Managing our waste

bring-in site

Malta’s waste management strategy establishes the attainment of a zero waste target by the year 2050. An ambitious target, but also an achievable one.  How will we get there in thirty five years time?

The waste management strategy was updated in January 2014 through the publication of a waste management plan aptly subtitled ‘A resource management approach’. It has a seven-year lifespan (2014-2020).

Waste is considered a resource which should be utilised instead of being thrown away.  For this to be achieved, we need to change gear and shift from a linear to a circular economy.

In the linear economy, we consume (or use) a product and at the end of its useful life we throw it away. On the other hand, the circular economy functions such that a product (or its constituent parts), at the end of its useful life, remains in existence by being utilised to create another product.

In line with the EU waste hierarchy, Malta’s waste management strategy rightly places waste prevention as a first step.

Waste prevention, or waste minimisation, signifies the reduction of generated waste to a minimum.  Life cycle thinking is key to reducing waste throughout the useful life of a product. This is done when a product is still being designed. Applying eco-design weeds out the unnecessary constituent elements of a product. In addition, these constituent elements are also examined, such that it is ensured that none of them impede the eventual recycling at the end of the product’s useful life.

We can also minimise waste by ensuring that we purchase and use only that which is required in appropriate quantities. We can do this, for example, by using products in large sizes instead of similar multiple products in small sizes, as a result sending less packaging to waste.

The next level of the waste hierarchy is the recycling of products at the end of their useful life. We already recycle glass, metal, paper and plastics but we need to substantially improve our recycling performance as a nation. We need to acknowledge that we had a very late start in recycling. The first attempts at recycling were carried out in the mid-1990s under the watch of then Parliamentary Secretary Stanley Zammit. Unfortunately, Dr Zammit received very little support in his endeavours. 2013 statistics indicate that in Malta only six per cent of domestic waste is recycled, with another five per cent being composted. This 11 per cent of Malta’s domestic waste, which does not go to landfill, is in striking contrast to that for Germany (65%), Slovenia (61%), Austria (59%), Belgium (55%) and many other countries.

Statistics for 2014 and 2015 may eventually show a slight improvement, but we still have quite a long way to go.

Wasteserv will shortly be commencing a pilot project to collect organic waste separately from domestic households. Organic waste can be converted into energy. It can also be used to produce compost. In addition, if the collection of organic waste is carried out successfully from all households, it may reduce the contents of the black garbage bag by as much as 50%, signifying a substantial reduction of domestic waste going to landfill. (If catering establishments were to take similar initiatives, the achievable results would be much more significant.)

A proper implementation of rules regulating the waste arising from electric and electronic equipment should hopefully be in place in the coming weeks when responsibility for this waste stream is definitely transferred to the private sector in terms of the extended producer responsibility specified in the EU’s WEEE Directive (WEEE meaning waste from electric and electronic equipment).

It is also essential to address the operation of scrap yards, which are an affront to Malta’s environmental obligations. They are mostly an eyesore, generally a blot on the landscape, as well as being the cause of negative environmental impacts.

Recycling scrap metal (and other materials) is an important economic activity which ensures that resources originally extracted from the earth are kept in use and not discarded as waste. Recycling activity, if properly managed, is an important economic activity which is environmentally friendly.

Managing properly the waste which we generate reduces our environmental impacts and improves our quality of life. In addition, the employment opportunities created are an important source of green jobs.

published in The Malta Independent on Sunday – 20 September 2015

The politics of e-waste

WEEE Electrical and Electronic Waste


Last Monday’s budget has placed waste on the national agenda once more.  This time the focus is on waste generated by electric and electronic equipment. Put simply the issue is that there exists conflicting legislation on the Maltese statute book. On the one hand it is the applicability of the Eco-Contribution Act. On the other hand its the WEEE Directive of the EU which has been transposed into Maltese legislation as of 2007 (Legal Notice 63 of 2007 since replaced by Legal Notice 204 of 2014). WEEE meaning Waste from Electric and Electronic Equipment.

The Eco-Contribution Act of 2004 established the quantum of an eco-contribution to be paid on electric and electronic equipment. This eco-tax was added on to the price of the various electric and electronic equipment sold in local shops: fridges, ovens, telephones, computers, electronic games, calculators, vending machines ………………….  The  amount of tax payable ranging from 25 euro cents to €69.88.

Eco-contribution collected peaked in 2008 at slightly over €15.6 million. It is estimated that around €7.8 million will be collected in 2014 and another €6 million in 2015.

As of 2007 producers (and their representatives), in addition to being responsible for the payment of the eco-contribution, have also been responsible for implementing the WEEE Directive in Malta. This Directive forms part of a number of a set of EU Directives which address different waste streams with the objective of ensuring that waste is considered as a precious resource. Hence the need to recover this resource in order to reintegrate it into the economy.  This means the transformation of all waste into useable resources.

The Directive applied the principle of extended producer responsibility throughout the life of the equipment.  This signifies that producers of electric and electronic equipment, directly as well as through their representatives (the importers) and those dealing with such equipment at points of sale retain responsibility throughout the life cycle of the products. This life cycle thinking has its first impact on the drawing board as producers seek to minimise the use of resources not only cost-wise but also due to the fact that if they do so they will have less to recover. This encourages eco-design. Thereby designing and subsequently producing products whilst keeping in mind their impact throughout their life. It is much more that a cradle to grave view. In fact it is considered as a cradle to cradle approach as at the end of its useful life a product will through recovery of the materials of which it is made up give rise to new products.

