Transposition of the PRF Directive in European Ports: Charging Models, Practices, and Recommendations

Abstract

As maritime transport continues to grow, the volume and complexity of waste generated by ships, such as garbage, sewage, and oily residues, requires the establishment of effective, accessible and well-regulated collection systems in ports. Ensuring effective waste management remains a major challenge across the European Union, as differences in national implementation and charging systems continue to undermine the sustainability of port reception facilities. Directive (EU) 2019/883 on port reception facilities (PRF Directive) was introduced to harmonise regulatory standards, ensure adequate infrastructure, and remove barriers to proper waste management. This paper analyses the transposition and implementation of the PRF Directive in selected EU countries, focusing on the differences in cost recovery systems (CRS) applied in ports. A comparative analysis of charging models and waste management plans for ports is carried out, including an in-depth study of the leading European ports with the highest reported waste volumes. A nine-criteria evaluation framework was developed through a stakeholder focus group involving port authorities, concessionaires, shipping companies, and the Harbour Master’s Office, and was applied using the multi-criteria TOPSIS decision methodology, complemented by sensitivity analyses and adjustments for different port types (cargo, passenger, fisheries, marinas). The results show that the best-performing models achieved C* values between 0.514 and 0.529, confirming the robustness of the evaluation framework. Overall, the findings indicate that the optimal charging model is context-dependent, with No-Special-Fee systems without special charges favoured in passenger and leisure ports, and Prepaid + Reimbursement models more suitable for cargo and fishing ports. The paper concludes with policy recommendations aimed at increasing transparency, ensuring consistent reporting, and aligning CRS models more closely with EU environmental objectives.

1. Introduction

Maritime transport plays an essential and irreplaceable role in international trade. It forms the basis for global economic connectivity, and the sustainability of this sector is the key to further economic development. Sustainability is achieved through a balance between three pillars: economic, social, and environmental. At the global and European level, there are numerous mechanisms and instruments aimed at reducing or eliminating the negative impact of maritime transport on the marine environment. The most important prevention mechanism is the Convention for the Prevention of the Pollution from Ships 1973/1978 (MARPOL Convention), which covers six different types of pollutants (oil, harmful liquid substances in bulk, harmful substances in packaging, sewage, garbage, and air pollution) with its six annexes [1]. MARPOL contains clear provisions on technical standards for ships, emergency procedures, and discharge prohibitions. More concisely, MARPOL Annex V—Regulations for the Prevention of Pollution by Garbage from Ships—prohibits the discharge of plastic waste, and restricts the discharge of other types of waste (e.g., food, paper, glass) depending on the distance from the coast. MARPOL also requires all ships of 100 gross tonnage and above, and every ship that is certified to carry 15 persons or more engaged in voyages to ports and offshore terminals under the jurisdiction of another Party to the Convention, and every fixed or floating platform to be provided with a Garbage Record Book. Another important legal framework at the European Union level that is directly related to MARPOL Annex 5 is Directive (EU) 2019/883 on port reception facilities for the delivery of waste from ships, amending Directive 2010/65/EU and repealing Directive 2000/59/EC—PRF Directive [2]. The PRF Directive requires ports to provide waste reception facilities in accordance with MARPOL requirements, including the reception of waste as specified in Annex V. It is important that ships can deliver waste without unnecessary delay. Ports are therefore obliged to organise the reception of waste in such a way that, except in justified cases (e.g., for safety reasons or due to exceptional operating conditions), there is no additional detention of ships or extension of port laytime. This removes one of the most common reasons why ships sometimes avoid handing over waste in port and disposing of it improperly in the marine environment. The Directive states that Member States shall ensure the availability of port reception facilities adequate to meet the needs of the ships normally using the port without causing undue delay to ships (Article 4 (1)). This provision aims to increase the efficiency of waste reception systems, reduce administrative and operational barriers, and increase incentives for shipowners to dispose of waste properly.

Other sources of pollution, such as oil discharges, are regulated by MARPOL Annex 1, ballast water by the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention) [3], and air pollution by a comprehensive set of instruments, including MARPOL Annex VI, Directive (EU) 2016/802 on the reduction of the sulphur content of marine fuels [4], the European Green Deal [5], the Fuel EU Maritime Regulation [6], and the extension of the EU Emissions Trading Scheme to the maritime sector from 2024 [7]. The issue of waste disposal, particularly for smaller ships, remains comparatively poorly regulated and less systematically addressed. MARPOL Annex V is primarily aimed at larger merchant ships, while smaller ships such as tourist and excursion vessels, boats, and yachts are often excluded from effective control mechanisms.

In the context of European maritime transport policy, the European Maritime Safety Agency (EMSA) repeatedly emphasises the need for a sustainable maritime transport sector by reducing marine pollution and supporting the transition to a circular economy. According to the European Maritime Transport Environmental Report (EMTER) [8], the quantities and types of ship-generated waste handled annually in EU ports are both significant and diverse. In 2023, ports handle approximately: 855,000 m³ of oily waste (sludge, slops, oily bilge water)—MARPOL Annex I; 59,000 m³ of noxious liquid substances—MARPOL Annex II; 250,000 m³ of sewage—MARPOL Annex IV; 488,000 m³ of garbage (including plastic, household, and operational waste)—MARPOL Annex V; and approximately 6800 m³ of exhaust gas cleaning scrubbers residues—MARPOL Annex VI.

These figures illustrate the operational and environmental burden of ship-generated waste on ports, particularly given the different types of waste, storage and treatment requirements, and the financial pressures on waste management systems. In this context, the PRF Directive plays a crucial role in promoting an integrated approach that combines the protection of the marine environment with port efficiency and circular economy principles.

