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APPENDIX C
INTERNATIONAL CASE EXAMPLES
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Appendix C
International Case Examples
Case studies are presented in this Appendix of SWM systems from Canada (province of Nova Scotia) and
Europe (Germany). These case studies integrate legal and institutional frameworks, SWM service
delivery, financing and cost recovery issues. Accordingly, they illustrate how modern waste management
concepts that reflect sustainable development principles can be applied to at national and local levels.
The case studies are drawn from two jurisdictions that are widely considered to have had the greatest
success in the implementation of integrated solid waste management systems to date. The experiences of
these jurisdictions is valuable in that it is possible to draw conclusions regarding lessons learned that
might be applied to the countries and territories that are the subject of this document. The actions that
have been taken in the jurisdictions covered by these case studies have been designed in response to the
circumstances that each faces; these may differ significantly from the circumstances, opportunities and
constraints in some or all of the countries that are the subject of this document. Consequently, although
the lessons learned may be relevant to countries and territories, it will still be necessary for to design
responses to the lessons learned that are appropriate for the country or territory in question.
Canada/Nova Scotia
Legal and Institutional Context SWM in Canada is a responsibility that is shared between the provincial
and the federal levels of government. Primary responsibility for SWM rests with the provinces; the role
of the federal government is largely limited to research and international or inter-provincial issues.
Accordingly, provinces develop their own legislation, rwegulations and institutional structures.
National Initiatives The greatest contribution of the federal government to SWM in Canada has been to
lead the coordination of broad SWM between provinces so that all provinces have generally harmonized
policy frameworks. In 1989, the federal and provincial governments jointly determined that a 50%
reduction in waste would be achieved by 2000. This decision was accompanied by the formulation of a
strategic national waste minimization action plan that laid out broad measures that provinces could take to
achieve the goal that had been set; specific actions to achieve this goal were to be designed and
implemented at the provincial level. At the national level, however, particular focus was placed on the
management of packaging in recognition that, more than other aspects of the waste stream, national
coordinated approaches were appropriate for managing packaging waste to achieve a 50% reduction in
packaging waste. Agreement was also reached that progress towards these goals would be monitored by
the national Department of Statistics. Financing of investments to achieve the national goals that had
been established was agreed to rest with the provinces and municipalities, although the federal
government committed financing to demonstrate innovative new technologies, undertake research and to
monitor progress towards the goals that had been established.
Nova Scotia Located on Canada’s east coast and with a population of 1 million people, Nova Scotia is
one of Canada’s smallest provinces. In the late 1980’s, SWM systems in the province were characterized
by waste haulage to open dumps that frequently lacked any environmental control. However, there was
recognition that the waste management systems of the time: (i) were not environmentally sustainable; (ii)
were not compatible with the tourism industry that was being built; (iii) were economically inefficient
since they involved the loss of essentially all the materials in the waste stream. The province therefore
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took the opportunity of a national momentum to change waste management systems to incorporate the
national objectives into its own broader objectives, which included: (i) upgrading facilities for the land
disposal of waste; and (ii) developing a new, export-oriented industry around the conversion of wastes
into resources.
Analysis of options and opportunities regarding how Nova Scotia could participate in achievement of
national objectives while also achieving its own objectives included technical and economic studies and
public consultations. These concluded with five key findings: (i) technology existed and was being
applied in other parts of the world that could recycle or compost the great majority of solid waste; (ii)
significant industry participation could only be achieved through direct regulation; (iii) litter from
beverage containers was a specific high priority public issue (iii) the costs associated with integrated
solid waste management systems could be reduced through joint municipal service delivery, revenues
from recovered materials; and (iv) there was broad public support for waste management systems based
on waste minimization and resource reutilization.
