The recycling rate

Until recently a member state reporting how much of its municipal waste it recycled could choose which of four ways to work the figure out. It told the Commission which one it had picked, and it could change its mind later.

The four sat in a Commission Decision of 18 November 2011 establishing rules and calculation methods for verifying compliance with the targets in the Waste Framework Directive. One counted the recycling rate of paper, metal, plastic and glass household waste. One counted household and similar waste. One counted household waste. One counted municipal waste, relying on statistical data. Member states were to “inform the Commission of the option chosen” in their first implementation report, and could change the option up to the report covering 2020, provided consistency in the data could be ensured.

Four quantities, then, all of them called the recycling rate, and one target applying to whichever a government had selected.

Where the weighing happens

The other question a rate leaves open is where along the process anybody puts the material on a scale.

A lorry collects. A sorting plant separates. Some of what it separates is baled and sold, some is rejected as contaminated, and some travels a long way before a recycler either uses it or does not. The tonnage differs at every one of those points, and each of them can be described, in English, as recycling.

Directive (EU) 2018/851 of 30 May 2018 settled it. As a rule, only the input to the recycling operation counts, and the measurement is taken there. A member state may instead measure the output of sorting, under a derogation, provided it deducts further losses before the material enters recycling and can show the output waste is actually recycled.

That is a change to where the scale sits. It is not a change to what happens to anybody’s packaging.

The numbers went down

The European Environment Agency records the consequence in a footnote. The methodology for calculating recycling rates for packaging and municipal waste “changed for the 2020 data reporting and onwards, with several EU Member States reporting lower recycling rates because of this”.

Nothing was recycled less. Bins were emptied as before, plants sorted as before, bales went where bales had been going. What altered was the point at which the material was weighed and the arithmetic applied to what the weighing found, and a number that had been going up went down.

The EU municipal waste recycling rate stood at 47.7 per cent in 2023. The target is 55 per cent by 2025, and eighteen member states have been identified as at risk of missing it.

Numerator, denominator, weighbridge

A percentage has a numerator and a denominator, and both are decisions. What counts as municipal waste, what counts as recycled, and at which weighbridge the question is asked are three separate choices, each defensible, each producing a different number from the same lorries.

For nine years the answer to which choices applied was: whichever the reporting government preferred, declared once and revisable. That is not a scandal and nobody appears to have concealed it. The options were published in the Official Journal, and the requirement to say which had been chosen was in the same document.

What it means is narrower and harder to fix. A target expressed as a percentage does not become enforceable by being written down. It becomes enforceable when somebody settles the denominator, and until 2018 nobody had.

The clerk’s brief

From the clerks, for the Patrician’s eyes

Compiled August 2026. Newest first; settled items are gathered into the note on the denominator at the foot. The clerks note that this file contains no allegation against anybody, and that the entries record the writing of definitions rather than the breaking of rules.

2023: Eighteen states at risk

The European Environment Agency’s indicator on waste recycling records the EU municipal waste recycling rate at 47.7 per cent in 2023, against a Waste Framework Directive requirement to recycle 55 per cent of municipal waste in 2025, with eighteen member states identified as at risk of missing that target. The clerks observe that the shortfall is being measured against a definition three years old, and that the previous definition would have produced a smaller one.

2020: The reporting year the numbers fell

From the 2020 reporting year the new calculation applied, and the European Environment Agency records that “several EU Member States report[ed] lower recycling rates because of this”. The clerks note that a drop of this kind arrives without any change in what was collected, sorted or sold, and that a time series broken in this way is the most honest thing in the file.

May 2018: The scale is placed

Directive (EU) 2018/851 of 30 May 2018 amended the Waste Framework Directive so that, as a rule, only the input to the recycling operation is counted, with a derogation permitting measurement at the output of sorting where further losses are deducted and the material is shown to be actually recycled. The clerks record that this is the first instrument in the file to say where the material is weighed, and that it took ten years from the Directive it amends.

November 2011: Four methods, and a choice

Commission Decision 2011/753/EU of 18 November 2011 established rules and calculation methods for verifying compliance with the recycling targets, and offered member states four of them: paper, metal, plastic and glass household waste; household and similar waste; household waste; and municipal waste computed from statistical data. A state was to inform the Commission which it had chosen, and could change until the report covering 2020. The clerks note that the target was uniform across the Union and the arithmetic was not.

The denominator

Every figure in this file is arithmetically sound and none of them measures the same thing. The material moved through the same lorries, plants and balers throughout, and what changed was where somebody stood with a scale and which tonnage they wrote down. The clerks’ standing assessment is that a percentage target is an instruction to whoever defines the denominator, that the Union left that definition to the governments being measured for nine years, and that the correction shows up in the record as a fall.