What does it signify for us?

Producers and their representatives have the direct responsibility of recovering  electric and electronic waste. In terms of the Directive they will either recondition the equipment or else strip it into its component parts and recycle the resulting materials. This will be done at a cost.  Depending on the efficiency of the process the producers and their representatives will recover a proportion of their costs when they sell the recovered resources.  The unrecovered costs may, in terms of the Directive, be added on to the price of the products. Producers’ representatives in Malta maintain that it is possible for the quantum of the unrecovered costs to be much lower than  what is currently being paid as an eco-contribution. Hence the net impact could be not only environmentally beneficial but also of direct benefit to the consumer.

The budget has announced a transition period lasting up to the end of August 2015 when it is planned that the eco-contribution on electric and electronic equipment is removed and producers (through their local representatives) assume their full extended responsibilities.

Electric and Electronic waste is currently collected by local councils through their bulky refuse service. It is also collected at bring-in sites operated by Wasteserve.  Producers will seek to coordinate these existing collection services with their already operational recovery schemes.

Alternattiva Demokratika-The Green Party as well as GRTU and other producers representatives have been insisting for ages that this is the way forward. In order to achieve results everyone must however play his part.

The net result will be beneficial for both the environment as well as the economy.


published in The Independent on Sunday – 23 November 2014

Reforming eco-taxation

Time for Radical Change

Malta Today reports this morning that in tomorrow’s Budget Speech Government will be proposing a reform of the Eco-Contribution Act. Malta Today further reports that the eco-contribution due on electric and electronic equipment will be discontinued. Instead, states Malta Today, Government will proceed with ensuring the implementation of the Waste from Electric and Electronic Equipment  (WEEE) Directive of the EU.

The WEEE Directive shifts responsibility for the recovery of waste from electric and electronic equipment to producers and their representatives. It is an Extended Producer Responsibility which has so far not been implemented in Malta notwithstanding various warnings  and infringement proceedings initiated by the EU Commission. It requires the  direct involvement of the private sector who will now have to assume direct responsibility for waste recovery in the WEEE stream.

The matter is dealt with extensively in AD’s Electoral Manifesto. In fact in the Environmental Chapter of AD’s 2013 Manifesto it is stated that :

“We encourage waste separation in localities. However we recognise that this is not enough. As a country we still lag behind and have failed to reach targets on packaging waste as well as waste generated by electrical and electronic equipment.

It is essential to address the operation of scrapyards. These process waste which is subject to at least three Directives of the EU, namely the WEEE Directive, the End of life Vehicles Directive and the Batteries Directive. The manner in which scrapyards have been permitted to operate signifies a total disregard of the principles and safeguards listed in the said Directives. The fact that after more than eight years of EU membership we are still discussing these issues signifies the low level of preparedness to shoulder environmental responsibilities resulting from EU adhesion.

It is essential that environmental taxation (eco-contribution) is reformed in order that it be ascertained that environmental objectives are attained. The private sector should not be penalised through double payment in order that it fulfils its responsibilities relevant to waste on which eco-contribution was due.

Environmental taxation has two objectives. Generating funds to be used by the exchequer as well as to serve as a deterrent and consequently to reduce environmental impacts. For the deterrent to be effective it is essential that when environmental taxes are proposed it be ensured that as far as possible an alternative product or service to the one being taxed which generates less impacts than the taxed product or service is available.

On the other hand we are aware that environmental taxes which are not properly designed can be regressive. That is they can have a negative social impact due to their impacting the quality of life of those with limited means. In order to ensure that the primary objective of environmental taxation would be environmental improvement AD proposes that environmental taxation should be the joint responsibility of the Ministry of the Environment and the Ministry of Finance.”

Eco-taxation can be of considerable benefit. It however needs to be properly designed. Alternattiva Demokratika looks forward to a discussion on the new proposals.

Waste Management politics


“We encourage waste separation in localities. However we recognise that this is not enough. As a country we still lag behind and have failed to reach targets on packaging waste as well as waste generated by electrical and electronic equipment.

It is essential to address the operation of scrapyards. These process waste which is subject to at least three Directives of the EU, namely the WEEE Directive, the End of Life Vehicles Directive and the Batteries Directive. The manner in which scrapyards have been permitted to operate signifies a total disregard of the principles and safeguards listed in the said Directives. The fact that after more than eight years of EU membership we are still discussing these issues signifies the low level of preparedness to shoulder environmental responsibilities resulting from EU adhesion.” (AD’s Electoral Manifesto, pages 89-90, March 2013)

The existence of operational scrapyards is an affront to Malta’s environmental obligations.

In scrapyards one finds discarded vehicles and other objects made primarily of metal  beyond their useful life. There are a number of operational scrapyards in various areas in Malta.  A major one was closed by MEPA some years back in Birżebbuġa. This is now in the process of reopening as an up to standard End of Life Vehicle facility based in Ħal-Far. The relative planning and environmental applications have been processed by MEPA and Malta Enterprise and the facility should be operational in the not too distant future.  There are other scrapyards (large and small) in various parts of the island. They are mostly an eyesore, generally a blot on the landscape as well as being the cause of negative environmental impacts.

