Mr. Peplow has been employed at the National Audit Office since 1986 and is currently senior audit manager within the Performance Audit Unit. He has been managing performance audits since 1999. He has also participated in parallel audits with State Audit Institutions of other EU Member States dealing with environmental themes and EU funding, namely Structural Funds. Since 1994, he has been the NAO’s representative in the INTOSAI and EUROSAI Working Groups on Environmental Audit. Mr. William Peplow holds a Master of Arts degree in Public Policy, a Master’s degree in Business Administration and a Diploma in Public Administration.
A core variable that drives human pressures on the environment is the size, composition and distribution of population. With a population of around 516,000 and an area of just 316 square kilometres, the Mediterranean island state of Malta ranks among the most densely populated countries in the World and is by far the most densely populated country in the European Union. Despite the revenues generated by tourism, these statistics become more dramatic when the arrival of 2.7 million1 visitors who arrive annually to Malta through the island’s dynamic tourism industry are equated in these figures. The foregoing implies great stresses on Malta’s waste management, including that relating to plastic – which causes harm to humans, animals and plants through toxic pollutants. It can take hundreds or even thousands of years for plastic to break down, so the environmental damage is long-lasting.
In Malta, plastic is imported either in granular form, which is then processed locally, or already processed. Some plastic will become waste, some will remain in stock or in circulation for some time, until it is disposed of. There are two main categories of plastic waste, namely plastic packaging and other non-packaging plastic.
Why did we do this audit?As at end 2017, Malta was lagging behind in attaining national and European Union (EU) waste management targets, such as those related to the recovery and recycling of plastic waste. Inadequate waste separation at source practices result in potentially recyclable waste being landfilled, which is by far the most expensive solution in financial and environmental terms. National waste strategies and the legislative framework advocate the polluter pays in principle but in practice, Government is shouldering the lion’s share of waste management-related costs.
On the other hand, Malta had embraced the principle of sustainable use of plastics through various policies, strategies and plans. This strategic framework recognised that addressing of plastic waste challenges was an urgent priority on a supranational and national level.
These circumstances prompted the National Audit Office Malta to evaluate, through a performance audit, the extent to which Government was effectively managing plastic waste, mainly that resulting from packaging and single use plastics.
This audit considered aspects and criteria emanating from the principles of the circular economy, which in turn constitute a tangible contribution to reaching the United Nation’s Sustainable Development Goal (SDG) 12, entitled Ensuring Sustainable consumption and production patterns. The latter includes a target to substantially reduce waste generation through prevention, reduction, recycling and reuse by 2030. SDG 3 and SDG 14 also come into play as these target microplastics and decisive actions to fight marine litter, respectively.
A further impetus to carry out this audit was that this study was to form part of a cooperative audit that was carried out jointly with another 11 European State Audit Institutions (SAIs) within the auspices of the European Organisation of Supreme Audit Institutions Working Group on Environmental Auditing (EUROSAI WGEA). The partners of the cooperative audit were the SAIs of Albania, Bulgaria, Hungary, Moldova, North Macedonia, Poland, Portugal, Romania, Serbia, Slovakia and Turkey. This cooperative audit performed by the different countries through a harmonised audit scope and methodology determined the degree to which different countries in Europe are effectively managing plastic waste as well as identifying best practices.
The publishing of the NAO’s report was timed to coincide with the drafting of national plans and the upgrading of the waste management infrastructure on the island. This study sought to add value by eliciting inefficiencies and leakages in the plastic waste management process which could be addressed through the ongoing national initiatives.
Objectives, Methodology and LimitationsWithin this context, the Malta NAO’s report:
- determined whether plastic waste management data is comprehensive and reliable.
- assessed whether the legal instruments and policies in place are adequate to provide proper plastic waste management and effective in the context of planned goal.
- assessed whether implementation, monitoring and enforcement are effective.
We adopted various techniques to realise the above audit objectives. These included documentation reviews, on site visits, interviews and data analysis. This approach enabled us to triangulate results to elicit more robust conclusions.
