Reference metadata describe statistical concepts and methodologies used for the collection and generation of data. They provide information on data quality and, since they are strongly content-oriented, assist users in interpreting the data. Reference metadata, unlike structural metadata, can be decoupled from the data.
Ministry of Agriculture, Rural Development and Environment
1.2. Contact organisation unit
Department of Environment
1.3. Contact name
Confidential because of GDPR
1.4. Contact person function
Confidential because of GDPR
1.5. Contact mail address
Ministry of Agriculture, Rural Development and Environment,
Department of Environment
1498 Nicosia, Cyprus
1.6. Contact email address
Confidential because of GDPR
1.7. Contact phone number
Confidential because of GDPR
1.8. Contact fax number
Confidential because of GDPR
2.1. Metadata last certified
19 February 2025
2.2. Metadata last posted
19 February 2025
2.3. Metadata last update
19 February 2025
3.1. Data description
We are reporting in accordance with most of the new calculation rules. Most of the packaging waste are sent after sorting for further treatment either in other MS or third countries, so there is significant difficulty in getting all the information needed for the calculation point. A deduction percentage was applied for materials (paper, plastic, aluminium and steel) exported/transferred abroad for further treatment for 2022, from data received from the Green Dot system and comparing data from the study of the Consurtium of companies Eunomia/ IACO/CHR.TSIARTA (2023) for the collection of data for 2022 prepared for the Department of Environment. We do not intend to report compliance with the old recycling targets.
The derogation to make use of average loss rates has been applied.
3.1.1. Description of the parties involved in the data collection
Table : Institutions involved in the collection of data and distribution of tasks
Name of institution
Description of key responsibilities
Department of Environment
Responsible for the implementation of the law, licensing EPR scheme (Green Dot Cyprus), individual packaging schemes and recycling units. Also for preparing the quality report for packaging and packaging waste to be send to Eurostat.
Green Dot Cyprus (EPR system)
Collective management system (EPR) for packaging and packaging waste undertaking the producer's responsibility acording to the packaging and packaging waste law N.32(I)/2002, responsible to report the generation of packaging waste and the recycling/reuse rate for their members.
Individual management schemes for packaging waste
Producers that set up their own individual system for the management of packaging waste.
Free riders/Other
Producers that are not known or are not registered or report to the EPR scheme or/and other private imports/export of packaging waste and on-line sales.
Recycling units (waste operators)
Waste operators collect, transport, separate the waste into different streams, pre- sorting them into bales and transfer/export them for further treatment abroad (third countries or other MS)
Companies that reported data for reusable packaging
Companies that reported data for the reuse of wooden pallets, glass bottles, plastic, metal crates and paper cartons boxes
Statistical Service
Helps to cross check the data, using them in the estimation of targets for municipal waste using the 4th method
3.2. Classification system
Packaging waste , under the waste code 150101 for paper, 150102 plastic, 150103 for wood, 150104 for metal (aluminium and steel) are mainly send to other MS or third countries for final treatment and for 150107 for glass the treatment is locally.
3.2.1. Classification of treatment operations
The treatment operations in CY refer only to Annex II - Recovery Operations In particular the relevant R codes are the following : - R 12 Exchange of waste for submission to any of the operations numbered R 1 to R 11 (****)
(****) this includes preliminary operations prior to recovery including pre-processing such as, sorting, crushing, compacting, pelletising, drying, shredding, conditioning, repackaging, separating, blending or mixing prior to submission to any of the operations numbered R1 to R11, as these materials are send abroad for further treatment.
3.3. Coverage - sector
Municipal Waste (European list of waste 15- household and industrial/commercial packaging waste)
3.4. Statistical concepts and definitions
We wish to take into account the amount of wooden packaging that is repaired for reuse in the calculation of the targets. Data are collected mainly from the EPR scheme and/or direclty from actual sources/companies repairing the wooden pallets. Repairing of wood reaches 98,5% from total recycling of wood. No assumptions have been made for the adjustment of the calculation.
No incineration takes place in order to have metals in incineration bottom ash for the calculation of the targets.
3.4.1. Types of reuse system in place for each material type
Reuse systems are mainly focused on wooden pallets that are repaired and reused, glass bottles cleaned and refilled and smaller quantities of reusable packaging from plastic, metal crates and paper/carton boxes. For 2022 data were collected from limited number of companies that reuse these type of packaging (data from the study of the Consurtium of companies Eunomia / IACO/CHR.TSIARTA (2023) for the collection of data for 2021/2022 prepared for the Department of Environment).
3.4.2. Other recovery of waste
No waste treatment related to 'other recovery'.
Energy recovery reported is estimated from the load of RDF collected from the MBT unit in Limassol and received by the cement instustry and the residues that are send for energy recovery from the pre-sorting/pre-treatment of packaging. From the two sources from the total of RDF a percentage of 3,12% is considered as packaging paper and a 15,74% as plastic packaging, as reported in the data base of the Environment Service. No energy recovery for wood was reported from the cement industry for 2022.
Small quanitites were reported from Forest Industries for energy recovery of wood.
3.4.3. Information on temporary storage of packaging waste
Temporary storage is mainly for the category of packaging metals as the recycling facilities have great quantities of stock (especially for steel) as they expect higher prices in the market in order to sell it and export it (this is one of the reason why waste metal recycling is greater than waste metal generated).
For 2022 actual quantities of glass treated in the cement kiln are reported (as mentioned in the Green Dot report), as stock storage is limited and now there is a balance for storage and treatment.
Paper recycling is also significally increased for 2022, indicating temporary storage /stocks for previous years , expecting higher prices to sell it on the market.
3.5. Statistical unit
Packaging waste in CY (in tonnes)
3.6. Statistical population
Number of producers (put on the market = generation of waste) = ~ 2000 companies +15% free riders
Number of presorting facilities/ or facilities that export waste= 17
3.7. Reference area
Cyprus
3.8. Coverage - Time
one year (2022)
3.9. Base period
Not applicable
Tonnes
Calendar year
6.1. Institutional Mandate - legal acts and other agreements
According to the packaging and packaging waste law N.32(I)/2022 , under article 15 all Packaging operators and all interested economic operators (producers, treatment facilities) are obliged to provide to the Minister with reliable data relating to their field of activity, which are required under article 14 of the law, that refers to the Environment's waste data base .
Also through the licence of Green Dot and legal act (regulations for the producer's responsibiity) , there are terms for the packaging waste management scheme to comply with the terms of their licence and report yearly to the competent authority. The same goes for indiviual management schemes.
Green Dot also through contracts (formal agreements) with their members (producers) have a agreement for them to provide necessary data regarding the type and quantities of packaging, they put on the market.
6.2. Institutional Mandate - data sharing
Data are provided by the responsible entities (producers/Green Dot/individual system/treatment facilities) to the competent authority yearly either directly/ through the waste data base of Environment service/ reports from GD. Individual data of each responsible entity are kept by the compentent authority and are not shared. Only the total sum of data can be shared (e.g with the Statistical Service, through the website as annual reports etc)
7.1. Confidentiality - policy
Permission is granted to disseminate / published the information contained in this quality report.
