The almost complete shadowing of the hazardous waste processing market, the irresponsibility of the authorities, and bureaucratic barriers to obtaining permits are hampering the economy, business, and the country's recovery during the war.
These and other critical issues in the field of waste management and the real state of the recycling market were discussed by representatives of business, the professional community, authorities, and local self-government during the round table "Waste during the war: bureaucracy vs. safety," organized by the Association of Environmental Professionals (PAEW).
Stakeholders spoke candidly about the problems they encountered when the state began to implement waste management reform. Here are the main ones:
1. The state imposed requirements on producers but did not provide opportunities to meet them.
Industry representatives and sector experts emphasized that Ukraine currently critically lacks infrastructure for processing. The Law of Ukraine “On Waste Management” requires waste to be transferred under specific codes and operations, yet for a number of groups there are simply no licensed operators in state registries, or the number is critically low. According to the head of the Waste Management Committee of PAEW, Aliona Shutenko, only 41 companies in Ukraine currently hold a license for hazardous waste management.
“Formally, business is breaking the law. In reality, there is nowhere for it to go,” states President of the Professional Association of Environmentalists PAEW Lyudmyla Tsyhanok.
2. As a consequence of the first point, almost the entire waste processing services market in Ukraine has gone “into the shadows.” Both environmentalists and industry players confirm this.
“Today, resource-containing waste is simply sold for cash and processed by 'black' processors. [...] The entire hazardous waste management market has moved 'into the shadows,' into cash, into landfills, and so on,” said the founder of Eco-Energoprom, Hlib Ryzhov.
He notes that the few licensees who do exist now choose whom to work with, and the prices for processing “have just skyrocketed.”
3. Retroactive application of new requirements.
The state changed classifications, codes, and formal approaches, and now, producers who have worked for years with valid permits and unchanged technologies are forced to go through the procedures again.
4. Double, and for hazardous waste – triple duplication of state regulation.
To be able to operate, the authorities require waste processors to undergo the following procedures:
- obtaining a permit for waste processing operations;
- environmental impact assessment (EIA);
- obtaining a license for hazardous waste management activities.
PAEW experts state that in practice, the permitting and licensing procedures often rely on very similar sets of documents and create duplicated obligations.
“These mechanisms have turned into state pressure,” – insists Aliona Shutenko.
5. Ukraine still lacks a primary risk assessment for demolition waste, which is generated after shelling. The state does not consider such waste potentially hazardous, even though it may contain asbestos, combustion products, heavy metals, polychlorinated biphenyls. It effectively legalizes the uncontrolled spread of potentially toxic materials, which will have a significant impact on human health.
“Over the previous four years, a managerial decision should have been made, but it was not. Therefore, it must be done now. There needs to be a clear risk management model,” – emphasized PAEW Vice President for Military Ecology and Ecosystem Restoration, Valentyn Shcherbyna.
6. Responsibility for implementing the reform is dispersed among different agencies. This is why there is no coordination, and no one is accountable for the overall functioning of the system.
7. The digital waste accounting system does not function fully , lacking all the necessary features. As a result, businesses encounter both procedural complexity on paper and digital barriers.
8. The interpretation of legislative norms and requirements for obtaining permits changes along with changes in the leadership of the relevant ministry.
Hlib Ryzhov shared that after leadership changes at the agency, his company was required to submit EIA conclusions that had not previously been necessary.
“A huge number of companies involved in waste management have faced this situation. Now they are at a standstill – not operating,” the businessman reports.
Previously, EcoPolitic had already examined the causes of the “waste” problem in Ukraine and discussed what each of us can do to improve the situation. We also explained what dangers asbestos release poses during the demolition of buildings and structures. To learn how the state is attempting to manage demolition waste, read our material here.