The legislative, regulatory and institutional program that the province implemented to achieve its
objectives responded to these findings, as shown in Table C.1. The consequences of these approaches
have included the substitution of recycling and composting in place of land disposal for most packaging,
paper, paperboard and biodegradable materials, and the participation of the private sector as the
operational means by which virtually all services are delivered under contract to the Service Regions;
facilities may remain under the ownership of the Service Regions, however, in order to ensure that
options are available with regard to choice of operator. Financing is undertaken by Service Regions on
behalf of the municipalities they serve and with support from the public/private Resource Recovery Fund
Board, whose finances accrue from the $Cdn 0.05 of unredeemed deposit on every beverage container
sold in the province. The participation of industry on the Resource Recovery Fund Board, which
participates in financing and administering recycling and composting initiatives, builds industry
participation in the SWM initiative within the framework of “shared responsibility” that governs the
relationship of producers, government and the public to SWM in Canada and which assigns “polluter
pays” responsibilities to all three.
Cost recovery uses a variety of mechanisms. Private and institutional generators are subject to user-pay
systems based on the volume (for transport) and weight (for disposal, recycling or composting) of waste
they generate. SWM costs of householders are paid from general municipal tax revenues. Revenues are
received from the sale of recyclable materials and compost. Cost recovery includes amortized and
depreciated capital costs, so that funds for capital replacement are available in a timely fashion.
Results The objective of reducing used packaging waste across Canada by 50% by 2000 was achieved in
1996. Across Canada, approximately 21 percent of all waste generated is recycled or composted; in Nova
Scotia, over 40 percent of waste generated is recycled or composted currently, and this proportion is
expected to rise to at least 50% by the end of 2000. Currently, there are 2,900 people employed in the
SWM sector in the province. The number of waste disposal facilities in the province has been reduced
from over 60 land disposal facilities (none of which met modern landfill design standards, and most of
which were open dumps) to 18 landfills; 1 municipal solid waste incinerator also operates.
European Union/Germany
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Legal and Institutional Context SWM among the member countries of the European Union (EU) is
subject to the policies of the European Parliament, which are expressed as “Directives”. EU countries are
required to implement national programs in accordance with Directives and according to timeframes
established by Directives. The wording of a Directive governs the flexibility and timing available to
national governments in the design and implementation of actions to conform with the Directive.
European Union The overall objectives of EU SWM policy are to: (i) give priority to the avoidance of
waste through application of clean technology; (ii) improve environmental standards associated with
waste management; and (iii) to prevent the abandonment of waste. The EU has endorsed the principle of
“polluter pays” and has determined the need to be self-sufficient in waste disposal. As a consequence of
these policy objectives, a high priority has been given to the recovery of waste for the purpose of
recycling, composting and recovery of energy. The EU has recognised both that: (i) “the reduction of
waste is essential for the sustainable growth” of the countries of the European Union.
The SWM policy objectives of the EU are expressed in a waste management Directives that obliges
national governments to: (i) use defined and harmonized waste management terminology; (ii) reflect a
priority on waste avoidance and waste recovery; (iii) develop national/regional SWM policy and plans in
consultation with the public and industry; (iv) license SWM operations; (v) consider the use of economic
instruments and the “polluter pay” principle to achieve waste avoidance; (vi) establish institutional
structures with specific responsibility for achieving these objectives. Additional Directives relevant to
SWM address performance standards for SWM incineration facilities and the management of packaging.
A draft Directive, to be considered by the European Parliament before the end of 1999, will address
specific aspects of the land disposal of waste.
The Directives issued by the EU have not only established a comprehensive structure for SWM in
member countries, but have also been pivotal in determining the specific SWM actions taken by
countries. The focus on waste avoidance has been given specific meaning through the establishment of
targets for the recovery in general of packaging waste and the recycling specifically of such waste; by
2001, a minimum of 50 percent by weight of packaging waste must be recovered for its material or
energy value, and a minimum of half of this amount must be recycled. The draft Directive on the land
disposal of waste: (i) establishes wastes that may not be landfilled (including liquid wastes, certain types
of industrial hazardous waste, infectious wastes and tires); (ii) requires that wastes to be landfilled must
be treated first to reduce potential for negative environmental impacts; (iii) requires that the amount of
landfilled biodegradable municipal waste be reduced by 25 percent by 2002 and by 75 percent by 2010;
(iv) specifies licensing requirements for landfills; (v) requires that the price charged by a landfill operator
for disposal of waste in a landfill must cover at least the costs of setting up and operating the landfill, in
addition to the costs required for closure of the landfill at the end of its life and the maintenance of the
closed landfill.
