CASE STUDY of knowledge transfer on Extended Producer Responsibility for packaging waste from Belgium to Malta


According to the EIR Malta Report of 2019, despite the faint improvements in previous years (2011-2013), the figures on municipal waste generation show a general tendency of increase in waste generation since 2014. This seems both to be the result of increased disposable income and tourism. The report reveals that in 2017 municipal waste generation was at 604 kg/y/inhabitant, compared to a 487 kg/y/inhabitant EU average. In addition, the recycling rate was only 6%; far bellow the EU average of 46%. In fact, according to the Early Warning Report of 2019, Malta is at risk of missing the 2020 municipal waste recycling target of 50%.

Moreover, the report shows that in 2017 the composting rate was extremely low far bellow EU average too. Least but not last, the landfilling rate was 86%, three points more than the figures showcased by the previous EIR report. This reveals an increasing trend in landfilling and means three times more landfilling than the EU average of 24%.

To sum up, Maltese waste management is still very focused on residual waste treatment and disposal. Therefore, crucial steps are required in order to comply with EU targets on diversion, recycling, biowaste and landfilling in next years. Both EIR report and the Warning report reflect necessary substantial investment to boost a new waste management system in Malta. They suggest efforts are made with regard to economic instruments and incentives (PAYT, increase of the landfill tax), separate collection (included biowaste), door-to door collection, communication campaigns, better coordination among administrations, EPR and allocation of Cohesion Funds to move away from excessive disposal towards infrastructure based on waste hierarchy criteria.

Maltese waste management has to face the challenges derived by the local geographical, cultural and demographic features. That is why it must be taken into account that Malta is an archipelago located in the Mediterranean Sea, with an area of 316 km2. Not only is it one of the smallest archipelagos in the world but also one of the densest, with over 417,000 residents to which must be added about 1,4 million tourists that visit every year.

The project

The project started with two events in September of 2019. Belgium has reached positive figures in terms of recycling, landfilling and biowaste management in last years and that is why the transfer of knowledge from Belgian peers was foreseen very beneficial for the Maltese ambition to switch radically its waste management.

Study visit (16th-18th September)

Firstly, representatives from municipalities of Malta and GreenPak Malta carried out a 3 days-long study visit in Belgium in order to reach know-how experience from FOST Plus (EPR for household packaging waste), Interafval (Association of Flemish Cities and Municipalities), OVAM (Public Waste Agency of Flanders), and IVC (Interregional Packaging Waste Commission of Belgium).

During this visit the Belgian legislative framework explored and discussed, the cooperation between Fost Plus (EPR scheme) and the Belgian municipalities for the collection and recycling of packaging waste, enforcement methods, communications methods to engage citizens, know-how to fight against litter and further aspects focused on the separate collection, sorting and recycling systems, especially, addressing packaging waste.

In addition, the Maltese delegation visited the packaging waste sorting plant at IMOG (Intermunicipal Company for Public Health in South-West Flanders), and could gain knowledge from a visit at IVM (Intermunicipal Association for garbage disposal Meetjesland) in Aalter, where they were introduced to a pilot project for the extension of separate collection of lightweight packaging. Finally, they visited a civic amenity site in the area of Aalter.

Expert Mission (23rd-24th September)

Secondly, in the course of the month, an expert mission to Malta was held with representatives from Interafval, FOST Plus from Belgium, GreenPak and representatives of the Maltese local and central government. The critical issues discussed during the event were focused on EPR system, separate collection (commercial and household waste, infrastructure, technology…) as well as communication strategies.

Interafval displayed a number of presentations with information regarding the system performed in Flanders. It covered the following points:

  • Evolution of the waste management in Flanders.
  • Key factors to obtain good results: the significance of the regulations was stressed, coordination of municipalities, constant communication with citizens, planning for a tailor-made local model, implementation of PAYT principle as well as finance pressure to prevent illegal dumping and incineration.
  • How they perform regarding the collection of commercial waste: legislation involved, administrative competences and details linked with the collection system, putting special emphasis on packaging.
  • Strategies on communications: Efforts in official municipal websites, social media, apps, publication of magazines and brochures, direct communication at the civic amenities, awareness campaigns and participation of volunteers.

In addition, FostPlus and GreenPak introduced their corresponding waste management system, achievements and challenges.

