EU Waste Early Warning Report: Guide for Businesses

The European Commission is preparing its next Waste Early Warning Report, an EU-level assessment designed to identify Member States that may be at risk of missing upcoming waste-management targets.

A new Call for Evidence, dated 28 September 2026, sets out the Commission's planned approach. The initiative is expected to result in a report to the Council and European Parliament, with indicative publication in Q4 2027. The Commission makes clear that both the timing and final content remain subject to change.

For businesses, the key point is equally important: this is not a new waste regulation and it does not itself introduce new compliance obligations.

Instead, the initiative assesses whether EU Member States are positioned to achieve existing targets covering municipal waste, packaging waste, food waste and landfilling. Member States considered at risk will be identified and may receive recommendations intended to improve their performance.

That makes the initiative particularly relevant to companies managing packaging, Extended Producer Responsibility (EPR), waste data, supplier information and circular-economy obligations across EU markets.

The Early Warning Report, or EWR, is part of the EU's mechanism for checking progress before important waste-policy deadlines arrive.

The European Commission's official implementation guidance explains that the Commission, supported by the European Environment Agency, is required to prepare early warning reports ahead of recycling and landfilling target years.

The forthcoming assessment will focus specifically on Member States' prospects for achieving:

The Commission intends to identify countries that appear at risk and provide recommendations for improving waste-management performance and sharing effective practices.

This creates an early intervention mechanism rather than waiting until the target year to determine whether a Member State has succeeded or failed.

EU waste performance continues to differ substantially between Member States.

The Commission's Call for Evidence states that EU waste generation did not decrease between 2010 and 2022 and notes that, although economic growth and waste generation have become relatively decoupled in parts of Europe, the EU remains off track in relation to its broader objective of reducing waste generation.

The document also cites Eurostat data indicating that in 2023 approximately 40% of municipal waste and 64% of packaging waste was recycled, with considerable differences between individual Member States.

Municipal waste recycling rates cited in the document ranged from around 12% to more than 63%, while packaging waste recycling ranged from approximately 30% to more than 80%. The document also points to insufficient progress on reducing food waste.

The figures demonstrate why EU-level performance cannot be assessed solely through an overall average. National infrastructure, collection systems, recycling capacity, policy implementation and enforcement can produce very different results across markets.

The 2023 Early Warning Report provides useful context for what the next assessment may examine.

According to the new Commission document, eight Member States were considered at risk of missing the municipal waste target:

Estonia, Finland, France, Ireland, Latvia, Portugal, Spain and Sweden.

A further ten were considered at risk of missing both municipal waste and overall packaging waste targets:

Bulgaria, Croatia, Cyprus, Greece, Hungary, Lithuania, Malta, Poland, Romania and Slovakia.

The Commission's 2023 communication similarly identified 18 Member States at risk of missing one or both of the relevant 2025 municipal and packaging waste targets.

Businesses should not assume that the same countries will receive the same assessment in 2027. The forthcoming evaluation will use newer information and will focus on later target periods.

The European Environment Agency, supported by its European Topic Centre on Circular Economy and Resource Use, has developed the methodology used to examine national performance.

According to the Call for Evidence, the assessment will use quantitative and qualitative success and risk criteria based on 2024 data to evaluate Member States' prospects of reaching the 2030 recycling targets and 2035 landfill target.

Countries identified as being at risk are expected to receive more detailed treatment.

The final report is intended to contain:

• identification of Member States at risk of missing relevant targets;
• assessment of national waste-management performance;
• general recommendations;
• country-specific recommendations; and
• dedicated annexes for Member States considered at risk.

The purpose is therefore not merely to publish a ranking of recycling performance. It is to identify gaps early enough for Member States to implement corrective measures before the deadlines arrive.

Is the Call for Evidence a New Compliance Requirement?

No.

This distinction is essential for businesses interpreting regulatory news.

The European Commission explicitly states that the initiative does not introduce new policy objectives. Its role is to support Member States in meeting targets already established through EU waste legislation.

