In April, the International Renaissance Foundation’s Environmental Initiative held another discussion with experts dealing with environmental issues in Ukraine. The topic of the conversation was the reform of the waste management system, which was launched in Ukraine in 2023.
The waste management system is a large set of measures, programs, and legislation aimed at building a systematic approach to managing all types of waste. This includes household waste, construction and industrial waste, and, in the new Ukrainian reality, demolition waste. It is not only about recycling or disposal of waste but also about the collection, transportation, treatment, and supervision of these processes and infrastructure facilities.
Until 2023, this system was regulated in Ukraine by outdated standards and practices, some of which we inherited from the Soviet Union. The system’s reform is focused on European standards and principles of the circular economy.
The work on the changes began long before 2023 and was carried out, in particular, by activists and environmental organizations, including the partners of the Environmental Initiative of the Foundation. It was expected that the reform would move quickly and that Ukraine would soon reach a decent level of waste management. However, due to the full-scale invasion of Russia, the state’s interest in financing circular economy technologies that would keep pace with the current level of consumption is far from being at the top of the list. Many of the challenges fall on the shoulders of local communities, which lack both infrastructure and expertise.
At what stage is the reform, and why is it necessary? What needs to be done at the community level to make its results more tangible for residents? These questions were raised during the discussion “Waste Management Programmes: What’s Up and What’s the Status of the Reform,” which was held with the support of Sweden, together with the NGO Zero Waste Lviv, and with the media support of the platform “Your City.” The conversation was moderated by Oksana Dashchakivska, manager of our Foundation. You can watch the discussion recording on the event’s Facebook page.
Why do we need the reform now?
Some may think that waste management reform during a major war is a wasteful and inappropriate use of public resources. But we at the International Renaissance Foundation are convinced that the changes that the reform will bring are needed by the country and its people right now, especially at the level of local communities. After all, when we talk about waste, we mean not only plastic, glass, or other household waste but also all the waste from the destruction caused by Russian aggression and all the construction waste necessary to rebuild cities.
But this is not the only reason why the reform is timely. Iryna Myronova, executive director of Zero Waste Lviv, said that waste management is as essential a public utility as water, electricity, or heat.
“In Lviv, we know what happens to the city if you don’t collect garbage for a week. Today, the issue of household waste is important for many communities in Ukraine, as the population has changed due to the war. However, waste management was inadequate even before the war. Reform in this area is necessary not only because of European integration but also to improve environmental standards in cities,” she says.
Expert support from Sweden
Sweden is a recognized global leader in waste management. Only about 3% of the waste generated in Sweden ends up in landfills. The rest is recycled, incinerated, or reused. Sweden, like the rest of the EU, applies a 5-pillar approach to waste management – five life stages of waste, at each of which the authorities, activists, and citizens try to reduce waste: prevention, reuse, recycling, incineration, and disposal.
In preparation for EU accession and waste management reform, Ukraine will try to implement the same model. Sweden promised to help us on this path through a joint program. Weine Wiqist, an employee of Avfall Sverige (Swedish Waste Management), a lecturer at Lund University, and the International Industrial Institute of Environmental Economics (IIIEE) in Sweden, will provide strong expert support in implementing the program. In his opinion, there are several factors for successful waste management: setting a clear goal at the state level, cooperation of large and small players (including large and small communities), and political sustainability in working towards this goal. The Swedish waste management model has four pillars: extended producer responsibility, circular economy, decentralization, and separate collection. Sweden will help Ukraine implement these and other best practices.
What is the state of affairs in the legal framework?
Reform is a significant legislative process. For systemic changes to occur, new standards must be regulated at the legislative level. Thanks to the efforts of civil society activists, experts, managers, officials, and international assistance, the fundamental law on waste management has been adopted. However, its functioning requires the development of several documents and laws that would enable the reform.
Yevheniia Popovych, Director of the Department of Digital Transformation, Electronic Public Services and Waste Management at the Ministry of Environmental Protection and Natural Resources, notes that during the active phase of the reform when we cannot use state budget funds, the Ministry engages international technical assistance.
“We help develop regional plans, feasibility studies, environmental impact, and strategic environmental assessments. Our job is to prepare a full package of documents and promote them to the region to attract international investors who agree to build plants. We are currently working on this in five regions and plan to expand this activity to other regions,” she says.
She noted that as of April 2024, the Ministry has already done much work. In particular, it has developed and is finalizing amendments to the Tax Code of Ukraine, which increase the tax on household and mining waste disposal by almost 200 times. “But in some regions of the country, there has been a considerable amount of mining waste for 30, maybe even 60 years. This is an artificial burden on these regions,” says Yevheniia Popovych.
