Unless we improve recycling, we will get bogged down in tonnes of waste

We need to stimulate the recycling industry, which has not had the chance to develop sufficiently due to negligible subsidies under the Extended Producer Responsibility (EPR) scheme and the lack of ecodesign. Without strong support, the industry will not manage waste, move us further away from a circular economy, and make it impossible to meet the EU’s stringent targets.

The recycling industry is highly fragmented in Poland. We have 300-400 large plants, including about 30 paper mills, several industrial glass recyclers and a dozen metal recyclers. The largest number of entrepreneurs recycle plastics, but only a handful of the 250 dedicated installations have the technical capacity to process more than 20,000 tonnes of raw material per year. This is disproportionately low in relation to the needs we see in the market. More than 4 million tonnes of packaging hits the shop shelves every year, 1 million of which is pure plastic packaging. Unfortunately, statistics show that one in two of them will never be recycled. Instead, it will go to a specialist waste incinerator or be illegally buried in an old pit.

It is not easy to pinpoint a single reason for such a situation. However, many waste management problems have a common link: the difficulty in processing waste, which is mainly influenced by the poor quality of selective collection in municipalities (60 to 70 per cent of waste ends up in sorting plants as mixed waste) and a lack of eco-design. The latter is nothing more than a system of guidelines defining standards for production materials and how they are combined. This set of guidelines is intended to reward environmentally-friendly solutions. Following the example of other countries, encourage companies to use materials that are easier to recycle, replace them with secondary raw materials or reduce the amount of waste produced. 

No ecodesign

There is no such system in Poland. As a result, the most essential criteria in the design of packaging continue to be its attractiveness and convenience for the consumer. This is understandable from a business perspective. Unfortunately, this means that the industry does not have to worry about what happens to the packaging once it has been emptied and thrown in the bin. Nor who will actually pay for managing this waste. And it often turns out that it will be impossible to recycle it. It is not the recyclers’ fault, but the materials used and their combinations that make the treatment process technically infeasible or financially unreasonable, because the costs of washing and separating specific fractions exceed the profit from the eventual sale of the new product made from them. 

The waste industry estimates that 50-80 percent of the contents of the yellow bin – which by definition should receive pre-sorted plastic and metal waste – are not recyclable. First example: a toothbrush that is a combination of many materials. Second example: a black meat tray. Others include paper packaging with a foil window, aluminium yoghurt lids, sauce sachets. On top of all this, there are the very common and difficult to recycle plastic wrappers in which we buy, for example, cut, already washed lettuce. Finally, polystyrene packaging, which is very light, yet takes up a relatively large space, so it is uneconomical to transport. Plastic is the most difficult to recycle. This is because each material needs a specialised installation depending on the type of polymer used. And these differ in chemical properties (e.g. chlorine content) and have different melting points. We can find six of these most recognisable plastics at home or on shop shelves (although there are dozens of different varieties).  

Contrary to popular belief that beverage bottles made of PET are the most challenging to recycle, PET is actually the easiest material to recycle, and there is no shortage of it on the market. Equally recycling-friendly is HDPE, considered to be the safest plastic for health, used in manufacturing children’s toys. It is thicker, more matte and not as popular as PET. It is used for packaging household chemicals and cleaning products. LDPE, which is used for food packaging, and plastic sacks, bags and carrier bags, is also common. A bottle cap? It is made of PP, or polypropylene, which is also used in the construction sector and to insulate electrical cables. A CD case, on the other hand, is made of polystyrene (PS). PVC, the material from which the pipes or veneers are made, closes the initial list. It can also be used as a food wrapping film. 

Urgent implementation of the Extended Producer Responsibility (EPR)

What can be done to make recycling all of these plastics, not just PET and HDPE, profitable? There are several possibilities. Above all, it will be necessary to make the rates paid by entrepreneurs under the EPR system more realistic and equal to European levels and tighten the market based on fictitious recycling and so-called trade in receipts. 

