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  • Thor Lindskog

The Present State of the Circular Economy in Ukraine

An effective system for the recycling and reconceptualization of “waste” is of great importance in developing a circular economy since a key aspect is not treating waste as waste but as a resource where the goal is to reduce surpluses as much as possible. In the case of Ukraine, they did not have a modern waste management system in place before the war and their pending status as a candidate country to join the EU is creating new opportunities for the introduction of a modern waste management system. This article will look at the current state of affairs (24 February 2022 – onwards) in the area of waste management and circular economy (CE) in Ukraine.

A CE revolves around the organization of an economic system which establishes a circular flow of resources so that materials, products, and their components always maintain the highest possible utility and value. At its core, this approach eliminates waste. Materials that are no longer necessary in one production cycle are reintroduced into another as a new resource for production or materials. In other words, CE models aim to reduce waste as far as possible through reusing resources at a product’s end-of-life for new products or materials, thereby creating new value.

Out of the three principles of a circular economy - (i) Eliminate waste and pollution, (ii) Circulate products and materials (at their highest value), (iii) Regenerate nature – eliminating waste is the one most consistent with Ukraine’s current needs. Prior to Russian aggressions, Ukraine was already facing waste management issues despite having developed several national strategies, reforms, and policies to combat the effects.

The main purpose of the waste management reforms targets the sporadic landfills which constitute Ukraine’s current management practice. Wartime has also exacerbated the situation by greatly increasing the amount of construction, demolition, and hazardous waste materials, which, in turn, is treated poorly due to no appropriate scheme for categorizing different types of waste.

In 2021, over 90% of Ukrainian household waste was disposed of at landfill sites, only 7% was recycled, and 1.7% burned. Out of the 6000 operational landfills; 824 did not meet environmental standards, 371 required renovation, 230 were overcrowded. Moreover, Ukraine was the only European country without extended producer responsibility (i.e., “no polluter pays” principle). Therefore, eliminating waste and pollution has been – and remains – a salient issue for Ukraine which must be adequately dealt with. So, what is being done?

Subsequent developments such as the attempt at European Union (EU) accession through compliance with the European Green Deal (EDG) have revealed weaknesses in the current state of affairs concerning Ukraine’s policy and legislative area of waste management and CE implementation.

State of Affairs in Waste Management

To reach EU member status, legislative reform is actively followed in Ukraine both locally and globally, aimed at stimulating businesses to transition to the latest production methods, including CE. The innovative management approach begins by treating “waste” as an opportunity, not a problem.

June 2022 – The law “On Waste Management” (“waste management law” – WML henceforth) was adopted and laid the foundation for future developments in the Ukrainian waste management system, previously poorly regulated and fragmented. The legal framework of the WML introduces regulation of waste management relations and is modelled after the EU directives (for e.g., the EDG). The adoption of WML is an opening for Ukraine to commence EU membership requirements, attract investors, and to build back better. While simultaneously developing the polluter pays principle which helps sorting and recycling waste and can boost the development of Ukraine’s CE and increase investment opportunities. The WML will be in effect on July 9th, 2023, presumably giving regulators and business operators time to adapt to the new circumstances.

What is the purpose of WML?

  • a new European waste management hierarchy and system of planning at local, regional, and national levels.

  • a polluter pays principle and extended producer responsibility which requires manufacturers to warrant the complete disposal of the packaging they place on the market together with the produce.

  • a new information system designed to streamline the accounting and reporting as well as the implementation of authorization procedures in waste management.

  • a subsystem of registers containing information about issued permits, ERP producers and their products, and which is accessible by the public meant to increase accountability.

  • procedures for collecting, removing, processing, and recycling household waste.

  • special rules regarding the disposal of waste because of bombardments in the current geopolitical climate and the closure and restoration of outdated landfills.

  • Finally, WML creates conditions for the formation of a modern waste recycling infrastructure in Ukraine corresponding to European directives and opens borders for investors. In other words, WML creates a foundation for the development of a CE.

Limitations of Ukraine’s waste management

The WML establishes novel guidelines for a - much needed – updated waste management system which could prompt a good basis for CE principles. The adoption of more sectoral laws and regulations will be necessary in achieving a full-scale reform and laying the groundwork for CE. The development and implementation of waste programs is covered by lenient administrative and environmental penalties and fines, in turn not providing incentive for producers to extend their responsibilities. In addition, Ukraine lacks meaningful action plans, basic legislation, and legislation for various types of waste (for e.g., batteries and packaging). Without these acts it is unlikely that Ukraine will reach the EGD, despite promises.

Lenient legislation aside, Ukraine finds itself in a precarious situation wherein laws and strategies compliant with the EU’s vision are taken on by Ukraine despite finding themselves in the middle of an armed conflict. As such, one can question the longevity of any proposed changes. Nonetheless, improvements in the development of waste management and implementing CE principles is a stepping stone for Ukraine since it provides them with more opportunity of reaching EU candidacy and achieving a Green Recovery. While there are some CE principles being discussed and slowly implemented on a national level there is nothing circular in motion just yet.


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