Although the PRF Directive aims to ensure that all ports have adequate waste reception facilities in accordance with MARPOL requirements, practice has shown that the system is mostly tailored to large ships, while smaller vessels often lack the infrastructure, clear protocols, or economic mechanisms that would promote proper waste management. This discrepancy between the international standards (MARPOL Convention) and local implementation practices (PRF Directive) is particularly evident in tourist-centred ports, where the cumulative pressure of smaller vessels can have a significant impact on the environment.

The aim of this paper is to analyse the transposition and implementation of the PRF Directive in the national legislation of EU Member States, focusing on the differences in charging models for waste disposal in ports. By comparing national approaches and analysing data collected from port authorities, the study identifies patterns, challenges, and best practices in the application of cost recovery systems (CRS).

To assess their relative effectiveness, a dedicated set of evaluation criteria was developed, taking into account economic, ecological, and administrative criteria. These criteria formed the basis for a structured evaluation of different CRS models and were integrated into a TOPSIS analysis, which was enriched with type-specific multipliers to take account of the contextual circumstances of the different port categories (cargo, passenger/cruise, fishing and marina ports).

The complementary aim of the paper is to contribute to a better understanding of how the provisions of the PRF Directive are implemented in practice, with a particular focus on the complexity of translating legal requirements into operational waste management systems at the port level.

In line with the above objectives, the paper aims to find answers to the following research questions:

• How have European countries transposed and implemented the provisions of the PRF Directive (EU) 2019/883 into their national legislation and port waste management plans?
• Which models of cost recovery systems (CRS) are currently applied in major European ports, and how do they differ in terms of scope and design?
• Which evaluation criteria are most important for assessing the suitability of different CRS models, and how do stakeholders prioritise these criteria?
• Based on the application of the evaluation criteria on the TOPSIS analysis and type-specific multipliers, which CRS models appear most suitable for different categories of ports (cargo, passenger/cruise, fishing, marinas)?

The remainder of this paper is organised as follows. Section 2 provides a brief literature review that situates the study within the framework of MARPOL and the PRF Directive, highlighting research gaps and the specific challenges faced by smaller ports and marinas. Section 3 outlines the research approach and explains the sequence of analytical steps. Section 4 introduces the main cost recovery systems (CRS) used in European ports and presents a comparative analysis of leading ports based on their waste management plans. Section 5 describes the design of the evaluation framework for CRS models, developed in consultation with key stakeholders. Section 6 details the methodology applied, including the TOPSIS model, the Borda weighting procedure, and the introduction of port-type multipliers. Section 7 presents the results of the analysis, including criteria weights, model rankings, and the outcomes of the sensitivity analysis. Section 8 discusses the implications of the findings and formulates practical and policy recommendations, while Section 9 outlines the study’s limitations and directions for future research.

2. Brief Literature Review

In order to analyse the scientific response to the implementation of the PRF Directive, a structured literature search was conducted in the Web of Science (WoS) database. The initial search was carried out in April 2025 and was limited to publications from 2019 onwards, the year in which the Directive entered into force. The query was performed using the TOPIC field (containing title, abstract, authors’ keywords and keyword plus) with the exact term “port reception facilities”. The aim of this review is to identify relevant contributions, highlight the main challenges in the management of ship-generated waste and assess how the scientific work has addressed regulatory, technical and operational aspects related to the objectives of the Directive.

The search resulted in a total of 22 published articles, of which 9 [9,10,11,12,13,14,15,16,17] were excluded following abstract screening and preliminary content analysis. These excluded studies, although relevant to maritime environmental issues, do not address the legal, institutional, or financial aspects of waste management systems—the main focus of this review. The final sample, therefore, comprises 13 studies, which together provide an insight into different national implementations, performance assessments, stakeholder perceptions and methodological innovations related to the PRF Directive.

Several studies focus on methodological contributions to the evaluation of the performance of PRF systems. Authors [18] propose a comprehensive Waste Reception Performance (WRP) framework based on quantitative indicators (e.g., waste and ship type specific metrics) and show that smaller ports may perform better than larger ones due to infrastructural and operational differences. Their findings suggest that standardised PRF strategies are insufficient and support tailored approaches. Khondoker and Hasan [19] analyse the port of Mongla in Bangladesh and assess the economic viability of a fully integrated PRF system. Their cost-benefit modelling shows that a well-designed reception system can generate positive financial returns, especially when aligned with environmental objectives and localised charging schemes. Similarly, Özbay et al. [20] analyse data on waste generation in a Turkish industrial port and find that the capacity for liquid waste is significantly underutilised despite accurate predictions for solid waste streams. This discrepancy emphasises the need for continuous reconciliation between predicted and actual waste streams—an essential practice to ensure the adequacy and cost-effectiveness of PRFs.

Environmental impact assessments play an important role in the literature, especially in environmentally sensitive regions. Lappalainen et al. [21] estimate nutrient discharges from cargo ship wastewater in the Baltic Sea and conclude that while the absolute amounts are small, PRFs are alarmingly underutilised—only 0.5% of ships discharged to land—suggesting systemic weaknesses in enforcement. Complementing this, Vaneeckhaute and Fazli [22] examined shipboard waste management in the Baltic Sea, a Particularly Sea Sensitive Area, and highlighted persistent problems, such as discharges at sea and the limited use of biogas valorisation techniques. These findings emphasise the need for stricter regulatory alignment and incentive structures to support on-board waste separation and environmentally friendly delivery practices.

