The prediction was made in the EfW Capacity Update, commissioned by Zero Waste Scotland on behalf of the Scottish Government, which provided an updated assessment of EfW infrastructure following the 2024 Landfill Ban Assurance Study.
The latest analysis retracted the 2024 assessment’s indication of significant overcapacity, suggested that more recent waste arisings data and revised construction plans will not lead to overcapacity.
The report estimated that Scotland could have up to 2.37 million tonnes per annum (Mtpa) of permitted EfW capacity by 2028, assuming facilities in advanced construction or with targeted commissioning dates are delivered on schedule.
However, the amount of waste that could actually be treated is expected to be lower, at around 1.96–2.08Mtpa, based on Scottish and UK average EfW utilisation rates.
As more construction is completed, the gap is expected in close by 2030.
The analysis modelled three scenarios for residual waste arisings through to 2035: Self-sufficiency, business as usual, and self-sufficiency with high recycling.
The report says the capacity surplus under the high-recycling scenario could reach around 500,000 tonnes from 2030, which would potentially be sufficient to accommodate current exports as well as provide contingency during shutdowns.
Spare capacity may not cover shutdowns
Despite the forecast closing of the capacity gap, the report warns that Scotland’s EfW fleet will have limited headroom.
It cautioned that the potential spare treatment capacity may not be available in practice because it is spread across different facilities and subject to operational, contractual and geographical constraints.
This means the available headroom is unlikely to be sufficient to cover the fleet’s planned maintenance shutdowns, with more risk when a prolonged unplanned shutdown at a large facility occurs.
Planned EfW shutdowns typically last between 14 and 21 days, with operators generally scheduling maintenance between April and October. The assessment says cumulative shutdowns could create a capacity deficit, particularly once landfill is no longer available for biodegradable municipal waste (BMW).
This could be exacerbated should the crisis with landfill capacity in England continue, reducing the amount of BMW that can come across the border.
Letsrecycle.com reported this month that multiple landfill sites across the North of England have reached capacity or otherwise closed their doors, meaning the loss of reportedly at least one million tonnes in capacity.
The Scottish Landfill Ban
The Scottish Environment Protection Agency (SEPA) announced in October 2025 that it will only enforce the Scottish landfill ban from 1 January 2028, as long as certain conditions are met.
The ban was first proposed in 2005 to come into effect in 2021 but was delayed to 2025 during the COVID-19 pandemic.
It includes paper and cardboard, glass, metals, plastics, bio-waste, wood, textiles, packaging, waste electrical and electronic equipment, waste batteries and accumulators.
It will also ban bulky waste such as mattresses and furniture, mixed waste and separately collected waste from sources other than households, where such waste is “similar in nature and composition to waste from households”.
The Scottish Government is also developing a Residual Waste Plan to 2045, due by 2027, which is expected to include an indicative EfW capacity cap as residual waste declines alongside the move towards a circular economy.
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