Sunce provided an overview for the European Commission before the preparation of the Early Warning Report to the EU member states


The Association Sunce sent a review of the European Commission’s Public Call for Statements in order to collect data for the purpose of preparing the Early Warning Report to the member states of the European Union (EU). The report is a warning to the countries that are not on track to meet the goals for recycling municipal and packaging waste by 2025 and the goal for 2035 in terms of landfills, which were transferred to our Waste Management Act (OG 84/21), and represent goals from EU directives.

Sunce, as a member of the European Environmental Bureau (EEB ) supports the opinion that EWR is a good and important tool to mobilize MS for a more ambitious and urgent action to reach the targets. However, it lacks political urgency and mandatory compliance.

The report mechanism was introduced by the package of waste directives, and the previous report was issued in 2018 towards 14 state members, among them the Republic of Croatia. In terms of goals for 2020 the Republic of Croatia failed to reach the targets regarding the waste separation and recycling for the year 2020, and since then the situation has not changed significantly.

The previous EWR stated a recycling rate for Croatia of 21%, while the municipal waste disposal rate for 2016 was 77% – among the highest rates in the EU. The official interim report of the Ministry for economy and sustainable development for 2021 shows that the rate of separate collection was 22.5 %.

This information and other findings mentioned below indicate a high risk that the Republic of Croatia will not succeed in achieving the 2025 recycling targets at least 55% of the mass of municipal and packaging waste by 2025 and the targets of disposing of a maximum of 10% of the total mass of municipal waste produced in landfills until 2035.

The recommended door to door waste collection service hasn’t been implemented in most municipalities, which is partly due to the high purchase prices of dry recyclers and the low prices of waste disposal in open landfills. A particular problem represents the collection of biowaste, which is not collected separately and disposed in composting and other facilities in most municipalities, despite the legal obligation.

There is a lack of local self-sustainability in waste management, investments in infrastructure, such as composting facilities, reuse centres, sorting rooms, etc. that would greatly facilitate the achievement of targets and efforts at the local level.

Also, the market for secondary raw materials is poorly regulated and underdeveloped. The purchase prices of separately collected waste have been declining for a long time and this represents a burden for waste management system. It is not appropriate to expect that waste management utility companies can place separately collected waste if the state does not provide them with necessary conditions. The state must ensure safe redemption and sustainable infrastructure that enables adequate shipping and efficient recycling of secondary raw materials through the extended producer responsibility system.

Since 2018, significant EU funds have been used for the implementation of educational and information activities related to waste management, procurement of containers and utility equipment. However, the percentage of waste separation and recycling has increased slightly. We believe it is necessary to revise the allocated funds and to avoid financing the municipalities that haven’t achieved a significant progress in reaching the targets.

The trend of increasing the amount of mixed municipal waste per capita is visible year after year in all Croatian municipalities. Meanwhile, insufficient measures are being taken to encourage waste prevention.

The provisions of the Single-Use Plastics Directive (SUPD) have been transposed into national law, but there is a lack of will to implement more ambitious measures that would stimulate citizens, public and private sector to ban/reduce single-use plastics from their business, service, or goods.

The lack of transfer of knowledge and experience among the main stakeholders is also recognized as a big challenge. There is a huge disparity of waste management results between the north (some municipalities separate more than 70% of their waste) and the south (some separate less than 5%). There is a need of a platform that would allow active and continuous exchange of information between relevant stakeholders.

Accordingly, Sunce also recommends the implementation of 2 regional waste management plans (instead of one national) to set priorities in a different way in less developed environments (southern region) compared to the more developed region (north).

With this review, we urge the European Commission to critically assess the official statistics in view of the above complications and propose meaningful recommendations for MS and their local municipalities.

We also request public announcement of results and activities carried out by the Republic of Croatia in relation to the findings and recommendations from the 2018 report.

Also, we urge the EC to take legal action against those governments, and thus also the Republic of Croatia, who take little or no action, in respect to EWR2018 and EWR2022 and to be stricter with its infringement processes in the future.