EU urged to consider moratorium on waste incinerators due to surplus capacity
28 Sep 2023 --- Zero Waste Europe (ZWE) is urging the EU to consider a moratorium on incinerators to address waste treatment capacity and steer waste management toward a more environmentally sustainable path.
“The relative advantages of incineration versus landfills are no longer as evident as they once were. This shift in perspective can be attributed to significant changes in the benefits of harnessing energy from waste. Not too long ago, it was frequently asserted that incineration would ‘replace coal-fired power generation’ or similarly carbon-intensive fuels such as oil-based heating,” Janek Vahk, Zero Pollution policy manager at ZWE, tells Packaging Insights.
“The argument that incinerators now generate energy that displaces the same environmentally harmful, carbon-intensive forms of energy they were once thought to replace holds little or no validity. Furthermore, various studies, including one funded by DG Environment, have raised questions about the prevailing belief that incinerators were vastly superior to landfills when considering their various external costs and benefits.”
The policy manager details that while it wasn’t always evident that incineration had a more adverse environmental impact, no study has concluded that the economic cost disparity between landfilling and incineration justifies the difference in benefits.
The report highlights a consistent annual increase of approximately 8 million metric tons in waste incineration capacity within the EU from 2004 to 2020. In 2020 alone, 60 million metric tons of additional waste incineration capacity remained unused. By 2023, the total capacity may reach approximately 220 million metric tons.
The study carried out by Equanimator for ZWE recommends careful coordination of any planned decommissioning, stating: “Those member states where excess capacity already exists should consider imposing moratoria, and managing a reduction in capacity.”
ZWE report suggests that 5% of incinerators could be decommissioned annually to address the surplus capacity issue.Reevaluating the waste hierarchy
The report, titled “Enough Is Enough: The case for a moratorium on incineration,” emphasizes the need for a coordinated effort at EU level to confront the growing issue of excess incineration capacity.
“To enact substantial change, we need to shift our focus from merely transferring waste from landfills to incineration and instead tackle the core problem of residual waste generation. We must set precise targets to curtail residual waste production and introduce penalties for incineration,” stresses Vahk.
“Currently, our regulatory framework strongly penalizes landfilling, while incineration largely operates without significant restrictions. A prudent initial step involves mandating waste sorting before energy recovery (and disposal). This should be complemented by economic incentives, such as CO2 taxes, which discourage waste incineration, especially when it involves fossil-derived materials. ”
ZWE’s report calls for reevaluating incineration’s role in the waste hierarchy, with potential reclassification as a disposal operation. The report suggests that 5% of incinerators could be decommissioned annually to address the surplus capacity issue. However, it points out a significant challenge in downsizing incineration capacity, which arises from its “privileged position” within the waste hierarchy.
This hierarchy determines the order of preference for waste management methods, and the report argues that this preference is currently largely “ideological.”
“The optimal timing for retiring incinerators typically aligns with the end of their intended lifespan, usually around 20 years. A critical decision must be made at this juncture – either invest a substantial sum in modernizing the facility or proceed with its decommissioning,” says Vahk.
“Research indicates that altering waste management practices can yield substantial climate change advantages. The primary benefits arise from waste prevention and recycling, especially with dry materials. In the realm of residual waste treatment and disposal, these practices tend to contribute to climate change emissions rather than aiding in overall emissions reduction. Transitioning from landfill to incineration yields no discernible benefits, if at all.” 
The report highlights a consistent annual increase of approximately 8 million metric tons in waste incineration capacity within the EU from 2004 to 2020.
Optimal timing for incinerator retirement
As of December 2024, the Waste Framework Directive mandates an assessment of disposal operations, offering an opportunity to revisit incineration’s role in the waste hierarchy and tackle overcapacity concerns. Vahk states, “The call for change is louder than ever – incineration must be reclassified as a disposal operation, with strict criteria for treating municipal waste.”
Coordinated efforts among member states are deemed essential to tackle these challenges and establish environmentally responsible waste management practices. ZWE underscores that urgent EU-level coordination is imperative to confront the mounting incineration capacity problem and ensure responsible waste management practices.
“This seems to be the right moment, particularly before constructing additional capacity, to affirm the similarity between landfilling and incineration. This classification should be applicable when waste has undergone mixed waste sorting, and landfill-bound waste has met minimum stability criteria,” Vahk tells us.
“By ending the practice of landfilling untreated waste and placing both incineration and landfilling of properly pre-treated waste in the same lowest tier of the waste hierarchy, we can offer member states more flexibility in pursuing higher recycling rates. This shift can also expedite progress toward climate mitigation, especially in regions where landfilling mixed waste remains a significant challenge.”
By Radhika Sikaria
