2. medium term is to bridge the gap between the two groups of EU
member states in relation to waste management performance, but also,
considering a long-term perspective, to spur a rise in recovery and re-
cycling levels among the EU candidate countries. In order to address the
latter problem, one of the initial steps is to understand the specific local
context of the European candidate countries and the challenges for
implementation of the European Union packaging waste standards in
general, and the EPR mechanism in particular. So far, in contrast to the
EU member states, where a significant amount of research and policy
attention has been directed towards the topics of packaging waste
management and the EPR mechanism, to date there has been com-
paratively little attention focused on the same topics in the context of
European candidate countries. In order to address this gap, by using
Serbia as a case study country, this paper examined the evaluation and
performance of a packaging waste management system based on the
EPR mechanism in the context of an EU candidate country.
2. Theoretical framework: extended producer responsibility (EPR)
system
2.1. What is it and how does the EPR system work?
The EPR framework is a national level and market oriented policy
(OECD, 2001). It represents an environmental policy that encompasses
the “polluter pays” principle where the producer bears the financial
responsibility of (packaging) waste management. The EPR aims to in-
ternalize the cost of environmental burdens related to the product’s
whole life-cycle by assigning responsibilities to producers who are ob-
ligated to take care of their products after consumers’ use (Lifset et al.,
2013; Sachs, 2006). It is enforced for different types of materials –
packaging waste, electronic waste, waste tyres, waste batteries, etc. –
and is adopted worldwide, but gained the most prominence in the EU
countries (e.g. Aarnio and Hämäläinen, 2008; Mayers, 2007; Nnorom
and Osibanjo, 2008). Today, there are about 400 EPR systems im-
plemented worldwide, generating significant resources from producers
by contributing to a global market worth about € 300 billion (OECD,
2016).
The EPR system allows the producers to exercise their responsibility
either individually or collectively, i.e. through individual or collective
compliance schemes. In individual compliance schemes, a producer is
responsible for organizing its own system for taking back used products
– which is usually the case when a producer sells its product(s) to a
limited number of users. On the other hand, when producers sell their
products to a vast number of users, collective compliance schemes are
much more common. Here, the producers transfer their responsibility
for management of packaging waste onto a specific so-called Producer
Responsibility Organization (PRO), which is set up to apply the EPR
mechanism on behalf of all adhering producers. There could be a cen-
tralized or competing PRO system within a country, i.e. with one domi-
nant PRO organization that covers the majority of materials placed on
the market, or several competing PROs, respectively. In return for its
service, a PRO receives financial contributions from producers, the level
of which usually depends on the quantity of packaging products placed
on the market. These contributions are used for investment in the de-
velopment of the infrastructure for source separation and collection of
recyclables, management of corresponding data, supervision of pre-
viously mentioned activities as well as to cover the operational costs of
a PRO. Investments in source separation and collection of recyclables
are usually made through contracts between PROs and local authorities
and/or private waste management operators (collectors). The level of
financial support that local authorities and/or private operators receive
differs across the countries and depends on who owns and sells the
collected recyclables.
The overall success of an EPR scheme is strongly related to its links
to a range of other supplementary policies (e.g. waste taxes, subsidies –
see also Alwaeli, 2010; Calcott and Walls, 2005) and regulations that
complement recycling initiatives by closing various loopholes (e.g.
landfill bans) (Loughlin and Barlaz, 2006; Tchobanoglous and Kreith,
2002). Finally, the EPR related activities require an adequate mon-
itoring and reporting system on the quantities of collected and recycled
packaging waste – which is usually done by a state authority.
2.2. Recent literature on EPR within the European context
The recent scientific literature shows different perspectives on
European EPR schemes according to the topics covered. First, a group of
contributions have analysed, evaluated and/or compared national EPR
schemes by focusing particularly on drivers and market conditions that
influenced the development of EPR schemes and their effectiveness, the
role of local authorities within EPR schemes, etc. (Cahill et al., 2011;
Hage, 2007; Loughlin and Barlaz, 2006; Niza et al., 2014). The second
stream of literature includes articles that investigated different aspects
of economic issues related to the functioning of EPR schemes, such as
who is bearing the net financial cost of packaging waste management –
industry or local government (da Cruz et al., 2012; 2014), cost and
benefits of waste management operators within different EPR systems
(Marques et al., 2014), appropriate producer fee models (Pires et al.,
2015), etc. The third stream of literature addresses the issues related to
the role and potential of EPR schemes in the prevention of packaging
waste generation (e.g. Tencati et al., 2016; Walls 2006). Finally, the last
group represents effort focused on examining various theoretical per-
spectives related to EPR schemes. For example, Massarutto (2014) and
Fleckinger and Glachant (2010) studied alternative models of the EPR
programme, Simões and Marques (2012) overviewed the use of dif-
ferent methods for assessing waste cost and (in)efficiency in the overall
waste sector, Baum and Schuch (2017) analysed the necessity of ad-
justment for distorting factors in benchmarking analysis related to cost
comparison of the different forms of the EPR implementation, while
Dubois (2012) highlighted a specific gap that might be created between
economic theory and implementation after introduction of specific
measures. In addition to these streams of scientific literature, there are
several recent and significant international organization reports. For
example, a recent report of the European Commission (European
Commission, 2014) aimed to identify guiding principles for the func-
tioning of European EPR systems by analysing and comparing different
types of EPR presented in European member countries. An OECD1
(2016) report provided a broad overview of key issues as well as gen-
eral considerations related to the EPR mechanism (e.g. potential ben-
efits and cost associated with EPR, the inclusivity of the EPR system in
regard to the informal recycling sector, etc.).
