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Waste Strategy 2005-08

1 Waste Strategy 2005-2008,
focus areas

• 1.1 Loss of resources and environmental impacts from waste must be reduced
• 1.2 Growth in waste must be decoupled from economic growth
• 1.3 Improved cost-effectiveness of environmental policies - improved quality in waste management
• 1.4 Improved cost-effectiveness of environmental policies - an efficient waste management sector
• 1.5 How to achieve the Strategy aims
• 1.6 Cost of the Strategy initiatives

Purpose of Waste
Strategy 2005-2008

The purpose of Waste Strategy 2005-08 is to outline guidelines for the Government's waste policy. It is the foundation stone for the national authorities' future waste management initiatives, and defines the framework for local municipal waste planning when they prepare the next generation of municipal waste plans for 2005-08. This Waste Strategy follows on from Waste 21 (1998-2004), and implements the national waste management initiatives that are compulsory for Member States in relation to the EU.

It is the aim of the Government to reduce our consumption of resources and decouple the increase in the volume of waste from economic growth. It is important that we reduce the environmental impacts arising from the generation and treatment of waste. Authorities, people and enterprises all have a joint responsibility in this task.

The Waste Strategy is an important element in the Government's overall strategy for sustainable development ^[1], which aims to help decouple economic growth from resource consumption. Focus on resource optimisation in production in the form of more resource-efficient products with long lifetimes, reduction in resource losses associated with waste treatment, waste prevention, and an increase in recycling can all contribute to sustainable development.

The Waste Strategy is one strategic element that works in synergy with the Government's other environment policy strategies, such as the chemical strategy – important for efforts to reduce the levels of xenobiotic substances in waste, the product-oriented environment strategy – with respect to the prevention of waste, the "Environment and health are closely related" strategy, and the strategy of making the market work for the environment.

The Government's waste policy for 2005-2008 builds upon three fundamental elements:

• We must prevent the loss of resources and environmental impact from waste.
• We must decouple growth in waste from economic growth.
• We must ensure the improved cost-effectiveness of environmental policies through:
• improved quality in waste treatment, and
• an efficient waste management sector.

These fundamental elements will be realised using a number of different instruments that take into account both the environment and economics. We will ensure that waste is treated in an environmentally responsible manner and at a reasonable price. It is therefore important that the quality of waste treatment is improved and that the basis for making decisions in the area of waste management is enhanced. We will establish new waste indicators that incorporate the most important environmental factors, such as resource consumption and environmental impacts. And we will also carry out cost-benefit analyses in several waste management areas. In order to achieve more efficient waste management, we need to look at how the entire sector is organised.

1.1 Loss of resources and environmental impacts from waste must be reduced

Resource consumption must be reduced

Waste represents resources. A central element in future initiatives will be to limit the loss of these resources as far as possible. Furthermore, the individual flows of materials will be prioritised. Not all materials are equally welcome in the flow of waste, and initial efforts must be directed towards substances with the greatest health and environmental impacts. Other materials are known to generate large volumes of waste or other pollution during their life cycle. These materials will also be given high priority in future initiatives. Prevention of waste is therefore an important element in the total efforts to move towards greater resource efficiency and more sustainable development.

Danish environment policy largely aims to promote the responsible use of resources. But even under the existing policy, it is still necessary to work for better utilisation of resources. In order to pursue this aim, an element of the Strategy will be to focus on generating data and developing methods that can evaluate the total resource usage and environmental impact of products and materials.

The Strategy will provide a basis for evaluating which combination of instruments best ensures resource efficiency and waste prevention. Special focus will be given to market-based mechanisms, in preference to prohibitions and orders.

1.2 Growth in waste must be decoupled from economic growth

Decoupling economic growth and waste

In the strategic effort to decouple growth in waste from economic growth, it is essential that the factors responsible for the generation of waste be identified. Economic growth has a large impact on the volume of waste. The greater the disposable income of the population, the more waste is generated. Activity in the construction industry is a good example of how the generation of waste is closely linked to economic conditions.

Our consumption and production patterns also play a role. Genuine preventative initiatives must build upon enterprises and people having the opportunity and the willingness to contribute to:

• producing and consuming less resource-intensive products that are durable and environmentally friendly,
• environmentally friendly products gaining greater market share,
• securing an opportunity to choose consumption patterns that benefit the environment.

