Auditor General Janar Holm said that: "Promises and the reality are becoming more and more divergent."

"Although Estonia, as an EU Member State, has been under obligation to recycle half of its municipal waste since last year, it is actually able to recycle less than third. This is precisely the greater recycling of bio-waste in addition to packaging waste that would help to achieve the recycling targets." Holm continued in an audit office press release, noting that Estonia has remained at the current level for 10 years already.

The National Audit Office prepared two reports, entitled "Recycling of bio-waste included in municipal waste" and "Waste recycling operations at landfills and supervision of landfills", covering the period 2017–2020, which formed the basis of these findings.

Both the Ministry of the Environment and the Ministry of Rural Affairs should, in addition to preventing the generation of food waste, make efforts to ensure that, for instance, compost made from such waste is returned to agriculture as valuable nutrients, which can replace artificial fertilisers and improve soil properties.

"The measures of the  Rural Development Action Plan could promote the use of compost made from bio-waste, but this has not been done at present," Holm said.

Compost could also be used in road construction and landscaping procurements, thus promoting its use, the audit office finds.

Unsorted waste still ending up in landfill sites

Another major issue is the proportion of municipal waste which is destined for landfills, unsorted, again 10 years after this practice should have ceased, the office says.

This can include bio-waste, which can end up incinerated or buried, even though the Waste Act prohibits the disposal of unsorted mixed municipal waste in refuse dumps, and the maximum amount of biodegradable waste, including paper, cardboard, timber, clothing and bio-waste, in landfills, is capped at 20 percent.

While the situation with recycling has improved over the past five years, the office says, the risk is still present that waste is mislabelled as recyclable in order to avoid pollution charges, primarily because the Environmental Board (Keskonnamet) does not determine whether recycling is justified when giving it the go ahead, while environmental permits do not establish specific requirements for recycling, plus supervision is not effective.

The audit office therefore recommends the Environmental Board carry out better inspections to iron out these issues. Landfill site operators should also provide credible evidence for their recycling actions, proving that waste is used to replace natural materials which would have been otherwise used, that replacing waste is useful in and of itself, and that waste is recycled in the same quantity as would have been required if natural materials had been used.

The office found that the board, formerly the Environmental Inspectorate, has not checked landfill compliance during the period 2017-2019, though the board justifies this lack of inspection based on legislative ambiguity and that systems are in place at local authority level which, the municipalities claim, ensure this.

Audit office: Environment ministry should ensure waste which can be recycled or incinerated

Neither the local authorities nor the Environmental Board have inspected whether waste is actually collected by types, the audit office says.

The Ministry of the Environment should also establish a requirement that no municipal waste which can be incinerated (which could be used in energy generation of for other bi-products - ed.) or recycled as material can be deposited at landfills, which would make the Environmental Board's inspections easier and encourage local authorities to separate waste.

Since only a quarter of bio-waste generated is collected separately, Estonia is at risk of incurring an EU waste fine.

Manifestations of this include municipal food and garden waste being deposited in the same trash cans, preventing the adequate collection of bio-waste – which could be used to produce bio-gas, as well as the compost usage noted above.

Recycling of bio-waste actually fell, from 18 percent of the total to 11 percent on year to 2019, the audit office found, while an action plan aimed at doubling municipal recycling by 2025 will not be completed a couple of years before that, making reaching the target more difficult.

Estonia has pledged to the EU that 55 percent of municipal waste will be recycled in 2025 and 65 percent will be recycled in 2035.

Bio-waste quick facts:

• 122,000 tonnes of bio-waste was generated in 2019.
• 93,000 tonnes of this ends up in mixed municipal waste, and just 29,000 tonnes is separately collected.
• Only 11 percent (13,900 tonnes) of bio-waste generated to date has been recycled, the majority of this being composted.
• A maximum of 37,500 tonnes of food waste per year can be composted or used to produce biogas.
• 57,000 tonnes of garden waste per year can be handled.
• Only 10,000-11,000 tonnes of compost is certified as meeting certain requirements.
• There are five municipal waste landfills operating in Estonia, which received 175,000 tonnes of waste in 2019.
• Pollution charges must be paid when disposing waste, which has the effect of making refuse disposal more expensive than recycling or recovery of waste. A landfill has to pay just under €30 per tonne of waste dispose.
• In 2019, landfills paid a total of €4.9 million in pollution charges.
• In 2019, landfills recovered 110,000 tonnes of waste.
• Landfills also use waste to generate waste fuel and in construction works (e.g. landfill slopes, interlayers, roads and sites).

The Ministry of the Environment has commissioned analysis to be completed in 2021, to determine options in achieving targets, and further activities regarding both waste management and circular management are planned for end of 2022.

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