European General Data Protection Regulation (GDPR).
7.2. Confidentiality - data treatment
Permission is granted to disseminate / published the information contained in this quality report. All data are aggregated before being published
8.1. Release calendar
Yearly 2022
8.2. Release calendar access
Not applicable
8.3. Release policy - user access
Data are released yearly for the public through the website of the Environment Service or through the website of Green Dot (for their data and their members, not the total for CY)
Yearly
10.1. Dissemination format - News release
Not applicable
10.2. Dissemination format - Publications
Annual Reports from waste management facilities on packaging/Custom documents
Not available at the moment. A new upgraded database is being prepared (through tender procedure) and the documentation of methodology is also being prepared and analytically described.
10.7. Quality management - documentation
Not applicable
11.1. Quality assurance
Guidelines are followed as previous years, in order to ensure the efficient use of resources and to collect information from all the relevant sources and involved stakeholders , ensuring quality, completeness and continuation of data .
11.2. Quality management - assessment
Overall assessment of data quality is based on following a standard procedure in the collection of data, comparing them with previous years. A tender document report from Eunomia for upgrading data and comparing sources of data , was added to the improvement of quality of data for year 2022.
12.1. Relevance - User Needs
Users of the statistical data are mainly the Environent Service and the Statistical service in order to prepare the relevant reports to Eurostat (on packaging waste, own resource and municipal waste). Public and relevant stakeholders use these data as an informative source.
12.2. Relevance - User Satisfaction
There are no measures to determine user satisfaction.
12.3. Completeness
All statistics that are needed are available, but some might have statistical error or wrong usage of codes during export of waste or when put on the market.
13.1. Accuracy - overall
Accuracy on generation and treatment of packaging waste:
GENERATION
A) Data gaps :
from estimates based on a representative sample of producers (small) with PoM under 2 tonnes per year,
from free riders unknown and not registered to the Green Dot system (undereporting) - the percentage for free riders is estimated this year to 15% extra per material but this is an estimation.
inaccurate data reporting by producers to Green Dot system. This is corrected through private audits on behalf of Green Dot Cyprus,
under reporting of data specifically for metals or paper put on the market as these companies:
are not registered in Green Dot scheme as they don't consider their metal products as packaging (like barrels, cylinders etc)
are registered but they undereport data, so metal reycling is higher than 100% comparing to waste generation, as these quantities are missing or under reported. We can see that the recycling of metal waste in 2022 (10134,44 ton) exceeds the generation (7377,7ton). This phenomenom trend for metals is continous over the years and possibly leads to the following conclusions:
Metal waste recycling is greater than generation, due to temporary storage (stocks) of packaging metals as the recycling facilities expect higher prices in the market in order to sell it and export it, as they informed us. This is a continuous practice through the years and needs further investigation.
Data for recycling are reported by the pre-sorting facilities that export the waste for further treatment, presenting official documents (bill of lading, custom document, Annex VII for exports/tranfer). A reason for greater recycling than generation, would be that the facilities collect and export (transfer) metals in general (not only packaging) using a 7,5 % assumption in their total load of metals to estimate the metal packaging. The percentage is estimated emprirically, from their experience through the years. May be this percentage is high, and this can result to higher recycling than generation. There is need for a quantified study to the measurement point after the pre-sorting and before exporting, on the specific issue.
b) The actual extra percentages for private imports/exports, internet, on-line sales data might be different than those estimated in our calculations, due to lack of completed system for collecting these data. This need to be improved with setting up a new upgraded electronic registy (there is an on going tender document procedure)
c) Incomplete data concerning the reuse as the sample size for collecting the data is still small, but this will be improved over the years.
TREATMENT
d) Waste management facilities reporting data to Green Dot and to the competent authority may be different but for year 2022 there was cross ckecking and correction of data in co-operation of competent authority and Green Dot. Particularly for industrial/commercial packaging waste, quantities and relevant documents must be reported firstly to the competent authority by the waste management facilities and after approvall, these data can be reported to Green Dot in order to get a financial incentive. Cross - checking of the various data submitted by a waste treatment facility in order to report the actual value of tonnages in our calculation is done by direct communication with the facility operators comparing and correcting them with Green Dot's data. The data for waste management facilities are also verified through the waste export documents sumbitted and recently through the electonic registry of waste, of the Department of Environment and this year from the on going study from the consortium Eunomia/IACO/Chr.Tsiarta for gathering data for 2022.
Concerning the data reported from waste management facilities, the completeness of data provided can be reassured as all companies are registered and are subject to permitting and regular inspection. The information from the export documents, reassures the tones of packaging treated abroad. Inspections take place regularly to reassure and monitor the packaging waste collected, separated and treated, in waste management facilities in Cyprus. Errors might occured, as some companies reports packaging (category 15, according to the list of waste) with a different code of waste in exports like municipal (category 20 or 19 , according to the list of waste ) or vice versa. Some companies did not responded to submision of data for 2022 and various sources were use to get the data.
e) ALR's calculation needs improvement and cross checking.This year ALR's is used from Green Dot's data as the on-going study suggested different ALRs with very high percentage for plastic (45%) to be deducted using averages from particular systems in Europe and the usage of different sorting technologies in Europe, but this needs cross checking and further investigation for the data for the following years.
Accuracy on the completeness of data for reusable packaging is limited, due to lack of data for 2022 as the data were collected from 8 companies that were indentified to put the highest amount of reusable packaging on the market, comparing them with total data of packaging placed on the market for the frst time. Not all stakeholders reusing packaging are known and registered. The competent authority is trying to set up a registry and to gather more data on reusable packagingfor the following years.
13.1.1. Statistical surveys used regarding packaging waste generation and treatment
The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in previous questions.
Component of packaging waste
Year
Statistical units
Percentage of population surveyed
Data (tonnes)
Confidence level
Error margin
Details of adjustments from the survey year to the current year
Other details
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
13.1.2. Statistical surveys used regarding reusable packaging
The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in other concepts.
Packaging material
Year
Statistical units
Percentage of population surveyed
Data (tonnes)
Confidence level
Error margin
Details of adjustments from the survey year to the current year
Other details
wooden pallets
2022
Not available
62%
2828,08
Not available
Not available
Not applicable
secondary packaging
metal barrels/cylinders
2022
Not available
62%
3424
Not available
Not available
Not applicable
sales packaging
paper boxes
2022
Not available
12%
0,02
Not available
Not available
Not applicable
sales packaging
plastic crates
2022
Not available
38%
2787,04
Not available
Not available
Not applicable
secondary packaging
glass bottles
2022
Not available
25%
8433
Not available
Not available
Not applicable
sales packaging
13.2. Sampling error
Accuracy on the completeness of data for reusable packaging is limited, due to lack of data for 2022 as the data were collected from 8 companies that were indentified to put the highest amount of reusable packaging on the market, comparing them with total data of packaging placed on the market for the frst time. Not all stakeholders reusing packaging are known and registered. The competent authority is trying to set up a registry and to gather more data on reusable packaging.
