May 3, 2023

FEAD calls for recognition of Waste-to-Energy activities in the EU Environmental Taxonomy for Sustainable Investments

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the EU environmental taxonomy and the EU’s ambition to steer investments to achieve its climate and environmental goals.

The EU is at the global forefront of the fight against climate change and most ambitious environmental legislations. FEAD fully supports these objectives and actively commits on its daily activities to achieve a sustainable economy by sustaining the transition towards a circular and climate neutral economy. We therefore believe that, as we already part from the globally highest standards, requirements under the EU Taxonomy, which must be ambitious to achieve its purpose, must also be achievable to create a real incentive for the industry to further improve its performance, and to not precisely exclude those activities where investments are mostly needed to make substantial contributions to the EU objectives.

The waste management sector is not only intrinsically at the core of the circular economy but has also an important role to play in the decarbonisation and depollution of the EU, as well as in its energy and strategic independence. The substantial contribution of the sector to the different EU Taxonomy objectives must be fully recognised along the whole waste management chain.

Concerning activities to be included in the Delegated Acts to the Taxonomy Regulation in the future, the energy recovery of residual waste that cannot be recycled (waste-to-energy and SRF production and use) should be covered. Waste-to-energy plays an essential role in circularity, as it moves up the waste hierarchy and is a key complement to more recycling.

Waste-to-energy activities are not a competitor nor an alternative to recycling, but a complementary process that ensures safe treatment of non-recyclable residual waste, be it from municipal or from industrial and commercial origin, including residues from recycling operations. In addition, waste-to-energy plants supply energy in the form of electricity and heat (to both district heating and industries), which entails CO2 savings compared to electricity produced by fossil fuel combustion and allows to diversify our energy supply (in particular with regards to district heating and cooling networks), accelerating simultaneously the roll out of renewable energies. Finally, waste to energy plants have also the potential to produce hydrogen and e-fuels. Through CCUS technologies, CO2 emissions can be either stored or even utilised in other applications and so contribute further to decarbonisation.

A study on the CO2 saving potential of the waste management sector shows that the key to achieving maximum CO2 avoidance is to make full use of recycling and waste-to-energy capacities throughout EU27 and the UK. Besides the production of energy, waste-to-energy enables the recovery of metals and inert materials from bottom ashes as well as the recovery of gypsum from flue gas cleaning. The production of gypsum from flue gas cleaning is becoming increasingly scarce due to the ongoing phase-out of coal; otherwise, gypsum would have to be extracted by mining natural gypsum, which would lead to serious impacts on nature and the environment. This shows that waste-to-energy keeps resources in the cycle as long as possible, thus reducing the use of primary raw materials through energy and resource recovery. This issue is also very rightly emphasised in Recital 14 of the draft Environmental Delegated Act. The current stringent and legally binding requirements for emissions control and energy efficiency, ensure that these plants operate in full alignment with European legislation.

From a legal perspective, a clear distinction should be made between incineration and waste-to-energy activities. The first one is a disposal activity and the latter one a waste recovery activity (R1), falling as such, under different sections of the waste hierarchy. For these reasons, energy recovery from residual non-hazardous waste should be fully recognised in a dedicated section as an activity substantially contributing to (a transition to) a circular economy, provided that the following conditions are cumulatively and rigorously met:

  • There is waste management plan in the given country to ensure there is no overcapacity and to ensure alignment with the waste hierarchy;
  • Only residual waste, resulting from selective collection or sorting, is subject to energy recovery under application of the R1 Formula;
  • The CCS/CCU feasibility is examined

Please see our feedback to the activities covered in the proposed draft in the tables below. For more information, please contact:

FEAD Secretariat

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, fuelling €5 billion of investments into the economy every year. For more information, please contact: