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European Suppliers of Waste-to-Energy Technology

ESWET

ESWET is a European association representing suppliers of waste-to-energy technologies.

Lobbying Activity

Response to Advanced Materials Act

13 Jan 2026

ESWET - the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to Energy (WtE) plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills. ESWET welcomes the opportunity to contribute to the European Commissions consultation on Advanced Materials, which plays a key role in strengthening the EUs industrial competitiveness, strategic autonomy and sustainability objectives. Ensuring secure access to materials, improving circularity and reducing reliance on primary resources are central to the success of advanced material value chains. In this context, the recovery of metals and mineral fractions from incineration residues represents an important contribution to Europes material base. Metals recovered from bottom ash provide secondary sources of critical and strategic raw materials, which can be reintroduced into industrial processes and used as feedstock for the production of high-performance and advanced materials. At the same time, processed mineral fractions can substitute primary raw materials in construction and other applications, reducing environmental impacts and supporting resource efficiency. WtE contributes to the circular economy by managing residual waste that cannot be prevented, reused or recycled. By safely treating these unavoidable fractions, WtE enables the recovery of materials and energy that would otherwise be lost, while preventing environmental and health risks associated with improper waste management. Through the recovery and supply of secondary raw materials and mineral resources, WtE technologies can support the development and scaling-up of advanced materials, complementing recycling and contributing to resilient, circular and low-carbon industrial value chains in Europe. This contribution outlines ESWETs perspective on the consultation and highlights how material recovery from WtE can support the objectives of the EUs advanced materials agenda, while remaining fully aligned with the waste hierarchy and Europes broader circular economy goals. Please find ESWET's contribution attached.
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Response to Circular Economy Act

6 Nov 2025

PLEASE FIND OUR FULL CONTRIBUTION ATTACHED. ESWET represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants in operation in Europe. Its mission is to promote technologies that safely treat non-recyclable waste while recovering valuable energy and materials, contributing to Europes climate goals, resource efficiency, and energy resilience. As the EU moves forward with the Circular Economy Act (CEA), ESWET welcomes this initiative as a timely opportunity to strengthen Europes resource security, industrial competitiveness, and environmental sustainability. Reducing the EUs dependence on imported raw materials and fossil energy requires recognising the contribution of recovery solutions that help keep resources and energy circulating within the European economy. Waste-to-Energy is a cornerstone of Europes circular economy, providing an essential public service for the safe, hygienic, and climate-responsible treatment of residual, non-recyclable waste. By converting this waste into renewable energy and secondary raw materials (SRMs), WtE ensures that no resource is lost while protecting citizens and the environment from pollution. Across Europe, WtE plants generate electricity and heat equivalent to the needs of more than 35 million citizens while recovering metals and minerals from bottom and fly ash that contribute directly to Europes resource security. By diverting waste from landfills, WtE prevents the release of methane over 80 times more potent than CO making it one of the most effective near-term measures to cut greenhouse gas emissions in the waste sector. Operating under the strictest environmental standards of the Industrial Emissions Directive, WtE also prevents the spread of pollutants such as PFAS and other persistent substances, providing a controlled and traceable end-of-life solution. Preserving the recovery status of WtE within EU law is therefore essential. Downgrading it or conflating it with disposal operations would undermine decades of investment, weaken circular progress, and risk a return to landfilling. Maintaining WtEs position above disposal in the waste hierarchy guarantees legal clarity, policy coherence, and environmental integrity, ensuring that Europe continues to manage its residual waste responsibly and within its borders. Looking ahead, Carbon Capture, Utilisation and Storage (CCUS) technologies will enable WtE to move from carbon-neutral to carbon-negative operations. By capturing the biogenic share of its CO emissions and supplying captured carbon as a feedstock for fuels, chemicals, and construction materials, WtE can help close the carbon loop turning unavoidable emissions into valuable resources. Recognition of WtE under the EU Taxonomy for sustainable activities is equally critical to ensure consistency between EU financial, waste, and climate frameworks. Despite its legal recognition in the Waste Framework, Landfill, and Renewable Energy Directives, WtE remains excluded from the Taxonomy a gap that restricts access to green investment for a sector that demonstrably supports circularity, energy recovery, and pollution prevention. Including WtE as a Taxonomy-eligible activity would strengthen the EUs ability to achieve landfill diversion, climate mitigation, and resource recovery objectives, while enabling investments in plant modernisation and decarbonisation through CCUS. Recognising both WtE operations and CCUS applications under the Taxonomy would provide the policy coherence needed to deliver a climate-neutral, circular European economy. As Europe advances the Circular Economy Act, it must recognise the full contribution of WtE to circularity, climate neutrality, and industrial resilience. WtE complements recycling, supports landfill diversion, and provides a bridge between waste management, clean energy, and carbon circularity ensuring that the EUs transition to a sustainable economy leaves no resource behind.
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Response to Heating and cooling strategy

9 Oct 2025

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. It seeks to promote the technologies that recover both energy and materials from non-recyclable waste that would otherwise end up in landfills. Waste-to-Energy (WtE) offers a critical, immediate, and cost-effective solution to decarbonise Europes heating and cooling sector. By recovering both renewable and waste heat from the thermal treatment of non-recyclable waste, WtE directly contributes to EU climate and energy targets. The forthcoming EU Heating and Cooling Strategy must recognise the indispensable role of WtE in providing reliable, partially renewable heat, supporting the circular economy, and displacing fossil fuels in district heating and cooling (DHC) networks. ESWET welcomes the Commission's initiative and urges stronger integration of WtE within the Strategy. Please find and consider our full position paper attached.
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ESWET: Waste-to-energy essential for EU grid stability and decarbonisation

