SAO: an ill-considered and expensive bio-waste management system is being developed in Latvia with a delay now


Is an efficient and economically sound bio-waste management system being developed in Latvia, and will its implementation take place within the set deadline? Unfortunately, the audit results clearly show that no. The currently developed system does not correspond to the situation in our country, for example, in terms of the total population and population density. The introduction of the system has been delayed significantly due to the chaotic implementation, lack of coordinated management and cooperation with all stakeholders. If the system is implemented only formally, then, first of all, the population will not be motivated and will not sort biodegradable waste to the extent needed for the capacity of the planned infrastructure. Secondly, people will overpay for bio-waste management. Thirdly, sanctions are possible, which means losses to the Republic of Latvia if the environmental goals set by the European Union are not achieved in time. Therefore, the State Audit Office calls for a complete review of the chosen approach to the introduction and development of the system and for finding the most appropriate solutions by making more efficient use of the available financial resources and infrastructure.


  • Latvia’s currently developed biological waste (bio-waste) management system is not proportionate, efficient, and economically justified.
  • Without a “restart” of the bio-waste management system, there will be no motivation to sort it, people will overpay, and losses to the state cannot be ruled out.
  • According to international experience, it is impossible to set up a separate bio-waste collection system without the active involvement of the population.

“Waste management in Europe, including Latvia, does not already belong to the group of services free-of-charge, and the price of waste management fees is expected to increase in the future. Households are already experiencing rising costs for many everyday consumer goods and services. Unfortunately, by not establishing an effective bio-waste management system in Latvia and by not using its opportunities to earn income from recycled waste, we run the risk of placing another expensive burden on the shoulders of the population, that is, for the maintenance of this system. Suppose the current approach is not “restarted”. In that case, the proposed system will be very costly for the government and unfriendly to the population. Potential EU sanctions may have a negative impact on the state budget if the system is not introduced in time,” explained Edgars Korčagins, Member of the Council of the State Audit Office. He has also indicated, “The financial burden correlates directly with the behaviour of the population participating in separate waste collection systems, separating non-paid waste from the total waste stream reduces the amount of waste subject to payment. This is how the principle of the ‘polluter pays’ works.”

The identified risks allow predicting that the bio-waste recycling system will not be implemented in time; sanctions must be taken into account

Between 2010 and 2018, total waste in the EU increased by 5% (114 million tonnes). A Directive of the European Parliament and of the Council stipulates that the proportion of municipal waste (MW) disposed of in landfills must be reduced to 10% of total municipal waste by 2035. About half of the municipal waste is bio-waste. To meet the target, an operational, efficient, and environmentally sound system of separate bio-waste collection and recycling must be in place by the end of 2023.

Unfortunately, the introduction of the separate bio-waste collection system in Latvia is developing very slowly. The infrastructure required for the bio-waste processing is only planned to be completed by the end of 2023. The audit has identified significant risks that allow us to predict that the effective bio-waste management system throughout the country will not be established within the set timeframe. The goals set in the Directive will not be achieved, which means that Latvia may be subject to EU sanctions. The minimum amount of the lump sum fine is 392,000 euros. Still, the penalty may be higher depending on the gravity and duration of the infringement, with the maximum amount of sanctions of 11,56,120 euros per year until the infringement is remedied.

In addition, the State Audit Office has estimated that without the introduction of the separate bio-waste collection and recycling system in the entire territory of the country already in 2021-2023, the population of Latvia does not receive potential savings of at least 16,576,830 euros, including in the Greater Riga Waste Management Region (WMR), 6,430,910 euros and 10,145,920  euros in other regions. Given the planned increase in the natural resources tax on waste disposal in 2022 and 2023, the unearned savings for the population may be even higher than estimated.

The paradox of the system: expensive bio-waste recycling facilities are created even though separately collected bio-waste is not available, and post-recycling materials may not be used

In Latvia, only the middle stage of the system (collection and recycling) is currently being implemented. The chosen solutions are expensive and applied equally in densely populated areas and in the areas with significantly smaller populations. In its turn, introducing the initial and final stages of the system leaves much to be desired currently.

A significant risk to the unjustified increase in bio-waste management fees is caused by the fact that the construction of substantial and expensive bio-waste anaerobic digestion facilities was started in six municipal landfills worth 90 million euros with the co-financing of the EU in the programming period 2013-2020 whose total bio-waste processing capacity would exceed the needs of Latvia. According to the State Audit Office estimates, with the construction of these facilities, the full available bio-waste processing capacity in Latvia will then reach 380,443 tons per year, including the processing capacity available at composting sites and biogas plants. In all WMRs (except for the Central Latvian WMR), the planned total bio-waste recycling capacity will be approximately 2 - 2.5 times higher than households’ forecasted maximum amount of bio-waste. The reason for this may be the data quality problem mentioned in almost every Latvian-wide waste management study and is still relevant. For making informed decisions, including investments and the capacities of infrastructure facilities, no reliable data on the quantities of bio-waste generated in the state and municipal administrative territories is available.

The costliness of the bio-waste recycling system is largely determined by the fact that the introduction of the system mainly focuses on anaerobic bio-waste recycling in Latvia, without popularising the use or introduction of other, partially already existing alternatives, such as the promotion of composting at home, the use and/or adaptation of existing bio-waste recycling infrastructure like composting sites and biogas stations for bio-waste recycling.