Monitoring of compliance by member countries is undertaken by the EU. Implementation, including
creation of national SWM frameworks, service delivery, financing and cost recovery are outside the
mandate of the EU.
Germany As a member of the EU, German SWM frameworks and systems have been designed to be
compliant with the Directives of the EU. Accordingly, the broad objectives and policies of the German
national SWM system reflect the “polluter pays” principle, the priority placed by the EU on waste
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avoidance, recovery and recycling (including composting) of waste and use of waste disposal facilities at
a method of last resort. In addition, an explicit objective of SWM in Germany is the development of a
“recycling economy”.
The SWM legislative and regulatory framework in Germany sets out broad requirements associated with
waste management planning, waste auditing , recycling and composting, incineration and energy
recovery, the certification of waste management facilities and the activities of the private sector. One of
the most important features of the German SWM legislative framework is that it interprets the “polluter
pays” principle in terms of placing responsibility for managing used products on “parties who develop,
manufacture, process, treat or sell products”; parallel with this, it establishes specific goals for the
recovery of used packaging.
In common with many other countries around the world, waste management services are delivered at the
municipal level. Private sector participation in all aspects of service delivery is encouraged. Compliance
with the legislative/regulatory framework is monitored by state and federal environmetnal agencies, and
municipalities monitor/enforce the contractual obligations of contractors. In response to their obligations
under the legislative/regulatory framework, packaging producers have established an organization known
Duales System Deutschland (DSD). DSD has designed and implemented the recovery and marketing of
systems necessary to achieve the levels of packaging recycling required under the legislative/regulatory
framework. The legislative/regulatory framework has also driven the redesign of products ranging from
packaging to automobiles in order to improve product recyclability.
The financing of SWM in Germany is undertaken at the municipal level for those wastes for which
municipalities are responsible. Packaging recycling systems have been financed by DSD; particular focus
has been placed on the establishing systems to recover and recycle used packaging using existing
infrastructure where possible and financing new collection and processing infrastructure where necessary,
especially for the recycling of plastics. User pay systems are in place for private and institutional waste
generators who contract with the private sector for the haulage of waste. In some municipalities, linkage
is established between the amount of waste set out for collection by householders and the amount the
household pays for waste management services; in most cases, however, public waste management
services are recovered as a budget item of municipal financing derived from general revenues. However,
budget estimates and cost recovery frameworks at all levels include allowance for capital expenditures, so
that capital equipment replacement can take place in a timely fashion.
Results The actions of the EU have resulted in co-ordinated action to give effect to dramatic SWM
changes in Europe, the full impact of which will only be seen over the next several years in most
countries. The key approaches to SWM have been established as, in decreasing priority: (i) avoidance of
waste; (ii) recycling and composting of wastes that are generated; (iii) recovery of energy from wastes;
and (iv) disposal of wastes. Legislative action has been taken to give specific effect to these priorities,
and this action incorporates broad SWM planning, the application of economic instruments, design and
performance standards for SWM facilities. Roles and responsibilities for action have been defined in
terms of the “polluter pays” principle.
The application of these approaches has been furthest advanced in Germany, where the “polluter pays”
principle has been taken to mean “producer responsibility”. One consequence of this approach has been a
sharp decline in the amount of packaging managed through disposal. One survey estimated that
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disposable packaging declined by 55 percent in Germany between 1990 and 1995, and that a further 50
percent reduction is anticipated by 2000. SWM planning and service delivery frameworks in Germany
are consistent with those required by the EU; user pay approaches to the use of waste management
services and infrastructure has also been critical to encouraging waste minimization and the utilisation of
SWM techniques other than disposal. Dedicated levels of monitoring and enforcement has accompanied
the implementation of the SWM system.
Lessons Learned
The following “lessons learned” are applicable to the countries and territories that are the subject of this
document:
1.
2.
3.
4.
5.