Our review reveals that the majority of the recent literature and
reports covers predominantly the context of European member coun-
tries. So far, little is known of EPR schemes’ performance and chal-
lenges in the context of European non-member countries. Furthermore,
only a few scientific studies provide in-depth quantitative and quali-
tative evaluation of the overall national EPR system related to packa-
ging waste (including all material specific recyclables: glass, plastic,
metal, paper/cardboard and wood). In order to address these gaps, by
examining the Serbian packaging waste management system, we
wanted to address questions such as (a) how the EPR mechanism per-
forms in the context of an EU candidate country and (b) what are the
main challenges in achieving EU recovery and recycling rates.
3. Materials and methods
3.1. Description of Serbian packaging waste management system (SPWMS)
3.1.1. Institutional framework
Serbia has a relatively young packaging waste management system
1
The Organization for Economic Co-operation and Development.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
131
3. that has been implemented in response to the EU waste management
directives. The EU Packaging Directive (1994)2
was translated into
Serbian legislation in 2009, when the Law on Packaging and Packaging
Waste3
entered into force (Official Gazette of RS, no. 36/09)4
. The law
corresponds to the concept of “polluter pays” and it sets overall national
recovery and recycling targets that have to be met by packaging waste
generators. Also, it allows the introduction of the EPR mechanism and
sets the foundation for a collective compliance scheme. Namely, ac-
cording to the packaging legislation, economic entities (packaging
producers) that place over 1 t of packaging on the market annually are
responsible for taking care of their packaging waste. They can achieve
the prescribed recovery and recycling targets through: (a) extending
their responsibilities to a collective PRO; (b) organizing an individual
compliance system for packaging waste management; (c) paying a
“polluter fee” prescribed by the Ministry of Environmental Protection
(MEP) in relation to their annual report on packaging quantities placed
on the market.
3.1.2. Organization of Serbian packaging compliance Scheme5
The administrative organization scheme of the SPWMS is presented
in Fig. 1. The actors involved in the Serbian packaging waste man-
agement system occupy seven different roles. As for administrative
duties – the MEP is responsible for overall monitoring of the actor’s law
obedience, while the Serbian Environmental Protection Agency is re-
sponsible for collecting official statistics on packaging and packaging
waste. The main responsibility for relocation of the financial con-
tributions from the producers to the actors in charge of the operational
management of packaging waste lies with the six licensed and com-
peting PROs – the backbone of the EPR scheme. The Serbian EPR
system initially started with three PROs, established in 2010 (SE-
KOPAK, EKOSTAR PAK and DELTA-PAK). In 2012, two more PROs
were licensed (CENEKS and TEHNO EKO PAK), while in 2013 the last
PRO (EKOPAK SISTEM) was registered. Each of the PROs has to achieve
overall national recovery and material specific recycling objectives
(Table 1) for all of five types of recyclables. To achieve that, the PROs
are allowed to manage and administrate the process of recovering re-
cyclables from each waste stream – municipal, commercial and in-
dustrial. Out of the six PROs, SEKOPAK, EKOSTAR PAK, DELTA-PAK
and CENEKS6
manage recyclables recovery from all waste streams,
while the other two PROs recover recyclables only within commercial
and industrial waste streams. For recovery of packaging waste from the
municipal waste stream, the PROs mainly contract and reimburse
Public Utility Companies (PUCs). As for the recovery of recyclables
from the commercial and industrial streams, the PROs usually contract
and reimburse private waste operators, but they can contract PUCs as
well (as in some municipalities PUCs are in charge of commercial and
industrial waste management). The reimbursement rates for the col-
lection and sorting of packaging waste paid by the PRO to the PUCs and
private operators are usually determined on an annual basis. However,
the financial supports received from the PROs represent the only sub-
sidies for public and private waste operators. A dominant part of the
expenses related to the waste operators’ service is covered by profit
obtained by selling recyclables to processing industries as well as from
local waste management taxes.
The Environmental Protection Fund (EPF) was an independent state
actor initially involved in the financial support of the packaging man-
agement system. However, with the change in government in 2012, a
political decision was taken to abolish the fund due to a formal claim of
financial abuse, i.e. non-transparent distribution of the fund’s invest-
ments (BGEN, 2016). Afterwards, the Department of Economic Instru-
ments for Environmental Protection within the MEP partly undertook
the fund’s roles and its activities – but with no clearly defined rules on
how financial resources should be allocated. In March 2016, the EPF
Fig. 1. The administrative organization scheme of the Serbian Packaging Compliance Scheme (adapted from SEPA, 2016).
2
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0062-
20150526.
3
The law was supplemented by nine rule books, for example: Regulation on the criteria
for the calculation of the allowance for packaging (Official Gazette of RS, no. 8/2010),
Rule book on the report forms for packaging and packaging waste management (Official
Gazette of RS, no. 21/2010, 10/2013), Rule book on the report forms for waste streams
(Official Gazette of RS, no. 114/2013), etc.
4
https://www.paragraf.rs/propisi/zakon_o_ambalazi_i_ambalaznom_otpadu.html.
5
Kosovo is not included in this analysis.
6
Since 2016, CENEKS has started to recover only paper and cardboard from the mu-
nicipal waste stream.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
132
4. has been re-established as a new fund called the “Green Fund”, which
should pave the way to the establishment of an independent revolving
fund in the near future. The new fund was officially launched in Jan-
uary 2017 and according to the first government announcement, no
more than 30% of the collected eco taxes will be directed to environ-
mental projects, where recovery of recyclables is just one among many
financed activities (BGEN, 2016).