It must be highlighted that as Malta has an important problem on litter and illegal dumping, the Belgian team provided with its experience in this field and the actions carried out in Flanders. They stressed the importance of a joint strategy among public and private players. Those actions addressed infrastructure, raise awareness campaign, engagement of citizens and companies and enforcement.

Finally, the experts from Belgium identified the key areas of necessary improvement in Malta and provided suggestions and recommendations in order to achieve EU targets.

Expert Missing to Malta Expert Missing to Malta

Presentations displayed during the expert mission in Malta

As a consequence of this visit, the observations and recommendations raised by the Belgian experts are summarized in the following areas:

  1. National legislation: The national policy is weak as regards sustainable waste management and is extremely focused on landfilling. It is necessary to build strong national legislation to boost a more sustainable model, to allow the reorganization of the competences on this matter and to permit the introduction of a Pay As You Throw (PAYT) scheme.
  2. Economic instruments: At the moment, there is no economic instrument intended to foster separate collection and treatment. Two important changes could have this effect: Changing the legislation to permit the introduction of a PAYT scheme and the implementation of a landfill tax in Malta (currently non-existent), which could mean an incentive for municipalities and regions, commerce and industry to promote more separation at source and recycling as well as investment in the appropriate waste treatment facilities to treat these waste streams separately and so have a more targeted approach to achieving the 2030/2035 recycling targets.
  3. Infrastructure: There is no sorting or recycling infrastructure on the islands, they only have a landfill and two MBT plants. Malta is dependent on waste exports to divert waste from landfills. Investment and advice on this area is absolutely necessary.
  4. Coordination efforts: Efforts should be made in two directions;
    1. Coordination among municipalities: There is lack of coordination thus the current local waste management systems contribute to an ineffective collection system and communication. Regarding this point, the experts recommend any of the following choices: either the creation of an inter-municipal cooperation system or transferring the competence on waste management from the municipalities to the regions. Nevertheless, the experts specify that in the last case, municipalities should be allowed to take part in policy development in order to assure that the local conditions and needs are taken into account.
    2. Cooperation between EPR and municipalities: The first step lies in the suitable adaptation of the national legal framework to permit the correct development of the EPR scheme.
  5. Enforcement: Another challenge faced by Malta is fly-tipping and illegal dumping. In order to resolve both problems Maltese authorities should strengthen enforcement.
  6. Communication efforts and incentives: Waste prevention, reuse and recycling awareness among Maltese citizens is very low, moreover, there is neither motivation nor incentives for the population to collaborate better in the separate collection system.

    In order to create an efficient and effective separate waste collection system which results in high quality, high quantity recovery of recyclable materials, improved engagement of citizens and business is needed. Communication should centre on sorting obligations, collection timetable and data on quantities recycled in both weight and percentage. Refinement of the organisation of the collection system to make it convenient for all is also needed as well as the introduction of incentives rather than fines.
  7. Extended Producer Responsibility (EPR): The current EPR systems struggle to achieve efficiency due to the current legal framework which does not form a secure basis for investment. There are two competitive EPR schemes for packaging waste which, due to the lack of clarity in the national legal framework on EPR, results in lack of coordination in the collection system. Solutions to this are considered urgent to put Malta in a position of being able to achieve the 2018 EU Directive’s recycling targets for packaging waste.
  8. Pressures and disadvantages: It must be said that Malta is an archipelago in the Mediterranean, has a high level of tourism, dense and growing population and many citizens have little space to separate waste at home. All these conditions mean that the per capita waste generation is higher than average because of tourism, separate collection rules must be communicated to tourists to decrease mixed waste quantities (the black bag) and as these islands are small, investing in recycling capacity is not economically viable; they are far from mainland Europe however to recycle, their sorted waste needs to be shipped to a Member State with capacity. Currently the majority of waste exports are to non-OECD countries.

These observations reveal that Malta faces numerous, serious challenges to the improvement of waste management and has a long way to go to create a waste management system capable of achieving the EU targets for landfill diversion, recycling and biowaste.


The experts from Belgium forecast future TAIEX assistance as necessary to assist with improving the legal framework (especially concerning EPR), improvement of the separate collection system, financial instruments, cooperation among the different levels of government (national, regional, local), new infrastructure as well as cooperation between EPR-schemes and municipalities.