Despite this multi-approach methodology we encountered a range of limitations, namely:
- Plastic-specific recycling targets - There were no national and EU plastic-specific recycling targets in other waste streams such as waste electrical and electronic equipment or end-of-life vehicles, despite there being an overall recycling target. As a result, this Office could not obtain reliable data on how much plastic is recovered from other waste streams.
- Strategies are still being drafted - On the national level, the European legislation on single use plastics was at the time still in the transposition stage. Moreover, the publication of a new Waste Management Plan was imminent to relace the then previous document which addressed issues up to 2020.
- Data fragmentation – The national regulator ERA (in full) encountered various problems to collect comprehensive data from stakeholders and to ascertain its quality and integrity.
- Data availability – Data is reported to the EU two years in arrears. Consequently, the NAO was at times constrained to utilise unofficial data provided by operators.
- Products containing plastic are not necessarily registered with customs – Unless the products are plastic granules, containers, bags or bottles, these are not registered as plastic products. Thus, products such as calculators and toys are not registered under the plastic category. Moreover, due to the free movement of goods, only plastic products that are imported or exported from / to countries outside the European Union are registered. Similarly, small quantities are excluded from such registration.
Waste management costs, including those related to plastic waste, are mostly borne by Government – particularly through the annual subvention of around € 25 million to WasteServ – the public entity responsible for organising, managing and operating integrated systems of waste management, including the sorting, reuse, utilisation, recycling, treatment and disposal of waste.
This deviates from the polluter pays principle. But it is also being acknowledged that socioeconomic principles come into play. The full transfer of costs to polluters implies that in turn these will be passed on to consumers – which would have an inflationary effect. Additionally, as a small country lacking in critical mass led to diseconomies of scale pushing up the cost per unit significantly. Moreover, the collapse of the recyclables’ market in 2017 and operational difficulties brought about by the incident at Sant’Antnin Waste Treatment Plant (SAWTP) in May 2017, which at the time was Malta’s main facility, meant that WasteServ revenues decreased disproportionally and thus the entity remained far from recovering its waste treatment costs. These circumstances also raised questions regarding the equitable sharing of risks and responsibilities through WasteServ’s agreement with the Packaging Waste Recovery Schemes.
Separation at source opportunities are not being fully exploited as separation guidelines are not strictly adhered to by waste generators – another variable which increases waste treatment costs and augments the amount of waste rejects to the detriment of recycling opportunities. The roots of this situation lie in two factors. Firstly, current regulations do not encourage stricter separation by waste streams, which renders waste treatment more complex and costly. Secondly, inappropriate waste separation at source practices contaminated potentially recyclable material.
Malta’s waste management operations were carried out within an infrastructure which lacked the appropriate capacity. In recent years, as outlined earlier, matters became more exacerbated through the SAWTP incident. Government acknowledged this and there was a strong political commitment to allocate around € 500 million to extend and upgrade Malta’s waste treatment facilities.
ConclusionsThere is no doubt about the required investment in Malta’s waste management facilities. Such an investment, however, will not deliver its full potential unless it is complemented with the increased adoption of circular economy principles, which in turn will facilitate the attainment of Sustainable Development Goals targets. The health and environmental risks of plastic can only be mitigated through a consorted effort by all stakeholders, including political, administrative, the industry and consumers, as well as an effort to reduce its production at the outset. This is especially relevant for a small country where its geographic and demographic make-up constitute major constraints and limitations on a number of fronts.
Recent DevelopmentsSince the publication of this performance audit in 2021, Government has implemented a number of initiatives to mitigate the risks associated with plastic waste and embrace further the principles of the circular economy. The publication of Malta’s new Waste Management Strategy is imminent and has already undergone a public consultation process. Additionally, the process for upgrading Malta’s waste infrastructure has commenced.
In 2021, Malta trebled its plastic waste recycling performance through investment in available infrastructure. Government has also announced that, as of January 2023, differentiated landfill fees to further encourage waste separation will become applicable so that Malta can continue moving towards its environmental targets. Malta has already implemented and is in the process of implementing other initiatives outlined in the Single Use Plastic (SUP) strategy. The net effect of these initiatives is to stem leakages from the various stages of the waste management chain through measures that promote the values of the Circular Economy Waste hierarchy.
1Data refers to 2019 figures. Source: NSO, Inbound Tourism: December 2021.