FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the EU's environmental taxonomy and the EU's ambition to drive investment to achieve its climate and environmental goals.
The EU is at the forefront of the global fight against climate change and has the most ambitious environmental legislation. FEAD fully supports these goals and is actively committed to its daily actions to achieve a sustainable economy by sustaining the transition to a circular and climate neutral economy. We therefore believe that, as we are already moving away from the highest global standards, the requirements of the EU taxonomy, which must be ambitious to achieve their purpose, must also be achievable in order to create a real incentive for industry to further improve its performance and not exclude precisely those activities where investments are mostly needed to make a significant contribution to the EU's objectives.
The waste management sector is not only inherently at the heart of the circular economy, but also plays an important role in the EU's decarbonisation and pollution removal, as well as in its energy and strategic independence. The sector's substantial contribution to the various objectives of the EU taxonomy must be fully recognised throughout the waste management chain.
As regards the activities to be included in future delegated acts of the Taxonomy Regulation, the energy recovery of residual waste that cannot be recycled (waste to energy and SRF production and use) should be included. Waste-to-energy plays a crucial role in the cycle as it moves up the waste hierarchy and is a key complement to increased recycling.
Energy recovery activities are not a competitor or alternative to recycling, but a complementary process that ensures the safe management of non-recyclable residual waste, whether of municipal or industrial and commercial origin, including residues from recycling operations. In addition, waste-to-energy facilities provide energy in the form of electricity and heat (both for district heating and industry), which brings CO2 savings compared to electricity generated by burning fossil fuels and allows us to diversify our energy supply (especially in terms of district heating and cooling networks), which at the same time accelerates the deployment of renewable energies. Finally, waste-to-energy plants also have the potential to produce hydrogen and e-fuels. Through CCUS technologies, CO2 emissions can be stored or even used in other applications, thus further contributing to decarbonisation.
A study on the potential for CO2 savings in the waste management sector shows that the key to achieving maximum CO2 reductions is to make full use of recycling and energy recovery capacities across the EU27 and the UK. In addition to energy production, waste-to-energy enables the recovery of metals and inert materials from ash, 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 continued phasing out of coal; otherwise gypsum would have to be extracted by mining natural gypsum, leading to serious impacts on nature and the environment. This shows that waste-to-energy keeps resources in circulation for as long as possible, thereby reducing the consumption of primary raw materials through energy and resource recovery. This issue is also very rightly highlighted in recital 14 of the delegated Environment Bill. The current stringent and legally binding requirements for emission control and energy efficiency ensure that these facilities operate in full compliance with European legislation.
From a legal point of view, a clear distinction should be made between incineration and waste-to-energy activities. The former is a disposal activity and the latter a recovery activity (R1), which as such falls under different parts of the waste hierarchy. For these reasons, energy recovery from residual non-hazardous waste should be fully recognised in the dedicated part as an activity contributing significantly to the (transition to) circular economy, provided that the following conditions are cumulatively and consistently met:
There is a waste management plan in place to ensure overcapacity and ensure compliance with the waste hierarchy;
Only residual waste from selective collection or sorting shall be subject to energy recovery according to formula R1;
The feasibility of CCS/CCU is being investigated.
More information on the FEAD website.