9 Oct 2025
Topic — EU initiative to increase electricity's share in energy consumption to achieve decarbonisation targets.
Message — ESWET advocates for Waste-to-Energy to be recognized as a dispatchable power source that balances the grid. They request policy support to further integrate these plants into the European energy system.12
Why — Official policy support would secure the sector's market position and promote technology uptake.3
Impact — Fossil fuel importers and landfill operators face reduced demand as waste-to-energy replaces their services.45
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Response to European Climate Law amendment

17 Sept 2025

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills. ESWET strongly supports the European Commissions proposal to set an ambitious 2040 target in line with a 90% net reduction in greenhouse gas emissions on the path to climate neutrality by 2050. Achieving this goal requires both deep emissions cuts and scalable, high integrity carbon removals. Waste to Energy (WtE) is uniquely placed to deliver on both fronts: it already mitigates emissions today by diverting residual waste from landfills, displacing fossil energy, and recovering materials; with Carbon Capture and Storage (CCS), the sector can provide durable, measurable carbon dioxide removals (BECCS) while fulfilling its essential hygienic mission in the waste hierarchy. Executive summary This paper outlines ESWET's position on how WtE technologies, primarily as standalone solutions, but also when integrated with CCUS, are indispensable levers for achieving the EUs climate goals while simultaneously advancing circular economy objectives and ensuring cost-effectiveness. This paper also argues that a truly effective climate policy for the waste sector must be holistic, recognising the sector's unique operational realities and its interconnectedness with energy systems and material cycles. It highlights several key policy issues that must be rigorously addressed to unlock the sector's full climate potential: The critical role of WtE in climate mitigation: WtE, by diverting non-recyclable waste from landfills, directly prevents significant methane emissions a potent short-lived climate pollutant. Furthermore, it recovers energy that displaces fossil fuels and enables material recovery, contributing to a net climate benefit. The transformative potential of CCS in WtE: When combined with CCS, WtE facilities can go beyond emission reduction to achieve carbon-negative outcomes by capturing and permanently storing biogenic CO2, thus actively removing carbon from the atmosphere. The imperative of cost-effectiveness: Decarbonisation must be achieved efficiently. WtE offers a cost-effective pathway for emissions reduction when assessed on a life-cycle basis, delivering high climate impact per euro spent while providing essential public services. A coherent, sector-wide policy framework: Climate measures for waste must be designed holistically to avoid any unintended consequences, such as undermining the waste hierarchy, higher costs for citizens, and diversion to less sustainable options. Effective design means applying the Polluter Pays Principle at the source (targeting producers of fossil-based products), preventing double or triple charging, ensuring a level playing field across all waste management options, and using a comprehensive LCA approach that recognises system-wide climate benefits. GHG Protocol reform for waste: Update accounting rules in order for waste-sector inventories to transparently recognise avoided emissions (landfill methane avoided, displaced electricity and heat, and materials recovery) following an LCA approach. Dual Global Warming Potential - GWP metrics (GWP20 and GWP100): Require reporting and appraisal under both time horizons across EU impact assessments, funding eligibility, disclosure, and cost-effectiveness evaluations. This captures the high near-term value of methane abatement while preserving longterm ambition, helping prioritise measures that deliver the most climate impact per euro in the 20302040 window. Please find our full analysis in the attached file.
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Waste-to-Energy suppliers urge voluntary EU carbon capture framework

11 Sept 2025
Topic — The initiative aims to develop competitive markets and transportation infrastructure for CO2.
Message — The organization calls for a comprehensive CO2 market that enables voluntary carbon capture deployment. They demand transparent third-party access and multiple transport modes, including rail and truck, for diverse plants.12
Why — Voluntary implementation prevents burdensome costs for facilities while allowing them to sell carbon credits.34
Impact — Monopolistic infrastructure providers lose market dominance through mandatory third-party access and diverse transport requirements.5
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ESWET Urges EU to Include Fly Ash in CRM List

25 Jul 2025
Topic — A regulation identifying waste streams with potential for recovering critical raw materials.
Message — ESWET calls for the inclusion of fly ash in the list of materials with recovery potential. They also urge the Commission to recognize mineral recovery from incineration residues as official recycling. Additionally, they request that these recovery activities be included in the EU Taxonomy.123
Why — Official recognition would improve the economic viability of recovery projects and attract sustainable finance.4
Impact — Landfill operators face business losses as waste is diverted toward incineration recovery plants.5
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

Statement accompanying ESWET's responses to the EC Questionnaire on the inclusion of Waste-to-Energy in the EU ETS This statement accompanies ESWET's responses to the European Commissions questionnaire on the potential inclusion of Waste-to-Energy (WtE) in the EU Emissions Trading System (ETS). It reflects our consolidated position as the European association representing suppliers of WtE technologies and builds on years of engagement with EU institutions, national authorities, and stakeholders across the waste and energy sectors. General Comment on the Survey Design and Scope ESWET welcomes the opportunity to contribute to this consultation. However, we find the survey format and framing to be insufficiently comprehensive and, at times, ambiguous in ways that risk undermining the consultations policy value. By presenting WtE inclusion largely in isolation without consistently integrating questions on upstream responsibility, landfill regulation, or carbon removals the survey overlooks the systemic nature of waste management and climate mitigation. This narrow framing could inadvertently support policy choices that are environmentally counterproductive, economically regressive, and socially disruptive. Policy Coherence and Environmental Effectiveness The EU ETS must not distort the waste hierarchy or penalise services essential to public health and circularity. Municipal Waste Incineration (MWI) treats non-recyclable residual waste and offsets more polluting or carbon-intensive options such as landfilling. Including WtE alone in the ETS without simultaneously pricing landfill emissions risks incentivising a shift to lower-cost but more harmful practices, undermining EU climate objectives and circular economy goals. The Polluter Pays Principle (PPP) and Upstream Responsibility WtE operators do not control the fossil content of waste streams; they are service providers managing societys residual output. The fossil CO in their emissions derives from upstream product and packaging design, not incineration processes. Without upstream policy measures such as extended producer responsibility, design-for-recycling standards, and material-based levies the imposition of direct carbon costs at the treatment stage misapplies the Polluter Pays Principle and risks further entrenching the problem. Strategic Coherence and Level Playing Field Including WtE in the ETS without also covering other carbon-emitting waste treatment routes would create regulatory asymmetry. It would also risk market distortions, emissions leakage, and a breakdown in coherence across EU waste and climate law. All GHG-releasing waste pathways including landfilling, chemical recycling, gasification, and other thermal or conversion technologies must be considered within a unified and balanced framework.
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ESWET urges waste-to-energy inclusion in EU decarbonisation act

8 Jul 2025
Topic — This initiative aims to accelerate industrial investments and support the decarbonisation of energy-intensive sectors.
Message — The association requests that waste-to-energy be recognized as anchor infrastructure for industrial clusters. They call for designating carbon capture technologies in this sector as strategic decarbonisation tools. Additionally, they seek inclusion in the EU Taxonomy and more funding incentives.123
Why — These proposals would secure green finance for technical upgrades and create profitable markets for carbon removals.45
Impact — Landfill operators face business loss as waste is diverted to more sustainable recovery facilities.678
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Waste-to-Energy Suppliers Urge Inclusion in Bioeconomy Strategy

23 Jun 2025
Topic — EU initiative to update its strategy for a circular and climate-neutral bioeconomy.
Message — The association requests that the EU recognize non-recyclable biogenic waste as a sustainable energy source. They urge a phase-out of landfilling to redirect waste toward energy recovery and fuel production. They also call for a technology-neutral approach that values all biogenic waste management pathways.12
Why — Formal recognition would increase investment in waste-to-energy plants and secure their market position.3
Impact — Landfill operators would face the closure of facilities as the EU phases out organic waste burial.4
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ESWET seeks waste-to-energy inclusion in low-carbon fuel rules

25 Oct 2024
Topic — The consultation defines a methodology to calculate greenhouse gas savings for low-carbon fuels.
Message — ESWET requests that the methodology recognizes carbon capture and utilization from waste-to-energy facilities. They propose removing restrictive sunset clauses on captured fossil carbon to support long-term infrastructure investment.12
Why — This allows waste-to-energy plants to secure long-term returns on expensive carbon capture investments.3
Impact — Climate goals for carbon sequestration are undermined if plastic waste is incinerated instead of landfilled.4
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Waste technology suppliers urge flexibility in emissions reporting

26 Jul 2024
Topic — The European Commission is updating rules for monitoring and reporting greenhouse gas emissions.
Message — ESWET calls for a flexible approach to emissions monitoring and opposes mandatory monthly sampling. They argue that changing rules so quickly creates significant administrative hurdles for operators.12
Why — Maintaining flexibility would prevent high costs and delays caused by insufficient laboratory capacity.34
Impact — Environmental oversight could be weakened by less frequent or less rigorous carbon monitoring standards.5
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Waste-to-energy firms urge broader carbon capture product recognition

16 Jul 2024
Topic — Establishing rules for greenhouse gases to be considered permanently chemically bound in products.
Message — ESWET calls for including incineration bottom ash in the regulation and broadening product definitions. They also advocate for upstream accounting to attribute emissions responsibility to producers at market entry.123
Why — This would strengthen the business case and financial incentives for carbon capture projects.45
Impact — Product manufacturers would face higher costs and responsibility for emissions at market entry.6
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European waste technology suppliers urge flexible carbon monitoring rules

23 Aug 2023
Topic — This consultation updates rules for monitoring and reporting greenhouse gas emissions in the EU.
Message — The organization calls for monitoring rules that reflect the complexity of treating mixed waste feedstocks. They request flexibility to choose between calculation and measurement methods while allowing higher uncertainty thresholds.12
Why — This would reduce compliance costs and prevent plants from being overcharged for carbon emissions.34
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Waste-to-energy suppliers urge EU to back carbon capture technology

22 Aug 2023
Topic — A consultation on deploying EU-wide carbon capture, utilisation, and storage infrastructure for 2050 neutrality.
Message — ESWET requests that carbon utilization technologies be included in the Net Zero Industry Act. They want the EU to provide financial support for integrating carbon capture into waste-to-energy plants.12
Why — The association would secure long-term investment viability and access to strategic net-zero funding.3
Impact — The environment and local communities suffer if non-recyclable waste is diverted back to landfills.4
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Waste-to-Energy Suppliers Demand Inclusion in EU Net Zero Act

26 Jun 2023
Topic — European Commission proposal to scale up manufacturing of clean energy technologies.
Message — ESWET requests including heat recovery, material recovery, and Carbon Capture and Utilisation in the strategic technologies list. They also advocate for including technologies related to transporting captured carbon.12
Why — Manufacturers would benefit from a simplified regulatory framework and priority status for their projects.3
Impact — European climate strategy is weakened by the exclusion of technologies that strengthen energy independence.4
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Waste-to-Energy suppliers urge EU to include incineration in Taxonomy