Recycling scrap metal (and other materials) is an important economic activity which ensures that resources originally  extracted from the earth are kept in use and not discarded as waste. Recycling activity if properly managed is an important economic activity which is environmentally friendly. Employment created in this type of activity is an important source of green jobs.

Vehicles and equipment beyond its useful life cannot be disposed of haphazardly. Three specific EU Directives,  namely the End of Life Vehicle Directive (ELV), the Batteries Directive and the Waste from Electric and Electronic Equipment Directive (WEEE) establish  the responsibilities of EU member states to regulate in detail these specific waste streams.  The objective is to recover metals and other materials which would otherwise go to waste. Their recovery should however be carried out in an environmental friendly manner.

Each and every part of a vehicle or a piece of equipment should be dismantled with particular care being given to the collection of fluids and gases. No such care is afforded in scrapyards.

Similarly it is to be pointed out that the electric and electronic waste directive (WEEE) is not being properly implemented in Malta. This is due to the fact that there is a conflict between the responsibilities spelt out in the Directive and the eco-contribution charged in Malta on electric, electronic and white goods.

The WEEE Directive spells out and applies the responsibility of producers for disposing of the electric and electornic waste generated by their products. It does so to encourage producers to put on the market products which are easily recoverable and which can be recycled without much difficulty and expense. The recovery from consumers of electric/electronic products and white goods beyond their useful life can be carried out an at expense which in terms of the WEEE Directive is to be added to the purchase price. But the situation in Malta is such that the cost of processing the waste generated by electric/electronic products and white goods is already quantified as an eco-contribution. This was fairplay when there was no WEEE Directve in operation. But now producers would have to pay twice for the same service. They pay an eco-contribution on placing the product on the market and then they must pay once more to honour their WEEE committments.

In view of the above the WEEE Directive has not yet been properly implemented in Malta.

It is about time that we get our house in order. The politics of waste is a very important matter which has not yet been given sufficient thought.  Except that is for the siting of waste management faciltiies, which seems to be the only waste issue which has interested the public in recent years.

The Issues Paper published recently by Minister Leo Brincat makes scant reference to the above. Maybe this is because it is a preliminary document preceeeding the actual Waste Management Plan for 2014-20.

A structured discussion on waste policy will certainly be of help. Having a multitiude of public consultation exercises by the different Ministries launched during the summer period is not  good practice. It is an old trick played by those who want to  nominally honour their obligations to consult.  Hopefully when the actual draft Waste Management  Plan 2014-20 is available for consultation we will have ample time to discuss.

published in The Times of Malta, Saturday August 31, 2013

Snippets from AD’s electoral manifesto: (19) Waste


The following extract is taken verbatim from Chapter 14 of AD’s Electoral Manifesto

We encourage waste separation in localities. However we recognise that this is not enough. As a country we still lag behind and have failed to reach targets on packaging waste as well as waste generated by electrical and electronic equipment.
It is essential to address the operation of scrapyards. These process waste which is subject to at least three Directives of the EU, namely the WEEE Directive, the End of life Vehicles Directive and the Batteries Directive. The manner in which scrapyards have been permitted to operate signifies a total disregard of the principles and safeguards listed in the said Directives. The fact that after more than eight years of EU membership we are still discussing these issues signifies the low level of preparedness to shoulder environmental responsibilities resulting from EU adhesion.

L-Estratt segwenti hu mehud kelma b’kelma mill-Kapitlu 14 tal-Manifest Elettorali ta’ Alternattiva Demokratika

Ninkoraġixxu s-separazzjoni tal-iskart fil-lokalitajiet. Nirrikonoxxu iżda li dan m’huwiex biżżejjed. Għadna lura bħala pajjiż biex nilħqu l-miri Ewropej għall-iskart mill-ippakkeġġjar kif ukoll l-iskart ġenerat minn apparat elettriku u elettroniku.
Hemm bżonn b’mod ġenerali li jkun imminimizzat kull xorta ta’ skart u għal dan l-iskop hu meħtieġ li jittieħdu inizzjattivi li jgħinu f’din id-direzzjoni.
Huwa neċessarju li jiġu indirizzati r-relevanza u l-mod tal-operazzjoni tal-iscrapyards. Preżentement f’dawn l-iscrapyards jiġi pproċessat skart li huwa kontrollat taħt tal-anqas tlett Direttivi tal-Unjoni Ewropea: id-Direttiva WEEE, l-End of Life Vehicles Directive u d-Direttva dwar il-Batteriji. Il-mod kif l-iscrapyards qed jitħallew joperaw f’Malta jfisser abbandun totali tal-prinċipji u salvagwardji elenkati fl-imsemmija Direttivi. Li wara iktar minn tmien snin mis-sħubija ta’ Malta fl-Unjoni Ewropea għadna nitkellmu fuq dawn l-affarijiet ifisser kemm kienet defiċjenti it-tħejjija biex pajjiżna jerfa’ l-obbligi ambjentali li dħalna għalihom bis-sħubija.

What it takes to Green Cinderella


published on Saturday March 20, 2010


Malta’s environmental policy has to date been EU driven for the simple reason that the political establishment in Malta has resisted its development. Dumping environmental responsibilities with land use planning has, in my view, been an integral part of this strategy.

Notwithstanding its past performance, the government’s declaration that it will now embark on consultations leading to the formulation of an environmental policy, which is locally driven, is welcome news. Only time will tell whether this is another exercise in green-washing.

