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EEW Energy from Waste GmbH

EEW

Planung, Bau und Betrieb von emissionsarmen und ressourcenschonenden Abfall- und Klärschlammverbrennungsanlagen mit effizienter Erzeugung von Wärme, Prozessdampf und Strom.

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

3 Dec 2025

EEW Energy from Waste GmbH backs the EU Taxonomy as a key tool for the green transition. The current Call for Evidence is a chance to refine technical screening criteria (TSC) for better alignment with EU goals. Effective waste management, including energy recovery, provided by Waste-to-Energy (WtE) offers significant environmental benefits, which are increasingly recognized by authorities. EEW urges clearer recognition of WtEs climate and resource contributions in the TSC and asks for the following adjustments: CCM/CCA 4.8 Electricity generation from bioenergy o The activity currently covers only electricity produced exclusively from biomass, biogas, or bioliquids. o WtE plants generate electricity with at least 50% biogenic input from waste and sewage sludge. o While the EU taxonomy accepts unavoidable waste heat for district heating, it does not offer equal recognition for electricity produced from the same process, despite its climate benefits. o In Germany, the biogenic share of electricity from thermal waste treatment is officially classified as renewable and eligible for green certificates under the EEG. o Recommendation: Remove the "biomass-only" requirement and recognize the biogenic fraction of WtE electricity as taxonomy-eligible. CEY 2.1 Phosphorus recovery from waste water o Facilities and processes enabling phosphorus recovery should include incineration, not just the final recovery step. o Incineration is essential for high phosphorus recovery rates, as mandated by the German AbfKlärV regulation for large plants. o Mono-incineration concentrates phosphorus in ash, simplifying further processing compared to untreated sludge. o The process also ensures hygienization, destroys contaminants, and recovers energy from biogenic sources. o Recommendation: Include all steps that enable phosphorus recovery, especially incineration with energy recovery; remove the limitation excluding prior steps. CEY 2.7 Sorting and material recovery from non-hazardous waste o WtE plants treat non-recyclable, non-hazardous waste for safe disposal and hygienization, while also enabling energy and material recovery of high-quality secondary raw materials. o Materials such as metals, minerals, and phosphorus (from sewage sludge) are recovered from slag ash after processing and hygenization. o Current TSC requirements, especially the at least 50% by weight and mechanical process rules, hinder taxonomy-aligned material recovery by conflicting with the environmental goal of reducing waste volume through incineration. o Recommendation: Remove the at least 50% by weight and strict mechanical process requirements. CCM 9.2 Research, development and innovation for direct air capture of CO2 o Waste-to-energy is recognized as a hard-to-abate sector and belongs to the critical infrastructure making Carbon Capture at the point source the key technology to achieve climate-neutrality. o The capture of biogenic and fossil CO emissions from waste opens up the opportunity to develop WtE plants into genuine CO sinks in the future. o While the transport and permanent storage of CO2 (CCM 5.11/5.12) are considered under the EU-Taxonomy, the enabling technology is limited to the least effective Direct-Air-Capture (DAC). o Recommendation: Create a TSC for the R&D costs as well as for the industrial capture of biogenic and fossil CO2 from industries with hard-to-abate emissions that is not limited to less effective Direct-Air-Capture.
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