13.3. Non-sampling error
Accuracy on the completeness of data for reusable packaging is limited, due to lack of data for 2022 as the data were collected from 8 companies that were indentified to put the highest amount of reusable packaging on the market, comparing them with total data of packaging placed on the market for the frst time. Not all stakeholders reusing packaging are known and registered. The competent authority is trying to set up a registry and to gather more data on reusable packaging.
14.1. Timeliness
Length of time between data availability and the event or phenomenon they describe is from the end of 2022 till now (20 months)
14.2. Punctuality
Data should have been delivered 30 June 2024 but due to unavailability of data the report was completed in October (4 months delay)
15.1. Comparability - geographical
Data are for Cyprus so no statistics are comparable between geographical areas.
15.2. Comparability - over time
1) Waste generation for 2022 was increased in comparison with waste generation in 2021, as there was an economic upgrading and prosperity , leaving behind the pandemic and economic crisis of the previous years . Also for free riders we used a different method for the calculation of free riders, adding to the total an extra percentages of 15% per material and not following the previous method in 2021 by adding various percentages per material deparnding on the trend of the market. The reason for changing the method was that it was both Green Dots report and the Eunomia study suggested a higher percentages to add for free riders reaching the20% and also the early warning report for highlighting the possibility of under estimating the waste generated. So we choose to add an extra 15% for free riders taking in mind the previous mentioned facts.
2) Green Dot Cyprus for the category of "others" has reported them in their total amount and then splitted them further and incorporated them into the categories for each material , so no quantities for "other" material was stated this year. This is an improvement as "others" should be categories not reported before as a packaging material (paper, plastic, metal, glass and wood).
3) Some data for waste treatment/ facility were used directly from the on-going study for data collected for 2022, as the facilities did not respond back and directly to the Department of Environment.
4) Differences in the total recovery of plastic packaging (increase in 2022 in comparison to 2021)
a) Recycling of plastic in CY was not available in 2022 as one of the treatment facility closed down and the others did not submitted any data on packaging. Plastic Recycling in 2022 slighlty increased due to market demand compared to 2021 data. Also the generation of plastic waste was increased in 2022 so in total the recycling was decreased .
b) For the energy recovery the recovery from plastic packaging waste increased in 2022 compared to 2021, as stated by Enerco (company for energy recovery/cement kiln) that received the sorting residue from green Dot as an RDF (was mainly plastic) and from the MDF in Limassol again as an RDF.
5) Material recycling for glass for 2022 continue to report actual quantities of glass treated in the cement kiln as in 2021, as their stock and treated quantities are now in balance in comparison with previous years. A higher recycling rate for glass was achieved in 2022 in comparison with 2021.
6)There was use of ALRs and deduction of residual percentage from waste send broad/transfer to MS for further and final treatment, from Green Dot data (not from data from the on - going study for plastic ALR's (for 2022)
Differences from previous year's data - No significant changes.
15.3. Coherence - cross domain
These data are used also by the Statistical Service in the review of reports , mainly for municipal waste.
15.4. Coherence - internal
Statistics are variable due to actual data collected from recyclers and due to changes of market prices for the waste materials.
15.4.1. Explanation for any component with a greater than 10 % variation
Explanation detailing the causes of the tonnage difference (in relation to which waste streams, sectors or estimates have caused the difference, and what the underlying cause is) for any component of packaging waste generated and recycled which shows greater than a 10 % variation from the data submitted for the previous data year.
Material
Variation (%)
Main reason for variation
increase of waste generation in 2022 in comparison with waste generation in 2021
+17%
economic prosperity, better situation for commerce and leaving behind the economic crisis cause by the pandemic, also more free riders were registered in Green Dot scheme, adding an extra 15% for free riders not following the previous market trends for adding percentages per material for free riders
Category "others"
100%
Others category was divided in to the each category of packaging analogically, so no quantity was stated for the category of others
Plastic Packaging Recovery in total decreased
44%
Plastic packaging and energy recovery increased
Plastic Packaging recycling was not available in CY
100%
Plastic Recycling in cy is not available, one company stoped its operation and the others did not reported any data for packaging.
Plastic Packaging energy recovery increased in 2022 in comparison with 2021
141,00%
For the energy recovery the recovery from plastic packaging waste increased in 2022 as the cement kiln submitted higher quantities for recovery from RDF (from the sorting residue from green Dot as an RDF (was mainly plastic) and from the MDF in Limassol again as an RDF.- data were received from Eunomia study
Aluminium packaging recycling decreased in 2022 outside the Eu
96,6%
The difference can be explain solely to the market different prices in EU MS and in third countries.
These are private deals/ agreements and decision made by the companies as the competent authority cannnot control the market. Their data are accepted, as they submit detailed forms from the cuctoms and Annex VII that shows the final destination and the receptors facility for the aluminium.
Paper Recycling recycling significally increased
+358,00%
The difference can be explain solely to the market different prices in EU MS and in third countries. The pre-sorting facilities in CY have found in 2022 better prices to sell the paper . Stocks of paper may also be the reason
These are private deals/agreements and decisions, made by the companies as the competent authority cannot control the market. Their data are accepted, as they submit detailed forms from the cuctoms and Annex VII that shows the final destimation and the receptors facility for the paper.
Glass
+18,0%
Higher recycling in 2022, actual quantities treated were reported
Not applicable.
17.1. Data revision - policy
In general if preliminary data are compiled and there is need to be later revised, this will be done to ensure transparancy and accuracy , but there is no specific written policy,
17.2. Data revision - practice
Correction of backward data series for 2021 to be comparable, adjusting the free riders percentage to each material generated fo an additonal +15%. and not adding various percentages depended on the trend of the market.
18.1. Source data
Data on the generation of waste are mainly collected through:
a) The Extended Producer Responsibility (EPR) scheme of Green Dot Cyprus (PROs) for packaging and packaging waste declared to be placed on the market (PoM), as packaging waste generated may be deemed to be equal to the amount of packaging placed on the market in the same year in a Member State. Data from EPR schemes were collected from each member- producer and reported to the competent authority in an annual report by the PRO for 2022. Data from the PRO are a combination of 1) analytical data per producer (category A), 2) statement of data per producer under category per tonnes (category B), 3) data for packaging of pesticides (category C) and 4) estimation of producers that did not report on time or non - compliance producers (not fulfilling their obligations).
b) Other sources for the generation of packaging waste include data from packaging put on the market by 5 individual management schemes (individual producers/companies) reported to the competent authority in an annual report.
c) Estimated data from the producers (mainly small producers- free riders(others) not registered with Green Dot Cyprus as there is no de-minimis threshold point (in 2017 a de minimis was set at 2 ton/year/producer but the legislation was amended to remove the threshold). All producers must now be registered under the Green Dot scheme and report data to them.
d) Estimated amounts of packaging associated with imports, on-line sales/trading (free riding). For exports, producers are instructed not to include these data in packaging generation in their reporting, as packaging exported and used in other counties will become waste abroad and reported in that specific MS.
e) Data sources for the preparation for reuse are collected directly through the EPR scheme (Green Dot Cyprus) for their members or/and directly from the other relevant companies reusing packaging.
