Incineration Bottom Ash (IBA): Recommendations for EU-level regulation

Incineration bottom ash (IBA) is one of the largest waste streams generated by municipal waste incineration in Europe, yet its use in construction and civil engineering remains largely unregulated at the EU level. This policy brief outlines a science-based framework for harmonised EU rules governing IBA, including binding limits for heavy metals, dioxins, PFAS, PAHs and microplastics, as well as requirements for ecotoxicity testing and environmental monitoring.

The recommendations aim to close existing regulatory gaps, protect human health and the environment, and ensure that any use of IBA in the circular economy is subject to robust precautionary safeguards.

Briefing is available in English. 

A toxic legacy: Bottom ash in Europe’s circular economy

Our latest report, “A toxic legacy: Bottom ash in Europe’s circular economy”, exposes the environmental and health risks linked to the growing use of incinerator bottom ash (IBA) in construction materials across Europe. The report finds that IBA contains hazardous substances, including heavy metals, PFAS (“forever chemicals”), persistent organic pollutants (POPs), and microplastics, which can leach into soil and water over time. It warns that promoting IBA as a “circular” material risks spreading pollution, locking Europe into waste incineration, and undermining the transition to a truly non-toxic circular economy.

Drawing on evidence from across Europe, the report calls for stronger EU rules, precautionary approaches, and policies that prioritise waste prevention and safe material management.

Full report and executive summary available in English, and Spanish.

Joint statement calling for a precautionary approach to incineration residues

A coalition of European civil society organisations call on the European Commission not to recognise incineration residues, particularly incinerator bottom ash (IBA), as circular materials due to their hazardous contents. The 44 signatories highlight the potential dangers of these materials, which could have adverse effects on both human health and the environment.

They therefore strongly discourage the use of incineration residues in construction and civil engineering, and urge the European Commission to ensure the Circular Economy Act (CEA) is non-toxic by design.

Available in English.

Economic impacts of O3 exposure

Air quality is a key social, economic and environmental factor within the EU, as pollutants such as ground-level ozone (O₃) have significant impacts on human health, the environment and public costs. This new report, commissioned by the Methane Matters coalition, analyses the health and environmental effects of ozone exposure across the EU and selected Member States, based on the best available data from 2022. It also examines the role of methane (CH₄) in ozone formation and assesses the extent to which methane mitigation could help reduce ozone concentrations.

The findings show that ozone limit values continue to be exceeded in many regions of the EU, highlighting the need for complex, cross-sectoral policy measures. Overall, the report provides a robust evidence base to support policy action to improve air quality and protect human health and ecosystems.

Available in English.

End of Waste Criteria to achieve a Toxic-Free Circular Economy in the EU

Zero Waste Europe and the Rethink Plastic alliance have identified key principles and safeguards for clear, consistent, and enforceable end-of-waste (EoW) criteria, anchored in protecting human health and the environment.

The development of EoW criteria is a tool to support the transition towards the circular economy by developing a new recycling market at the European level and harmonising the different approaches among Member States.

Driven by the need for transparency, traceability, clarity, enforceability, and non-toxicity, this report outlines the general rules for EoW, with two specific sections on plastics and textiles.

Available in English.

Building a healthy circular economy: Integrating chemicals, products, and waste under the Circular Economy Act

Our society is continuously, and often unknowingly, exposed to a low-level mixture of harmful chemicals – a problem that remains both underestimated and largely unaddressed. This policy briefing highlights the clear health and economic consequences of the European Union’s (EU) lax toxic-chemical policies, and proposes that these be strengthened in the upcoming Circular Economy Act (CEA).

The CEA would thus serve as a guiding compass to drive resilient economies and strategic use of the EU’s resources, while ensuring a safe and toxic-free transition for workers, small and medium enterprises (SMEs), and citizens. A CEA with stringent toxic-chemical policies would allow the EU to harness circularity and competitiveness to better protect its citizens, and prevent a future public health crisis.

Available in English.

Call for a moratorium on new waste incineration in the EU

156 civil society organisations have issued a joint letter to President Ursula von der Leyen, EU Commissioners, and national ministers calling for an immediate moratorium on approving and building new waste incineration facilities across the European Union (EU).

Led by the Zero Waste Europe network, this coalition is calling for:

– An EU-wide moratorium on new waste incinerators (R1 and D10);

Phase-down strategies for existing incineration capacity;

Increased investment in circular economy infrastructure, such as reuse systems, composting, and recycling technologies.

The letter was sent as part of today’s wider Day of Action Against Incineration of the ‘’Better than Burning’’ campaign, which includes a Manifesto and social media testimonials on the harmful impact of waste incineration in their countries.

Available in English and Hungarian.

PFAS, Dioxins and PAH in Primary School Air Filters Ivry-sur-Seine (suburb of Paris, France), 2024-2025

The latest biomonitoring report by ToxicoWatch shows that air filters in schools in Ivry-Sur-Seine (Paris) contained PFAS, dioxins, and other dangerous chemicals linked to areas in close vicinity of waste incinerators.

The biomonitoring research in Ivry-Sur-Seine found dioxins in school filters and dust; dixion-like PCBs which were legally banned decades ago; and PAHs, a chemical also found in cigarette smoke. It also found levels of PFAs in air filter dust exponentially above the EU safety limits.

The report underlines the findings of previous biomonitoring reports carried out in communities near waste incinerators across Europe (see The True Toxic Toll page), showing that waste incineration emissions contaminate nearby air, water, and vegetation – putting human health and the environment at risk.

