The study, Including incineration in the EU ETS: Assessing potential impacts on landfilling, argued that concerns over waste being diverted from Energy from Waste (EfW) facilities to landfill due to rising costs are “largely unfounded”.
The report, authored by Equanimator, found that existing regulations, infrastructure and contractual arrangements significantly constrain any move back to landfill.
Across much of the EU, landfill is already tightly restricted. In countries such as Belgium, Germany and Sweden, less than 5% of municipal waste is landfilled, reflecting long-standing bans and pre-treatment requirements.
Because of these restrictions, the report concluded there is very limited scope for waste currently sent to incineration to be diverted elsewhere, even if ETS-related costs increase.
It added that waste management systems are shaped less by short-term price signals and more by legal obligations and physical infrastructure.
Cost increases unlikely to favour landfill
Including incineration in the ETS is expected to increase operational costs, with estimates of around €35 per tonne of waste at current carbon prices.
However, the report stressed that this does not make landfill a cheaper or more attractive option in most cases.
Landfill taxes across Europe have risen significantly in recent years, in some countries reaching €60–€130 per tonne, often exceeding the expected ETS-related cost increase.
In addition, many Member States require waste to be treated before landfilling, adding further costs and limiting its use as a fallback option.
The report concluded that economic signals continue to favour better waste treatment rather than disposal.
Janek Vahk, Zero Pollution Policy Manager at ZWE, commented: “Price signals alone do not determine waste flows in Europe.
“The combination of landfill restrictions, taxes, and policy obligations means that a shift to landfill is not only expensive, but heavily restricted by Europe’s policy framework.”
Recycling expected to increase
Rather than driving waste down the hierarchy, the analysis suggested that including incineration in the ETS could accelerate a shift towards recycling.
Higher costs for fossil-based waste streams – particularly plastics – are expected to encourage improved sorting and material recovery, reducing the volume of residual waste sent to incineration.
The report noted that this aligns with EU recycling targets, which will in any case require reductions in the amount of waste being incinerated in several Member States.
Call for stronger landfill rules
To address any remaining risks, Zero Waste Europe is calling for stronger policy measures as part of the forthcoming Circular Economy Act.
Recommendations include:
- Tighter enforcement of the Landfill Directive, particularly pre-treatment requirements
- Continued use and strengthening of landfill taxes
- Policies to reduce residual waste and boost recycling
The report also highlighted the importance of aligning national rules with rulings from the Court of Justice of the European Union on waste treatment prior to landfill.
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