3.1.3. Informal Recycling Sector (IRS)
Despite the institutionalization of the Serbian packaging waste
management system by introducing the EPR scheme, the IRS plays a
very important role and it is dynamically linked to the formal system. It
is mainly due to the fact that a large quantity of recyclable materials
within the municipal solid waste (MSW) streams remains “unused” and
usually disposed to landfills. In addition, low wages and a high un-
employment rate in combination with refugee movement from the
province of Kosovo during the war-conflict in 1999 as well as constant
people returns of economically marginalized groups of Serbian citizens
from the EU countries (mainly individuals from the Roma community)
have also influenced the creation of a large waste picker (WP) group
(Scheinberg et al., 2016). As a result, the market failures related to a
low supply of recyclables from the MSW stream in combination with a
set of socio-economic factors open a space for the actors outside the
formal recycling market to occupy the main role related to the supply of
recyclables from the MSW stream. The great majority of the WPs come
from socially and economically marginalized groups of society. Ac-
cording to some estimations, there are approximately 30,000 informal
WPs in Serbia making their living by collecting and selling packaging
waste – mostly PET, paper and cardboard recyclables (Čurćić et al.,
2015; SAPWR, 2015). The WPs sell collected materials to the private
licensed waste collectors, directly to the recycling industry (especially
PET) or to PUCs in charge of MSW management (see Fig. 1). However,
the quantities of recyclables collected by WPs are not included in the
official statistics, but rather they are assigned to official actors.
3.1.4. Collection and recovery of packaging waste
As for the particular way of collection and recovery of packaging
waste from the municipal waste stream – the waste collectors use sev-
eral methods. First, in those municipalities where the recycling pro-
grammes exist, the most common collection method for packaging
waste is curb-side collection, where mixed household waste is collected
from residential areas and sorted in Material Recovery Facilities
(MRFs). There are currently ten municipalities in Serbia which have
MRFs. Second, several cities have partly implemented systems for pri-
mary separation of MSW by introducing the infrastructure for sepa-
rately collecting wet (the organic waste fraction and non-recyclables)
and dry (recyclables) fractions of MSW. To facilitate these systems, in
some cities within the collective residential areas, there are two on-
street or two underground containers per location. Also, in some areas
dominated by family houses – a set of two plastic boxes or bags are
used. Recyclables collected in this way are also sorted in MRFs and
usually are of better quality than those recovered from mixed MSW.
Third, several PUCs are organizing the extraction of recyclables from
landfills by employing human labour (usually the most socially and
economically marginalized groups of society). For example, in the
Serbian capital – Belgrade, and the second largest city – Novi Sad, there
are currently up to 60 and 30 people, respectively, engaged as waste
pickers (WPs) for recovering recyclables from landfills7
. The WPs are
obligated to sell all collected recyclables to the PUCs, for a price sig-
nificantly lower than the market price. Here, the PUCs employ the WPs
through a contract with a third party – a company that organizes the
work of the WPs, and which is responsible for their work safety. In this
way the PUCs try to formalize the work of WPs who had already been
present on many landfills (but in much larger numbers).
3.1.5. Recycling industry
Serbia has a recycling (processing) industry for all kinds of packa-
ging waste categories, which is mainly located within the private sector.
To a great extent, some branches of the recycling industry (in particular
paper, metal and glass) are the legacy of the former state of Yugoslavia,
dating back to the last century. For example, paper industry was es-
tablished in 1921, while glass industry was established in 1986. On the
other hand, the recycling of plastics is a relatively new industry, where
plastic recyclables are usually processed at a lower level of technolo-
gical treatment and then mainly exported abroad for further processing.
There are two national associations of recyclers in Serbia: the Serbian
Association of Packaging Waste Recyclers and Association of Serbian
Recyclers (members of this organization are not only associated with
packaging waste, but also with other kinds of waste).
3.2. Secondary and primary data collection and analysis
Our secondary data collection consisted of three main data sets: (i)
reports on the annual performance of the Serbian packaging waste
management system (SPWMS) issued by Serbian Environmental
Protection Agency; (ii) national census data issued by the Statistical
Office of the Republic of Serbia and (iii) official data on packaging
waste in EU countries issued by the statistical office of the European
Union (EUROSTAT8
). To supplement these secondary data sets, we also
conducted desk research of the academic literature and specialized re-
ports on the packaging and packaging waste and EPR schemes perfor-
mance in Europe. In addition, in order to get a more nuanced picture
about the SPWMS’s functioning and performance, we collected avail-
able data related to packaging waste from various local and national
media archives as well as professional websites and social network
Table 1
Overall and material-specific national targets for recovery and recycling of packaging waste in Serbia 2010–2019 (SEPA, 2016).
I period II period
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
OVERALL TARGETS
Recovery % 5 10 16 23 30 38 44 50 55 60
Recycle % 4 8 13 19 25 31 36 42 48 55
MATERIAL SPECIFIC RECYCLING TARGETS
Paper and cardboard % 0 0 14 23 28 38 42 47 53 60
Plastic % 0 0 7.5 9 10.5 14 17 19 21 22.5
Glass % 0 0 7 10 15 19 25 31 37 43
Metal % 0 0 9.5 13.5 18.5 23 29 34 39 44
Wood % 0 0 2 4.5 7 11 12 13 14 15
7
Information obtained at the Conference “Reciklaža i uključivanje neformalnih
sakupljača u sistem upravljanja otpadom [Recycling and inclusion of informal waste
pickers into the waste management system]” organized by the Serbian Chamber of
Commerce and Industry in Belgrade, Dec 16, 2016.
8
http://ec.europa.eu/eurostat/statistics-explained/index.php/Packaging_waste_
statistics.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
133
5. groups.
The primary data are collected via 15 semi-structured interviews in
order to map the main challenges currently faced by the system.
Namely, we interviewed representatives of 9 different stakeholders that
are directly involved in various activities within SPWMS (see Table 2).
The interviews were carried out between March 2016 and April 2017,
and they lasted between 40 min and 2 h. The interview questions cov-
ered the following issues: (i) detailed description of the actor role
within SPWMS; (ii) relationship and cooperation with other actors
formally and informally involved in SPWMS; (iii) main challenges faced
by an interviewed actor within the current system of packaging waste
management; (iv) pros and cons of current system for packaging waste
management (e.g. institutional, organizational and financial perspec-
tives); (v) opinion about the IRS role within the formal packaging waste
management system; (vi) perceived barriers and opportunities, both
within an interviewee’s organization and external to it, for improving
SPWMS performance in relation to recyclable recovery and recycling
levels.