3 May 2023
Topic — EU initiative establishing a classification system for sustainable investments in the circular economy.
Message — The group calls for the EU to include waste incineration with energy recovery when it replaces landfills. They also want to ensure that recovering materials from wastewater and combustion products remains part of the sustainable finance rules.12
Why — Including these technologies would make their members' incineration projects eligible for green investment.3
Impact — Landfill operators would lose their competitive advantage and face faster phase-outs.45
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Waste-to-energy suppliers urge clear carbon removal certification rules

23 Mar 2023
Topic — The European Commission is developing a regulatory framework for certifying carbon removals.
Message — ESWET requests clear rules for measuring biogenic and fossil carbon in waste-to-energy plants. They advocate for a feasible certification mechanism that avoids being overly burdensome for operators. They also want recognition for the full range of carbon capture and utilization technologies.123
Why — This would provide clarity for investors and help the sector reach net-zero targets.45
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

Please find attached ESWETs full response to the consultation. ESWET the European Suppliers of Waste to Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. It seeks to promote the technology which, within the frame of the Waste Hierarchy, recovers energy from waste that would otherwise end up in landfills. ESWET supports the European Commissions initiative to evaluate the application of the Polluter Pays Principle (PPP) to the environment. PPP is a key principle of EU environmental law that is crucial for improving environmental protection. For this reason, it needs to be properly and adequately integrated in EU policies, which then need to be implemented effectively to increase prevention, control, and remedy of pollution. Among other fields, the PPP needs to be reinforced with respect to waste, as this is a source of pollution to air, water and soil. The 2021 special report of the European Court of Auditors on the application of the PPP found that waste legislation reflects the PPP but does not ensure polluters cover the full cost of pollution. ESWET calls on the European legislators to empower the Polluter Pays Principle to make those responsible for waste generation pay for its environmental and climate impacts. Based on the scope of a specific legal instrument (e.g., Emissions Trading System Directive for CO2 emissions, Air Quality Directive and Industrial Emissions Directive for pollution of air, etc.) the EU legislation should apply the PPP considering that waste management is part of the treatment of the problem and not the cause of pollution by itself. In that sense, the EU legislation should consider that Waste-to-Energy plants are actually given the mission to prevent pollution from non-recyclable waste and to recover its energy. They are not themselves the producers of the waste. Unfortunately, waste is not eternally recyclable, nor all waste is recyclable. Residual waste streams, requiring safe treatment, will persist and potentially grow globally. Even with the best technologies in place, recycling will not always be possible or economically viable for certain waste. The only viable solution for treating this residual waste is in state-of-the-art Waste-to-Energy plants, which close the loop of the circular economy. WtE offers a holistic approach to resource recovery from non-recyclable, non-hazardous waste; it diverts those wastes from landfills, recovers metals and minerals, and produces renewable energy (from the biodegradable fraction of waste), thus becoming an indispensable link of the circular economy and creating value for society. More specifically, Waste-to-Energy contributes to the circular economy by: Providing a hygienic service to the community by treating non-recyclable waste and pollutants, which would otherwise end up in landfills. Providing secondary raw materials from incineration residues, a process known as material recovery. Recovering energy from waste and providing a local and reliable source of renewable electricity, heat, hydrogen and fuels, substituting fossil fuels and strengthening the EUs energy security. Recovering the emitted carbon from its processes through carbon capture technologies and producing further products and fuels. The EU policies reflecting the Polluter Pays Principle should consider the positive impact of Waste-to-Energy in pollution prevention and in its vital role in the waste management hierarchy.
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Response to European Critical Raw Materials Act

25 Nov 2022

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills. ESWET welcomes the Commissions call for evidence on the European Critical Raw Materials Act, as announced during the State of the Union address. Raw materials and critical raw materials will be essential to ensure the success of the twin digital and energy transition, especially in the deployment of renewable energy and the decarbonisation of hard-to-abate sectors such as transport. To this aim, more emphasis needs to be put on the use of critical and non-critical secondary raw materials and recycled materials. Following the waste hierarchy (Article 4, Directive 2008/98), priority needs to be given to waste reduction; preparing for re-use and recycling. However, not every waste is recyclable. Waste can be contaminated or polluted, and most materials cannot be recycled indefinitely and have to be recovered, or as a last resort, disposed of in landfills. POLICY RECOMMENDATIONS: 1. Consider both critical raw materials and non-critical raw materials as both will be the keys to accelerate the energy transition 2. Recognise the role of Waste-to-Energy in the circular economy as the sector contributes to the supply of secondary raw materials (both metals and minerals) 3. Address the untapped potential of EU supply by facilitating the use of materials from waste streams 4. Provide regulatory and financial incentives to increase the EUs material circularity Please find the full contribution in attachment.
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

ESWET: Waste-to-Energy is vital for EU recycling targets

1 Aug 2022
Topic — Commission assessment of Member States' progress toward 2025 and 2035 waste targets.
Message — ESWET argues Waste-to-Energy is a crucial partner for recycling non-recyclable materials. They want its role in meeting landfill targets to be officially recognized.12
Why — This ensures a permanent role and market demand for thermal treatment technologies.3
Impact — Landfill operators lose business as waste is diverted to energy recovery facilities.4
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ESWET Urges Inclusion of Waste-to-Energy in New Biofuel Rules

20 Jul 2022
Topic — The Commission is developing a methodology to measure renewable content in co-processed transport fuels.
Message — ESWET requests that the rules explicitly include waste-to-energy and waste-to-fuel activities. They also want the Commission to consider the high costs and delays of radiocarbon testing.12
Why — This expansion would provide the waste-to-energy sector with needed clarity for producing renewable fuels.3
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Waste-to-energy suppliers urge EU to include waste in fuel rules