The economic dimension of PRF utilisation is also critically examined. Tuljak-Suban and Suban [23] apply game theory to sewage sludge disposal strategies and show that well-calibrated fixed fee systems can serve as effective regulatory instruments by encouraging waste disposal and reducing avoidance behaviour. In a separate socio-economic assessment, Martínez-López et al. [24] use a social cost-benefit framework to assess sewage handling at Las Palmas. They conclude that only water reuse scenarios provide a net social benefit and argue in favour of applying the polluter pays principle to promote sustainable on-board treatment.

Further environmental monitoring studies demonstrate the impact of inadequate PRF coverage. Wilewska-Bien et al. [25] estimate that food waste from Baltic Sea shipping contributes 34 tonnes of phosphorus annually, a non-negligible contribution in relation to the overall nutrient budget. This emphasises the need to consider food waste and other nutrient-rich streams both in the design of PRFs and in the regulatory framework. Similarly, Maglić et al. [26] point out that ballast water sediments, which are often treated like conventional ship waste, may contain harmful substances and therefore require special management protocols to prevent pollution.

A number of studies have analysed the dynamics of governance and the perspectives of those involved. Bukša et al. [27] propose an optimisation-based trade-off model for nautical tourist ports that considers both revenue generation and environmental protection objectives. Although developed in a different context, the underlying principle of striking a balance between economic profitability and environmental responsibility strongly aligns with the core objectives of the PRF Directive, which aims to ensure that port waste reception systems are both financially sustainable and environmentally effective. Against this background, the challenge in setting appropriate waste charging structures is twofold: ensuring that operating costs are covered while incentivising proper waste disposal and minimising marine pollution.

Özkaynak and İçemer [28] analyse the management of ship-generated waste in Turkish and international ports using a stakeholder-based survey approach. Their analysis reveals significant differences in tariff structures, not only between countries, but also between ports within the same national system. Also, the disparities in technical capacity and staff knowledge are noted. These findings point to systemic inconsistencies that may hinder effective implementation of the PRF Directive. The authors emphasise the need for harmonised charging mechanisms and improved training of both ship and port personnel as cornerstones for improving compliance with the Directive and operational efficiency in all EU ports.

The operation of cruise ships proves to be a particularly complex area. While the study by Kotrikla et al. [29] focuses geographically on the Caribbean, it points to the significant amounts of waste generated by cruise ships, highlighting a broader global challenge. The findings reinforce the view that the cruise industry is a significant contributor to ship-generated waste, requiring well-developed port reception facilities and harmonised management practices. This emphasises the importance of sound and consistent implementation of the PRF Directive, especially in ports frequently visited by large passenger ships.

Complementing this case-based insight, Sanches et al. [30] offer a broader literature review that confirms the complexity of cruise ship waste management and the increasing academic attention driven by rapid tourism growth. Together, these studies underscore the urgent need for port reception systems that are tailored to the specific challenges of the cruise sector—both in terms of infrastructure and policy. This is particularly relevant when considering the aims of the PRF Directive, which seeks to ensure adequate, accessible, and efficient reception facilities across all vessel types.

Although considerable methodological and empirical progress has been made, particularly in performance measurement and environmental impact assessment, the integration of regulatory, financial and operational dimensions in ports remains uneven. Customised solutions that take into account the size of the port, the composition of traffic, the type of waste and local environmental pressures are essential for the effective implementation and enforcement of the PRF Directive.

3. Research Approach

This study combines qualitative and quantitative analyses to examine the transposition and implementation of Directive (EU) 2019/883 on port reception facilities for ship-generated waste (PRF Directive) across selected European countries. The methodological process comprises several key stages. First, relevant legal and strategic documents were systematically collected, including national legislation, port waste management plans, and publicly available data from annual reports and tariff regulations of selected European ports. Particular attention was given to ports with the highest reported waste delivery volumes, as identified in the EMTER 2025 report [8].

Second, a comparative analysis was undertaken of the charging models employed for waste reception services, encompassing indirect fee systems, direct charging, prepaid schemes, and hybrid approaches. This was complemented by an assessment of how national frameworks have transposed the PRF Directive’s requirements, with a focus on the development and operationalisation of port-level waste management plans.

Thirdly, a focus group was organised with port authorities, concessionaires and other relevant stakeholders. During the meeting, the participants discussed the criteria for the assessment of cost recovery systems (CRS) and considered whether they are applicable in practice. On this basis, an evaluation framework was developed to systematically evaluate each CRS model. Participants were asked to rate the models against the agreed criteria and to rank the criteria in order of importance to gain an insight into stakeholder priorities. A total of nine criteria were used: simplicity of charging, incentivising waste delivery, administrative burden, compliance with the EU Directive, financial sustainability, fairness to users, environmental effectiveness, transparency and monitoring, and flexibility/adaptability.

In the next phase, the results of the focus group were combined with a multi-criteria decision-making approach to select the optimal charging model for ports. In particular, the ranking of criteria produced by the stakeholders was integrated into the TOPSIS (Technique for Order Preference by Similarity to Ideal Solution) process, which enables the systematic evaluation of alternatives based on several weighted criteria. This approach enabled the identification of the charging model that best reconciles compliance, financial sustainability and operational feasibility. The methodological design follows the framework proposed by Ogonowski [31] adapted and calibrated using the data from the stakeholder inputs (including port authorities, concessionaires, and other relevant stakeholders). Methodological framework for evaluating cost recovery systems in ports is presented in Figure 1.

