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Confederation of European Waste-to-Energy Plants

CEWEP

CEWEP is the European umbrella association representing waste-to-energy plant operators.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

4 Dec 2025

CEWEP - Confederation of European Waste-to-Energy Plants represents owners and operators of European Waste-to-Energy plants. Waste-to-Energy (WtE) is an essential public-service infrastructure that treats residual, non-recyclable waste, supports high recycling quality by removing contaminants and treating residues from the recycling process, and recovers materials and energy that would otherwise be lost. In this way, waste returns to the economy as secondary raw materials and as energy. The Taxonomy Delegated Acts are closely linked with two Commission Notices on interpretation and implementation (also called FAQs): C/2023/6756 (interpreting the Climate Delegated Acts) and C/2025/1245 (interpreting the Climate and Environmental Delegated Act). If the Delegated Acts are reviewed, these Notices should be updated in parallel. In particular, Notice C/2023/6756 contains an interpretation that is not aligned with recent scientific evidence from the Commissions Joint Research Centre and risks hindering circularity for a critical raw material phosphorus. Updating the Notices should therefore ensure alignment with the latest scientific findings. CEWEP calls for: - Reviewing the Commission Interpretation Notices at the same time as the Environmental Delegated Acts to avoid inconsistencies and legal uncertainty. - Aligning the Notices with recent findings by the JRC regarding the need for mono-incineration of sewage sludge, to support investment in phosphorus recovery, which is covered in the Environmental Delegated Act. - Clarifying in these Notices the interpretation of significant increase in waste incineration under DNSH to provide clarity for non-hazardous, non-recyclable waste streams where incineration delivers the best environmental outcome. Please see attached paper for more information and concrete examples.
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and

20 Nov 2025 · Meeting on PFAS in Waste

Meeting with Andrzej Celinski (Cabinet of Commissioner Piotr Serafin) and Google and

18 Nov 2025 · Presentation on the state of play of the negotiations of the next MFF, with the special focus on communication activities.

Response to Circular Economy Act

6 Nov 2025

Waste-to-Energy (WtE) is an essential public-service infrastructure that safely treats residual, non-recyclable waste, supports high recycling quality by removing contaminants, and recovers materials and energy that would otherwise be lost. Like this, the waste we generate is returned to the economy not only as secondary raw materials, but also as energy. The Circular Economy Act should align legislation, economic instruments, and financing frameworks with this reality, so that residual waste is treated safely and in a sustainable way, closing the loop both in terms of materials and in terms of energy. Key asks: - Recognise WtE as a complementary activity to recycling, critical for hygiene and pollution control in circular material flows. - Prioritise economic instruments that lead to the highest environmental benefit and strengthen Extended Producer Responsibility (EPR) for non-recyclable product designs. - Resolve inconsistencies between the EU taxonomy and circular economy objectives, particularly regarding phosphorus recovery and material recovery from incinerator bottom ash (IBA) Our policy paper, attached, provides more information on these issues.
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Waste-to-energy sector seeks central role in EU energy security

13 Oct 2025
Topic — The EU is revising its energy security rules to integrate decarbonised and electrified systems.
Message — CEWEP requests better cross-sector coordination to integrate waste-heat into local district heating and industrial networks. They also advocate for simplified permitting and financial support for infrastructure like heat pipelines.12
Why — These measures would facilitate the replication of successful waste-to-energy industrial projects across Europe.3
Impact — Natural gas suppliers lose market share as waste-to-energy systems replace industrial gas boilers.4
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Waste-to-energy plants demand central role in EU heating strategy

9 Oct 2025
Topic — This consultation explores strategies to accelerate the decarbonisation of European heating and cooling systems.
Message — CEWEP calls for the recognition of waste energy as waste heat. They demand local planning to integrate these plants into networks. They also seek funding and faster permitting for heat infrastructure.123
Why — These measures would attract infrastructure investment and secure long-term contracts with industrial heat users.45
Impact — Natural gas suppliers would lose revenue as waste heat replaces gas-fired boilers in industrial sectors.67
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CEWEP urges EU investment aid for waste energy recovery

6 Oct 2025
Topic — The European Commission is revising regulations exempting certain state aid from prior notification and approval.
Message — CEWEP proposes a dedicated provision for investment aid to cover waste treatment installations performing energy recovery. Eligibility should require compliance with high energy efficiency performance levels.12
Why — This would allow members to secure state funding to modernize their waste treatment infrastructure.3
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CEWEP urges inclusion of Waste-to-Energy in carbon removal certification

22 Sept 2025
Topic — The EU is establishing certification methodologies for permanent carbon removal activities.
Message — The organization wants Waste-to-Energy recognized as a provider of permanent carbon removals. They argue biogenic CO2 capture can result in net negative emissions and credits.12
Why — This would enable waste plants to generate valuable credits and reach net-negative emissions.3
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Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

Waste-to-energy sector seeks recognition for carbon removal potential

16 Sept 2025
Topic — The amendment of the European Climate Law to set 2040 targets.
Message — The sector calls for EU policies to support carbon capture technologies at waste plants. They argue these facilities should be recognized as providers of permanent carbon removals.12
Why — This would turn their emissions into a revenue stream through carbon removal markets.34
Impact — Landfill operators face business losses as waste is diverted to energy recovery plants.56
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Waste-to-energy sector urges inclusion in EU CO2 infrastructure planning

11 Sept 2025
Topic — The initiative aims to develop competitive markets and transportation infrastructure for carbon dioxide.
Message — The sector seeks guaranteed access to CO2 transport networks and inclusion in European infrastructure planning. They argue for exclusion from the carbon trading system in favor of specific decarbonization incentives.123
Why — This allows plants to bypass expensive carbon taxes while securing technical support for decarbonization.45
Impact — Local economies would bear higher costs if these facilities face carbon taxes without infrastructure.67
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Waste-to-Energy industry urges EU to prioritize landfill methane reduction