In addition to these interviews, as a method for primary data col-
lection we used participant observation of formal and informal actors as
some of the authors attended over 10 local and regional meetings, de-
bates and conferences devoted to packaging waste and the informal
recycling sector (IRS). The data and information collected through
participant observation were particularly helpful to better situate the
role, performance and various challenges faced by the IRS (as these data
are usually absent in official reports and available literature).
Data analysis was divided into two parts. Firstly, the selected sec-
ondary datasets were interrogated in order to examine more nuanced
relationships than those presented in the original data sources. Then,
summary and descriptive statistics were performed. Secondly, the pri-
mary data collected via interviews and participant observations were
coded into various nodes and sub-nodes related to the research objec-
tives as well as to the main interview topics. Using this method we were
able to organize, classify, and analyse a large amount of unsorted data
and get more refined categories.
4. Results and discussion
The annual placements of packaging9
on the Serbian market are
presented in Table 3. The amount of packaging placed on the market
has increased by 1.5% in the period between 2011 and 2016. In this six-
year period, considering the material specific weight, market placement
of all kinds of packaging increased except glass packaging, the annual
placement of which decreased by almost 30% for the same period (see
Table 4). This reduction in the amount of glass packaging could be
largely related to the trend for the replacement of glass with plastic
packaging in the beverage industry.10
On the other hand, the highest
increase of packaging material placement over the six-year period was
recorded for wood and paper/cardboard: 39% and 8%, respectively (see
Table 4). In 2016, the materials specific weight share of packaging
waste was: paper/cardboard (32%) and plastic (26%), followed by
wood (21%), glass (17%) and metal (4%) (see Table 4).
The total amount of packaging waste recovery through the EPR
system has been progressively increasing in line with the national
binding targets (see Table 4). In 2016, over 98% of the amount of
packaging placed on the market was covered by the EPR system, while
the rest was placed by 244 companies11
outside the EPR system. Cur-
rently, there is no company in Serbia with its own packaging waste
management system. On average, 95% of recovered waste is recycled.
As for the number of “free riders”, currently, there is no available in-
formation. However, the existence of the problem was acknowledged
by the MEP (SEPA, 2017), who is planning to address this problem by
developing the integrated informative system for storing and managing
information on all waste streams.
Statistical analysis indicates linear increasing ratio between packa-
ging placed on the market and collected packaging waste for every
waste fraction in period 2011–2016 (see Table 4). Paper and cardboard
packaging waste shows highest increasing trend (58%), followed by
metal (34%), plastic (17%), glass and wood packaging (∼17%). Total
linear increase of the system efficiency is 31% (see Fig. 2).
The commercial and industrial waste streams represent the main
Table 2
Interviewed actors.
Actor Position Number of interviewed persons
Ministry of environmental protection Head and the head assistant of Waste and Wastewater Management Division 2
Serbian Environmental Protection Agency Independent Advisor at Department of National Registry of Pollution Sources 1
The Producer Responsibility Organisation (PRO) Sales Manager (PRO 1), Supply Manager (PRO 2) 2
Municipality representatives Member of Waste Management Group, City of Novi Sad 1
Public Utility Company Assistant Landfill Manager (PUC, Novi Sad), Head of Recycling (PUC Belgrade) 2
Private waste operators (recyclable collection and trade) Environmental Engineer (from the City of Bačka Palanka), Owner (from Novi
Sad)
2
Packaging waste recyclers President of Serbian Association of Packaging Waste Recyclers 1
Civil Society Organisation (voluntary recyclables collection) President of UG Komšija (the city of Novi Sad) 1
Informal actors Street waste pickers 3
Table 3
Annual placement of the overall packaging on the Serbian market (in tonnes)
(SEPA, 2011; 2012; 2013; 2014; 2015; 2016).
2011 2012 2013 2014 2015 2016
Companies within
EPR system
Number of companies
1069 1306 1462 1616 1722 1771
[t]
334257 340409 317327 324408 339695 344662
Companies with its
own packaging
waste
management
system
Number of companies
1 – – – – –
[t]
3737 – – – – –
Companies outside
the EPR system
Number of companies
324 232 262 268 244 277
[t]
5663 3837 4258 8608 11332 4139
Totala
Number of companies
1394 1538 1724 1884 1966 2048
[t]
343657 344246 321585 333016 351028 348801
a
Besides paper/cardboard, plastic, glass, metal and wood, the “total” values
of packaging waste includes a small amount of “other recyclables” which do not
fit into the main groups of recyclable materials.
9
Placement of packaging and packaging waste generated in EU legislation are used as a
synonym
10
For more insights about glass-packaging issues see Meylan et al. (2013).
11
On average, the majority of these companies are placing much lower amounts of
packaging on the market than those companies under the EPR scheme.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
134
6. Table 4
The quantities of municipal waste produced (P) and collected (C), the type and weight of overall packaging materials placed (P) on the Serbian market and collected
(C) within the EPR system (adapted from SEPA, 2011; 2012; 2013; 2014; 2015; 2016; 2017).
2011 2012 2013 2014 2015 2016
GDP per capita (€)b
4200 4100 4300 4200 4300 4400
Municipal waste [kg/person]
P Ca
P Ca
P Ca
P Ca
P Ca
P Ca
370 289 360 254 340 268 300 234 260 192 270 211
Packaging materials [kg/person]
P C P C P C P C P C P C
Plastic 11.8 1.6 12.3 1.9 11.9 1.9 12.3 2.3 13.0 2.9 12.8 3,8
Glass 11.9 0.9 10.8 1.1 8.6 1.3 7.8 1.3 8.5 1.7 8.4 2,2
Metal 1.6 0.1 1.7 0.6 1.8 0.5 1.8 0.7 1.9 0.7 2 0,8
Paper/Card. 14.4 3.9 14.6 5.3 14.5 7.7 15.0 9.1 17.5 11.5 15.6 13,2
Wood 7.5 0.2 8.0 0.6 7.9 0.9 9.0 1.0 10.0 2.2 10.4 2,1
Total [kg/person]
47.2 6.7 47.4 9.4 44.7 12.3 45.9 14.4 51.0 19.0 49.3 22,1
[%]
100 14.1 100 19.7 100 27.3 100 31.3 100 37.2 100 44.7
a
collected and disposed by public utility companies.
b
http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&plugin=1&pcode=tsdec100&language=en.