4. Cost Recovery Systems (CRS) in European Ports

4.1. Approaches to CRS Models

Effective waste management in ports is crucial to reducing illegal discharges of ship-generated waste into the marine environment. Both international regulations (MARPOL) and regional frameworks, such as the PRF Directive, require ports to provide adequate port reception facilities and to establish transparent and fair cost recovery systems (CRSs).

The underlying principle is the polluter pays principle: the costs of waste management infrastructure and services in ports should not only be borne by the ships discharging waste, but should be passed on to all port users. This will remove the financial incentive for illegal discharges [32].

Within the European Union, cost recovery is regulated in more detail by the PRF Directive [2]. The Directive sets out minimum requirements for cost recovery systems (CRS) in EU ports and introduces several important obligations [2]:

• All ships calling at EU ports must pay an indirect fee, regardless of whether they actually deliver waste.
• This indirect fee must cover a significant part of the operating costs of PRFs, in particular the total cost of managing waste in accordance with MARPOL Annex V (garbage).
• Direct fees may still be charged, but only for waste quantities that exceed “reasonable quantities” or for certain waste streams such as exhaust gas cleaning residues (EGCS sludge) or cargo residues.
• Finally, ports must ensure that all fees are set in a transparent and proportionate manner that reflects the actual costs of providing the service while avoiding a disproportionate burden on port users.

The choice of cost recovery system is not uniform in maritime ports, but depends strongly on the type of port and the waste streams it typically handles. In accordance with the GloLitter Guidance [32], a number of general considerations have been made regarding the use of cost recovery systems. In large cargo ports, where significant volumes of oily residues (Annex I) and garbage (Annex V) are generated, hybrid systems combining an indirect fee with additional direct charges for excess volumes are often considered most effective as they strike a balance between fairness and predictable revenues. In contrast, passenger and cruise ports generate significant volumes of mixed garbage and sewage, making the no-special-fee system particularly suitable as it removes financial barriers for ships producing large volumes of waste per voyage, while encouraging waste separation and recycling. Fishing ports face different challenges, particularly for plastics and operational waste, where cost recovery is often linked to national extended producer responsibility (EPR) schemes or supported by public subsidies. Finally, in small marinas and leisure ports, where waste flows are less predictable and volumes are limited, implementing CRS models is further complicated by highly seasonal traffic patterns and a predominance of recreational users, whose waste generation is irregular and often poorly documented. As a result, simplified or locally funded systems are often favoured over complex CRS structures. These differences illustrate that while the legal framework provides a common basis, the practical design of CRS models needs to be adapted to the operational profile of each type of port.

Based on the requirements of Directive (EU) 2019/883 and the Commission implementing Regulations [33,34], the GloLitter Guidance [32] and taking into account the practices applied in different Member States, five main categories of cost recovery models for ship-generated waste can be distinguished (

Table 1. Overview of CRS models for ship-generated waste.

Model	Key Characteristics	Advantages	Disadvantages
Indirect (Contributory) Fee	Fixed or partly variable fee, usually included in port dues; applies regardless of waste delivery.	Encourages regular delivery since the cost is already covered; administratively simple; predictable for shipowners.	May not cover all MARPOL waste streams; smaller waste generators may feel overcharged.
Contributory Fee with Thresholds	Standard quantities covered (based on ship size, type, or voyage); excess amounts charged separately.	Fairer distribution of costs; avoids overburdening low-waste ships; incentivises waste minimisation.	More complex administration; requires accurate thresholds and monitoring.
Prepaid with Reimbursement	Ships pay in advance; partial refund possible depending on actual use of PRFs.	Aligns cost with actual delivery; strong incentive for proper reporting and monitoring.	Administratively demanding; requires robust documentation and auditing.
No-Special-Fee/All-In	All basic waste streams included in port dues; only exceptional types (cargo residues, hazardous waste) charged separately.	Removes financial barriers; proven to increase waste delivery; especially effective for cruise/passenger ports.	Risk of cross-subsidisation (ships generating little waste still pay); may not cover costly special streams.
Sanitary Due + Direct Fee	Basic costs covered by a sanitary due; special waste streams (e.g., EGCS sludge, cargo residues) charged directly.	Ensures minimum cost recovery while targeting polluters of special streams; adaptable to local needs.	Can create confusion; requires clear separation between “covered” and “direct fee” waste.

).

4.2. Comparative Analysis of Leading European Ports

Year 2023 was the first full year of data reporting under the PRF Directive. The EMTER 2025 [8] report shows that the ports of Rotterdam [35], Antwerp [36], and Copenhagen Malmö Port (CMP) [37] received the largest volumes of ship-generated waste, making them important reference points for analysing the application of different cost recovery systems in practice. Comparison of CRS models for ship -generated waste in European ports is presented in

Table 2. Comparison of CRS models for ship-generated waste in European ports.

Criteria	Rotterdam	Antwerp	Copenhagen Malmö Port (CMP)
Delivered waste (2023)	475,000 m3	210,000 m3	132,000 m3
CRS model	Contributory (indirect fee) integrated into shipping dues; standard volumes included, excess charged separately.	Hybrid system: compulsory indirect fee covering all ships + direct charges for extra services or excess amounts.	No-special-fee model: reception costs included in port dues; special streams charged separately.
Types of waste covered	MARPOL Annex I, IV, V (oily waste, sewage, garbage).	Broad coverage: MARPOL Annex I, II, IV, V, VI (incl. scrubber residues).	MARPOL Annex I, IV, V, VI + segregated recyclables (glass, metal, e-waste).
Digitalisation/monitoring	Port Community System (PCS); electronic reporting.	Linked with THETIS-EU; digital tracking and reporting.	Technical requirements (standard flanges, packaging); detailed waste segregation rules.
Incentives/penalties	Discounts for “clean ships” using alternative fuels or with lower footprint.	“Green ship” discounts; penalties for non-compliance or non-reporting.	Strong focus on recycling and user campaigns; no special fee encourages compliance.
Port profile	Europe’s largest cargo hub: containers, tankers, bulk.	Multifunctional port: containers, tankers, industry, limited passengers.	Multi-purpose port with strong cruise traffic

.