11 Sept 2025
Topic — A consultation on the EUs global climate and energy transition strategy.
Message — The strategy should include waste management and energy recovery in climate agendas. It should prioritize global action on methane mitigation and support landfill restrictions.12
Why — This would secure international financing and favorable regulatory status for waste-to-energy plant operators.34
Impact — Landfill operators face business losses as partner countries shift toward alternative waste treatment capacity.5
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Waste-to-Energy Industry Demands Stricter Definition of Recycled Plastic Content

19 Aug 2025
Topic — EU rules for calculating recycled content in single-use plastic beverage bottles.
Message — The organization requests that only waste input be counted as recycled content, excluding non-waste materials. They want the Waste Framework Directive recycling definition explicitly included and additional guidance with concrete calculation examples.123
Why — This would protect their competitive position by preventing virgin plastics from being counted as recycled content.45
Impact — Plastic producers using chemical recycling or advanced processing methods may face stricter eligibility requirements.67
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CEWEP backs inclusion of incineration residues in recovery list

22 Jul 2025
Topic — Defining which waste products have high potential for critical raw material recovery.
Message — CEWEP welcomes the inclusion of sludges and incinerator bottom ashes in the list. This recognition encourages investment in recovery infrastructure and fosters innovation.12
Why — This recognition attracts investment into their infrastructure and validates their market role.3
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Waste Industry Warns ETS Inclusion Could Harm European Taxpayers

8 Jul 2025
Topic — Review of the EU Emissions Trading System and its market stability reserve.
Message — CEWEP calls for a holistic approach including landfills and methane emissions. They propose shifting carbon costs to plastic manufacturers rather than incinerators.12
Why — This would avoid multi-billion euro compliance costs and maintain lower gate fees.3
Impact — Municipalities and citizens will face significantly higher costs for essential sanitary services.4
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CEWEP urges waste heat utilization in industrial decarbonisation efforts

3 Jul 2025
Topic — EU initiative to speed up industrial decarbonisation while maintaining European competitiveness.
Message — The organization recommends that industrial strategies mandate the assessment and use of available waste heat. They call for greater support for heat networks and simplified permitting for new energy connections.123
Why — Mandated heat recovery creates new revenue streams for waste-to-energy operators at low cost.4
Impact — Fossil fuel providers will lose market share as industries transition to heat networks.56
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Waste-to-Energy group urges clearer EU sustainable finance rules

30 May 2025
Topic — This consultation evaluates the revision of EU sustainable finance disclosure rules to simplify the framework.
Message — The group calls for improved alignment between the SFDR and taxonomy framework. They request a clear methodology to ensure waste-to-energy activities are not automatically excluded.12
Why — Clarification of the principle would encourage private investment and remove barriers to sustainable finance.3
Impact — Landfill operators would lose waste volumes as facilities divert material from landfills.4
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and FEAD and BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V.

22 May 2025 · Exchange of views on the feasibility study to include waste incineration and landfilling in the ETS Directive (greenhouse gas emission allowance trading).

Meeting with Christian Ehler (Member of the European Parliament) and Schwarz Corporate Affairs International GmbH and Energy and Climate Policy and Innovation Council e.V.

2 Dec 2024 · Waste to energy

CEWEP urges recognition of waste-to-energy as critical infrastructure

26 Nov 2024
Topic — A review of the EU energy security framework after the energy crisis.
Message — CEWEP advocates for expanding domestic waste-to-energy capacity to strengthen energy security. They propose using non-recyclable waste to supply reliable electricity, heat, and industrial steam.12
Why — The sector would gain political and financial backing for new infrastructure projects.3
Impact — Fossil fuel importers lose market share to local, waste-derived energy production.4
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Waste-to-energy plants demand flexible EU emissions monitoring rules

25 Jul 2024
Topic — The European Commission is updating rules for monitoring and reporting greenhouse gas emissions.
Message — CEWEP requests removing monthly analysis requirements and clarifying emission factors for municipal waste. They urge for greater flexibility on uncertainty tiers due to the complex nature of waste.12
Why — Flexible rules would prevent the overestimation of emissions and reduce complex compliance costs.34
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Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

The DNSH principle as written in the Taxonomy Regulation was established for a very specific and narrow purpose in the sustainable finance framework (signal for investors). It does not take properly into account realities, very diverse locally, of the waste management in all EU MSs. It also does not fully follow EU waste legislation, in particular the waste hierarchy. Waste management is an integrated activity, different steps are required to treat the waste. Waste-to-Energy plants (waste incineration with energy recovery) are part of such an integrated approach, and have an important hygienic task for our society: treating waste that is not suitable for recycling, ensuring that the pollutants and contaminants it contains are safely destroyed and preventing landfilling of waste. WtE is therefore an important component of the circular economy, pollution prevention, climate mitigation and Europes energy security. The criteria for interpretation of the DNSH must take into account the local conditions and different waste treatment schemes in the EU and the particular influence of geography on waste treatment design. This should be reflected in the application of DNSH principle and legislation covering EU funds and budget, a prerequisite to fully recognise the role WtE plays to achieve a clean circular economy and to foster private investments in this sector. It should be clarified that, under the right conditions, WtE and mono-incineration of sewage sludge do not lead to significant harm of any environmental objectives. The only way to achieve common objectives in the European Union for all the Member States from different realities is through the creation of criteria and mechanisms that take into account the diversity of the situation in which each Member State finds itself, especially given that a significant number of countries still have a very high dependence on landfill and are far from the conditions that allow them to fulfil the goals to which they are all committed. Without the means appropriate to their concrete reality not only the objectives of environmental policy are jeopardised, but also the just transition in which no member state should be left behind. More information can be found in the attached paper.
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Meeting with Kadri Simson (Commissioner) and

