ESWET position paper on the EU Commission Call for Evidence for a Circular Economy Act
As the EU moves forward with the Circular Economy Act (CEA), ESWET welcomes this initiative as a timely opportunity to strengthen Europe’s resource security, industrial competitiveness, and environmental sustainability. Reducing the EU’s dependence on imported raw materials and fossil energy requires recognising the contribution of recovery solutions that help keep resources and energy circulating within the European economy.
To achieve a truly circular system, all stages of waste management must work together. While waste prevention, reuse, and recycling remain top priorities under the waste hierarchy, not all waste can be feasibly or safely recycled. Many waste streams are not designed for recycling, or can be contaminated, made of complex composite materials, or degraded to the point where recycling is no longer technically or economically viable. If not properly managed, this residual waste poses serious environmental and health risks, contributing to pollution and undermining Europe’s circularity and climate goals.
Even in a fully circular economy, non-recyclable waste will continue to exist. At present, this waste can only be managed in two ways: either through landfilling or through Waste-to-Energy (WtE), which combines energy and material recovery. Residual waste represents the boundary of what recycling systems can handle, and modern WtE facilities help close the loop by recovering valuable resources that would otherwise be lost.
In this context, WtE should be recognised as a public service – a societal necessity that ensures non-recyclable waste is treated safely and hygienically, without polluting land, water, or air.
Despite these clear contributions, the role of Waste-to-Energy in both resource and energy recovery remains largely overlooked in EU policy frameworks. The Circular Economy Act (CEA) offers a key opportunity to address this gap by recognising WtE as an essential component of a sustainable waste management system.
As the EU works to reduce its dependence on imported raw materials and fossil energy, it must ensure that residual waste is treated in a way that supports resource efficiency, energy recovery, and climate protection. WtE technologies already make this possible, safely transforming what cannot be recycled into heat, power, and secondary raw materials (SRMs).
In addition, recognising WtE as a complementary partner to recycling is essential. By managing non-recyclable fractions including recycling residues, WtE safeguards the integrity of recycling systems, prevents pollution from improperly disposed waste, and recovers energy and materials that would otherwise be lost. Following and supporting recycling, WtE forms the backbone of a circular, resilient, and climate-neutral Europe where no valuable resource is wasted.
This position paper outlines ESWET’s contribution to the legislative discussion and provides concrete recommendations to ensure that the Circular Economy Act fully recognises the role of WtE in managing non-recyclable waste, recovering valuable materials, and supporting the EU’s decarbonisation and circularity goals.