The government’s commitment to safeguard the environment is not to be gauged through its declarations but through its actions or lack of them. Its lack of environmental credentials has been manifested many times. The latest being by Parliamentary Secretary Mario de Marco who, when introducing the Environment and Development Planning Bill in Parliament, stated that the environment will “no longer be the Cinderella of development”.

This has not come about accidentally. It was a deliberate exercise as a result of which the expertise, which the former Department for the Environment was slowly accumulating, was wiped out. Those who plotted the merger needed to ensure that environmental decisions were subject to development considerations at all times.

Cabinet responsibility for the environment made its first appearance immediately after the 1972 Stockholm Human Environment Conference. In 1976, Malta had a Minister for Health and the Environment. His environmental remit focused on landfills. During his watch, the Luqa and Wied Fulija landfills were closed and a new landfill at Magħtab was opened!

The first real minister for the environment in Malta was Daniel Micallef. He was appointed in 1986 during Labour’s last months in government by then Prime Minster Karmenu Mifsud Bonnici, who was seeking to counterbalance the widespread corruption in the Lorry Sant-led Ministry of Works. This corruption was subsequently documented.

Between 1986 and 2002 much was achieved. It would suffice to state that when, in 2002, the Department for the Environment was disbanded it had more credibility and was much more effective than Mepa’s Environment Directorate is today.

A local company that bottles water and soft drinks was recently awarded the 2009 Environment Award for Industry by the Cleaner Technology Centre. The company had relocated to a new site, upgrading its facilities to function eco-efficiently. But it still makes use of substantial amounts of water extracted from the water table through boreholes and sells this as bottled water and soft drinks. Extraction is to the tune of 51 million litres annually. The director of the Cleaner Technology Centre, when prodded in other sections of the press, admitted that the award adjudicating board was not aware that the company extracts ground water through boreholes. Seen within the context of Malta’s depleted water table this award is environmentally blasphemous.

Some persons entrusted with environmental matters have a proven capability of justifying the unjustifiable. This partly explains why Malta’s environmental administration is in shambles.

Within this context I believe there are more pressing issues than the drafting of an environmental policy. Applying all the EU environmental acquis would be a good first step.

A point I have harped on in these pages (1) (2) is the non-implementation of the waste from electric and electronic equipment directive. This directive applies “the producer responsibility principle” as a result of which producers and their representatives have to take back electrical and electronic waste from consumers. Most importers are aware that they are in breach of the directive’s provisions. They feel, however, that they cannot honour their obligations unless the government reviews the eco-contribution regime as, otherwise, they will end up paying twice for the same responsibilities: a payment through eco-contribution and another one through financing the take-back.

There is also a need for legislation regulating noise pollution. EU legislation on the matter (the environmental noise directive) deals only with traffic/transport-generated noise and substantial parts of it are not applicable to Malta. As the EU does not deal sufficiently with the matter, Malta has to date considered it safe to conveniently ignore the need for noise pollution legislation completely. In a densely populated community this issue is of the utmost importance, yet, successive governments have not been bothered.

These examples (water, waste, noise) just scratch the surface of the deficiencies of the environmental set-up, an area which has been continuously muzzled, sidelined, ignored and deprived of resources. It is this attitude which has to change.

The environmental policy this country needs is one which enables its government to be clear and consistent. Declarations on their own are not sufficient as commitment has been continuously absent. If the government really wants to translate its declarations into action it will take much more than an environmental policy to Green Cinderella.

The Politics of Waste


by Carmel Cacopardo

pubished September 26, 2009



The Italian Mafia eco threat through the sinking in the Mediterranean of at least 42 ships laden with toxic and nuclear waste has far-reaching implications. The real impact, however, will not be clear for some time until all relative details are known.

Last week, the announcement was made of a settlement relative to the dispute that arose after the dumping in 2006 of some 500 tonnes of toxic waste around Abidjan, the capital city of Ivory Coast. This settlement was denounced by both the association of the victims (31,000 residents of Abidjan) and by the international NGO Greenpeace that described it as an exploitation of African poverty.

Going through e-mails published by Greenpeace in the UK newspaper The Guardian last week, it is clear that at one point the toxic waste that ended up at Abidjan was to be processed at the fuel terminal of La Skhira, Tunisia. It appears however that the Tunisian management asked too many questions after examining a sample of the toxic waste such that other destinations were considered more appropriate!

Within this context it would be reasonable to consider what is being done locally with the toxic waste generated on these islands. I will limit myself to the discarding of electric and electronic equipment in Malta, a source of toxic waste. This is regulated by the provisions of the Waste (from) Electric and Electronic Equipment Directive of the EU. Known as the WEEE Directive, it has been transposed into Maltese law through Legal Notice 63 of 2007, yet, to date, it is not being implemented.

On the basis of the producer responsibility principle, producers of the electrical and electronic equipment placed on the Maltese market, as well as their representatives, are responsible in terms of the WEEE Directive for taking back obsolete/discarded equipment. In the long term this would mean that the design of the equipment is improved thereby facilitating repair, possible upgrading, reuse, disassembly and recycling and, consequently, cut the costs of disposal.

Taking back obsolete/discarded equipment involves a cost. Producers and their representatives are objecting because the government is forcing them to pay twice over for the waste they generate. Since 2004, on the basis of the polluter-pays principle, the government is already charging an eco contribution, which was specifically designed to pay for waste management costs. Subsequently, as a result of the transposition of the WEEE Directive, the responsibility for the managing of WEEE waste was hived off to the private sector. However, the government is still collecting the eco contribution while the private sector is expected to foot the bill for taking back obsolete/discarded electric and electronic equipment.