Data on waste recycling, are collected:
f) from the licensed treatment (recycling) facilities of packaging waste that pre- sort packaging waste and then send them abroad for further final treatment (data from annual report and data submitted in the electronic registry of the Department of Environment) and
g) from the EPR scheme of Green Dot Cyprus (cross-check mainly for the commercial/industrial packaging waste send abroad).
For 2022 for a number of companies, data were taken direclty from an on- going study of the consortium of companies Eunomia / IACO/CHR.TSIARTA (2023) for the collection of data on packaging (and other waste streams).
18.1.1. Waste samples from waste analysis
No waste analysis was possible for 2022. It is programmed for late 2024 - 2025 and tender documents are being prepared.
The waste samples for waste analysis are taken from:
Approach
Details about the flows of waste covered
Directly from the bin
Not applicable
From the waste trucks
Not applicable
Other approaches
Not applicable
18.1.2. Source of waste flow data for estimation
Sources
Materials covered
Waste collectors
Not available
Not available
Waste treatment operators
Not available
Not available
Municipalities
Not available
Not available
Others
Not available
Not available
Note: Materials to be covered and analysed will be the municipal waste (as described in the definition of the Directive 2008/98/EC covering all the relevant waste codes refered to them).
18.2. Frequency of data collection
The source data are collected yearly with the placed on the market approach (from EPR scheme) and the waste treatment units. Waste analysis method is programmed to be followed every 5 years.
18.3. Data collection
Systematic yealry process of gathering data for preparing report for Eurostat from the Department of Environment. Data are use also from the Staistical Service to prepare other data for municipal wastes.
18.3.1. Description of the methodology and verification of data on packaging waste generated in case waste analysis is used
No waste analysis is used for 2022 data. A tender document is being prepared for following the waste analysis approach, in late 2024- 2025.
18.3.2. Description of the methodology to report on composite packaging
Tetrapak is a composite packaging (paper, plastic and aluminium film) and according to the bibliography it consists of 75% paper, 20% plastic and 5% aluminium. For 2022 data we used the bibliography for minumum estimations to add quantites per material with no use of the derogation of 5% as tetrapack was already divided per category by the Green Dot Scheme in their report for 2022.
18.3.3. Description of methods for determining packaging waste treatment
Packaging waste material
Total
Plastic
Wood
Ferrous metals
Aluminium
Glass
Paper and Cardboard
Other
Data collection methods
Administrative reporting
No
No
No
No
No
No
No
No
Surveys
No
No
No
No
No
No
No
No
Electronic registry
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Waste analysis
No
No
No
No
No
No
No
No
Data from waste operators
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Data from municipalities
No
No
No
No
No
No
No
No
Data from extended producer responsibility schemes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Other
No
No
No
No
No
No
No
No
Additional information about the methodology, including the combination of methods used:
a) Data reported from waste operators:
Waste operators are subject to permitting and regular inspection. Terms in their permits include the reporting of waste collected, separated to categories, pre-sorted and send abroad for further final treatment (tranfer to MS or export in third countries), according to the waste codes from the LoW. The information collected from export/transfer documents (e.g. Annex VIII - for the transboundary movement, bill of lading, custom documents), reassures that packaging waste were received and treated by recycling facilities abroad. In addition the waste operators, particularly for the industrial/commercial packaging waste stream, must report these quantites (in tonnes) first to the competent authority and after to Green Dot, in order for them to get a financial incentive. Some treatment units (mostly in European Union) can proof that they operate "in broadly equivalent conditions", having a permit, being inspected and having the obligation for record keeping, but this needs further cross-checks and guidance, in order to collect all the information/data needed also from recycling facilities in third countries. Local pre-sorting units sending their waste abroad, must also demand and keep further documentation from treatment units abroad, in order to submit to the competent autority the required information on the specific measurement point used for each waste stream. The same applies for the full use of ALRs.Calculation points are used only at the local CY facilities as described in question 18.5.4. and 18.5.4.1. For the remaining waste streams send abroad, the measurement points used are at the output of sorting operation units and depend on the weight of waste send abroad (MS/third countries) as stated in the export documents, with deduction of the ALR percentage calculated from Green Dot, for the sorted material.
b) An electronic registry collecting information on waste has been set up at the Department of Environment and is in operation since 2021. Waste operators (units) are obliged to report the collected, treated and exported quantities of packaging waste data (and other) from 2019 and on. Data submitted are being evaluated for correction, as a number of units report waste might use different or wrong waste codes (19 instead of 15) for their exports . Waste facilities stated that the two waste codes are the same as it reffers to the end result from their pretreatment procedure and those waste are still packaging waste.
c) Green Dot Cyprus, according to its perrmit, is obliged to report to the competent authority each year the quantities of packaging put on the market per material (packaging waste generated) and also the quantities collected, pre-sorted and further exported/treated for the household and industrial/commercial sector.
18.3.4. Explanation of the scope and validity of surveys to collect data on the generation and treatment of packaging waste
Verification process: annual checks made by the PROs, checking differences in producer's data, a significant increase or decrease in particular material put on the market in comparison with data from previous years by a third party auditing company. No waste analysis is followed for 2022, but it is approved and programmed for 2024-2025. No surveys were used to collect data on the generation and treatment of packaging waste. Data were collected directly from EPR schemes reports, waste operators and electronic registry adding our estimated data (free riders, on line sales, private imports).
18.3.5. Explanation of the scope and validity of surveys to collect data on reusable packaging
Data for 2022 were collected through direct questionnaires send to stakeholders for reusable packaging (based on a on-going tender document). The systems are mainly in closed - loop systems (circulated by a company) for drinks, refreshments, food and industrial gases in cylinders. With a study prepared by Eunomia for upgrading data on packaging waste (and other streams) for 2021/2022 we gather more data on reusable packaging in comparison with 2020 data and in particular data on the rotations/year .
18.3.6. Detailed description of the method to collect data in order to calculate the amount of metals separated from incineration bottom ash
Calculation of recycling of metals from incinerator bottom ash : Detailed description of the method to collect data in order to calculate the amount of metals separated from incineration bottom ash in accordance with the Commission Implementing Act adopted in accordance with Article 37(7) of Directive 2008/98/EC.
Data
Description of the measurement method to obtain the data
Total amount of metal concentrate extracted from incinerator bottom ash
Not applicable
Average level of metallic content in the total amount of metal concentrate, including the reliability of any surveys undertaken
Not applicable
Proportion of waste entering incineration plants that is packaging waste, including the reliability of any surveys undertaken
Not applicable
18.4. Data validation
The Process of monitoring the results of data compilation and ensuring the quality of the statistical results is described int he following sections 18.4.1-18.4.5.
