OpenLobby.EU
Explore

AVR-Afvalverwerking B.V.

AVR

AVR is an advanced waste treatment based in Rotterdam (NL) with several other plants in the Netherlands.

Lobbying Activity

Response to Circular Economy Act

29 Oct 2025

The Circular Economy Act should maximise the retrieval of secondary raw materials while remaining technology-neutral and environmentally ambitious. A systematic change should be made with innovation, resource efficiency and the environment at the top of mind. AVR is an innovative Waste-to-Energy (WtE) treatment facility based in Rotterdam and Duiven (NL). As such, AVR strives to retrieve maximal value from mixed household waste and commercial and industrial waste in a circular and environmentally sound manner by retrieving secondary raw materials and converting residual waste into steam, heat and electricity. AVR is also at the forefront of Carbon Capture Utilisation and Storage (CCUS) applications in the waste incineration sector. AVR has a running carbon capture installation for its facility in Duiven, and is on track to install one in its facility in Rotterdam. In 2023, AVR processed 1,634 kt of waste, supplying district heating to 113,000 households. Furthermore, 475 kt of CO2 emissions were avoided, and 43.5 kt of CO2 were captured. AVR asks the European Commission to consider the following policy measures: Implementing a stricter enforcement of European Waste management legislation, in particular the Landfill Directive; Introduce national targets for commercial and industrial waste for landfill reductions as well as for recovery operations; Renouncing harmonised European End-of-Waste criteria in favour of targeted and specifically adapted regional criteria; Introducing financial incentives for secondary raw materials; Limiting the export of waste outside of the EU, especially waste containing critical raw materials; Facilitating waste streams to innovative facilities based on objective and quantifiable comparison criteria.
Read full response

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

AVR is a progressive and advanced Waste-to-Energy treatment facility based in Rotterdam and Duiven (NL). AVR strives to retrieve maximal value from mixed household waste and commercial and industrial waste in a circular and environmentally sound manner by retrieving secondary raw materials from residual waste and converting residual waste into steam, heat and electricity. AVR is also at the forefront of Carbon Capture Utilisation and Storage applications in the waste incineration sector. As such, it has invested in a carbon capture installation for its facility in Duiven and is on track to install a carbon capture installation in its facility in Rotterdam as well. In 2023, AVR processed 1,634 kt of waste, allowing it to supply district heating to 113,000 households. Furthermore, 475 kt of CO2 emissions were avoided, and 43.5 kt of CO2 were captured. AVR is not opposed to the inclusion of waste incineration into the EU Emission Trading System. However, to ensure a minimum of carbon leakage to other sectors, the European Commission must consider the following point in the upcoming revision of the Emission Trading System: - Avoiding carbon leakage through the inclusion of landfills and the treatment of commercial and industrial waste - Introduce incentives for the industry to invest in emission-reducing technologies, e.g. through carbon removals - Remove any additional national taxation system to avoid double taxation of waste incineration companies - Introduce effort-sharing measures to ensure the most efficient and sustainable treatment of waste - Reduce the administrative burden for companies by utilising the existing practices and reporting mechanisms of the sector
Read full response

Meeting with Tom Berendsen (Member of the European Parliament)

15 Oct 2024 · Waste recycling

Response to Amendment of the free allocation rules in response to the ETS revision/Fit For 55

21 Dec 2023

AVR, an advanced Waste-to-Energy (WtE) facility located in the Netherlands, responds to the Commissions call for evidence on the proposed delegated act under the EU Emissions Trading System (EU ETS) with the following. AVR continuously invests in innovative technologies to support the EU's efforts in combating climate change and transitioning to a sustainable and low-carbon economy. Addressing the Concerns in Recital (2) of Regulation (EU) 2019/331: AVR acknowledges the second recital of the delegated regulation proposal, which states the obligations for monitoring and reporting emissions from installations incinerating municipal waste and excludes heat delivered by these installations from the scope of the EU ETS for free allocation purposes. While AVR acknowledges that WtE facilities are not yet included in the EU ETS, AVR argues that WtE facilities will likely be added in 2028 and that especially those facilities employing CCUS differ significantly from conventional waste incineration installations. To that end, we believe the exclusion of WtE providing heat for district heating in the delegated act proposal is counterproductive. Indeed, the delegated act amending the distribution of free allocations would be an adequate mechanism to provide positive incentives for waste incineration installations to apply emission-mitigating technology and play a part in the Energy transition of the EU. The Issue with Free Allocations for District Heating: The current framework of the delegated act allows for free allocations to district heating systems. However, it fails to recognise that advanced WtE facilities, such as AVR, are key contributors to these district heating systems. This exclusion is counterproductive, as it benefits the clients of the heating systems without acknowledging the significant investments and efforts made by WtE facilities to reduce emissions. The EU ETS should more fairly distribute the benefits and responsibilities, recognising the role of WtE in district heating. This oversight not only disincentivises innovation but also places an unfair financial burden on WtE facilities which are crucial for a sustainable energy future. Amendment to the Delegated Act Proposal: Facilities such as AVR that provide heat for district heating and invest in advanced emissions-mitigating technology should be eligible for free allocations under the EU ETS from 2028 onwards. This incentive would encourage the use of advanced emissions-mitigating technology as well as fairly treat facilities that provide heat for district heating. This would lead to a considerable reduction in greenhouse gas emissions from a hard-to-abate sector (non-recyclable waste treatment). In conclusion, AVR urges the inclusion of specific incentives for advanced WtE facilities, such as free allocations for WtE facilities that produce heat for district heating, in the EU ETS. Such measures would not only support innovative facilities in contributing to the EU's climate objectives but also foster technological advancements crucial for a sustainable future within a circular economy. Thank you for considering our perspective on this important matter. We remain committed to working collaboratively towards a greener and more sustainable Europe.
Read full response