9 Jan 2024 · Meeting with CCS Europe members on CCS strategy.

Confederation of Waste-to-Energy Plants urges EU to build carbon infrastructure

14 Aug 2023
Topic — The initiative assesses measures to optimize European carbon capture and storage infrastructure.
Message — The sector requests CO2 transport networks, storage capacity, and market opportunities for usage. They also call for a system to track carbon removals and a market mechanism.12
Why — Support would provide legal security for investments and help plants reach net negative emissions.34
Impact — Fossil fuel suppliers could lose market share as captured CO2 replaces fossil-based feedstocks.5
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Waste plants seek flexible EU greenhouse gas reporting rules

14 Aug 2023
Topic — The European Commission is updating rules for monitoring and reporting industrial greenhouse gas emissions.
Message — CEWEP requests clarification on the emission factor for municipal waste to prevent over-estimating fossil emissions. They also demand more flexibility on monitoring tiers due to the complexity of measuring heterogeneous waste streams.12
Why — The sector would avoid inflated carbon costs and the administrative burden of proving reporting difficulties.34
Impact — Environmental monitoring accuracy may suffer if waste operators are granted exemptions from stricter measurement tiers.5
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Waste-to-Energy sector urges clearer definitions for energy recovery

7 Jul 2023
Topic — New EU rules for companies reporting their environmental and social sustainability data.
Message — The association requests that reporting standards explicitly distinguish energy recovery from disposal. They want definitions aligned with existing European waste legislation to avoid confusion.12
Why — This classification ensures their members' plants are recognized as recovery facilities.3
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CEWEP urges EU recognition of Waste-to-Energy carbon removal potential

23 Jun 2023
Topic — EU consultation on establishing a 2040 climate target for 2050 neutrality.
Message — CEWEP requests a clear platform for negative emissions accounting and market mechanisms to support carbon capture. They advocate for diverting waste from landfills to recycling and energy recovery to cut methane emissions.12
Why — EU support would help the industry reach net negative emissions while securing investment.3
Impact — Landfill operators lose market share as waste is diverted to energy recovery.4
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European waste plants demand Taxonomy inclusion for energy recovery

3 May 2023
Topic — The initiative establishes a classification system for environmentally sustainable economic investment activities.
Message — CEWEP requests technical screening criteria for Waste-to-Energy plants to address residual waste. They argue energy recovery should be recognized as superior to landfilling.12
Why — Taxonomy inclusion would allow these plants to attract sustainable investment and financing.3
Impact — Landfill operations may lose business as waste is diverted to energy recovery.4
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European waste-to-energy plants urge carbon removal certification

23 Mar 2023
Topic — This consultation proposes a regulatory framework to certify and monitor sustainable carbon removals.
Message — CEWEP requests a platform for negative emissions accounting and market mechanisms to recognize carbon removals. They highlight that carbon capture technologies could turn waste plants into net negative emission sources.12
Why — This framework would provide legal security for investments and stimulate broader technological development.3
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

27 Sept 2022 · Industrial Emissions Directive

Response to Classification and labelling of chemicals - assignment of notes to certain substances in the CLP Regulation

19 Aug 2022

CEWEP - Confederation of European Waste-to-Energy Plants - is the umbrella association of the owners and operators of Waste-to-Energy (incineration with energy recovery) Plants across Europe. We have the following comments to the consultation: A. Timing of the consultation is very inconvenient: only 4 weeks in the middle of the holiday period is not enough. B. Proper link to note 11, which was just under consultation, is not given. It is burdensome to search other consultations in order to know what is the proposed formulation of the note. C. Generic problem of the chemical legislation is that it does not take into account downstream use in the waste legislation. This provokes problems in waste classification.
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Waste-to-Energy Industry Urges Better Enforcement of EU Waste Laws

28 Jul 2022
Topic — EU assessment of member states' progress toward 2025 recycling and 2035 landfill targets.
Message — The organization calls for stronger implementation and enforcement of existing EU waste legislation, focusing on reducing waste generation and improving separate collection. They emphasize the need for quality recycling standards, better product design for recyclability, and ambitious future legislation tackling additional waste streams beyond municipal waste.123
Why — This positions waste-to-energy facilities as essential infrastructure for meeting EU targets and climate goals.45
Impact — Landfill operators lose business as the industry pushes to reduce landfilling of organic waste.67
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CEWEP demands inclusion of waste incineration in fuel carbon rules

17 Jun 2022
Topic — Methodology for calculating greenhouse gas savings from recycled carbon transport fuels.
Message — Include CO2 from waste incineration in emission reduction calculations. Remove the restrictive 2035 deadline for fossil carbon point sources. Account for carbon savings achieved by diverting non-recyclable waste from landfills.123
Why — Operators would secure long-term investment viability for hydrogen and fuel production.4
Impact — Communities lose access to local low-carbon fuel if waste is landfilled.5
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Waste-to-Energy industry backs EU carbon removal certification framework

2 May 2022
Topic — This consultation concerns a new EU regulatory framework for certifying sustainable carbon removals.
Message — CEWEP seeks a clear platform for negative emissions accounting and market mechanisms. They want waste-to-energy to be recognized as a net negative emissions energy source.12
Why — Certification would provide legal security for investments and stimulate technological development.3
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Waste-to-Energy Industry Opposes Residual Waste Reduction Targets

22 Feb 2022
Topic — Revision of EU Waste Framework Directive on waste management and recycling.
Message — The association requests the Commission not propose quantitative targets for residual waste reduction. They argue focus should be on implementing existing recycling targets and extending recycling and landfill targets to industrial and commercial waste by 2035.12
Why — This would protect waste-to-energy plant capacity and maintain their role treating non-recyclable waste.34
Impact — Environmental groups lose stronger measures to reduce overall waste generation and incineration.5
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Meeting with Pär Holmgren (Member of the European Parliament)