The results of the comparison show that Rotterdam, as the largest European freight hub, relies on a contribution system integrated into the shipping charges, which ensures predictable cost recovery and, at the same time, levies additional charges for excess volumes. Antwerp takes a hybrid approach, combining a mandatory indirect fee with direct charges for specific services, covering a wider range of MARPOL waste flows. In contrast, the Port of Copenhagen-Malmö (CMP) applies a no-special model, where most waste reception costs are integrated into the port dues and the focus is on separation and recycling, an approach that is particularly suitable for the significant cruise traffic.

The analysis of waste management plans in major European ports reveals several common trends in the implementation of cost recovery systems (CRS). One of the most notable developments is the increasing use of environmental incentives, where ports offer discounts and rebates to ships with advanced environmental performance. To illustrate environmental incentives, the Port of Helsinki offers an environmental discount of up to 11% on vessel charges for ships with a high Environmental Ship Index (ESI) score, low noise emissions, or verified environmental innovations [38].

Ships powered by liquefied natural gas, equipped with shore power connections or certified under programmes such as the Green Award or Environmental Ship Index (ESI), can benefit from reduced fees, directly linking CRS to wider sustainability goals.

Another important trend is the introduction of special regulations for certain transport segments. Liner vessels, short sea shipping and passenger vessels are often subject to differentiated cost recovery schemes, reflecting the fact that their operating patterns and waste profiles differ significantly from those of bulk carriers or tramp vessels.

At the same time, digitalisation is changing waste management in ports. Ports are increasingly requiring waste reports and delivery confirmations to be submitted via online platforms using electronic forms and automated reporting systems. In the Port of Rotterdam, digital tools such as the geoFluxus Waste Profile Platform enable companies to map and monitor their waste flows in real time, optimise processing routes, and support circular economy objectives [39]. The Port of Antwerp–Bruges has implemented the APICS web application and the Port Dues Portal, which allows shipping agents to submit ship waste declarations and manage port charges online [40]. The Copenhagen–Malmö Port (CMP) operates an Agent Portal for electronic pre-arrival notifications and waste reporting, streamlining communication between ship operators and port authorities [41]. This change not only simplifies administrative processes for shipowners and agents but also increases transparency and data quality for the authorities.

Finally, all ports analysed have specific regulations for hazardous waste streams. These types of waste generate higher handling and treatment costs, and the ports, therefore, apply specific procedures and additional charging mechanisms to ensure their proper management.

Following the previous analysis, variations in governance structures, traffic composition, and policy priorities are the main reasons why the CRS model differs across countries. Greater harmonisation and transparency are observed at ports operating within centralised regulatory frameworks and stable financial mechanisms. In contrast, ports governed locally or through concession-based arrangements often adapt CRS models to local operational realities. The degree of digitalisation and integration of environmental incentives also reflects broader national strategies towards sustainability and circular economy goals. The PRF Directive provides a common regulatory framework, but its practical application remains context dependent.

5. Design of the Evaluation Framework for CRS Models

In order to assess the suitability of different cost recovery systems (CRS), an evaluation framework was developed in a focus group involving representatives of Croatian port authorities, concessionaires, and other key stakeholders (such as shipping companies, Harbour Master’s Office). The aim was to capture different perspectives and ensure that the assessment tool reflected both legal requirements and operational concerns.

The selection of evaluation criteria was based on a synthesis of several sources. In addition to the relevant provisions of Directive (EU) 2019/883 and its implementing regulations, the framework drew on recent studies addressing the performance of port reception facilities and charging schemes [19,24,27] as well as on the GloLitter Guidance [32] and examples of cost recovery systems applied in other European ports. An initial list of ten potential criteria was derived from the literature review and refined through stakeholder consultations. Following stakeholder consultations, overlapping items were merged and prioritised, resulting in a final set of nine criteria that ensure balanced coverage of economic, administrative, regulatory and environmental aspects.

Additionally, participants ranked the criteria by perceived importance, and the Borda count method was used to aggregate their preferences into a collective weighting scheme. The focus group process validated the applicability of the criteria in real port contexts.

The resulting criteria cover a wide range of considerations:

• Simplicity of charging: how easy is the system to apply in practice?
• Incentive to deliver waste: the extent to which the system encourages ships to use port reception facilities.
• Administrative burden: the amount of paperwork and reporting required from both ports and ship operators.
• Compliance with the EU Directive: alignment with the obligations of Directive (EU) 2019/883.
• Financial sustainability: the ability of the system to ensure stable funding of PRF infrastructure and services.
• Fairness towards users: equitable distribution of costs between different ship types and operators.
• Environmental effectiveness: the extent to which the model reduces illegal discharges and supports recycling.
• Transparency and monitoring: clarity of the charging system and the ability to monitor compliance.
• Flexibility and adaptability: the ability of the model to adapt to different port types and traffic segments.

