International comparative study of 3R and waste management policy developments

Table 1 shows the waste management policy frameworks in the EU and the five countries. Driven by global environmental problems and the depletion of natural resources, the major focus of waste management policies changed during the late twentieth and early twenty-first centuries. Formerly, the focus was on promoting environmentally sound waste treatment to avoid local environmental pollution, whereas policies have shifted to pursue the concept of sustainability by introducing and promoting 3R policies.

Under the Pollution Prevention Act, the 2010–2014 Strategic Plan is currently being drawn up. According to a draft, the purposes of the plan are to (1) reduce greenhouse gas (GHG) emissions, (2) reduce the manufacture and use of hazardous substances, (3) decrease the use of water, (4) create effective business activities, and (5) develop institutions and integrate established practices for pollution protection. The draft also states that achievement of the first four goals will result in co-benefits [1].

The Resource Conservation Challenge is a program complementary to the RCRA and Pollution Prevention Act. It aims to prevent pollution and promote reuse and recycling, reduce the use of hazardous chemicals, and conserve energy and resources. Its action plan sets MSW recycling targets [2].

The US Environmental Protection Agency (EPA) is also currently working on amending the EPA Strategic Plan. According to the draft, they will shift the political priority from waste management to resource management as a strategy to reduce GHG emissions [3].

Waste management policy in the USA is currently integrated and includes measures to reduce GHG emissions, manage hazardous chemicals, and conserve natural resources.

EU In the EU, the Waste Framework Directive (2008) [4] has been established as the basic waste management legislation, and EU Member States have implemented domestic laws on waste management under this directive. The most notable characteristic of the EU’s waste management system is the promotion of 3R policies in parallel with waste management regulations. The Directive on the Incineration of Waste (2000) and the Directive on the Landfill of Waste (1999) concern waste management. The Directive on the Incineration of Waste primarily sets standards for the application of best available techniques/best environmental practice (BAT/BEP) for environmental conservation, and it has had a notable effect in reducing dioxin emissions. The Directive on the Landfill of Waste sets standards for a tiered reduction of the disposal of wastes containing organic materials at final disposal sites (i.e., landfills). To reduce the amount of wastes for final disposal, the directive has promoted the introduction of 3R policies [5, 6]. The Directive on Waste Electrical and Electronic Equipment (WEEE) and the Directive on Restriction of Hazardous Substances (RoHS) were established in 2002 for the purpose of promoting sound material recycling and preventing pollution from the hazardous chemicals contained in such wastes. WEEE recycling has been promoted through the introduction and use of WEEE collection points. The extended producer responsibility (EPR), which requires that a producer of products manages them through reuse, recycling, and disposal even after their useful life and must develop and produce products that are easy to reuse and recycle, was applied to the basic concepts for the development of 3R policies for WEEE and packaging. Germany was the first country within the EU to apply EPR to packaging waste, in 1992 [7], and that was followed by legislation on collecting and recycling of end-of-life vehicles (ELV) and waste batteries.

Although EPR is recognized as an important concept in the UK, its waste management policy is based on the principle of shared responsibility which presupposes that the responsibility for production of a product, circulation, consumption, disposal, and recycling is shared by everyone [8]. The government has signed a voluntary agreement with industry to reduce wastes and promote recycling of packaging materials, food, and paper. The UK introduced a landfill tax, which is currently 40 GBP/t and will increase by 8 GBP annually to 72 GBP/t in 2013. Italy has introduced economic measures through a unit-based fee system whereby a management fee in paid according to the quantity of waste to discharge to encourage better waste management, and about 15% of municipalities, or 29% of Italy’s population, currently are covered by this type of system [9].

