Administration de l’environnement

Unité surveillance et d'évaluation de l'envionnement

1, avenue du Rock´n´Roll . L-4361 Esch-sur-Alzette

26 June 2025

19 September 2025

19 September 2025

LU is reporting under the new calculation rules.

In previous years, LU has collected data on ALR directly from waste processing firms recycling household packaging. With the introduction of a new EPR scheme for non-household waste, more comprehensive information will then be available for this waste stream.

Table : Institutions involved in the collection of data and distribution of tasks

The statistics are mainly based on EWC codes.

Only the R/D codes listed in Annexes I and II of Directive 2008/98/EC are used.

All sectors are covered.

We wish to take into account the amount of wooden packaging that is repaired for reuse: 70%.

We wish to take into account the amount of metals in incineration bottom ash (IBA) for the calculation of the targets.

The Hospitality and food sector uses a considerable part of reusable glass beverage bottles.
Plastic reusable bags > 50 microns are used by 74% of the consumers when they shop; half of these bags are the “Ecosac”, a national bag (EU best practice) which is implemented by a major part of the supermarkets and distributors and sold to consumers. Also, for vegetables, a national meshbag, the “Superbag” has been developed and is proposed to consumers in the same selling places.

There are currently no other major mainstreams of reusable packaging known by our administration.

The category other recovery includes the use of glass waste from incineration bottom ash.

+/- 40% of Energy Recovery that is from R1 incinerators, out of all Energy Recovery reported.

Temporary storage is not considered.

Waste handlers operating in Luxembourg.

Total LU population of waste handlers.

Entire country.

2023

Not applicable.

Tons.

Calendar year

National and european waste legisation. Directive 94/62/EC sets out the EU’s rules on managing packaging and packaging waste ( Directive 94/62/EC on packaging and packaging waste).

LU environmental legislation.

Statistics on packaging and packaging waste are in accordance with the Commission Decision 2005/270/EC.

European General Data Protection Regulation (GDPR).

No confidentiality requirement.

30 June 2025.

Not applicable.

Not applicable.

Annual.

Not applicable.

Fact sheets Valorlu.

Please find more information on this website (Dechets municipaux).

No microdata available.

Not applicable.

No documentation apart from metadata.

No documentation available.

No QA procedure.

No QA assessment.

Eurostat, other users.

Not available.

Data are complete.

LU is facing the following challenges in determining the quantities of packaging waste generated and treated:

• Manual Analysis and Approval of Reports: LU must manually analyze and approve over 1,000 reports submitted by companies transporting and treating waste. These reports often contain incorrectly attributed EWC codes and/or treatment codes, and inconsistencies occur between different years. Different EWC codes (e.g., 20 xx xx or 15 xx xx) for the same waste type can be used by the same companies in different years. These inconsistencies are flagged, and companies are asked to confirm or correct their data. This manual process is time-consuming and prone to errors.
• Inconsistent EWC Codes at Sorting Facilities: EWC codes are almost never the same at the input and output of sorting facilities, making it difficult to identify the final destination of packaging waste that was collected separately or sorted. This issue is especially pronounced in sorting facilities that process packaging alongside non-packaging waste.
• Double Counting in Waste Streams: Waste streams between waste handlers can lead to double counting. LU has developed a data analysis method to prevent double counting, but it cannot be completely excluded, requiring many manual plausibility checks.
• Unknown Final Treatment of Exported Waste: Even if waste is separately collected or sorted in LU, it can still be exported to another sorting or collection facility. In such cases, the treatment codes R12 or R13 are used, and the final treatment often remains unknown. This problem has been partly reduced with  the additional information received by the PRO from non-household PPW. For this purpose the final destinations used by collection facilities.
• Humidity and Contamination Rates: The humidity and contamination rates were only measured for plastic packaging during the last residual waste analysis. For other types of packaging, LU has used rates that were never reviewed or measured. For comparability reasons, these rates have remained unchanged over the years. In the new WCA humidity and contamination were remeasured and updates. For the remaining waste types the humidity rates remained unchanged.

Luxembourg is also facing issues affecting the collection of data on reusable packaging. Ideally, data on reusable packaging would be collected through the EPR scheme, as they are well-positioned to collect such data from their members. Currently, the EPR scheme only covers household packaging, but this is set to change to include non-household packaging. Luxembourg plans to wait until this change before conducting such a study. This study will need to be carefully planned, as companies will find it difficult to identify reusable packaging and determine factors such as rotation. Luxembourg hopes to launch this study in 2026.