A draft law on normative drafting equipment is also under discussion (the Ministry of Justice is currently approving it). In addition, the draft law on electrical and electronic equipment has been published and discussed with key stakeholders. Verkhovna Rada is presently finalizing the draft law on packaging and packaging waste.
Yevheniia also noted that the Ministry is developing proposals on the liability of manufacturers of batteries, accumulators, tires, and oils, a draft law on the decommissioning of vehicles, including those obtained as a result of hostilities, etc. The Ministry also conducted more than 130 inspections of hazardous waste.
She also noted that already at this stage of the reform, it is necessary to build and develop waste management infrastructure and change the attitudes of citizens: “Our Swedish colleagues emphasize the importance of involving people in understanding the need for change. In countries such as Sweden, Germany, and Austria, waste sorting rates vary. Education is also important: children learn the rules of waste sorting and the risks of environmental pollution through games, which helps to improve their environmental awareness,” says Yevheniia.
What will happen at the community level?
Most of the changes envisaged by the legislative framework of the reform will take place at the level of territorial communities. According to Diana Novikova, Head of the Household Waste Management and Utility Services Division of the Department of Utilities at the Ministry of Community Development, Territories and Infrastructure of Ukraine:
“Community development and living conditions depend on the cooperation of local governments with communities and the organization of the chosen model of household waste management, raising public awareness of the implementation of good practices.”
She also noted that outreach to the public and synchronization of all actions is an integral part of this stage of the reform:
“Based on the data we collect annually from the regional military administrations (except for the southern and eastern regions of Ukraine and the occupied territories, where it is impossible to collect this information), in 2023, more than 10% of household waste was sent to collection points and waste processing plants, and more than 1% was recycled. To be able to calculate all the indicators of preparation for the reuse of household waste, the Ministry has prepared a draft order, which is now being coordinated with other ministries, including the Environment, as a single environmental platform is now being introduced to ensure the interaction of all business entities in the field of waste management, public authorities, and local governments. We are currently reviewing a draft order on state waste accounting. After these orders are adopted, the working platform will be created, and all targets should be achieved synchronously for all types of waste.”
“Seven resolutions of the Cabinet of Ministers have been adopted concerning household waste management, including the rules for providing this service, contracts for waste collection and transportation, the procedure for holding tenders, setting tariffs, and developing programs in this area. The law also approves rules for composting biowaste, a methodology for separate waste collection, and a methodology for calculating and amending utility tariffs.
The law defines the powers of local governments to organize household waste management, develop local waste management plans, strengthen their capacity, and provide all necessary tools for exercising their powers.
The Ministry annually collects information on the practices of implementing separate waste collection, composting, and sorting stations, the only waste incineration plant in Ukraine, Energia, and posts all this on its website,” said Diana Novikova.
What is the vision of hromada reform, and what can be the role of the public?
Each community is unique in dozens of ways. What works well at the level of large cities in western Ukraine may not be possible for towns and villages in the east, especially those close to the fighting. Some communities are better prepared to implement the changes envisaged by the reform, while others do not even have the up-to-date data needed to build a strategy. Often, the work towards the reform was carried out by local activists and civil society organizations. For example, such as the NGO “Nova Druzhkivka”.
Its head, Serhiy Pronkin, explains:
“Even before 2022, Druzhkivka did not have any innovative foreign household waste management practices at the city council level. When we came to work in this sector, I immediately asked the representatives of the executive authority why this was so. I did not get an answer. I found it when I looked at what was happening at the economic level. Druzhkivka produced 12,000 tonnes of household waste, 39% organic. It costs UAH 75 to dispose of one tonne at a landfill in neighboring Kramatorsk. The tariff for household waste collection is very low – it costs less per person per month than a carton of milk. And this is also the question of why no one wants to raise tariffs by providing better services and using modern approaches to waste management,” says Pronkin.
Serhii notes that civil society activists could not fully influence what is happening in the community, as regulations, the economic component, political will, etc, limit their opportunities and powers. He also noted that some communities, even those far from the active combat zone, lack fundamental analyses of the situation:
“When we opened our second office in Kirovohrad Oblast, we started working with small communities like ours. And their situation is about the same, i.e., nothing. During one meeting in 2024, I asked: ‘Do you know the morphology of your garbage? No. In communities with no constant fighting, there is no analytics at the basic level. We need to fight this, to advocate for the situation in each community,” says Serhii Pronkin.