16 Jun 2021 · Methane strategy (staff level)

Response to Revision of EU Ambient Air Quality legislation

13 Jan 2021

CEWEP, the Confederation of European Waste-to-Energy (WtE) Plants, welcomes the initiative of reviewing the EU Air Quality standards and aligning them more closely with the recommendations of the World Health Organization. Because of their dual nature, while offering an environmental and sanitary service, WtE facilities produce energy in the form of electricity and/or heat which allows the replacement of fossil fuels in conventional systems. This becomes extremely advantageous for the improvement of air quality in urban areas where WtE plants are connected to the district heating network, replacing polluting individual boilers. Especially during cold seasons, this translates in great emissions savings with lower emissions and higher energy efficiencies. WtE plants comply with the most stringent regulation for industrial activities in the EU, and this has been further strengthened with the recent waste incineration BREF and BAT conclusions. The sophisticated flue gas cleaning systems and techniques applied in WtE plants guarantee that pollutants are safely abated, ensuring low emission levels with no harmful effects on health and the environment. There is a wide existing literature on the pollutant levels in the output streams of waste incineration plants that shows this aspect. More information can be found at: https://www.cewep.eu/review-health-studies/ Furthermore, the study "Emissions of Fine and Ultrafine Particles from stationary combustion plants" (available in the Health and Environment section on the CEWEP website) investigated the emissions from WtE plants and the flue gas cleaning technologies commonly adopted. Among the key findings of this study, it emerged that for all WtE plants analysed, the concentrations measured were consistently lower by at least two orders of magnitude compared with those found for wood and oil combustion in domestic boilers. WtE, incineration with energy recovery, plants serve society, protect the environment and the climate by reducing the volume of waste, treating polluted substances in an environmentally sound way and recovering climate-friendly energy and materials in the process. WtE plays a crucial role in circular economy diverting waste from landfills and treating residues from recycling processes in line with the EU waste hierarchy. As part of the European Green Deal, CEWEP strongly believes that WtE has a major role not only in a circular economy and climate protection perspective, but also towards the contribution of higher Air Quality standards inside the EU. CEWEP, Confederation of European Waste-to-Energy Plants, is the umbrella association of the operators of Waste-to-Energy (incineration with energy recovery) plants, representing about 410 plants from 23 countries. They make up 80% of the Waste-to-Energy capacity in Europe. Its members are committed to ensuring high environmental standards, achieving low emissions and maintaining state of the art energy production from remaining waste that cannot be recycled in a sustainable way.
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Meeting with Florika Fink-Hooijer (Director-General Environment)

12 Jan 2021 · waste to energy

CEWEP urges inclusion of Waste-to-Energy in EU sustainable finance taxonomy

17 Dec 2020
Topic — The Delegated Regulation defines environmentally sustainable economic activities for investment purposes focusing on climate change.
Message — The organization calls for Waste-to-Energy to be included on the sustainable finance agenda to fully tap into its greenhouse gas savings potential. They also propose aligning cement and plastic manufacturing criteria with existing waste incineration and treatment standards.123
Why — This would secure their sector's eligibility for green investment and ensure a level playing field with other industries.45
Impact — Cement and chemical recycling facilities would face stricter environmental standards and more complex greenhouse gas calculation methods.67
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

CEWEP, the Confederation of European Waste-to-Energy (WtE) Plants, welcomes the initiative of reviewing the Guidelines on State aid for environmental protection and energy 2014 - 2020, EEAG (2014/C 200/01), based on a higher climate ambition for 2030. By diverting waste from landfills and producing low carbon energy, WtE (incineration with energy recovery) plants greatly reduce the overall GHG impact of the waste sector. Throughout the years, this has also helped the member states that have decided to invest in WtE technologies to reach their national emissions reduction targets. WtE plants serve society, protect the environment and the climate by reducing the volume of waste, treating polluted substances in an environmentally sound way and recovering climate-friendly energy and materials in the process. It is fundamental that EEAG continues to cover energy and environment topics in a circular economy perspective. These policy measures shall enable synergy effects between those areas and lead to decarbonisation and strengthening of the environmental protection. WtE plays a crucial role in circular economy diverting waste from landfills and treating residues from recycling processes and should remain eligible for aid in line with the EU waste hierarchy. We support the revision of EEAG, in particular the possibility to broaden the aid scheme to allow the participation of other sectors, technologies or projects that can all contribute to a targeted objective, namely towards decarbonisation. It is fundamental to open the possibility of support to an entire sector or all undertakings facing the same environmental challenge (such as the waste management sector as a whole) to ensure a level playing field and minimise competition distortions. Throughout the years, WtE has demonstrated to be an effective solution towards GHG reduction through decarbonisation of the electricity and heating systems, improving energy efficiency, use of local and renewable sources and reduction of waste disposal in landfills. Considering the new EU Green Deal targets, the EEAG should continue to support WtE improvements in heat utilisation and energy efficiency through district heating and industrial steam projects, especially in member states that still heavily rely on landfills and where an integrated waste management system has yet to be developed. Moreover, with bigger penetration of intermittent renewables in electricity production there is a need for balancing and storage options. WtE can also fulfill this purpose together with creating new synergies with upcoming technologies such as CCUS and Hydrogen production for low carbon transport.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