National SWM policy should recognise the broad negative impacts of waste on the environment
and the economy, as well as on society, and should be structured to: (i) encourage waste
avoidance; (ii) integrate the recovery of material and energy value into the economy; (iii) include
public input into its preparation; (iv) ensure the environmentally sustainable siting and operation
of waste management infrastructure and equipment; (v) develop specialised SWM capacity at all
levels of application; (vi) incorporate monitoring and enforcement activities; (vii) implement full
cost accounting methods in the capitalisation and cost recovery elements of SWM systems;
incorporate user-pay mechanisms and service delivery by the private sector.
Under the “polluter pays” principle, product producers have responsibilities for managing their
products when they are discarded as waste; these responsibilities encompass financial
participation in SWM systems.
Application of the “polluter pays” principle, together with mechanisms for its application, are
increasingly being defined in law. Voluntary agreements between industry and government on
the application of the “polluter pay” principle are not sustainable over the long term since neither
side is bound by such agreements; in addition, there is continuing risk that some private sector
operators will not participate in a voluntary agreement, or will back out, thereby subverting the
intent of the agreement and creating a market distortion.
Broad-based and phased plans should be prepared to guide investments in SWM. Plans should
identify, at a minimum: (i) the sequence of actions that will be taken to implement enhanced
SWM and the timing of actions; (ii) who will undertake the actions and with what objectives and
results anticipated; (iii) who will monitor/enforce actions; (iv) how actions will be financed; (v)
how costs will be recovered.
Dedicated institutional capacity is required at all levels to ensure effective implementation of
SWM systems.
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Table C.1
Selected Solid Waste Management Regulatory and Institutional Frameworks
Framework
Component
Canada
Nova Scotia
European Union
Germany
Overall Objectives
Reduction of 50% in amount of
solid waste disposed of by 2000 as
compared to 1990, consistent with
sound environmental practices;
national performance standards for
incinerators.
Achieve national targets for reduced solid
waste and packaging; implement “full
containment” landfills; maximize
economic benefits associated with
management of “wastes” as resources;
achieve greater municipal cooperation
Give priority to the avoidance of waste
generation and the reduction in harmfulness;
to encourage the development and
application of clean technology as a means
of achieving the first objective; to improve
environmental standards associated with
waste treatment and disposal; to prohibit
abandonment of waste. Establish principle of
“polluter pays” and self-sufficiency in waste
management.
To develop waste law and waste
management towards a recycling
economy.
Policy Approach
Preparation of national waste
minimization action plan;
development of national Packaging
Protocol for reducing packaging
waste; monitoring of progress by
federal Department of Statistics and
provinces.
Phased agenda of regulatory initiatives
based on results of public consultation
process, complemented by limited
flexibility for action by municipalities and
private sector.
Preparation of Directives establishing overall
waste management policy frameworks for
SWM and specific aspects of SWM.
Legislation to enshrine the primacy
of waste avoidance and the
recycling of wastes that are
generated. Disposal is identified as
the least desirable management
method.
Legislative/
Regulatory
Instruments
No direct legislative/regulatory
instruments; application of national
policy depends on voluntary
agreements between federal
government and provinces.
Legislation that establishes the target to
reduce waste requiring disposal by 50%
by 2000 and regulations and implementing
procedures that: (i) ban disposal of
specified plastics, compostable organic
material, glass and metal food containers,
cardboard, newspaper, most beverage
containers, tires, car batteries; (ii) require
all beverage containers to be refillable or
recyclable and implementing a “half-back”
beverage container deposit/refund
program; (iii) places a levy on tires, which
is used to support tire recycling; (iv)
Directives oblige member states to establish
national frameworks consistent with those of
the Directives. EU Directives require that
member states should: (i) harmonize waste
management terminology; (ii) implement a
hierarchy of waste management principles
that places priority on waste avoidance; (iii)
consult with industry and the public on
SWM policy/plans; (iv) establish national/
regional waste management planning
processes; (v) establish national systems for
licensing waste disposal and recovery
operations; and (vi) apply economic
Legislated application of the
polluter pays principle; the creation
of a prevention-oriented hierarchy
of obligations (avoidance before
thermal or material recycling); the
equal status of thermal and
material recycling; producers'
responsibility for their products;
extending the opportunities for the
privatisation of waste disposal.