Fig. 2. Ratio between packaging waste collected (C) and placed on the market (P) within EPR system from 2011–2016 (based on SEPA, 2011; 2012; 2013; 2014;
2015; 2016).
Fig. 3. The sources of collected packaging waste within the EPR system (SEPA, 2011; 2012; 2013; 2014; 2015; 2016).
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
135
7. sources from which the packaging waste has been recovered through
the EPR scheme. Considering the share in total quantity of packaging
waste collected, the recyclables collection from the MSW has decreasing
trends. Namely, 41% of recyclables have been collected from MSW in
2011, comparing to 30% in 2016 (see Fig. 3). This reduction in re-
cyclables recovery rate from MSW could be directly related to poor
performance of PUCs and linked to the abolishment of the EPF in 2012
– which represented the main source for financing the municipal pro-
grammes and infrastructure for source separation and collection infra-
structure12
.
The share of packaging waste collected through the EPR system by
each PRO is presented in Table 5. As presented in the table, SEKOPAK
and EKOSTAR PAK collected the greater share of packaging waste.
However, all of the six PROs have been successful in fulfilling the
specific national recycling goals (see Table 6).
As for the levels of packaging fees, according to available data from
SEKOPAK, which is a Serbian member of the European umbrella PRO
organization PRO EUROPE,13
they are among the lowest in Europe (see
Table 7). Initially, according to data obtained from the interviews, the
packaging fees should have progressively increased year on year.
However, this did not happen, which is mirrored in the decreasing
trends recorded in the last few years (PRO EUROPE, 2014).
4.1. Comparison with EU countries
In this part of the paper, we compared the main packaging waste
statistics between Serbia and EU countries. The EU countries are
grouped into 3 groups: (i) the EU15 countries14
, represented by the old
EU member states; (ii) the CEE11 countries15
(Central East European
Countries) represented by 11 newer EU member states that joined the
European Union during the 2000s and 2010s and which generally have
a lower economic standard; (iii) the EU2816
which comprises all the
member states. Figs. 4 represents a comparison between Serbia and the
EU28, EU15 and CEE11 countries in relation to quantities of packaging
waste generated, packaging waste recovered and recycled. In general,
the quantities of packaging waste produced across European Union
countries have growing trends. However, there is a significant varia-
bility in the total quantities of packaging waste generated within EU15
and CEE11 countries, where the countries in the latter group generate
on average 40% less packaging compared to the former group. On the
other hand, the CEE11 countries produce on average 51% more
packaging waste than Serbia. There is similar variability in the rates
among these groups and Serbia for quantities of recovered and recycled
waste.
5. The key challenges
Based on data on trends and progress of the SPWMS as well as on
the data obtained through the conducted interviews and participant
observations, in this part of the paper we present and discuss the key
challenges that have been shown to be critical for the further devel-
opment of the system.
5.1. Low supply of collected recyclables from MSW stream
The major challenge faced by the Serbian recycling sector is the low
and decreasing supply of collected recyclables from MSW (see Fig. 3). It
is becoming clear that if the amount of recovered and recycled packa-
ging waste in Serbia has to increase in order to achieve the constantly
rising EU levels (see Fig. 45), it will be necessary to increase the re-
cyclable supply from MSW. Namely, in April 2016, the European
Commission adopted the Circular Economy Package, which introduced
revised legislative proposals on waste that give even more priority to
diverting packaging waste from disposal by 2030 (European
Commission, 2016). Some of the common “2030 EU targets” are: re-
cycling 70% of municipal waste; recycling 80% of packaging waste,
reduction of landfilling to a maximum of 5% of municipal waste
(European Commission, 2017). However, in Serbia, a large amount of
recyclables from the MSW currently remains unrecovered. Several
closely interrelated issues are directly linked to this problem. First, the
majority of Serbian municipalities do not operate recycling pro-
grammes for household waste as they are not strictly enforced, nor do
they possess the infrastructure for primary selection, collection and
separation of packaging waste. Also, with the current level of monthly
waste management fees (2.6–3.5 c€/m2) and insufficient percentage of
chargeability (70% for households), the public operators do not possess
sufficient financial funds to invest in adequate infrastructure (e.g. bins
for different waste, waste transfer stations, etc.) (Vujic et al., 2017).
Also, the abolishment of the Environmental Protection Fund in 2012 cut
a significant financial resource that was used for investment in the in-
frastructure for recyclable collection from household waste. Further-
more, even though some of the public waste operators are supported by
international donor or aid development programmes, these incomes are
not sufficient to operate recycling programmes for the household.
Second, the payment of landfill tax – as a financial initiative for re-
cycling promotion only exists in a few Serbian municipalities where
sanitary landfills are operating. Thus, the majority of municipalities are
not “stimulated” to develop strategies that would recover recyclables
from MSW in order to reduce costs for landfill disposal. Third, specific
challenges related to IRS are faced in some urban areas. Namely, several
of the largest Serbian municipalities (e.g. Belgrade, Novi Sad, Pančevo),
supported by the PROs, have been investing in various infrastructure
projects for primary selection (e.g. waste bins for PET, paper and
cardboard). However, as the existing practise and interest of the rather
large WP community were completely ignored and excluded during the
planning process of the projects, these recycling initiatives proved to be
short-lived (Mrkajić and Stanisavljević, 2015). Namely, the WPs usually
damage new on-street facilities in order to pick up the recyclables,
while the municipalities have had no success in preventing them in
those activities. Finally, the lack of expertise during the recycling policy
development gave rise to some unintended and counterproductive
consequences. For example, the municipality of Novi Sad (the second
largest city) had supplied two large residential areas with bins for
primary separation of recyclables (blue bin) and organic and other
waste (green bin). In the beginning, the residents enthusiastically em-
braced the new service. But, very soon they found it pointless to
Table 5
The share of packaging waste collected by the licensed PROs (SEPA, 2011;
2012; 2013; 2014; 2015; 2016).