2 Dec 2020 · Circular economy and waste-to-energy

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

CEWEP, the Confederation of European Waste-to-Energy Plants, welcomes the initiative of updating the EU Effort Sharing Regulation (ESR) and the review of the national emissions reduction targets based on a higher climate ambition for 2030. We fully support the principle that all sectors will need to contribute to reach climate neutrality by 2050 and Waste-to-Energy (WtE) is ready to continue playing an active role towards more ambitious climate goals. By diverting waste from landfills and producing low carbon energy, WtE plants greatly reduce the overall GHG impact of the waste sector and this has also helped through the years the member states that have decided to invest in WtE technologies to reach their national emissions reduction targets. As an example, the European Environmental Agency in the annual EU greenhouse gas inventory report 2019 reported that: “Italy, contributing with 13.1 % to EU-28+ISL emissions in 2017, featured an increasing trend of CH4 emissions from landfills until 2001 and a decreasing trend thereafter. This is driven, inter alia, by the increasing amount of waste landfilled until 2000 and a decrease thereafter. Also, CH4 recovery has increased throughout the time series. The key drivers for the fall in emissions are the national policy diverting solid waste from landfill to waste incineration plants and waste diversion measures.” For what regards the policy options in the ESR Inception Impact Assessment, we support Option 3. Only sectors not included in the ETS should be covered by the ESR. Option 2, double coverage of some sectors, would lead in some cases to double taxation, which should be avoided. While carbon pricing is a useful tool to reduce carbon emissions in sectors that compete in the free market, for other sectors (e.g. waste) member states will need a certain flexibility in order to be able to plan an integrated waste management system that works properly, that is environmentally sound, safe for human health and, among other things, has a significantly lower impact on carbon emissions. For this reason, we do not believe that Option 1 is the best option for ESR. Municipal waste incineration with energy recovery plays a fundamental role in the waste management system of several member states: in this sense, in a climate perspective, looking at WtE separately from the entire waste sector (e.g. by including it into the ETS) would be counter-productive, as the market will encourage diversion of some waste streams to cheaper, less environmentally sound routes (marine litter, landfills, export to third countries with lower environmental and social standards, reintroduction of polluted materials into the circle, etc.) which will end up generating more GHG emissions. Furthermore, it would make recycling more expensive as WtE plants treat the residues from sorting and recycling plants.
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European waste plants warn ETS inclusion will boost landfilling

26 Nov 2020
Topic — This consultation reviews the EU Emissions Trading System to meet higher climate targets.
Message — The organization argues the carbon market is unsuitable for the waste sector's public health mission. They request that the EU account for wider climate benefits, such as energy recovery and landfill diversion, rather than just direct emissions.12
Why — Excluding the sector from regulations avoids significant measurement costs and prevents overlapping national taxes.345
Impact — Citizens and local communities face higher costs for waste treatment and energy.6
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Waste-to-energy plants urge energy recovery for non-recyclable vehicle parts

19 Nov 2020
Topic — Revision of EU rules for managing and recycling end-of-life vehicles.
Message — The organization advocates for maintaining energy recovery for waste streams that cannot be reused or recycled. They also call for solid methodologies in recycled content calculations and updated legal definitions.12
Why — This ensures waste-to-energy plants continue receiving materials that are unsuitable for recycling.3
Impact — Alternative fuel producers may lose access to waste streams if recycling definitions exclude fuel production.4
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Waste-to-Energy (WtE, waste incineration with energy recovery of municipal and similar commercial and industrial waste) is one of the most strictly-regulated industrial sectors. Multiple studies have found no evidence of a negative impact of WtE on health or the environment. Only a very small fraction of air emissions in Europe comes from it. Data collected by the E-PRTR shows that dioxin emissions from WtE (considered as a marker for incineration of waste in the past) account for less than 0.2% of the total industrial dioxin emissions, not considering road transport. Waste-to-Energy incineration contributes only 1,8% of NOx and less than 1% of mercury emissions to the overall European industrial emissions. The newly adopted Waste Incineration (WI) BAT Conclusions will improve further the environmental benefits of the sector as they are the legally binding basis to update environmental permits. WI BAT Conclusions set more demanding standards than the already very strict existing legal requirements of the IED‘s Annex VI (covering waste incineration), regarding emission limits but also adding a number of controlled substances and monitoring requirements. We would like to provide the following recommendations for the foreseen review: • A focus on environmental policies that are coherent and based on scientific evidence. • A realistic ambition and guarantee a level playing field for all European sectors. • An environmental integrated approach (recognising cross-media effects) for all climate and environmental aspects focusing on: o Reinforcing existing legislation and implementation. o Ensuring that targeted additional actions do not tackle those who already contributed to lower emission levels. • Permits in the Industrial Emissions Directive (IED) should be updated and granted based on a technology driven analysis and a transparent and robust methodology to derive emission limits. The IED itself is fit for its purpose. • BREF review processes are based on dedicated data collection and questionnaires from well performing plants, that have to be defined following the principle of environmental protection as a whole. This step, although time consuming, is necessary to avoid shortcuts that might only favour a plant or a technique that minimise impact on one pollutant but has cross media effects that should not be overlooked. The alternatives such as using EPRTR data to identify well performing plants do not abide by the same principle. • Reduce pollution and other environmental and climate impacts within the waste management sector means for example preventing landfilling of recyclable and recoverable waste.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

[Full statement in PDF attached] CEWEP believes that IED provisions are a fundamental step forward for the reduction and elimination of pollutants arising from industrial activities. The pillars of the IED, in particular the integrated approach, the use of best available techniques and the public emission reporting are key for achieving results in terms of environmental performance of the plants. Waste-to-Energy (WtE, waste incineration with energy recovery of municipal and similar commercial and industrial waste) is one of the most strictly-regulated industrial sectors. Multiple studies have found no evidence of a negative impact of WtE on health or the environment. Only a very small fraction of air emissions in Europe comes from it. Data collected by the E-PRTR shows that dioxin emissions from WtE (considered as a marker for incineration of waste in the past) account for less than 0.2% of the total industrial dioxin emissions, not considering road transport. We would like to provide the following recommendations for the foreseen review: • On the one hand, the BREF process aims to identify BAT and BAT associated emission performance levels that apply to units/processes (e.g. a furnace or a boiler) expressed very often in concentration, sometimes using specific units. On the other hand, the E-PRTR Regulation is about absolute amount of substances emitted by a facility during a year (e.g. a plant or a sub-installation most of time, i.e. covering more than one unit/process). As a consequence, E-PRTR data, even normalised, cannot be used to identify the well performing plants for the Sevilla process. In order to secure that the Integrated Approach is followed, the correct analysis of all environmental impacts has to be performed when deciding the list of well performing plants. Only with balanced trade-off decisions we can protect the environment as a whole. • Discussions under the E-PRTR Expert Group recently resulted in the definition of units and metrics for reporting certain contextual fields. For what concerns the Waste-to-Energy sector, it was suggested to include also MWh of energy generated. This suggested change should be reconsidered as it only applies to activity 5(b) - Installations for the incineration of non-hazardous waste - and not other waste treatment activities that also generate energy, which would mean undermine the level playing field under sector 5. In addition, it would open the door for a bias comparison between WtE and power plants (in a disadvantageous position since for activity 1.c the proposed unit is MWh of thermal input): WtE are not power plants and are designed to safely treat non-recyclable waste while maximizing the production of sustainable energy. Waste-to-Energy (WtE) safely destroys pollutants in the residual waste (it is a sink for pollutants) and fulfills a hygienic task to the society while recovering energy and materials from the bottom ash. WtE is the most sustainable and hygienic option to treat waste that is not suitable for recycling, thanks to its sophisticated flue gas cleaning system and the energy recovery process.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

