New Luxembourg Waste Management Plan – Good basis, but weak implementation
The new national waste and resource plan for Luxembourg was recently made available for public consultation. This plan is an important tool for adapting Luxembourg’s waste policy to national and European requirements. The plan contains many relevant measures, but often remains too vague and unclear in terms of implementation. It lacks binding targets, timetables, clear responsibilities and sufficient funding.
Mouvement Ecologique submitted a statement; read a brief summary here. The detailed document can be found at www.meco.lu.
Mouvement Ecologique welcomes key parts of the inventory. The action plan also identifies a whole range of possible measures that are to be welcomed.
1) Prioritise concrete measures to achieve (still partially) general goals according to impact and urgency
The plan contains numerous general declarations of intent, but little precise information on implementation, responsibility and timing. Important measures are not prioritised according to impact or urgency, and there is a lack of clear information on resources. To be effective, concrete goals, prioritised instruments and better links to available resources are needed.
2) Binding measures must complement awareness-raising
Awareness-raising is important, but cannot guarantee an effective waste policy on its own. The plan relies too heavily on the voluntary commitment of stakeholders and consumers. Legally binding frameworks and incentives are needed to ensure comprehensive implementation.
3) Clearer rules on the use/recovery of waste generated in Luxembourg
The current data on waste streams remains too superficial and does not provide clear information on actual recycling channels. There is a lack of detailed data, binding targets and improved traceability of exports. Strategic considerations regarding national waste disposal are also hardly addressed.
4) The circular economy – a stepchild in the waste management plan
Although the circular economy is central, it plays only a minor role in the plan. Implementation remains vague, and there is a lack of interministerial cooperation and clear structures. In view of negative developments, which were also highlighted by the European Environment Agency (EEA) in a very recent report, this area urgently needs to be strengthened and strategically developed.
5) Address consumer behaviour as a driver of waste production and identify alternative approaches
Although the plan emphasises the importance of moderate consumption, this priority is not reflected in its measures. Luxembourg has an above-average level of resource consumption, which is why greater awareness-raising and concrete measures are needed in this area.
6) Provide greater support to resource centres so that they can fulfil their central role
Resource centres are crucial for prevention and reuse, but the plan remains vague on this point. Resource centres must become genuine local hubs for repair, reuse and sharing. Mandatory and transparent statistical monitoring must be put in place to measure progress. Finally, the state must link its funding to the achievement of these criteria, while offering additional incentives for particularly ambitious centres.
The same applies to the measure mentioned concerning resource centres for businesses.
7) Comments on various waste categories
In the case of textiles, there is no clear strategy for implementing EU requirements, particularly with regard to reuse and producer responsibility. Issues such as sewage sludge, microplastics and contaminated sites are only dealt with superficially, although there is a considerable need for action here.
Conclusion
The draft PNGDR 2025 is an important foundation in its current form, but it remains too vague and non-binding to initiate a genuine transition to a circular economy.
Mouvement Ecologique calls on the government to build on this plan, particularly by further developing the key measures, and thus to present an ambitious instrument that focuses on prevention and reuse, strengthening resource centres, reducing massive exports and controlling the “use” of exported waste, establishing local repair and reuse activities, and promoting the circular economy.
The present plan should be supplemented by a binding financing plan and an analysis of the available human resources and governance structures.
Only under these conditions can Luxembourg reduce its ecological footprint, create high-quality local jobs and meet citizens’ expectations for a sustainable and solidarity-based society.