MEMBER ZONE
October 23, 2024

The ongoing assessment of the potential inclusion of municipal waste incineration and other waste management processes, notably landfilling, in the EU ETS

By July 2026, the Commission is due to assess and report on the feasibility of including municipal waste incineration installations in the EU ETS from 2028. To avoid creating an uneven playing field, the Commission has also been mandated to assess the possibility of including other waste management processes, such as landfilling, fermentation, composting and mechanical-biological treatment.

An impact assessment (IA) is the precondition for such a major change and must reflect the best options to tackle its CO2 in the long-term, considering both, climate and circular economy. If appropriate, the IA will then be followed by a legislative proposal, which must address the specificities of the waste sector. In this respect, FEAD notes the following points:

  • FEAD is fully committed to the EU’s decarbonisation objectives and to the decarbonisation of the waste sector. In fact, while fulfilling its main public service mission of treating waste safely, the waste management industry is already making an important contribution by avoiding the extraction, processing and use of virgin raw materials and fossil fuels, and its corresponding emissions. These avoided emissions must be accounted for, be it within the EU ETS or an alternative system.
  • In line with the above, carbon emissions should have a role, including for our sector. However, it is also important to stress that our specificity lies on the fact that waste management operators are located at the receiving end of products’ lifecycle and, as such, do not determine the nature, amount and CO2 content of the waste streams they receive for treatment. This is specifically relevant to waste incineration operators who, unlike energy producers, do not have flexibility in the choice of input. On the other hand, genuine emission reductions can be achieved by incentivising better separate collection, especially of all highly carbon-containing plastic waste, improving the energy performance of waste incineration plants and financing innovative solutions for the capture, use or sequestration of CO2.
  • The separate collection of organic waste is a low-hanging fruit that must be implemented in all municipalities across the EU as soon as possible, and which would prevent such waste from entering both landfills and waste incineration facilities.
  • In implementation of the waste hierarchy, waste flows should not be diverted from energy recovery to disposal for economic reasons, ensuring that landfills are not more competitive than waste incineration with energy recovery.
  • For the moment only waste incineration facilities are required to monitor and report their emissions under the EU ETS. As it is unclear how the emissions from landfills could be measured and monitored, the Commission must consider coming forward with an alternative and innovative mechanism addressing landfill emissions, that includes a comprehensive calculation method, without including legacy emissions derived from waste that was landfilled in the past.

Any identified option for the waste sector must ensure predictability, efficiency and avoid double taxation, while effectively incentivising the waste sector to reduce its emissions. The impact assessment must reflect the best options to tackle its CO2 emissions in the long-term, considering both, climate and circular economy, for both waste incineration and for landfilling. A level playing field across the EU and the implementation of the waste hierarchy must be equally ensured.

In view of the above, FEAD stands ready to contribute to the Impact Assessment with the knowledge and expertise of the waste sector across Europe.


FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fueling €5 billion of investments into the economy every year.