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.

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.

Not applicable.

LU must manually analyze and approve over 1,000 reports submitted by companies transporting and treating waste. These reports often contain incorrectly attributed EWC codes and/or treatment codes, and inconsistencies occur between different years. Different EWC codes (e.g., 20 xx xx or 15 xx xx) for the same waste type can be used by the same companies in different years. These inconsistencies are flagged, and companies are asked to confirm or correct their data. This manual process is time-consuming and prone to errors.

12 months.

No time lag.

Not applicable.

The results of a new WCA and the data received from the PRO for non-household packaging have influenced the outcomes. The information on ALR for PPW has been included in the 2021 and 2022 submissions, which have since been resubmitted.

No cross domain analysis carried out.

No internal coherence test carried out.

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.

Not applicable.

Not applicable.

PPW calculations were recyclulated until 2021

The primary source of data is the national waste database, which receives yearly reports from waste handlers operating in Luxembourg. The second one is data received from the PRO's

The waste samples for waste analysis are taken from:

Annual collection of waste quanitities, every 3 years residual waste analysis.

Waste handlers are required to submit on a annual basis the amount and type of waste transported, sorted or transported.

• The distinction between non-packaging waste and packaging waste collected together was mainly done using the EWC codes used by waste handlers and collectors. For certain fractions, such as mixed packaging waste (15 01 06) or paper and cardboard waste (20 01 01), waste analysis was carried out. For all other fractions, estimates were used.
• The packaging materials in mixed waste streams from households are based on the results of waste analysis. The packaging waste contained in non-household waste is also based on a residual waste analysis.

Drink cartons are reported as 70% paperboard, 20% plastic and 5% aluminium. However, the waste analysis only distinguishes between drink cartons and composite packaging, for which the composition is unknown. For the 2023 reporting, LU assumed that composite packaging in residual waste contained 40% paperboard and 53% plastic and 7% aluminium. LU will work to improve data on this point and has already collected data on crips pakets, drink pouches and coffee bags. This is however not yet sufficient to cover all composite packaging. For EWC fraction 150110, the distinction between plastic and metal packaging was made based on the treatment code (R03 for plastic and R04 for metal).

Additional information about the methodology, including the combination of methods used:

The determination of waste flows relies entirely on the annual data provided by waste handlers in Luxembourg. Within these waste flows, the identification of packaging waste is established through the utilisation of EWC codes and waste analysis. ALR have been provided by the EPR scheme for the houseshold packaging.

Please find more information at this website (Dechets municipaux).

No surveys were carried out.

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.

Manual.

According to the revised national waste law of March 21, 2012, the export of waste intended for recovery to non-European Union countries is prohibited, except under special permit. Such export had already been prohibited under the modified waste management law of June 17, 1994, which was in effect prior to the 2012 law. Furthermore, the export restriction and notification procedures outlined in regulation (EC) 1013/2006 of the European Parliament and Council are also applicable in addition to the export prohibition outlined in the 2012 waste management law.

Illegal shipments are detected through road checks which are carried out regularly. Administrative and physical checks related to shipments of waste can also be part of other inspections, e.g. IED.

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.

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.

Manual.

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered 

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered

Packaging waste generated estimated by waste analysis

Based on waste analysis and partly on PoM for non-household

Measurements are made at the output of the sorting facility, ensuring that non-target materials are not missed or double counted. The contamination (impurities) and humidity rate of the waste at the output of the sorting plant are estimated. It is assumed that these impurities, which are removed at the recycling plant, are not recycled.

Compostable packaging treated in biowaste treatment plants have not been considered.

The assumption is made that for all separately collected packaging, the proportion of different materials is less than 5%. This assumption is applicable to cardboard packaging, drink bottles, and cans. However, it is important to note that composite packaging, such as packaging used for food, excluding beverage cartons, is not collected separately in Luxembourg.

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.

Only adjustments for impurities and humidity.

In mixed waste.

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.

Description of the methodology to exclude waste originating from other countries, where applicable. Aggregated data across facilities of a similar type is acceptable.

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