How the waste management administrator system works and saves municipal funds, based on the example of Lviv
The Law on Waste Management singles out communities with more than 500,000 inhabitants. It changes the institutional structure of the relationship between residents and carriers (those who collect waste) and introduces a waste management administrator. Lviv community is one of those where this system is to be implemented. Petro Kinash, Director of the Lviv Municipal Enterprise “Administrator of Household Waste Management Services,” explained how it works at the level of Lviv:
“In 2023, the city identified three priorities for 2024: separate collection, education, and culture in this area, and implementing the new waste management law. To launch a separate collection when the new law comes into force, we need morphology and infrastructure. We need to give people the same tools for sorting and the same bins; otherwise, we cannot expect results. This should be done before the introduction of extended producer responsibility. Thanks to a shared vision with our carriers, the city has been provided with 100% containers for plastic and biowaste and 85% for glass. Separate collection is fully operational in Lviv,” says Petro Kinash.
Lviv is currently at the stage of approving separate waste collection in the city. This provides the basis for the administrator’s work, as it streamlines container sites.
Lviv produces over 200,000 tonnes of waste per year. Petro Kinash noted that this year, thanks to carriers, coordinated work, and the launch of various projects, 7% (15,000 tonnes) of waste was sorted: 3.5% organic and 1.5% each of plastic and glass.
“Landfill disposal is much more expensive, so we saved about UAH 30,000,000 for the community, for the residents,” said Petro Kinash.
But he also noted that during the war, it was challenging to teach people to handle household waste differently than they are used to. Especially older people. Therefore, in his opinion, the effectiveness will only be seen through the training of the younger generation:
“We are actively implementing the program in schools and kindergartens and other educational institutions. We already have 20 schools with full-fledged separate collections and plan to open 50 more this year. Each school has its container site, where waste is sorted, and its efficiency is monitored.”
Mr Kinash also shared other observations on the potential of the changes made:
“We have made a morphology: 44% organic, 17% plastic and 11% glass. That is, the potential for separate collection is more than 70%, and we comply with all legal requirements. This is a mutual responsibility of the city and the community; essential things to drink clean water and breathe fresh air.
There are 24 regulatory documents for the effective implementation of the law on waste management, 15 of which are fully approved, seven are under development, and two are not yet approved. We will work on them within our competence. One of the key and essential documents is the introduction of an administrator. A plant is being built in our city, there is a composting station, and we have five carriers. The market is entirely divided into five approximately equal shares. There are four private companies and one municipal company. The administrator will control the entire market, be able to assess the situation, and introduce one tariff for all. Now, the tariffs for each carrier are different; each has its technical base, salaries, and internal documents.”
Petro Kinash believes that it will be an advantage for the population if the administrator can regulate this, keep records of container sites, and control waste removal. The administrator will introduce the same game rules in the market for everyone, and the best will be determined only by the quality of services provided.
What about small hromadas?
Big cities are, of course, more profitable for haulers to service. A large city produces more waste, so the hauler will potentially earn more. Big cities are also more logistically adapted. For example, Lviv has equipped container sites, a composting station, places for collecting large-sized equipment, and plans to build a site for collecting electronic waste. Smaller cities do not have such infrastructure. However, this point can be considered when planning the changes envisaged by the reform.
This will be facilitated by the fact that the law on waste management provides for four levels of plans – national, regional, local, and individual (for support organizations). Hanna Bashta, Deputy Director of the Department of Ecology and Natural Resources of the Lviv Military Administration, spoke about them.
“The National Waste Management Plan will be adopted and implemented shortly. It is currently undergoing a strategic environmental assessment and should consider the second level – regional plans to be developed at the regional level. The third level is local plans for territorial communities. And the fourth level is the plans of each enterprise, business entity, including regional landfills,” explains Hanna Bashta.
She noted that since the national plan has not yet been adopted, we cannot develop regional plans:
“Everything is structured there, with percentages and indicators for each five years that each region must provide to reduce the amount of waste. Waste has to be taken to landfills or dumpsites (as of today). Therefore, we cannot start developing a regional plan yet. The Department of Ecology of the Lviv Regional State Administration has developed the terms of reference for it. We formed a working group and invited everyone – NGOs, scientists, carriers, authorities, and local governments. We sent the draft plan to the working group and partially discussed it. But we are still waiting for the national plan to be adopted.”
Cluster approach
Another innovation of Lviv, as described by Hanna Bashta, is the cluster approach:
“In each cluster (a group of identical or similar elements gathered together or close to each other), a regional solid waste landfill and a reserve landfill were envisaged. Each landfill provides for the expansion of the area of use and the possibility of installing a waste sorting line. If a landfill is available, we will carry out reclamation, while the rest will be gradually closed in the future. The cluster approach also involves a logistical approach to regional landfills, creating waste sorting or transfer stations,” explains Ms Hanna.