1.3 Improved cost-effectiveness of environmental policies – improved quality in waste management

We must ensure improved quality in waste management. To date, waste management has been based around the waste hierarchy, and it should continue to be. This tool is a useful instrument for initially determining which treatment waste should receive. The waste hierarchy dictates that waste fractions must be moved up in the hierarchy. This means that the prevention and recycling of waste must be given priority over incineration. Ultimate priority must be given to avoiding landfilling of waste. However, there needs to be a balanced evaluation. In general, we should follow the waste hierarchy when it is both environmentally justified and cost-effective.

We must strive to develop and use the treatment that is best for the environment. At the same time, we must watch and demand that the price we pay for treatment of waste is the most cost-effective solution for society. The environmental quality achieved for the money spent needs to be clear. However, an important question is whether we are always able to assess whether a given treatment is optimal.

The waste hierarchy on its own is not sufficient for choosing the best treatment for the waste of the future. We need a more solid basis for making the right decisions. In other words, the waste hierarchy is an imprecise a tool to base future choices about the treatment of waste upon. It is necessary to be able to document the environmental benefits we gain from the money spent on a specific form of treatment. In the future, there must therefore be greater focus on the connection between economics and environmental impact in the waste management choices we make.

In order to promote better quality in waste management, there are three central focus areas in particular that require improvement over the next few years.

• Firstly, we must develop a method that makes it possible to assess the quality of waste treatment and to evaluate whether waste is being treated at the right price.
• Secondly, we need more stringent requirements governing the treatment chosen for waste.
• Finally, we must work towards waste becoming less hazardous, and reducing the volume of hazardous waste.

Quality assessment

Method for assessing quality – new waste indicators

Technologies that make it possible to utilise the resources in waste – both the energy and material resources – and to eliminate problems with xenobiotic substances, are usually considered to be high-quality treatment technologies. This continues to be a good guide for what an effective technology should be able to achieve. But these parameters may also be difficult to work with in practice. It is therefore necessary to develop a method that indicates, at a more detailed and specific level, how well we are able to treat waste, and at what price. This can lead to greater transparency in decisions.

The first steps to develop this instrument have already been taken. Waste Strategy 2005-08 includes the first calculations of a number of waste indicators that highlight resource and energy consumption and landfilling requirements for various waste fractions. These indicators show where the greatest environmental effect can be achieved, for example, by choosing recycling instead of incineration.

To date, the focus has been on the volume of waste produced and how this waste is treated. The greater the recycling percentage, the better the waste treatment was seen to be. This is no longer adequate. It is now necessary to supplement the previously used indicators with new indicators that tell us something about the environmental impact from waste. The new waste indicators need to be refined so that they provide a total picture of resource consumption and environmental impact. These indicators must also be supplemented with an evaluation of each material's environmental and health effects.

One needs to be aware that the new indicators are associated with a certain degree of uncertainty. They require a large statistical base and complicated calculations. Therefore, initially, they will not be quite as robust as the existing indicators for the volume of waste in tonnes, and they should be interpreted with caution.

The waste indicators will be combined with cost-benefit analyses. This will provide a solid basis for assessing whether the specific waste fractions are being treated in the way that is best for the environment and at the right price.

Waste treatment requirements

Waste treatment requirements

We must ensure that recycled materials are of higher quality and that treatment has the minimum possible environmental impact. Once it has been decided that a waste fraction should be separated for the purpose of receiving special treatment, we must stipulate more stringent quality requirements for the treatment of the waste.

In the years ahead, we will probably see new requirements placed on the treatment of fractions such as PVC and impregnated wood. In addition, as a consequence of the Directive on the landfill of waste, a number of "acceptance criteria" for the landfill of waste must be developed. Overall, waste treatment requirements will lead to better quality in waste treatment.

Waste has to be less hazardous

Waste has to be less hazardous
Waste has to become less hazardous over time. Under the product-oriented environment strategy and the chemical strategy, action will be taken, in the long term, against hazardous substances in products. This will mean that waste will become less "hazardous" as these products finally end up in the flow of waste.