By applying these criteria in a systematic manner, the evaluation framework allows a comparative evaluation of CRS models and helps to identify which approaches are most suitable under different circumstances.

6. Research Methodology: TOPSIS and Sensitivity Analysis

This study applies a multi-criteria decision-making approach to evaluate CRS models for port reception facilities. The methodological framework combines stakeholder input, the definition and weighting of evaluation criteria and the application of the TOPSIS technique (Technique for Order of Preference by Similarity to Ideal Solution), supplemented by type-specific adjustments and sensitivity analyses. The approach is based on the model proposed by Ogonowski [31], adapted to the context of European ports and based on data collected from port authorities, concessionaires and other relevant stakeholders. The analysis was performed in the R programming language (version 4.3.2), The R Foundation for Statistical Computing, 2022) within the RStudio development environment (version 2023.12.0 Build 369; © 2009–2023 Posit Software, PBC). The list of nomenclature and symbols used in research methodology is available in Supplementary materials (Table S1).

6.1. Definition of the Problem and Criteria

The selection of an optimal charging model for waste reception services in ports represents a multi-criteria decision problem. Nine evaluation criteria were defined on the basis of a focus group with representatives of port authorities, concessionaires and ship operators. The alternatives evaluated included five CRS models: indirect fee, contributory with thresholds, prepaid with reimbursement, no special fee/all-in, and sanitary due + direct charging.

6.2. Determining the Weights of Criteria

The approach was adapted to be based on the ranking of criteria provided by the stakeholders. In the focus group, representatives of port authorities, concessionaires and ship operators were asked to rank the nine criteria on a scale from 1 (most important) to 9 (least important).

The Borda method, which is frequently used in multi-criteria decision-making, was used to aggregate these ratings. According to this method, each criterion j receives points $p_{ik}$ depending on its position in the ranking assigned by respondent k. The highest rank (1) was assigned 9 points, while the lowest rank (9) received 1 point. The total score for each criterion is then obtained as:

$$P_j=\sum _i{p}_{ik}$$

(1)

where $P_j$ represents the aggregated importance score of criterion j based on all participants’ responses.

The assigned points are the inverse of the rank. The total score for each criterion was then normalised into a weight vector:

$$w_j=\sum _{j=1}^n{P}_j, \sum _{j=1}^n{w}_j=1$$

(2)

where n is the number of criteria.

6.3. TOPSIS Method—Ranking of CRS Models

To rank the charging models, the TOPSIS method was applied. The method is based on the principle that the best alternative is the one closest to the “ideal” solution and furthest from the “anti-ideal” solution.

The procedure involved the following steps:

• Decision matrix construction: data collected during the focus group (scores on a 1–5 scale for each model against each criterion) were structured into a decision matrix:

$$X=\left[x_{ij}\right]$$

(3)

where $x_{ij}$ is the score of model i under criterion j.

2.

Normalisation: the matrix was normalised to ensure comparability across criteria:

$$x_{ij}^{\prime }={\displaystyle \frac{x_{ij}}{\sqrt{\sum _{i=1}^m{x}_{ij}^2}}}$$

(4)

3.

Weighted matrix: normalised values were multiplied by the weights of the criteria:

$$v_{ij}={ w}_j\cdot x_{ij}^{\prime }$$

(5)

where $w_j$ are the weights obtained from the ranking of criteria by stakeholders.

4.

Ideal and anti-ideal solutions: the best (A⁺) and worst (A⁻) values for each criterion were defined as:

$$A^{+}=\left\{\underset{i}{\max }{v}_{ij},\forall j\in J\right\},\hspace{1em}{A}^{-}=\left\{\underset{i}{\min }{v}_{ij},\forall j\in J\right\}$$

(6)

5.

Distance from ideal and anti-ideal: for each model, the Euclidean distance was calculated:

$$d_i^{+}=\sqrt{\sum _{j=1}^n{\left(v_{ij}-A_j^{+}\right)}^2,}{ d}_i^{-}=\sqrt{\sum _{j=1}^n{\left(v_{ij}-A_j^{-}\right)}^2}$$

(7)

6.

Closeness coefficient—A relative closeness index was computed:

$$C_i^{*}={\displaystyle \frac{d_i^{-}}{d_i^{+}+d_i^{-}}},0\le C_i^{*}\le 1$$

(8)

• Ranking—CRS models were ranked according to the value of $C_i^{*}$, with the highest score indicating the most suitable model.

6.4. Port-Type Weighting Multipliers for Contextual Adaptation

To adapt the methodology to different operational contexts, the base weights $w_j$ were adjusted using multipliers for the port type $m_j^{type}$. These multipliers reflect the different priorities of passenger/cruise, cargo, fishing and marina ports. The adjusted weights were then renormalised as follows:

$$w_j^{type}={\displaystyle \frac{w_j\cdot m_j^{type}}{\sum _{l =1}^n{w}_l\cdot m_l^{type}}}, \sum _{j =1}^n{w}_j^{type}=1$$

(9)

where l is an auxiliary index summing over all criteria.

The selection of multipliers was based on previous studies and policy recommendations for different port categories. The adjustments were defined as follows:

• Passenger cruise ports: greater emphasis on fairness, environmental effectiveness, and transparency (+20%), less emphasis on flexibility (−10%).
• Cargo ports: greater emphasis on financial sustainability and reduced administrative burden (+20%), less emphasis on fairness (−10%).
• Fishing ports: greater emphasis on simplicity of charging and flexibility (+20%), less emphasis on compliance with EU regulations (−10%).
• Marinas: greater emphasis on environmental efficiency and transparency (+20%), less emphasis on administrative burden (−10%).