“We introduced the clusters to local governments, agreed with them on the location of regional landfills on their territory, and collected proposals for using other areas to construct future regional landfills. We also met with the main carriers operating in the region to submit their proposals, taking into account the logistics and economic component of waste transportation.”
Extended Producer Responsibility (EPR) – how and when will it work?
Dialogue with businesses and producers is a necessary component of the waste management reform. After all, the reform also includes extended producer responsibility. For example, in Sweden, where this rule is in place, manufacturers cannot market goods whose packaging is not recyclable. Accordingly, all Swedish companies that manufacture or recycle packaging (bottles, polyethylene packaging, glass containers, etc.) comply with the provisions of the Packaging Act. But how will this work in Ukraine?
As of 2024, hundreds of companies operating in Ukraine deal with secondary raw materials and waste and should be included in the dialogue on reform implementation. For example, since 1991, Ukraine has had a production and environmental association for procuring and using secondary material resources, UKRVTORMA. This is the country’s largest waste management structure, which includes about 100 specialized procurement and processing enterprises of large, medium, and small businesses in all Ukraine regions.
Specialized procurement enterprises of the association collect and prepare waste recyclable materials, including waste paper, recycled textile and polymeric materials, glass, worn-out tires, etc. Recycling companies that utilize recyclable materials produce cardboard, toilet paper, polyethylene pipes, boxes, a wide range of products made from recycled polymeric materials, etc.
Petro Semko, CEO of Ukrvtorma, who also participated in the discussion, believes that Ukraine has large capacities for recycling paper, polymers, glass and PET bottles, and waste paper.
“Ukraine should introduce separate waste collection to reduce the burden on landfills and use more recyclable materials. However, this requires significant investment in depot containers, special machines, and sorting lines, which are still lacking in the country,” says Semko.
As for the extended producer liability, Mr Semko believes the relevant draft law will be adopted shortly. However, this is only one step among many:
“Ukraine has a law on waste, but we still need to adopt up to 10 laws, including batteries, electronic scrap, oils, and tires, to make everything work. Only after the law is adopted will we know whether we can operate as a WEEE and what kind of operator we will have.”
“12 large companies, including Carlsberg, Pepsi, and Coca-Cola, have set up their separate waste collection operator. In pilot projects in Vyshhorod and other cities (Irpin, Bucha, Kotsiubynske, Hostomel, Vorzel), 400-500 depot containers for separate collection are being installed and funded by these companies. They buy the depot containers, hire a service company to handle the logistics, and sort the recyclables. And we pay them for the recyclables we sell on the market. This is the experience of foreign countries where packaging manufacturers finance similar initiatives. If a law allows packaging manufacturers to set up and finance their operators, it will increase profit. Experience shows that government leadership in such initiatives, for example, through the state-owned company UkrekoKomResursy, can be less effective,” explains Petro Semko.
According to Iryna Myronova, producers must unite, create RPR organizations, and, in cooperation with communities and transport companies, finance the collection of packaging that they put on the market. This will reduce the financial burden on citizens who have to pay for waste management and make it easier to move to separate collections, as additional funds will be focused on the separate collection of a valuable waste resource.
“Since the fire at the Hrybovychi landfill in Lviv, we have had the highest cost of waste management paid by citizens and subsidized by the city: now it is UAH 180,000,000 per year, previously UAH 320,000,000 per year. This is for mixed waste that has to be transported to landfills in the region and beyond. The whole system is expensive,” explains Iryna.
The role and potential of condominiums
In many cities, condominiums are active in implementing separate waste collection. For example, in Lviv, municipal waste management practices implemented by HOA initiatives significantly exceed the percentage of waste collected separately.
“The purity of organic waste is excellent. This is when an HOA closes its container site, works with its residents, and can pay not for the average rate but for what they throw away. In the waste management reform, it is important to establish careful accounting in the administrator’s work: who generates waste, who pays for it and how much, and a payment system tied to the amount of mixed waste generated,” says Iryna Myronova.
Pay for what you throw away – how do we calculate the waste we throw away?
Iryna Mytronova explains that waste is more complicated than water, electricity, or heat, for which we have meters. She explains:
“There are standards for waste generation. This is more detailed information than is available today in morphology. As for the actual waste removal, each carrier has accurate information: how many customers they serve and how much waste is generated. Condominiums that have closed their container sites sometimes say that they have almost halved their waste collection fees by monitoring and ordering services based on the number of containers filled. There are a lot of digital technologies abroad, smart containers, different systems.”
