News and Statements
UKRPEC comment on the preparation of the Regional Waste Management Plan in the
Kyiv region
The Department of Ecology and Natural Resources of the Kyiv Regional Military Administration
announced the start of the public discussion procedure for the Regional Waste Management
Plan in the Kyiv Region until 2034.
According to the Law “On Waste Management” regional waste management plans are
developed for each region for ten years. They are prepared and approved by the regional state
administrations. Regional plans must be consistent with the National Waste Management Plan
and, at the same time, serve as the basis for the respective local plans.
Despite the fact that the government approved the National Plan back in 2019, and the law
requires regional plans to be developed within a year after it came into force, as of today, only
three regions have approved such documents.
The public discussion of the Regional Waste Management Plan in the Kyiv Region will last until
November 27. Roman Tytykalo, the head of the permanent commission of the Kyiv Regional
Council on Environmental Issues, noted in a comment to the “KyivVlada” publication that the
plan might be submitted for approval by the regional council at the end of 2025 or the beginning
of 2026. Before this, the document must be approved by the relevant ministries.
Regional Plans and the EPR System
As Volodymyr Slabyi, Chairman of the Executive Committee of UKRPEC, explains, despite
the fact that local self-government bodies and producers of packaging and packaged goods are
key partners within the future Extended Producer Responsibility (EPR) system, the current
legislation does not provide for the participation of producers or their representatives in the
process of preparing regional waste management plans.
“The preparation of a regional plan is primarily an opportunity to conduct a morphological
analysis of waste in the region, as well as an audit of existing sorting and recycling
facilities. Based on this data, local authorities, together with the EPR organization, must
develop a long-term plan for the development of the waste management system in the
region.The UKRPEC pilot project in the communities of the Kyiv region today has the results of
such morphological studies, as well as many years of experience of cooperation with
local self-government bodies, the population, and enterprises that provide services for
the collection, removal, pre-sorting, and recycling of waste. This experience should be
taken into account when developing the regional plan.The management of packaging waste within the EPR system should be a separate
section in the national, regional, and local waste management plans. This approach
would comply, in particular, with the norms of EU Regulation 2025/40 (PPWR) — a
document that should serve as a guide for the reform of packaging waste management
in Ukraine.Unfortunately, today we cannot demand this from local self-government bodies, as they
act exclusively within the framework of current legislation. And it, in turn, in no way links
regional plans with the EPR system.This legal gap must be closed. The interaction
between the EPR organization and local self-government bodies is the key to a
successful reform of the waste management system,” — Volodymyr Slabyi emphasizes.
We remind you that the current Law "On Waste Management" places an obligation on local self-
government bodies to ensure the achievement of targets for the reuse and recycling of
municipal waste — specifically, at least at the level of 10% of the total volume as early as 2025.
At the same time, packaging waste constitutes a significant share of municipal waste, so local
self-government bodies and the future EPR system face the joint task of organizing effective
separate collection, sorting, and recycling of this waste.