In the years ahead, we need to work out a strategy for hazardous waste that focuses on the degree of hazard from the waste and identifies any barriers preventing waste from being sent to the most environmental and cost-effective treatment.

We currently have criteria for determining whether waste is hazardous, but a method needs to be developed that indicates which treatment the hazardous waste should receive. New initiatives in this area will be considered throughout the term of the Strategy.

1.4 Improved cost-effectiveness of environmental policies – an efficient waste management sector

Organisation of the waste management sector

In Denmark, waste management has been organised in such a way that currently there is a smoothly operating waste management system and a high degree of environmental protection. Furthermore, the costs of waste management are extremely reasonable compared to other countries.

The municipalities have responsibility for all waste and have overseen the management of waste within a complete municipal waste system. It has not been uncommon for municipalities to also take responsibility for operational tasks in the area of waste management. The majority of all landfill sites and waste incineration plants are publicly owned and operated.

International studies have shown that Denmark has relatively low costs for the incineration and landfilling of waste. Note that this has been achieved without compromising the environment. It is worth maintaining this.

Good results have thus been achieved in the way Denmark has organised waste management, but there are also weaknesses. Some of the most significant problems are: inadequate competition within the sector, confusion of the municipalities' roles as an authority and as an operator, difficulties for waste producers in gaining exemption from municipal waste collection schemes, data reporting requirements, lack of transparency in waste fees, inexplicable differences in processing fees, and failure to implement new treatment technologies (plants) under market conditions.

At the same time, analyses have been carried out that indicate various degrees of potential to improve efficiency in the areas of incineration and landfilling.

Waste must be managed in both an environmental and cost-effective manner – this is important. We must therefore take an unprejudiced look at who is best able to carry out each task, and how it can be done most effectively. Future waste policy needs to give greater attention to economic factors in decisions, so that collection methods and forms of treatment are chosen that are environmentally and cost effective. Clearer choices and a more visible prioritisation of initiatives are goals in themselves, and are also necessary in order for people and enterprises to take more responsibility and for local waste solutions to better reflect the needs of people and enterprises.

In spring 2002, the Government appointed a work group to undertake a complete assessment of the scope and significance of the most important problems in the area of waste management, and to identify the advantages and disadvantages of deregulating the waste management sector. In 2004, this work group is due to report on proposed future solutions within the areas in which the group believes it is necessary to change waste management organisation and legislation. The results of this work are intended to contribute, in general, to a more efficient sector in which it is easier for people and enterprises to dispose of waste, and where it is clear where the money is going and what the costs of waste management are.

The work group has proposed and initiated studies into the transparency of fees and into the advantages and disadvantages of deregulating landfill and incineration activities. Studies investigating the following items are also being planned: analysis of reporting obligations, a central register of waste carriers, simplification of the municipal waste regulations, transparency in the role of waste carriers and waste brokers, experience from an area of waste management subjected to competition (the recycling sector), separation of the roles of authority and operator, and producer responsibility for disposed products.

The work group will focus on the framework conditions for the waste management sector, including organisational, competition and economic factors for both domestic and commercial waste and for private and public players. The work of the work group will naturally influence the implementation and results of the Waste Strategy, since the aim of the work is to ensure that the waste management sector becomes more efficient.

However, the work group is not intended to examine trends in volumes of waste, initiatives to prevent increased volumes, or specific goals for specific waste fractions and forms of treatment. The aims of the Waste Strategy are based on the existing framework for the waste management sector. It is too early at this stage to say anything about the extent to which organisational changes will contribute to a more efficient waste management sector, in economic and environmental terms.

Waste Strategy 2005-08 should therefore not be considered to be an exhaustive description of the initiatives that will be implemented during the period in relation to the organisation of waste management and the use of control mechanisms. Changes to organisational factors will not be discussed further in the Strategy. The work group will conclude its work in 2004. On the basis of their findings, the Government will decide what initiatives are to be implemented from 2005 and on.

Producer responsibility in relevant areas

One goal of the Waste Strategy is to identify whether advantages can be achieved by introducing producer responsibility in relevant product areas. It needs to be evaluated whether producer responsibility can be introduced without a heavy administrative burden on manufacturers/importers and authorities. It also needs to be evaluated whether producer responsibility can lead to more environmentally friendly products. For certain products in particular, producer responsibility is expected to be very suitable.