17 Jun 2022
Topic — A consultation on calculating greenhouse gas emission savings for recycled carbon fuels.
Message — ESWET requests that waste incineration be explicitly included as an emission reduction source. They also seek the removal of the 2035 limit on fossil carbon capture.123
Why — This would provide investment security for plants converting non-recyclable waste into hydrogen.4
Impact — The EU's decarbonization efforts lose access to immediate and local low-carbon fuels.5
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Waste-to-energy tech suppliers urge EU carbon removal certification

29 Apr 2022
Topic — The Commission is proposing a regulatory framework for certifying sustainable carbon removals.
Message — ESWET calls for monitoring standards suitable to Waste-to-Energy and a recognized 50/50 biogenic emission split. They also request financial support and end-of-waste status for captured carbon.1234
Why — A solid certification framework would establish the business case needed for carbon capture investments.5
Impact — Environmental groups lose if carbon accounting relies on fixed estimates rather than precise monitoring.67
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Waste-to-energy technology providers seek recognition in gas rules

12 Apr 2022
Topic — This consultation addresses updating EU gas rules to facilitate renewable and low-carbon gas markets.
Message — ESWET calls for legislation to include avoided emissions from landfill diversion in carbon calculations. They urge a carefully designed methodology for calculating emissions savings from non-recyclable waste. They also support creating a certification system for low-carbon fuels similar to renewable fuels.123
Why — Recognizing waste-derived energy as low-carbon allows the industry to play a larger role in decarbonisation.4
Impact — Fossil fuel providers lose market share as waste-derived energy replaces imported natural gas.5
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Feb 2022

ESWET - the association representing European Suppliers of Waste-to-Energy Technologies - welcomes the Commission roadmap on the Environmental impact of waste management and is fully in support of waste reduction. However, while waste prevention is the most desirable goal in the long-term, waste generation is still on the rise in Europe and needs to be dealt with, including non-recyclable waste. See full contribution in attachment.
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Response to Measures to reduce microplastic pollution

18 Jan 2022

ESWET welcomes the EC’s call for evidence on microplastics pollution and measures to reduce its impact on the environment. Microplastics pose a serious threat to the whole ecosystem, including to human health, requiring immediate action from all responsible actors. ESWET’s views: • It is important to distinguish the sources of microplastics’ releases, as this can help understand how to properly deal with microplastic leakages. • As part of an integrated waste management chain, treatment of non-recyclable waste in advanced Waste-to-Energy (WtE) facilities, operated under stringent EU standards, complements recycling to tackle the leakage of microplastics in the environment and at the same time constitutes the most viable and proven way to treat both primary and secondary microplastics. • As also part of the Circular Economy, WtE ensures that residual waste is still used as a resource instead of being lost in landfills, as previously stressed in the EC Communication on the role of WtE in the circular economy. • ESWET thus invites the EC to reaffirm the mission of WtE in the prevention of plastic-related pollution as a complementary instrument to waste prevention, reuse and recycling. Plastics that have already been placed on the market should stay on the market as long as possible, in line with the circular economy, through strengthened recycling and recovery operations. For plastics that find their way out of waste treatment, a stronger focus should be given, making sure that a comprehensive and integrated plan for collection, sorting, recycling, and Waste-to-Energy for non-recyclable waste is in place, avoiding plastic waste leakages to the maximum. The vital role that the waste management sector can play in reducing plastic waste leakages is outlined by the Waste hierarchy. However, the waste hierarchy does not stop in recycling since not every waste is eternally recyclable; residual plastic waste includes non-recyclable plastic waste following collection and sorting or rejected plastic waste from recycling facilities. The most viable and proven solution for this residual plastic waste as per the waste hierarchy and the circular economy is the recovery of its energy content in advanced Waste-to-Energy facilities with high energy efficiency and low emissions. WtE plants are a key actor in waste pollution prevention since, as a complementary option to recycling, they divert non-recyclable waste from landfills and prevent related short-, medium-, and long-term risks of pollution of groundwater, soil, and air from plastics, microplastics, and nanoplastics. A 2015 study by McKinsey & Company and Ocean Conservancy showed that the most effective tools for the reduction of plastic leakage are WtE technologies to treat waste in areas with high waste density. Overall, the findings of this study make it clear that there is no “one size fits all” approach to preventing plastic-waste leakage. For non-recyclable waste, the treatment options ensuring plastics elimination and scoring the most across all five metrics are WtE and gasification. The manufacturers of WtE technology represented by ESWET provide state-of-the-art technological applications for effectively and efficiently treating thermally pollutants from waste that cannot be recycled. This includes residual plastic waste and microplastics which would otherwise end up in landfills or be dumped illegally in waterways, in the old linear fashion. Particularly for primary microplastics, the overwhelming majority is directly or indirectly discharged in sewage water and wastewater systems: 96% of the total sources of primary microplastics could be captured by extended wastewater treatment facilities, and then – if not recyclable – they could be destroyed by sewage sludge incineration. Therefore, we see once again that WtE provides a sustainable and ultimate treatment of plastics and microplastics that cannot be recycled, minimising any leakages to the marine environment.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

