47 MARTINDALE CENTER FOR THE STUDY OF PRIVATE ENTERPRISE and Orebić provide examples of how tourism can subsidize environmental mitigation efforts, where local governments prioritize it. However, fragmentation means that one municipality’s success does not extend to others. Those like Dubrovnik—one of the most touristic in Croatia— struggle to address a substantial seasonal increase in waste. As of 2023 in Dubrovnik, a mere 1.75% of waste was separated and 24.7% recycled, a long way from the EU target of 55% recycled by 2025. This waste separation rate is almost 18 times lower than the rate in Orebić, though they are in the same county and experience similar influxes of tourism. Overall, the Dubrovnik-Neretva County separation rate was only 5.5% in 2023, falling much lower than the national average of 29.3%. Additionally, the separation rate in Dubrovnik-Neretva County actually declined by 1.9% compared to 2022 numbers (7.5% separation rate), indicating the county is moving backward regarding separate collection of plastic, glass, and paper. Also concerning is that 2023 tourism in Dubrovnik-Neretva County generated 14,961 tons of waste out of the county’s total waste generation of 77,886, meaning 19.2% of all municipal waste generated directly resulted from tourism. Dubrovnik-Neretva County had 17 active separate waste collection service providers as of 2023, which fragmented its collection system, further contributing to its low separation and recycling rates (Požgaj et al., 2024). The contrast between Dubrovnik and Orebić, despite having similar geography, tourism volume, and EU funding, illustrates that the main obstacle is the absence of any mechanism requiring neighboring municipalities to coordinate. This fragmentation, alongside the absence of a centralized waste collection service, indicates a structural problem compounded by the waste generated by tourism. Another challenge in changing waste management practices in the tourism sector is its interconnectedness with the economy. Although restricting tourism may curb the increase in waste production, it would have detrimental economic consequences. This inherent tension, which no single municipality can resolve alone, has delayed systemic changes. Croatia is not incentivized to restrict tourism in order to reduce waste production because the benefits of the tourism industry outweigh the costs of waste generation. If one municipality implements harsh regulations against tourism waste generation, tourists will travel to others that will in turn reap the economic benefits. Similarly, because waste treatment is the responsibility of individual municipalities, lasting impact requires collective action the current structure does not facilitate. Impact of tourism seasonality on waste generation Seasonality is also a critical contributor to the strain placed on the waste management system. As the number of tourists has increased in recent years, the majority of this influx occurs solely throughout the summer months (Ćorluka & Vukušić, n.d.). Tourism is also concentrated in only a few areas that must deal with the additional accumulation of waste, leading to further systemic strain. One case study found waste generation at Croatian tourism properties increased by of over 800% between January and peak summer months (Kiš et al., 2021). This seasonality contributes to massive overutilization of resources, including waste management infrastructure during summer months, leading to much larger capacity needs than if the waste were spread out evenly throughout the year or to all municipalities. Taxation on tourism To address the increased waste generation, Croatia has implemented a tourist tax. This tax is intended to hold tourists financially responsible for the damage attributed to the industry’s growth. It is levied in several ways, including hospitality accommodations, nautical tourism vessels, and cruise ships (Tomislav, 2014). The tax is collected and spent at the municipal level, meaning municipalities with the heaviest tourist pressure are also the ones deciding how, or whether, to invest the revenue in waste infrastructure. There is no redistribution to those that have to deal with tourism’s waste burden but do not benefit as much from its revenue. Consequences of municipality fragmentation on waste management Croatia’s system results in different policies and budget concerns in each municipality, making it difficult to accomplish desired changes on a national scale. These delays can be attributed to institutional and policy barriers, implementation lags, and even geography concerns that vary by municipality. Lag in regulation and policy implementation Regulatory and implementation delays are partially to blame for a lack of policy change and development. Many of the EU regulations include a short window for implementation, placing unrealistic expectations to shift infrastructure, leading to poor preparation and the need for policy deadline extensions. For instance, the Ordinance on Packaging and Packaging Waste has been amended 10 times in the past 12 years as the outlined benchmarks have not been met. Constantly
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