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POL-55

This is a proposal for discussion, not an enacted law.

Ali Zuweid's Political Programme

Legislative proposal · Energy, Infrastructure, Water, Environment and Urban Development

Waste Management, Circular Economy and Hazardous Substances Law

Document numberPOL-55
TypeProposed federal law — comprehensive framework
Version1.0
Publication and update date7 October 2026

Executive summary

The proposal shifts Iraqi waste regulation from dispersed prohibition and licensing rules to an integrated lifecycle framework, beginning with waste prevention and ending in safe disposal. It adds instruments not yet covered by a comprehensive national framework: source separation, secondary-material standards, extended producer responsibility, electronic hazardous-waste tracking, special-stream regulation, informal-worker inclusion and the circular economy.

Official 2025 data demonstrate the institutional gap: 13.6 million tonnes of ordinary waste and 8.1 million tonnes of demolition and construction debris were collected; the report identified 133 landfill sites without environmental approval versus 65 approved sites and one operating sorting and recycling plant. Collection covered 68.6% of the population in the report's Iraqi coverage, excluding the Kurdistan Region. The proposal therefore bases legal obligations on progressive coverage, data and oversight rather than national numerical targets unsupported by a complete baseline.

No parallel executive authority is created. The Ministry of Environment retains environmental standards, tracking and oversight; Baghdad Municipality, governorates and municipalities retain local-service responsibilities within their powers; and the federal ministry responsible for municipalities and health, industrial and customs bodies coordinate. This reflects shared environmental-policy competence under Article (114/Third) and decentralisation and constitutional-priority rules in Articles (115) and (122).

The proposal recognises Parliament's first reading of the Municipal Solid Waste Management Bill on 9 September 2026. Rather than parallel laws, it requires a unified legislative pathway combining municipal provisions with industrial and hazardous waste, special streams and circular-economy rules.

National baseline

The Statistics and Geographic Information Systems Authority's 2025 municipal-services report provides the latest published official baseline available when preparing this proposal. Its figures must be read within its coverage, especially exclusion of Kurdistan, without converting the percentage of governorates by predominant disposal method into a share of national waste weight.

Brief baseline — Iraq Environmental Statistics, Municipal Services Sector, 2025 (excluding the Kurdistan Region)
IndicatorOfficial 2025 valueLegislative implication
Population served by waste collection68.6% of the population; 93.5% in urban areasClear access gaps beyond urban centres justify progressive coverage duties and service-level indicators.
Collected waste21.8 million tonnes/year: 13.6 million tonnes ordinary waste and 8.1 million tonnes rubble/construction and demolition wasteConstruction and demolition waste is large enough to require distinct regulation within the Law.
Collected hazardous waste11,451.5 tonnes/yearThis measures municipal collection within the report, not necessarily all national generation, requiring source-based tracking.
Ordinary waste rate1.4 kg/person/dayVolume justifies prevention, separation and recovery before landfill.
Predominant disposal methodIn 93.8% of covered governorates, the predominant method was disposal at sites without environmental approvalThis is a percentage of governorates by predominant method, not national waste weight.
Landfill sites65 environmentally approved sites versus 133 without approvalRequires risk classification and phased closure/upgrading, stopping new unlicensed sites.
Operating sorting and recycling plantsOne operating plant according to the reportSupports market, facility, secondary-material and producer-responsibility regulation beyond disposal and collection orders.

Source: Statistics and Geographic Information Systems Authority, Iraq Environmental Statistics — Municipal Services Sector 2025, published 2026.

Legislative policy

The proposal combines seven choices: a waste hierarchy; no new administrative apparatus; decentralised municipal services and service standards; extended producer responsibility for suitable streams; auditable data and tracking; energy recovery reserved for residual waste rather than replacing recycling; and tighter hazardous-waste, hazardous-substance and transboundary controls.

