Response to EC Consultation on the Climate Delegated Act and Environmental Delegated Act of the EU Taxonomy

We appreciate the opportunity to contribute to the European Commission consultation on the Climate Delegated Act and Environmental Delegated Act of the EU Taxonomy. We welcome the Commission’s efforts to simplify and clarify the technical screening criteria for several economic activities and would like to take this opportunity to draw attention to an important issue that remains unaddressed: the absence of WtE from the EU Taxonomy.

This omission has persisted despite a long-standing demand from stakeholders and growing recognition of WtE’s essential role in treating non-recyclable waste, securing energy and secondary materials, supporting landfill diversion, reducing methane emissions, and contributing to Europe’s climate and circular-economy objectives.

We note that this discussion is not new. In June 2023, when adopting the Environmental Delegated Act with the support of the Platform on Sustainable Finance, the Commission explicitly acknowledged – in recital 15 on page 14 – its intention to consider the recycling of Incinerator Bottom Ash (IBA) in the next revision of the EU Taxonomy. This acknowledgement confirms that the sector is relevant to the Taxonomy framework, even if not yet fully reflected in it.

In addition, the latest report of the Platform on Sustainable Finance invited stakeholders to identify new activities for inclusion in the Taxonomy. Numerous submissions requested the inclusion of WtE. While the report acknowledges these requests, it ultimately made no recommendation on WtE and offered no explanation for its omission. This lack of clarity on whether WtE-related activities are Taxonomy-aligned remains a concern for the sector, and becomes even more problematic when considering the integration of Carbon Capture for Utilisation or Storage (CCUS) in WtE plants.

For these reasons, we believe it is necessary to reopen the discussion on the inclusion of WtE in the EU Taxonomy.

Click here for the full position paper