The government is collecting payment to make good for responsibilities it no longer shoulders. While it has a new role, as a regulator, through WasteServe it still insists on direct involvement. One would have expected this attitude from a government that advocates state intervention but not from one that is prolific on rhetoric relative to the pivotal role of the private sector.

The government’s attitude is impeding the private sector from developing a service, responsibility for which has been specifically assigned to it by EU legislation. This has been going on for the past 30 months and, as a result, most of the waste generated during this time by items listed in the WEEE Directive is unaccounted for.

The WEEE Directive is applicable to: household appliances (small and large), IT and telecommunications equipment, consumer equipment, lightning equipment, electrical and electronic tools, toys, leisure and sports equipment, medical devices, monitoring and control instruments and automatic dispensers.

Consumers are entitled to return to a supplier any obsolete/discarded item to which the WEEE Directive applies. The supplier, on behalf of the producer, will then ensure that the item is reconditioned, recycled or else stripped into its component parts, which can then be reused as raw materials or else appropriately disposed of. This obviously involves an expense that suppliers are entitled to recover by charging the consumer the real cost of waste management. Consumers are, however, already being charged an eco contribution, this being a waste management fee for costs that are not incurred anymore.

Late last year, the EU embarked on a revision of the WEEE Directive. Through this revision the EU aims to fine-tune the provisions of the directive such that it is more effective. In Malta, having not yet initiated implementation of the WEEE Directive, we are in the ridiculous situation of having a government that proclaims it is environment friendly but then whenever possible goes out of its way to torpedo the implementation of the environmental acqui.

It is the importers who are now directly responsible for implementing the provisions of the WEEE Directive. However, this does not exonerate the government whose double charging for WEEE waste is clearly the sole reason for WEEE’s non-implementation in Malta.

WEEE Responsibility


published on 23 May 2009

by Carmel Cacopardo



The Nationalist Party’s and Alternattiva Demokratika’s 2008 electoral manifestos proposed the free distribution of energy-saving light bulbs in order to encourage energy conservation but with a difference!

Prior to that, in London, the then Labour mayor Ken Livingstone had, as part of the London Climate Change Action Plan in January 2008, launched a “light bulb amnesty” as a result of which each London household could exchange a traditional incandescent light bulb for an energy-e fficient one.

The public in Malta should be informed not only of the benefits but also as to the advisable precautions relative to the use of these energy-saving light bulbs or compact fluorescent lamps (CFLs).

The use of CFLs, notwithstanding their price, saves about 75 per cent of electrical energy used for lighting purposes by traditional bulbs.

An educational campaign relative to breakages and disposal of CFLs is essential.

Damage to the CFL can release mercury dust to air. In other countries users have been advised that they are to vacate and ventilate rooms for about 15 minutes when CFL breakages occur. This is essential to avoid inhaling mercury dust. It is imperative that in homes and, in particular, in areas where children and the elderly and/or sick people gather, those in charge are aware as to the measures they should take. Advice is also called for as to the cleaning of the resulting breakages and the manner in which the damaged CFL is to be disposed of.

It is to be borne in mind that, due to their containing about four milligrams of mercury dust per light bulb, CFLs are subject to the provisions of the EU WEEE Directive (Waste from Electric and Electronic Equipment). This directive has been transposed into Maltese legislation through Legal Notice 63 of 2007 but it is not yet being implemented.

The EU established the framework for dealing with hazardous waste resulting from electric and electronic equipment and applied thereto the principle of producer responsibility. This means that producers and distributors (irrespective of the selling technique used) are directly responsible for the handling of this type of waste.

The government has the role of a regulator, ensuring that EU legislation is adhered to within Maltese territory. Being an EU member in my view, at least, signifies this much in addition to harping on the availability of EU funds, which assist us in attaining objectives of a better quality of life. The WEEE Directive had to be implemented in various stages between 2004 and 2006 and the Maltese government was in breach of its provisions, so much so that the EU Commission had already initiated infringement procedures against Malta due to the delay in transposing it into Maltese law.

The recently-published update to the Maltese Waste Management Strategy for public consultation postponed once more consideration of the plans for the implementation of the WEEE Directive in Malta.

Within this context, the placing of over one million CFLs in one go on the market without having in place a waste management strategy for hazardous waste is surely not environmentally responsible. While addressing the issue of energy consumption, the government is creating an equally serious problem by encouraging the use of hazardous materials without having first ensured that the required waste management infrastructure is in place and functioning.

The responsibility is not just the government’s. It has to be equally shouldered by producers and distributors who, unless they act fast, may eventually have to carry the can and pay the fines due for not assuming their producer responsibilities. Taxpayers’ monies should not be used to bail out those who have failed to shoulder their responsibilities.

Those who have advised local distributors that the management of hazardous waste is a government responsibility would do well to reconsider their position. This is an area the EU has assigned to the private sector, which must ensure that the impacts of all products it places on the market are addressed. In fact, the WEEE Directive, in addition to responsibility for today’s hazardous waste, also assigns to producers and distributors responsibility for historical waste, that is responsibility for WEEE waste generated prior to the implementation of the directive.