Responsibilities without a parallel executive authority
BodyProposed statutory role
Ministry of EnvironmentEnvironmental standards, hazardous-waste classification, tracking, environmental licensing, international obligations and oversight.
Federal ministry responsible for municipalitiesModel service guides and standards, capacity building and national coordination without central operation of local services.
Baghdad Municipality, governorates and municipalitiesPlan, operate or contract collection, transport and local facilities; set charges and service levels and remove illegal dumping.
Ministry of Health and health bodiesSeparate healthcare waste within facilities, control infection and coordinate transport and treatment.
Industrial, commercial and standardisation bodiesSecondary-material standards, resource efficiency and producer and product requirements.
Customs, border and security authoritiesPrevent illegal traffic, verify documents, seize and refer cases under law.

The Law sets no national recycling percentages, factory numbers or single capital cost. These operational figures require a comprehensive baseline, waste composition, markets, sites and treatment technologies. It instead mandates a national strategy, local plans, uniform indicators and financial statements, making subsequent targets reviewable and accountable.

Statement of reasons

This Law is enacted to protect health and the environment from unsound waste and hazardous-substance management; guarantee healthy environmental conditions; resolve fragmented collection, transport, treatment and disposal rules; advance prevention, reuse, recycling and circular economy; regulate producers and special streams; improve hazardous-waste tracking and compliance with Basel, Rotterdam, Stockholm and Minamata obligations binding on Iraq; and allocate federal, regional, governorate, Baghdad and municipal responsibilities consistently with the Constitution and decentralisation.

Explanatory memorandum

1. Why a framework broader than municipal waste alone?

Municipal waste is most visible but is not the sole risk or economic-loss source. The 2025 report records 8.1 million tonnes of construction and demolition waste plus hazardous municipal collections; industrial, healthcare, electronic, oil, battery and tyre streams extend beyond household-service logic. Municipal-only legislation leaves gaps and encourages shifting problems between streams.

2. Why no new authority?

The central problems are overlapping roles and weak data, tracking and facilities, rather than absence of a new institution. The proposal confirms Ministry environmental-standard and hazardous-waste duties, local service responsibilities and existing-council coordination, reducing establishment costs and duplicate powers and clarifying accountability.

3. What does circular economy mean here?

The proposal converts the term into prevention, preparation for reuse, by-product and end-of-waste criteria, green procurement, repairability, viable recycled content and producer responsibility. Incineration is not recycling, and disguised disposal cannot count as recovery merely because marginal financial value exists.

4. Energy recovery's position

Energy recovery follows prevention, reuse and recycling. Long-term thermal facilities built before reliable separation and data systems could create waste-supply commitments that crowd out recycling. Licensing therefore requires lifecycle, energy, efficiency, emissions and ash-management assessment.

5. Hazardous substances and waste

The proposal builds on existing Ministry transport permits, adding uniform movement codes, electronic tracking and clear generator, carrier and recipient duties. Radioactive waste remains technically regulated by the National Nuclear, Radiological, Chemical and Biological Regulatory Authority under Law No. (1) of 2024 to avoid overlap.

6. Extended producer responsibility

Producer responsibility prevents municipalities and citizens alone bearing costly or hazardous post-consumer product burdens. It does not immediately apply to everything: stream and market studies, producer registers, realistic targets, financial and technical audits and equal domestic/imported treatment precede application to electronics, batteries, tyres, oils, packaging and other streams.

7. Social justice and informal workers

Informal recovery exists, and immediate exclusion may deepen concealment and poverty. The proposal requires voluntary inclusion through registration, training, cooperatives, small contracts and occupational safety while prohibiting hazardous child labour.

Transitional provisions and implementation requirements

Success depends on sequencing rather than numerous day-one obligations. Core principles and prohibitions commence separately from digital systems, facilities and producer-responsibility arrangements requiring time and data.

Proposed institutional implementation stages
Period after commencementMandatory action
Within 6 monthsBegin standardising waste codes, inventorying generators and facilities, and designing national registers and tracking.
Within 12 monthsIssue core regulations, adopt or update national strategy, and launch covered operator and producer registration.
Within 18 monthsUpdate local plans, classify non-compliant landfills and prepare existing-facility compliance plans.
Within 24–36 monthsLaunch priority producer-responsibility systems after establishing baselines, capacity and reception points.
PeriodicallyAnnual data reports, five-year national-plan reviews and market- and outcome-based regulatory target reviews.
Core transition principle: Transition cannot legalise new environmentally unapproved dumps, open burning or unlicensed hazardous-waste handling. It aligns existing systems and facilities rather than suspending basic protection.

