Study Finds Major Benefits to Including Incineration in EU-ETS
Published just last week (19th June), a study, carried out by CE Delft and commissioned by Zero Waste Europe and Reloop stated that including waste incineration in the EU-ETS would lead to significant emission cuts; seeing a significant drop in carbon emissions.

Published just last week (19th June), a study, carried out by CE Delft and commissioned by Zero Waste Europe and Reloop stated that including waste incineration in the EU-ETS would lead to significant emission cuts; seeing a significant drop in carbon emissions. 

The study highlighted multiple benefits of including incineration in the scheme, and also cited job creation as a major benefit, claiming that transitioning from incineration to recycling would create 8,700 to 16,400 new jobs by 2030. 

Up to 32 Million Tonnes of Carbon Cut

The analysis extends scenarios until 40 and states that adding incineration to the EU-ETS would help cut emissions by 4 – 7 million tonnes annually by 2030, rising to 18 – 32 million tonnes by 2040. Of note, an early version (2021) estimated 2.8 – 5.4 Mt by 2022, and 4.3 – 8.8 Mt by 2030, depending on whether both fossil and biogenic CO₂ are included. 

Policy Recommendations

The study also goes on to make some policy recommendations, stressing the importance of complimentary policies to maximise benefits, including: 

  • Mandatory recycled content targets (especially in plastics)
  • Wider use of Pay-As-You-Throw (PAYT) tariffs.
  • Stronger Extended Producer Responsibility (EPR) frameworks

The Real Impact on Energy from Waste

The inclusion of incineration in the Emissions Trading Scheme – both in the EU and the UK – marks a significant policy shift and we can’t ignore the impact this EU-ETS study will inevitably have on the UK EfW market, especially as the two schemes ‘link up’ in a new government deal, announced in May 2025. 

While intended to drive decarbonisation, it adds a new cost burden to the daily operation of Energy from Waste (EfW) facilities, making them more expensive to run. At the same time, it risks reinforcing negative public perception – often shaped by misinformation and misunderstanding – around the role EfW plays in a responsible, modern waste management system.

EfW facilities remain a critical part of the UK’s and Europe’s residual waste infrastructure, treating material that cannot be recycled and recovering energy in the process. By diverting this material from landfill, they help mitigate methane emissions and reduce the long-term environmental impacts associated with land contamination. 

In this context, the policy focus should not simply be on penalising incineration, but on encouraging performance improvements across the sector – recognising the contribution EfW makes in reducing landfill reliance and supporting national energy resilience.

There are practical, lower-cost pathways to cut carbon from EfW operations without undermining their economic viability. 

Reducing the volume of fossil-based plastics in the residual waste stream is one of the most effective interventions – tackling emissions at source while aligning with wider goals on extended producer responsibility and plastics reform. 

Within the plant, improving operational efficiency also offers strong returns. Combined Heat and Power (CHP), especially when connected to local district heating schemes, can significantly improve carbon performance. 

Further gains can be made through targeted upgrades – such as improved combustion control or flue gas treatment – with modest capital investment.

The UK’s approach to emissions reporting will be equally important; a consistent and transparent framework for accounting biogenic CO₂ is essential to provide operators with clarity and fairness as they prepare for inclusion in the UK-ETS by 2028.

With the right mix of policy support and technical guidance, the EfW sector can continue to evolve – offering a necessary bridge in the journey toward a low-carbon, circular economy.

In short, while the study presents a compelling case for emissions reductions, it does not fully reflect the complexity of the Energy from Waste landscape – where the environmental value, operational realities, and strategic role of EfW deserve more balanced consideration in the policy conversation.

Paul Winter
Paul Winter

Paul is the founding Director of Paul Winter Consulting which he formed in 2015. He is particularly focused on helping Clients understand the Construction Process and help them maximize their returns on investment. He has worked at senior level in Major International Companies and his experience ranges from the construction of Complex infrastructure projects from Power to airports and Roads For the last 15 years Paul has provided support to a number of clients including: - EPC Contractors - European Companies looking to enter the UK Market - Client side Project Management - Commercial and Project Management Training - Advising on Project funding He is focused on developing strategies for investment in Energy from Waste Projects and delivering the financial outcomes through effective project management

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