The point at issue is clearly the eco contribution payable on a number of electric and electronic products. Maltese business is correct in complaining that it has been shouldered with a double responsibility: responsibility for WEEE waste and simultaneous payment of eco contribution. This, however, does not exonerate businesses from putting in place a collection system for WEEE waste (including CFLs).

By failing to revisit the eco contribution regime, the government is obstructing business from moving on to shoulder its producer responsibilities. Further procrastination will not make matters any easier. It is in everybody’s interest that business conforms to its WEEE responsibilities and for that to happen the government must get out of the way.

Strateġija nejja

 l-orizzontippubblikat it-Tlieta 14 t’April 2009

minn Carmel Cacopardo



Id-dokument li ppubblika l-Gvern li permezz tiegħu jipproponi li jaġġorna l-istrateġija dwar l-iskart jippre­żenta proposta nejja. Hi nejja għax filwaqt li fiha ingredjenti tajbin ma tasalx biex tfassal triq addattata biex l-iskart li niġġe­neraw fid-djar tagħna jonqos.

Il-proposta tqiegħed l-inċi­nerazzjoni fiċ-ċentru tal-ħidma biex ikun immaniġġjat l-iskart. Dan fil-fehma tiegħi hu żbaljat. Żbaljat mhux għax l-inċineraz­zjoni għandha tkun imwarrba. Xejn minn dan. Imma żbaljat għax biex l-inċinerazzjoni tkun għodda addattata trid tinkwadra ruħha fi strateġija li tagħti pri­jorità lil dik l-għodda ambjentali u fiskali li jħajru n-nies inaqqsu l-iskart li jipproduċu.


L-ewwel pass f’din it-triq kellu jkun li jkun eżaminat bir-reqqa minn x’hiex huwa magħmul l-iskart iġġenerat fid-djar. Id-dokument ippubblikat mill-Gvern ma jagħmel l-ebda referenza għal dan. Fil-fatt fir-rapport imħejji mill-Awstrijaċi dwar l-inċinerazzjoni, intitolat “Waste to Energy in Malta – Sce²nar²i²os for Implementation”, jirreferu għal stħarriġ li sar fl-1989 minn Vince Gauci, u studju ieħor tal-Uffiċċju Nazzjonali tal-Istatistika ta’ Mal²ta fl-2003. Ma jidher li hemm l-ebda informaz­zjoni iktar riċenti.

It-tip ta’ skart li niġġeneraw jinbidel biż-żmien skond l-użanzi li naddottaw u l-mod kif ngħixu. Pereżempju l-ammont ta’ plastik iġġenerat fl-iskart jidher li qiegħed jikber kontin­wament u wieħed mill-kontri­buturi għal dan hi d-dipendenza tagħna dejjem tiżdied fuq ikel ippakkjat fil-plastik. Dan huwa riżultat mhux biss tal-ħajja dej­jem iktar mgħaġġla imma ukoll tar-rwol dejjem jikber tas-supermarkets il-kbar fil-kummerċ ta’ oġġetti tal-ikel.

Ir-riċerka biex issostni l-aġġornament tal-politika dwar l-iskart f’Malta hi neċessarja, iżda hi nieqsa. Kif tista’ tfassal politika li twieġeb għall-ħtiġijiet tal-lum jekk il-qagħda attwali m’hix imkejla b’mod adekwat u frekwenti? F’pajjiżi oħra dan isir b’mod regolari u jindunaw b’dan il-mod b’affarijiet li jkunu qed jinbidlu minn kmieni b’mod li jkunu jistgħu jilqgħu għalihom.

Fir-Renju Unit kmieni fix-xahar ta’ Frar 2009, ġie ppub­blikat rapport mill-Local Government Association Ingliża, intitolat “War on Waste: Food Packaging Study Wave 3”. F’dan ir-rapport żie eżaminat is-sehem tas-Supermarket Chains kollha fl-Ingilterra għall-ġenerazzjoni tal-iskart. Wieħed mis-suġġe­rimenti li joħroġ minn riflessjoni dwar dan l-istudju huwa jekk l-ippakkjar tal-ikel, tant meħtieġ minħabba l-iġjene, ikunx iktar għaqli li jsir fi plastik biode­gradabbli. Plastik ta’ dan it-tip imbagħad ma jkollux bżonn ta’ inċineratur iżda jkun jista’ jiġi pproċessat flimkien mal-iskart organiku l-ieħor.

Jidher li l-Gvern f’Malta għad ma eżaminax din il-materja. Il-grupp ta’ strateġija dwar l-iskart lanqas biss jidher li xamm ir-relevanza tagħha għall-aġġorna­ment tal-istrateġija!


Tajjeb li nistaqsu fejn irridu naslu? Hemm diversi miri li rridu nilħqu. Fuq quddiem nett għandna nimmiraw biex l-iskart jonqos. Qed issir ħafna ħidma biex l-iskart li jintrema jonqos, u l-frott dwar din il-ħidma qed jinkiseb bil-mod bl-għarfien dejjem iktar tan-nies tal-ħtieġa li nirriċiklaw. Imma li nirriċiklaw għalkemm huwa tajjeb mhuwiex biżżejjed.