Japan The basic law for establishing a Material Cycles Society (2000) defines recyclable resources and states the principles for their utilization [10]. The law has the goal of a society wherein the consumption of natural resources is restrained and the environmental load is reduced as far as possible, through promotion of the 3R as well as the environmentally sound waste management. The law set quantitative targets for three indicators: resource productivity, cyclical use rate, and final disposal amount. These goals have also been pursued on a global scale through the Group of Eight (G8) process known as the 3R initiative. The basic legislation concerning waste management in Japan consists of the Waste Disposal and Public Cleansing Law (amended in 2010), which is the basic law of waste management, and the Law for the Promotion of Effective Utilities of Resources (2001), which is the basic law for recycling of used resources. The laws for recycling specific items such as containers and packaging, WEEE, food waste, construction waste, and ELV were established in these laws. In addition, the Law on Promoting Green Purchasing was enacted in 2001, with the purpose of promoting government procurement of recycled products. Japan’s waste management system is characterized by the existence of two independent basic acts on waste management as well as on material recycling, under which the laws concerning recycling of specific items are laid down. The legislative framework is similar to those of the EU and Korea.

Korea The basic legislative framework on waste management in Korea consists of the Waste Management Act (amended in 2007) and the Act on Promotion of Resources Saving and Recycling (amended in 2008) [11]. The full-text amendment of the Waste Management Act was implemented in 1991 to introduce waste recycling, a deposit system, and standards for incineration and landfill [12]. The Act on Promotion of Resources Saving and Recycling is a revision of the Act on Promotion of Resource Recycling enacted in 2002, and it lays out the basic plan for material reuse, the fee system for waste treatment, regulations on the use of one-way packaging and goods, and EPR [13]. EPR was also included in the Act on Resource Recycling of Electrical and Electronic Equipment and Vehicles, which was enacted in 2008 [14].

The initial driving force for the promotion of 3R policies in Korea was a strong campaign by neighborhoods against the construction of waste treatment facilities [14]. The Promotion of Installation of Waste Disposal Facilities and Assistance to Adjacent Areas Act [15] was enacted in 1995 to ensure that facilities were adequately established. At the same time, a fee system for waste generation was introduced as a strict economic measure against increases in the amount of waste, in addition to other measures such as separated collection and regulations on the use of one-way packaging. From 2005, organic wastes were no longer accepted at landfills and had to be recycled [16].

China The basic environmental legislation in China is the Environmental Protection Law of the People’s Republic of China (1989), under which other laws were established. The Environmental Pollution Prevention and Control Law by Solid Waste was enacted in 1996 and amended in 2005. It introduced the application of 3R policies for solid municipal, industrial, and hazardous wastes and required not only a reduction in the amount of waste but also in its hazardousness [17]. Treatment consists mainly of detoxification of wastes, but the law does not establish a priority in terms of treatment methods (e.g., incineration or landfill). The inventory on hazardous wastes was also established in this act.

The Circular Economy Promotion Law, enacted in 2008, is the basic law concerning material cycles and waste management in China [18]. Several factors are said to be behind the enactment of the Circular Economy Promotion Law, including a lack of resources, insufficient use of recycled materials, and a national strategy of tackling the problem of resource depletion, accompanied by the desire for sustainable economic growth. In other words, the substantial lack of resources in the face of a rapidly growing economy caused China to expand its use of recycled materials. At the same time, China’s economic growth was accompanied by a massive increase in the amount of waste generated; this produced serious social and environmental problems and an urgent need to improve China’s waste management systems. Consequently, the integrated use of recycled resources and the promotion of zero emissions at production facilities were considered to be essential, especially in the circular economic zone where many industrial facilities are located. The Circular Economy Promotion Law thus emphasizes the promotion and management of 3R activities in the industrial sector and includes economic incentives, such as a reduction in, or exemption from, the value-added tax, for the integrated and circulative use of resources [19].

In order for the Circular Economy Promotion Law to have substantive effects, WEEE and MSW management systems needed to be enhanced through improving recycling and waste treatment techniques and strengthening the financial base of companies utilizing recycled resources. Although the focus of waste management policies in China has been on the problem of resource depletion and maintaining rapid economic growth, the environmental protection system with regard to imported recycling materials also needed improvements. Furthermore, measures also had to be taken against increased MSW caused by population expansion and economic development in urban areas. To this end, the ELV Recycling Law (2001) and Management Ordinance on WEEE (2009) were established [19]. The production of automobiles is increasing dramatically in China and is predicted to result in a massive increase in ELV in the near future. Nevertheless, rather than ensuring sound waste management of ELV, the ELV Recycling Law emphasizes the prevention of illegal remodeling, ensures car safety, and promotes the purchase of new models with environmentally friendly features. Furthermore, existing recycling facilities lack the capacity to meet the predicted demand for ELV recycling [20, 21].