CEWEP welcomes the European Commission’s Inception impact assessment on the evaluation and review of the Energy Efficiency Directive (2012/27/EU) - EED and in particular the measures to promote security of supply, resource-efficiency, circular economy, competitiveness and reducing pollution. In line with the European Green Deal objectives, we fully support the option to raise the ambition level of the energy efficiency measures, focusing on increasing the deployment of District Heating and Cooling (DHC) and valorisation of heat from industrial applications. Waste-to-Energy – WtE (incineration with energy recovery) generates reliable and environmentally friendly energy, while at the same time providing vital waste services. Together with electricity, WtE in CHP (Combined Heat&Power) helps providing renewable energy to households and industries, through DHC networks and process steam. Because of its dual function, WtE is the link between renewable energy and circular economy. Residual waste (not suitable for recycling) should be regarded as a sustainable source of energy. If not used for energy recovery, the residual waste would otherwise be landfilled, where it would emit methane gas, with a huge impact on the climate. Even considering the latest and more ambitious goals of waste reduction, reuse and recycling, residual waste will be a persistent issue that communities all around Europe will have to face. About 57 million tonnes of municipal waste are still landfilled in Europe (Eurostat 2019, data of 2018), and almost 175 million tonnes considering all the waste streams (except mineral waste). The CO2eq emissions from landfills would also be prevented by WtE diversion together with the greenhouse gas emissions savings due to conventional fossil fuels replacement, such as coal, natural gas, etc. CEWEP calculates that WtE plants could produce 190 TWh of energy by 2035, enough to supply more than 50 million people with heat and electricity and to replace 10% of the energy supplied by the coal sector today. In many European cities, WtE contributes significantly to DHC networks (about 90 TWh per year). There is a major opportunity for further improvement by linking more heat or process steam customers to WtE plants. The Heat Road Map Europe 2050 suggests that the potential is 200 TWh per year by 2050 for heat alone. Further policy changes are needed to improve infrastructure for DHC and process steam for industry as well as to promote the efficient integration of WtE plants into local heat and power grids. WtE can also secure baseload capacity and reliable grid stability, especially in smarter and more integrated energy networks. The WtE sector has been also continuously able to evolve not just towards higher performances and more stringent emission standards, but also in terms of industrial coupling. Examples of efficient integration with other technologies, such as heat pumps, have already taken place in the sector, allowing enhanced energy recovery from waste. One of the most important pillars of the EU’s energy policy is the energy efficiency first principle. CEWEP strongly believes that WtE already fulfils that principle and helps reducing dependence on fossil fuels and lower greenhouse gas emissions. Energy recovery from residual waste should be regarded as an important and reliable source of energy capable of diversifying the EU’s energy mix, boosting energy efficiency and reducing dependency on fossil fuels imports. CEWEP, Confederation of European Waste-to-Energy Plants, is the umbrella association of the operators of Waste-to-Energy (incineration with energy recovery) plants, representing about 410 plants from 23 countries. They make up 80% of the Waste-to-Energy capacity in Europe. Its members are committed to ensuring high environmental standards, achieving low emissions and maintaining state of the art energy production from remaining waste that cannot be recycled in a sustainable way.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

CEWEP welcomes the European Commission’s Inception impact assessment on the revision of the Renewable Energy Directive (2018/2001) – REDII and in particular the measures to promote District Heating and Cooling (DHC), energy efficiency and the use of heat from industrial sources. In line with the European Green Deal objectives, we fully support the option to raise the ambition level of the REDII, in particular focusing on increasing the deployment of renewables in the power, heating and cooling as well as transport sectors. Because of its dual function, Waste-to-Energy - WtE (incineration with energy recovery) is the link between renewable energy and circular economy. Residual waste (not suitable for recycling) should be regarded as a sustainable source of energy. If not used for energy recovery, the residual waste would otherwise be landfilled, where it would emit methane gas, with a huge impact on the climate. Even considering the latest and more ambitious goals of waste reduction, reuse and recycling, residual waste will be a persistent issue that communities all around Europe will have to face. Furthermore, with respect to virgin biomass, the use of residual waste for energy production and in particular the biodegradable fraction of waste does not contribute to sustainability concerns like deforestation or land use change. Among renewable energies WtE can also secure baseload capacity and reliable grid stability, especially in smarter and more integrated energy networks, while at the same time providing vital waste services. Together with electricity, WtE in CHP (Combined Heat&Power) helps providing renewable heat to households and industries, through DHC networks and process steam. CEWEP calculates that WtE plants could produce 190 TWh of energy by 2035, enough to supply more than 50 million people with heat and electricity and to replace 10% of the energy supplied by the coal sector today. In many European cities, WtE contributes significantly to DHC networks (about 90 TWh per year). There is a major opportunity for further improvement by linking more heat or process steam customers to WtE plants. The Heat Road Map Europe 2050 suggests that the potential is 200 TWh per year by 2050 for heat alone. Further policy changes are needed to improve infrastructure for DHC and process steam for industry as well as to promote the efficient integration of WtE plants into local heat and power grids. WtE could play an important role as well in hydrogen development. Energy from WtE plants can produce green hydrogen through electrolysis providing grid stability, buffering capacity and storage of energy – this is essential when more and more intermittent renewable sources are present in the energy mix. Afterwards it can be used in different kind of applications: from industry to mobility. CEWEP strongly believes that WtE helps reducing dependence on fossil fuels and lower greenhouse gas emissions. Energy recovery from residual waste should be regarded as an important and reliable source of energy capable of diversifying the EU’s energy mix by boosting the share of renewable energies and reducing dependency on fossil fuels imports. CEWEP, Confederation of European Waste-to-Energy Plants, is the umbrella association of the operators of Waste-to-Energy (incineration with energy recovery) plants, representing about 410 plants from 23 countries. They make up 80% of the Waste-to-Energy capacity in Europe. Its members are committed to ensuring high environmental standards, achieving low emissions and maintaining state of the art energy production from remaining waste that cannot be recycled in a sustainable way.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Vanessa Mock (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 Sept 2020 · sustainable finance