Meta s-supermarkets joffru prezzijiet irħas dan jagħmluh għal diversi raġunijiet. Jixtru bil-kwantità u jagħfsu lill-pro­dutturi għall-prezzijiet orħos, kif ukoll inaqqsu kemm jifilħu x-xogħol bl-idejn. Meta jsir dan jonqsu konsiderevolment l-ispejjeż tagħhom. Huwa komdu ħafna li tieħu pakkett minn fuq l-ixkaffa jew mill-freezer tas-su²per²mar²ket u dritt għal ġot-‘trol²ley’ mingħajr ħtieġa ta’ kju biex jintiżen il-ġobon jew il-perżut! Parti mill-ispejjeż li s-supermarket jiffranka tispiċċa ġġorrhom is-sistema tal-immaniġġjar tal-iskart għax jiġi iġġenerat iktar skart tal-plastik. Dan nistgħu nevitawh b’żewġ modi. Fejn dan hu possibli nistgħu nużaw inqas plastik li jiġġenera l-ikel ippak­kjat billi nixtru iktar ikel frisk. Apparti li huwa iktar sustanzjuż jikkontribwixxi ukoll kemm għall-ġenerazzjoni ta’ inqas skart, kif ukoll biex tissaħħaħ l-industrija agrikola f’Malta.

Il-Gvern iżda jista’ jinsisti li l-ippakkjar jibda jsir fi plastik biodegradabbli. Hemm diversi miżuri li jista’ jieħu biex dan isir. Għax mhux sewwa li biex tas-supermarkets ikunu kompe­tittivi jitfgħu l-piż fuq is-servizzi pubbliċi li jridu jerfgħu piż addizzjonali ta’ skart iġġenerat li qiegħed dejjem jikber.

L-istrateġija aġġornata dan kollu ma tikkunsidrahx.

Skart elettriku u elettroniku

L-aġġornament tal-istrateġija tipposponi li tħares lejn l-iskart elettriku u elettroniku. Din hi materja li bħala pajjiż għandna obbligi x’nimplimentaw kif jirriżulta mid-Direttiva tal-Unjoni Ewropeja WEEE (Waste from Electric and Electronic Equipment). Id-Direttiva WEEE titfa’ l-obbligu biex apparat elettriku jew elettroniku li spiċċa l-użu tiegħu jinġabar minn min jipproduċih jew l-aġenti tiegħu. Għalkemm l-avviż legali dwar dan ġie ppubblikat żmien ilu għad hawn ħafna tkaxkir tas-saqajn biex din id-direttiva tkun implimentata. Ir-raġuni għal dan hi ċara. Fil-waqt li l-Unjoni Ew­ropeja a bażi tal-prinċipju ta’ ‘pro­ducer responsibility’ tinsisti li min jipproduċi dan l-apparat għandu jerfa’ r-responsabbiltà kollha għall-iskart li jiġġenera, fl-istess ħin permezz tal-Liġi dwar l-Eko-Kontribuzzjoni, il-Gvern assuma din il-funzjoni huwa minflok is-settur privat. Għal dan l-iskop qed jiġbor l-eko-kontribuzzjoni biex jagħmel tajjeb għall-ispejjeż. Fil-mument li d-Direttiva WEEE tkun implimentata parti mill-Liġi tal-Eko-Kontribuzzjoni jkollha tispiċċa jew tkun riveduta minħabba li min ibiegħ inkella jkun suġġett għal spiża doppja – l-eko-kontribuzzjoni u l-ispiża biex jiġbor u jipproċessa l-iskart elettriku u elettroniku. Jidher li l-Gvern s’issa ma sabx soluz­zjo­ni. Allura jipposponi.

Sadanittant dan l-iskart m’hu­wiex se joqgħod jistenna li l-Gvern jiddeċiedi x’se jagħmel. Min irid jibdel friġġ jew televixin xorta “jeħles” mill-friġġ jew mit-televixin il-qadim. Uħud mill-friġġijiet il-qodma qed jinġabru bis-sistema tal-iskart goff im­ħaddma mill-kunsilli lokali. Oħrajn qed jinġabru minn tal-ħanut li jbiegħu friġġ ġdida. Imma bosta oħra qed isibu ruħhom fl-iscrapyards imxerrda mad-diversi partijiet ta’ Malta. Dawn l-iscrapyards li jekk organizzati sewwa jistgħu jkunu ta’ ġid u kontribut fl-istrateġija dwar l-iskart ma jissemmew imkien fid-dokument li l-Gvern ippubblika għad-diskussjoni!


L-istrateġija tiffoka fuq il-ġenerazzjoni tal-elettriku mill-iskart. Dan fih innifsu hu tajjeb. Imma kif tfassal l-aġġornament tal-istrateġija ma jagħti l-ebda importanza lill-istampa kollha. Qed tingħata l-impressjoni li billi jinħaraq parti mill-iskart se nsolvu ħafna problemi. Veru li se nnaqqsu r-rata li biha timtela l-miżbla. Veru ukoll li se niġġe­neraw madwar 3% tal-elettriku minn sorsi li kieku kienu jintre­mew. Dan hu tajjeb. Imma meta tiffoka b’daqstant qawwa fuq l-inċinerazzjoni bħala soluz­zjoni qiegħed jingħata l-messaġġ żbaljat li m’għadux iktar impor­tanti li nindirizzaw iżjed ħeġġa u inizjattivi biex jonqos il-ġene­razzjoni tal-iskart. Dan hu l-mes­saġġ li joħroġ meta d-dokument ippubblikat jonqos milli jittratta u jaġġorna l-mod kif nistgħu nnaq­qsu l-ġenerazzjoni tal-iskart.