7. Results

7.1. Criteria Weights

The aggregation of the stakeholder rankings using the Borda method [42] produced a normalised weight vector for the nine evaluation criteria. The results (

Table 3. Calculated weights of evaluation criteria.

Criterion	Points	Weight (wj)
Simplicity of charging	37	0.164
Incentive to deliver waste	35	0.156
Compliance with EU Directive	32	0.142
Fairness to users	30	0.133
Environmental effectiveness	26	0.116
Financial sustainability	22	0.098
Administrative burden	21	0.093
Transparency and monitoring	17	0.076
Flexibility/adaptability	5	0.022

) show that participants gave the highest priority to the simplicity of charging (0.164) and the incentive to deliver waste (0.156). This was followed by compliance with the EU Directive (0.142) and fairness to users (0.133). In contrast, flexibility/adaptability (0.022) and transparency and monitoring (0.076) were rated as less critical under the current conditions.

This distribution indicates that stakeholders place the greatest value on practical applicability and regulatory compliance and consider adaptability to different contexts to be of secondary importance.

7.2. TOPSIS Results: Rankings of CRS Models

The results of the TOPSIS procedure are presented below.

Table 4. Normalised values of CRS models obtained by multiplying criteria scores with corresponding weights.

	Criteria
CRS Model	Simplicity of Charging	Incentive for Waste Delivery	Administrative Burden	Compliance with EU Directive	Financial Sustainability	Fairness Towards Users	Environmental Effectiveness	Transparency and Monitoring	Flexibility/Adaptability
Indirect (Contributory)	0.082	0.059	0.053	0.061	0.044	0.047	0.047	0.027	0.009
Contributory + Thresholds	0.059	0.066	0.031	0.072	0.044	0.071	0.047	0.037	0.010
Prepaid + Reimbursement	0.055	0.077	0.027	0.063	0.052	0.065	0.057	0.041	0.009
No-Special-Fee (All-In)	0.092	0.080	0.053	0.061	0.033	0.047	0.059	0.027	0.009
Sanitary Due + Direct	0.073	0.063	0.036	0.061	0.044	0.063	0.047	0.036	0.012
Weights	0.1644	0.1556	0.0933	0.1422	0.0978	0.1333	0.1156	0.0756	0.0222
The nature of the criteria	s	s	d	s	s	s	s	s	s

s—stimulant; d—destimulant.

shows the weighted decision matrix resulting from the application of the weights derived by the stakeholders to the normalised values for each criterion. The categorisation of the criteria as stimulating or destimulating is also indicated.

The ideal (A⁺) and anti-ideal (A⁻) solutions were determined on the basis of the weighted values (

Table 5. Ideal and anti-ideal solutions for CRS models.

Criterion	Simplicity	Incentive	Administrative Burden	Compliance	Financial Sustainability	Fairness	Environmental Effectiveness	Transparency	Flexibility
Ideal (A+)	0.092	0.080	0.027	0.072	0.052	0.071	0.059	0.041	0.012
Anti-ideal (A−)	0.055	0.059	0.053	0.061	0.033	0.047	0.047	0.027	0.009

). For stimulants, the ideal corresponds to the maximum value and the anti-ideal to the minimum value, while the rule is reversed for destimulants.

The distance of the tested objects from the ideal (d+) and anti-ideal (d−) solution is shown in

Table 6. Distances of CRS models from ideal and anti-ideal solutions.

CRS Model	d+	d−
Indirect (Contributory)	0.048	0.030
Contributory + Thresholds	0.039	0.038
Prepaid + Reimbursement	0.039	0.045
No-Special-Fee (All-In)	0.044	0.044
Sanitary Due + Direct	0.034	0.033

.

The result of the calculation of the coefficient of the relative proximity C* of the decision variants to the ideal solution allowed for obtaining a ranking is shown in

Table 7. Ranked CRS models according to TOPSIS score.

CRS Model	C*
Prepaid + Reimbursement	0.53677263
No-Special-Fee (All-In)	0.497639985
Sanitary Due + Direct	0.497145547
Contributory + Thresholds	0.491209859
Indirect (Contributory)	0.380717999

. Additionally, supplementary comparison of alternatives based on TOPSIS distances is available in Supplementary materials (Figure S1).

When type-specific multipliers were applied to account for the contextual characteristics of the different port categories, the results shifted compared to the baseline scenario (

Table 8. Best-performing CRS models by port type.

Port Type	CRS Model	C* Value
Passenger–Cruise	No-Special-Fee (All-In)	~0.529
Cargo–Container	Prepaid + Reimbursement	~0.527
Marinas/Small Craft	No-Special-Fee (All-In)	~0.514
Fishing Ports	Prepaid + Reimbursement	~0.524

).

These results confirm that the optimal CRS model is context dependent. Passenger and leisure ports favour systems without special fees, which simplify administration and promote compliance. Cargo and fishing ports, on the other hand, tend to favour prepaid and reimbursement models.

7.3. Sensitivity Analysis Results

To further test the robustness of the results, a sensitivity analysis was carried out in which the weighting of the environmental effectiveness criterion was varied for different port types. The analysis illustrates how changes in ecological priorities influence the relative ranking of the CRS models (Figure 2).

In cargo container ports, the No-Special-Fee (All-In) and Prepaid + Reimbursement models gained in rank when the multiplier for environmental effectiveness was increased, while Contributory + Thresholds and Indirect declined. This indicates that in the freight sector, a stronger emphasis on ecology favours “all-in” and “prepaid” schemes.