Available in English and French.

Response to the consultation | Single-use plastic beverage bottles – EU rules for calculating, verifying and reporting on recycled plastic content

The EU Circular Economy Act: a key opportunity for sustainable resource use, long-term competitiveness, and strategic resilience

The joint statement is a collaborative effort by seven prominent European civil society organisations: Cambridge Institute for Sustainability Leadership (CISL), Ellen MacArthur Foundation, Environment Coalition on Standards (ECOS), European Environmental Bureau (EEB), Institute for European Environmental Policy (IEEP)Reuse and Recycling European Union Social Enterprises (RREUSE), and Zero Waste Europe. The statement aims to ensure that the Circular Economy Act fully embeds circular economy principles in Europe’s entire economic system.

The statement reinforces the role of the circular economy as key for the EU to reach its three main priorities: competitiveness, strategic resilience, and decarbonisation. It urges the European Commission to ensure that the upcoming EU Circular Economy Act delivers an ambitious, systemic shift in how Europe manages its material use, specifically with:

– Setting science-based targets on resource use.

– Harnessing the potential of keeping products and components in use, not just materials.

– Accelerating safe material circulation by integrating chemical and circular economy legislation.

Available in English.

The True Toxic Toll – Biomonitoring report in Zubieta, Spain

This biomonitoring report by ToxicoWatch and supported by Zero Waste Europe reveals dangerously high levels of dioxins, PFAS, and heavy metals around the Zubieta Waste-to-Energy incinerator in Spain. Samples from backyard eggs, moss, soil, and water show widespread contamination, with one egg recording the highest dioxin levels in Europe in over a decade. The findings raise serious concerns about ongoing emissions and call for urgent action to protect environmental and public health.

Available in English.

The True Toxic Toll – Biomonitoring report in Paris, France

This biomonitoring report by ToxicoWatch, supported by Zero Waste Europe and Collectif 3R, reveals high levels of dioxins, PFAS, and heavy metals in vegetation, moss, and soil around the Ivry-sur-Seine incinerator in Paris. Samples taken from schools and public areas show widespread contamination, with some dioxin levels exceeding EU safety limits. These findings align with earlier public health alerts and underline the urgent need for tighter emission controls and environmental monitoring across urban incineration zones.

Available in English and Croatian.

The True Toxic Toll – Biomonitoring report in Harlingen, The Netherlands

This biomonitoring report by ToxicoWatch’s, supported by Zero Waste Europe, uncovers worrying levels of dioxins, PFAS, and heavy metals near the Harlingen Waste-to-Energy incinerator. Backyard chicken eggs, soil, moss, and water samples show significant contamination—PFAS levels in ditch water were 138 times above Dutch drinking water limits, and dioxins in eggs exceeded EU thresholds. These findings, spanning over a decade of research, highlight the urgent need to investigate pollution sources and resume continuous emissions monitoring at the REC facility.

Available in English.

Circular Economy Act policy recommendations

The European Union stands at a critical juncture. With six planetary boundaries already breached and a rapidly shifting global economy, the Circular Economy Act (CEA) should serve as a guiding compass to drive how we consume and produce differently, how we empower communities, and build resilient economies through job creation in circular sectors. It must promote value preservation and ensure the strategic use of our resources, while ensuring a safe and toxic-free transition for workers, SMEs, and citizens.

Ahead of the European Commission’s publication of the Clean Industrial Deal (CID), Zero Waste Europe presents its position paper laying out the vision for the CEA: more than a technical fix to the waste crisis, it should serve as a guiding compass within a broader industrial strategy.

Available in English.

Executive summary available in English, Portuguese, Croatian, German, and Greek.

The True Toxic Toll – 2nd biomonitoring report in Turna na Bodvou, Slovakia

This report presents the findings of the second phase of a multi-year biomonitoring study (2023–2025) conducted in 8-11 May, 2024.
The research focuses on the deposition of persistent organic pollutants (POPs), including dioxins (PCDD/F/dl-PCB), Polycyclic Aromatic Hydrocarbons (PAHs), PFAS, and heavy metals (HM), in the vicinity of the Cementáreň Turňa nad Bodvou cement plant in the Košice Region of Slovakia.
By assessing pollution levels, this study provides critical data to address environmental and public health impacts in the area.
Available in English.

Safety of food contact materials: 20 years of inaction on EU’s basic rules

In this open letter issued to European Commission President Ursula von der Leyen, Zero Waste Europe and 50+ organisations call for immediate revision of the Food Contact Materials (FCM) Regulation.

The letter highlights critical health risks from harmful chemicals in food packaging, including over 70 carcinogens and endocrine disruptors, and demands a comprehensive update to EU regulations within the current legislative term.

With an estimated €157 billion annual cost from chemical exposure and rising health concerns, the organisations urge for robust safety standards that protect consumers, particularly vulnerable populations like children and pregnant women.

Available in English.

For an ambitious EU mandate embracing a holistic vision on circular economy – joint open letter to MEPs

In this open letter to Members of the European Parliament ahead of the hearings of EU Commissioner-designate candidates, a group of NGOs, EU organisations, and sustainable businesses calls out for stronger circular economy policies in Europe.

With the EU’s Circular Material Use Rate showing minimal improvement over the past decade, the letter asks for rigorous questioning of EU Commissioner-designate candidates on twelve critical areas, including binding resource reduction targets, improved Extended Producer Responsibility frameworks, a healthy circular economy, and circular taxation systems.

Available in English.