The Commission also states that no impact assessment will be undertaken because the initiative is not a legislative proposal and does not introduce new policy choices.

Companies should therefore avoid describing the Call for Evidence itself as a new regulation, legal deadline or new producer obligation.

Its importance comes from what may follow at national implementation level.

Where weaknesses are identified, Member States may need to improve collection systems, recycling infrastructure, waste prevention measures, reporting practices or other aspects of implementation to improve progress toward the existing targets.

For manufacturers and sellers, the resulting policy response could indirectly increase the importance of accurate packaging, EPR and waste-related information.

The direct subject of the report is Member State performance, but waste legislation is implemented through systems that depend heavily on economic operators.

Manufacturers, importers, distributors, brand owners and online sellers may already be responsible for activities such as producer registration, packaging classification, quantity reporting, evidence retention and financing waste-management systems under applicable national and EU frameworks.

For example, ComplyMarket's current EPR compliance guidance describes EPR management as involving regulatory applicability, producer information, quantity and category data, supporting evidence, jurisdiction-specific marketability and ongoing change monitoring.

The Waste Early Warning Report does not create those responsibilities. However, a stronger policy focus on waste-target performance makes high-quality underlying data increasingly important.

Businesses do not need to wait for the 2027 report to improve their readiness.

The most useful approach is to establish a controlled data and compliance structure now so that regulatory changes can be incorporated without rebuilding the entire process.

1. Map the Markets Where Products Are Sold

Start by identifying every EU Member State in which products or packaged products are placed on the market.

Do not manage EU waste compliance as a single undifferentiated requirement. National registration, reporting and implementation structures can differ even where the underlying framework comes from EU legislation.

A controlled market map should connect:

product → packaging → legal entity → market → applicable obligation.

This provides the basis for determining where EPR, registration, reporting or other waste-related requirements may apply.

2. Build a Controlled Packaging Inventory

A business should be able to identify the packaging associated with each relevant product or SKU.

Depending on the product and compliance scope, useful data can include packaging type, component, material, weight, supplier, country and product relationship.

The objective is to avoid repeatedly collecting the same information whenever reporting requirements change.

A structured packaging dataset can also support broader PPWR and EPR workflows. ComplyMarket's published packaging guidance similarly emphasizes the importance of structured packaging and reporting information for companies operating under evolving EU requirements.

3. Determine Producer Responsibility by Market

Companies should identify which entity carries the relevant responsibility in each jurisdiction and sales scenario.

This exercise should consider manufacturers, importers, distributors, brand owners, retailers and distance sellers where relevant.

Responsibility should not be assigned based simply on who physically manufactures packaging.

Instead, businesses should document their conclusion and retain the evidence supporting it.

4. Connect Waste Requirements to Actual Products

Regulatory intelligence becomes far more useful when requirements can be connected directly to products, markets and business activities.

A regulatory library alone does not answer the operational question:

Which requirement applies to which product in which country?

ComplyMarket's product regulatory compliance structure is designed around linking legislation, requirements, products, evidence, marketability and warnings rather than maintaining regulations as isolated documents.

This type of applicability structure becomes particularly useful when national implementation measures change.

5. Centralize Registration and Reporting Evidence

Compliance records should not remain scattered across employee inboxes, spreadsheets and local folders.

A central evidence structure can contain, where applicable:

registration numbers, producer records, declarations, submitted reports, supporting calculations, supplier evidence, correspondence and approval history.

The aim is traceability.

When information changes, compliance teams should be able to determine which products, countries and reporting processes are affected.

6. Establish Data Ownership

Waste and EPR compliance frequently crosses several departments.

Procurement may own supplier information.

Engineering may know packaging specifications.

Sales knows where products are placed on the market.

Finance may hold quantities.

Compliance understands regulatory applicability.

Sustainability teams may manage circular-economy reporting.

Without clear ownership, reporting problems often become data-governance problems.

Define who owns each dataset, who validates it and who approves information before regulatory reporting.

7. Introduce Change Management

Packaging specifications, suppliers, product portfolios and sales markets change continuously.

Compliance data should change with them.