Vietnam The basic legislation for environmental management in Vietnam is the Environmental Protection Law (amended in 2005), which takes precedence over other laws concerning waste management. The waste management system was established under the Decree on Solid Waste Management (2007), which establishes environmental protection measures for solid waste treatment [22]. The Decree covers the overall waste management policy and prioritizes recycling, reutilization, and treatment and recovery, to prevent land consumption by landfills [23]. The collection, transport, and treatment of waste are subject to fees of 40,000 VND/t for MSW and as much as 6,000,000 VND/t for hazardous wastes [24]. Hazardous and medical waste categories are defined under the decision [25, 26]. The former regulation on the control of hazardous wastes (decision no. 155/1999/QD) was incorporated in the Decree regulations on solid waste management as articles 70–75 at the time of its amendment.

The targets for waste management in Vietnam are determined under The National Strategy on Integrated SWM for the years of 2025 and 2050 (2009) [27]. The mid-term strategic targets for 2025 are to have separated MSW. Solid wastes from business activities in urban areas and hazardous and non-hazardous wastes from industrial sectors are to be managed completely (100%) in an environmentally sound manner, and 90% of all construction wastes in urban areas and municipal solid wastes in the suburbs are to be collected. In addition, the strategy calls for minimizing the amount of final disposal by 2050 through the collection of all solid wastes, promotion of 3R policies, and employment of advanced and environmentally sound techniques. In Vietnam’s case, the incentive for the promotion of 3R activities in urban areas seems to arise from a sense of crisis about the upcoming depletion of land available for use as landfills [28].

The EU and other countries employ a common hierarchical approach in their 3R and waste management policies. However, there are also unique approaches within the various countries. For example, in China, where the concept of the circular economy is promoted as a policy ideal, Article 3 of the Solid Waste Pollution Prevention and Control Law clearly states that reduction (the first priority in the 3R management hierarchy) should be achieved not only in the amount of wastes but also in the waste’s level of hazardousness [29]. The EU’s waste management system is characterized by concerns about the practicality and effectiveness of its 3R policies, the development of a realistic legal framework, and the underlying attitude of policymakers toward simplifying the bewildering expansion of waste management systems [30].

Most of the countries are also setting concrete quantitative targets. The waste management targets are summarized in Table 2 (for the USA), Table 3 (the EU), Tables 4 and 5 (Japan), and Table 6 (Korea). A new waste management strategy is currently being drawn up in the USA, so the targets in Table 2 may soon be subject to revision.

Waste management targets serve as the progress benchmarks of 3R policies, and the targets are determined at the same time as the waste management hierarchy. The targets for reduction of overall wastes have the highest priority, followed by the targets for specific recycled items and targets for specific waste management measures.

The USA, Japan, and Korea all set targets for waste generation. In the USA, the maximum target for waste generation, which was to be achieved by 2008, is 4.5 lb person⁻¹ day⁻¹ or approximately 2 kg person⁻¹ day⁻¹ [2]. The target is under revision and discussion. In Japan, the target for non-industrial waste generation in 2015 is 1,070, or 520 g person⁻¹ day⁻¹ for household solid waste [10]. If achieved, these targets would bring about a 10% (total MSW) and 20% (household waste) reduction relative to the base year of 2000 for the USA and Japan, respectively. In Korea, however, the reduction rate relative to the estimated MSW amount in the target year is applied as a target index. The MSW amount of waste for 2012 is estimated to be 47,975 t/day, and the reduction target is 45,177 t/day or 5.8% [31].