18.4.1. Detailed description of the system for quality control and traceability for packaging waste pursuant to Article 6a(3) and (8) of Directive 94/62/EC
Data for recycled packaging waste are gathered through documents submitted from the pre-sorting facilities in Cyprus showing the course of the waste and the details of the final destination (Annex VII of Regulation 1013(I)/2006, Bill of lading, other custom documents). Waste are send abroad/ exported for final recycling to other member states and third countries.
Local pre-sorting units sending their waste abroad, must also demand and keep further documentation from treatment units abroad, in order to submit to the competent autority the required information on the specific measurement point used for each waste stream. The treatment units (mostly in European Union) can proof that they operate "in broadly equivalent conditions", having a permit, being inspected and having the obligation for record keeping, but this needs further cross-checks and guidance, in order to collect all the information/data needed also from recycling facilities in third countries.A list for treatment units abroad is being prepared (from end 2023- 2024) to cross check their details and ability for final treatment of waste.The reporting of waste collected, sorted and treated is obligatory yearly through their waste management permits.
To further ensure the reliability and accuracy of the data gathered on recycled packaging waste, the Department of Environment has set up an electronic registry for the facilities (operating in CY), to report and submit their data.
The ALR's is applied for 2022 per material according to Admixture (imputirities) Percentage provided by the Green Dot system, as reported in their annual report, for waste after sorting that are send abroad for final treatment.
18.4.2. Traceability of waste treated outside the member State and ensuring its treatment in conditions broadly equivalent to the requirements of EU environmental law
Packaging waste material
Subject to final treatment in the Member State (yes/no)
Shipped to another EU Member State (yes/no)
Exported outside the EU (yes/no)
Description of specific measures for quality control and traceability of packaging waste, in particularly as regards monitoring and validation of data
Plastic
no
yes
yes
Checks for the data reported to the competent authority (sumbission of documents - Bill of lading, Annex VII for transboundary movement, customs documents) No final treatment in Cyprus this year
Wood
yes
no
no
Inpections of the facilities for the final treatment procedure and relevant documents as final treatment is in Cyprus
Ferrous metals
no
yes
yes
Checks for the data reported to the competent authority (sumbission of documents- Bill of lading, Annex VII for transboundary movement, customs documents)
Aluminium
no
yes
yes
Checks for the data reported to the competent authority (sumbission of documents - Bill of lading, Annex VII for transboundary movement, customs documents)
Glass
yes
no
no
Inpections of the facilities for the final treatment procedure and relevant documents as final treatment is in Cyprus
Paper and cardboard
no
yes
yes
Checks for the data reported to the competent authority (sumbission of documents - Bill of lading, Annex VII for transboundary movement, customs documents)
Others
no
no
no
no
18.4.3. Description of measures to ensure broadly equivalent waste treatment
The recycling facilities submit to the competent authority all the necessary documents for checks, according to Regulation N.1013/2006 as described above.
18.4.4. Verification of data on packaging waste generated
The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.
Packaging waste material
Cross-check (yes/no)
Time-series check (yes/no)
Audit (yes/no)
Verification process
Plastic
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
Wood
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
Ferrous metals
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
Aluminium
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
Glass
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
Paper and cardboard
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
Others
no
no
yes
It is mandatory in Green Dot's permit to conduct yearly audits for a sample of 5% of the total quantities (tonnes) that producers (members of GD) put on the market for each packaging material, using also economic statements for each company. Each audit takes place by an independent third party audit company and it is conducted following the International Standards on Auditing or the Interantional Standards on Review Engagements.
18.4.5. Verification of data on packaging waste recycling
The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.
Packaging waste material
Cross-check (yes/no)
Time-series check (yes/no)
Audit (yes/no)
Verification process
Plastic and Paper
no
yes
yes
For all packaging waste material: the Department of Environmnent has a database (documents for each company) with copies of all the exports/tranfer of waste to other MS or third countries. Documents include information on data per code of waste, per waste operator, the recycling units abroad that treats waste into final product yearly. Recently an electronic registry is established with sumbission of data per code of waste by each units
Wood
no
yes
yes
For all waste: Each waste operator is licensed by the competent authority to manage specific waste streams. Τhe DoE inspectors perform regular inspection (min once a year) to the pre-sorting facilities, checking relevant documents that can reassures the recycling. If non-compliance is identified a letter of warning is send asking them to take corrective measures. Also facilities send exports documents for industrial commerecial packaging waste, every 3 months, to the competent authority for checks and approval in order to get financial motive from the Green Dot system.
Ferrous metals
no
yes
yes
As above
Aluminium
no
yes
yes
As above
Mixed waste
no
yes
yes
As above
Others
no
yes
yes
As above
18.5. Data compilation
Operations performed on data to derive new information according to a given set of rules are described in the followinf sections 18.5.1-.18.5.6
18.5.1. Methods for determining packaging waste generation
Approach
% of waste generated based on this approach
Approach 1 Put on the Market (POM) based on EPR data, complemented with estimates to ensure full coverage of the EPR data
100%
Approach 2 POM based on sources other than EPR (e.g. based on production and import statistics and factors to estimate the amount of packaging associated to these product flows)
Not applicable
Approach 3 Waste analysis
Not applicable
Other approaches :
Not applicable
18.5.1.1. Approach 1 - Put on the Market (POM) based on EPR
Primary sources and their shares in the total.
Sources for calculation of PoM
% of packaging total covered
Threshold of this source(*)
Total
Plastic
Wood
Ferrous metals
Aluminium
Glass
Paper and Cardboard
Other
EPR scheme data
85,6
85,8
85,8
80,9
85,8
85,8
85,6
0
No threshold de minimis set for reporting (a limit for a de-minimis of 2 tonnes/y/producer was removed from legislation in 2017)
Administrative reporting different from EPR
0,2
0,05
0
4,9
0
0
0,2
0
from 5 individual management schemes
Surveys
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Electronic registry:
1,2
1,2
1,2
1,2
1,2
1,2
1,2
0
small producers not registered in Green dot, only listed in catalogues of the Department of Environment
Other :
13,0
13,0
13,0
13,0
13,0
13,0
13,0
0
imports/on-line sales/other
(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered
18.5.1.2. Approach 2 - Put on the market (POM) calculated from production and reign trade statistics and using coefficients of packaging for the sold goods in question
Primary sources and their shares in the total.