ESWET – the European Suppliers of Waste to Energy Technology – represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. ESWET welcomes the European Commission’s proposal for the revision of the Energy Taxation Directive (ETD), as it accurately sets preferential tax rates for the use of renewable and low-carbon fuels and hydrogen for end-consumers, and shifts tax incentives away from fossil fuels and towards clean technologies. Waste-to-Energy is an essential part of the European waste management and contributes to the decarbonisation of the sector: it diverts non-recyclable waste from landfills, recovers energy and secondary raw materials, provides reliable renewable energy, and prevents GHG emissions. Waste-to-Energy activities are involved in biomass applications for energy uses. Biomass, in particular the biodegradable fraction of municipal and industrial waste, is a renewable energy source. It is estimated that the renewable energy output from Waste-to-Energy plants is more than 50%, contributing substantially to decarbonising the energy systems in Europe, and replacing fossil fuels in energy-intensive industries, including in the heating and transport sectors. Waste-to-Energy – A solution for reliable low-carbon fuel Waste-to-Energy covers a wide range of different technologies, including the production of biogas from biogenic waste, with proven advantages to the European energy mix. Energy from waste presents a significant versatility as it produces not only heat and power but also useful products; Waste-to-Energy can produce low-carbon fuels and hydrogen, whereby the combustion of municipal solid waste can provide some or all of the energy required for the generation of hydrogen through electrolysis or certain types of gasification. This low-carbon hydrogen represents a significant alternative to fossil fuels in powering fuel cell buses in cities, or refuse trucks collecting municipal waste. Renewable and low-carbon hydrogen are considered key to the climate objectives, especially in energy-intensive industries and transport. The benefits of waste-derived fuels include the contribution to climate change mitigation, and to the reduction of land competition between energy and food crops. Besides, the JRC 2016 report on WtE states that the conversion of municipal solid waste to biofuels can provide significant GHG savings, e.g., for ethanol from municipal solid waste, GHG savings are estimated at -225g CO2e/MJ. Pursuant to the above, advanced sustainable biofuels and biogas, as well as renewable hydrogen produced from the biogenic fraction of waste, should be subject to the lowest minimum rate of €0.15/GJ, as per the ETD. This should also be the case for low-carbon hydrogen and fuels, including recycled carbon fuels, for a transitional period of at least 10 years. This would facilitate the uptake of any renewable and low-carbon fuel and hydrogen available in the market, thus realising faster the transition to carbon neutrality. See also our attached position on the proposed revision of the RED, which is of relevance to the above.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Please find attached ESWET’s full response to the consultation. ESWET represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. We welcome the European Commission’s proposal for the revision of the Renewable Energy Directive (RED), as it accurately addresses the urgency of up-taking every renewable energy source available, including the electricity, steam, heating, and cooling generated from non-recyclable waste. Indeed, around 50% of the energy output of Waste-to-Energy plants is renewable as it comes from the biodegradable fraction of waste. Key points for ESWET: • Emerging Waste-to-Energy applications can help reach the increased targets of the RED, which require the uptake of more renewable energy and fuels. o Waste-to-Energy is a key actor in the treatment of non-recyclable waste and at the same time, it constitutes a reliable source of continuous energy, partially renewable, as a complement to intermittent renewable energy sources. It relies on waste directly available in Europe which contributes to the European Green Deal objective of securing affordable renewable energy within the European Union. o The recovered energy is turned into electricity, heat, or low-carbon fuels, to the benefit of communities and industries. o It is estimated that Waste-to-Energy plants in Europe account for 2.4% of the EU’s total energy supply. In 2018 in Europe, Waste-to-Energy plants exported around 40 billion kWh of electricity and 90 billion kWh of heat, which provided 18 million citizens with electricity and 15.2 million citizens with heat. For instance, Waste-to-Energy plants provide more than 30% of the overall heat production in the district heating networks supplying Copenhagen and 16 neighbouring municipalities. • The revised RED should continue to recognise the partly renewable feature of the energy from Waste-to-Energy plants and to count it towards the EU renewable energy targets based on the percentage of biogenic waste (calculation method provided by MS legislation). This energy from waste, which can be recovered as heat or electricity, should not be subject to RED sustainability criteria. • The definition of biomass should continue to include “the biodegradable fraction of waste”, which should continue to be considered a source of renewable energy. o Biomass has the potential of replacing fossil energy carriers and feedstocks in energy-intensive industries. Waste-to-Energy activities are involved in biomass applications for energy uses. It is estimated that the renewable energy output from Waste-to-Energy plants is more than 50%, contributing substantially to decarbonising the energy systems in Europe, in particular by substituting fossil fuels in the heating and transport sector. o The advantage of using biomass in energy applications in energy-intensive industries is that when it is combined with Carbon Capture and Storage (CCS), the industry can provide a net removal of CO2 from the atmosphere, resulting in negative emissions. • The exception for biofuels, bioliquids, and biomass fuels produced from waste and residues, as granted by Article 29 paragraph 1 subparagraph 2 should remain. However, amending the sustainability criteria for biofuels in Art 29 (10) could prove counter-productive as the current ones are still under implementation by the Member States. • Recycled carbon fuels for fuels produced from the fossil part of waste should continue to count towards meeting the transport targets. • Any relevant sustainability criteria for fuels from waste should take into account avoided greenhouse gas (GHG) emissions from landfill diversion and captured GHG emissions from CCUS implementation.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