Waste-to-Energy plants urge focus on recycling quality

5 Aug 2020
Topic — The European Commission is reviewing packaging requirements to reduce waste and improve circularity.
Message — CEWEP emphasizes that the elimination of toxic substances should take priority over simply increasing recycling volumes. They argue that Waste-to-Energy plants act as essential gatekeepers by treating contaminated materials that would otherwise pollute the recycling stream.12
Why — This perspective secures a permanent role for incineration in the circular economy infrastructure.3
Impact — Low-quality recycling operations might lose out if strict toxic substance standards are enforced.4
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Response to EU Methane Strategy

5 Aug 2020

Please find attached CEWEP feedback on the EU methane strategy.
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Response to Strategy for smart sector integration

8 Jun 2020

Please find attached CEWEP response to a future EU strategy on energy sector integration.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

7 May 2020 · To discuss matters related to incineration and EU policy, notably: Taxonomy; Incineration as part of the ETS and chemical recycling.

CEWEP urges EU Taxonomy recognition for Waste-to-Energy plants

24 Apr 2020
Topic — The consultation establishes criteria for environmentally sustainable economic activities within the EU climate taxonomy.
Message — The organization urges the European Commission to define criteria for Waste-to-Energy as a sustainable activity. They argue it reduces emissions by diverting waste from landfills and recovering energy.12
Why — Including Waste-to-Energy in the taxonomy would secure essential investment and financing for new infrastructure.3
Impact — Landfill operators and waste exporters lose business as waste is diverted to incineration plants.4
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CEWEP urges technical focus in industrial emissions revision

21 Apr 2020
Topic — Updating EU industrial emissions legislation to support zero pollution and sustainability goals.
Message — The organization requests that the Commission protect the Integrated Approach and use sound technical information. They argue that specific waste incineration matters should be tackled in appropriate technical forums.12
Why — Maintaining technical complexity helps the sector avoid oversimplified regulations that ignore industrial realities.3
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Response to Revision of the Energy Tax Directive

1 Apr 2020

CEWEP (Confederation of European Waste-to-Energy Plants) welcomes the European Commission’s (EC) work to revise the Energy Taxation Directive (ETD). We fully agree with the reason for the review - alignment with the European Union’s (EU’s) policy objectives inter alia: decarbonisation, energy efficiency and protection of human health and environment. As the review of ETD should focus on environmental issues, we would like to suggest considering the following issues: • Apply minimum tax rates or exemptions for use of excess heat from industrial installations. Align ETD with goals expressed in 2016 Heating and Cooling Strategy and 2018 Clean Energy Package for all aiming inter alia at enhancing delivery of excess heat to industrial sites and/or District Heating Networks. • Apply exemptions for Combined Heat and Power (CHP) production in order to maximise energy efficiency gains. • Promote renewable energy sources and align with 2018 Renewable Energy Directive. • Encourage sectoral integration. • Apply minimum tax rates or exemptions for processes directed towards abatement of pollutants (e.g.: for auxiliary burners and flue gas cleaning). • Carry out impact assessment and apply life cycle thinking to the evaluation of possible options for the review of the ETD. CEWEP is the umbrella association of the owners and operators of European Waste-to-Energy (incineration with energy recovery) Plants. Our members are committed to ensuring high environmental standards, achieving low emissions and maintaining state of the art energy production from remaining waste that cannot be recycled in a sustainable way.
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Response to Climate Law

6 Feb 2020

In light of the European Commission’s Climate Law Roadmap CEWEP would like to highlight how waste management can contribute to EU climate neutrality by 2050. Landfill diversion is a low hanging fruit for climate mitigation. In 2017, about 58 million tonnes of municipal waste were still landfilled in Europe, rising to around 175 million tonnes if all waste streams are considered. This leads to more than 140 million tonnes of CO2eq emissions. Decomposing waste in landfills generates methane – a greenhouse gas 28 times more potent than CO2. As one of the most comprehensive studies on the topic has stated, “Diversion from landfill is the main contributor to GHG mitigation in the waste management sector” . Landfilling waste which could be recycled or recovered for energy, means burying valuable resources. The environmental risks associated with landfilling include contamination of soil and groundwater, or microplastics being blown by the wind into the seas or rivers from uncontrolled landfills. Landfills also take up valuable land space and their aftercare period can last hundreds of years. Diverting the currently unrecyclable waste streams to Waste-to-Energy (WtE) from landfills would prevent around 875 kg of CO2eq emissions per tonne of waste. Considering that a significant part of the waste currently landfilled could be recycled in the future, total savings of more than 150 million tonnes of CO2eq emissions (more than half of the annual CO2 emissions from fossil fuels in Spain) could be achieved every year in the EU by shifting waste that can be recycled or recovered from landfilling to a treatment higher up the Waste Hierarchy. Quality recycling and WtE contribute hand-in-hand to the EU climate goals CEWEP supports recycling that produces new materials in an environmentally, technically and economically sound manner in order to replace virgin materials. The combustible part of the residual waste that cannot be recycled in this sustainable way should be treated in WtE plants which therefore serve as an important enabler of the circular economy. At the end of the combustion process, metals such as iron, aluminum, copper and zinc can be recycled from the bottom ash, this way saving more than 3 million tonnes of CO2eq that otherwise would have been emitted in the production process. WtE replaces fossil fuels WtE plants could produce 190 TWh of energy by 2035, enough to supply more than 50 million people with heat and electricity and to replace 10% of the energy supplied by the coal sector today. In some urban areas with efficient district heating in place, energy from waste covers more than half of the residents’ heat demand – a significant contribution to energy security. Half of the energy produced from waste is renewable as it comes from biological origin. At the same time WtE complements other - intermittent - renewable energy sources and delivers reliable baseload energy. The remaining half of energy from waste, although fossil, is recovered as a waste treatment service to the society. The WtE sector is looking into possibilities of CO2 capture and use or storage where appropriate and sustainable, assuming that the necessary (financial and infrastructural) framework will be put in place. Conclusion: Sustainable waste management contributes to GHG mitigation. Diverting waste from landfills to recycling and energy recovery is the main contributor to GHG mitigation in the waste sector. EU landfill diversion policies must be implemented as soon as possible. Additionally, the landfill diversion targets must be extended to all commercial and industrial waste that can be recycled or recovered (municipal waste is just less than 10% of the whole waste volume).
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Waste-to-energy sector calls for treating non-recyclable residual waste