Targets for waste management measures are also used in the USA, EU, Japan, and Korea. In the USA, the target recycling rate in 2008 was 35 wt%, relative to 31 wt% in 2002 [2]. In terms of the amount of material recovery, this represents an increase from 57.55 million ton (Mt) in 2001 to 69.04 Mt in 2008. In the 2010–2014 Strategic Plan, which is currently being revised, the target amount of 3R materials increases by approximately 58 Mt by 2014 [1]. The EU determined that separation and collection should be deployed by 2015 for paper, metals, plastics, and glass, and it set the long-term recycling target at 50 wt% of household waste to be recycled by 2020. The EU also aims to gradually reduce the amount of total household-generated waste containing organic material in landfills (75% in 2006, 50% in 2009, and 35% in 2016) [30]. In Japan, the recycling target is 12 Mt (24 wt% of waste generation), and the target for final disposal is 23 Mt (41% relative to the base year of 2000) [10]. In Korea, the recycling target for 2012 is 27,558 t/day (10 Mt/year), or 61.0 wt% of total waste generated [31].

The USA, EU, and Korea also set recycling targets for packaging materials. In the USA, the target recovery amount for each material is defined, and the rate of recovery is calculated relative to the amount of each material as waste in the base year 2001 [2]. The target rates of recovery are 24.2% (+9.2%) for wooden packaging, 19.4% (+12.8%) for plastics, and 38.7% (+12.7%) for drinks packaging. It is likely that thermal methods are not regarded during the calculation of recovery rates in the USA. In the EU, the targets for material recycling and the targets for recovery, including heat utilization, are defined relative to the waste amount generated in the base year [30]. The material recycling target is 55 wt%, whereas the target rate of recovery is 60%. In Korea, the recycling target for each material is set yearly; in 2008 it was 50 wt% for glass and 65 wt% for steel cans [16]. The Korean performance report shows that the recycling rates for glass bottles, aluminum cans, and steel cans exceed 75 wt% [31]; thus, the target recycling rates may be subject to amendment. In addition, quantitative targets have also been set for reducing the use of packaging materials, and the selection of materials is also regulated [16].

Tables 7 and 8 show the amounts of waste generated and the methods (recycling, incineration, and landfill) used to treat MSW in the EU, USA, Japan, and Korea. Figure 1 shows the distribution of the management methods. In Japan, the total amount of landfilled materials includes incinerated materials that have gone through shredding and sorting processes at treatment facilities, recycled materials, and final disposal materials, including incinerated residues. Thus, for comparison, the amount recycled in Japan was calculated as (amount of waste generated) − (directly incinerated amount + direct landfilled amount); this was also done for data from the EU, although the calculated quantities are greater than the amounts in published data. Furthermore, although thermal recovery is not included in recycling in the USA, EU, and Korea, it is included in recycling in Japan.

The USA has the highest rate of waste generation (800 kg person⁻¹ year⁻¹), followed by Japan and Korea (both around 400 kg person⁻¹ year⁻¹). In terms of MSW composition in the USA, the most dominant component is packaging, which accounts for 30%, followed by waste containing organic materials (27%), paper (24%), and steel and plastics (18%; percentage by weight in 2008) [38].

Waste management methods are quite different in Japan from in the EU and the other countries. Waste incineration predominates in Japan and the rate of final disposal in landfills is extremely low, whereas the rate of incineration is usually low elsewhere (Table 7; Fig. 1). There are also differences among the EU, USA, and Korea. The landfill rate in the USA and the EU reaches about 40–50% of the total amount of waste generated, but it is only about 20% in Korea. Korea also has a much higher recycling rate (almost 60 wt%) than the EU and USA (about 30–40 wt%). The yearly changes in management methods shown in Table 8 indicate that changes have been relatively gradual in the USA, whereas the landfill rates have drastically decreased as the recycling rates have increased in the EU, Japan, and especially in Korea.

Recycling rates in 2007 were highest in Korea (58 wt%), followed by the EU (41 wt%), USA (33 wt%), and Japan (25 wt%) (Fig. 2). The rate of recycling in Korea increased rapidly since restrictions were imposed on disposing of organic waste in 2005. In Korean statistics, separated and collected organic waste is counted as recycled waste [39]. The ratio of organic waste to total recycled waste was 45 wt% in 2008, indicating that almost half of recycling material is organic waste. However, although the organic waste is currently subject to composting and utilization as feed, there are still technical and economic problems with the use of organic waste [31]. Similarly, disposing of organic waste in landfills is prevented by law in the EU; this may have resulted in a higher recycling rate. In the USA, the rate of recycling refers mainly to paper and garden organic waste. In Japan, the rate of recycling refers mainly to paper and packaging waste. One reason for a low recycling rate is that the recycling of organic waste is not quite advanced enough.