ESWET welcomes the Commission's roadmap and would like to stress that affordable CCUS implementation could provide the opportunity for the Waste-to-Energy sector to become carbon-negative. Waste-to-Energy (WtE) is a waste management option that is complementary to recycling to the extent that it safely treats non-recyclable waste that would be landfilled otherwise. Besides this mission in pollution prevention, WtE plants also turn the waste into electricity and heat for the community and industries, thus using non-recyclable waste as a resource and playing a role in the circular economy [1]. However, the combustion process in WtE is also responsible for direct GHG emissions. These direct emissions are at least partially offset via energy recovery (to the extent that it prevents the use of fossil fuels), material recovery (metals and aggregates are recovered in WtE plants, thus preventing the energy-consumptive extraction of virgin materials) and landfill diversion. Indeed, in addition to long-term risks to the environment, landfills are also responsible for methane emissions, a GHG 84 times more potent than CO2 over a 20-year period. But with carbon capture implementation, WtE has the potential of becoming carbon-negative depending on the nature of its waste input. Waste treated in WtE plants contains non-biogenic (fossil) materials and biogenic (plant-based) materials. The CO2 produced from the incineration of this biogenic component does not lead to increasing atmospheric CO2 levels. Since more than 50% of WtE’s CO2 emissions are of biogenic origin, Waste-to-Energy is one of the few sectors with the potential of becoming carbon negative via the production of bioenergy with carbon capture and storage (BECCS). This would be in line with the Intergovernmental Panel on Climate Change (IPCC) SR15 report (2018, p. 34) that acknowledges the necessity to use Carbon Dioxide Removal (CDR), including BECCS, in order to limit warming to 1.5°C [2]. Furthermore, support to CCUS implementation in Waste-to-Energy is also in line with the European Commission’s views on the matter, as indicated in a written answer[3] to a parliamentary question[4] on the potential of WtE power generation and carbon capture and storage to generate net carbon removals. A recent report Eunomia stressed how UK CCS plans could be underpinned by Waste-to-Energy [5]. But already the WtE sector has shown successful applications of the technology. Like the Klemetsrud plant in Oslo where carbon removal will participate in the city’s goal of 95% emissions reduction (in essence, climate-neutrality) by 2030 [6]. A similar project in Amager Bakke plant in Copenhagen could remove 500,000 tonnes of CO2 per year. For carbon capture technologies implementation to be successful, it should be made economically viable on all processes that have unpreventable CO2 emissions. This includes the Waste-to-Energy sector that cannot just stop treating the waste it receives as part of its mission in pollution prevention. These technologies will need further investments to provide effective cost abatement at a wider scale. This will be further explored in the next years and has to come along with the development of transportation infrastructure as well as a legislative framework that fosters business opportunities and clarifies standards for carbon capture and storage. Sources: [1] Communication on the role of Waste-to-Energy in the circular economy, COM/2017/034 final: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A52017DC0034 [2] https://www.globalccsinstitute.com/wp-content/uploads/2019/10/Waste-to-Energy-Perspective_October-2019-5.pdf [3] https://www.europarl.europa.eu/doceo/document/E-9-2020-005683-ASW_EN.html [4] https://www.europarl.europa.eu/doceo/document/E-9-2020-005683_EN.html [5] https://www.eunomia.co.uk/uk-carbon-capture-plans-could-be-underpinned-by-waste-sector-2/ [6] https://eswet.eu/integration-of-ccs-in-waste-to-energy-plants-a-step-closer/
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Waste-to-energy suppliers urge technology-neutral inclusion in EU taxonomy

18 Dec 2020
Topic — New EU rules classifying which economic activities qualify as environmentally sustainable investments.
Message — ESWET requests that waste-to-energy be recognized as a sustainable activity in the taxonomy. They seek a level playing field by applying uniform environmental standards to all technologies.12
Why — This would allow the sector to attract green funding and maintain market parity.3
Impact — Landfill operators lose business as non-recyclable waste is diverted toward energy recovery plants.4
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please, find attached ESWET’s full feedback to the EC Roadmap on updating the EU ETS.
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Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

ESWET – the European Suppliers of Waste-to-Energy Technology – welcomes the publication of an Inception Impact Assessment for the Update of concentration limit values of persistent organic pollutants in waste, as it is one of Waste-to-Energy’s roles to close the toxic loophole of polluted waste. It is indeed Waste-to-Energy’s primary mission to safely treat residual waste, unfit for recycling, by taking the pollutants out of the eco-cycle while using the waste as a source of energy turned into electricity and heat. Waste-to-Energy plants also recover ferrous and non-ferrous metal from incineration bottom ashes and thus prevents the polluting extraction of primary raw materials. In turn, incineration ashes can be re-used, for instance for roads and construction purposes. In other words, non-recyclable waste is used as a resource instead of being dumped and quite literally wasted. Waste streams with high POPs concentration (e.g. mono charges) are not sent to Waste-to-Energy plants for municipal solid waste but are specifically treated in hazardous waste incinerators. However, municipal solid waste deemed unfit for recycling and sent to Waste-to-Energy plants is by nature heterogeneous. Unlike other treatment options that only deal with limited types of high-quality residual waste, Waste-to-Energy technology is able to take care of residual municipal solid waste in general. It also means that Waste-to-Energy plants have to be ready to deal with all kind of pollutants. The combustion technologies are usually considered to be the most economically appropriate to treat POP-containing waste and modern incinerators are designed to match the stringent emissions levels established under EU legislation. In trials highlighted in the 2015 PlasticsEurope report End-of-life treatment of HBCD-containing polystyrene insulation foams, neither in the flue gas nor in the residues any limits were exceeded, and it was underlined that “state-of-the-art Municipal Solid Waste Incinerator operation guarantees […] high-efficiency destruction of HBCD” (technical summary report, page 14). More broadly, controlled incineration with high temperatures (e.g., at 1,000°C) is also mentioned in the 2019 Ramboll study to support the review of waste related issue in annexes IV and V of Regulation (EC) 850/2004 as an effective way to destroy other POPs. As a safeguard, highly sophisticated processes in Waste-to-Energy plants ensure that, if not destroyed, pollutants contained in the waste and transferred to the flue gas through combustion are filtered (e.g.: adsorption by mean of activated carbon, coke or other additives, etc.) and deposited.
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ESWET urges EU to include Waste-to-Energy in green taxonomy