Financial and operational impact

Reliable national costs require updated facilities, vehicle and contract inventories, governorate waste-composition studies, and defined sites, technologies, prices and design lives. The proposal avoids false capital-cost precision and requires a financial implementation statement tied to national planning.

Financial-impact assessment method
Impact itemNatureFinancing method
National data and tracking systemDigital establishment and inter-agency integration, followed by operation and maintenance.Existing-body budgets and possible technical assistance; reuse government platforms where feasible.
Collection and equipment expansionOngoing local capital and operating costs.Local budgets, fair service charges and performance contracts, subsidising gaps that cannot socially be recovered.
Sorting, recycling and treatmentCapital and operating costs vary substantially by technology and scale.Public, private or partnership investment after competition and feasibility studies, without quantity guarantees undermining the waste hierarchy.
Sanitary landfill and dump closureCapital costs and long-term closure and monitoring guarantees.Local/federal budgets according to jurisdiction, disposal charges and operator financial security.
Producer responsibilityFunding ring-fenced for particular streams.Producer and importer contributions based on net costs and independent audits, rather than general municipal budgets.
Contaminated or orphan sitesPotentially high and unpredictable costs.Responsible parties first; where recovery fails, environmental-fund or budget mechanisms by risk priority.

Implementation also requires laboratories, inspection capacity, training and evidence custody systems, using existing ministries, directorates, Baghdad Municipality, municipalities and health bodies rather than a new independent apparatus. Electronic registers and uniform movement documents can reduce medium-term verification and fraud costs if genuinely interoperable rather than separate platforms.

Brief international comparison

The EU Waste Framework Directive legally prioritises prevention, preparation for reuse, recycling, other recovery and disposal, with general producer-responsibility, role-allocation and data requirements. The proposal draws on this structure without copying EU quantitative targets or institutions.

Egypt adopted Waste Management Regulation Law No. (202) of 2020 and implementing regulations as a comprehensive framework. Comparison shows the value of unified licensing, planning, responsibilities and waste-stream rules, adapted to Iraq's decentralised constitutional system and shared powers.

Hazardous-waste governance rests not only on national comparisons but on Basel's prior informed consent and environmentally sound management, Stockholm's persistent-organic-pollutant duties, Minamata's mercury provisions and Rotterdam's internationally traded hazardous-chemical and pesticide requirements.

Sources and references

  1. Constitution of the Republic of Iraq 2005 — Supreme Judicial Council.
  2. Environmental Protection and Improvement Law No. (27) of 2009 — legislative reference, with Ministry of Justice confirmation of continuing application.
  3. Ministry of Environment — Environmental legislation, including municipal, hazardous and healthcare-waste instructions.
  4. Ministry of Environment — Environmental approval for hazardous-waste transport and movement-document and licensing requirements.
  5. Environmental Protection and Improvement Strategy of the Republic of Iraq 2024–2030 — Ministry of Environment.
  6. Iraq Environmental Statistics — Municipal Services Sector 2025 — Statistics and Geographic Information Systems Authority.
  7. Iraqi Council of Representatives — Session (17) decisions and recommendations, 9 September 2026: first reading of the Municipal Solid Waste Management Bill.
  8. Iraqi Council of Representatives — Laws search database, including Basel Amendment Accession Law No. (13) of 2021.
  9. Ministry of Justice — National Nuclear, Radiological, Chemical and Biological Regulatory Authority Law No. (1) of 2024.
  10. Basel Convention — Parties: Iraq acceded on 2 May 2011; entry into force on 31 July 2011.
  11. Rotterdam Convention — Parties: Iraq acceded on 18 April 2017.
  12. United Nations — Iraq's Stockholm Convention accession on 8 March 2016.
  13. United Nations — Iraq's Minamata Convention ratification on 16 September 2021.
  14. European Union — Consolidated Waste Framework Directive 2008/98/EC: waste hierarchy and extended producer responsibility.
  15. Egyptian Environmental Affairs Agency — Waste Management Regulation Law No. 202 of 2020 and implementing regulations.

Last live-source verification date: 7 October 2026. Sources document context and diagnosis; draft articles are independently formulated legislative provisions without citations inside each Article.

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