Including incineration in the EU ETS will not drive more landfilling, new report finds

Brussels, 16 April 2026 – Including waste incineration in the EU Emissions Trading System (EU ETS) is unlikely to lead to an increase in landfilling across Europe, according to a new report from the environmental network Zero Waste Europe (ZWE).

The report, “Including incineration in the EU ETS: Assessing potential impacts on landfilling”, finds that concerns about waste shifting from incineration to landfill due to higher costs are largely unfounded. Instead, the analysis shows that existing EU policies, national regulations, and market structures will continue to limit landfill use and support better waste management outcomes.

In short, the report finds:

• No significant shift to landfill expected, as regulatory restrictions, landfill bans, and long-term contracts mean waste systems cannot easily switch from incineration to landfill.
• Landfill use is already tightly constrained, for example,  in Member States like Belgium, Germany and Sweden, where less than 5% of municipal waste is landfilled. This leaves very little room for diversion.
• Economic signals favour better treatment, not disposal. Landfill taxes and mandatory pre-treatment requirements make landfilling more expensive than incineration in most cases, even with added carbon costs.
• As recycling is likely to increase, higher costs for fossil-based waste streams (notably plastics) will create incentives for improved sorting and recycling rather than disposal.
• Risks are limited and localised. Only a small number of countries with low landfill costs and weaker enforcement may face marginal risks of diversion.

The report, written by Equanimator Ltd., highlights that waste management decisions are shaped less by short-term price changes and more by infrastructure, legal frameworks, and contractual obligations.

According to Janek Vahk, Zero Pollution Policy Manager at Zero Waste Europe: “Price signals alone do not determine waste flows in Europe.” He adds: “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”

The study also underlines the climate importance of avoiding landfill. Landfills remain a major source of methane emissions, a potent greenhouse gas, reinforcing the need for strict enforcement of EU waste legislation. Based on the report’s findings, the organisation concludes that including incineration in the EU ETS would support, rather than undermine, Europe’s waste hierarchy, provided that existing legislation is properly implemented.

To address the remaining risks of landfilling, Zero Waste Europe recommends that the following measures be included in the Circular Economy Act:

• Stronger enforcement of the Landfill Directive, particularly pre-treatment requirements;
• Continued use and strengthening of landfill taxes;
• Policies to reduce residual waste and boost recycling.

ENDS

Notes to the editor

• Read the full report here.

Further reading

• Waste incineration under the EU ETS – an assessment of climate benefits (2025 update)
• Incineration in the EU emission trading system: a set of suggestions for its inclusion
• Inclusion of waste incinerators under the EU ETS and its impact on waste management fees

Press contacts

Nanna Bille Cornelsen, Communications Officer at Zero Waste Europe – [email protected] or [email protected]

Janek Vähk, Zero Pollution Policy Manager at Zero Waste Europe – [email protected]

About Zero Waste Europe

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards a better use of resources and the elimination of waste in our society. We advocate for sustainable systems; for the redesign of our relationship with resources; and for a global shift towards environmental justice, accelerating a just transition towards zero waste for the benefit of people and the planet. www.zerowasteeurope.eu