Producer responsibility should not be chosen as a unilateral Danish solution. This mechanism must be introduced at the international level, for example in the EU. Regulations governing producer responsibility have already been introduced in the EU in areas such as end-of-life vehicles and waste from electrical and electronic equipment.

Environmental and cost-benefit assessments – a better basis for making decisions

In the area of waste management, it is important to ensure greater environmental effect from the investments made.

Many factors play a part in which solution should be chosen – available treatment and collection technologies, willingness to separate waste, and many others. In the future, waste management will presumably require more advanced technological solutions than those that exist today, and there will therefore be even greater sorting and collection requirements, etc. These technological solutions may make it necessary to make new investments in the area of waste management.

There must also be better prioritisation, based on good documentation, within the range of possible schemes that can be initiated in waste management. It will be necessary to weigh up the advantages and disadvantages achieved. In other words, for all initiatives, it will be necessary to know whether the environmental effects we achieve through a specific measure in waste management also correspond to the costs.

To ensure that the environmental effect is as great as possible, it will be necessary, in a methodical and structured way, to weigh up environmental and economic factors – and ensure that we can compare various initiatives. In this respect, environmental and cost-benefit assessments are tools which can provide part of the basis for waste policy decisions. They permit environmental effects to be compared against cost-benefit analyses, ensuring that the decisions made incorporate an economic perspective.

The strength of these analyses is that the information is structured in such a way that the decision made is well-founded and documented – and no other viable alternatives exist. Using environmental and cost-benefit analyses, it will be clearer what a given initiative costs, and what effects it has. However, cost-benefit analyses are only part of the decision basis. There may be political reasons for implementing an initiative, even though a cost-benefit analysis shows that it is not economically viable.

All this is not as easy as it sounds. Any method has strengths and weaknesses. One of the greatest weaknesses is that not all environmental effects have been thoroughly investigated, and not everything has been assigned a monetary value. There is also some uncertainty involved in placing a value on environmental effects. A responsible environmental and cost-benefit analysis is also very dependent on the data available. It is therefore important that sufficient information exists on both the environment and costs.

We must, of course, continue to prioritise the investigations we initiate. Any change in the Danish regulations that results from an EU directive has normally been evaluated in connection with the negotiations, and therefore does not necessarily need to be investigated at the same level of detail as other regulations when they need to be implemented. Within the framework of the EU directives, implementation must take place in a way that balances costs and environmental effects.

The same is true for some of the areas mentioned in the Strategy. It shows the direction the development should take; but both environmental and economic factors need to be investigated more closely to ensure a well-documented and objective decision basis. Cost-benefit analyses will be carried out when the areas have been specified in more detail and sufficient data is available.

1.5 How to achieve the Strategy aims

Denmark currently recycles a large proportion of the total volume of waste. But there is still room for improvement.

The Government's aim for future initiatives in relation to the total volume of waste is to increase recycling. At the same time, the aim is to reduce the volume of landfilled waste, so as to avoid loss of resources. The recycling aim for 2008 is 65%, and the aim for landfilling is a maximum of 9%.

The monitoring activities of the local environmental authorities are an important element in achieving the future waste management aims.

The Waste Strategy contains a total of more than 100 new initiatives, covering the entire waste management spectrum. The majority of these initiatives are directed towards implementing both EU and Danish regulations, and making new knowledge available through development and elucidation projects. In addition, a number of initiatives aim to develop new tools, sub-strategies and environmental and cost-benefit assessments. Finally, the Strategy contains a small number of information activities. The Strategy cannot be implemented without financial support for the majority of these initiatives.

The aims are to be achieved through initiatives directed towards the following areas:

Cross-cutting initiatives

Knowledge-sharing is a central instrument to be used by the players in implementing the Strategy. Waste Centre Denmark has a central role in this area, and it is important that the Waste Centre can promote knowledge-sharing between players in the area of waste management. The waste centre is supported by funding in the annual Finance Act.

In order to promote the development of new, full scale, treatment technologies, it is necessary to continue to provide financial support. Efforts will also be made to ensure that regulations support the use of the new technology.

Transparency needs to be achieved in municipal fees. To this end, changes to the Environmental Protection Act will be proposed.

