“ZWE on the RED agreement: moving towards the right direction on waste, but there is still room to manoeuvre”


30 Mar 2023


Zero Waste Europe (ZWE) acknowledges the decisions taken today by the Council and the European Parliament to reach a provisional political agreement on the revision of the Renewable Energy Directive (RED)

For ZWE, while this decision will help accelerate the renewable energy production in Europe, we regret that several amendments proposed by the European Parliament to exclude the use of hybrid sources such as mixed waste and Recycled Carbon Fuels (RCFs) for renewable energy generation were watered down.

Support schemes and Mixed Waste Sorting

The parties agreed that Member States should make renewable energy support to waste incineration conditional on the implementation of separate collection obligations (1). Member States could also require that operators apply mixed waste sorting systems to remove fossil materials prior to incineration (2). 

Janek Vahk, ZWE’s Climate, Energy, and Air Pollution Programme Coordinator states: “While the parties failed to make mixed waste sorting requirements mandatory, this is a step forward. It now depends on Member States to make sure that this requirement is fully implemented”.

ZWE and Reloop recently published a guidance on how to legislate mixed waste sorting in the context of the Renewable Energy Directive. The document recommends applying MWS systems of defined quality to remove fossil-derived materials to ensure that only biogenic waste is used for renewable energy generation. Following the requirement, the operators would either need to pre-sort the waste on-site or demonstrate that all waste received has undergone sorting prior to it being delivered for incineration.

Recycled Carbon Fuels (RCFs) 

Final agreement on the methodology assessing greenhouse gas emissions savings from RCFs – i.e. potentially plastic based fuels – considers the specific case of waste. It considers emissions associated with the company’s consumption to produce recycled carbon fuels, which would have not happened in more established end-of-life treatment of waste (3). 

Lauriane Veillard, ZWE’s Policy Officer on Chemical Recycling and Plastic-to-Fuels: “Despite the rightly emphasise put on waste in the final wording, the reached agreement falls short as it considers the “avoided emissions from inputs’ existing use”, which were removed from the European Parliament’s position adopted in July.”

Recognising the “avoided emissions from inputs’ existing use” would have allowed accounting for all emissions related to the production of waste-based RCF. The use of the concept of “avoided emissions” is a theoretical way to reduce the climate impact of practices by comparing the scenario with the one with the most emissions. In the current case, with the incineration of waste. A recent study on plastic-to-fuels shows that plastic-derived fuels produce high exhaust emissions compared to diesel.

The political agreement reached today is provisional pending formal endorsement by the Parliament and then the Council, after which they will be published in the EU’s Official Journal and enter into force. 


Notes for editors:

Wording agreed in the RED III:

  1. Support schemes (Art 3)

“The production of renewable energy produced from the incineration of waste if the separate collection obligations laid down in Directive 2008/98/EC have not been complied with.”

      2. Mixed waste sorting (Art 19)

“However, biofuels, bioliquids and biomass fuels produced from waste and residues, other than agricultural, aquaculture, fisheries and forestry residues, are required to fulfil only the greenhouse gas emissions saving criteria laid down in paragraph 10 in order to be taken into account for the purposes referred to in points (a), (b) and (c) of the first subparagraph. In the case of the use of mixed wastes, Member States may require operators to apply mixed waste sorting systems aimed at removing fossil materials. This subparagraph shall also apply to waste and residues that are first processed into a product before being further processed into biofuels, bioliquids and biomass fuels.”

3. Recycled Carbon Fuels (Art 29 a) 

“The Commission is empowered to adopt delegated acts in accordance with Article 35 to  supplement this Directive by specifying the methodology for assessing greenhouse gas emissions savings from renewable fuels of non-biological origin and from recycled carbon fuels. The methodology shall ensure that credit for avoided emissions is not given for CO2 the capture of which has already received an emission credit under other provisions of law. The methodology shall cover the life-cycle greenhouse gas emissions and consider indirect emissions resulting from the diversion of rigid inputs such as wastes used for the production of recycled carbon fuels.”