20 Jan 2020
Topic — The European Commission's roadmap for a more sustainable and circular European economy.
Message — CEWEP requests that non-recyclable residual waste be treated in waste-to-energy plants. They also advocate for extending landfill diversion targets to include industrial waste streams.12
Why — Mandatory treatment of residual waste ensures long-term demand for incineration infrastructure.34
Impact — Landfill operators face reduced volumes as waste moves up the regulatory hierarchy.56
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and FEAD

29 Oct 2019 · waste management policy, circle economy, EU taxonomy

Waste-to-energy sector warns against premature industrial emissions evaluation

4 Dec 2018
Topic — The European Commission is evaluating the effectiveness of the Industrial Emissions Directive.
Message — CEWEP believes a proper evaluation needs a sufficient amount of data. They argue 2020 is too early to see impacts on installation performances.12
Why — The sector avoids the risk of policies being based on a distorted picture.3
Impact — Public health and environment lose the benefit of faster pollution reduction efforts.4
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

5 May 2017 · Waste-to-Energy Communication

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

5 May 2017 · waste to energy

Response to Commission Regulation amending Annex III to Directive 2008/98/EC

17 Aug 2016

CEWEP would like to stress that the proposed Commission Regulation amending Annex III to Directive 2008/98/EC on HP 14 (based on the outcome of “Study to assess the impacts of different classification approaches for hazard property "HP 14") does not provide a suitable approach to assess the ecotoxicity of waste. In general, CEWEP would like to highlight that CLP is not applicable one-to-one to waste. For e.g. bottom ash, a more accurate assessment should follow a tiered approach composed of a screening of the relevance of hazardous properties, followed by further investigation of each relevant hazardous property using a worst case assessment approach, and finally leading to a detailed assessment of any hazardous property not disregarded previously. This last step would include leaching data and chemical speciation as well as assumptions on exposure conditions, allowing for a final conclusion on the hazardous properties in a real-life situation. None of the proposed methods in the study follows this approach. All four methods are based on analytical results from total composition measurements and do not take into account the actual risk of the absorption of substances by the environment. They also ignore the type of waste, the information available regarding the waste and the recovery application. Within EU waste legislation there is already a comprehensive legal framework and a complementary risk assessment based on the impact of waste on the environment, which limit the areas for recovery or disposal applications. Under CLP, substances and mixtures of known composition are carefully regulated on the basis of their intrinsic hazardous properties. However, the input – and therefore, the output – of Waste-to-Energy plants is highly heterogeneous. Methodologies applied in the CLP based on chemical analysis and disregarding the specific characteristics of waste could lead to a great inaccuracy of the results. This was acknowledged in the draft study presented on 20th April 2015: “Limited information and uncertainties regarding the composition of waste is the main limit of approaches based on chemical analysis. Methodologies provided in the DPD and the CLP are meant for mixtures with known composition; so their applicability for the assessment of waste, which includes the assessment of mixtures with unknown composition, is not straightforward and has not been evaluated. In particular, the heterogeneity of waste samples [...] can make determination of composition difficult.[...] Additionally, the application of worst-case scenarios when the composition of waste is not sufficiently known leads to an overestimation of the waste hazard. Thus, assessments using chemical analyses may not reflect the actual ecotoxicity of waste”. While methods 1, 3, and 4 would overestimate the hazardousness of the waste, method 2 uses M-factors that are defined only for some substances. When not defined, M-factors are provided by manufacturers and not by the European Commission, which leads to inconsistencies among the values and lack of reliability for both industries and authorities. Moreover, a waste sample cannot be lead back to the producer of the original product, making it therefore complicated to determine M-factors. Due to the short time given to stakeholders to reply to this consultation it is not possible to provide more details on the impacts of the draft proposal. Moreover, the unpredictability of the impact is increased by the fact that the study was not supported by a proper impact assessment. Implementing unsuitable methodologies will risk hampering the recovery of e.g. bottom ash without environmental reasons and sending more waste to landfill even though in many Member State there is not enough capacity left. Therefore CEWEP calls on the European Commission and the TAC to refrain from final approval of this proposal until a proper harmonized method fit for the purpose of characterising complex solid waste streams is reached.
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Meeting with Daniel Calleja Crespo (Director-General Environment)

3 Feb 2016 · Waste to Energy's role in a sustainable Circular Economy

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

24 Apr 2015 · Cewep position on circular economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

25 Mar 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

25 Mar 2015 · Circular economy

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

25 Mar 2015 · Circular Economy