Sources for calculation of PoM
% of packaging total covered
Threshold of this source(*)
Total
Plastic
Wood
Ferrous metals
Aluminium
Glass
Paper and Cardboard
Other
Production statistics
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Foreign trade statistics
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Specific surveys :
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Electronic registry :
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Other :
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered
18.5.1.3. Approach 3 - Waste analysis
Packaging waste generated estimated by waste analysis
Type of waste
Number of samples taken
Total volume or weight of samples taken
What proportion does the sample represent of the total waste generated (in %)
Frequency of sample
Volume in cubic metres
Weight in tonnes
Mixed household and similar waste
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Separately collected municipal waste
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Separately collected business waste
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Others :
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
18.5.2. Information on estimates for packaging placed on the market
a) For smaller producers, not registered in the Green Dot (EPR Scheme) (part of the free riders), estimations were made using the assumption that these producers put 2 tonnes/year/producer on the market each, as this assumption was followed int the previous years. These producers are listed in the Department of Environment 's catalogues, representing only a small percentage of the market (about 1,2%). All producers are obliged now to be part of a collective managenment scheme or to create their own individual and report their quantitative data to the system (no threshold/de minimis is set in the legislation).
b) There are also quantities of packaging put on the market that cannot be traced or directly counted from various sources and which are not reported (eg. private imports, on- line sales, new companies, unknow free riders). Custom offices, in 2022, agreed to give information to the Department of Environment about the companies (producers) importing packaged products. In this way we can contact and notify them about their obligations, in order to follow procedures for their compliance. All producers in the future will be obliged to be registered in an electronic registry having ideally one unique number to use in order to complete their imports.
For these data, an assumption is made, in 2022 adding to all materials put on the market an extra 15% , in comparison with previous years that different percentages for free riders were added to each material, depended on the market trend . For the market trend two years were compared (eg. 2020 and 2021 to find the extra percentages for free riders for each material put on the market). For 2022 this was not possible as there was a fluctation on the quantities put on the market by Green Dot ( 2020 - 76105t, 2021- 70908t and 2022- 76966 t) as this will indicate a negative percentage for free riders . In addition a suggestion of adding 20% per material put on the market by the free riders were proposed in the report of Green Dot for 2022 and the Eunomia study fro 2022 . Last, due to the early warning report and the observation that we might submit underestimated data for the generation of packaging waste (put on the market) we decided to add an extra 15% to all the materials put on the market.
These are estimates as no waste analysis has been carried out in 2022 to determine the actual extra percentage for free riders. A waste analysis is planned for late 2024- 2025 for municipal waste generation that will indicate also packaging put on the market. The suggestion of Green Dot and Eunomia study for for adding an extra 20% to each material put on the market by producers is rather high and will be further evaluated better with the waste analysis aproach.
c) For tetrapack we used the assumption based on bibliography, that these waste can be split per material in the following percentages for tetrapak: 75% paper, 20% plastic and 5% aluminium adding them to the corresponding material. Green Dot Cyprus for the category of "others",has stated them in total and then splitted them further and incorporated them into the categories for each material, so no "other" material was stated separately. This is an improvement as "others" should be categories not reported before as a packaging material (paper. plastic, metal, glass,wood).
18.5.3. Presence and calculation of estimates and indication of added volume in % of the total
Packaging waste material
Total
Plastic
Wood
Ferrous metals
Aluminium
Glass
Paper and Cardboard
Other
Validation
Corrections for underreporting of units covered by the above sources
yes 1,4%
yes 1,25%
yes 1,2%
yes 6,1%
yes 1,2%
yes 1,2%
yes 1,4%
No
Estimates for units below the threshold (de minimis)
No
No
No
No
No
No
No
No
Estimates for other units legally exempt from reporting
No
No
No
No
No
No
No
No
Estimates for freeriders
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
No
Private imports /exports by private parcels
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
No
Private imports /exports (from journeys)
No
No
No
No
No
No
No
No
Internet imports and exports i.e. on-line sales
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
yes 4,3%
No
Other corrections
No
No
No
No
No
No
No
No
18.5.4. Measurement points for recycling applied
Packaging waste material
Description of measurement points used (at calculation point or at the output of sorting operation with subtraction of non-target materials as appropriate, end-of-waste criteria, etc.), including variation at regional and local level
Plastic
at the output of sorting operation (mainly exported to another MS/outside of the EU) + at the calculation point when treated in CY (limited amounts of packaging waste comparing to export) for the production of plastic products (for 2022 no treatment was possible in CY)
Wood
at calculation point (sorted wood after reconditioned/repairing of wooden pallets and shredding into shawdust and used for composting purposes in land)
Ferrous metals
at the output of sorting operation of metals (exported to another MS/outside of the EU for final treatment entering a metal smelter)
Aluminium
at the output of sorting operation of metals (exported to another MS/outside of the EU for final treatment entering a metal smelter)
Glass
at calculation point (sorted glass that does not undergo further processing before entering a glass furnace for the production procedure of cement in a cement kiln)
Paper and cardboard
at the output of sorting operation (exported to another MS/outside of the EU for final treatment)
Others
divided to the previous categories as reported by Green Dot Cyprus
18.5.4.1. Detailed description of the methodology to calculate the amount of non-target materials removed between the measurement and the calculation points, where applicable
The total sorting plant input (weight of material received at the recycling/treatment plant ) is used as a measurement point, as the amount of material accepted by the re-processing plant with deduction of residuals reported in Cyprus. Non-packaging material are removed before sending the materials abroad during the pre-sorting procedure. Information about any other non -targeted material removed or moisture when received abroad is difficult to be obtained by treatment units abroad that cannot provide directly to the competent authority this information. Electronic registry of waste (ERW), annual reports of recycling companies, electronic reporting to the PROs, and data of export (copies, Annex VII and bill of lading) to the competent authority can provide details on the the weight of material at the output of the sorting operation, that further are send abroad for final treatment. The weight of material at the input to the recycling operation abroad with deduction of admixture (impurities) output reported in Cyprus is the quantities recycled/treated and used as a calculation point.
More details on the calculation points locally (CY) for the specific materials are the following : 1) Plastics: one company uses plastic for the production of insulated products eg. for roof and wall panels and another company produces plastic products but none of them reported any packaging data for 2022. A third company was operating the previous years producing pellets but it is now closed 2) Wood: the wood is sorted and cleaned for the re-condition and repairing of it. 3) Glass: the glass is sorted, after removing any impurities or other materials, before entering a glass furnace for the production procedure of cement. For all the other materials before sending them abroad for further and final treatment, they are pre -sorted in categories, removing any impurities or other non-targeted materials.
As informed by the Green Dot system, an analysis and sampling control of the sorted material takes places at the pre- sorting units to check the quality of the material and the effectiveness of the sorting. Due to the limited amounts of materials, the sorting takes place mostly by hand, but the average percentage of cleanness of the output of material is estimated at 96,7% . The admixture (impurities) output percentage is deducted from the total of each waste stream exported abroad to third countries or transfered to other MS (ALRs). Below you can see the percentages per material as calculated in the analysis and sampling control. Then an average deduction percentage is estimated and combined per material to find the average per material Plastic (PET+PE/PP+FILM+20%plastic from TETRAPACK (below)/4 = 3,0275% deduction of total), steel (FE below=3,04% deduction of total),aluminium (Aluminium + 5% tetrapack (below)/2 =1,06125 % deduction of total) and paper (OCC+75%TETRAPAK (below)/2= 3,21875% deduction of total). No analytical data per category per material (eg. PE. PET, PP etc.) for all pre -sorting unit is available but only for some, so the deduction rates were estimated as average per material.