A defined workflow should trigger review when, for example:

• packaging materials change;
• component weight changes;
• a new supplier is introduced;
• a new EU market is entered;
• a product is discontinued;
• producer details change; or
• new regulatory requirements become applicable.

Continuous change management is more reliable than rebuilding compliance information shortly before a reporting deadline.

8. Monitor the 2027 Early Warning Report

The Commission currently indicates Q4 2027 for the Waste Early Warning Report, although it explicitly notes that the timetable may change.

Once published, companies should review:

which Member States are identified as at risk, which waste streams are highlighted, what national weaknesses are identified and what corrective recommendations are proposed.

This can help regulatory and sustainability teams determine where national policy changes may deserve closer monitoring.

One of the biggest risks in regulatory monitoring is turning an early-stage policy initiative into a claim about a legal obligation that does not yet exist.

Companies should therefore distinguish between three separate layers:

Existing legislation — obligations that already apply.

Early Warning Report — the Commission's assessment of whether Member States can meet existing waste targets.

Possible national responses — future implementation or enforcement measures that Member States may adopt to improve performance.

Keeping these categories separate prevents unnecessary compliance work while still allowing businesses to prepare for meaningful changes.

The Call for Evidence is also intended to collect feedback.

The Commission wants information about implementation challenges within Member States and views on measures that could improve waste-management performance.

The consultation is particularly interested in measures supporting areas such as waste prevention, separate collection, sorting and recycling.

For relevant businesses, industry groups and other stakeholders, this creates an opportunity to provide practical information about barriers affecting implementation.

Useful evidence may include operational challenges, data limitations or implementation issues, but submissions should be based on documented experience rather than assumptions.

Before the next EU Waste Early Warning Report, compliance teams should be able to answer the following questions:

The purpose is not simply to prepare for one Commission report.

It is to build a compliance system capable of responding to regulatory change without repeatedly reconstructing data from scratch.

When will the next EU Waste Early Warning Report be published?

The Commission's Call for Evidence currently gives Q4 2027 as the indicative timing. The document also states that the timetable is subject to change. 090166e5341e8c96

Does the initiative create new obligations for companies?

No. The Commission explicitly states that the initiative introduces no new policy objectives and is not a legislative proposal.

Which waste areas will the report examine?

The initiative covers municipal waste, packaging waste, food waste and landfilling, including progress toward 2030 and 2035 targets.

Why should companies monitor it?

The report may identify weaknesses in national implementation and recommend corrective measures. Businesses operating across affected waste and packaging frameworks should therefore monitor subsequent national policy and enforcement developments.

Preparing for evolving EU waste requirements requires more than monitoring regulatory headlines. Companies need structured regulatory information, product and packaging data, evidence and clear responsibility across multiple markets.

ComplyMarket supports this through an integrated compliance-management approach.

The platform's EPR capabilities are designed to help companies maintain producer and stream-specific data, manage applicable regulatory requirements, organize quantity and classification information, collect supporting evidence, assess jurisdiction-level readiness and monitor missing or expired compliance evidence.

ComplyMarket's broader Product Compliance Management environment also connects legislation and standards with applicable requirements, product compliance status, supporting evidence, marketability and warnings.

For manufacturers, importers, distributors and online sellers operating across several EU markets, this can help create a more controlled approach to:

• monitoring waste and EPR regulatory requirements;
• mapping requirements to products and jurisdictions;
• maintaining packaging and supplier information;
• centralizing compliance documents and evidence;
• supporting EPR reporting workflows;
• identifying missing or expired evidence;
• maintaining audit-ready traceability; and
• preparing for regulatory changes across markets.

The EU Waste Early Warning Report should therefore be viewed as a regulatory signal to monitor rather than a new corporate compliance requirement.

Its broader message is clear: progress toward 2030 and 2035 waste targets is being closely assessed, and Member States that are falling behind may need to strengthen implementation.

For businesses, the most effective response is not to wait for those changes. It is to establish reliable product, packaging, market and evidence structures now so future requirements can be identified, assessed and implemented efficiently.