27 Apr 2020
Topic — Establishing a classification system for sustainable activities to guide green investment decisions.
Message — The group invites the Commission to define criteria recognizing waste-to-energy's contribution. They seek to ensure the safe treatment of residual non-recyclable waste.12
Why — Sustainable classification would help the industry secure financing needed for massive capacity growth.34
Impact — Landfill operators face declining business as more waste is redirected to energy plants.56
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Response to EU rules on industrial emissions - revision

21 Apr 2020

ESWET acknowledges the Commission’s plan to revise the Industrial Emissions Directive, in particular its ambition to contribute to circularity and the decarbonisation of industry. In that respect, ESWET expresses its support to the Commission’s efforts towards a green transition and seizes the opportunity to share its perspective. 1) Waste-to-Energy and circularity: It is widely understood why waste prevention, re-use and recycling are part of the circular economy. But everything is not recyclable and, as a complementary tool to recycling, it is Waste-to-Energy’s mission to safely treat the residual share of waste that cannot be recycled. As acknowledged by the Commission [1], Waste-to-Energy has thus a role to play in the circular economy. The technology ensures that residual waste is used as a resource instead of being dumped in landfills where it would be, quite literally, wasted. In Waste-to-Energy plants, non-recyclable waste is hygienised and used to generate energy then turned into electricity and heat, metal is recovered during the process, combustion ashes can be reused for instance in construction, and pollutants are safely removed by the flue gas cleaning systems. However, at this stage the potential contribution of the Directive to circularity in the waste incineration sector is not yet clear. Other tools like the Waste Framework Directive are already specifically dedicated to circularity and waste management, including waste incineration. The impact of new provisions should thus be carefully assessed beyond the sole IED, so that overlaps and over-regulation that could affect the coherence of the overall EU legislation are avoided. It should also be noted that any attempt to boost circularity should first start with the development of a viable economic environment which, for many sectors, is closely related to necessary progress in establishing a functioning secondary raw material market through appropriate instruments. 2) Waste-to-Energy and decarbonisation: The potential of waste management in greenhouse gas reduction should not be underestimated: waste was in 2017 the fourth largest source sector of emissions (3%) behind fuels (77%), agriculture (10%) and industrial processes (8%). A significant amount of these emissions is related to landfills. When waste is landfilled, the organic material in the waste decomposes and produces methane, a greenhouse gas that is up to 86 times more potent than carbon dioxide over a 20-year period. That is why the diversion of waste from landfills to other waste management options is at the core of decarbonisation in this sector: between 1995 and 2017, while the total amount of municipal waste treated increased by 13%, the amount of landfilled waste fell by 60% and greenhouse gas emissions from waste dropped by 42% according to EEA estimates [2]. Due to their complementarity, recycling and Waste-to-Energy have been key drivers of landfill diversion and related decarbonisation. Besides their role in waste hygienisation, Waste-to-Energy plants act in fact as carbon sinks as they: - provide a substitute to fossil fuel, as waste is used to generate energy which is then converted into electricity and heat; - prevent further raw material extraction by recycling metals; - divert non-recyclable waste from landfills, preventing methane emissions there. Should the Commission decide to draft new provisions on decarbonisation, it would thus be important to take into account - beyond sole direct emissions - the overall impact of Waste-to-Energy in the decarbonisation of the waste management sector and in particular its active role in landfill diversion. Otherwise, such provisions could be counterproductive and hamper decarbonisation through landfill diversion, especially if methane emissions from landfills are not applied similar provisions. [1] COM(2017)34, section 5 [2] https://ec.europa.eu/eurostat/web/products-eurostat-news/-/DDN-20200123-1
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Response to A new Circular Economy Action Plan

20 Jan 2020

See the attached ESWET position paper on the Roadmap for a new Circular Economy Action Plan.
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

ESWET would like to welcome the Commission’s initiative to launch an evaluation of the Industrial Emissions Directive (IED) as a sign of its dedication to ensure that the IED remains an efficient piece of legislation. However, ESWET expresses reservations regarding the timeliness of such initiative. In particular, the Waste Incineration BREF is still in the drafting stage and implementation is therefore foreseen by end of 2023 or beginning of 2024. The sector has no concrete experience of BREF implementation under the IED and, while it may be able to comment on specific issues such as the BREF elaboration process, it won’t be able to comment on the permitting stage where implementation issues will only arise as of 2020. Moreover, the Commission itself has reached the conclusion, less than a year ago, in its first report on the implementation of the IED, dated December 2017, that the IED “is a good example of better regulation”, that it is “too early to see the practical results of the changes to the IED” and that 2020 “would appear an appropriate time to consider the launch of a full evaluation of the IED”. While ESWET believes that the above-mentioned conclusions are, by and large, still accurate, a number of proposals for improvements to the roadmap are attached and, should the evaluation go ahead, ESWET will strive to contribute to the discussion as comprehensively and constructively as possible.
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Meeting with Astrid Ladefoged (Cabinet of Vice-President Karmenu Vella)

12 Jan 2017 · Waste to Energy

Meeting with Daniel Calleja Crespo (Director-General Environment)

6 Oct 2015 · ESWET's activities - contributing to Circular Economy