The possibility of simplifying enterprise registration and reporting obligations needs to be assessed. The number of municipal regulations needs to be reduced, and the contents of the regulations need to be harmonised to make it easier for enterprises to work across municipal boundaries.

A strategy for hazardous waste will be prepared. The purpose of this strategy will be to identify whether the various regulations which relate to or refer to hazardous waste represent barriers to the best economic and environmental management of waste, and to identify potential initiatives to minimise these barriers.

Building and construction

The large volume of building and construction waste that is currently recycled can be contaminated by substances with harmful environmental impacts. During the period of the coming plan, these substances will be required to be washed out so that the waste can be recycled in an environmentally responsible manner and under the same conditions as apply to the recycling of other residual products.

In addition, the use in buildings of chemicals which cause environmental and health problems will be reduced as much as possible, so that future building waste becomes cleaner. It will be investigated whether there is an environmental and health effect in connection with the use, renovation and demolition of buildings containing PCB.

Proposals will be made for specific resource and environment indicators for individual construction projects. These indicators will enable building contractors to take responsibility for improving environmental factors in construction. Principles will also be proposed for a benchmarking system that makes it possible to evaluate and compare environmental initiatives.

Furthermore, regulations will be introduced regarding the treatment of district heating pipes containing CFC's or HCFC's, as a consequence of the EU regulation on substances that break down the ozone layer.

Households

In general, people will be better informed about municipal schemes. Evaluation will be made of whether an environmental effect can be achieved by carrying out an information campaign on consumption and waste. Many consumption and behaviour patterns become established as children. To ensure that future generations are conscious of resource and waste problems, information and teaching materials will be prepared for pre-schools, and primary and high schools.

A tool will be prepared for local evaluation of the most environmentally and economically appropriate management of organic domestic waste. This will enable municipalities to assess whether two-part collection of the organic component of domestic waste should be locally introduced, and make a decision about this. Experience has shown that the volume collected, and the costs associated with the collection of organic domestic waste, can vary significantly. However, factors associated with incineration, e.g. heat disposal or the need for pre-treatment before bio-gasification can also vary locally and have a critical impact on the environmental economic assessment.

Recycling of packaging will be increased in accordance with the goals for 2008 under the revised Packaging Directive. Municipalities will be required to increase the collection of plastic and metal packaging from households.

Municipalities will be encouraged to increase the reuse and recycling of bulky waste. They will also be encouraged to establish networks for staff at recycling centres.

Enterprises need to focus on reducing the volume of waste in the production process, and on producing more environmentally friendly products. There are often economic advantages in focusing on these areas, due to savings in raw material consumption. Assessment will be made as to whether increased use of environmental management in enterprises can be best achieved through sector agreements or whether guidelines on waste requirements need to be prepared in connection with the environmental approval of enterprises.

Industry is currently landfilling waste which it is now possible to recycle. This waste must be moved to recycling, as long as this is cost-effective.

The existing tool for analysing an enterprise's waste will be refined. It is currently being used by small and medium-sized enterprises, but the tool must be developed so that it can also be used in large enterprises and in the service sector.

The management of animal waste has to be changed as a consequence of new rules adopted in the EU in the form of the EU Regulation on animal by-products. These rules are administered by the Ministry of Food, Agriculture and Fisheries.

Industry and institutions, trade and offices

Changes in the EU's Packaging Directive require introduction of a number of initiatives in this area. The Strategy therefore contains initiatives to increase recycling of plastic transport packaging and other plastic packaging from all enterprises, and 15% recycling of wood packaging waste has to be achieved.

The EU Directive on waste electrical and electronic equipment must be implemented by the end of 2004. This entails, inter alia, manufacturers being given responsibility for waste management and having to cover the costs of this.

Retail trade

In order to strengthen initiatives in retail trade, a panel of players from the sector has been appointed. The Retail Trade Panel has been given the task of promoting the supply of cleaner products in the area of convenience goods, and helping to increase consumer interest in such products. The Retail Trade Panel will also focus on reducing the environmental impact from the sector, for example, in the area of transport and packaging.

