ESWET reply to the EU Commission consultation on GHG savings of low carbon fuels

ESWET welcomes the opportunity to provide feedback to the European Commission on the proposed Delegated Act (DA) and Annex concerning greenhouse gas (GHG) emission savings for low carbon fuels. However, we are concerned that certain elements of the Act and Annex may overlook valuable low-carbon energy sources, such as hydrogen produced from WtE processes and fuels derived from non-recyclable waste. This could hinder their development and integration, limiting the potential growth of these technologies from the start.

ESWET’s main points of concern:

• Prioritising CCU for fuel production from Waste-to-Energy (WtE) can often be a more practical solution for emissions reduction compared to CCS, thus the legislation should enable CCU from WtE.
• Clarification needed on inclusion of biogenic CO₂ from waste incineration under point 10(c).
• Clarification needed on GHG calculation methodology and waste feedstock in low carbon fuel production.
• The sunset clause in point 10(a) of the Annex on deducting captured fossil carbon is very restrictive for hard-to-abate sectors like WtE.
• Point 10 (f) of the Annex should be interpreted in a way that includes captured fossil emissions from WtE facilities as eligible for emissions deduction.
• Clarity and consistency in EU legislation are imperative.
• E ex-use should consider explicitly landfill diversion, also of plastic waste.

Emissions from processing (e p) should consider unavoidable emissions from non-recyclable plastic waste in WtE Plants.

Analytically:

1) Prioritising CCU for fuel production from Waste-to-Energy can often be a more practical solution for emissions reduction compared to CCS, thus the legislation should enable CCU from WtE.

What is more, CCS is often seen as a viable solution for WtE plants to reduce emissions by capturing and storing CO₂. However, it is crucial to specifically recognise and prioritise CCU for fuel production, especially in the context of WtE facilities, as a complementary and sometimes more practical approach.

Coupling CCU with WtE is particularly important because WtE plants not only manage and treat waste — addressing a critical societal need — but also operate in a sector that is inherently hard to decarbonise. Enabling these plants to convert captured CO₂ into renewable synthetic fuels, such as e-methanol or e-kerosene, offers a practical pathway to repurpose emissions, turning waste into a valuable energy resource. This approach is especially relevant when CCS is not feasible due to factors such as high costs, unsuitable locations, lack of access to storage hubs, limited space, or infrastructural challenges.

By allowing and fostering CCU for fuel production from WtE processes, policymakers can provide a flexible and efficient solution that maximises the utility of existing waste streams while contributing to energy transition goals. Legislation should therefore focus on opening doors rather than imposing restrictive measures that could hinder the development of CCU in WtE.

Click here to read the full position paper.