NRO 2011 2012 2013 2014 2015 2016
[%]
SEKOPAK 46.3 38.8 34.8 37.3 39.4 41.7
EKOSTAR PAK 46 51.9 56.7 46.6 41.5 38.3
DELTA-PAK 7.7 7.7 3.3 3.6 3.6 3.5
TEHNO EKO PAK / 1.6 5.0 6.9 7.4 7.1
CENEKS / / 0.2 2.2 4.1 3.4
EKOPAK SISTEM / / / 3.4 4 6
12
According to the Serbian Chamber of Commerce and Industry data, there has been a
recorded decline in investments – both in industry and in local public infrastructure
projects since 2012 (BGEN, 2016).
13
PRO EUROPE is an umbrella organization for the majority of European PROs.
14
The EU15 consists of the following countries: Austria, Belgium, Denmark, Finland,
France, Germany, Greece, Ireland, Italy, Luxemburg, the Netherlands, Portugal, Spain,
Sweden and the United Kingdom.
15
The CEE11 consists of the following countries: Bulgaria, Croatia, Czech Republic,
Estonia, Hungary, Latvia, Lithuania, Poland, Romania, Slovakia, Slovenia.
16
Besides EU15 and CEE 11 countries, the EU28 comprises as well: Cyprus and Malta.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
136
8. Table 6
Fulfilment of specific national goals by the PROs (in %) (SEPA, 2011; 2012; 2013; 2014; 2015; 2016).
National
targets
NROs
(average)
National
targets
NROs
(average)
National
targets
NROs
(average)
National
targets
NROs
(average)
National
targets
NROs
(average)
2012 2013 2014 2015 2016
[%]
Paper/
cardb.
14 36.7 23 54 28 60.4 38 77.3 42 85.6
Plastic 7.5 15.5 9 16.1 10.5 17.3 14 19.3 17 25.2
Glass 7 9.9 10 14.7 15 16.2 19 26 25 27.2
Metal 9.5 37.9 13.5 27.6 18.5 38.1 23 31.4 29 36.3
Wood 2 7.1 4.5 12 7 11.1 11 22.8 12 24.4
*
The “PROs (average)” values refer to the percentage of recyclable quantities collected by the PROs in relation to the total recyclable quantities placed on the market
by companies within the EPR system.
Table 7
The level of packaging fees in the region and in some of the EU member countries in 2014 (PRO EUROPE, 2014)c
and average selling prices in Serbia (from 2016
onwards).
Packaging fees Selling pricea
Serbia Macedonia Slovenia Estonia Spain Greece Serbia
[EUR/t] [EUR/t]
Paper/Cardboard 6 18.2 87 105 68 52.5 84-127
Plastics 11.2 22.10 68 409 377 66 186-338
Glass 6.9 19.80 36 102 19,5 10.9 17 – 34
Metal 7.5 20.80 77 255 85 21 Steel: 144-177
Wood 7.9 21.20 53 41 21 9.5 3 – 4.2b
a
paid by recycling industry.
b
price per piece for used/damaged EUR-pallet.
c
For information on the packaging fees for other European countries, please see PRO EUROPE (2014).
Fig. 4. Packaging waste generated (A), recovered (B) and recycled (C).
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
137
9. continue with waste separation, as the public operator used the same
vehicle for collecting the recyclables and other waste.
5.2. Loopholes affecting the recycling industry and PROs
As has been the case in other countries that introduced the EPR
scheme (Grodzińska-Jurczak et al., 2004; Loughlin and Barlaz, 2006), a
number of issues emerged in the Serbian recycling legislation that have
to be more precisely defined. In the first place are calls for corrections
to the Law on packaging and packaging waste. The strongest initiative
and the most articulated proposals for the law correction came from the
recycling industry. The main driver of their initiative is the insufficient
supply of recyclables on the Serbian recycling market.
The recycling industry highlights several legislative issues as the
main problems in relation to the low recyclables supply.17
First, the
abolishment of the EPF in 2012 has been seen as a very critical gov-
ernment move, as it has had an effect on the development of municipal
recycling programmes which are planned to be the major suppliers of
the national recycling market. Second, the association argues that the
national targets for recovery and recycling of packaging waste were set
too low, and thus they do not truly stimulate recyclables recovery from
MSW streams. Currently, the PROs are almost able to fulfil the national
recovery and recycling goals solely by targeting the collection of
packaging waste from commercial and industrial waste streams (which
is actually true for the three most recently licensed PROs). This situa-
tion is possible as there are no institutional constraints in relation to the
source from which recyclables should be collected – thus the PROs take
advantage of this state of affairs as it is less financially demanding to
organize recyclables collection from commercial and industrial
streams.18
Third, the recycling industry finds it very problematic that
there is no legal obligation which defines the level of funds that the
PROs have to invest in the development of primary infrastructure for
packaging waste selection and collection (especially for the MSW
stream). These and several other specific requests made by the recycling
industry, which particularly targets PROs, are presented in Table 8.