An important factor that would reduce the maintenance costs of the bio-waste recycling system is the further use of the final recycling product, including sales. However, there is still no legal framework for determining the final status of bio-waste in Latvia, which would allow the efficient and safe use of compost and/or digestate obtained from bio-waste. There is also no quality system for compost introduced, as is the case in most EU Member States. Thus, it is impossible to reduce bio-waste management costs by receiving revenue from selling the products resulting from bio-waste recycling.

It has resulted in a paradoxical situation when a system is being created in Latvia where bio-waste will be recycled expensively. Still, there is no recyclable waste and no place to use the valuable materials obtained from recycling in reality.

Fundamental policy implementation problem: the system is developed without centralisation and effective coordination

Several reasons have contributed to the situation we are in now. Firstly, the overall coordination of public policy is not effective; the action of the policy-maker, the Ministry of Environmental Protection and Regional Development (MEPRD), is limited to the incomplete development of binding legislation and only partial monitoring of the situation, leaving the development of the separate bio-waste collection system largely to each local and regional government. In addition, the situation of local and regional governments as policy implementers is complicated by the fact that no specific goals and tasks have been set for the implementation of the system at the national level; no specific quantitative or qualitative indicators have been stipulated to ensure that the system is both formally implemented in local and regional governments. It operates economically and efficiently by balancing environmental targets, demand, supply, and costs.

Implementing separate bio-waste collection and recycling systems has not been planned and coordinated with all parties involved. Although the National Waste Management Plan 2014-2020 provided actions to implement the separate bio-waste collection and recycling system, most WMRs did not develop plans at the regional level that would cascade the targets set in the national plan sequentially. Moreover, the targets set in the national development-planning documents, which were not met in the previous programming period, were carried over to the new programming period without assessment, without setting performance indicators or providing local and regional governments with greater clarity on the introduction of the bio-waste management system.

It is impossible to set up a separate bio-waste collection system without the active involvement of the population

According to international experience, it is impossible to set up a separate bio-waste collection system without the active involvement of the population. Raising awareness of Latvia’s population about the importance of waste sorting has not been sufficient, despite the initiatives taken by public organisations and green living enthusiasts. Local and regional governments and their institutions have also been reluctant to demonstrate the separate bio-waste collection by their example, for instance, in institutions with catering establishments (educational institutions, etc.), and they have not organised and supported communities’ initiatives. Until now, house managers, who are the closest stage of the bio-waste management system to the population, have been insufficiently motivated and involved in raising public awareness about waste sorting.

“Public involvement is not always limited to producing information leaflets or advertisements, but also proactive action, such as offering citizens free containers for the separate bio-waste collection, thus promoting public awareness and involvement. Contrary to the experience of other countries, there are no clearly defined tasks for public awareness-raising activities in Latvia, and their effectiveness is not assessed. Unfortunately, as a result, Latvia has so far failed to create an understanding of the need, opportunities and benefits of separate bio-waste collection,” pointed out E. Korčagins.

Although “the horse almost left the barn”, costs can still be reduced

The auditors of the State Audit Office stress that the amount of investment required to establish and maintain the system in Latvia was and still can be reduced in several ways:

  • The EU practice shows that the separate bio-waste collection system is not always set as mandatory throughout the country, but only in some municipalities. For example, decisions are made about more cost-effective solutions when considering the specific situation and possible solutions elsewhere. For instance, in Hungary, separate local/ regional initiatives have been launched for the separate bio-waste collection without introducing such a system at the national level.
  • System costs can be reduced by using pre-existing bio-waste recycling infrastructure, such as biogas plants and by introducing alternative uses of bio-waste apart from anaerobic digestion where possible.
  • An essential factor that allows for reducing the system maintenance costs is the further use of the final product of processing, including sales. This requires a legal framework to determine the final status of bio-waste, which would allow the efficient and safe use of compost and/or digestate from bio-waste. One must also introduce a compost quality system, as it has been done in most EU Member States. In this way, the product obtained from bio-waste recycling could be commercialised, and the bio-waste management costs could be reduced from the revenue generated through the sale of processed products.

#AfterAudit, there are 15 recommendations provided to the MEPRD and local and regional governments to immediately introduce an efficient and economically sound bio-waste management system and create a common understanding of the responsibilities and requirements of the system participants throughout Latvia. The deadline for implementing the State Audit Office recommendations for local and regional governments is 2022, and for the MEPRD 2023.


  • At present, the majority (between 30% and 60%) of bio-waste goes to unsorted (mixed) municipal waste (UMW), from which it is no longer possible to completely separate it technologically, although sorting facilities are installed in municipal landfills (MWL). The mechanically separated bio-waste fraction contains many unwanted impurities (such as glass and plastic). Bio-waste reduces the opportunities for sorting and reuse of other UMW.
  • The amount of bio-waste per capita varies significantly across the EU, from 75 kg per capita in Hungary to 375 kg per capita in Denmark (the EU average is 175 kg per capita). The share of bio-waste in municipal waste (MW) also varies: from 17% in Hungary to 48% in Spain. The amount and proportion of bio-waste generated depend on various factors, including data collection and reporting methodologies, level of urbanisation, the existence of a separate waste collection system, the prevalence of composting at home, climatic conditions, etc.
  • Waste generators, including residents, pay for the collection of unsorted waste and are interested in reducing its volume by lowering the cost of waste management; a separate collection of bio-waste minimises the amount of UMW.
  • Setting up a separate collection is crucial to provide bio-waste without significant impurities.

Additional materials

  • Audit report | Infographics | Recommendation implementation timeframe (7) #AfterAudit

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