Material - CleanessPercentages - Admixture (imputirities) Percentage PET 97,91% 2,08%
PE/PP 97,71% 2,29%
FE 96,96% 3,04%
ALUMINIUM 98,19% 1,81%
MIXED PAPER 97,65% 2,35%
OCC 98,25% 1,75%
FILM 93,51% 6,49%
Tetra Pak 93,75% 6,25%
18.5.4.2. Detailed description of how compostable packaging recovered at biowaste treatment plants has been identified and recorded in the data
Not applicable
18.5.5. Methodology to determine recycled amounts from composite packaging or packaging composed of multiple materials
Tetrapak is a composite packaging (paper, plastic and aluminium film) and according to the bibliography references is consisted in 75% paper, 20% plastic and 5% aluminium. No recent quantification analysis/survey for the composition of products from multible materials placed on the market was conducted. Green Dot system (PRO) reports now their data for tetrapack disributed in the other categories for waste packaging materials.
18.5.6. Use of Average Loss rates (ALRS)
Description of the sorted packaging waste to which ALRs are applied, types of sorting plants to which different ALRs apply, the methodological approach to calculating ALRs at such point(s), including the statistical accuracy of any surveys used, or the nature of any technical specifications.
Sorted waste material and sorting plant type
ALR applied (in %)
Description
For ALRs in 2022 for sorted waste material or sorting plant type a deduction percentage was applied in the total quantities of each material send abroad or transfer to EE as no other reliable data are available on material losses before the calculation point, in the context of shipment and export of waste.
as explained in question 18.5.4. and 18.5.4.1
CY as explained in question 18.5.4. and 18.5.4.1 applied ALRs at the different outputs of sorting processes as our waste are mainly exported for further and final treatment, not being able to have reliable and analytical data on losses from the actual operators in the receiving country.
18.6. Adjustment
No adjustments were made , only the ALR was applied.
18.6.1. Adjustment for impurities and humidity
Factors
Total
Plastic
Wood
Ferrous metals
Aluminium
Glass
Paper and Cardboard
Other
Correction factors for impurities and humidity in % of waste
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
How the correction factors are derived
Not applicable
If no correction of impurities and humidity is applied, how they are accounted
No correction factor is applies only the ALR
18.6.2. Attribution of waste to packaging and non-packaging types and correction for humidity
Description, where applicable, of the methodology to exclude non-packaging waste from the reported amount of recycled packaging waste and of the methodology to correct the amount of packaging waste at the measurement point in order to reflect the natural humidity rate of packaging (including by using relevant European standards). Aggregated data across facilities of a similar type is acceptable.
Packaging waste material
Facility type
Share of packaging waste (%)
Description of the methodologies applied to obtain the percentage
Paper
Sorting into different categories of paper (OCC, NCC, non packaging), removing materials and impurities, shredding, pressing into bales, export/transfer to third countries and MS
54,1%
Actual reported data to the competent authority (sumbission of documents-Bill of lading, Annex VII for transboundary movement, customs documents and electronic registry)
Plastic
Mainly sorting into different categories of plastic, removing materials and impurities, shredding, pressing into bales, export/transfer to third countries and MS
13,8%
Actual reported data to the competent authority (sumbission of documents-Bill of lading, Annex VII for transboundary movement, customs documents and electronic registry)
Glass
Collection, sorting and cleaning glass from impurities and residuals, usage in the production procedure of cement and usage in quarries in CY
15,7%
Actual reported data to the competent authority (for glass treated only in CY, documents include quantities received and treated
Metal
Sorting into different categories of metals removing materials and impurities, pressing into bales, export/transfer to third countries and MS for smelting
16,4%
Actual reported data to the competent authority (sumbission of documents-Bill of lading, Annex VII for transboundary movement, customs documents)
Wood
Collection,shredding into shawdust and used for composting purposes in land and also repairing wooden pallets
0,05%
Actual reported data to the competent authority and EPR for local recycling as shawdust (wood treated and repaired in CY not included in the share of packaging waste %), documents include quantities received and treated
18.6.3. Attribution of waste
Description of the methodology to exclude waste originating from other countries, where applicable. Aggregated data across facilities of a similar type is acceptable.
Packaging waste material
Facility type
Share of waste from the Member State (%)
Description of the methodologies applied to obtain the percentage
No input/import of packaging waste in Cyprus from other MS, we only export/transfer waste to other third countries/MS
not applicable
not applicable
not applicable
No further comments.
We are reporting in accordance with most of the new calculation rules. Most of the packaging waste are sent after sorting for further treatment either in other MS or third countries, so there is significant difficulty in getting all the information needed for the calculation point. A deduction percentage was applied for materials (paper, plastic, aluminium and steel) exported/transferred abroad for further treatment for 2022, from data received from the Green Dot system and comparing data from the study of the Consurtium of companies Eunomia/ IACO/CHR.TSIARTA (2023) for the collection of data for 2022 prepared for the Department of Environment. We do not intend to report compliance with the old recycling targets.
The derogation to make use of average loss rates has been applied.
19 February 2025
We wish to take into account the amount of wooden packaging that is repaired for reuse in the calculation of the targets. Data are collected mainly from the EPR scheme and/or direclty from actual sources/companies repairing the wooden pallets. Repairing of wood reaches 98,5% from total recycling of wood. No assumptions have been made for the adjustment of the calculation.
No incineration takes place in order to have metals in incineration bottom ash for the calculation of the targets.
Packaging waste in CY (in tonnes)
Number of producers (put on the market = generation of waste) = ~ 2000 companies +15% free riders
Number of presorting facilities/ or facilities that export waste= 17
Cyprus
Calendar year
Accuracy on generation and treatment of packaging waste:
GENERATION
A) Data gaps :
from estimates based on a representative sample of producers (small) with PoM under 2 tonnes per year,
from free riders unknown and not registered to the Green Dot system (undereporting) - the percentage for free riders is estimated this year to 15% extra per material but this is an estimation.
inaccurate data reporting by producers to Green Dot system. This is corrected through private audits on behalf of Green Dot Cyprus,
under reporting of data specifically for metals or paper put on the market as these companies:
are not registered in Green Dot scheme as they don't consider their metal products as packaging (like barrels, cylinders etc)
are registered but they undereport data, so metal reycling is higher than 100% comparing to waste generation, as these quantities are missing or under reported. We can see that the recycling of metal waste in 2022 (10134,44 ton) exceeds the generation (7377,7ton). This phenomenom trend for metals is continous over the years and possibly leads to the following conclusions:
Metal waste recycling is greater than generation, due to temporary storage (stocks) of packaging metals as the recycling facilities expect higher prices in the market in order to sell it and export it, as they informed us. This is a continuous practice through the years and needs further investigation.