Landfill sites

The volume of landfilled waste has declined over recent years. It is important to ensure that the operation of landfill sites is environmentally optimal. As an element in the implementation of EU legislation, during the period of the Strategy it will become a requirement that documentation be available for waste content and leaching of xenobiotic substances. The new requirements for waste characterisation are expected to contribute to a further reduction in the volume of landfilled waste. The trend is expected to be in the direction of fewer, but larger, landfill sites. This will allow better operation of the sites, both in terms of the environment and cost effectiveness.

An action plan for the future management of flue gas cleaning products will be prepared. The plan will be prepared in cooperation with waste incineration plants. The action plan will contain deadlines for when each problem with flue gas cleaning products has to be solved.

New EU regulations

A number of new or revised directives will soon be issued by the EU. These directives typically have a short deadline for implementation in Danish legislation. The directives are: the Sludge Directive, the Directive on biological treatment of biodegradable waste for agricultural applications, the Battery Directive and the Transport Regulation.

1.6 Cost of the Strategy initiatives

The Strategy contains various types of initiatives. A number of measures have been made necessary by new or revised EU directives, and as such, implementation in Danish legislation is compulsory. The costs of these initiatives have been estimated:

• The Packaging Directive, including increased recycling of plastic, cardboard, wood and metal packaging
• The Electronics Directive, including implementation of producer responsibility
• Implementation of acceptance criteria for landfilling of waste
• Regulations on the treatment of district heating pipes containing CFC's or HCFC's, as a consequence of the Regulation on substances that break down the ozone layer

In order to achieve the goal in the revised Packaging Directive, plastic packaging must be collected from households. On the basis of environmental cost-benefit analyses carried out, the collection method with the lowest costs per tonne of plastic waste has been chosen. The total costs are estimated to be approx. DKK 2 million per annum. In order to achieve the goal in the Packaging Directive, it will also be necessary to increase the collection of plastic transport packaging from enterprises that handle large quantities. This is not expected to lead to a net increase in costs to enterprises, since the increased costs of collection will be offset by savings in treatment expenses for mixed waste for incineration. Should it become necessary to collect plastic packaging from enterprises that handle only small quantities, this will lead to an increase in costs to these enterprises.

The new material-specific goals in the Packaging Directive are only expected to lead to a limited increase in the costs of collecting metal packaging from households. A report for the Danish Folketing will be prepared in 2005 on how the goal of 55% recycling of all packaging waste can be achieved. The other initiatives will be carried out in a way that ensures improved cost-effectiveness of environmental policies.

To date, electrical and electronic products have been collected via municipal schemes financed through municipal fees. Under the new directive, producer responsibility will be introduced, with the result that waste management costs will be included in the prices of these products. Costs associated with the waste treatment of electrical and electronic products are expected to constitute 0.2 – 3.0 per cent of the products' purchase prices.

The economic consequences of implementing the annex to the Directive on the landfill of waste are difficult to calculate. Before the waste is landfilled, information must be available on the composition of the waste and leaching of contaminants in the short and long-term ("characterisation"). The associated costs can only be calculated when it is known which types of waste must be characterised. The total costs to waste producers for characterisation of waste types for landfill is estimated to be of the order of DKK 100-200 million. It is expected that these costs will be incurred over approx. a two-year period (2005-2006).

In addition to the costs of characterisation, waste producers will be regularly required to document that the particular waste type characteristics are not changing over time. This documentation will be in the form of analyses (compliance tests) aimed at showing whether the composition and leaching characteristics of a waste type have changed in relation to the results from the earlier characterisation. If the characteristics are changing, the waste producer may, in the worst case, be required to perform a new characterisation of the particular waste type. The total annual costs to waste producers for carrying out compliance tests are estimated to be in the order of DKK 5-10 million.

During the 1990's, international rules were implemented regarding the phasing out of substances that deplete the ozone layer, in the Montreal Protocol and in an EC Regulation on substances that deplete the ozone layer. One study has shown that the greatest quantity of these substances is found in district heating pipes. The volume of scrapped district heating pipes that contain ozone layer depleting substances will significantly increase in the years ahead, but no information is available about how many of these scrapped pipes will be excavated. It will therefore be necessary to investigate this before the expenses associated with separate treatment of district heating pipes containing ozone layer depleting substances can be calculated. When a specific scheme is implemented for the waste management of these waste fractions, emphasis will be given to finding the most cost-effective scheme.

