The Strategic Plan for Urban Waste (PERSU 2023), published in March 2023, outlined the main goals, activities and plans to respond to the enormous challenges of urban waste management in Portugal, which necessarily involve diverting waste from landfills and increasing the reuse and recycling of the waste we produce in our homes.

Packaging plays a central role in this strategy. If Portugal wants to reach other figures in packaging recycling - especially glass recovery - it needs to look at the undifferentiated waste container. The methodology of the last 20 years has proven to be exhausted, as shown by the stagnation of results.

The strategic plan is based on increasing multi-material selective collection in existing waste families but also includes the dedicated collection of new types of waste, with a strong emphasis on organic waste. Other waste families will be managed individually as part of extended producer responsibility, such as furniture and mattresses.

The revision of the General Waste Management Regime (RGGR) could have been an opportunity to acknowledge the importance of undifferentiated flows of urban waste management with a view to meeting the collection and recycling goals, which unfortunately did not happen.

Unavoidable in the RGGR is the proposed increase in the Waste Management Fee (TGR). Rather than discussing the colossal increase in the unit value of the Waste Management Fee, which is planned for entities such as Electrão, it is important to look at the destination of the funds, which will be of millions of Euros and channelled into strengthening public administration bodies and the Environmental Fund. With this, we lose traceability and the guarantee that the fees collected from electrical equipment or packaging sectors will be applied to those same collection and recycling systems.

Also regarding the RGGR, it would be very important for the Urban Waste Management Systems to have objectives for the different families that make up urban waste, namely packaging, batteries and electrical equipment. These are materials that represent little from a financial point of view but which have a huge environmental impact.

The RGGR is also timid about its waste collection networks. There is no question about the territorial reserve of municipalities, but it should be possible to encourage the establishment of private collection points directly managed by Extended Producer Responsibility systems. This would allow the country to rely on the flexibility, autonomy and dynamism of entities such as Electrão to improve and encourage separation, particularly among different economic agents.

Also of note in 2023 was the work done by the Environment Committee in the Portuguese Parliament, namely the hearing of IGAMAOT's Inspector General, which clarified that the parallel market is not IGAMAOT's responsibility.

. It is public knowledge that there is a parallel economy, fuelled by the diversion and processing of waste, with notorious economic, environmental and reputational damage to the country. So, who is the administration agent that can help combat the parallel market?

After great disappointment at CAGER's inactivity in 2023, we are witnessing with some expectation the reactivation of its operation in 2024, in the hope that it will quickly produce results and that the compensations that have greatly damaged Electrão will be made effective. This will always be a contentious issue, as Electrão will defend to the last moment the compensation it receives from its competitors for the good recycling results it delivers to the country.

The RGGR also provides for ERSAR to be called upon to take regulatory responsibility for the packaging flow. It's not clear how this change can improve the way things work. This proposal promotes regulatory complexification, by increasing the number of entities involved, rather than simplification.

Electrão is awaiting the publication of the new, longer license cycle so that it can renew and plan activity for the three systems in which it already participates and launch and implement activity in the single-use plastics for tobacco products, to which it is a candidate in partnership with other companies in the sector.

The European regulatory context in 2023 was no less productive than the domestic one. The new regulation on batteries has established a new framework. The implementation of a regulation, more immediate than a directive, to be transposed into national legislation will allow for greater uniformity throughout Europe. This regulation introduces an important novelty: the concept of the quantity available for collection. For the first time, this concept removes the emphasis on collection and recycling based on consumption or estimated waste production and assesses recycling by what is actually available for collection and recycling as a product of consumer society.

This change represents a paradigm shift and seeks to respond to the challenges of the circular economy, which presupposes greater reuse of products at the consumption stage, implying that the waste to be managed will decrease rather than increase. On the one hand, we're going to have management entities collecting waste to achieve recycling targets. On the other hand, there are a number of initiatives to promote the circular economy in order to retain products at the consumption stage. It's a paradox of the circular economy to which the regulation seeks to respond. This concept was applied to the regulation of used batteries but could be extended to the management of used electrical equipment and could even be applied in the context of packaging.

The batteries regulation contains other novelties, such as a level of incorporation of recycled materials into new products, which promotes a balance between supply and demand for recycled materials. Historically, extended producer responsibility has created a supply of recycled materials for some of which there was no demand. These regulatory changes aim to strengthen the demand for these materials in order to develop the markets for them to be effectively taken back, with environmental and economic benefits.

The batteries regulation also establishes, for the first time, goals by target material. The batteries regulation puts the house in order by specifying a range of families: from electric car batteries to light vehicles and portable batteries. The regulation also introduces new concepts associated with the circular economy, such as repair and reuse.

Packaging management has not escaped this legislative dynamism either. The acceleration of the packaging regulation follows in the footsteps of the battery regulation. It highlights, for example, the reinforcement of the incorporation of recycled materials into packaging and the attack on over-packaging. The packaging regulation seeks to better define what packaging is, clarifying what is inside and outside this concept. Being a regulation, it will allow for a better comparison between countries for statistical purposes.