Legislation identifies that only
wastes that cannot be recycled may
be disposed of. Regulatory
directives have been implemented
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Canada
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Nova Scotia
European Union
Germany
establishes technical and social criteria for
landfills and incinerators, and for
composting facilities; (v) establishes
financing mechanisms for municipalities
to plan and implement SWM systems; (vi)
encourages industry stewardship; (vii)
monitors progress towards the waste
reduction goal.
instruments to achieve waste avoidance; (vii)
establish institutional structures to implement
these actions. Incineration Directive sets
performance standards. Packaging Directives
establish targets and schedules for
recovery/recycling of used packaging.
Proposed sub-directive on landfill requires
pretreatment of waste, 75% reduction in
landfilling of biodegradable waste by 2010.
to govern: (i) waste certification;
(ii) the European catalogue of
waste classes; (iii) waste requiring
recycling under special
supervision; (iv) waste
management planning and waste
audits; (v) the activities of private
sector waste disposal firms.
Institutional
Elements
National secretariat (Canadian
Council of Ministers of the
Environment – CCME) coordinates
implementation of national policy
Legislation/regulations administered
through Department of the Environment.
Municipalities organized into 7 Service
Regions for planning and delivery of
SWM services. Resource Recovery Fund
Board (RRFB), a public/private
partnership, established to implement
beverage container deposit/return system
and participate in financing recycling and
composting activities.
A Directorate within the EU is responsible
for monitoring compliance with the
Directives and proposing amendments for
approval by the European Commission.
Legislation delivered through
German Environmental Agency
within the Ministry for
Environment, Nature Conservation
and Nuclear Safety. Municipalities
deliver waste collection services.
Producers responsible for
packaging have established Duales
System Deutschland (DSD) to
finance and, where necessary,
operate mechanisms for the
recovery and recycling of used
packaging.
Service Delivery
Elements
None at federal level
Service Regions may choose to deliver
SWM through private sector contracts;
businesses and institutions separately
contract with private sector. Facility
infrastructure owned by Service Regions.
None at EU level.
Municipalities deliver waste
collection disposal services or
through private sector contractors.
Private sector responsible for
recycling used products.
Monitoring/
Enforcement
CCME monitors progress towards
national objectives; no authority to
enforce
Department of the Environment monitors
compliance with environmental standards.
Municipalities monitor performance of
service provision.
EU monitors enforcement. Member
countries are obligated to comply.
German Environmental Agency
monitors compliance with federal
requirements. Municipalities
monitor performance of service
provision.
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Canada
Nova Scotia
European Union
Germany
Financing/ Cost
Recovery
Federal government makes
financing available for new
technologies, approaches etc.
related to SWM in accordance with
national objectives; financing/cost
recovery of day-to-day operations
outside mandate of national
government.
Facilities capitalised by municipalities
with assistance from RRFB. Operating
costs recovered from sale of recyclable
materials and compost, contributions from
RRFB and municipal tax revenues.
Financing and cost recovery are outside EU
mandate.
Public facilities financed by
municipalities. DSD and members
finance packaging recycling. Cost
recovery for public facilities from
private user fees and taxes; user
fees for public users in some cases.
DSD cost recovery from licensing
of logo denoting recyclable
packaging and revenues from
recovered materials.
Results
National reduction of greater than
50% in packaging sent for disposal
between 1989 and 1996; 21% of
solid waste recycled or composted
(preliminary 1999 estimate).
Amount of waste requiring disposal
reduced by over 40% as compared to
1995; number of disposal facilities
reduced from 60 in 1990 to 18 in 1999;
2,900 jobs in solid waste sector.
Aggressive SWM programs being
undertaken by member states. Rapid waste
avoidance, recycling and composting
technology development and
implementation.
Reduction in disposable packaging
of 55% in 1995 compared to 1990;
further 50% reduction projected by
2000. Reduced reliance on landfill