Skip to content

To achieve climate neutrality in the EU by 2050, it’s important to address all the sources of greenhouse gases (GHG) effectively.

In order to achieve climate neutrality in the EU by 2050, it is important to effectively address all sources of greenhouse gases (GHG). To this end, the European Commission is currently reviewing all its policies and is considering expanding the scope of the EU Emission Trading System (ETS) to include municipal waste incineration in other industries. However, the industry claims that ETS should not be applied to waste incinerators, and its inclusion would be counterproductive.

We have reviewed and refuted their claims to demonstrate the multiple benefits of such inclusion and how to do it in practice.

1. Domestic waste incinerators should not be regarded as conventional power stations or industrial installations that burn fossil fuels.

Municipal solid waste incinerators (MSWI) burn municipal or similar waste as fuel to generate energy. Plastics account for a large part of the materials burned in municipal incinerators. Since traditional plastic is derived from petroleum, it is a fossil fuel and is considered a source of harmful climate change emissions.

In addition, MSWI's fossil carbon dioxide emissions have increased by approximately 300% in the past ten years, reaching 52,102 kilotons of fossil carbon dioxide in 2018. Therefore, it is very urgent to solve these emission problems.

2. The WTE plant contributes to the replacement/alternative energy production of fossil fuels.

Compared with traditional fossil power plants such as combined cycle gas turbines (CCGT), MSWI releases more greenhouse gases to produce energy.

In addition, the average carbon intensity of burning municipal solid waste in municipal incinerators is 504-509 gCO2/kWh. This is twice the average carbon intensity of the EU power grid, which was 249 gCO2e/kW in 2019.

Since these infrastructures have a lifespan of about 15 to 20 years, they postpone the much-needed and urgent transition to less carbon-intensive power generation infrastructure (such as wind and solar renewable energy).

3. MSWI helps reduce greenhouse gas emissions from landfills.

Although greenhouse gas emissions from landfills appear to be decreasing, the actual emissions from landfills are being transferred to the energy sector-because more and more waste is being incinerated in MSWI plants. Since the MSWI plant’s greenhouse gas emissions are not reported under the waste sector but under the energy sector, it gives the wrong impression that we are reducing the overall emissions from the landfill.

In fact, according to the latest available data, the total CO2 emissions from waste burning in the MSWI plant in 2018 were approximately 95,425kt CO2, which is almost the same as the 2018 CO2eq emissions from landfills of 99,429kt CO2eq.

4. WTE's ETS cost will have a negative impact on waste management activities with higher waste levels.

The compositional analysis of the residual waste shows that most of the materials currently used as raw materials for incinerators can be recycled or composted. Higher incineration costs will directly encourage improvements in separate collection and sorting processes to recover materials that will eventually remain in the residual waste stream.

This will also develop in the direction of a greater extension of producer responsibility. Higher incineration prices will provide market signals for those who produce non-recyclable and difficult-to-recycle products because they will pay more for climate change costs in design decisions.

5. If energy recovery from waste within the EU becomes too expensive, it is likely that more residual (plastic) waste will be exported to other countries with lower costs or lower environmental and social standards.

In fact, the delivery of residual waste to non-OECD countries has been banned. Shipments to OECD countries may still occur, but they need to go through a process of prior written notification and consent-which means that the importing country must give consent before shipment.

As for illegal transportation, the EU and importing countries are stepping up efforts to combat waste crimes, so it will be more difficult to illegally export residual waste (for example, marking it as recyclable plastic or paper).

6. Since some member states have already imposed taxes on waste incineration, the additional ETS costs will result in double taxation on incineration.

The additional ETS cost mainly affects the cost of burning fossil materials (such as plastic packaging, synthetic clothing, etc.). It can be combined with the overall tax on waste incineration and, if necessary, can be adjusted accordingly. The advantage of combining it with an incineration tax is that it will not only increase the power to recycle fossil materials, but also increase the power to recycle other items such as food waste, paper, and metals.

7. The additional ETS costs will be reflected in higher waste disposal gate fees or energy prices, which means higher costs for citizens, local communities and industries.

It is important to use higher incineration costs to implement the "polluter pays" principle. Therefore, additional costs should be allocated to waste providers/producers as much as possible, for example by charging higher fossil material processing gate fees. Using the "polluter pays" principle to identify polluters, and by allocating to them the cost of carbon emissions, increased incentives to improve classification and reduce the share of fossil content-as well as develop new habits to reduce residual waste.

In addition, the inclusion will help to correct the current unfair competition with renewable energy suppliers (such as wind and solar), which must compete with the relatively cheap energy provided by municipal incinerators, because the current system will not affect fossil fuels. The carbon cost of "fixing" waste incineration.

8. The EU-level general regulatory framework and clear technical guidelines should first be defined as determining the fossil part of CO2 emitted by waste incineration power generation facilities.

There are methods for monitoring fossil CO2 emissions from waste incinerators, such as the radiocarbon ((14)C) method. For example, countries that have voluntarily included waste incinerators in the scope of ETS (Sweden) and facilities that have been included in the EU level (such as joint incineration facilities) use these methods.We recommend combining the radiocarbon method with waste composition analysis. The latter allows consideration of changes in waste composition due to raw materials (for example, the use of more biological materials such as garden waste in certain seasons) or waste collection practices (for example, separate collection of biological waste from the end of 2023). This will allow us to identify the substances being incinerated and assess how many of them are recyclable or reusable, giving decision makers the opportunity to implement new strategies to recycle these materials.

Still have questions about the EU Emissions Trading System (ETS) extension to municipal solid waste incineration (MSWI)? Please contact Janek Vähk (, coordinator of the Climate, Energy and Air Pollution Project.

About the latest post

Joint Press Release: The Broad Alliance urges the European Parliament to protect consumers from dangerous or illegal products sold through Amazon and AliExpress' online marketplace. -15/07/2021 Open letter to the European Parliament-Stop selling and importing illegal products through the online market-15/07/2021 "Chemical recycling" design stifles upstream innovation-12/07/2021

Previous article Reuse the network