N/A (for countries in which a high share of the

Ferrous metals packaging (household) population is already covered by high convenience 0.5 0
collection services)

N/A (for countries already having mandatory sorting at

Ferrous metals packaging (non-household) 0.5 0
source)

N/A (for countries in which a high share of the

Aluminium packaging population is already covered by high convenience 1 0
collection services)

N/A (for countries in which a very high share of the

Glass packaging (household) population is already covered by high convenience 0.5 0
collection services)

N/A (for countries already having mandatory sorting at

Glass packaging (non-household) 0.5 0
source)
 N/A (for countries in which a very high share of the
Plastics packaging (household) population is already covered by high convenience 0.5 0
collection services)

N/A (for countries already having mandatory sorting at

Plastics packaging (non-household) 0.5 0
source)

N/A (for countries already having mandatory sorting at

Wooden packaging 1 0
source)

Extended producer responsibility (EPR) and similar schemes

All main packaging fractions* are covered by EPR

P-5.1 Coverage of EPR schemes schemes, covering household and non-household 1 2
packaging

There is fee modulation in at least two of the main

P-5.2 Fee modulation in EPR schemes for packaging packaging fractions* AND fee modulation for one 1 2
packaging fraction meets three assessment criteria

Material specific EPR assessment - Paper and cardboard EPR scheme covering household and non-household
P-5.3 1 1
packaging waste packaging

Material specific EPR assessment - Ferrous metals EPR scheme covering household and non-household
1 1
packaging waste packaging

Material specific EPR assessment - Aluminium packaging EPR scheme covering household and non-household
1 1
waste packaging

EPR scheme covering household and non-household

Material specific EPR assessment - Glass packaging waste 1 1
packaging

EPR scheme covering household and non-household

Material specific EPR assessment - Plastics packaging
packaging, with a fee modulation meeting at least two 1 1
waste assessment criteria

Material specific EPR assessment - Wooden packaging

EPR scheme covering all non-household packaging 1 2
waste

Total packaging recycling target 30.00

Maximum score 32.00
94%
Paper and cardboard recycling target
Total score 27.00
Maximum score 30.00
90%
Ferrous metals packaging recycling target
Total score 27.00
Maximum score 30.00
90%
Aluminium packaging recycling target
Total score 27.00
Maximum score 32.00
84%
Glass packaging recycling target
Total score 27.00
Maximum score 32.00
84%
Plastics packaging recycling target
Total score 20.00
Maximum score 34.00
59%
Wooden packaging recycling target
Total score 28.00
Maximum score 32.00
88%
Assessment sheet - Target for landfilling of municipal waste
MS Belgium
Date Jun-22

SRF Assessment result Weight Score

Current situation and past trends
Distance to target < 10 percentage points, or target
LF-1.1 Distance to target 5 10
exceeded

Landfill rate in 2020 < 20% and decrease in last 5 years

> 5 percentage points,
or
LF-1.2 Past trends in municipal solid waste landfill rat Landfill rate in 2020 < 25% and decrease in last 5 years 1 2
> 10 percentage points
or
Landfill rate in 2020 < or = 10%

Target for reducing the amount of biodegradable

municipal waste (BMW) landfilled to 35% of BMW
LF-1.3 Diversion of biodegradable municipal waste from landfill 1 2
generated in 1995 has been achieved in 2016 or in the
year specified in the derogation where applicable

Total score 14.00

Maximum score 14.00
100%