What is the Extended Producer Responsibility (EPR)? This is a mechanism that has been in place since 2001 which obliges producers to subsequently manage waste from the products they place on the market. In Poland, such regulations cover, among other things, packaging and packaging waste. The trouble is that the existing provisions – which assume that, under the EPR, businesses contribute to the costs of collection, separation and preparation for recycling – have proven totally ineffective, with insufficient funds flowing into the recycling system. According to calculations, efficient recycling of secondary raw materials would require as much as two billion zlotys per year, and according to the rules still in force, producers introduce only a fraction of this amount (i.e. several tens of millions) annually. The same fee in other EU countries is even several times higher.

Read more about the EPR here.

Ecomodulation needed 

When implementing the new EPR model, it is necessary to introduce an ecomodulation mechanism. It would reward companies that choose easy recycling materials and reduce the amount of packaging, e.g. by avoiding several layers of film coating each part of the product sold. The principle would be simple: the less a product impacts on the environment due to, among other things, the use of common and homogeneous materials, or is simply more durable and reusable, the lower the fee. Ecodesign could include the criterion of the material used and consider, e.g. the shape of the packaging, which may make it more challenging to recycle or minimise the weight of the packaging (while maintaining product safety features). 

Boosting demand for secondary raw materials

Another tool will be to oblige producers to use secondary raw materials in newly produced packaging, which will increase the demand for recyclate. Today, thanks to low oil prices, it is so cheap to manufacture a PET bottle that it is not worth using recycled material. It is easier to import a new one, sometimes from the other side of the world, than to manufacture it locally, using recycled materials. 


The fact that such an obligation will become a necessity is determined by the EU Directive on single-use plastics (the so-called SUP Directive, from single-use plastics), which was adopted in mid-2019. It is commonly identified only with a ban on the sale of plastic cutlery, plates or earbuds, but the regulations contained therein go much deeper. They stipulate that by 2025 at the latest, PET beverage bottles will have to contain a minimum of 25% recycled material. From 2030, the recycled content is to increase to 30%, and the obligation will apply to all beverage bottles, regardless of the material they are made from. 

It should be considered whether similar regulations should also be extended to other products. This would be supported by the fact that PET bottles constitute only a small percentage of the entire packaging sector (the Polish market receives about 220 thousand tonnes of them annually). In this case, PET is the only raw material whose market price remains at a good level. One explanation is the increasing pressure from consumers and the decisions of many foreign producers who have started to add recyclate to new products. 

If introduced for a larger group of products, minimum recyclate use levels should be gradually increased (e.g. by 5% year on year, starting from a baseline of 20%). In parallel, financial incentives could be put in place, such as reducing VAT on recycled products.

Investment in plants 

Sortownia odpadów komunalnych. Do takich instalacji trafiają odpady z naszych domów. Są tam dodatkowo segregowane i rozdzielane np. butelki plastikowe od puszek aluminiowych (oba, zupełnie różne w późniejszym przetwarzaniu rodzaje odpadów znajdziemy w tym samym, żółtym pojemniku na tworzywa sztuczne). Później są one belowane i przygotowywane do przekazania do recyklingu.It will also be necessary to increase the current capacity at plastic recycling facilities to fill the current investment gap. In particular, there will be a need for facilities that are currently lacking in Poland and Europe, i.e. plants for PS waste treatment. It is also necessary to develop plants that would recycle PET – tray (fruit packaging), PET – coloured in the mass (household chemical products), PP film, HDPE film. 

As estimated by the Ministry of Climate and Environment, the investment requirement could be around 0.8 - 1 million tonnes between 2028 and 2034. This would require the construction of about 20-25 facilities with a capacity of 40,000 tonnes per year for the various fractions, including in particular about 8-10 facilities for recycling PE film only from the municipal waste stream. This in turn, according to the ministry’s calculations, would require financial outlays at the level of EUR 800-1000 million (i.e. approx. PLN 3.44-4.30 billion), including for investments in the recycling of PE film only – EUR 320-600 million (i.e. approx. PLN 1.40-2.58 billion – depending on the facility’s capacity). The success of these investments will be determined by public institutions’ support and the availability of EU funds. 

Author: TOGETAIR Editors