Data on the recycling of packaging materials in the USA, EU, and Japan are shown in Table 9. There are differences among the scope of packaging materials collected in these countries. In the USA, the categories are glass, paper (corrugated cardboard boxes, milk containers, collapsible boxes, other bags, and packaging), metals (steel and aluminum cans), plastics [poly(ethylene terephthalate) (PET) bottles, high-density polyethylene, low-density polyethylene, and others], and wooden packaging [36, 40]. In the EU, the categories are glass, plastic packaging, paper packaging, and wooden packaging [44]. In Japan, the categories are glass, steel cans, aluminum cans, food trays, PET bottles, drinks boxes, corrugated cardboard, and other paper and plastic packaging [10]. In Japan and the EU, the categories are clarified in detail because the burden of the expense for collection and recycling falls on industry, whereas in the USA, the targets for recycling rate of packaging and containers are set by federal government, but collection systems are developed by each state or local government rather than at the federal level [45].

The recycling rate of packaging materials (the amount of recycled packaging as a proportion of total packaging waste generated, or C/B in Table 9) is highest in the EU at 58.8 wt%. The EU also has mandatory regulations and clear recycling targets. The rate is lowest in Japan (23.7 wt%), which has a legal recycling system but no clear targets for recycling. The US rate (43.8 wt%) is closer to that of the EU.

The USA generates the greatest amount of packaging waste per person (249 kg person⁻¹ year⁻¹), 1.5–2 times the amounts in the EU (165 kg person⁻¹ year⁻¹) and Japan (93 kg person⁻¹ year⁻¹). In the EU, despite the early development of recycling specifically aimed at reducing packaging waste, the generation of packaging waste has increased (Fig. 3). There are also great differences among the rates of packaging recycling in these countries (Fig. 4). The existing recycling systems may have targets that are clearly enough defined for the reduction of waste packaging materials [5].

Promotion of packaging waste reduction and a mandatory recycling system have been implemented at several stages in Korea, including product design, sale, and collection and recycling. Under the EPR, introduction of mandatory recycling (including of tires and WEEE) by businesses is under way. In addition, reduction in the use of packaging is currently promoted by restrictions on the size of product packaging and by the use of a deposit system. Although public data on the rate of packaging recycling in Korea are not available, we estimated the amount of packaging recycling to be 41.7 kg person⁻¹ year⁻¹, assuming that the amounts of glass, cans, plastic, and resins shown in the Korean waste statistics [39] are packaging wastes. The dominant components were glass and plastics (PET bottles). Glass, in particular, accounted for almost half of the total amount. This estimation places Korea between Japan (22 kg person⁻¹ year⁻¹) and the EU (97 kg person⁻¹ year⁻¹).

Waste incineration is a source of dioxin emissions, and the trends in dioxin emissions per capita from waste incineration for several countries are shown in Fig. 5. In Japan, dioxin emissions exceeded 60 μg-TEQ person⁻¹ year⁻¹ (TEQ, toxic equivalent) until strict political measures to control dioxins emissions, in the form of guidelines for the reduction of dioxins emission, were taken in 1997, at which point a large decrease in emissions occurred. In the USA, the rate of incineration had also been relatively high, (over 30 μg-TEQ person⁻¹ year⁻¹) until 1995, when countermeasures were taken and emissions rapidly decreased. In the EU, the unit dioxin emission rate had also been relatively low, 11 μg-TEQ person⁻¹ year⁻¹, until 1995 because the incineration rate had been relatively low and the early abatement of dioxin emission (Fig. 5).

Figure 6 shows the relationship between dioxin emissions and waste incineration in Japan from 1990 to 2006 [48]. Most combustible waste was incinerated during this period, but after the Special Law on Countermeasures against Dioxins was implemented in 1999, incineration facilities were updated and a rapid decrease in emissions occurred. The rate of decrease leveled out for a few years, but dioxin emissions eventually decreased by more than 99% of the original level, driven by improved technology and the later promotion of 3R policies, which brought about a reduction in the amount of waste incinerated.