In marinas and small ports, the picture was more dynamic. At higher multipliers, Sanitary Due + Direct lost its initial advantage and was overtaken by No-Special-Fee (All-In), suggesting that environmental priorities may shift the balance between competing models in leisure-oriented ports.

In passenger–cruise shipping ports, the pattern was similar to that of cargo ports: No-Special-Fee (All-In) and Prepaid + Reimbursement improved their relative position, while Indirect and Contributory + Thresholds fell. Sanitary Due + Direct remained in a middle position, but showed a gradual decline.

In the fishing ports, the trends were almost identical to those in the marinas: higher ecological multipliers allowed No-Special-Fee (All-In) to overtake Sanitary Due + Direct, confirming the sensitivity of smaller ports to environmental weighting.

Overall, the analysis shows that environmental effectiveness is one of the most decisive criteria and has the potential to change the top-ranked model in certain port contexts, especially in marinas and fishing ports.

8. Discussion and Conclusions

The results of this study highlight the complexity of implementing cost recovery systems (CRS) in European ports. The evaluation framework developed with stakeholders was effective in capturing both legal requirements and practical considerations. However, a key finding is that the importance of individual criteria varies across contexts. Ports differ in their traffic composition, waste profiles, and institutional environments, meaning that the same charging model cannot be applied everywhere with equal success. The framework must therefore remain flexible, allowing the weighting of criteria to be adjusted according to the priorities of political decision-makers and port communities.

A second important finding is the crucial role of environmental effectiveness. Models that include ecological incentives—such as No-Special-Fee (All-In) and Prepaid + Reimbursement—consistently perform better when environmental priorities are emphasised, achieving C* values between 0.514 and 0.529 across port types. This was confirmed by the sensitivity analysis, which showed that increasing the weighting of environmental effectiveness shifted the ranking of the models across all port types. The effect was particularly strong in marinas and fishing ports, where relatively small adjustments in ecological priorities were sufficient to overturn the initial ranking of the models. This suggests that environmental effectiveness is a decisive criterion, capable of reshaping port-level preferences, and that the design of CRS should be closely aligned with the broader EU sustainability agenda.

The comparison with existing policy guidance, such as the GloLitter recommendations, further reinforces this point. In passenger and cruise ports, both the results and the recommendations support No-Special-Fee (All-In) as the optimal model. In cargo ports, however, the results diverge: the modelling indicated Prepaid + Reimbursement, while the guidance tends to recommend hybrid contributory systems with thresholds. In fishing ports and small marinas, the outcomes again show partial overlaps but also differences. The model results favoured prepaid or All-in approaches; policy guidance emphasises the importance of subsidies, extended producer responsibility (EPR) schemes, or simplified local systems. These differences underline that, while quantitative modelling is useful for identifying robust patterns, policy frameworks introduce additional social and institutional dimensions—such as fairness, subsidiarity, or funding arrangements—that go beyond the purely technical evaluation of criteria. Despite the progress made with the PRF Directive, significant challenges remain in practice. While large commercial ports increasingly benefit from integrated digital tools such as the Port Community System (PCS), smaller marinas and leisure ports still rely on manual procedures and fragmented reporting. As demonstrated by Deja et al. [43] PCS can serve as a single digital platform integrating waste notifications, monitoring, and coordination among stakeholders. Although primarily implemented in larger ports, such systems could be adapted or simplified for smaller marinas to improve data consistency, traceability, and compliance with the PRF Directive.

Additionally, reporting on waste volumes is still inconsistent, with some ports not providing complete or comparable data. This undermines the transparency and monitoring function of CRS and makes it difficult to share best practices. Stricter enforcement of reporting requirements, combined with the digitalisation of procedures, would not only improve oversight but also reduce the administrative burden for both ports and ship operators. Addressing these gaps is particularly important, given that the sensitivity analysis demonstrates how strongly the final outcomes depend on the accuracy of input data and the correct calibration of multipliers for port types.

From a policy perspective, several recommendations can be made:

• Strengthen incentives for ecological performance by systematically linking CRS incentives to environmental certifications and technologies.
• Ensure full compliance with reporting obligations, with EMSA and national authorities providing guidance and technical support to smaller ports.
• Promote harmonisation and comparability between ports, leaving room for contextual adjustments in the weighting of criteria.
• Encourage stakeholder involvement in the design and review of CRS to ensure that systems remain both practical and fair.

In conclusion, the analysis shows that CRS models cannot be evaluated independently of their regulatory, environmental, and operational context. The study offers several novel contributions: it develops a structured, nine-criterion evaluation framework based on stakeholder input; applies and contextually adapts the TOPSIS method using port-type-specific multipliers; and empirically demonstrates that environmental effectiveness is a decisive, rank-shifting criterion, especially for smaller ports. The proposed framework provides a structured, data-driven tool for balancing legal, operational, and ecological dimensions. By appropriately weighting the criteria and integrating ecological priorities, ports can establish cost recovery schemes that ensure financial sustainability while actively supporting EU environmental objectives and marine pollution prevention.

9. Limitations of a Study and Future Work

The developed framework provides a structured basis for assessing CRS models, but its application is subject to certain limitations, such as the detail and update frequency of documents related to waste management; data inconsistencies across Member States; limited full comparability; and the weighting of criteria based on a limited regional sample. Future work should focus on expanding the stakeholder base across different EU regions, integrating longitudinal data to capture regulatory evolution, and exploring hybrid multi-criteria approaches that combine quantitative modelling with behavioural and institutional analysis.