Data for recycling are reported by the pre-sorting facilities that export the waste for further treatment, presenting official documents (bill of lading, custom document, Annex VII for exports/tranfer). A reason for greater recycling than generation, would be that the facilities collect and export (transfer) metals in general (not only packaging) using a 7,5 % assumption in their total load of metals to estimate the metal packaging. The percentage is estimated emprirically, from their experience through the years. May be this percentage is high, and this can result to higher recycling than generation. There is need for a quantified study to the measurement point after the pre-sorting and before exporting, on the specific issue.
b) The actual extra percentages for private imports/exports, internet, on-line sales data might be different than those estimated in our calculations, due to lack of completed system for collecting these data. This need to be improved with setting up a new upgraded electronic registy (there is an on going tender document procedure)
c) Incomplete data concerning the reuse as the sample size for collecting the data is still small, but this will be improved over the years.
TREATMENT
d) Waste management facilities reporting data to Green Dot and to the competent authority may be different but for year 2022 there was cross ckecking and correction of data in co-operation of competent authority and Green Dot. Particularly for industrial/commercial packaging waste, quantities and relevant documents must be reported firstly to the competent authority by the waste management facilities and after approvall, these data can be reported to Green Dot in order to get a financial incentive. Cross - checking of the various data submitted by a waste treatment facility in order to report the actual value of tonnages in our calculation is done by direct communication with the facility operators comparing and correcting them with Green Dot's data. The data for waste management facilities are also verified through the waste export documents sumbitted and recently through the electonic registry of waste, of the Department of Environment and this year from the on going study from the consortium Eunomia/IACO/Chr.Tsiarta for gathering data for 2022.
Concerning the data reported from waste management facilities, the completeness of data provided can be reassured as all companies are registered and are subject to permitting and regular inspection. The information from the export documents, reassures the tones of packaging treated abroad. Inspections take place regularly to reassure and monitor the packaging waste collected, separated and treated, in waste management facilities in Cyprus. Errors might occured, as some companies reports packaging (category 15, according to the list of waste) with a different code of waste in exports like municipal (category 20 or 19 , according to the list of waste ) or vice versa. Some companies did not responded to submision of data for 2022 and various sources were use to get the data.
e) ALR's calculation needs improvement and cross checking.This year ALR's is used from Green Dot's data as the on-going study suggested different ALRs with very high percentage for plastic (45%) to be deducted using averages from particular systems in Europe and the usage of different sorting technologies in Europe, but this needs cross checking and further investigation for the data for the following years.
Accuracy on the completeness of data for reusable packaging is limited, due to lack of data for 2022 as the data were collected from 8 companies that were indentified to put the highest amount of reusable packaging on the market, comparing them with total data of packaging placed on the market for the frst time. Not all stakeholders reusing packaging are known and registered. The competent authority is trying to set up a registry and to gather more data on reusable packagingfor the following years.
Tonnes
Operations performed on data to derive new information according to a given set of rules are described in the followinf sections 18.5.1-.18.5.6
Data on the generation of waste are mainly collected through:
a) The Extended Producer Responsibility (EPR) scheme of Green Dot Cyprus (PROs) for packaging and packaging waste declared to be placed on the market (PoM), as packaging waste generated may be deemed to be equal to the amount of packaging placed on the market in the same year in a Member State. Data from EPR schemes were collected from each member- producer and reported to the competent authority in an annual report by the PRO for 2022. Data from the PRO are a combination of 1) analytical data per producer (category A), 2) statement of data per producer under category per tonnes (category B), 3) data for packaging of pesticides (category C) and 4) estimation of producers that did not report on time or non - compliance producers (not fulfilling their obligations).
b) Other sources for the generation of packaging waste include data from packaging put on the market by 5 individual management schemes (individual producers/companies) reported to the competent authority in an annual report.
c) Estimated data from the producers (mainly small producers- free riders(others) not registered with Green Dot Cyprus as there is no de-minimis threshold point (in 2017 a de minimis was set at 2 ton/year/producer but the legislation was amended to remove the threshold). All producers must now be registered under the Green Dot scheme and report data to them.
d) Estimated amounts of packaging associated with imports, on-line sales/trading (free riding). For exports, producers are instructed not to include these data in packaging generation in their reporting, as packaging exported and used in other counties will become waste abroad and reported in that specific MS.
e) Data sources for the preparation for reuse are collected directly through the EPR scheme (Green Dot Cyprus) for their members or/and directly from the other relevant companies reusing packaging.
Data on waste recycling, are collected:
f) from the licensed treatment (recycling) facilities of packaging waste that pre- sort packaging waste and then send them abroad for further final treatment (data from annual report and data submitted in the electronic registry of the Department of Environment) and
g) from the EPR scheme of Green Dot Cyprus (cross-check mainly for the commercial/industrial packaging waste send abroad).
For 2022 for a number of companies, data were taken direclty from an on- going study of the consortium of companies Eunomia / IACO/CHR.TSIARTA (2023) for the collection of data on packaging (and other waste streams).
Yearly
Length of time between data availability and the event or phenomenon they describe is from the end of 2022 till now (20 months)
Data are for Cyprus so no statistics are comparable between geographical areas.
1) Waste generation for 2022 was increased in comparison with waste generation in 2021, as there was an economic upgrading and prosperity , leaving behind the pandemic and economic crisis of the previous years . Also for free riders we used a different method for the calculation of free riders, adding to the total an extra percentages of 15% per material and not following the previous method in 2021 by adding various percentages per material deparnding on the trend of the market. The reason for changing the method was that it was both Green Dots report and the Eunomia study suggested a higher percentages to add for free riders reaching the20% and also the early warning report for highlighting the possibility of under estimating the waste generated. So we choose to add an extra 15% for free riders taking in mind the previous mentioned facts.
2) Green Dot Cyprus for the category of "others" has reported them in their total amount and then splitted them further and incorporated them into the categories for each material , so no quantities for "other" material was stated this year. This is an improvement as "others" should be categories not reported before as a packaging material (paper, plastic, metal, glass and wood).
3) Some data for waste treatment/ facility were used directly from the on-going study for data collected for 2022, as the facilities did not respond back and directly to the Department of Environment.
4) Differences in the total recovery of plastic packaging (increase in 2022 in comparison to 2021)
a) Recycling of plastic in CY was not available in 2022 as one of the treatment facility closed down and the others did not submitted any data on packaging. Plastic Recycling in 2022 slighlty increased due to market demand compared to 2021 data. Also the generation of plastic waste was increased in 2022 so in total the recycling was decreased .
b) For the energy recovery the recovery from plastic packaging waste increased in 2022 compared to 2021, as stated by Enerco (company for energy recovery/cement kiln) that received the sorting residue from green Dot as an RDF (was mainly plastic) and from the MDF in Limassol again as an RDF.
5) Material recycling for glass for 2022 continue to report actual quantities of glass treated in the cement kiln as in 2021, as their stock and treated quantities are now in balance in comparison with previous years. A higher recycling rate for glass was achieved in 2022 in comparison with 2021.
6)There was use of ALRs and deduction of residual percentage from waste send broad/transfer to MS for further and final treatment, from Green Dot data (not from data from the on - going study for plastic ALR's (for 2022)
Differences from previous year's data - No significant changes.