Also in 2023, the so-called "e-assessment" began: a study conducted by the European Union with an external consultant to evaluate the success and failure of used electrical equipment management policies. This study will result in a decision by the European Commission on whether to revise the directive, publish a regulation or take different measures. The study is not complete, but there are some significant preliminary conclusions.

From the outset, there is a trend towards stagnation in CENELEC certification, which verifies the best environmental performance in treatment units. The activity of an electrical equipment shredder counts for recycling purposes in Poland or Hungary but not in Portugal. Europe needs to quickly make this certification compulsory, at least for hazardous flows, which are especially sensitive due to their negative impact on health and the environment.

A second important aspect, common to all countries, is the inability to meet targets for the collection and recycling of electrical equipment, mainly because of exports to uncontrolled destinations and the parallel market, which diverts and processes electrical equipment without taking decontamination into account, with severe environmental and public health consequences.

In the last quarter of the year, the European Commission recommended that member states consider economic incentives for the return of specific electrical equipment, such as cell phones, computers or tablets, using innovative, unconventional logistics, like postal services or others, in order to promote collection. The recommendation has since been incorporated into UNILEX. Electrão has been a pioneer in some pilot experiments in awarding economic incentives, not directly to the consumer but to other economic agents with whom it interacts.

We should also highlight a unique initiative in the recycling sector: the critical raw materials regulation. It identifies materials that Europe considers critical to leveraging the energy and digital transition and the defence sector.

Various geopolitical and geostrategic issues have led Europe to look at its autonomy and consider alternatives for the supply of certain materials. In the absence of raw material availability, the consumer's home emerges as an alternative source for securing these materials. This way, we can collect, separate, treat and reintegrate them into new production chains.

The new regulation identifies materials and sets targets for recycling to contribute around 25%. It's a total game-changer. It's about putting the recycling system at the heart of the European strategy in the name of sovereignty, self-governance and the rights of the environment.

In 2023 in Portugal, selective collection in recycling bins resulted in around 460,000 tons of packaging. Overall, taking into account the contribution of packaging recovered from undifferentiated waste, mechanical and biological treatment processes and incineration, the national packaging management system sent 499,000 tons for recycling, very close to the 2022 figures, which means that the system has not grown. Of these, 56,000 tons were taken back by Electrão and sent to recyclers.

Aluminium packaging increased by 9% compared to the previous year. Plastic grew by around 4%, and paper/cardboard rose by 3%. Glass showed a negative trend, with 3% less packaging recycled than the previous year.

The potential of undifferentiated waste collection

For two decades, Portugal has focused on increasing selective collection and communicating waste separation. The model of the last 20 years has stagnated, as the results show. The country currently recycles just over half of the packaging it consumes. There is, therefore, an urgent need to give the undifferentiated stream more prominence within the framework of urban waste management. If Portugal wants to reach other figures in packaging recycling - especially glass recovery - it needs to look at the undifferentiated container.

There are many valuable materials in the undifferentiated stream and there are many options for separating them by processing this waste. In order to follow this strategy, it is essential to promote the selective collection of bio-waste. By removing bio-waste, the materials that are still mistakenly deposited in the undifferentiated container - despite the huge awareness and communication effort of the last 20 years - will be free of contaminants and easier to recover for reuse/recycling.

If Portugal wants to meet the targets that have been set for the management of municipal waste, particularly packaging, it will have to work on the two streams - selective and undifferentiated - and promote multi-material collection and the separation of different families of materials to boost recycling. 

Even the Deposit and Return System for beverage packaging, which the country has been looking forward to for several years, could gain traction and boost recycling rates to around 80 and 90 percent, particularly in the beverage packaging family.  However, this will always be a complementary effort that won't be enough to reverse the trend.

Increase in counterpart values

The fees to be paid by management entities to Municipal Waste Management Systems for sorting packaging increased by 14% in 2023. The process of reviewing these values has not yet been completed, and a significant increase is expected for the second half of 2024. This will have an impact on the amounts to be charged to the companies that place the packaging on the market and, consequently, on consumer bills. 

This reinforcement of the values, which have not been updated since 2017, was urgent but, more than discussing magnitudes of value, it is important to ensure that efforts are made to increase economic efficiency and quality of service. We often hear citizens outraged at how full the recycling bins are, at the lack of maintenance in the surrounding areas, and that the frequency of routes is unknown. Several service quality indicators need to be fine-tuned. When the consumer is likely to pay twice as much for the service, what guarantees are there that this will be a fair cost?

We are dealing with a single service provider that operates under the logic of a natural regional monopoly, as is the case with SGRUs and municipalities. Only competition can guarantee economic efficiency. Introducing competition in collection, at least in the downtown area, would not be complex. In sorting, however, for reasons of economies of scale and scope, the scenario could be different.

We are living through a critical moment in waste management. . In order to achieve the objectives, collaboration between all players in the value chain must be strengthened. The solution is not to simply present companies with a higher bill, making consumption more expensive. The operation of the management entities that represent them is constrained, particularly when it comes to managing end-of-life packaging. Management entities are held hostage by a closed model that offers little room for evolution. There is an urgent need to optimize operations, with a transparent model and fair costs that promote efficiency and guarantee better service quality.