The two larger PROs support the majority of the recycling industry
requirements. Also, they call for additional regulation in order to close
the other loopholes in the EPR system. For example, SEKOPAK requires
that the legislation does not allow the recycling industry to establish a
PRO. SEKOPAK justifies this request by the fact that some PROs, which
have been partly funded by the recycling industry, practise mono-
polistic behaviour as they unevenly invest their funds in the recovery of
certain recyclables only (e.g. paper). Thus, some of the PROs are “ac-
cused” of not facilitating the equal development of the infrastructure
for the recovery of all recyclable materials. Also, the two larger PROs
are critical towards lately established PROs, accusing them of not in-
vesting funds in any development of the infrastructure as well as for
lowering the packaging fees, which are a further 40–50% less than their
already low packaging fees – which actually runs counter to the “pol-
luter pays” principle (SAPWR, 2016). Due to this phenomenon, some of
the PROs have started to face problems related to the loss of their
customers (i.e. contracted producers) who choose to cooperate with
those PROs that offer their services for a much lower price. Finally,
some PROs face problems related to chargeability of the packaging fees
from the producers. Here, they claim the existence of problems related
to the lack of legislative instruments and state inspection to enforce
some of the polluters to pay their packaging fees. Any enforcement by a
PRO directed towards the polluters with irregular payment of packa-
ging fees might result in the producer breaking its contract with that
PRO and signing a contract with some other PRO. As such, all these
phenomena, if not resolved, might undermine the existing EPR scheme
and create system distortions.
5.3. Informal recycling sector integration challenges
The rather large Serbian WP community of 30,000 individuals,
which is dynamically linked to the formal recycling system, represents a
fact that can hardly be ignored while discussing the performance and
further development of the Serbian packaging waste sector. Namely, in
order to increase the supply of recyclables from the MSW stream, the
Serbian waste policymakers seem to currently have two general possi-
bilities: a) to modernize its MSW collection system and exclude the
existing IRS from the system, or b) to modernize the MSW collection
system by integration of the IRS into the formal recycling strategies.
Both approaches are quite challenging.
The first option represents a strategy focused on technological mod-
ernization, which would require extraordinary national economic
growth to allow an increase in public investment in municipal waste
policies as well as an increase in the waste management fees paid by
citizens. According to an estimation of the Serbian Chamber of
Commerce and Industry, the current Serbian investments in all en-
vironment related policies, programmes and projects represent only
0.25% of its GDP, while to achieve the EU environmental standards –
Serbia should allocate a minimum of 1%–1.25% of GDP (BGEN, 2016).
On the other hand, if the investment costs were completely passed on to
industry – that would require a significant increase in packaging fees.
This would be a very hard and unpopular political decision taking into
account that the final consequences would be the higher price of pro-
ducts, i.e. a reduction of the already low purchasing powers of Serbian
citizens. Thus, with the current economic situation, this scenario seems
to be unrealistic, at least in a short to medium term (Vujić et al., 2011).
The second option would represent a strategy primarily focused on
socio-technological modernization (Rutkowski and Rutkowski, 2015;
Scheinberg and Anschtz, 2006). Namely, the current existence of large
IRS in combination with a high unemployment rate and low wages
opens the possibility for waste policy makers to create labour-intensive
recycling programmes, similar to those present in other world regions
(South America, Asia, etc.) (Ezeah et al., 2013; Rutkowski and
Rutkowski, 2015; Wilson et al., 2006). However, to utilize these po-
tentials, such a hybrid model has to fit its local context, interests, tech-
nologies, and available resources (Zapata Campos and Zapata, 2014). In
addition, it is necessary to achieve strong political will, regulatory
support as well as public acceptance. In respect to these requirements,
some steps have been undertaken in the last several years. As for po-
litical will and regulatory support of the WP community’s inclusion –
the strongest initiative came from international and local non-govern-
mental organizations,19
and the domestic recycling industry. For ex-
ample, the German Society for International Cooperation (GiZ) has
been implementing a six-year project “Municipal Waste and Waste-
water Management” (2011–2017). As one of the project’s four areas of
activity is listed “inclusion of minorities and informal stakeholders in
the regulated waste management system”20
. Through this activity,
some of the first quantitative and qualitative analyses and studies re-
lated to IRS have been financed21
. On the other hand, the Serbian
governmental authorities have focused on IRS issues mainly through
the national-level activities related to improvement of Roma status.
Namely, the Serbian government accepted several policies during the
2000s and 2010s in order to secure the involvement of the Roma po-
pulation in the formal labour market. For example, one of the issues
within the Action plan for implementation of Strategy for the Improvement
17
Based on information from an interview with the president of the Serbian
Association of Packaging Waste Recyclers, see also SAPWR (2015).
18
In contrast to households, the commercial and industrial entities are producing a
great amount of packaging waste in a certain place, and that waste is usually separated
before collection as a part of a company’s environmental management systems.
19
The most active are: the German Society for International Cooperation (GiZ), United
States Agency for International Development (USAID), the Dutch NGO WASTE, YuRom
Centar, Tree HOUSE.
20
More info at: https://www.giz.de/en/worldwide/21215.html
21
The final report is expected by the end of 2017.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
138
10. of Roma Status in the Republic of Serbia (2010) was a plan to recognize
WP activities as a formal occupation. As a result, the “waste picker”
profession received national occupational recognition (Scheinberg
et al., 2016). However, even though this government step paved the
way for IRS inclusion in the formal recycling sector, the overall legal
framework still does not stimulate the full inclusion of WPs. For ex-
ample, one of the most problematic issues is linked to the fact that the
Serbian institutional framework does not recognize the organizational
structure of “social enterprise” which would allow a reduction in the
state social and retirement taxes for members of WP cooperatives. The
organization of the WP cooperatives through establishment of the social
enterprises is important as it helps to strengthen the organizational
structure of the informal sector into a formalized group while at the
same time it makes them competitive with formal waste operators
(Ezeah et al., 2013; Gutberlet, 2012; King and Gutberlet, 2013). Finally,
as for public acceptance – besides the NGOs’ support, many re-
presentatives of recycling industries have strongly advocated inclusion
of the informal sector in the formal system of packaging waste man-
agement, while they see the WPs as a major supplier for some recycl-
ables (especially PET and cardboard/paper). However, the main chal-
lenges are related to the fact that the majority of municipal authorities
(i.e. PUCs) still consider WPs’ activities as incompatible with the goals
of modernizing the MSW management systems (Mrkajić and
Stanisavljević, 2015) as well as with the European safety regulative
frameworks and standards. As the municipal authorities in charge of
waste management represent key actors to IRS inclusion, a significant
effort has to be made to make them acknowledge and recognize the
overall benefits of the work of WPs.