As a basic principle, policies on managing chemical substances should be promoted in an integrated manner with 3R and waste management policies. The management principles of hazardous wastes and persistent chemical substances are as follows: (1) avoid the use of hazardous chemicals (clean), (2) use the substances cyclically if no adequate alternatives are available to meet the utility expected (cycle), and (3) prevent their emission into the environment and stabilize current and previously generated stocks or waste (control) [56]. In the USA, following similar principles, the Pollution Prevention Act lays down chemical management in a manner consistent with the Toxic Substances Control Act. The Pollution Prevention Act sets management policy for chemical substances and prioritizes source prevention over other measures. These include environmentally sound recycling, which is permitted only when source prevention is not possible, and waste treatment, which is permitted only when source prevention and recycling are not possible. Disposal and emission are defined as the last measures. Peeler [57] gave an example from Washington State, where a Chemical Action Plan is being undertaken concerning the management of mercury, polybrominated diphenyl ether (PBDE), and lead. Hylander [58] warned that, especially in the case of mercury, a better treatment exists than recycling, that hazardous substances are used in some cases despite existing alternatives, and that recycling becomes much easier when basic materials are not contaminated with hazardous substances.

An important issue that still remains to be solved in some countries such as Japan and the EU is the management of household hazardous waste (HHW). The European Commission Directorate of the General Environment conducted a study on HHW and published its final report in 2002 as a part of a strategy to enhance sound life-cycle management of products [59]. In the report, HHW was defined as “waste that may increase hazardousness of municipal solid waste when being landfilled, incinerated or composted,” and a focus was put on the hazardous household chemical substances. Fourteen chemicals were classified as high priority for solid waste management: As, Pb, Cd, Cr, Cu, Ni, Hg, Zn, PCBs, benzene, tetrachloroethylene, trichloroethylene, tetrachloromethane, sodium cyanide. They were identified from an emissions inventory from treatment facilities, such as landfills and incinerators. Asari et al. [60] conducted a survey of HHW possession and of the participants’ experiences concerning involvement in HHW collection and recycling systems. The results indicated that providing information about the hazardousness of a product significantly increased the rate of participation in HHW collection and recycling systems. In Japan, there is a warning system for marking the presence of specific chemical substances in electrical and electronic equipment (JIS C 0950, J-MOSS) to control heavy metals such as mercury and cadmium, which are constituents of products such as personal computers, televisions, and refrigerators [61].

The US EPA [62] reported that waste management and GHG emissions are strongly correlated. The report concluded that waste reduction and recycling promotion are considered highly important in reducing GHG emissions for the following reasons: (1) promotion of recycling will reduce energy utilization, (2) reduction of waste incineration will also reduce emissions, (3) prevention of methane gas generation by reducing the amount of landfill waste will also contribute to emissions reduction, and (4) protection of forests through paper recycling will help to maintain their carbon dioxide absorption function.

In the EU, under the Directive on Landfill of Waste (council directive 1999/31/EC), the amount of biodegradable municipal waste being landfilled is targeted to be reduced to 75% of the 1995 level in 2006, 50% in 2009, and 35% in 2016. According to GHG emissions estimates derived from MSW management in the EU [5], waste prevention measures and recycling of biodegradable municipal waste could result in a reduction in GHG emissions of approximately 75 Mt-CO₂ in 2010 and 60 Mt-CO₂ in 2020 (Fig. 7). The following assumptions were made in these estimates: the amount of MSW generated would increase from 520 kg person⁻¹ year⁻¹ in 2004 to 680 kg person⁻¹ year⁻¹ in 2020, and the ratios of management methods in 2020 would be 34% for landfill, 42% for recycling, and 23% for incineration with power generation. The emissions associated with the transport, treatment, and disposal of waste were counted as direct GHG emissions. Indirect reductions in GHG emissions were also calculated, including the use of recycled materials in place of natural resources and the substitution of power generated from fossil fuels. Better MSW management was shown to be effective in reducing GHG emissions, and the report concluded that introduction of more effective recycling as well as power generation from waste would accelerate the reduction of GHG emissions [5].