Zero Waste Europe criticizes EC’s proposal to exclude waste-to-energy from ETS reform

15 Jul 2021 --- Zero Waste Europe is scrutinizing the European Commission’s proposal for the reform of the EU Emissions Trading System (ETS) regulation because it leaves municipal waste-to-energy (WTE) incinerators out of the scope.

“If you phased out coal, WTE is the most CO2-intensive energy form,” Janek Vähk, climate, energy and air pollution program coordinator at Zero Waste Europe, tells PackagingInsights. 

Research by Client Earth stresses electricity-only incinerators are a more carbon-intensive form of electricity generation than the current marginal grid average.

Meanwhile, a 2020 report from Zero Waste Scotland maintains WTE can no longer be considered a source of low carbon energy within a UK and Scottish context.

Zero Waste Europe flags CO2 released by municipal incinerators can result in an annual unpaid cost to society of around €1.3 billion (US$1.5 billion), whereas sorting materials from residual waste could save 0.73 billion metric tons of CO2 globally.

The Commission responds
Commenting on Zero Waste Europe’s criticism, a European Commission official tells PackagingInsights emissions from the waste sector will remain covered by the Effort Sharing Regulation. 

“Although at this stage, the Commission’s proposal does not provide for including waste incineration in the existing ETS, the Green Deal already puts forward a policy framework and dedicated initiatives to promote economic circularity,” says the official. 

They highlight the EU Industry Strategy, Circular Economy Action Plan and the European Battery Alliance “to name just a few.” 

The EC has released its proposal for the ETS reform, leaving municipal waste-to-energy incinerators out of scope.ETS details
The ETS addresses the EU’s 2050 climate neutrality goal and its intermediate goal of reducing net greenhouse gas (GHG) emissions by at least 55 percent by 2030. 

The regulation works on the “cap and trade” principle: gradually lowered over time, a cap limits the total amount of certain GHGs that can be emitted. Corporations buy or receive emissions allowances, which they can trade with one another as needed. Heavy fines are imposed if companies do not cover their emissions with their allowances.

The latest legislative revision focuses on:

• Increasing the pace of annual cap reduction to 2.2 percent as of 2021.
• Reinforcing the Market Stability Reserve – an EU mechanism that reduces emission allowance surpluses in the carbon market and improves the EU ETS’s resilience to future shocks.
• Continuing the free allocation of allowances as a safeguard for the international competitiveness of industrial sectors at risk of carbon leakage.
• Financially supporting low-carbon transition initiatives.

The argument to include municipal incinerators
Although emissions from waste incineration are already included in the ETS, municipal solid waste (MSW) incineration plants are currently exempted. This leaves over 500 waste incineration plants in Europe with no obligation to address their adverse climate change impact. 

According to a Zero Waste Europe study, MSW incinerators emitted over 95 million metric tons of CO2 in 2018 alone. Furthermore, the electricity produced by MSW plants is more carbon-intensive (around 504 gCO2e/kWh) than electricity generated through the conventional use of fossil fuels.

The organization highlights several benefits of including WTE into ETS and increasing the costs for MSW incineration:

• Correcting the “unfair” competition with other energy producers, especially those using renewable sources such as wind and solar energy. 
• Encouraging better and more climate-friendly waste management methods, such as improving separate collection, sorting and recycling, and incentivizing waste providers to decrease the share of waste sent to incineration. 
• Stronger moves toward greater Extended Producer Responsibility, making those producing non-recyclable and hard-to-recycle products pay more of the climate change costs of their design decisions.
• Incentivizing waste providers to further recover materials from the residual waste stream.
• Improving local air quality.

Thoughts on chemical recycling
Increasing municipal incineration costs could have numerous environmental and socioeconomic benefits. Next to purification and depolymerization, WTE, also known as thermal conversion, is one of the three main chemical recycling technologies. Page 28 of the June edition of The World of Food Ingredients covers nascent chemical recycling technologies in detail.

Rabobank predicts advanced recycling plants will double to around 140 plants globally by 2025 as regulatory and public demand for recycled plastics packaging drives “huge” investment.

Despite this industry growth, Zero Waste Europe sees chemical recycling as inferior to its mechanical counterpart due to its greater environmental impact. 

“We need a strong push toward a truly circular design that prepares plastics for reuse and recycling, according to the most environmentally sound options and avoids carbon-intensive treatments, such as pyrolysis and gasification,” says Vähk.

“Allowing currently unrecyclable plastics to be treated via these energy-intensive technologies instead of being redesigned for mechanical recycling would mean trapping ourselves into an expensive and high-carbon lock-in situation.” 

Mixed waste sorting moves
If not chemical recycling, what approach should industry take to effective waste management? Research from Eunomia says residual waste sorting will “always be necessary” to meet climate mitigation demands. 

“They say holistic resource systems always include mixed waste sorting as a fundamental pillar in maximizing recycling rates and GHG benefits. Mixed waste sorting powerfully enables the recycling of packaging not captured in deposit return schemes and separate collections effectively and with equal yield quality,” Vähk explains.

Tomra’s white paper “Holistic resource systems” states that mixed waste sorting can capture more than double the amount of plastic in comparison with separate collections.

Reusable packaging support
Despite varying views on environmental-forward recycling technologies, Zero Waste Europe maintains Europe must prioritize the move toward reusable packaging, one of Innova Market Insights’ top packaging trends for 2021.

Vähk observes plastics are “not very circular materials,” necessitating the establishment of reuse systems. 

“While we are working on designing plastics for real recycling, we could use the downcycling as an option to deal with the current waste. We should avoid burning plastics as we can’t continue to emit CO2 into the atmosphere.”

By Anni Schleicher