6. Concluding remarks
This study provides a quantitative and qualitative analysis of the
Serbian national-level framework for packaging and packaging waste
management in regard to its evaluation and performance over the
course of the last six years. Serbia could be generally regarded as a
country with an evolving administrative and institutional approach to
packaging waste management. However, it has been possible to capture
much of the progress of the packaging waste management system from
the data presented in this study. Serbia has successfully managed to
recover nationally required amounts of packaging waste through the
EPR system, by targeting primarily recyclables from commercial and
industrial waste streams. The Serbian recycling market is in expansion,
which is mirrored in the increasing supply of collected recyclables from
less than 50,000 t in 2011 to over 155,000 t in 2016. However, there is
still room for improvement of the system. The main challenges that
have to be addressed in order to continue the further progress and
development of the system are: (i) the low supply of recyclables from
MSW, (ii) loopholes affecting the recycling industry and work of PROs,
and (iii) formalization of the IRS role within the EPR system. In regard
to these challenges, a set of general recommendations can be proposed.
As for the first two listed challenges, possible measures should:
• Secure stable and sufficient public investment in infrastructure for
primary separation, collection and sorting activities through a newly
established “Green Fund”. It is also necessary to establish trans-
parent procedures for the fund investments and secure strict in-
spection and monitoring of the performance and efficiency of re-
cycling programmes.
• Set national minimum packaging fee levels and enforce an increase
of the current level of packaging fees. At the same time, in order to
ensure sufficient financial transfer between industry and munici-
palities (i.e. waste management operators), it is necessary to define
the minimum percentage of the fund that a PRO has to invest in the
recovery of recyclables from MSW streams.
• Introduce landfill taxes – in order to stimulate municipalities to
reduce the amount of packaging waste disposed in landfill.
However, caution should be taken that the tax should not be set too
high in order to avoid the risk of illegal dumping. Finally, this
measure could be additionally supported by activity of supervision
of the disposal by a governmental authority.
As in many other developing countries where IRS exists, the activ-
ities of this sector bring multiple benefits for Serbia as well. The most
important of them is mirrored in the fact that the collection of recycl-
ables provides a livelihood for many members of marginalized social
groups. The IRS also diverts significant amounts of recyclables from
landfill to the recycling industry at much lower cost than formal waste
operators. Therefore, the question of the IRS inclusion in the formal
recycling system in Serbia seems important, especially considering its
social, environmental and economic components. The proactive actions
towards the IRS formalization should be continued and directed to-
wards the development of national and local initiatives and action plans
for the structural and legal inclusion of WPs, which should target both
service and value chains. Here, as Scheinberg et al. (2016) argue,
documentation, valorization and quantification of WPs’ contributions to
recyclable recovery is one of the crucial tasks, while international waste
management ideas and solutions should be carefully adjusted to the
local context and peculiarities as well as existing WP practices. In-
clusive programmes should offer at least the same level of income that
the WPs can already earn, in addition to health and pensions insurance.
Finally, this study has not specified all the challenges that the
SPWMS are currently facing. If the whole system is to be critically
evaluated, the following issues should be considered as well: problems
related to packaging waste reporting methodology, issues related to
Table 8
The recycling industry’s proposals for the law corrections in relation to the work of the PROs.8
Proposed correction Justification
Mandating the minimum level of initial capital for establishing a PRO, as a guarantee
that a PRO will be able to fulfil the producer responsibility undertaken.
To discipline small PROs which have reduced the packaging fees, and therefore
generally decreased the amount of investment in the development of infrastructure for
primary selection and collection of recyclables – which in turn lowers the supply of
recyclables.
Mandating PROs to deliver an annual report on their fund expenditure. To regulate the work of PROs and their fund expenditure – i.e. to make sure that
packaging fees received from industry are mainly reallocated towards the development
of infrastructure for primary separation and collection of the recyclable waste.
Mandating the minimum level of packaging waste that has to be collected from MSW. To make the work of PROs transparent in order to boost MSW recycling programmes
and thus increase the supply of recyclables.
Prohibiting the recyclables trade by PROs. To prevent the PROs influencing the purchase price of packaging waste. Currently, the
recycling industry accuses a few PROs of being involved in the purchase of packaging
waste by using their funds to offer a better price to waste generators than the recycling
industry.
Mandating the minimum percentage of PRO funds that has to be invested in
development of the system for packaging waste collection as well as for
development of the Serbian recycling industry.
To increase recyclables supply. To modernize the recycling industry in order to improve
its regional competitiveness.
V. Mrkajić et al. Resources, Conservation & Recycling 136 (2018) 130–141
139
11. national recyclable export/import policies, the lack of experts em-
ployed in the state and municipal waste management departments as
well as citizens’ awareness raising activities.
Acknowledgements
In this paper, we presented the results of the research project
“Development and implementation of a ‘social technology solution’ for
the improvement of the recyclable collection from municipal waste in
Vojvodina” supported by the Province Secretary of Science and
Technological Development, Vojvodina Province, Republic of Serbia
[Razvoj i primena “društvene tehnologije” za unapređenje sakupljanja
ambalažnog otpada iz komunalnog sektora na teritoriji AP Vojvodine
Pokrajinski sekretarijat za nauku i tehnološki razvoj]. Xiaoming Wang
was partly supported by the National Natural Science Foundation of
China (Grant No. 51508049). Pedro Haro thanks the Universidad de
Sevilla for the post-doctoral Grant Contrato de Acceso al Sistema
Español de Ciencia, Tecnología e Innovación (VPPI-US). The coopera-
tion between authors is related to the COST Action Mining the
European Anthroposphere (MINEA), supported by COST (European
Cooperation in Science and Technology).
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