Iryna Myronova also says that “the previous law says that there should be rules for different businesses, which are more difficult to control because you have to ‘follow’ all the individual entrepreneurs, shops, and kiosks. That’s why we often shift these unaccounted-for businesses onto residents. Our case studies of the morphological composition of waste in condominiums show that in those closed condominiums where there is no business nearby, there was 450 grams of waste per person. And this is in summer when there is more waste because there is usually more organic matter. Therefore, when developing a regulation, it is important to clearly understand who is the waste generator, how much waste is produced by businesses in the city, and to work with businesses. If we translate our case studies, it turns out that businesses generate 48% of waste in the city. They must pay for it.”
Petro Kinash, director of the Lviv municipal enterprise “Administrator of Household Waste Management Services,” explained how it works at the level of Lviv, explaining that according to the law, there is a single mechanism for paying for solid waste – the person/rate. Now, the development of the norms and the rules based on which they are developed have lost their validity, so new ones are being developed.
“If it were ‘whoever produces what pays what,’ then local governments would adjust the accounting to this, and everything would be after the fact. Now, the generation rate in our community is 1 kilogram per person per day; in Kyiv – it is 1.9 kilograms, and in some regions – 3 kilograms. To sort this out, we need one waste management company. According to the new law, the city owns the waste, but there should be an administrator. If it is a monopolist, it can keep track of business, population, and the budget,” explains Petro Kinash.
Where should we get the money for waste management reform??
A separate issue that inevitably arises in any discussion of reforming the system is its financing. Waste management costs money, and it is a service for which citizens, in addition to the state, should also pay.
“I would like us to raise conscious citizens. I want everyone to understand that waste management costs money that everyone has to pay for this service,” says Iryna Mytronova, “The costs of waste management should be covered by residents first and foremost. They should have an incentive to pay for it. But I want to ensure that when reforming this system, we do not forget about those who have been ensuring the return of valuable materials for recycling all these years. These are informal waste collectors, mostly poor in Ukraine, who pick out recyclables from garbage bins and mixed waste, take them to collection points, and make a living. These people must be supported, formalized, and involved in the waste management system when implementing community-based reforms.”
Diana Novikova called for the development of infrastructure in this area:
“Since the first days of the full-scale invasion, many facilities have been destroyed. These include containers, garbage trucks, waste management facilities, landfills, sorting plants, and container yards. The updated report on damage assessment and recovery needs, including household waste management, is part of a comprehensive assessment of the war’s consequences. The issue of humanitarian financial support for the restoration of communities and the development of the sector remains relevant. The Ministry is cooperating with international financial organizations in this area. Recently, 19 communities in four oblasts received support from the EU and the Japanese government in the form of equipment for household waste management after the destruction. This is an important step towards the country’s economic resilience, and we will continue to cooperate in this area,” she said.
Hanna Bashta noted that “the law provides for an increase in the environmental tax rate, but the mechanism for its distribution has not yet been fully defined. Grants are also an important source of funding, especially in a full-scale war when the state or regional budget cannot cope on its own. The responsibility of producers from 2030 will also include the accumulation of funds for waste sorting and recycling. We have European practice and experience that can be used to develop these mechanisms.”
Serhiy Pronkin believes that communities can accumulate funds for small educational initiatives that will contribute to reform implementation: “For example, in Khmelnytskyi, the Goofy Centre was built at the expense of the local budget and adapted to this need. Residents need to get involved in household waste management, as the infrastructure can be the best in the world. Still, without changes in mindset, it will not produce the desired results,” says Serhii.
Petro Kinash believes education and culture should be the main priority: “We have developed a free 3D art book game for kindergartens, and now we are implementing it in a trial version. Having collected containers, we created a free learning center. It’s not a global scale, but in 2023, more than 2,000 primary school children were trained there to sort waste physically. You can start with little funding; the main thing is the desire.”
Petro Semko believes that with the increase in disposal volumes, tariffs should also increase. However, this will be the responsibility of the city, city authorities, and utility companies, which will have to work harder and invest more of their own money. “As for extended liability, we are all waiting for the law. If there is a law, there will be money, big business will be able to buy depot containers, and we will be able to start separate collections,” says Petro Semko.
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The material was prepared with the informational support of the media platform “Tvoe Misto” within the framework of the EPAIU Initiative, implemented by the International Renaissance Foundation with the support of Sweden.
