ESWET and CEWEP fully support the reduction of greenhouse gases in the waste sector. Integrating Waste-to-Energy (WtE) into the EU Emissions Trading System (ETS) in its current form, however, would create unintended environmental and economic impacts without delivering the expected climate or circularity gains.

To ensure the ETS can effectively contribute to a climate-neutral waste system, substantial adjustments are essential. The sector stands ready to work with policymakers to develop a tailored, future-proof framework that enables a successful transition to climate neutrality.

WHAT CAN BE DONE?

1. Carbon pricing in waste management needs to go together with measures to ensure the EU waste goals and the Circular Economy Act will be realised landfill reduction first

Landfill reduction first
Despite several efforts to reduce landfilling over the past decades, landfill rates in many EU Member States remain persistently high, resulting in significant methane emissions.
Diverting recoverable waste from landfills to higher levels of the waste hierarchy, such as recycling and WtE, will substantially reduce methane emissions, save primary raw materials and deliver greater CO₂-equivalent savings than carbon capture technologies or carbon pricing alone.

Carbon pricing for WtE may result in more waste going to landfills (waste leakage) because WtE and Recycling would become more expensive.

2. Carbon Capture, Utilisation and Storage (CCUS)  is a concrete vision and part of the ultimate solution, but there is no business case yet for the WtE sector

The development of CCS and CCU in the WtE sector is still at an early stage. While the potential for carbon use and long-term carbon storage is significant – and may ultimately contribute to negative emissions – progress is currently hindered by the absence of CO₂ transport and storage infrastructure, high upfront costs, a lack of effective financial support and robust regulatory framework.

The current EU Taxonomy framework further increases investment uncertainty, limiting the sector’s ability to scale up these technologies. Further limitations of CCUS are the space occupancy of carbon capture units and their significant energy consumption, which lowers the delivery of energy from WtE plants.

3. Apply the Polluter – Pays Principle where it works

WtE plants are not the origin of the fossil carbon contained in waste; rather they represent the final treatment option for non-recyclable plastics and other fossil carbon containing materials, which are a growing global challenge. Responsibility for the climate impacts  associated with the thermal treatment of virgin, fossil-based, non-recyclable materials should therefore be shared with producers.

This could be achieved by further developing Extended Producer Responsibility (EPR) schemes covering the treatment of residual waste containing fossil carbon. While fossil CO₂ emissions from waste could continue to be measured and reported at WtE facilities (downstream), the financial obligation under the EU ETS should be shared
upstream to actors with decision-making power over product design and material inputs, including manufacturers and virgin fossil fuel suppliers (upstream).

This would create incentives to reduce virgin fossil-based content in products while also helping EU recyclers, struggling today with low-priced virgin plastics flooding the EU market.

4. Foresee a future where carbon is made circular as a resource and where waste is valorised via material and energy recovery. 

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