Il-messaġġ joħroġ iktar ċar meta jissemmew pajjiżi oħra bħala prova li l-inċinerazzjoni tista’ ssir b’suċċess. Ma jingħadx imma li uħud minn dawn il-pajjiżi għandhom suċċessi kbar fil-mod kif jindirizzaw l-iskart: kemm jipprovaw inaqqsu l-ammont iġġenerat kif ukoll jir­nexxilhom jirriċiklaw ħafna iktar skart milli wasalna għalih aħna bħala pajjiż. Xhieda ta’ dan hi l-istatistika komparattiva dwar l-iskart fl-Unjoni Ewropeja ippub­blikata riċentement.

L-istrateġija għandha tinħema iktar. Irid ikun ċar li l-prijorità tal-ħidma għandha tkun li l-iskart iġġenerat jonqos. Imma dan għandu jirrifletti ruħu f’inizjattivi li jwasslu biex din il-prijorità titwettaq.

Għalhekk il-proposta hi nejja għax teħtieġ ħafna iktar ħsieb. Jekk min ħa ħsieb ifassal l-aġ­ġornament tal-istrateġija dwar l-iskart ikun irid, m’għandi l-ebda dubju li bosta huma dawk li lesti jagħtu kontribut. Għax fuq l-iskop qed naqblu. Li jonqos hu li flimkien infasslu t-triq li biha nistgħu naslu.

Waste update : back to the drawing board


by Carmel Cacopardo

published on Saturday February 28, 2009


The Solid Waste Management Strategy update published recently, identifies a zero waste scenario as a long-term aim. It refers to a number of studies commissioned and proceeds to a selective use of conclusions from the said studies, which are still under wraps.

A Situation Audit of the strategy was carried out in 2005. Yet, the only conclusion that has found its way into the proposed update is a statement on the practical non-existence of the interministerial committee set up to coordinate the strategy’s implementation across government. The full Situation Audit should see the light of day. The public has the right to be informed as to the manner in which targets were attained and the reasons as to why others were missed.

The update is incomplete; it postpones updating the strategy on hazardous waste, promising instead a Topic Paper in the future. The management of hazardous waste includes the implementation of the WEEE Directive (Waste from Electric and Electronic Equipment), which is way behind schedule.

Producers and their representatives in terms of the WEEE Directive assume full responsibility for the waste generated by their products. Yet, the government, through the simultaneous application of the eco-contribution and the WEEE Directive, has placed them in a situation where they have to pay twice for the handling of electric and electronic waste: The payment of an eco-contribution and shouldering producer responsibility in terms of EU legislation. The result is that while, on paper, the WEEE Directive in Malta has been transposed, in practice its implementation is being obstructed. It is an area of responsibility that EU legislation assigns specifically to the private sector, yet the government is reluctant to lose a substantial chunk of eco-contribution revenues and is consequently applying the brakes.

The regulation of scrap yards does not feature in the update. They are required in order to recycle scrap metal. However, they should operate within a regulatory framework, in particular in conformity to the WEEE and the ELV (End of Life Vehicle) Directives. Recently, it was reported that, during testimony submitted in a planning appeal, concerning the enforcement order relative to the Ta’ Brolli scrap yard in Birzebbuga, it was revealed that part of its business originates from the custom of government departments and corporations!

Some scrap yards process scrap from disused refrigerators! Processing? They just crush them, as a result releasing refrigeration gases to air. These gases are CFCs (chloroflorocarbons), contributors to the depletion of the ozone layer. In a regulated environment in terms of the WEEE Directive, processing disused refrigerators for waste would include the careful collection of the CFCs as a first step. Instead, some Maltese scrap yards are contributing to the depletion of the ozone layer in contrast to the provisions of the 1987 Montreal Protocol, which Malta has bound itself to observe and implement.

The proposal for an updated strategy encourages a policy favouring waste incineration. It proposes that the use of bio-digestion to convert waste to energy is complemented by a policy favouring incineration. Specifically, it proposes a waste to energy incinerator to be sited at Delimara next to the power station. This could also mean that on waste recovery sites (currently in operation or projected) the two technologies could co-exist.

Incineration is undoubtedly a waste management tool. In my opinion, it should however, only be used as the last option.

Relying on incineration to produce electricity would, on the plus side, reduce required landfill space and the fuel bill. It would still, however, contribute to the production of greenhouse gases and, hence, cannot be described as a source of clean energy. On the minus side, it negates the need to reduce waste generation and produces other possibly toxic emissions, which would vary dependent on the composition of the RDF (refuse derived fuel).

The regulation of these emissions is normally established through a permit issued by Mepa in terms of the EU Directive on Integrated Pollution Prevention and Control. The acceptability or otherwise of an incineration facility even as a tool of the last resort would in my view result from two points: The quality of emissions control imposed by Mepa through the conditions established in the IPPC permit, and the enforceability of these conditions.

If the manner in which the Marsa incinerator has operated in the past months is a reliable indicator on the workings of Mepa and Wasteserv, this is sufficient on its own to discard the incinerator option even as a tool of last resort.

These are just a few of the points indicating reasons as to why the proposed waste strategy update needs to go back to the drawing board. Together with the fact that a Strategic Environmental Assessment has not to date been carried out, this is clear evidence of its poor quality. Such a document cannot lead to a fruitful public discussion.