In addition to the above legal instruments, the Regulation on animal by-products (Danish Ministry of Food, Agriculture and Fisheries) applies from 2003. This Regulation does not repeal the temporary ban on feeding using meat-and-bone meal that has been in force since 1 January 2001, and was decided at the EU Agriculture Council meeting in December 2000. As a result of the ban, a large quantity of meat-and-bone meal has to be treated as waste. The industry has reported that the extra expenses incurred are estimated to be of the order of DKK 200 million per annum.

Other initiatives in the Waste Strategy require further assessments of the economic consequences. No specific new initiatives will be implemented in these areas until a cost-benefit analyses has been carried out.

A number of initiatives relating to the separation of special fractions were started as a result of the previous waste plan. In these areas, a decision on the final treatment of the fractions will await investigation of environmental and economic factors. This applies to initiatives such as:

• PVC
• impregnated wood

These analyses are expected to be completed in 2003.

A number of initiatives in the Waste Strategy indicate the direction the Government wishes to work towards. Measures under these initiatives will not be economically evaluated before the Strategy comes into force. However, the environmental and economic consequences will be evaluated before decisions are made about starting specific, binding initiatives. This may be relevant within initiatives such as:

• Increased recycling of industrial waste.
• Initiatives for increased recycling of bulky waste.
• A strategy for hazardous waste.
• Changes to the Statutory Order on residual products, including requirements relating to the content of organic contaminants, and extension of the Order to include building and construction waste.
• Investigation of the options for introducing producer responsibility for relevant products

In addition, a number of initiatives will require that elucidation projects be carried out with government funding.

A number of new or revised directives will soon be issued by the EU. These directives typically have a short deadline for implementation in Danish legislation. The following rules are coming soon:

• Directive on packaging and packaging waste
• The Sludge Directive
• Directive on biological treatment of biodegradable waste for agricultural applications
• The Battery Directive
• The Regulation on the shipment of waste

The Packaging Directive is being revised. In October 2002, a common position was adopted, in which goals were set for 2008 for the utilisation and recycling of various packaging materials and the total quantities of packaging. The revised directive is expected to be finally adopted in 2003. The national goals for the recycling of packaging waste in 2008 in this Waste Strategy have been matched to the expected objectives in the EU's revised Packaging Directive.

The Sludge Directive from 1986 is being revised, and the Commission's proposal is expected to be ready in 2003. The Directive is expected to continue to be a minimum requirements directive, and preliminary announcements suggest that the Directive's limit values will be brought closer to Danish limits, which are significantly lower than the existing minimum requirements. Denmark will work towards a reduction in these limit values and the introduction of requirements on organic xenobiotic substances, with the aim of bringing these requirements closer to existing Danish levels.

The Commission plans to present a Directive on biological treatment of biodegradable waste for agricultural applications in 2004. From preliminary work on the Directive it is apparent that the Commission is considering compulsory source separation of organic domestic waste throughout the EU. The Commission is also considering whether the Directive should be a minimum requirements directive or whether Member States will have to use the limit values in the Directive. Denmark does not believe that requirements for the collection of organic domestic waste should be regulated at the EU level, but believes it is important that minimum standards are set for the content of hazardous substances in treated waste. Denmark will therefore work towards the Directive being a minimum requirements directive, and the requirement for source separation being excluded.

It is expected that the EU will revise the current Battery Directive during the term of the Waste Strategy. It is expected that the change will be to the effect that all batteries should be collected and recycled. No timetable for the revision has been set.

The Regulation on shipment of waste is being revised, but the timetable for completion is not known. The primary purpose of the revision is to integrate the OECD decision of 14 June 200 C (2001) 107/FINAL in the regulation. This decision entails a mandatory harmonisation of lists and other requirements in the Basel Convention on the shipment and disposal of hazardous waste.

The change also aims to simplify procedures and specify clearer and more uniform requirements for notification, shipping documents, information, provision of financial security, etc., throughout the entire community.

It is also expected that written consent will have to be obtained prior to the shipment of both orange and red waste, instead of only for red waste, as is the case today.

Footnotes

[1] See "A shared future - balanced development", Denmark's National Strategy for Sustainable Development, the Danish Government, 2002.

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Version 1.0 June 2004, © Danish Environmental Protection Agency