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

AVR, a leading Dutch Waste-to-Energy company and active member of CEWEP, employs advanced technologies to meet the highest environmental standards. This approach minimizes emissions, increases energy efficiency, and extracts valuable resources from waste, including using Carbon Capture (CCS/CCU) technology. CCS technologies allow for direct or indirect removal of carbon dioxide from the atmosphere by capturing emissions and having them transported to be stored underground. The integration of CCUS with Waste-to-Energy could capture about 60 to 70 million tonnes of carbon dioxide in Europe every year according to the IPCC publication "Mitigation of Climate Change from April 2022. Please read our full feedback attached.
Read full response

Response to Early Warning Report on Waste

1 Aug 2022

Introduction AVR welcomes the review of the Early Warning Report (EWR) by the European Commission, introducing reports which will effectively keep EU Member States on the right path towards achieving their targets laid out in the ‘2018 Waste Package’. In particular, AVR supports the goal of the EWR to guide the implementation of the Waste Framework Directive and improve the performance of Member States in their waste management. The prohibition of landfilling recyclable waste would be a step in the right direction. In order for waste management to fully enable the circular economy, the whole lifecycle of products needs to be taken into account including their treatment. In addition to CEWEP’s feedback to the European Commission, AVR would like to share two suggestions that the initiative might focus on as best practices for EU Member States: 1. Incentives to utilise CO2 In order to support the transition from a linear to a circular economy, Member States can play an important role by incentivising investments in environmentally sound waste management techniques. An example of such an incentive is the Dutch ‘Sustainable Energy Production and Climate Transition Regulation’ (SDE++) operating subsidy scheme, which started in 2021. This scheme enables investments in carbon capture installations and the energy transition. These types of subsidy schemes support sustainable investments by waste managers to upgrade existing facilities and enable a transition in national waste management by phasing out the disposal of waste in landfills as aimed in the Waste Framework Directive. Therefore, AVR believes that national subsidy schemes contribute to strengthen waste management practises by retrieving more resources from waste. 2. Enable waste hubs with public-private agreements A significant amount of waste in Europe that ends up in landfills still contains valuable resources that will not be recycled or recovered. Through agreements between the Dutch Government and the waste sector, major steps have been made to become more circular. For example, the Dutch ‘Green Deal’ agreement from 2012 that agrees on the quality of bottom ashes and useful application of this material. Nowadays, this agreement has been transposed into national legislation. This example shows that Member States can play a leading role in creating the right conditions to establish waste hubs for environmentally sound waste management by making sure retrieved and recovered materials can be put back on the market. Conclusion AVR welcomes the efforts undertaken by the European Commission to report on the progress of Member States’ transition to environmentally sound waste management. By recommending best practices to Member States, the EWR could have a serious impact on the sustainability of waste management in Europe. If innovative practices such as the extraction of mineral fractions from bottom-ash and carbon capture techniques are supported by Member States, the transition to becoming carbon neutral in 2050 might be accelerated. For more information about AVR's position, please find the document attached.
Read full response

Response to EU Strategy on Adaptation to Climate Change

29 Jun 2020

AVR is a progressive and innovative Waste Recycling Energy Plant (WREP) based in Rotterdam (NL), with several other plants in the Netherlands. WREPs strive to retrieve maximal value from mixed household waste, commercial and industrial waste in a circular and environmentally sound manner. AVR retrieves plastics, metals, propylene, and minerals as secondary raw materials from residual waste and converts the remainder of the residual waste into steam, heat and electricity with a (very) high energy efficiency according to the European R1 energy efficiency formula. In addition, the CO2 is captured, stored, and transported to nearby greenhouses that use it in growing vegetables. For more information please visit www.avr.nl AVR welcomed the European Commission’s proposal for an EU Climate Law, putting into legislation the 2050 target of carbon-neutrality. As the new Strategy for Adaptation to Climate Change will be designed to support the challenging achievement of the EU Climate Law, AVR has designated three main issues for the Strategy to focus on: • Drastic emission abatement measures are only feasible with the implementation of circular innovative technologies of Carbon Capture and Storage/Utilisation; • With the idea of “build-back-better” AVR believes that the ETS fund revenue should also be used to fund emission abatement technologies for non-ETS sectors • Better air and soil quality is crucial to address health issues and biodiversity drop, therefore air-quality improvement measures should take into account how waste is treated by focusing on innovative facilities and help the fight against climate change. AVR welcomes the efforts of the European Commission to use the current crisis in order to bounce back, in a better and greener way. However, to do so it will be very important not to be fully dependent on the public’s opinion and not to neglect fact-based, innovative projects that might be out-of-the-box for now but could be the new norm in a few years. When waste is no longer be seen as such, but as a raw material thanks to advanced technologies, it will open a whole new level of circularity on the European market. AVR is counting on the new Strategy on Adaptation to Climate Change to create a supporting and solution-oriented framework to support and accelerate the deployment of innovative technologies.
Read full response

Meeting with Frans Timmermans (Executive Vice-President) and EEW Energy from Waste GmbH and

9 Jun 2020 · European Green Deal, circular encomony and waste policies